HomeMy WebLinkAboutDEQE - 4/9/1990/1
ww Daniel S. Greenbaum
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baum
Commissioner
Gilbert T. Joly
Regional Director oZali.e/i , ✓"� 9 r-r��
Hatheway & Patterson Co., Inc.
P.O. Box 177
Mansfield, Massachusetts 02048
ATTENTION: Mr. William E
President
Gentlemen:
Pursuant to 310 C
Protection, Bureau of Was
report titled "Phase II
Environmental Assessment"
the Hatheway & Patterson
The report was prepared o
Inc. and submitted for a
40.545(5)(a), the Departm
inadequate and that addit
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April 9 , 19 0 )774F,,' PFPART. �7.FNT of
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RE: MANSFIELD--WSC/SA-4-0571
Hatheway & Patterson
15 County Road,
Phase II Report,
Massachusetts General Laws
Chapter 21E, 310 CMR 40.000
MR 40.536(1)(b), the Department of Environmental
to Site Cleanup (the Department), has reviewed the
Site Investigation and Preliminary Health and
(the report) for the site WSC/SA-4-0571 at and near
facility on County Road, Mansfield, Massachusetts.
n your behalf by Keystone Environmental Resources,
pproval on January 2, 1990. Pursuant to 310 CMR
ent has determined that the report is incomplete and
ional Phase II activities are necessary.
The purpose and scope of a Phase II - Comprehensive Site Assessment are
described under 310 CMR 40.545(1). Phase II activities must assess the full
extent and character of contamination areally and in depth, evaluate the risk
of harm to the public and to the environment, and provide all the data
necessary to develop remedial response alternatives as required in 310 CMR
40.546. The format and content of a Phase II Report are prescribed at 310
CMR 40.545(4). The Phase II Report is a final and comprehensive public
document on site assessment that must include the results of all previous
work on and near the site. To be approved, a Phase II Report must be
complete and adequate. Following are the findings of the Department relative
to the requirements of 310 CMR 40.545(4).
310 CMR 40.545(4) A Summary of Findings and Conclusions:
This section needs to be revised to reflect the changes required in the
body of the report.
Original Printed on Recycled Paper
CM
310 CMR 40 545(4)(b) Phase II Scope of Work:
310 CMR 40.545(2)(a) requires that gaps identified in Phase I activities
be completed in a Phase II - Comprehensive Site Assessment. Therefore,
Section 310 CMR 40.545(4)(c) must be preceded by an account of Phase I
activities not adequately covered in previous reports, in particular:
- 310 CMR 40.543(2)(a)3, a reasonable estimate of quantities of oil or
hazardous materials used, treated, stored, disposed, or generated
through past and present uses of the location.
- 310 CMR 40.543(2)(a)4, a history of all disposal methods for oil or
hazardous materials at the location, including an identification of
disposal areas and types and quantities of material disposed.
- 310 CMR 40.543(2)(a)5, locations of wells, septic systems, drip or
leaching areas, lagoons, piping, storage tanks above and below ground,
outdoor storage areas, or other places where oil or hazardous materials
were used, stored, treated, or disposed. An accurate plan and
description of current procedures to capture drip or waste oil or
hazardous materials in the course of normal operations at the facility.
- 310 CMR 40.543(2)(a)6, a summary of all releases of oil or hazardous
material; fires and explosions which have occurred at the location;
environmental licenses, permits and approvals issued for activities at
the location; and all environmental enforcement actions by federal,
state or local agencies.
310 CMR 40.543(2)(b)4.b, a description and outline (on a map) of overt
evidence of environmental damage.
- A complete description with plans of remedial response measures and
short term measures undertaken at the site and an inventory of oil or
hazardous materials recovered, recycled or disposed on -site or off -site
as a result of these measures.
310 CMR 40.543(2)(b)6.a, a source or authority for the statement that
there are no private water supply wells at or in the vicinity of the
site.
310 CMR 40 545(4)(c) Physical Site Characteristics:
This section must give an account of all the activities required under
310 CMR 40.545(3)(a)1-12.
1. The site plan(s) or map(s) need to outline abutting properties and
buildings, identify addresses, usage, owners and operators.
Within the Hatheway & Patterson facilities, work areas, spaces and
rooms need to be outlined and their function or usage identified.
Drip, collection, leaching or catchment areas, drains, pipes,
tunnels, cellars, pits, sewers and conduits of any sort need to be
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outlined, their purpose identified and their course traced to the
municipal sewer system, storm sewers, catch basins, leaching
fields, dry wells, septic systems, discharge pipes, tanks or
reservoirs.
All past and recent sampling locations, boreholes and installations
of any sort at and near the site need to be identified and plotted
on the site map.
2. Topography needs to be mapped. Areas barren of vegetation or
discolored because of environmental stress need to be described and
outlined.
3. In order to assess the risk of harm to the environment, the report
needs to develop seasonal dilution models that will test compliance
with ambient water quality criteria and confirm the surface water
analysis on the site. Seasonal base flow of the Rumford River
needs to be measured and compared to the estimated seasonal
discharge of contaminated ground water.
Complete and adequate.
The vegetation of the wetlands on the site need to be characterized
and environmental stress must be outlined and described. A
determination needs to be made on the status of these wetlands as
critical habitats on the basis of a reading of the Natural Heritage
and Endangered Species Program of the Massachusetts Division of
Fish and Wildlife as well as applicable state and federal
regulations.
The report describes a stratigraphy that consists of bedrock, till,
alluvium, fill and pavement, in that order of superposition. A
geologic map outlining the outcrop of bedrock and till and a map
contouring the thickness of overburden need to be compiled. This
section also requires a table that lists the depths or elevations
of the startigraphic units encountered in the boreholes logged at
and near the site.
The report indicates that a number of slug -tests in the overburden
failed because of very high hydraulic conductivities; but the
report fails to identify the boreholes where this condition was
encountered. These boreholes need to be slug -tested again with
equipment better suited to the task.
7. This section requires the compilation of a structure map of the top
of the bedrock on the site.
8. The hydrogeologic data and interpretations submitted in the report
raise a number of questions that need to be resolved.
a. Gauging is incomplete and inadequate. The Rumford River was
gauged only once and the Rumford River Backwash was never
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surveyed or gauged. Numerous surface water stations need to
be maintained and surveyed and must be gauged on each site
sampling round.
b. The piezometric maps submitted in the report fail to integrate
surface water and ground water gauging data, are inadequate
along the margins and the toe of the plume, and fail to
establish whether the Rumford River and the Rumford River
Backwash are fully penetrating hydraulic boundaries. This
section requires some additional piezometric control and
gauging, and the compilation of areal and vertical flow nets
that clearly illustrate the paths of contaminant transport and
resolve the relationship that exists between surface waters
and groundwater.
9. Adequate and complete.
10. This section requires an estimate of mean annual precipitation and
mean annual recharge as a percentage of precipitation.
11. Municipal sewer lines, tie-ins, storm sewers, catch basins and
water mains need to be plotted on site map/s or plan/s.
12. Adequate and complete.
310 CMR 40 545(4)(d) Sources and Extent of Releases of Oil and Hazardous
Materials•
This section must give an account of all the activities required under
310 CMR 40.545(3)(b)1-6.
A determination must be made that the sources identified are or are
not continuing to release contaminants. Phase II activities must
be adequate to support a good correlation between the contaminants
released to the environment and the sources identified at the site.
Contaminants in ground water must be traced back to spills, leaks,
separate -phase slugs of products, disposal sites or leaching areas.
2. The definition of the limits and levels of contamination required
in this item depend largely on the adequacy and completeness of
sampling and analysis. The Department requires that sampling be
representative, systematic and comprehensive. Aggregate samples
may not be used, and when only one sample is planned for any given
location, it must be a worst -case sample chosen on the basis of
field -screening, odor and color. The field -screening data for
soils are not reported at all. They should at the very least be
recorded on the borehole logs. The Department needs to be
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persuaded that the soil conditions reported accurately describe the
worst conditions present on the site.
The report does not address the extent, thickness and composition
(or fingerprint) of separate -phase product encountered at the site.
The extent, thickness and composition of separate -phase
contaminants must be reported and mapped for each sampling and
gauging round. With few exceptions, the presence of measurable
thicknesses of separate -phase product constitutes an imminent
hazard requiring notification and short term measures.
Sampling and analysis of surface waters need to be seasonal and
must reach backround levels downstream.
Groundwater monitoring wells should be installed immediately
downgradient of treating units and areas of known or suspected
releases, such as the location of the former leaking underground
fuel oil storage tank and the dry well formerly used for the
disposal of waste oil and products at the facility. Groundwater
monitoring wells should also be installed immediately upgradient
of those stretches of the Rumford River bank that show heavy
staining from discharge of free-floating oil or product into the
River.
The assessment of the extent and the level of contamination at the
site in soils and in ground water needs to reach background levels
areally and in depth. The monitoring activities undertaken at the
site so far fail to achieve this goal. In addition, this section
requires for each medium the compilation of a series of
concentration contour maps that graphically illustrate the extent,
the level of concentration and the progress of each contaminant
found at the site. Relative to this task the report is incomplete.
3. This item calls for an estimate of the volume of soils and the
volume of ground water contaminated above background levels.
Volumes of contaminated soils and ground water are not addressed
at all in the report.
4. Adequate and complete.
S. The report does not adequately predict the transport of contaminant
solutes in ground water. This understanding has not been achieved
largely because the hydrogeological model of the site is incomplete
and inadequate (see item 310 CMR 40.545(4)(c)6 and 8 above) and
the extent and level of contamination is not fully known and has
not been adequately compiled (see item 310 CMR 40 545(4)(d)2
above). In addition to advection, this task requires an evaluation
of dispersion and retardation, chemical and biological, and
estimates of discharge rates into the Rumford River and the Rumford
River Backwash.
310 CMR 40 545(4)(e)Characterization of Oil or Hazardous Materials:
This section must give an account of the activities required under 310
CMR 40.545(3)(c)l and 2.
1. All contaminants, rather than a
need to be addressed. Volumes of
given in the report.
2. Complete and adequate.
selected group of contaminants,
contaminants on the site are not
This section must give an account of activities required under 310 CMR
40.545(3)(d)1-4.
1. Workers currently employed on the site need to be included on the
list of human receptors, and their daily receptor doses resulting
from exposure at the site shall be compared to FIFRA standards or
guidelines, among other applicable standards, policies or
guidelines, to arrive at total site cancer risks and total site
non -cancer risks.
The current availability of a municipal water supply for household
use does not condemn groundwater at the site. Unless there are
hydrogeological reasons to reject groundwater as a resource
(brackishness, low yield), consumers of ground water from private
water supply wells on the site need to be included on the list of
human receptors for reasonably foreseeable future conditions
without remediation. Among those ground water consumers, children
would be the most sensitive receptors.
Because fencing may not be regarded as a permanent solution,
children trespassing the area occupied by the operational facility
must be included on the list of human receptors for reasonably
foreseeable future conditions without remediation.
2. Exposure points to consumers of groundwater must include all
recharge areas that could potentially draw groundwater from the
plume now and in the foreseeable future (at least for the next
fifteen (15) years).
3. Complete and adequate.
4. The public health risk assessment seeks to discover whether health
effects on the most sensitive receptor exist anywhere on the site
which will trigger the requirements for a remedial response action
pursuant to 310 CMR 40.545(3)(j) for existing and reasonably
foreseeable land uses. This is a worst -case determination that
must be based for acute exposure on a specific exposure point and
on the concentrations calculated for that exposure point, and these
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in turn must be derived from an
evaluation of chronic exposure, the
circumscribed to exclude low level
at the margins.
individual sample. In the
exposure area must be carefully
exposure point concentrations
At the very least, the Northern, Central and Southern Exposure
Areas need to be subdivided further into exposure areas east and
west of the Rumford River. Some of the samples with low or
undetectable contaminant concentrations currently used to obtain
exposure point concentrations may have to be excluded.
This section must satisfy the requirements of 310 CMR 40.545(3)(e). It
is complete and adequate.
These sections must give an account of the activities required under 310
CMR 40.545(3)(g)1-3 and (h).
The Department's Office of Research and Standards (ORS) will review
these sections following a determination by the Bureau of Waste Site Cleanup
that the activities required under 310 CMR 40.545(3)(a) through (e) are
complete and adequate. Therefore the characterization of risk submitted in
the report has not been reviewed at this time.
310 CMR 40.545(4)(1) Conclusions:
This section of the report must record the determination made pursuant
to 310 CMR 40.545(3)(i) or (j). If the additional activities required above
materially change this determination, the report will need to be revised.
310 CMR 40 545(4)(k) Recommendations for Future Actions
Should the results of the risk assessment trigger the undertaking of
activities required under 310 CMR 40.546 Phase II - Development of Remedial
Response Alternatives and Final Remedial Response Plan (FRPP), this section
needs to include a schedule for the submittal of the FRPP relative to the
date of receipt of the approval of the Phase II report.
310 CMR 40.545(4)(1) Appendices:
Complete and adequate.
Therefore, the Department requires that you submit no later than thirty
(30) days from receipt of this letter a Phase II Scope of Work which complies
with 310 CMR 40.000 and conforms to the requirements and guidelines set out
above. Within fourteen (14) days of receipt of this letter you are required
ME
to notify the Department in writing of your intention to carry out all the
tasks outlined above. This letter shall include provisions to contract with
a consultant knowledgeable in the area of hydrogeological investigation and
uncontrolled hazardous waste site assessment and abatement who shall conduct
all additional site assessment and remedial response actions at the site.
You have been previously notified of your liability in the Notice of
Responsibility letter dated August 16, 1988.
Should you need additional information, please contact Marcel Boelitz
at (508) 946-2868. The Department looks forward to your cooperation in the
assessment of the site.
Very truly yours,
Mark J. aegle', Ckief
Site Remediation Section
B/MVB/lm
CERTIFIED MAIL #P707 024 566
RETURN RECEIPT REQUESTED
cc: DEP - BOSTON - BWSC
DEP - SERO - BWSC
Data Entry
Board of Selectmen
Town Hall
50 West Street
Mansfield, MA 02048
Board of Health
Town Hall
50 West Street
Mansfield, MA 02048
Conservation Commission
Town Hall
50 West Street
Mansfield, MA 02048
Keystone Environmental Resources, Inc.
3000 Tech Center Drive
Monroeville, PA 15146