HomeMy WebLinkAboutAmended OOC Request Prepared by:
349 Route 28, Unit D
W. Yarmouth, Massachusetts 02673
24 Charles Street, South Yarmouth
Request to Amend OOC SE 83-2253
Town of Yarmouth
Conservation Commission
December 2021
Prepared for:
Amy MacIsaac
24 Charles Street
South Yarmouth, MA 02664
BSC Job #50444.00
December 1, 2021
Town of Yarmouth
Conservation Commission
1146 Route 28
South Yarmouth, MA 02664
Attn: Kelly Grant, Conservation Administrator
RE: Request to Amend Order of Conditions SE 83-2253, 24 Charles Street, South
Yarmouth, Massachusetts, BSC Job #50444.00
Dear Ms. Grant and Members of the Conservation Commission:
BSC Group, Inc. (BSC) is pleased to submit this Request to Amend the Order of Conditions
SE 83-2253 on behalf of Amy MacIsaac (the Applicant) for the project located at 24 Charles
Street, South Yarmouth, Massachusetts (the Site). The approved project consists of the
construction of an addition to an existing single-family dwelling in the footprint of a portion
of the deck, alterations to the existing deck, and the relocation of the existing septic system
further inland (the Project).
The homeowner was switching their heat source from oil to natural gas, and found a leak
coming from the oil tank. Upon further exploration it was found that a large area beneath
the existing single-family home has become contaminated due to the oil leak; please see
attached foundation plan showing contaminated area. Also attached with this request is a
Phase I Initial Site Investigation/ Tier Classification and Immediate Response Action Status
Report #3 from Green Seal Environmental, LLC. Please refer to this report for more
detailed information on the leak and contaminated area; specifically, page 14 paragraph 2 for
a detailed description of the remedation.
In order to remediate the Site, the applicant would like to amend the existing order of
conditions. The requested amendment would allow the applicant to remove all contaminated
soil from beneath the house and within the existing foundation. The applicant proposes to
lift and temporarily move the existing single-family home so that all contaminated material
can be removed from the site. To accomplish this, a new foundation wall is proposed in
order to support the existing garage while the house is lifted; see attached Site Plan of Land
from BSC Group, Inc. The new wall will create ± 89 s.f. of impacts within the 35’-50’
buffer to top of coastal bank. The new foundation wall is the only new proposed impact.
After removing all contaminated material, new foundation walls will be poured within the
footprint of the existing foundation. Then the house will be placed back on top of the
foundation within the footprint of the existing home.
All contaminated material will be hauled off to an appropriate disposal site. The limit of
work and erosion controls will remain the same as the already approved project because no
work is proposed closer to resource areas. All disturbed areas will be restored to pre-
Kelly Grant – Yarmouth Conservation
12/1/2021
Page 2
existing conditions once the house is back in place.
Included with this request to amend the OOC SE 83-2253 are…
1. Town of Yarmouth AOOC Checklist
2. Certified Abutters List
3. Abutter Notification Letter
4. Phase I Initial Site Investigation/ Tier Classification and Immediate Response
Action Status Report #3 from Green Seal Environmental, LLC
5. Site Plan of Land from BSC Group, Inc.
6. Foundation Plan from Apex Engineering
7. Check for Legal Advertising Fee
This application is being submitted in accordance with the Massachusetts Wetlands
Protection Act and the Town of Yarmouth Wetlands Protections By-law. If you have any
questions or require additional information, please contact me at (508) 778 - 8919.
Truly yours,
BSC Group, Inc.
Paul Mancuso, WPIT
Environmental Scientist
cc: Department of Environmental Protection, Southeast Regional Office, 20 Riverside
Drive, Lakeville, MA 02347
Amy MacIsaac, 24 Charles Street, South Yarmouth, MA 02664
Yarmouth Conservation Commission • 1146 Route 28 • South Yarmouth, MA 02664-4492
Tel. (508)-398-2231 Ext. 1288 • Fax (508)-398-0836 • TTD# (508) 398-2231
Revised February 2016
Administrative Checklist
Request to Amend an Order of Conditions
General Information:
The letter must be submitted two weeks prior to the next scheduled Conservation Commission meeting. No new
information may be accepted into the Commissioner’s pack et a week before the meeting. Failure to follow the
Administrative Checklist guidelines shall result in an Administrative Incomplete Application and will not be
advertised for a Public Hearing. Contact the Conservation office if you need assistance. For more information, refer
to Wetlands & Waterways Program DWW Policy 85-4.
Submitting an Application:
1 original letter requesting an amendment. The request shall include the DEP file number, project location,
specific narrative of the proposed change and current applicant/homeowner information.
1 original and 7 copies of the updated plan, folded separately, right side out with title. All plans shall
reference NAVD1988 unless otherwise noted. Landscape plans shall be detailed to show proposed and
existing conditions, native species, size and spacing.
A pdf of original letter, plan, and other supporting information emailed to kgrant@yarmouth.ma.us. Please
put the property’s street address in the pdf file na me.
A 100’ radius map, current abutters list and abutters notification identifying the property owners who are to
be notified per 310 CMR 10.00. Abutters list must be certified by the Town Assessor’s office. The
Assessor’s office requires 7 days advance notice.
Submit Certified Mail Receipts (PS Form 3800) for all abutters.
Submit Certified Mail Receipts for Massachusetts Natural Heritage and Endangered Species Program and
Massachusetts Division of Marine Fisheries if applicable. Alternatively, you may visit their websites for
electronic filing information. If filed electronically, please copy kgrant@yarmouth.ma.us.
Legal ad fee - check payable to “Town of Yarmouth”.
(Refer to Fee Schedule at https://www.yarmouth.ma.us/696/Filing-Forms)
Waterway’s jurisdiction – Any coastal projects such as, but not limited to, docks, piers, bulkheads,
revetments, dredging and boardwalks shall require submittal of all Notice of Intent, plans and supplemental
information to the Town of Yarmouth Waterways/Shellfish Committee via the Natural Resources office by
certified mail or in-hand delivery. The applicant or his/her representative must provide the Conservation
office proof that this has been done or the filing will not be accepted.
1 pdf of the letter, plan and other supporting information shall be sent VIA EMAIL to DEP, Southeast
Region at SERO_NOI@mass.gov with a subject line showing “YARMOUTH - RAOC – MassDEP 7-Digit
File Number” and copied to kgrant@yarmouth.ma.us. We must receive a copy of this email as proof that it
has been sent to DEP.
DEPARTMENT
OF
CONSERVATION
X
X
X
X
X
N/A
X
N/A
X
70/ 115/ / /
WAHNSCHAFFT OLIVER
ZANAPALIDOU RACHEL
34 CHARLES ST
SOUTH YARMOUTH , MA 02664
70/ 114/ / /
LEAHY JAMES K
LEAHY DEBORA J
661 LIBERTY ST
BRAINTREE , MA 02184
70/ 112.1/ / /
THIELMAN WILLIAM J III
C/O GRIECO JOHN E
13 STOCKWELL LN
SOUTHBOROUGH , MA 01772
70/ 104/ / /
RICE ALLISON
BELCHER ELIZABETH & AARON
17 CHARLES ST
SOUTH YARMOUTH , MA 02664
70/ 113/ / /
MACISAAC AMY TRS
AMY MACISAAC REV TRUST
24 CHARLES ST
SOUTH YARMOUTH , MA 02664
70/ 98/ / /
BANK OF AMERICA N A TR
PO BOX 460329 DEPT 909
HOUSTON , TX 77056
70/ 97/ / /
WOJNAR STANLEY J
WOJNAR APHRODITE M
14650 DURBIN ISLAND WAY
ST JOHNS , FL 32259
70/ 96/ / /
BARR JOHN D
NORTON WENDY JANE
29 BASS RIVER RD
SOUTH YARMOUTH , MA 02664
70/ 95/ / /
MALLOY PAUL F
MALLOY SALLY M
1 ALBERMARLE RD
NEWTONVILLE , MA 02460
70/ 94/ / /
MALLOY PAUL F
MALLOY SALLY M
1 ALBERMARLE RD
NEWTONVILLE , MA 02640
70/ 100/ / /
GOW JAMES E
GOW BARBARA A
11 BRYN MAWR AVE
AUBURN , MA 01501-1620
70/ 99/ / /
PAZAKIS ROSETTO M
PAZAKIS BARBARA E
17 BASS RIVER RD
SOUTH YARMOUTH , MA 02664-3125
NOTIFICATION TO ABUTTERS UNDER THE
MASSACHUSETTS WETLANDS PROTECTION ACT &
TOWN OF YARMOUTH WETLAND BY-LAW, CHAPTER 143
In accordance with the second paragraph of the Massachusetts General Laws Chapter 131, Section 40,
you are hereby notified of the following:
A. The name of the applicant is Amy MacIssac
B. The applicant has filed a Request to Amend an Order of Conditions with the Yarmouth
Conservation Commission, seeking permission to remove, fill, dredge or alter an Area Subject to
Protection under the Wetlands Protection Act (MGL c. 131 s. 40 & Town of Yarmouth Wetland
By-Law, Chapter 143).
C. The address of the lot where the activity is proposed is 24 Charles Street, South Yarmouth
D. Proposed work is to remove all contaminated material from the Site. A leak from an old oil tank
has contaminated soil at the Site.
E. Copies of the Request to Amend an Order of Conditions may be examined at the Yarmouth
Town Hall at the Conservation Commission office between the hours of 9:00 a.m. and 4:00
p.m. Monday thru Friday. For more information, call (508) 398-2231 ext. 1288.
F. Copies of the Request to Amend an Order of Conditions may be obtained from the
applicant’s representative. Applicant’s representative’s phone number: 508-778-8919
G. Information regarding the date, time and place of the public hearing may be obtained by calling
the Yarmouth Conservation Commission office at (508) 398-2231 ext. 1288
H. Person sending this notification (representative)
Name Paul Mancuso
Address 349 Route 28, Unit D
Town West Yarmouth State MA Zip 02673
Telephone 508-778-8919
Note:
• Notice of the public hearing, including date, time and place will be published at least five (5)
days in advance in a newspaper of general circulation.
• Notice of the public hearing, including date, time and place will be posted in the Town Hall not
less than forty-eight hours in advance.
• You may also contact the Southeast Regional Office of the Department of Environmental
Protection at (508) 946-2800 for more information about this application.
Green Seal Environmental, LLC
114 State Road, Bldg. B, Sagamore Beach, MA 02562
T: 508.888.6034 F: 508.888.1506
www.gseenv.com
1
MassDOT Certified
DCAMM Certified
MCSS-2001-0001
November 8, 2021
Mr. John Handrahan, Chief – Brownfields and C&E
Massachusetts Department of Environmental Protection (MassDEP)
Southeast Regional Office (SERO)/Bureau of Waste Site Cleanup (BWSC)
20 Riverside Drive
Lakeville, MA 02347
RE: PHASE I INITIAL SITE INVESTIGATION/TIER CLASSIFICATION and
IMMEDIATE RESPONSE ACTION STATUS REPORT #3
MacIsaac Residential Property - RTN 4-28586
24 Charles Street – South Yarmouth, MA 02664 (Parcel ID:70/113)
Dear Mr. Handrahan,
Green Seal Environmental, LLC (GSE) has prepared the following Phase I Initial Site Investigation report
and Supporting Documentation to support Tier 1 Classification at the subject property at the one-year
anniversary of Release Notification in accordance with the provisions of 310 CMR 40.0483 and 40.0500;
respectively. This document also includes an Immediate Response Action (IRA) Status report beyond those
previously submitted; the most recent being September 14, 2021. It is our intent to continue the IRA
concurrent with Comprehensive Response Actions with the work proposed in the Phase II Scope of Work
presented herein.
This Phase I Investigation, as the basis of Tier I Classification, relies heavily on the environmental
assessment activities and risk assessment undertaken as part of the ongoing IRA following the initial remedial
response conducted for the removal of impacted soils from the release area undertaken in the period from
December 2020 to January 2021. These response actions were conducted under the previous Licensed Site
Professional (LSP) of record for the release. Under the verbal approval of MassDEP for the removal of up to
200 yards of impacted soils, excavation activities resulted in the generation of some 28.5 tons (20 yards) of
remedial waste from a roughly 10 foot x 8 foot x 8 foot (D) area. On January 7, 2021, light non-aqueous phase
liquid (LNAPL) was measured in monitoring well MW-1, located upgradient of the release area, and verbal
approvals were extended for the removal of up to 500 gallons of LNAPL and oily water.
The excavation was not advanced into the water table below 8 feet as apparently based on structural
concerns and shoring capacity to maintain a safe work space. As a result, residually impacted soils remain
within the capillary fringe of the release area and no LNAPL recovery was made other than a drum of oily liquids
and spent absorbents.
Subsequent assessment under the Successor LSP indicted significant risk associated with residual soil
and groundwater impacts as driving vapor intrusion into an occupied dwelling as a Critical Exposure Pathway
(CEP). Piping left within the backfilled excavation was used to construct a sub-slab vapor extraction system as
NOVEMBER 8, 2021 MACISAAC: 24 CHARLES STREET – SO YARMOUTH/MCSS-2021-0001
PAGE 2 OF 19 PHASE I/TIER CLASSIFICATION: RTN 4-28586
GREEN SEAL ENVIRONMENTAL | 114 STATE ROAD, BUILDING B, SAGAMORE BEACH, MA 02562 | T: 508-888-6034
was piloted and verbal authorization granted by the MassDEP for the operation and maintenance of this system
as an active exposure pathways mitigation system. The efficacy of this system has been demonstrated by
subsequent indoor air testing as a temporary measure. Additionally, verbal authorization to extend the
removal of up to 2,500 gallons of LNAPL and oily water for further source reduction was requested and granted.
Several attempts were made in the most recent reporting period to remove oily water and LNAPL from the
release area using the wellpoint (IW-1) left within the area of excavation. Such efforts had limited success with
the recovery of 258 gallons of oily water with globules of free phase liquid. Such poor recovery is attributed
to the low permeability of the partly silty very fine sands in the upper aquifer and the design of the well as a
1¼ inch driven galvanized well.
Although all substantial hazards are mitigated under current conditions and engineering controls, an
IRA Status Report for additional aggressive soil removal is included within this Phase I/Tier Classification report.
Such is intended under the existing verbal approvals with a Permanent Solution objective as the most effective
and desired remedial option in a review of remedial alternatives. Such work is currently being planned,
contracted and locally permitted at the time of this filing.
In accordance with the provisions of 310 CMR 40.0810(6), the scope and level of detail employed in
this Phase I Investigation is commensurate with the nature and complexity of the Disposal Site, wherein a
known source of petroleum contamination, from a single release, occurred at a residential dwelling and the
hydrogeologic conditions, solute fate and exposure pathways have been investigated throughout the IRA, as
summarized herein. This work has been, and continues to be conducted under LSP oversight in a manner
consistent with the Massachusetts Contingency Plan (MCP) Response Action Performance Standards (RAPS),
pursuant to 310 CMR 40.0191 and the QA/QC policies of GSE. The facts and statements herein are, to the best
of our knowledge, a true and accurate representation of the Site activities, remedial response actions and
environmental conditions associated with the project to date.
ENVIRONMENTAL SETTING AND PROPERTY DESCRIPTION [Refer to Appendix A]
The subject property is a 0.79-acre parcel of land at 24 Charles Street in South Yarmouth, Massachusetts,
owned by MacIsaac Amy Trustee/Amy MacIsaac Rev Trust, and currently used as a primary residence. The
Town of Yarmouth identifies the property as Parcel ID 70-113-10256 as some 1,500 feet north of the Bass River
Bridge in South Yarmouth at the West Dennis Town line. According to the Town of Yarmouth Assessor’s
database, the property is improved upon by a single-story, single-family residence, with a living area of 1,928
square-feet, constructed in 1945. The dwelling has a garage with living space upstairs and a walkout basement.
The improvements include a wooden deck, landscaped areas, and a gravel driveway [Refer to Figure 1 –
Appendix A].
Until December 10, 2020, oil heating was used and the heating oil was stored in the basement in an
aboveground storage tank (AST), original to the property. In, or around November 6, 2020, the sub-slab fuel
line connecting the oil tank to the furnace leaked causing a 225+ gallon release to the environment as resulting
in soil and groundwater impacts underlying that portion of the dwelling between the former tank and furnace
and as extending to the front entrance area. The extent of soil and groundwater impacts at the Disposal Site
is a portion of the subject property underlying a portion of the dwelling footprint and extending to the west
under the driveway area in an approximate 30-foot x 30-foot area (900 square feet). It also includes the area
of excavation and exterior monitoring well MW-1 [Refer to Site Plan – Appendix A].
NOVEMBER 8, 2021 MACISAAC: 24 CHARLES STREET – SO YARMOUTH/MCSS-2021-0001
PAGE 3 OF 19 PHASE I/TIER CLASSIFICATION: RTN 4-28586
GREEN SEAL ENVIRONMENTAL | 114 STATE ROAD, BUILDING B, SAGAMORE BEACH, MA 02562 | T: 508-888-6034
According to the 2018 USGS topographic map (Dennis, Massachusetts quadrangle), the property is situated
approximately 15 feet above the mean sea level on the western portion (front of the property); and slopes
down into the 100-year flood zone as waterfront property abutting the Bass River tidal estuary. The subject
residential property is surrounded by similar high density residential properties to the north, west, and south.
High density commercial development is to the south along Route 28 as a State Highway and transportation
corridor. The subject property and the surrounding properties are all serviced by an extensive municipal water
system with no potable wells within 500 feet of the Site and neither the subject property or Site fall within any
designated Zone II – Wellhead Protection area nor Zone A of any surface water reservoir. There is no municipal
sewer in the area and the subject and abutting properties are on private septic systems. A stormwater drain
is located along the southern property boundary pursuant to an easement agreement with the Town of
Yarmouth, and the outfall is located on the subject property.
Based on the Mass GIS Priority Resource mapping overlay and Phase I Site Assessment Map, the property
categorically falls within the Cape Cod Sole Source Aquifer and as such the GW-1, Method 1 – Risk
Characterization drinking water standards would apply [Refer to Figure 2 – Appendix A]. These standards for
drinking water ingestion exposure are overstated in the area of the Site as a high-density residential area
abutting a tidal estuary wherein the density of development and potential source of pollutants from private
sewage discharge and threat of salt water intrusion preclude the development of a public water supply.
Notwithstanding, further considered under the provisions of 310 CMR 40.0932(5), the GW-1 standards are
considered under the review of additional remedial response measures under the IRA to absolve significant
exposure risks to human and environmental receptors identified. Additionally, based on the depth to
groundwater at approximately 8-9 feet below grade in the area of the release and footprint of the occupied
residential dwelling, the GW-2 and GW-3, Method 1 – Risk Characterization standards are considered in the
evaluation of Significant Risk. Based on soil impacts within the release area being below a permanent structure
or at depths greater than 4-feet below the existing grade, the S-2 and S-3/GW-1, GW-2 and GW-3 soil criteria
is considered under existing conditions. The S-1/GW-1, GW-2 and GW-3 criteria is further considered under
the foreseeable future use and activities at the Site.
Sensitive Receptors
Human receptor groups at the property include residents, visitors (adults and children), and subsurface utility
or construction workers. As noted, based on soil accessibility, frequency and intensity of use, under current
conditions as below the concrete basement floor at depth, the exposure threat to residually impacted soils via
ingestion and dermal contact are minimal as is ingestion exposure threat for the drinking of impacted
groundwater. The primary exposure consideration under current conditions is the potential for vapor intrusion
and inhalation associated with the residual soil and groundwater impacts as is being addressed by engineering
controls for the sealing of the basement floor and use of a sub-slab venting system wherein indoor air testing
shows that the system is effective in the control of this CEP and no substantial or imminent hazards are
documented by the testing of indoor air conducted to allow for occupancy of the residential dwelling.
The Yarmouth Health Department (HD) reported that a well is located on 8 Bass River Road, approximately 340
feet northwest of the subject property. Upon contacting the Yarmouth Water Department, a water service
was confirmed and the status of the well was determined to be for irrigation only. As such, no protected water
supplies (potable wells, Zone II areas, Interim Wellhead Protection Areas or Zone A surface water reservoirs)
are present within 500 feet of the property. The subject property is connected to a private septic system and
municipal water services are provided to the subject property and the surrounding area.
NOVEMBER 8, 2021 MACISAAC: 24 CHARLES STREET – SO YARMOUTH/MCSS-2021-0001
PAGE 4 OF 19 PHASE I/TIER CLASSIFICATION: RTN 4-28586
GREEN SEAL ENVIRONMENTAL | 114 STATE ROAD, BUILDING B, SAGAMORE BEACH, MA 02562 | T: 508-888-6034
As noted, the Bass River runs along the eastern boundary of the subject property and is considered by
established Site-specific groundwater flow direction to be the most sensitive environmental receptor with
noted tidal flats and Massachusetts Natural Heritage & Endangered Species Program estimated rare wetland
wildlife habitat within 250 feet of the release area. Based on plans prepared by BSC Group, and approved by
the Yarmouth Conservation Commission, the release is some 120 feet from the edge of the Salt Marsh but falls
within the 50 foot buffer zone for the defined Coastal Bank and as within 50 feet of the AE (EL) 100-year flood
zone. All work within the release area is subject to Conservation Commission jurisdiction. Prior work was
conducted with the benefit of communications with the Conservation Agent under an Emergency (NOI)
Certification issued September 9, 2021. Moving forward, additional remedial response actions will be framed
as an amendment to the existing Notice of Intent and Order of Conditions SE83-2253 as previously issued for
the proposed addition to the rear of the house and upgrade of the septic system.
IRA STATUS III [RTN4-28586]
Background/Historic IRA Activities
On October 22, 2020, approximately 213 gallons of oil were delivered to the subject residential property at 24
Charles Street in South Yarmouth, MA. On the evening of November 5, 2020, the homeowner noticed that hot
water and heat were not available, and contacted an oil-burner service company. The oil-burner service
technician conducted an inspection on the morning of November 6, 2020, and determined that the AST was
out of oil. The fuel oil company was called and an additional 228.9 gallons were delivered on November 6,
2020, at approximately 9:00 am. The fuel company was unable to prime the furnace and restart it. The oil-
burner technician was called again and upon inspection he advised the homeowner that the fuel oil supply line
was the likely issue, and he shut off the supply line in the late morning. On November 6, 2020, the sub-slab
supply line was decommissioned, an overhead oil supply line was installed, and the Yarmouth Fire Department
(FD) was notified of the loss of approximately 200 gallons of oil. The Yarmouth FD notified the Yarmouth HD.
The FD and HD met with the homeowner and the oil-burner technician and advised the homeowner to hire an
LSP. However, no Notification under a 2-Hour Condition was advised or otherwise made. On November 9,
2020, the homeowner contracted with GSE to conduct preliminary investigations to qualify Notification and
Remedial Response liabilities.
On November 10, 2020, GSE conducted a site inspection and conducted two shallow borings through the
concrete slab near the oil-burner and encountered grossly impacted soils as confirming a release to the
environment. After confirming that the MassDEP had not been notified by others, GSE notified the MassDEP
of the 2-Hour release condition on November 11, 2020. At the time of Notification, verbal approval for the
removal of up to 200 yards of impacted soils was approved.
On December 15 and 16, 2020, Trident Environmental Group, LLC of Norfolk, Massachusetts, (Trident)
conducted a limited soil removal under GSE oversight to reveal the sub-slab fuel supply line, and to
preliminarily assess the extent of petroleum impacts in soil. On December 15, 2020, a 5-foot by 5-foot section
of the concrete slab was removed. Following the removal of the slab, the underlying soil was removed using
hand tools to expose the decommissioned underground fuel supply line and nearby septic pipe. A ruptured
protective sleeve was observed on the fuel line. The fuel line was comprised of two sections connected with
a threaded joint. Oil was observed along a portion of the exposed length of the supply line and around the
joint. Petroleum staining was observed on the soil in the vicinity of the joint and along the supply line and
gross soil impact was noted to a depth of at least 5 feet below the basement slab. On December 16, 2020,
additional soil removal was conducted to assess the extent of petroleum impacts. The overall depth of the
NOVEMBER 8, 2021 MACISAAC: 24 CHARLES STREET – SO YARMOUTH/MCSS-2021-0001
PAGE 5 OF 19 PHASE I/TIER CLASSIFICATION: RTN 4-28586
GREEN SEAL ENVIRONMENTAL | 114 STATE ROAD, BUILDING B, SAGAMORE BEACH, MA 02562 | T: 508-888-6034
excavation was approximately 14 inches below the concrete slab, except in the middle area, where the
excavation was advanced to an additional 2 feet. Approximately 1.4 cubic yards of soil were removed at this
time and stored in 55-gallon drums.
In the period between December 28, 2020 and January 5, 2021, GSE performed a series of interior and exterior
borings to define the extent and magnitude of soil impacts and for the purpose of installing monitoring wells
for groundwater sampling and analysis. GSE advanced three interior soil borings (HB-3 through HB-5) beneath
the basement floor slab (bs) up to approximately 9 feet and two shallower borings, HB-6 and HB-7, and
screened soil samples with a photoionization detector (PID). Total organic vapor (TOV) readings at HB-3 were
greater than 300 part per million by volume (ppmv) between 3.5 to approximately 7 feet, where the boring
was terminated. A TOV reading of >100 ppm was reported at HB-4 at the groundwater interface at 8 feet as
confirming groundwater impact. The soil boring HB-5 was terminated at approximately 6 feet below the slab
due to refusal. A maximum TOV reading of 5.7 ppmv was recorded in HB-5 at the 2-4-foot interval. As such,
HB-1, HB-2 and HB-3 represented a targeted area of gross soil impact to the groundwater interface for
additional soil removal between the former oil tank and burner which would require extensive shoring.
On January 5, 2021, six exterior soil borings (SB-1 through SB-6) were installed to depths of up to 20 feet below
ground surface (bgs) using direct-push methodology for the installation of monitoring wells. Soil samples were
screened with a PID and soil classification was noted. The soil was primarily classified as very fine to coarse
sand with varying amounts of gravel and fine silt, except for a band of dense clayey silt at all but one boring
location. The layer of clayey silt was observed at approximate depths ranging between 12 to 17 feet bgs.
Elevated TOV readings, exceeding 100 ppmv, were recorded at soil boring SB-1 (MW-1) at depths between
approximately 16 and 20 feet bgs corresponding with the groundwater interface. Soil samples from this
location reported petroleum hydrocarbon impacts greater than the applicable Method 1 standards at this
location where LNAPL was present. All soil borings were completed as one-inch flush mount monitoring wells.
On January 7, 2021, the six newly installed wells were developed. During well development, LNAPL thickness
of 0.01 feet was detected in monitoring well MW-1. Subsequent groundwater gauging and site-specific
groundwater flow computations show this well as upgradient of the release area and impact is attributed to
LNAPL travel above the silty clay horizon. During subsequent well gauging events conducted in January, March,
and June, LNAPL was not detected in any of the six monitoring wells and with the exception of MW-1, none of
the other monitoring wells reported any groundwater impacts.
On January 21, 2021, additional concrete slab was removed by Trident in preparation for removal of
petroleum-contaminated soil using a vacuum excavator (vactor) from an approximately 6-feet wide, 9-feet
long, and 9-feet deep area under verbal authorizations granted by MassDEP. Between January 25 and 27,
2021, excavation of soil was conducted via vactor and hand tools. For structural safety, a timber shoring box
designed by Apex Engineering Co., Inc. of Rochester, Massachusetts, was constructed on-site and driven in by
Trident’s subcontractor, 38 Excavation, Inc. A total of 25.08 tons of contaminated soil were removed and
staged on-site in vactor boxes. The excavation was advanced to approximately 8.5 feet, and apparently based
on structural concerns and worker safety, it was not advanced further. Soil samples were collected from the
excavation side walls by drilling holes through the sheathing of the shoring box at depths ranging between 4.5
feet and 8.5 feet below the slab. Soil samples were also collected from the bottom of the excavation. The
analytical data for the endpoint soil sampling is presented on Table 1 below.
NOVEMBER 8, 2021 MACISAAC: 24 CHARLES STREET – SO YARMOUTH/MCSS-2021-0001
PAGE 6 OF 19 PHASE I/TIER CLASSIFICATION: RTN 4-28586
GREEN SEAL ENVIRONMENTAL | 114 STATE ROAD, BUILDING B, SAGAMORE BEACH, MA 02562 | T: 508-888-6034
On February 23, 2021, the excavation was prepared for backfilling by removing the accumulated oily water and
installing infrastructure for future remediation efforts. A drum pump was used to remove approximately 20
gallons of oily water accumulated at the base of the excavation. The removed oily water was stored in a drum.
A 1 ¼-inch diameter galvanized well with 2 feet of 0.010 slotted stainless steel well screen was driven in the
northeastern corner of the excavation for future groundwater injections or LNAPL extraction. The well-screen
was driven using a 4-inch PVC pipe to approximately 4- feet below the excavation base. The well point was
then extended above the basement floor. The bottom of the excavation was then leveled and absorbent pads
were used to remove the minor LNAPL accumulation. The excavation was backfilled with ¾-inch native sub-
angular stone to approximately 6- feet below the slab. Two 5-foot long, 2-inch diameter, 0.020-inch slotted
PVC screens were placed horizontally in the excavation. The top of the stone was covered with a sheet of
vapor barrier and further backfilled with excavatable flowable fill by Trident and its subcontractors on March
2, 2021.
The impacted soils generated were transported to Ondrick Materials & Recycling, LLC, of Chicopee under a Bill
of Lading on January 27 and February 26, 2021. A total of 25.08 tons was transported for asphalt recycling as
representing some 17 yards taken from the area of excavation in the basement utility room under the footprint
of the dwelling. The drum of oily water and absorbent pads were transported offsite by Clean Harbors on
March 1, 2021 to Spring Grove Resource Recovery in Cincinnati, OH under a duly executed Uniform Hazardous
Waste Manifest. The IRA Status Report #1 for the project was filed on March 11, 2021 and did not include the
March 9, 2021 soil or groundwater analytical results.
On April 12, 2021, GSE personnel, including the then LSP of Record, made an inspection of the property to
conduct indoor air testing in consideration of dwelling occupancy. This testing indicated that there was
significant degradation of the indoor air as a result of the assessment and soil removal activities and the existing
2 foot slotted screen within the backfilled excavation was used for the construction and piloting of a sub-slab
venting system to allow for dwelling occupancy. The then LSP submitted a Notice of LSP Termination as filed
on May 19, 2021 as expressing the end of LSP Oversight for the subject RTN on May 14, 2021.
NETLAB Case Number: 1A28045
Lab Sample Number:
Date Sampled:
Date Received:
Parameter Units
Sample
Result
Reporting
Limit
Sample
Result
Reporting
Limit
Sample
Result
Reporting
Limit
Sample
Result
Reporting
Limit
Sample
Result
Reporting
Limit
Sample
Result
Reporting
Limit
Sample
Result
Reporting
Limit
Sample
Result
Reporting
Limit
Sample
Result
Reporting
Limit
Sample
Result
Reporting
Limit
Sample
Result
Reporting
Limit
Method 1
S-1 & GW-1
Extractable Petroleum Hydrocarbons (EPH)
Unadjusted C11-C22 Aromatic Hydrocarbons mg/kg 586 13.5 2130 6.95 16.2 6.81 ND 6.63 11 6.62 70.7 6.53 2320 6.79 3940 14.5 87.9 8.76 497 8.37 547 8.42
Naphthalene mg/kg 1.87 0.67 8.32 0.34 ND 0.34 ND 0.33 ND 0.33 0.33 0.32 5.55 0.34 8.59 0.72 ND 0.43 1.55 0.41 2.3 0.42 4
2-Methylnaphthalene mg/kg 7.78 0.67 11.9 0.34 ND 0.34 ND 0.33 ND 0.33 0.96 0.32 6.73 0.34 28.7 0.72 0.89 0.43 4.4 0.41 5.63 0.42 0.7
Phenanthrene mg/kg 3.69 0.67 0.72 0.34 ND 0.34 ND 0.33 ND 0.33 ND 0.32 11.3 0.34 1.07 0.72 ND 0.43 2.45 0.41 2.79 0.42 10
Acenaphthene mg/kg 1.18 0.67 ND 0.34 ND 0.34 ND 0.33 ND 0.33 ND 0.32 3.48 0.34 6.02 0.72 ND 0.43 0.79 0.41 0.92 0.42 4
Acenaphthylene mg/kg 1.23 0.67 4.57 0.34 ND 0.34 ND 0.33 ND 0.33 ND 0.32 2.36 0.34 3.03 0.72 ND 0.43 ND 0.41 ND 0.42 1
Fluorene mg/kg ND 0.67 1.15 0.34 ND 0.34 ND 0.33 ND 0.33 ND 0.32 1.02 0.34 4.54 0.72 ND 0.43 ND 0.41 ND 0.42 1000
Anthracene mg/kg 1.7 0.67 10.2 0.34 ND 0.34 ND 0.33 ND 0.33 ND 0.32 4.15 0.34 ND 0.72 ND 0.43 1.02 0.41 1.13 0.42 1000
Fluoranthene mg/kg ND 0.67 ND 0.34 ND 0.34 ND 0.33 ND 0.33 ND 0.32 ND 0.34 ND 0.72 ND 0.43 ND 0.41 ND 0.42 1000
Pyrene mg/kg ND 0.67 ND 0.34 ND 0.34 ND 0.33 ND 0.33 ND 0.32 ND 0.34 ND 0.72 ND 0.43 ND 0.41 ND 0.42 1000
Benzo(a)anthracene mg/kg ND 0.67 ND 0.34 ND 0.34 ND 0.33 ND 0.33 ND 0.32 0.88 0.34 1.67 0.72 ND 0.43 ND 0.41 ND 0.42 7
Chrysene mg/kg ND 0.67 ND 0.34 ND 0.34 ND 0.33 ND 0.33 ND 0.32 ND 0.34 ND 0.72 ND 0.43 ND 0.41 ND 0.42 70
Benzo(b)fluoranthene mg/kg ND 0.67 ND 0.34 ND 0.34 ND 0.33 ND 0.33 ND 0.32 ND 0.34 ND 0.72 ND 0.43 ND 0.41 ND 0.42 7
Benzo(k)fluoranthene mg/kg ND 0.67 ND 0.34 ND 0.34 ND 0.33 ND 0.33 ND 0.32 ND 0.34 ND 0.72 ND 0.43 ND 0.41 ND 0.42 70
Benzo(a)pyrene mg/kg ND 0.67 ND 0.34 ND 0.34 ND 0.33 ND 0.33 ND 0.32 ND 0.34 ND 0.72 ND 0.43 ND 0.41 ND 0.42 2
Indeno(1,2,3-cd)pyrene mg/kg ND 0.67 ND 0.34 ND 0.34 ND 0.33 ND 0.33 ND 0.32 ND 0.34 ND 0.72 ND 0.43 ND 0.41 ND 0.42 7
Dibenz(a,h)anthracene mg/kg ND 0.67 ND 0.34 ND 0.34 ND 0.33 ND 0.33 ND 0.32 ND 0.34 ND 0.72 ND 0.43 ND 0.41 ND 0.42 0.7
Benzo(g,h,i)perylene mg/kg ND 0.67 ND 0.34 ND 0.34 ND 0.33 ND 0.33 ND 0.32 ND 0.34 ND 0.72 ND 0.43 ND 0.41 ND 0.42 1000
C9-C18 Aliphatic Hydrocarbons mg/kg 915 13.5 4630 69.3 33.7 13.6 ND 13.2 17.5 13.2 61 13 4930 67.7 12300 144 220 17.5 1230 16.7 1230 16.8 1000
C19-C36 Aliphatic Hydrocarbons mg/kg 251 13.5 1270 69.3 ND 13.6 ND 13.2 ND 13.2 24.3 13 1610 67.7 3810 144 66.8 17.5 362 16.7 348 16.8 3000
C11-C22 Aromatic Hydrocarbons mg/kg 568 13.5 2090 6.95 16.2 6.81 ND 6.63 11 6.62 69.4 6.53 2280 6.79 3890 14.5 87 8.76 487 8.37 534 8.42 1000
Volatile Petroleum Hydrocarbons (VPH)
Unadjusted C5-C8 Aliphatic Hydrocarbons mg/kg 27.9 5.3 131 6 ND 5.3 ND 5.3 ND 5.3 22.3 5.3 342 53.7 586 59.6 22.8 8.5 126 8.3 50 8.1
Unadjusted C9-C12 Aliphatic Hydrocarbons mg/kg 228 5.3 1680 23.9 10.2 5.3 ND 5.3 ND 5.3 221 5.3 2110 53.7 3230 59.6 197 8.5 706 8.3 332 8.1
Benzene mg/kg ND 0.3 ND 0.3 ND 0.3 ND 0.3 ND 0.3 ND 0.3 ND 2.7 ND 3 ND 0.4 ND 0.4 ND 0.4 2
Ethylbenzene mg/kg 0.8 0.3 4.1 0.3 ND 0.3 ND 0.3 ND 0.3 0.6 0.3 8.6 2.7 20 3 0.6 0.4 3.8 0.4 1.5 0.4 40
Methyl t-butyl ether (MTBE)mg/kg ND 0.05 ND 0.06 ND 0.05 ND 0.05 ND 0.05 ND 0.05 ND 0.5 ND 0.6 ND 0.08 ND 0.08 ND 0.08 0.1
Naphthalene mg/kg 1.8 0.5 6.7 0.6 ND 0.5 ND 0.5 ND 0.5 1.5 0.5 7.1 5.4 19.6 6 ND 0.8 5.5 0.8 1.5 0.8 4
Toluene mg/kg 0.4 0.3 3.6 0.3 ND 0.3 ND 0.3 ND 0.3 ND 0.3 5.7 2.7 14.6 3 ND 0.4 3.2 0.4 1.2 0.4 30
m&p-Xylene mg/kg 2 0.5 11.4 0.6 ND 0.5 ND 0.5 ND 0.5 1.6 0.5 24.2 5.4 59.4 6 1.4 0.8 11.2 0.8 4.1 0.8 see below
o-Xylene mg/kg 1 0.5 5.3 0.6 ND 0.5 ND 0.5 ND 0.5 0.8 0.5 11.6 5.4 28.1 6 ND 0.8 4.9 0.8 1.8 0.8 see below
Total xylenes mg/kg 3 0.5 16.7 0.6 ND 0.5 ND 0.5 ND 0.5 2.4 0.5 35.8 5.4 87.4 6 1.4 0.8 16.2 0.8 5.9 0.8 400
C5-C8 Aliphatic Hydrocarbons mg/kg 27.5 5.3 127 6 ND 5.3 ND 5.3 ND 5.3 22.3 5.3 336 53.7 571 59.6 22.8 8.5 123 8.3 48.8 8.1 100
C9-C12 Aliphatic Hydrocarbons mg/kg 172 5.3 1290 6 10.2 5.3 ND 5.3 ND 5.3 168 5.3 1630 53.7 2380 59.6 155 8.5 517 8.3 254 8.1 1000
C9-C10 Aromatic Hydrocarbons mg/kg 52.6 5.3 369 23.9 ND 5.3 ND 5.3 ND 5.3 49.7 5.3 433 53.7 744 59.6 39.1 8.5 169 8.3 70 8.1 100
TABLE 1: ENDPOINT ANALYTICAL SUMMARY VS METHOD 1 - RISK CHARACTERIZATION STANDARDS (JANUARY 2021)
MacIsaac: 24 Charles Street - South Yarmouth, MA RTN4-28586
PURPLE = CONCENTRATIONS EXCEEDING THE METHOD 1 RISK CHARACTERIZATION STANDARDS
EX-B16 (9.5')
1A28045-11
1/27/2021 15:30
1/28/2021 13:31
EX-B14 (9.5')
1A28045-09
1/27/2021 15:20
1/28/2021 13:31
EX-B15 (9.5')
1A28045-10
1/27/2021 15:25
1/28/2021 13:31
EX-S3 (4.5')
1A28045-07
1/27/2021 14:28
1/28/2021 13:31
EX-S4 (8.0')
1A28045-08
1/27/2021 14:35
1/28/2021 13:31
EX-S5 (4.5')
1A28045-05
1/27/2021 15:06
1/28/2021 13:31
EX-S6 (8.0')
1A28045-06
1/27/2021 15:14
1/28/2021 13:31
EX-S7 (4.5')
1A28045-03
1/27/2021 14:56
1/28/2021 13:31
EX-S8 (8.0')
1A28045-04
1/27/2021 15:01
1/28/2021 13:31
EX-S1 (4.5')
1A28045-01
1/27/2021 14:45
1/28/2021 13:31
EX-S2 (8.0')
1A28045-02
1/27/2021 14:50
1/28/2021 13:31
NOVEMBER 8, 2021 MACISAAC: 24 CHARLES STREET – SO YARMOUTH/MCSS-2021-0001
PAGE 7 OF 19 PHASE I/TIER CLASSIFICATION: RTN 4-28586
GREEN SEAL ENVIRONMENTAL | 114 STATE ROAD, BUILDING B, SAGAMORE BEACH, MA 02562 | T: 508-888-6034
The current LSP of Record was engaged by GSE on June 21, 2021 and subsequently assigned to the project and
made a thorough review of the public record documentation and internal files. The Successor LSP made initial
contact with the property owner the week of July 5, 2021 with the benefit of the June 24, 2021 indoor air
testing results as indicating that an Imminent Hazard did not exist and that under Method 3, the dwelling had
been occupied with no apparent significant risk as dependent on use of engineering controls. As such the need
to obtain verbal approvals for the operations and maintenance of the sub-slab venting system was identified
as an active remedial system. Additionally work within jurisdiction of the Wetland Protection Act jurisdiction
needed to be approved by the Yarmouth Conservation Commission. Off-gas granular activated carbon (GAC)
treatment was added and an onsite meeting with the Yarmouth Conservation agent and the MassDEP case
officer were arranged. These meetings were used for discussion of the project moving forward wherein
outstanding issues for IRA verbal approvals of an active remedial system, local conservation commission
jurisdictional approvals and planned assessment activities for consideration of exposure risks were discussed.
The result of such meetings was verbal authorization was provided to operate, maintain and monitor the
existing sub-slab venting system and an Emergency Certification for work completed to date was issued
allowing 60 days for a formal filing of an Amendment to the existing Notice of Intent for future remedial
response activities, wherein aggressive soil removal and in-situ treatment were remedial alternatives being
evaluated with the benefit of quarterly indoor air testing, quarterly monitoring well sampling and groundwater
analysis and supplemental soil testing at the perimeter of the area of the former excavation.
Monitoring wells MW-1, MW-2, MW-3 and MW-4 were sampled on July 6, 2021, and analytical results reported
all fractional EPH/VPH compounds and fractional analytes at MW-2, MW-3, and MW-4 as non-detect wherein
the reporting limit concentrations were less than the strictest GW-1, Method 1 – Risk Characterization
standards. Laboratory analysis for MW-1 again reported significant impacts above GW-1, Method 1 Risk
Characterizations standards. Such concentrations were greater than previously reported in March 2021 and
in the case of the C9 to C18 aliphatic compounds, also greater than the GW-2, Method 1 standards. The IW-1
well was also sampled and reported only low-level impacts. This well was found to be fully penetrating with
top of screen some 2-feet below the groundwater interface. As such, the laboratory analysis of this well
following installation and testing in July 2021, were not representative of the extent of groundwater impacts
wherein the presence of LNAPL was noted prior to backfill. This work was considered and indicated that
additional remedial response actions were necessary to advance the IRA to evaluate exposure risks as the
driver for consideration of remedial alternatives analysis on a cost to benefit basis to meet regulatory closure
objectives.
In the interim, under verbal approvals granted, on August 25, 2021, a vac-truck was used to remove oily water
from the 1 ¼ inch galvanized well (IW-1) set within the release area. The intent of this work was to use of the
vac-truck to simulate high-vacuum extraction in the upper portion of the aquifer wherein the water level would
be dropped and LNAPL and oily water accumulated. This work had limited success and recovered only 68
gallons of oily water with globules of free phase dyed fuel oil due to the low permeability of the very fine silty
sands in the upper portion of the shallow aquifer and size and construction of the driven well. Such work
indicated limitations of using the well as part of the remedial alternative consideration of bio-sparging. On
August 26, 2021, additional soil testing was conducted to further evaluate the extent and magnitude of soil
impacts along the perimeter of the excavation area. A series of seven borings were conducted as part of this
supplemental assessment [HB-16 to HB-22]. Field testing indicated no significant impact with TOV
concentrations as less than 5 ppmv in the 0-4’ intervals at these locations. Otherwise, composite sidewall (4-
8’) and bottom of hole (8-10’) samples were submitted for EPH/VPH analysis for each of these perimeter
locations. This analytical data was pending at the time of the second IRA Status Report filing on September 14,
2021.
NOVEMBER 8, 2021 MACISAAC: 24 CHARLES STREET – SO YARMOUTH/MCSS-2021-0001
PAGE 8 OF 19 PHASE I/TIER CLASSIFICATION: RTN 4-28586
GREEN SEAL ENVIRONMENTAL | 114 STATE ROAD, BUILDING B, SAGAMORE BEACH, MA 02562 | T: 508-888-6034
IRAS3 Status Update (9/14/21 to 10/29/21)
In the current reporting period, the analytical results for the additional soil testing were reported as indicating
significant residual soil impacts below and beyond the extent of former soil removal in the 4-8’ bs intervals (10-
14’ bgs) along the southern and eastern perimeter areas [EX-S3, EX-S4, HB-18 and EX-S-1] and from 8-10’ bs
(14-16’ bgs) in all other perimeter areas; most notably along the southern and eastern perimeter [HB-18, EX-
B-16, HB-19, HB-20 and HB-22]. Analytical results show that residual impacts are significantly greater than the
applicable Method 1 – Risk Characterization standards as driving exposure risks, most notably vapor intrusion.
These analytical results are summarized on Table 2 and define a new target area for in-situ treatment or
aggressive soil removal with the benefit of dewatering remedial options. These targeted areas for soil and
groundwater treatment/removal are shown on the Site Plan in Appendix A.
The analytical results received on September 9, 2021 were incorporated into site characterization input forms
for recommendations for in-situ treatment to MicroBac and Regenesis. These soil testing results and analytical
summaries are presented in Appendix E. The soil testing and groundwater results indicate a 30-foot x 20-foot
x 2-4-foot (D) area of impact running from the MW-1 monitoring well to the back of the interior wall separating
the basement laundry area from living room as targeted for treatment or soil removal to a depth of 10 feet
below the basement floor. It is estimated that some 80-90 yards impacted soils are located in this area, and
some 3,300 gallons of impacted groundwater within the interstitial pore space in these soils.
GSE returned to the property on September 14, 2021 for the Operation, Monitoring and Maintenance (OM&M)
inspection and monitoring of the sub-slab soil vapor system and again on September 28-29, 2021 for the
OM&M inspection of the system as corresponding to the fourth quarter sampling of monitoring wells, and to
repeat indoor air testing in consideration of the CEP. Additional OM&M inspections were made on October
6th, 14th and 29th, and were coordinated around site meetings with contractors and removal of additional
impacted groundwater from the IW-1 wellpoint and MW-1, which was replaced with a 2 inch well for this
purpose. Through the reporting period, TOV readings within the sub-slab venting system have decreased from
112 ppmv (9/14/21) to 27 ppmv (10/29/21). During the inspection on October 14, 2021, the GAC drum was
replaced due to TOV breakthrough. These field-testing results and tracking of OM&M activities are shown in
the tracking chart in Appendix B and visually charted below.
CLIENT SAMPLE ID HB-16/17-COMP (4-8)HB-16/17-COMP (8-10)HB-18 (4-8)HB-18 (8-10)HB-19-20-COMP (4-8)HB-19-20-COMP (8-10)HB-22 (4-8)HB-22 (8-10)
SAMPLING DATE 26-AUG-21 26-AUG-21 26-AUG-21 26-AUG-21 26-AUG-21 26-AUG-21 26-AUG-21 26-AUG-21
LAB SAMPLE ID L2146462-01 L2146462-02 L2146462-03 L2146462-04 L2146462-05 L2146462-06 L2146462-07 L2146462-08
CAS Number S1/G1-14 S1/G2-14 S1/G3-14 Units Q Q Q Q Q Q Q Q
General Chemistry
Volatile Petroleum Hydrocarbons
C5-C8 Aliphatics, Adjusted C5-C8-ALPHA-J 100 100 100 mg/kg 5.57 U 79.3 28.6 U 229 5.93 U 446 5.95 U 90.4
C9-C10 Aromatics C9-C10-ALPHA-UJ 100 100 100 mg/kg 5.57 U 641 72 1240 5.93 U 1870 5.95 U 378
C9-C12 Aliphatics, Adjusted C9-C12-ALPHA-J 1000 1000 1000 mg/kg 5.57 U 614 64 1040 5.93 U 1560 5.95 U 351
Methyl tert butyl ether 1634-04-4 0.1 100 100 mg/kg 0.056 U 0.755 U 0.286 U 0.694 U 0.059 U 0.831 U 0.06 U 0.379 U
Naphthalene 91-20-3 4 20 500 mg/kg 0.223 U 9.75 1.15 U 26 0.237 U 40 0.238 U 4.96
Extractable Petroleum Hydrocarbons
2-Methylnaphthalene 91-57-6 0.7 80 300 mg/kg 0.324 U 19.8 U 6.74 U 74.2 U 0.344 U 80.9 U 0.347 U 3.18
Acenaphthene 83-32-9 4 1000 1000 mg/kg 0.324 U 19.8 U 6.74 U 74.2 U 0.344 U 80.9 U 0.347 U 2.01 U
Acenaphthylene 208-96-8 1 600 10 mg/kg 0.324 U 19.8 U 6.74 U 74.2 U 0.344 U 80.9 U 0.347 U 2.01 U
Benzo(a)anthracene 56-55-3 7 7 7 mg/kg 0.324 U 19.8 U 6.74 U 74.2 U 0.344 U 80.9 U 0.347 U 2.01 U
Benzo(a)pyrene 50-32-8 2 2 2 mg/kg 0.324 U 19.8 U 6.74 U 74.2 U 0.344 U 80.9 U 0.347 U 2.01 U
Benzo(b)fluoranthene 205-99-2 7 7 7 mg/kg 0.324 U 19.8 U 6.74 U 74.2 U 0.344 U 80.9 U 0.347 U 2.01 U
Benzo(k)fluoranthene 207-08-9 70 70 70 mg/kg 0.324 U 19.8 U 6.74 U 74.2 U 0.344 U 80.9 U 0.347 U 2.01 U
C11-C22 Aromatics, Adjusted C11-C22-ALPHA-J 1000 1000 1000 mg/kg 6.49 U 1610 1050 7940 6.87 U 13600 6.94 U 1190
C19-C36 Aliphatics C19-C36-ALPHA-UJ 3000 3000 3000 mg/kg 6.49 U 927 462 5020 6.87 U 7460 6.94 U 436
C9-C18 Aliphatics C9-C18-ALPHA-UJ 1000 1000 1000 mg/kg 6.49 U 2190 942 11100 6.87 U 18900 6.94 U 1330
Chrysene 218-01-9 70 70 70 mg/kg 0.324 U 19.8 U 6.74 U 74.2 U 0.344 U 80.9 U 0.347 U 2.01 U
Dibenzo(a,h)anthracene 53-70-3 0.7 0.7 0.7 mg/kg 0.324 U 19.8 U 6.74 U 74.2 U 0.344 U 80.9 U 0.347 U 2.01 U
Indeno(1,2,3-cd)Pyrene 193-39-5 7 7 7 mg/kg 0.324 U 19.8 U 6.74 U 74.2 U 0.344 U 80.9 U 0.347 U 2.01 U
Naphthalene 91-20-3 4 20 500 mg/kg 0.324 U 19.8 U 6.74 U 74.2 U 0.344 U 80.9 U 0.347 U 2.01 U
Phenanthrene 85-01-8 10 500 500 mg/kg 0.324 U 19.8 U 6.74 U 74.2 U 0.344 U 80.9 U 0.347 U 2.01 U
TABLE 2: ANALYTICAL SUMMARY OF SUPPLEMENTAL SOIL ASSESSMENT (8/26/21) VS METHOD 1 - RISK CHARACTERIZATION STANDARDS
MACISAAC IRA RTN4-28586: 24 CHARLES STREET - SOUTH YARMOUTH, MA
Q = QUALIFIER, U=NON-DETECT (REPORTING LIMIT CONCENTRATION REPORTED
GREY FILL = REPORTING LIMIT CONCENTRATION GREATER THAN METHOD 1 STANDARD, GREEN = REPORTED CONCENTRATIONS GREATER THAN METHOD 1 STANDARD, ORANGE= GREATER THAN S-3 DIRECT CONTACT, YELLOW= GREATER THAN UCL
NOVEMBER 8, 2021 MACISAAC: 24 CHARLES STREET – SO YARMOUTH/MCSS-2021-0001
PAGE 9 OF 19 PHASE I/TIER CLASSIFICATION: RTN 4-28586
GREEN SEAL ENVIRONMENTAL | 114 STATE ROAD, BUILDING B, SAGAMORE BEACH, MA 02562 | T: 508-888-6034
Analytical results for quarterly groundwater analysis for samples collected on September 29, 2021 again
reported the absence of groundwater impacts at all monitoring wells (Non-Detect) with the exception of MW-
1, which has consistently shown groundwater impacts at this upgradient location as attributed to preferential
pathway along the silty sand aquiclude at the top of the shallow aquifer. During this sampling round, a 0.01-
foot thickness of LNAPL was reported at MW-1 monitoring well wherein an absorbent pad was used to remove
standing product ahead of sampling. Notwithstanding, the analytical results at the MW-1 monitoring well
reported significantly reduced concentrations of fractional EPH/VPH compounds and target analytes as
compared to the previous quarterly testing in July 2021. Only the C9 to C10 aromatic compounds exceeded
the GW-1, Method 1 Standard as presented in Table 3 below and as included with the laboratory results in
Appendix E.
NOVEMBER 8, 2021 MACISAAC: 24 CHARLES STREET – SO YARMOUTH/MCSS-2021-0001
PAGE 10 OF 19 PHASE I/TIER CLASSIFICATION: RTN 4-28586
GREEN SEAL ENVIRONMENTAL | 114 STATE ROAD, BUILDING B, SAGAMORE BEACH, MA 02562 | T: 508-888-6034
GW-1 GW-2 GW-3 1/20/21 3/9/21
C9-C18 Aliphatic Hydrocarbons 700 5,000 50,000 3,150 ND 200 5,900 ND 100
C19-C36 Aliphatic Hydrocarbons 14,000 NS 50,000 1,440 ND 200 1,940 ND 100
Unadjusted C11-C22 Aromatics 1,700 236 2,560
C11-C22 Aromatic Hydrocarbons 200 50,000 5,000 1,680 219 2,520 114
Acenaphthene 20 NS 10,000 5 ND 5 0.27 ND 0.4
Acenaphthylene 30 10,000 40 ND 1 ND 1 ND 0.19 ND 0.4
Anthracene 60 NS 30 ND 5 ND 5 ND 0.19 ND 0.4
Benzo(a)anthracene 1 NS 1,000 ND 1 ND 1 ND 0.19 ND 0.4
Benzo(a)pyrene 0.2 NS 500 ND 0.2 ND 0.2 ND 0.09 ND 0.2
Benzo(b)fluoranthene 1 NS 400 ND 1 ND 1 ND 0.19 ND 0.4
Benzo(g,h,i)perylene 50 NS 20 ND 5 ND 5 ND 0.19 ND 0.4
Benzo(k)fluoranthene 1 NS 100 ND 1 ND 1 ND 0.19 ND 0.4
Chrysene 2 NS 70 ND 2 ND 2 ND 0.19 ND 0.4
Dibenzo(a,h)anthracene 0.5 NS 40 ND 0.5 ND 0.5 ND 0.19 ND 0.4
Fluoranthene 90 NS 200 ND 5 ND 5 0.19 ND 0.4
Fluorene 30 NS 40 ND 5 ND 5 1.43 ND 0.4
Indeno(1,2,3-cd)pyrene 0.5 NS 100 ND 0.5 ND 0.5 ND 0.19 ND 0.4
2-Methylnaphthalene 10 2,000 20,000 10 5 16.5 1.43
Naphthalene 140 700 20,000 5.9 12.5 1 16.5 4
Phenanthrene 40 NS 10,000 6.8 ND 1 1 ND 0.4
Pyrene 60 NS 20 ND 5 ND 5 0.66 ND 0.4
C5-C8 Aliphatic Hydrocarbons 300 3,000 50,000 573 420 --108
C9-C12 Aliphatic Hydrocarbons 700 5,000 50,000 2,460 1,430 --1080
C9-C10 Aromatic Hydrocarbons 200 4,000 50,000 1,310 976 --601
Benzene 5 1,000 10,000 67 51.1 --ND 2
Ethylbenzene 700 20,000 5,000 108 112 --44.2
Methyl tertiary-Butyl Ether 70 50,000 50,000 ND 10 ND 10 --ND 3
Naphthalene 140 700 20,000 26 24 --13.2
Toluene 1,000 50,000 40,000 283 289 --39.7
Xylenes (total)10,000 3,000 5,000 507 496 --255
Total Metals
Iron NA NA 8,350
Manganese NA NA 263
Dissolved Metals
by EPA Methods
Iron NA NA 7360
Manganese NA NA 252
BOD ----7
COD ----23
DO ----6.96
Nitrate as N ----0.502
pH ----6.37
Redox Potential ----171
Sulfate (Total)NS NS NS ----8.2
TABLE 3: GROUNDWATER SUMMARY ANALYTICAL RESULTS MW-1 VS METHOD 1 STANDARDS
MACISAAC IRA RTN4-28586: 24 CHARLES STREET - SOUTH YARMOUTH, MA
All results in micrograms per liter (µg/L). ND= Non-Detect.
Lt. Green = Concentrations Exceeding the Method 1 Risk Standards, Dk Green = Elevated Metals Concentrations Exceeding Drinking Water Standards
Conventional Chemistry Parameters
7/6/21Sample Date
Sample Identification MW-1MCP Method 1 Risk Characterization
Standards
Extractable Petroleum Hydrocarbons (EPH) by
MassDEP Method EPH-04.1.1
Volatile Petroleum Hydrocarbons (VPH)
by MassDEP Method VPH
9/29/21
NOVEMBER 8, 2021 MACISAAC: 24 CHARLES STREET – SO YARMOUTH/MCSS-2021-0001
PAGE 11 OF 19 PHASE I/TIER CLASSIFICATION: RTN 4-28586
GREEN SEAL ENVIRONMENTAL | 114 STATE ROAD, BUILDING B, SAGAMORE BEACH, MA 02562 | T: 508-888-6034
Indoor air testing results for the basement area samples collected on September 29, 2021 reported significantly
lower concentrations of Air-Phase Petroleum Hydrocarbons (APH) relative to previous testing conducted in
June 2021 with the benefit of active sub-slab venting and sealing of the basement floor. All such APH
concentrations were reported as Non-Detect, or at low level concentrations wherein in all cases, the reported
concentrations or reporting limit concentrations, are significantly less than the Residential Threshold Values
(RTV). APH concentrations in the first-floor sample were consistent with the previous June 2021 results with
the exception of the fact that the concentration of benzene was significantly decreased as considered a
confounding compound and the concentration of C5 to C8 aliphatic compounds was significantly increased. It
is noted that in the review of this data, that benzene in the most recent sampling of the impacted MW-1
monitoring well was absent and C5 to C8 aliphatic compounds were significantly reduced. This combined with
decreasing TOV values in the sub-slab system and the identification of a printing set left in the room where the
indoor air sample was collected provide lines of evidence to consider both benzene and the reported C5 to C8
aliphatic compounds as confounding and not representative of vapor intrusion from the subsurface. The
analytical results are summarized in Table 4 below, and the complete laboratory report is included in Appendix
E.
On October 6, 2021, GSE returned to the property to again pump oily water and LNAPL from the IW-1 well
point in the release area and from monitoring well MW-1, which had been replaced with a 2 inch casing for
this purpose. Again, the use of the vac-truck was limited to the recovery of 200 gallons of oily water with a
heavy sheen and globules of free phase dyed fuel oil. This remedial waste was managed at the Tradebe facility
in Stoughton as documented on the Oil and Hazardous Waste Manifest included in Appendix C.
RISK CHARACTERIZATION AND IMMINENT EVALUATION
Soils
The end point sampling at the extent of the January 2021 excavation, and most recently in the supplemental
soil testing along the perimeter of the area of soil removal, indicates that soil impacts remain above the
Method 1 Risk Characterization standards and in some cases above the S-3 Direct Contact Concentrations
Location
EPC
FF
Sample ID:
Date Sampled:
Air-Phase Petroleum Hydrocarbons (APH) by MassDEP Method RL RL RL RL RL RL
C5-C8 Aliphatic Hydrocarbons 58 330 2,200 27 15 880 18 140 79
C9-C12 Aliphatic Hydrocarbons 68 220 680 40 ND 10 530 ND 12 33 22.5
C9-C10 Aromatic Hydrocarbons 10 44 14 ND 10 ND 10 14 ND 10 ND 10 5
Benzene 2.3 11 ND 2 ND 2 ND 0.6 ND 2 2.6 1.2 1.9
1,3-Butadiene NS NS ND 2 ND 2 ND 0.5 ND 2 ND 2 ND 0.5 1.25
Ethylbenzene 7.4 7.4 2.3 ND 2 ND 0.9 2.2 ND 2 1.3 1.15
Methyl t-butyl ether (MTBE)39 39 ND 2 ND 2 ND 0.7 ND 2 ND 2 ND 0.7 0.85
Toluene 54 54 8.3 ND 2 ND 0.9 8.6 5.7 8.7 7.2
Naphthalene 0.6 2.7 ND 0.63 ND 0.63 ND 0.26 ND 0.63 ND 0.63 ND 0.26 0.22
m&p-Xylene see Total xylenes 14 14
o-Xylene see Total xylenes 4.1 3.8
Total xylenes 20 28 18 2.1 ND 1.8 17 3.3 6 4.65
First Floor Living Room
TABLE 4: INDOOR AIR APH SUMMARY VS RESIDENTIAL THRESHOLD VALUES
MACISAAC IRA RTN4-28586: 24 CHARLES STREET - SOUTH YARMOUTH, MA
All results are in micrograms per cubic meter (µg/m3). Green Shaded = Concentrations Exceeding RTVL Values, Bold values less than 90th percentile
FF-IA3
9/30/2021
FF-IA2
6/24/2021
Residential
Threshold Values 4/13/2021 4/13/2021
90th Percentile
Residential Typical
Indoor Air
Concentrations
B-IA1 FF-IA1B-IA2
6/24/2021
Basement Utility Room
B-IA3
9/30/2021
NOVEMBER 8, 2021 MACISAAC: 24 CHARLES STREET – SO YARMOUTH/MCSS-2021-0001
PAGE 12 OF 19 PHASE I/TIER CLASSIFICATION: RTN 4-28586
GREEN SEAL ENVIRONMENTAL | 114 STATE ROAD, BUILDING B, SAGAMORE BEACH, MA 02562 | T: 508-888-6034
considered under Method 2 and the Upper Concentration Limits. Based on the intensity, frequency and
accessibility of these soils, which are at least 14 feet below the existing exterior grade, or 8 feet below the
footprint of an existing structure, the soil conditions do not represent any Imminent or Substantial Hazards
relative to associated ingestion, inhalation or dermal contact exposures at this time. Notwithstanding, these
soil concentrations result in the leaching of petroleum hydrocarbons into groundwater as dissolved and free
phase concentrations and accumulations and represent the source for the vapor intrusion pathway identified
and a potential for substantial release migration to downgradient environmental receptors. Such conditions
require additional remedial response actions under the existing IRA to eliminate Significant Risk under the
foreseeable future use and activities at the property.
Groundwater
LNAPL accumulations and groundwater impacts at MW-1 and in the area intermediate and including the
previous area of soil removal exist above the Method 1 – Risk Characterizations standards and contribute to
the vapor intrusion pathway and potential impact to downgradient receptors as noted. Notwithstanding the
fact that the groundwater is likely to qualify as a Non-Potential Drinking Water Source Area for elevated metals
and as subject to saltwater intrusion, the presence of LNAPL is a driver for vapor intrusion pathway and the
likelihood of substantial release migration. No such downgradient migration is apparent from the most recent
testing, and the engineering controls appear to be effective in controlling vapor intrusion and significant
inhalation risk. As such, under current conditions, no Imminent or Substantial Hazards are apparent as
associated with the ingestion, inhalation or dermal contact exposure to impacted groundwater. Such
conditions do, however, require additional remedial response actions under the IRA to eliminate Significant
Risk under the foreseeable future use and activities at the property.
Vapor Intrusion/Indoor Air
The effectiveness of the active system was re-evaluated by repeated APH testing of indoor air on September
29, 2021 as noted above. Notwithstanding the use of lines of evidence to exclude benzene and increased C5
to C8 aliphatic compounds as confounding and as within the 90% of background concentrations measured in
homes without a heating oil release, the entirety of the analytical results was evaluated under the Method 3
ShortForms for Imminent Hazard and Significant Risk. Such forms were peer reviewed by Debbie Listernick, a
Risk Assessor with the firm of O’Reilly, Talbot and Okum Engineering in Boston, MA, to qualify findings as
presented below.
NOVEMBER 8, 2021 MACISAAC: 24 CHARLES STREET – SO YARMOUTH/MCSS-2021-0001
PAGE 13 OF 19 PHASE I/TIER CLASSIFICATION: RTN 4-28586
GREEN SEAL ENVIRONMENTAL | 114 STATE ROAD, BUILDING B, SAGAMORE BEACH, MA 02562 | T: 508-888-6034
In the evaluation of the full data set, resulting Excess Lifetime Cancer Risk (ELCR) are less than the 1 x 10-5 and
the Hazard Index (HI) does not exceed 1.0 using the one significant figure rule. These ShortForms indicate that
there is no Imminent or Substantial Hazard associated with the inhalation of impacted air attributed to vapor
intrusion under current conditions. Such conditions do, however, require additional remedial response actions
under the IRA to eliminate Significant Risk under the foreseeable future use and activities at the property
without reliance on mechanical systems to prevent vapor intrusion at higher concentrations.
Resident - Indoor Air: Table RAIH-1 ShortForm Version 10-12
Exposure Point Concentration (EPC)Vlookup Version v0315
Based on Resident Age 1-6 (Cancer and Noncancer)
ELCR (all chemicals) =6.69E-07
**Do not insert or delete any rows**HI (all chemicals) =8.92E-01
Click on empty cell below and select OHM using arrow.
Oil or EPC
Hazardous Material (µg/m 3)ELCRair HQair
BENZENE 1.2E+00 6.7E-07 1.2E-01
ALIPHATICS C5 to C8 1.4E+02 7.0E-01
TOLUENE 8.7E+00 1.7E-03
ETHYLBENZENE 1.3E+00 1.4E-04
XYLENES (Mixed Isomers)6.0E+00 1.5E-02
ALIPHATICS C9 to C12 3.3E+01 5.5E-02
Resident - Indoor Air: Table RA-1 ShortForm Version 10-12
Exposure Point Concentration (EPC)Vlookup Versionv0315
Based on Resident Ages 1-31 (Cancer) and 1-8 (Noncancer)
ELCR (all chemicals) =4.01E-06
**Do not insert or delete any rows**HI (all chemicals) =1.05E+00
Click on empty cell below and select OHM using arrow.
Oil or EPC
Hazardous Material (µg/m 3)ELCRair HQair
BENZENE 1.2E+00 4.0E-06 1.2E-01
ALIPHATICS C5 to C8 1.4E+02 7.0E-01
TOLUENE 8.7E+00 1.7E-03
ETHYLBENZENE 1.3E+00 1.3E-03
XYLENES (Mixed Isomers)6.0E+00 6.0E-02
ALIPHATICS C9 to C12 3.3E+01 1.7E-01
Resident - Indoor Air: Table RA-1 ShortForm Version 10-12
Exposure Point Concentration (EPC)Vlookup Versionv0315
Based on Resident Ages 1-31 (Cancer) and 1-8 (Noncancer)
ELCR (all chemicals) =6.35E-06
**Do not insert or delete any rows**HI (all chemicals) =8.44E-01
Click on empty cell below and select OHM using arrow.
Oil or EPC
Hazardous Material (µg/m 3)ELCRair HQair
BENZENE 1.9E+00 6.4E-06 1.9E-01
ALIPHATICS C5 to C8 7.9E+01 4.0E-01
TOLUENE 7.2E+00 1.4E-03
ETHYLBENZENE 1.2E+00 1.2E-03
XYLENES (Mixed Isomers)4.7E+00 4.7E-02
ALIPHATICS C9 to C12 2.2E+01 1.1E-01
AROMATICS C9 to C10 5.0E+00 1.0E-01
METHYL TERT BUTYL ETHER 8.5E-01 2.8E-04
EPC FF 6/24/21 and 9/30/21
NOVEMBER 8, 2021 MACISAAC: 24 CHARLES STREET – SO YARMOUTH/MCSS-2021-0001
PAGE 14 OF 19 PHASE I/TIER CLASSIFICATION: RTN 4-28586
GREEN SEAL ENVIRONMENTAL | 114 STATE ROAD, BUILDING B, SAGAMORE BEACH, MA 02562 | T: 508-888-6034
REVIEW OF REMEDIAL ALTERNATIVES UNDER THE IRA [Refer to Appendix D]
MicroBac is a provider of a biological remedial additive that has cultured total petroleum hydrocarbon (TPH)
degrading bacteria (M1000H) in conjunction with a nutrient solution (Tri-Phasic 12) to provide biological
mineralization of petroleum hydrocarbons in soils and groundwater. Regenesis is the provider of the various
remedial additives used for petroleum remediation. Their PetroFix product is a powdered activated carbon
that absorbs petroleum hydrocarbons from soil and groundwater and fixes such compounds such that bacteria
can feed on the carbon source. This product was considered in addition to the MicroBac as a viable bio-
remedial strategy. A second product, RegenOx, as a two-part slow-release oxidant was considered in the
aggressive soil removal strategy as a contingency for any remaining soil or groundwater impacts as a polishing
agent. Information on these products, site characterization inputs and recommendations are provided in
Appendix D.
Based on the review of projected costs and the relative advantages and disadvantages of the remedial
alternatives presented, the owner wishes to proceed with the physical removal of impacted soils and
groundwater through de-watering with contingency for RegenOx wherein at the limit of excavation, RegenOx,
Part A would be mixed with bottom of hole soils, and an infiltration system would be constructed for potential
application of the RegenOx, Part B activator for chemical oxidation treatment. Such would be accomplished
under the existing verbal approvals with the understanding that the addition of the Part B activator solution
would require written authorization and would be framed as an IRA Modification as requested herein on the
BWSC-105 submittal [Refer to Appendix B]. The dwelling would be shored and temporarily moved off the
foundation with occupants temporarily relocated. The clean overburden would be removed and segregated
for re-use (approximately 120 yards). Once completed, impacted soils would be excavated for direct loading
and transport to Ondrick from 4-10 feet below the basement floor, as some 10-16 feet below grade in the front
yard area (approximately 115 yards), facilitated by dewatering. At the extent of the excavation at 2 feet below
the groundwater interface, some 2,280 pounds of RegenOx, Part A would be mixed with soils into the bottom
of hole area, and an infiltration system of perforated pipe in double-washed stone would be constructed within
the excavation to stabilize the open hole pending the receipt of analytical results for endpoint soil samples
collected. Based on these results meeting the applicable Method 1 standards or otherwise under Method 3
considerations, the decision for the application of the RegenOx, Part B activator would be made as based on
prior written approval expressly requested under this IRA Status Report with IRA Modification. Some 440
pounds of RegenOx, Part B would be mixed with 600-800 gallons and water and applied to the bottom of hole
area through the infiltration system or otherwise over the washed stone as based on conditions on the ground
at the time of such decision.
PHASE I INITIAL SITE INVESTIGATION
General Disposal Site Information
The subject property is a 0.79-acre parcel of land at 24 Charles Street in South Yarmouth, Massachusetts,
owned by MacIsaac Amy Trustee/Amy MacIsaac Rev Trust, and currently used as a primary residence. The
Town of Yarmouth identifies the property as Parcel ID 70-113-10256 as some 1,500 feet north of the Bass River
Bridge in South Yarmouth at the West Dennis Town line. According to the Town of Yarmouth Assessor’s
database, the property is improved upon by a single-story, single-family residence, with a living area of 1,928
square-feet, constructed in 1945. The dwelling has a garage with living space upstairs and a walkout basement.
The improvements include a wooden deck, landscaped areas, and a gravel driveway.
NOVEMBER 8, 2021 MACISAAC: 24 CHARLES STREET – SO YARMOUTH/MCSS-2021-0001
PAGE 15 OF 19 PHASE I/TIER CLASSIFICATION: RTN 4-28586
GREEN SEAL ENVIRONMENTAL | 114 STATE ROAD, BUILDING B, SAGAMORE BEACH, MA 02562 | T: 508-888-6034
According to the 2018 USGS topographic map (Dennis, Massachusetts quadrangle), the property is situated
approximately 15 feet above the mean sea level on the western portion (front of the property); and slopes
down into the 100-year flood zone as waterfront property abutting the Bass River tidal estuary. The subject
residential property is surrounded by similar high density residential properties to the north, west, and south.
High density commercial development is to the south along Route 28 as a State Highway and transportation
corridor. The subject property and the surrounding properties are all serviced by an extensive municipal water
system with no potable wells within 500 feet of the Disposal Site, and neither the subject property nor Disposal
Site fall within any designated Zone II – Wellhead Protection area or Zone A of any surface water reservoir.
There is no municipal sewering in the area and the subject and abutting properties are on private septic
systems. A stormwater drain is located along the southern property boundary pursuant to an easement
agreement with the Town of Yarmouth, and the outfall is located on the subject property.
Based on the Mass GIS Priority Resource mapping overlay and Phase I Site Assessment Map, the property
categorically falls within the Cape Cod Sole Source Aquifer, and as such the GW-1, Method 1 – Risk
Characterization drinking water standards would apply [Refer to Figure 2 – Appendix A]. These standards for
drinking water ingestion exposure are overstated in the area of the subject property as a high-density
residential area abutting a tidal estuary wherein the density of development and potential source of pollutants
from private sewage discharge and threat of salt water intrusion preclude the development of a public water
supply. Notwithstanding further considerations under the provisions of 310 CMR 40.0932(5), the GW-1
standards are considered under the review of additional remedial response measures under the IRA to absolve
significant exposure risks to human and environmental receptors identified. Additionally, based on the depth
to groundwater at approximately 8-9 feet below grade in the area of the release and footprint of the occupied
residential dwelling, the GW-2 and GW-3 Method 1 – Risk Characterization standards are considered in the
evaluation of Significant Risk. Based on soil impacts within the release area being below a permanent structure
or at depths greater than 4 feet below the existing grade, the S-2 and S-3/GW-`1, GW-2 and GW-3 soil criteria
are considered under existing conditions. The S-1/GW-1, GW-2 and GW-3 criteria are further considered under
the foreseeable future use and activities at the subject property.
Disposal Site Map
The Disposal Site, as the subject of RTN 4-28586, is defined by those areas significantly impacted by the fuel
oil release and include a portion of the subject property at 24 Charles Street in South Yarmouth, MA. The
Disposal Site covers an approximate 30 foot wide x 30 foot long area under the central portion of the dwelling
and extends into the front yard and driveway area in the vicinity of the front entrance and location of
monitoring well MW-1. This approximate 900 square foot area is depicted on the Site Plan in Appendix A.
NOVEMBER 8, 2021 MACISAAC: 24 CHARLES STREET – SO YARMOUTH/MCSS-2021-0001
PAGE 16 OF 19 PHASE I/TIER CLASSIFICATION: RTN 4-28586
GREEN SEAL ENVIRONMENTAL | 114 STATE ROAD, BUILDING B, SAGAMORE BEACH, MA 02562 | T: 508-888-6034
Disposal Site History
According to the Town of Yarmouth Assessors records, the subject property was constructed in 1945 and has
been in residential use since that time. The current Trust was established in April 2020, and the property was
previously in the Lockhart family since 1985. There is no known prior use of the property prior to 1945.
Release History
The Disposal Site is the subject of RTN 4-28586, where an estimated 200+ gallons of No. 2 fuel oil was released
to soils and groundwater underlying the dwelling in or around November 6, 2020. Notification of the release
was made on November 11, 2019 following subsurface investigations conducted by GSE confirming such
impacts to the environment. Verbal IRA approvals have been granted for the removal of up to 200 yards of
impacted soils, the evacuation/recovery of up to 2,500 gallons of LNAPL and oily water, and the operations,
maintenance and monitoring of an active sub-slab venting system. Response actions taken to address the
release have included environmental assessment, the removal of some 17 yards of impacted soils and 300
gallons of LNAPL and oily water. These response actions are documented in the Immediate Response Action
Plan (1/6/20), Immediate Action Status Report #1 (3/11/20) and Immediate Response Action Status Report #2
(9/14/20) with accompanying Transmittal forms, filed with the MassDEP and part of the public record.
Oil and/or Hazardous Material Use and Storage History
No. 2 fuel oil has historically been stored at the subject property for heating purposes. A single-walled, 275-
gallon AST was located in the basement of the dwelling prior to the subject release in November 2020.
Subsequent to soil removal in January 2021, the property was converted to natural gas. Small quantities of
fuel, paints and cleaning supplies are stored and used at the property as typical of residential use. Otherwise,
there has been no use or storage of any significant quantities of oil and/or hazardous material (OHM).
Waste Management History
Typical household solid waste (trash/garbage) is generated at the property as periodically removed and taken
to the local municipal transfer station for licensed management or disposal. Sanitary waste from the
residential dwelling is managed with a private subsurface sewage disposal system located northwest of the
subject building. As part of the remedial response actions undertaken under RTN 4-28586, remedial waste
generated has been managed at licensed facilities as documented on Bill of Ladings or Uniform Hazardous
Waste Manifests.
Environmental Permits and Compliance History
Remedial response actions under the Immediate Response Action conducted under verbal approval granted
by the MassDEP. These approvals are documented in various BWSC-101 and BWSC-102 forms issued between
November 11, 2020 and August 5, 2021. The subject property falls within the 100 foot buffer zone to a Coastal
Bank and as such is subject to jurisdiction under the Wetlands Protection Act. Initial response actions were
reported to the Yarmouth Conservation Department and work initially proceeded under what appears to have
been an understanding that such work was covered under the existing Order of Conditions for SE83-2253
issued on January 19, 2021. On Successor LSP engagement, the Yarmouth Conservation Administrator was
contacted to confirm such understanding and advised that an Emergency Certification would be issued to cover
NOVEMBER 8, 2021 MACISAAC: 24 CHARLES STREET – SO YARMOUTH/MCSS-2021-0001
PAGE 17 OF 19 PHASE I/TIER CLASSIFICATION: RTN 4-28586
GREEN SEAL ENVIRONMENTAL | 114 STATE ROAD, BUILDING B, SAGAMORE BEACH, MA 02562 | T: 508-888-6034
previous work but that moving forward with work beyond environmental testing, a Modification to the Notice
of Intent specifically for future soil removal would be required within 60 days of the September 8, 2021 granting
of the Emergency Certification. At the time of this filing, the NOI Modification is being prepared for filing,
public hearing and approval in advance of the start of the planned IRA Modification with contingency for
remedial additive use and chemical oxidation treatment of residuals.
These events document environmental permitting and compliance history. The filing of this Phase I Initial Site
Investigation and Tier 1 Classification with IRA Status Report, represents a return to compliance in pursuit of a
Permanent Solution by way of IRA Modification, as outlined herein.
Site Hydrological Characteristics
Environmental assessment activities performed at the Site over the past twelve months, have included at least
seven (7) test borings and twenty-two (22) hand borings for soil sampling and subsurface characterization, and
the installation and testing of seven (7) monitoring wells. Surficial soils at the subject property consist of
primarily of glacial outwash sands typical of Harwich Outwash Plain deposits. Site specific geology shows that
these unconsolidated sands are interbedded with silts and clays as likely under the influence of more recent
deposits along the Bass River. These low permeability silty members are present at the subject property and
make up the upper portion of the shallow aquifer at some 14 feet below grade at the front of the house and
at less than 8 feet below grade from the basement floor. The differential in porosities and permeability of
these soils, and apparent dip of bedding to the west, have influenced the migration of oil from under the house
towards MW-1 in an upgradient location.
Groundwater gauging was conducted during site visits made by GSE throughout the IRA. Well gauging was
used to compute site-specific groundwater flow direction as tidally influenced and ranging from a north-
northeasterly to easterly direction as shown on the Site Plan in Appendix A. The resulting solute pathway is
towards Bass River approximately 225 feet to the east. Based on the measured shallow hydraulic gradient
between MW-1 and MW-3 (7/6/21: 0.0071 ft/ft), and estimated hydraulic conductivity of the fine to very fine
silty sands in the upper aquifer as 25 ft/day with 20% porosity, a groundwater flow velocity of 0.5 ft/day is
estimated with a 10% retardation considered. As such, the time of travel to intermediate downgradient wells
is estimated as 60-80 days. As such, groundwater sampling after January 2021 (3/9/21, 7/6/21 and 9/29/21)
would be representative of dissolved phase, downgradient groundwater impacts associated with the
November 2020 release. No such downgradient impacts have been reported outside the area of the release
as again attributed to the silty nature of the silty sands in the upper aquifer.
Nature and Extent of Contamination
Significant residual soil impacts remain below and at the perimeter of the previous excavation within a 30 foot
x 30 foot area as appearing to be restricted in soils some 4-10 feet below the basement floor as corresponding
to the seasonally adjusted groundwater interface. Such soil impacts and LNAPL accumulations have resulted
in dissolved phase groundwater impacts as noted within a slightly larger footprint from within the central
portion of dwelling and extending westerly by preferential travel to the front entrance exterior area in the
vicinity of monitoring well MW-1. These impacted soils and groundwater, in close proximity to the finished
basement floor have resulted in a vapor intrusion migration pathway to the dwelling, which is currently being
mitigated by engineering controls and active sub-slab venting. These areas of residual soil and groundwater
impact, and vapor exposure pathway are targeted for further remedial response actions under the IRA
Modification.
NOVEMBER 8, 2021 MACISAAC: 24 CHARLES STREET – SO YARMOUTH/MCSS-2021-0001
PAGE 18 OF 19 PHASE I/TIER CLASSIFICATION: RTN 4-28586
GREEN SEAL ENVIRONMENTAL | 114 STATE ROAD, BUILDING B, SAGAMORE BEACH, MA 02562 | T: 508-888-6034
Migration Pathways/Exposure Potential
Notwithstanding the fact that impacted soils are mostly isolated under the footprint of the dwelling or of
limited accessibility with low frequency and intensity of use below 6 feet and that dissolved phase groundwater
impacts appear restricted to the release area in silty soils as not driving any substantial hazard under current
conditions, these impacts are the driver for vapor intrusion as a CEP and must be addressed for IRA Completion
and in support of a Permanent Solution for closure. Future response actions under the continuing IRA
Modification are intended to remove impacted soils and groundwater and eliminate the CEP to document a
finding of No Significant Risk for the foreseeable future to support a Permanent Solution without conditions as
the expressed objective of the owner.
EVALUATION OF NEED FOR IRA/PHASE II SCOPE OF WORK
An Immediate Response Action is already in place and will continue through the filing of this Phase I Initial Site
Investigation and Tier 1 Classification wherein a CEP is present. The continuation of the IRA will be used to
remove additional impacted soils and groundwater with contingency for additional chemical oxidation
treatment if deemed necessary as driven by significant exposure risk to identified human and environmental
receptors. Such will support a finding of No Significant Risk as technical justification for an IRA Completion
and Permanent Solution Statement. The continuation of the IRA under Modification to include the contingency
for chemical oxidation treatment using the RegenOx remedial additive is at this time considered the Phase II
Scope of Work. The design, permitting and approval of such work is expected to take place within 30-days of
this filing.
Monthly inspections for the operation, maintenance and monitoring of the sub-slab venting system will
continue with measurement of TOV influent and effluent. The off-gas GAC treatment will be maintained
throughout operation and the GAC filter changed once significant breakthrough is noted (>20% of influent
concentration) and the spent treatment filters recycled for re-use or otherwise managed as remedial waste.
Quarterly sampling of monitoring wells for EPH/VPH analysis will continue through the planned IRA
Modification as will quarterly indoor air testing for APH as long as the building remains occupied. Additionally,
baseline water quality testing (iron, sulfate, sodium, pH, ORC, conductivity and DO) will be repeated in the
upgradient MW-6 monitoring well and downgradient MW-3, MW-4 and MW-7 monitoring wells and repeated
monthly following RegenOx, Part B activator use. Indoor air testing or sub-slab soil vapor testing will be
repeated prior to re-occupancy.
A Bill of Lading will be prepared and approved by the receiving facility in advance of soil removal for direct
loading, transportation and recycling of impacted soil. Hazardous Waste Manifests will be used otherwise for
transport and recycling of impacted water and LNAPL from de-watering operations. Endpoint soil samples will
be collected from discrete sidewall and bottom of hole areas for EPH/VPH analysis with target analytes.
PHASE I COMPLETION STATEMENT
The Phase I Investigation has been completed in accordance with the provisions of 310 CMR 40.0480 and a
Completion Statement is made herein, in accordance with 310 CMR 40.0484. The Phase I Investigation has
been used to qualify the source of fuel oil contamination and to qualify the extent and magnitude of soil and
groundwater impacts as limited to the areas of remedial response actions under the IRA. Environmental
assessment activities performed have been used to characterize hydrogeologic conditions, establish potential
NOVEMBER 8, 2021 MACISAAC: 24 CHARLES STREET – SO YARMOUTH/MCSS-2021-0001
PAGE 19 OF 19 PHASE I/TIER CLASSIFICATION: RTN 4-28586
GREEN SEAL ENVIRONMENTAL | 114 STATE ROAD, BUILDING B, SAGAMORE BEACH, MA 02562 | T: 508-888-6034
migration pathways and review critical exposures for the discrete area of residual soil and groundwater
impacts remaining. Such information serves as the basis of the Tier 1 Classification for the Site. Due to the
fact that vapor intrusion and unmitigated impact to indoor air, as a CEP, potentially represents a long-term
significant exposure risk, the Site is categorically defined as a Tier 1 Site, pursuant to 310 CMR 40.0520(2) (a).
CONCLUSIONS
The analytical data for soil, groundwater and indoor air testing conducted to date have been evaluated wherein
no Imminent or Substantial Hazards are opined under current conditions and temporary engineering controls.
Notwithstanding, additional remedial response actions are required to support a condition of No Significant
Risk for all potential exposures in the foreseeable future to support regulatory closure and filing of an IRA
Completion and Permanent Solution Statement wherein a CEP exists. Additional response actions presented
herein for the removal of additional soil and impacted groundwater will be conducted under verbal approvals
previously granted. The contingency for remedial additive use for chemical oxidation treatment of any
residuals however considered an IRA Modification and does expressly need written approval as now being
sought to proceed. Future environmental assessment/monitoring activities will dictate the need for any
additional remedial measures to be represented in future IRA Status reports or under the Comprehensive
Response Actions statutory timelines to follow.
The findings of this investigation, as represented herein, set forth the rationale and technical
justification for the Phase I Completion Statement and Tier I Classification established by the certifications
made on the attached Transmittal Forms. The LSP opinions are based upon available data and regulations in
effect at the time of this reporting. If you have any questions, or need additional information, please contact
us directly at your earliest convenience.
Sincerely,
GREEN SEAL ENVIRONMENTAL, LLC
____________________________ __________________________
David C. Bennett, LSP Victoria Costa, Project Manager
Technical Advisor Manager of Environmental Services
Encl: Supporting Documentation [Appendices A-G]
Cc: Amy MacIsaac, Trustee (Owner/PRP)
Robert Whritenour, Town Administrator - Town of Yarmouth, rwhritenour@yarmouth.ma.us 1
Chief Philip Simonian, Yarmouth Fire Department, psimonian@yarmouth.ma.us1
Carl Lawson, Inspector – Yarmouth Health Department, lawson@yarmouth.ma.us1
Kelly Grant, Administrator – Yarmouth Conservation Department, kgrant@yarmouth.ma.us1
1 As part of Public Notice requirements, the report Title Page, Narrative, Index, Transmittal forms and Site Plan are
included, pursuant to paperwork reduction policy. The full report is available as public record on the MassDEP website
database at https://eeaonline.eea.state.ma.us/portal#!/search/wastesite or, upon written request to GSE, full copy
(electronic or paper) will be provided.