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HomeMy WebLinkAboutenvironmental assessment 2015BENNETT ENVIRONMENTAL ASSOCIATES, INC. LICENSED STTE PROFESSIONALS, ENVIRONMENTAL SCIENTISTS, GEOLOGISTS, ENGINEERS 1573 Main Street, P.O. Box 1743 Brewster, MA 02631 TO Mr. Jaime Goncalves, Case Officer MA DEP - SERO Bureau of Waste Site Cleanup (BWSC) 20 Rivenide Drive Lakeville, MA 02347 LETTER OF TRANSMITTAL DATE: 619115 (s08) 896-r706 fax (508)896-5109 JOB NUMBT]R: uEAl5-10746 REGARDIN(;: SI I I PPI\(; \I I]'I'HOI): Gleason Residence, 8l Ddving Tee Circle, South Yarmouth, MA RTN 4-25484 COPIES D,\'I't]DESCRIPTION I 614/15 IMMEDIATE RESPONSE ACTION STATUS I REPORT, with Supporting Documentation For review and comment tr For approval tr As requested tr For vour use:tr REMARKS: cc: Kate Cole - Daughter of Homeowner/?RP, POA (Electronic copy on CD) Susan Crane, Esquire - Counsel to Homeowner (Eleclronic copy on CD) Lt. hspector Matt Bea$e - Yarmouth FD (narrative, index and site plan) Carl Lawson, Jr. - Yarmouth Health Div. (nanative, index and site plan) William Hinchey - Yarmouth To\a! Manager (narrativ€, index and site plan) FROM: David C. Bennett, LSP, Principal, and Todd M. Everson, ES, Senior Project Manager / lr IfenclosEes are not as noteq kindly nodry us at onc€ Mail n tr tr tr Pick Up Hand Deliver Other_UPM Green Card/RR riority Mail Express Mail Certified Mail tr ! a tr IMMEDIATE RESPONSE ACTION STATUS I SUPPORTING DOCUM ENTATION RTN 4-25484 Gleason Residence 81 Driving Tee Circle - South Yarmouth, MA [Assessors Map 101, Parcel 3] BEA15-10746 JUNE 4,2015 \ \ ,6nNNBrr ExvIRoNMENTAL AssocIATEs, INC. LICENSEDSITE PROFESSIONALS L ENVIRONMENTAL SCIENTISTS I. GEOLOGISTS t. ENGINEERS 1573 Main Street - PO. Box 1743, Brewster, MA 02631 (r 508-896-1706 {, Fax 508-896-5109 {, www.bennett-ea com BEAt 5-10746 June 4, 201 5 Mr. Jaime Goncalves, Case Officer MA DEPARTMENT OF ENVIRONMENTAL PROTECTION (MA DEP) Southeast Regional Office (SERO) Bureau of Waste Site Cleanup (BWSC) 20 Riverside Drive Lakeville, M402347 RE IMMEDIATE RESPONSE ACTION STATUS I Gleason Residence -- RTN 4-25484 81 Driving Tee Circle - South Yarmouth, MA [Assessor's Map 101, Parcel 3] Dear Mr. Goncalves, BENNETT ENVIRONMENTAL ASSOCIATES, INC. (BEA) has prepared this Immediate Response Action Status I report (IRAS I) with Supporting Documentation as a sunmary of the circumstances of release discovery, response actions, environmental assessment and contaminated soil removal conducted at the above referenced property following Release Notification and issuance of the Notices of Responsibility to the Homeowner and Hall Oil Company, Inc. Immediate Response Actions have been performed under verbal authorizations in response to a reported 50 gallon release of #2 fuel oil from an above ground storage tank (AST) in the dwelling basement, to evaluate any potential exposure risks inclusive of any Imminent Hazard or Substantial Release Migration conditions. The IRAS I report focuses on those response actions performed subsequent to the filing of the IRA Plan in April 2015. Those response actions performed within the initial 60 days from Release Notification are summarized herein to orient the reviewer to the ongoing remedial response. The homeowner relocated fiom the subject dwelling towards the end of2014. Alerted to a low fuel level by a neighbor, who was serving as caretaker of the property, the homeowner contacted Hall Oil Co., Inc. (dba The Oil Peddler), as a local provider of fuel, to make a delivery. The caretaking neighbor provided access and witnessed the delivery. During delivery, the driver became aware that something was wrong with the conveyance and/or storage of the fuel oil. The driver stopped delivery, entered the dwelling, identified an actively leaking AST and reportedly called Hall Oil for assistance. The Yarmouth Fire Department was contacted to respond, who in tum notified the MA Department of Environmental Protection (MA DEP). Hall Oil also contacted Global Remediation Services for further recovery of fuel oil, and to stabilize site conditions. The sum of emergency response actions resulted in the transfer of fuel oil from the ruptured tank to the supplemental tank and a 55-gallon drum to stop the leak, the application and containment of speedy-dry to the basement floor to recover spilled fuel oil, and the removal and containment of fuel oil stained household items from the basement. The remedial waste was I EMERGENCYSPILLRESPONSEgWASTESITECLEANUPLSITdASSESSMENTLPERMITTINGLSEPTICDESIGN&INSPECTION WATER SUPPLY DEVELOPMENT, OPERATION & MAINIENANCE L WASTEWATER TREATMENT, OPERATION & MAINTENANCE JUNE 4,2015 PAGE 2 OF 17 GLEASON/BEAI5-I0746 IRA STATUS I, RTN 4.25484 stored outside in a sheltered location. This represents the extent of work performed by Hall Oil Company and their subcontractors. BEA was engaged in the days following the release to establish engineering controls to restore indoor air quality, perform environmental assessment to qualifu the extent and magnitude of impact, and direct cleanup operations. As a result of active ventilation and vapor barriers, indoor air quality has been restored with TOV concentrations currently reported less than 1 ppmv. Environmental assessment and remedial response actions in the dwelling basement were facilitated by the removal of interior, fuel oil stained wood-framed walls and other impacted household debris. Impacted debris and residual fuel oil were transported from the subject property for proper disposal. Based on the extensive assessment performed, contaminated soil removal within the qualified Zone A in the dwelling basement has been completed wherein field testing of end-point soil samples has indicated background conditions. Those portions of the basement concrete floor that received the release have been demolished, removed and managed as remedial waste. Environmental assessment of soils formerly beneath the concrete floor has begun with select TOV-biased samples submitted for laboratory analysis of petroleum hydrocarbon concentrations. Those analltical results were pending at the time of this report. Environmental assessment along the filUvent pipes were performed to qualify the extent and magnitude of the exterior fuel oil impacts to soils, noted as Zone B, as are associated with the apparent overfill ofthe ASTs. Contaminated soil removal was begun along Zone B; however further excavation has been temporarily suspended due to the discovery of a 4' frost wall where the extent of fuel oil impacts along Zone B appear greater than originally qualified. This situation requires additional shoring to address structural concems prior to completing soii removal. Additional environmental assessment has begun to firther qualifu the extent and magnitude of the Zone B impacts, with laboratory analytical of select TOV-biased samples pending at the time of this report. The pending laboratory analysis will be employed to direct further assessment, and subsequently contaminated soil removal, along Zone B. Currently, verbal authorization fiom the Departrnent is limited to 30 cubic yards of contaminated material. Based on the findings of the current environmental assessment, BEA hereby seeks a 25 yard extension (55 yards total) of verbal authorization for soil removal under the IRA to accommodate additional contaminated soil removal anticipated. At this time, most of the household items have been removed from the dwelling to accommodate remedial lesponse actions and the subsequent planned sale of the property. Engineering controls have been maintained to minimize mobilization of fuel oil vapors throughout the dwelling. The homeowner does not reside at the subject property and the dwelling has been unoccupied since prior to the release. The dwelling is kept locked against unauthorized access. The Zone B area of excavation has been capped with wood timbers, plywood and plastic sheeting against collapse and precipitation, as could exacerbate environmental conditions. Based on the response actions and environmental assessment performed, and that the property is unoccupied, no Imminent Hazards or Substantial Hazards have been reported under existing conditions. The investigation of potential Imminent or Substantial Hazard conditions will continue under the IRA in consideration of worker safety and as part of the vapor entry and closure objectives. \ JUNE 4, 20I5 PAGE 3 OF 17 GLEASON,tsEA15-I0746 IRA STATUS I, RTN 4.25484 Aggressive soil removal for the excavation and recycling of impacted soil and stained concrete has been developed as cost efficient, with the highest degree of certainty over the shortest period of time, to absolve further damage to the property and potential exposures to future inhabitants, and to absolve potential leaching to the groundwater. The continuation ofthe IRA for aggressive soil removal prescribes additional environmental assessment to qualifu residual fuel oil impacts along Zone B, and in soils formerly beneath the removed portion of the basement concrete floor. Based on the proposed environmental assessment, the scope of work to remove fuel oil impacted soils will be revised as will require additional structural shoring to accommodate excavation beneath load bearing points. It is expected that these changes and the retum to soil removal will occur within two-weeks of this filing. End-point soil sampling and laboratory analysis will be relied upon to qualifo remedial response performance in review of potential dermal contact, ingestion and inhalation exposure risks to identified human receptors, leaching to groundwater, and impacts to other environmental resources. Based on the remedial response performance evaluation, infiltration systems comprised of stone ag$egate and perforated piping may be constructed and installed concurent with backfill of Zote A and/or Zone B as a contingency for further treatment of soil and/or groundwater, or for venting of residual VOCs, as necessary. If significant VOC concentrations are reported in end-point soil samples, indicating potential vapor entry into the building, soil vapor testing will be conducted following the remedial response to qualify the potential for vapor intrusion and to determine if soil vapor and indoor air are media of concem. Additional testing ofindoor air will be considered based on a "lines of evidence" evaluation, following the removal of all impacted building materials and end-point soil sampling, PID screening, discemable odors and soil vapor testing. Based on the vertical extent of significant impacts, particularly those impacts along Zone B as susceptible to the receipt of precipitation, the potential for groundwater impact as a result of the subject release will continue to be investigated under the IRA in review of risk characterization and project closure objectives. Future environmental assessment activities will dictate the need for any additional remedial measures to be represented in future IRA Status reports filed within 6 months of this IRA Plan, and every six months thereafter. Remedial response and environmental assessment activities proposed herein, and potentially to follow, are intended to mitigate any Critical Exposure Pathways and Significant Risk to identified human and environmental receptors towards a Permanent Solution Statement (PSS). It is the objective to offer a PSS with a preponderance ofphysical evidence to support a finding ofNo Significant Risk in advance of the one-year Tier Classification statutory deadline. The information contained herein serves as the technical rationale andjustification for the environmental assessment and response actions previously conducted as well as those further activities proposed within. This work has and will continue to precede under direct LSP supervision in a manner consistent with the MCP Response Action Performance Standards (RAPS) pursuant to 310 CMR 40.0191 and the QA/QC policies of BENNETT ENVIRONMENTAL ASSOCIATES, INC. The facts and statements herein are, to the best of our knowledge, a true and accurate representation ofthe Site activities, remedial response actions / \ JUNE 4,2015 PAGE 4 OI: I7 CLEASON/BEAI5-I0746 IRA STATUS I, R]-N 4-25484 and environmental conditions associated with the project and LSP Opinions acknowledged by the certification on the attached BWSC-I05 Transmittal Form. ENVIRONMENTAL CONDITIONS [Refer to Appendix A] The subject Gleason residential property is located at 81 Driving Tee Circle in South Yarmouth, MA. The subject property is some 500' (+/-) north of the Driving Tee Circle/Curve Hill intersection [Refer to Figure 1]. The subject property is located on the outskirts of the Blue Rock Golf Course, as part of a seasonal community. The property is developed by a one-story, single family dwelling on an approximate half-acre lot in a residential neighborhood typical of the surrounding residential area. Access to the subject property is unrestricted, with high frequency/high intensity of use, and children potentially present. The dwelling and area of release in the basement are kept locked as presently vacated, thereby restricting access. However, the area of the basement, as partially finished is considered to have high frequency and intensity ofuse, with children present, as a foreseeable use as occupied residential dwelling. The subject property is completely upland and slopes from east to west with groundwater estimated as approximately 25-35' below ground surface (bgs). Given site topography, groundwater is projected approximately 30' below the basement floor (sub-slab = ss). Regional groundwater contours indicate an easterly groundwater flow direction towards Bass fuver [Refer to Figure 21. Cat Swamp Pond to the north, and Lily Pond to the southwest, are also identified in relative close proximity to the subject property. Based on regional flow direction, Bass River is identified as the primary environmental receptor, however Cat Swamp Pond and Lily Pond are also noted as potential environmental receptors. The dwelling is unoccupied as predating the subject release as noted. Onsite workers and visitors to the property are now considered potential human receptors, with future occupants as the primary human receptors. The subject property is shown on the Mass GIS 2lE overlay as falling within the Zone II of the Yarmouth PWS as part of a Cunent Drinking Water Source Area (CDWSA) within the Sole Source Aquifer for all of Cape Cod east of the canal [Refer to Figure 3]. The subject property is not located within the Zone A ofa surface water reservoir. Based on these conditions, the RCGW-I and RCS-l Notification criteria are applicable as consistent with the provisions of 310 CMR 40.0362 and 40.0361, respectively. The GW-l and GW-3 groundwater categories and the S-3 (GW-l/GW-3) soil categories are applied in considerations of Method 1 - Risk Characterization standards as a measure of significant risks to human and environmental receptors, pursuant to 310 CMR 40.0932 and, 40.0933, respectively. The strictest S-1/S-2IS-3 (GW-I/GW-3) soil criteria are considered under Method I Risk Characterization in review of foreseeable future use ofthe property. These standards have been developed in review of potential ingestion, incidental inhalation of dust particles and dermal contact exposures to humans, and in consideration of leaching to groundwater or significant impacts to environmental resources. Other considerations of vapor entry and associated inhalation exposues, and/or vegetative intake and ingestion of vegetables, are not adequately characterized under Method I criteria, and Method 3 evaluation may be conducted as appropriate. \ \ .tuNE 4,20r5 PAGE 5 OF I7 GLEASON/BEAI5.IO746 IRA STATUS I, RTN 4"25484 BACKGROUND [Refer to Appendix B] At the time of the release the homeowner, Emily Gleason, had relocated from the property. At the time of fuel oil delivery a neighbor, who had been monitoring the subject property on behalf of Ms. Gleason, provided access to the fill/vent pipes for Hall Oil Co, Inc. (dba The Oil Peddler) and witnessed the delivery. During delivery, the driver noted that something was wrong with the conveyance or storage of fuel oil, entered the dwelling basement, and discovered that one of the ASTs had ruptured and was actively leaking fuel oil to the concrete floor. Upon realizing the release, the driver contacted the Hall Oil corporate offrce for assistance. Hall Oil subsequently advised the Yarmouth Fire Department of the release; Yarmouth Fire Department subsequently notified the MA DEP and the Yarmouth Health Inspector of the release. Hall Oil contacted Global Remediation Services of Taunton, MA to respond to the release, recover spilled fuel oil and stabilize conditions. Hall Oil personnel isolated the failed AST and transferred its contents to the competent tank to draw down the fuel level and stop the active leak. The neighbor reported that the spilled fuel oil pooled on the concrete basement floor in the work room where the tanks were located and mobilized thereafter to the finished portion of the basement. Hall Oil and Global Remediation personnel applied speedy dry to the basement floor and subsequently drummed the used absorbents (6 x 55-gallon drums). The 55-gallon drums of remedial waste were secured and stored outside on a concrete patio at the back of the dwelling, sheltered beneath an elevated porch. Additional remedial waste, such as stained carpets, was contained in plastic and secured on the rear patio beneath the elevated porch. The MA DEP (Jaime Goncaives, Case Officer) endorsed the emergency response actions and directed the environmental contractor to continue to recover as much ofthe released fuel oil as possible. Yarmouth Fire Department persomel contacted the daughter of the homeowner, Kate Cole, and advised her of the release and the emergency response actions. Ms. Cole, on behalf of her mother, contacted BEA on February 3,2015; BEA was subsequently engaged to establish engineering controls, perform environmental assessment and direct cleanup operations under LSP oversight. The Department assigned Release Tracking Number (RTN) 4-25484 to the Immediate Response Action (IRA). EfWIRONMENTAL ASSESSMENT fRefer to Appendix B & Site Plan] Immediate Res nse Action Plan During the initial inspection on February 3,2015, indoor air screening with a calibrated photoionization detector (PID) [MiniRAE 3000, 10.6 eV lamp, calibrated to benzene standard] reported TOV concentrations ranging from 4.1 ppmv on the first floor to 33.8 ppmv in the basement release area. Modest petroleum staining to the basement concrete slab was observed in JUNE 4,20I5 PAGE 6 OF 17 GLEASON/BEAI5- I0746 IRA STATUS I, RTN 4-25484 the work room where the tanks were located. The rest ofthe basement was finished living space except for a small utility room which contained the fumace, hot water heater and chimney. Sections of carpet had been cut and removed due to fuel oil impact. Those areas of the concrete slab formerly beneath the carpet exhibited some petroleum staining. Two 275-gallon steel ASTs were noted as plumbed together to deliver fuel oil to a boiler and hot water heater in the adjacent utility room. Closer inspection of the vessels revealed a ruptured seam along the top half of the tank nearest the garage [Refer to Site Plan]. For the purpose of identification, the subject tank that ruptured and represents the source ofthe release is designated AST 1. The supplemental tank that did not leak is designated AST 2. Photo 1: Close-up ofruptured seom rtrd deflcction ofvessel on ASTI ,s cruse of relerse offu€l oil BEA persorLnel established vapor barriers and active ventilation as engineering controls to exhaust petroleum vapors outside against further mobilization throughout the dwelling. Subsequent to initiating active ventilation, TOV concentrations were reported between 2.4 ppmv and 20.5 ppmv. BEA returned the following day to inspect the dwelling and engineering controls. The vapor barriers and active ventilation were reported to be in good condition, and indoor air screening reported improved indoor air quality with TOV concentrations between 0.6 ppmv on the first floor and 15 ppmv in the basement tank room. The tanks were in the same condition as the day before with no further spillage noted. BEA directed an onsite meeting with the homeowner's son, Peter Gleason, and an insurance adjuster, Doug Bentley from Friedline & Carter, on February 6,2015. The substance of the meeting involved review of the circumstances of release, documenting fuel oil impacts to household items, coordinating access to the dwelling for future work, and identifuing preferential a /' a T -ry { JUNE 4, 20 I5 PAGE 7 OF 17 GLEASON/BEA I5.I0746 IRA STA'TUS I, RTN 4.25484 pathways towards environmental assessment. lndoor air quality screening reported PID readings between 0.3 ppmv on the first floor and 2.9 ppmv in the basement work room; this improvement was due to the engineering controls established. During the meeting, red dyed fuel oil staining in snow near the exterior fill and vent pipes was observed, and photo-documented, indicating the vessel had been overfilled. The fumace for the dwelling failed to fire over the weekend of February 7-8, 2015, and resulted in a burst pipe along the first floor. Water from the burst heating pipe mobilized to the basement. Although none of the water came into contact with significant fuel oil impacts, the water recovered from the basement floor was stored in a 55-gallon drum to be managed as remedial waste. The plumbing system was drained, and the dwelling winterized, on February 9, 2015, to accommodate continued active ventilation and absolve potential future issues associated with operation of the fumace. On February 10, 2015, BEA directed an onsite meeting with representatives for the homeowner (Kate Cole, daughter, POA; Peter Gleason, son), the insurance adjuster for MA Fair Plan (Doug Bentley, Friedline & Carter), the MA DEP (Jaime Goncalves, Case Officer), and representatives for Energi, the insurer for Hall Oil Co, Inc. (Walter Connors, Joseph DiFranco). Based on the subject AST having apparently been ruptured outwards along a welded seam due to intemal pressure, the Department stated it would issue Notices of Responsibility (NOR) to both the homeowner and Hall Oil. Energi agreed to release Global Remediation Services from its commitment to Hall Oil and Energi on the subject release so Global could continue to manage remedial waste and provide environmental contractor services under agreement(s) with the homeowner. Photo 2: Removsl of partition with oil satursted phle and pen€ling 8s sourc€ ofodor in !re' rdditionrl panctretioDs as pr€fercntirl pethways for oil relerse iIto u ofunfilished basemcnt to etposc rny nderlying soils. Ms. Cole engaged Global Remediation to remove additional wood framing and paneling in the basement, pump the remaining fuel oil from tanks, and secure the tanks within the a.?, 8, ,4 i l ':aa =-,1,-4. >- l I T JUNE 4, 20I5 PAGE 8 OF 17 basement but outside the release area. Global Remediation containerized all of the impacted household debris in a roll-off container for transport and disposal at Covanta (SEMASS) in Rochester, MA. Global performed this work on February 12,2015. The residual fuel oil/oily water were transported to Tradebe Treatment & Recycling in Stoughton, MA for disposal on February 13,2015. The household debris was transported to Covanta for disposal on March 17, 2015. In the period between February 6 and February 18, 2015, BEA performed environmental assessment to qualify the extent and magnitude of the release. The locations of hand borings were based on proximity to preferential pathways through the concrete basement floor to underlying soils. The locations ofthese borings are represented on the Site Plan in Appendix A. Two-foot soil samples were collected in 8-ounce glassjars and sealed with aluminum septa. The jars were agitated to develop organic volatiles. The samples were then field screened by'Jar headspace" method with a PID as consistent with the MA DEP Interim Soils Policy (WSC-94- 400). Dexsil PetroFlag tests were employed to supplement jar headspace screening and qualify TPH concentrations in the field. Select soil samples collected from beneath the concrete basement floor were submitted for MA Certified analysis of extractable/volatile petroleum hydrocarbons (EPIWPH) and target analyte (PAH,tsTEX) concentrations. The sum of these laboratory analytical results is presented in the following Table I. The significance of these results is further discussed in the fusk Characterization section of this report. I-{ltIt rl r'Rn Ac rEcaclL sorrEr:rR\E fE lrr' fI\.a9+. sLl8traf of so& rsSIJ!\E\I,r?Elra s-ra J Gitr -t) cntMtr 1EIFO I n!l(CtrR{CrEC{rD}.- ot 2 7 :l {III \PH - \t[d. adsl@ l]-\dF..,to6. T:qn r,,116 ' raE< loha< E[!!aac S*na !!llc' lrtlf,i6' Elt-lnn utL Rool@ts1,hdtnr, ?.r.!i-Fo!a!d?.r'1DdHi'..:i6t < bdidd :i!i.D..d .o!cadi!6 s!J.l Ia' 'OE d ti.\l.iod t lE* at.eaiai.. dir.i. c@ri/dri The sum of environmental testing to that point indicated a small area of significant fuel GLEASON,AEAI5-I0746 IRA STATUS I, RTN 4-25484 l JUNE 4, 20 15 PAGE 9 OF I? GLEASON/BEAI5,1O746 ]RA STATUS I, RTN 4.25484 oil impact underlying the former basement floor wherein a pre-existing hole provided a route of infiltration. Based on the field and lab data developed, an approximate 6' x 6' x 4'D area of signifrcant fuel oil impact beneath the basement floor was established as the focus of contaminated soil removal. Despite extensive environmental assessment via fifteen hand borings, BEA proposed that the affected portion of the concrete floor be demolished, removed and managed as remedial waste under the IRA in order to accommodate visual inspection and further testing ofunderlying soils as appropriate and necessary to qualify potential impacts beyond those established. BEA coordinated with Ms. Cole, who was granted Power of Attomey for her mother, towards removal of sensitive items from the subject dwelling, as well as fumiture and fibrous materials, in preparation for additional remedial response actions. This work was done to improve access for proposed contaminated soil removal operations, to absolve potential targets for TOV on which to adsorb, and to absolve potential sources of off-gassing, as would otherwise contribute to persistent indoor air quality degradation. In consideration of the planned concrete and soil removal, on March 3,2015 BEA requested verbal authorization to remove 30 cubic yards of contaminated material from the qualified areas of impact. The Department granted verbal authorization for the removal ofup to 30 cubic yards of fuel oil contaminated material. Subsequent to qualiffing sigaificant fuel oil impact to soils beneath the footprint of the dwelling, inspections reported stable conditions, improved indoor air quality (TOV: <0.1 - 0.3 ppmv) and a substantially diminished fuel oil odor. The subject AST, and the supplemental tank, remained empty, secure and standing on plastic sheeting in the basement, pending forensic investigation to substantiate the cause of the release. BEA coordinated with Mrs. Cole (POA) and Mr. Gleason, and their retained counsel, to secure bids fiom qualified contractors to implement the IRA Plan towards contaminated soil removal and inspection of soils underlying the concrete basement floor. On April 2, 2015, BEA directed a site review with Cyn Environmental Services of Stoughton, MA towards preparation of a competitive bid to perform removal of contaminated soil and concrete. During the inspection a significant fuel oil odor was reported in surface soils near the fill/vent pipes, as was fuel oil staining to the concrete apron in front of the garage. These areas had previously been hidden with significant snow cover. BEA coordinated additional environmental assessment to qualify the extent and magnitude of exterior impacts. The interior release in the dwelling basement and the exterior release near the fill and vent pipes were subsequently identified as Zone A and Zone B, respectively. On April 6,2015, BEA performed environmental assessment via a series of four hand borings to qualifu the extent and magnitude offuel oil impact along Zone B at the exterior ofthe dwelling in the vicinity of the fill and vent lines. Two-foot samples were collected from each boring, from ground surface to depth. Field screening of these soil samples reported significant Immediate Response Action Status I , JUNE 4,2OI5 PAGE IO OF I7 GLEASON,tsEAl5-t 0746 IRA STATUS I, RTN 4-25484 fuel oil impact due to the apparent overfill associated with the release. BEA submitted select soil samples for MA Certified Analyses of EPFI/PAH and VPTVBTEX concentrations. These results are presented in the following Table IL The significance of these results is further discussed in the Risk Characterization section ofthis report. TABLEII:81 DRIIING TED CIRCLI, SOUTH I'ARMOUTH, MA- Rm 425{E4 suM MARY OF SOrL ASSf,SSM ENT, I?lrlEPH, S,l /S2 (GW-r) C.R ITER IA MI.]IHOD I RISKC'IIARACTf,RIZATION SAMPLETD STOCXTtr,ECOMP olar,I0,r2: q'] I HB-12: r0-lr' 3 s-r Dc s-1DC AdjEl.n C'c8^liDidk (ID) Adj6r.d Ca{l2lrph.iis0lD) 2 ,(D 500 ol 2 .t t0o J00 &7 432 J I 2 1 I I { 2 7 lm im fr) 3m t@ t.1 al 0.8 0? <l <l WH = Vohd. P.rr*@Hrdd.rb6B, T.rBd Anrb16 - Aaa., Tob6., EhtD@., xylr., MrBE, .Lrhrn*r. EPH = En8hhL P.toklnHrdEclrh.nr, PAH - Pobnuct a ADonc Hldocllt@s < hdi.rB MnDa.a c@@r on Sldcd .Ia,.DEar rn. Mdod I Pislcl'udqiarion cdan @tun@d Rl A,.l)1t!n Wolt dd r l50406Dr0 Based on the exterior soil testing along Zone B, an approximate 9' x 4' x 6'D area of significant fuel oil impact was qualified and targeted for removal to absolve exposure risks, including contaminant leaching to groundwater, estimated as approximately 29' below the vertical extent of exterior fuel oil impact. The homeowner and POA, having selected Cyn Environmental Services to remove a portion of the concrete floor and excavate contaminated soils lrom Zone A, sought a revised bid from Cyn to include Zone B contaminated soil removal. To that end, BEA met with Cyn personnel, and Apex Engineering of Rochester, MA, at the subject property on April 15, 2015, to review the revised scope of work for two areas of soil removal, and also to review temporary structural shoring requirements to accommodate safe excavation of Zone A contaminated soils in close proximity to the center girt beam of the structure. Based on the revised scope of work and shoring requirements, Cyn prepared and \ JTJNE 4,20I5 PAGE II OF I7 GLEASON/BEAI5.IO746 IRA STATUS I, RTN 4.25484 presented a revised bid for the homeowner and POA RISK CHARACTERIZATION/IMMINENT HAZARDS [Refer to Appendix D] Soil With the realization of significant exterior fuel oii impacts along the front of the foundation (Zone B), in conjunction with those impacts reported underlying the basement concrete floor (Zone A), the S-1/S-2/S-3 (GW-l/GW-3) soils categories are applicable in consideration of Method 1 - Risk Characterization, as consistent with the provisions of 310 CMR 40.0933. For the purposes of risk characterization, the most restrictive S-1/S-2iS-3 (GW-1/GW- 3), Method 1 - Risk Characterization standards are considered in review of ingestion, particulate inhalation and dermal contact exposures related to foreseeable future uses and activities at the Site. These standards were developed to evaluate potential ingestion (S- 1), particulate inhalation (S-2) and environmental (S-3) exposures, and in consideration of potential leaching of contaminants to groundwater (GW-1/GW-3). Although select S-1 (GW-l/GW-3), Method 1- Risk Characterization standards are exceeded, laboratory analltical has reported all EPH, VPH and target anallte concentrations less than the S-1, S-2 and S-3 Direct Contact standards. The dwelling has been unoccupied throughout the project timeline as predating the subject release. The residence has been winterized, is kept locked, and will remain unoccupied throughout the project as restricting access to the basement and the excavated Zone A. Notwithstanding, at the time of this reporting soil removal has been completed in Zone A and analyticai results received as Non-Detect as At the time of this report, the center girt beam in the basement has been supported with steel beams and cribbing, and contaminated soil removal within Zone A has been completed. Field screening has indicated background conditions were met in all sidewalls and along the bottom-of-hole of Zone A, with analy.tical results for end-point samples pending. Contaminated soil removal along Zone B has begun, however, assessment of soils along the extent of the current excavation has indicated significant fuel oil impacts beyond the extent and magnitude originally qualified. Furthermore, despite full foundation walls along the balance of the dwelling and garage, the construction of the foundation wall along the front of the garage, adjacent to Zone B, is a 4' frost wall. As such, Zone B contaminated soil removal was not advanced beyond 3' bgs because additional structural shoring is required to advance the Zone B bottom-of-hole in consideration of worker safety and structural integrity. Laboratory analytical associated with Zone B assessment, and review of such analytical to prepare a revised scope of work for Zone B, is currently pending. In addition, laboratory analyical, and analyical review, associated with potential fugitive fuel oil impacts formerly underlying the affected portion of the concrete slab in the basement, is also pending as critical towards absolving potential interior residual impacts in consideration of soil vapor and potential vapor intrusion. The significance of these findings, and the associated remedial response actions to follow, are further discussed ion the Risk Characterization and IRA sections of this report. JLr].tE 4, 2015 PAGE 12 OF I7 CLEASON/BEA15.10746 IRA STATUS I, RTN 4,25484 consistent with background concentrations. These results have not been included as would further delay IRASI reporting. This data will be included and further evaluated in the next submittal. Groundwater Based on the mapped CDWSA desigration and proximity to groundwater, the GW-l and GW-3 groundwater categories are considered applicable in consideration of Method 1 - Risk Characterization standards, as consistent with the provisions of 310 CMR 40.0932. These standards were developed to evaluate potential ingestion (GW-l) and environmental (GW-3) exposures. The vertical extent of interior soil impact in the worst-case area along Zone A, represented by HB-13, was qualified as 4'ss. Based on the concentrations of petroleum hydrocarbons reported at the HB-l3 location as exceeding the S-3 (GW-l/GW-3) standards, the potential for further leaching of contaminants to groundwater is indicated. However, based on the position of the worst case impacts as fully beneath the dwelling foundation, and that the vertical extent of significant impact is some 20' (+/-) above groundwater, further leaching of petroleum hydrocarbons and associated groundwater impacts related to Zone A are not anticipated. Such conditions and the need or monitoring wells will continue to be investigated under the IRA, particularly along the exterior Zone B wherein the vertical extent of significant soil impact has been identified at greater depths as pending qualification by additional assessment and laboratory analysis. The area remains capped with gutters redirected against rainfall infiltration pending additional soil removal. Based on the soil testing and occurrence of significant soil impacts relative to isolation under the footprint of the subject dwelling and capped areas, and apparent 20'+ separation to groundwater, dwelling, no groundwater impact as a result ofthe subject release is anticipated or qualified at this time, and no Imminent Hazards or Substantial Hazards with respect to gloundwater have been identified. Should pending assessment report a significant change in the While additional environmental data is being developed and construction activities are temporarily suspended, family members and BEA personnel will continue regular inspections of the dw-elling. As previously reported, contaminated household items (carpets, interior walls, fumiture, porous rnaterials) have been removed from the dw'elling to eliminate targets for VOC adsorption and potential future sources of off-gassing. The basement remains isolated with plastic vapor barriers, and a commercial grade fan with tubing continues to actively ventilate the dwelling. Also, the Zone B excavation has been secued with wood timbers, plywood and plastic sheeting against sidewall collapse and precipitation to prevent the exacerbation of environmental conditions. As such, with the residence unoccupied, and access/engineering access controls in- place, no Imminent or Substantial Hazard conditions with respect to soil are apparent under existing conditions. However, Method 1 - Risk Characterization standards are apparently exceeded along Zone B, and may also be exceeded in soils formerly underlying the basement concrete floor, pending laboratory analytical results. Therefore, potential exposue risks exist and remedial response liability for waste site clean-up remains appropriate and necessary to establish a condition ofNo Significant Risk for all foreseeable activities and use ofthe property. JUNE 4,20I5 PAGE 13 OF I7 GLEASON/BEAI5-I0746 IRA STATUS I, RTN 4.25484 extent and magnitude of fuel oil impact along Zone A or Zone B and affect the Conceptual Site Model, the need for groundwater sampling and analysis will be revisited. Indoor Air Indoor ambient air quality within the [iving space of the residence was originally evaluated during BEA's initial response on February 3,2015, and has been monitored during subsequent Site visits in consideration ofworker safety. Indoor air screening has been conducted with a calibrated PID. Subsequent to implementing engineering controls (plastic vapor barriers, active ventilation), indoor air screening has reported TOV concentrations approaching background (<0.1 - 0.3 ppmv), and trace petroleum odors have been limited to the basement, representing substantial improvement from the date ofrelease. The property has been unoccupied and kept locked throughout the ordeal, thereby mitigating exposure risks and restricting access. Based on engineering controls, access and ambient air quality screening, no Imminent or Substantial Hazards relative to indoor air quality are reported under existing Site conditions. The removal of all impacted building materials and household contents is intended as a potential source of indoor air degradation. Ozone treatment following the completion of all soil removal and capping of exposed soils is intended. Indoor air and vapor intrusion will be further qualified by future screening of indoor air, end-point soil testing and, if necessary pursuant to 310 CMR 40.0942(d), APH analysis of soil vapor and/or indoor air testing as consistent with the "lines of evidence" investigation of vapor intrusion and potential indoor air sampling under the "Interim Final Vapor Intrusion..." guidance (#WSC-l1- 43s). Izu CONTINUATION To date, Zone A contaminated soil removal has been completed with analytical results reporting background conditions were met in all sidewall and bottom-of-hole areas; the Zone A confirmatory analltical results will be presented in the next IRA Status report. The concrete floor has been demolished and removed as remedial waste. Environmental assessment of soils formerly beneath the basement concrete floor was begun with select, TOV-biased samples submitted for MA Certified analyses of petroleum hydrocarbon concentrations to qualifr potential residual impacts. Additional testing of those soils formerly beneath the concrete floor will be completed as concurrent with additional assessment along Zone B. Contaminated soil removal along Zone B began, but has been temporarily suspended to facilitate additional assessment to revise the Zone B area of significant impact and proposed area of contaminated soil removal. Environmental assessment of soils along Zone B has begun, with laboratory analytical results pending. Such analyical results will be employed to direct further Zone B assessment and develop a revised scope of work to complete Zone B contaminated soil removal. Based on the depth of significant fuel oil impacts, structural support ofthe front (east) frost wall of the garage, and potentially other sections of the front full foundation wall, will be necessary to accommodate excavation of contaminated soils in review of worker safety and structural integrity. JT-INE 4, 2OI 5 PAGE 14 OF 17 CLEASON/BEA15-10746 IRA STATIIS I. RTN 4-25484 In review of contaminated soil removal operations, fuel oil contaminated soils have been, and will continue to be, excavated and loaded for direct transport to Aggregate Industries' South Dennis facility, r.rnder a properly executed Bill of Lading, for asphalt batch recycling. Based on environmental assessment and laboratory analyses relative to fuel oil impacts along Zone B and potentially in soils formerly beneath the basement concrete floor, BEA seeks authorization ofan additional 25 yards of impacted soil removal under the continuation of the IRA. BEA will further prepare a revised Bill of Lading to accommodate the additional proposed volume, as well as the timing of such soil removal. Such work will be performed to absolve exposure risk considerations, including potential VOC impacts adj acent to the foundation described in 310 CMR 40.0942(1)(d). Following the removal of significant impacts from the release area(s) as described, confirmatory end-point soil samples will be collected and preserved for risk-based EPIYPAH and VPHtsTEX analvses. Contingencies for construction and installation of infiltration systems in the completed Zone A and Zone B excavations remain part of the IRA as subject to remedial response performance. The potential infiltration system(s) would be constructed of four inch, schedule 40, perforated PVC pipe laterals set within the washed stone aggregate along the backfilled excavation(s). The lateral components will be covered with stone and capped with a polyvinyl barrier. Backfill of the excavation will be completed \Mith structual fill or clean compacted material in order to provide a solid, compacted base for load-bearing points. A four inch, schedule 40, solid PVC riser will be plumbed to the lateral components, run outside above the roof line of the dwelling, and connected to a wind turbine. This type of system would have the versatility for ventilation and enhanced air flow, and could accommodate future field PID monitoring of soil vapor within the backfilled excavation in review of potential vapor intrusion. The infiltration system would also provide the flexibility to deliver remedial additives to mitigate residual impacts if necessary. The need for treatment of soil and/or groundwater will be evaluated as based on the laboratory results for the end-point soil samples from both Zone A and Zone B. Based on the remedial response performance and the analytical results for the end-point soil samples, particularly those representing the bottom-of-hole, future groundwater monitoring may be employed to further qualifr the efficacy of contaminated soil removal in considetation of potential leaching of contaminants to groundwater in a CDWSA. Likewise, end-point soil sampling, removal of all intemal sources of petroleum vapors and indoor air screening will be considered in the evaluation ofvapor entry and related inhalation exposures. This IRA has been has been endorsed by the homeowner and homeowner's daughter (POA), as effectively an extension of the original IRA Plan, wherein contaminated soil removal will provide the greatest certainty of complete, effective remediation wherein project closure objectives can be met in the shortest amount oflime. The objective ofthe remedial sfategy is to achieve a condition of No Significant Risk and a Permanent Solution/regulatory ptoject closure within one year of release discovery. The contractor proposal will be forwarded to the homeowner's daughter (POA), and retained counsel, for approval as reasonable and customary for reimbursements under any coverage extended to the homeowner, or to Hall Oil Co, Inc. as a PRP. It is anticipated that this work will resume wi&in 21 days of submittal with work to be ]LJ I.IE 4, 20 I 5 PAGE I5 OF I7 GI,EASON/BI]AI 5-I 0746 IRA STATUS I, RlN 4.25484 completed by the next status report, IRAS II (11131/2015) for the planned sale, and subsequent re-occupancy, of the dwelling as subject to restoration of utilities, site safety and indoor air evaluation. Future environmental assessment/monitoring activities will diotate the need for any additional remedial measures to be represented in the next IRA Status report (IRAS II) as will be filed within 60 days of this IRA Plan, and then every six months thereafter. Remedial response activities considered herein, and potentially to follow in subsequent IRA Status reports, are intended to mitigate all Critical Exposure Pathways and to facilitate a Permanent Solution in order to avert all potential risks to identified human and environmental receptors in support of a Permanent Solution Statement without restriction to future activities and uses of the subject property. ENVIRONMENTAL MONITORING BEA has collected, and will collect, representative end-point soils samples from the sidewall and the bouom-of-hole areas of the Zone A and Zone B areas of contaminated soil removal, respectively. Such soil samples will be tested for EPTWPH and target analyes concentrations in review of remedial response performance, potential exposure risks and project closure objectives. Based on the laboratory analytical results for end-point soil samples, the need for additional response actions, such as groundwater monitoring and/or soil vapor testing, will be evaluated in review ofrisk characterization and regulatory project closure. Subsequent to the completion of contaminated soil removal, and considering indoor air quality screening, the dwelling may be commercially cleaned and teated with ozone to destroy residual petroleum hydrocarbons. BEA will monitor TOV concentrations within the dwelling and, if appropriate, at a infiltration system riser or soil vapor probe, in consideration ofindoor air quality and potential vapor intrusion. Pursuant to 310 CMR 40.09420(1)(d), if laboratory analyses report any significant VOC concentrations adjacent to the foundation or concrete slab (6' lateral, l0' vertical) that could result in vapor entry, soil vapor testing for APH analysis will be performed in review of potential vapor intrusion as consistent with the provisions of the "Interim Final Vapor lntrusion..." guidance (#WSC-11-435). End-point soil analytical results, indoor air quality screening, soil vapor analysis will serve as "as lines of evidence" in consideration ofthe need for additional APH testing of the indoor air prior to the planned sale, and subsequent re-occupancy, ofthe dwelling. Field inspections will be conducted and documented on "Inspector's Daily Record of Work Progress" reports. Should groundwater monitoring be appropriate and necessary, field measurements of groundwater elevations, olfactory and visual observations and the field-testing of pH, dissolved oxygen, conductivity and temperature will be reported on Monitoring Well Sampling Logs. Remedial response and environmental assessment work will proceed as consistent with the QA/QC Policies of BEA outlined within Appendix E. Personal protection and safety standards for BEA were specified in the Site Specific Health and Safety Plan outlined in Appendix F ofthe IRA Plan previously filed. JUNE 4,2OI5 PAGE I6 OF I7 CLEASON/BEAI5-I0746 IRA STATUS I, RTN 4-25484 CONCLUSIONS Based on the dwelling being unoccupied as pre-dating the subject release, and in consideration of established access and engineering controls, no Imminent or Substantial Hazards are reported as associated with the subject release. Based on observations, monitoring and testing conducted to date, the Conceptual Site Model (CSM) has been revised to represent that an approximate 50-gallon fuel oil release was triggered by apparent overfill and the subsequent rupture of a welded searn on the subject AST l. The tank ruptue reportediy occurred during fuel oil delivery wherein significant fuel oil impacts around the exterior fill/vent pipes has indicated overfill. The fuel oil was released from the ruptured tank to the concrete basement floor and subsequently mobilized due to the pitch of the floor and the volume of the release. Emergency response actions, initiated within minutes of release discovery, served to limit the damage to household items, as well as to mitigate significant impacts to soils beneath the concrete slab. Impacted household debris, spent speedy-dry and recovered fuel oil have been managed as remedial waste with appropriate security, transport and disposal documented. Both tanks have been pumped empty and secured in the dwelling basement on plastic sheeting. Contaminated interior wood fiaming, paneling, shelves and other household items have been removed and managed as remedial waste to accommodate environmental assessment and remedial response actions. Contaminated soil removal along Zone A has been completed with background conditions met along the extent of excavation. Immediate response actions have been performed under verbal authorizations granted by the Department. The continuation of the IRA with additional soil removal represented by this f,rling, proposes additional environmental assessment to be completed along Zone B as well as along soils previously capped by the basement concrete floor. Based on such assessment, contaminated soil removal along Zone B, and potentiaily within the basement outside Zone A, will resume for removal of remaining residual soil impacts and absolve potential exposure risks. Authorization to extend the volume of contaminated soil removal to 55 yards is sought as based on the aforementioned environmental assessment. Field PID screening and Dexsil testing will be used to provide technical assistance and direct excavation operations. End-point soil sampling and ambient air quality screening, and potentially soil vapor and indoor air testing, will be used to qualifu remedial response performance in review of risk characterization. Groundwater testing may be considered as subject to laboratory analysis of end-point soil samples. The results of the proposed additional contaminated soil removal, and associated environmental assessment and monitoring, will be presented in the next IRA report to be submitted within 6 months of this IRAS I filing. The findings of this investigation, as represented herein, set forth the rationale and technical justification for the LSP Opinions offered, as established by the certifications made on the attached Immediate Response Action Transmittal Form (BWSC-105). The LSP Opinions are based on available data and regulations in effect at the time of this reporting specific to the subject Site. JUNE 4,20I5 PACE I7 OF I7 (iLEASONBEA l5-10746 IRA STATUS I, R]N 4-25484 Should there be any questions regarding this project, or need for additional information, please contact our office at your earliest convenience. Sincerely, NMENTAL ASSOCIATES, INC. LSP Todd n, ES Senior ect Manager Encl: Supporting Documentation [Appendices A-E] Kate Cole - Daughter of Homeowner/PRP, POA (Electronic copy on CD) Susan Crane, Esquire - Counsel to Homeowner (Electronic copy on CD) Lt. Inspector Matt Bearse - Yarmouth FD (narrative, index and site plan) Carl Lawson, Jr. - Yarmouth Health Div. (narrative, index and site plan) William Hinchey Yarmouth Town Manager (narrative, index and site plan) IMMEDIATE RESPONSE ACTION PLAN SUPPORTING DOCUMENTATION RTN 4-25484 Gleason Residence 81 Driving Tee Circle - South Yarmouth, MA [Assessors Map 101, Parcel 3] BEAI5-10746 JIINf, 4.2015 Prepared For: MA DEPARTMENT OF ENVIRONMENTAL PROTECTION Southeast Regional Offrces: Bureau of Waste Site Cleanup/Emergency Response Section 20 Riverside Drive - Lakeville, MA 02347 Jaime Goncalves, Case Officer Prepared Bv: BENNETT ENVIRONMENTAL ASSOCIATES, INC. 1573 Main Street - Brewster, MA 02631 David C. Bennett, LSP On Behalf Of: Emily Gleason, Homeowner, PRP Kate Cole, Daughter ofPRP, POA l8 Woodcrest Road Westborough, MA 01581 APPENDIX A: Reference Phns - Figure l: Site Locus Plan [USGS Topographic Quad., Yarmouth, MA. 1998] (excerpt) - Figure 2: Ground-Water Resources ofCape Cod, MA [LeBlanc et al, 1986] (excerpt) - Figure 3: MA DEP BWSC GIS Map [2015] - Site Plan entitled, "Immediate Response Action Status I..." Prepared by BENNETT ENVIRONMENTAL ASSOCIATES, INC., dated April 15,2015. APPENDIX B: Field Reports - Irspector's Daily Records of Work Progress APPENDIX C: Environmental Records/Permits - Aggregate Industries Soil Recycling Submittal - BWSC-I 12: Bill of Lading w/ eDEP Submittal Summary/Receipt - BWSC-105: Immediate Response Action Transmittal Form eDEP Submittal Surnmary/Receipt APPENDIX D: Laboratory Analysis - Environmenlal Assessment - Soil [R.1. Anal)tical] (Work Order #1504-06990 REV A,4/13/15) APPENDIX E: Quality Assurance/Quality Control Plan