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Daniel S.Greenbaum / I
Commissioner S/O,a
Gilbert T.Joly oLa��erRc , Au zdJac��0,9g47"
Regional Director
(O,f) 9J17=M3 &xt Off-6V
CORI
December 21, 1988
Gary Stumpf RE: BARNSTABLE--OIR/SA 4-214
Mobil Oil Corporation Mobil Service Station
3225 Gallows Road 1149 Route 132 .
Fairfax, Virginia 22037-0001 Request for Information
M.G.L. Chapter 21E
Dear Mr. Stumpf:
The Department of Environmental Quality Engineering has received your letter
of November 3, 1988, and attached records of data collected at the site during
1988.
Additional information is required by the Department relative to the site.
Pursuant to the Department's authority to perform information gathering
activities and its authority to investigate, sample and inspect records,
conditions, equipment, practices or property under M.G.L. Chapter 21E Sections
2, 4 and 8, you are directed to provide the Department, within fifteen (15)
days of receipt of this letter, with the following information and records:
1. Results of all soil vapor testing at the site conducted by
Neet, Inc. ;
2. All records of product volume recovered and removed from the
site;
3. All correspondence between Mobil and Zecco, Inc. regarding
environmental conditions and releases of gasoline at the site;
4. Results of all gasoline storage tank and product line testing
ever completed at the site; and
5. All records of repairs made to gasoline dispensing equipment at
the site including but not limited to repairs to underground
storage tanks, lines and pumps.
You are hereby notified that failure to respond to this request may subject
you to legal action including criminal prosecution, court imposed civil penalties,
administrative orders or civil administrative penalties assessed by the Department.
:r
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Your response to this request for information must be sent to James Begley
of this office.
Very truly yours,
Christophe Tilden, P.E., Chief
Hazardous Waste Section
T/JB/kan
CERTIFIED MAIL NO. P 893 314 401
RETURN RECEIPT REQUESTED
cc: Office of Incident Response
Boston, MA
Board of Health
Town Hall
Hyannis, MA 02601
Barnstable Fire Dept.
93 High School Road Ext.
Hyannis, MA, 02601
ATTN: Chief Richard Rarrenkoff
Zecco, Inc.
345 Main Street
Northboro, MA 01532
L. Miller
Mobil Oil Corporation
3225 Gallows Road
Fairfax, Virginia 22037-0001
T. Valenti
Mobil Oil Corp.
508 Chelsea Street
E. Boston, MA 02125
Arlene Barrios
Mobil Oil Corp.
508 Chelsea Street
E. Boston, MA 02125
I
7
al/P�?,C�l4��iZPJ2�i��/Z(f�Cl�i2/74:�?/Z.�i V/?.Q.Cl?.eP,/GUZC�i
Daniel S.Greenbaum
Commissioner Jacc��iP.adC c�
Gilbert T.Joly Xv4 u& &kaA, �✓�,creeac/uce�OU-47
Regional Director
(S&)f B.,7 teg1, &t 6TC-6,P-1
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1... + ;• ; January 18, 1989
Gary Stumpf RE: BARNSTABLE--OIR/SA 4-214, Mobil
Mobil Oil Corporation Service Station, Route 132, M.G.L.,
3225 Gallows Road Chapter 21 E, Short Term Measures,
Fairfax, Virginia 22037-0001 Phase II Requirements
Dear Mr. Stumpf:
1-be Department of Environmental Quality Engineering has reviewed available
information regarding the above-referenced site including information submitted with
your letter of November 3, 1988.
Please be advised that the Department has classified the site as a Priority
Disposal Site according to the Massachusetts Contingency Plan (MCP) 310 CM11 40.544:
Interim Disposal Site Classification System.
The MCP (310 CMR 40.000) took effect on October 3, 1988. On July 1, 1986, the
Department first notified Mobil Oil Corporation (Mobil) of their responsibility to
conduct site assessment activities and remedial actions at the site in accordance with
M.G.L., Chapter 21E, the "Massachusetts Oil and Hazardous Material Release, Prevention
and Response Act." The Notice of Responsibility was sent to Mobil following the
discovery of a product line leak prior to May 30, 1986.
As Regulations promulgated pursuant to Chapter 21E, the MCP is designed to ensure
the protection of health, safety, public welfare and the environment by establishing
requirements and procedures for a comprehensive response to releases and threats of
release of oil or hazardous materials. As a responsible party, Mobil is required to
perform response actions in accordance with M.G.L., Chapter 21E and the MCP.
Currently the site is considered to be in Phase II - Comprehensive Site Assessment
(310 CMR 40.545) of the MCP and a Short Term Measure (310 CMR 40.542) , in the form of a
product recovery/ground water pump and treatment system, is being conducted at the site.
In October, 1988, -representatives of the Department discovered that .an additional
release of gasoline had occurred at the site resulting in an accumulation of free
gasoline in the subsurface at the water table.
In your letter of November 3, 1988, you indicated Mobil's intention to install
an additional product recovery system southwest of MW-10 (IN-2) in order to halt the
migration of free product and dissolved volatile organic compound (VOC) contaanination
in ground water. The Department concurs with Mobil that such an installation is
necessary. The proposed installation will be considered a Short Term Measure (STM)
according to the MCP 310 CMR 40.542.
-2-
Please be advised that the Department must approve all STMs prior to
implementation. The Department requires that within sixty (60) days from your receipt of
this letter, Mobil sutmit for review and approval prior to implementation, the
following additional information relative to the Short Term Measure:
1. A design, consisting of complete plans and specifications which shall
include, but not be limited to, the following:
a. A schedule for. implementation of the approved Short Term Measure following
Department approval;
b. Complete plans and specifications for all on-site treatment, storage,
and disposal activities;
c. A preliminary health and safety plan;
d. An environmental monitoring plan, including construction and long term
monitoring;
e. A preliminary contingency plan;
f. A preliminary security plan; and
g. An estimated cost of design, construction, and operation and maintenance.
2. A construction plan consisting of the following:
a. A construction schedule; and
b. Identification of all records, reports, logs and other pertinent
information which shall be maintained to document construction activities.
3. An initial operation and maintenance plan which shall include:
a. Start-up, testing, and maintenance over the first year of operation;
b. Identification of the equipment necessary for operation and maintenance;
c. • Specification of the type, frequency, and duration of testing or
monitoring; and
d. A quality assurance and quality control plan; the plan shall provide a
description of the criteria to be used in detecting and evaluating
deficiencies, selecting corrective measures, and implementing corrective
measures.
Mobil must comply with all existing local, State and Federal permitting and approval
rerniirement-G= A permit for cli cr_har^yc of - eateci effluent is required by the Division of
Water Pollution Control and all systems that generate air discharges must be approved by
he Division of Air alit Control. All additional permits and approvals must be
t Quality
identified and prompt action shall be taken to obtain such permits and approvals in order
to avoid delays in implementing the STM. Permitting activities and time frames must be
included in the schedule for implementation of the approved STM (l.a. above) .
-3-
A review of the performance of the existing product recovery/ground water treatment
system (ra-1) has indicated the system is in need of modification. Analysis of VOC
concentrations in March, April, June, August and September, 1988, quantified excessive
levels in the system effluent. On October 18, 1988, Department engineers inspected
the site and found the air stripping tower malfunctioning, full of water and overflowing
contaminated water to the surface of the ground. Fouling of the air stripper with iron
bacteria is the apparent reason for system malfunction. In addition the Department has
recently received complaints from residents adjacent to the site regarding noxious odors
from the air stripper.
The Department requires that, within sixty (60) days from your receipt of this
letter, Mobil submit for review and approval prior to implementation, detailed plans for
modification of RW-1 with provisions for reducing system fouling (i.e., iron
removal) , modifications to reduce VOC emissions in air and water effluent prior to
discharge and to discontinue discharge to the storm drain and pond north of Route 132. A
subsurface ground water discharge system must be installed to allow for recirculation of
treated effluent. Reconstruction plans for RW-1 must include all items required above
for the Rw 2 STM. Where appropriate plans can be combined to include both systems. All
appropriate permits and approvals must be identified and obtained prior to implementation
as for R972.
Be advised that the modification to the existing treatment system will require a
peim - i��Ue3 by the D` "S11 oL Air duality Control. 310 CMR 7.02(2) (a) (6) requires
that new facilities install Best Available Control Technology (BACT) . The Department
has determined that BACT for aeration to remove VOC from contaminated soils or
ground water is carbon adsorption or other technology which will result in an equivalent
emission reduction. Enclosed are the following Design Data Sheets to assist you making
application to the Department:
DDS-3 Industrial and Commercial Facilities
DDS-3c Wet Collection Devices
DDS-3d Adsorption Equipment
DDS-3e Afterburners
Should you have any questions regarding the air pollution control application
requirements, contact Alan S. Pickering at the Regional Office.
In order to comply with the MCP, Mobil must conduct additional work at the site.
Therefore, the Department requires Mobil, within forty-five (45) days of receipt of this
letter, to submit for review and approval a scope of work as outlined in 310 CMR 40.545
(2), items (a) through (f) for additional Phase II Activities.
In addition to analyses previously conducted at the site the sampling plan (310 CMR
40.545(2)(d)) must include provisions for soil and ground water analysis for lead.
Unless justification for their exclusion is provided, all Phase II Activities at and
near the site must be completed as required by the MCP. Some work has been completed at
the site and therefore sections that must be addressed are listed below by specific MCP
reference under 40.545(3) .
-4-
(a) Investigation of Physical Site Characteristics
3. needs to be further addressed with emphasis on surface water effects
on ground water flow (horizontal and vertical) and contaminant migration;
5. needs to be addressed;
6. needs to be further addressed;
8. needs to be further addressed;
9. needs to be addressed; and
11. needs to be further addressed.
(b) Identification of Source and Extent of Release
1. needs to be further addressed to define release(s) of gasoline at the site
subsequent to the line leak which occurred previous to May 1986;
2. needs to be further addressed to define the extent of ground water
contamination (horizontal and vertical). -Review of monitoring information
submitted indicateds VOCs have migrated beyond wells y and v to the
southwest of the service station. The width, length and depth of the plume
has not been defined. The Department has determined the soil gas survey
conducted at the site by Target Environmental in September 1988, was
insufficient for the intended purpose of defining ground water
contamination. Methods used by Target failed to detect VOCs in areas where.
monitoring wells (3, 7, 10 and 17) showed the presence of free product at
the time of the survey.
In addition, poor performance of the RW-1 treatment system, as
previously referenced, gives the Department reason to believe VOCs have been
released to the effluent receiving pond north of Route 132. The impact of
this release to the receiving pond must be evaluated.
3. needs to be addressed;
4. . needs to be addressed;
5. needs to be further addressed;
6. needs to be addressed with emphasis on the existence and concentration
of VOC vapors in buildings adjacent to the service. station.
c. Characterization of (released) Oil.or Hazardous Materials, all items need to be
addressed.
d. Identification of Exposure Points and Determination of Exposure Point
Conce.-trations. all itomc need to be addressed.
e. The results of the Phase II-Comprehensive Site. Assessment shall be provided
as stated in this section.
-5-
f. Characterization of Risk of Harm to Human Health, all items need to be
addressed.
g. Characterization of Risk of Harm to Safety, Public Welfare and the
Environment, all items need to be addressed.
h. When No Further Remedial Response Action is Necessary, all items need to be
addressed.
i. Requirements When a Remedial Response Action is Necessary, all items need to be
addressed.
Should you have any questions regarding case OIR/SA 4-214, please contact James
Begley of this office.
Very truly yours,
c7/
Gerald A. Monte, Acti ief
Site.Assessment Section
M/JFB/re
Enclosures
CERTIFIED MAIL #P893 315 347
RE'i'URN RECEIPT REQUESTED
cc: Office of Incidence Response
Barnstable Board of Health
Thwn Hall
Hyannis, MA 02601
Barnstable Fire Department
93 High School Road Ext.
Hyannis, MA 02601
ATTN: Chief Richard Farrenkoff
Zecco, Inc.
345 Main St.
Northboro, MA
L. Miller
Mobil Oil Corp.
3225 Gallows Road
Fairfax, Virginia 22037-0001
Arlene Barrios
508 Chelsea St.
East Boston, MA 02125
I
-6-
cc: DWPC - SERO
DWPC - Boston
ATrN: Ronald White
DAQC - SERO
ATPN: Alan S. Pickering
Frank McDonough
Rainbow Motel
Route 132
Hyannis, MA 02601
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