HomeMy WebLinkAboutDEQE - 8/16/1988Daniel S. Greenbaum
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( August 16, 1988._
Hathaway & Patterson RE: MANSFIELD--OIR/SA-4-571
P.O. Box 177 Release of Hazardous Material,
Mansfield, Massachusetts 02048 15—County Street, Mansfield, MA
/' NOTICE OF RESPONSIBILITY,,
(_-Massachusetts General Laws,
Chapter 21E
ATTENTION: William E. Haynes, President
Gentlemen:
The Department of Environmental Quality Engineering, Division of
Hazardous Waste, has recently reviewed a May 1988, hydrogeological site
assessment report on the above -referenced site titled "A soils and
Hydrogeologic Investigation" prepared on your behalf by Keystone
Environmental Resources, Inc. This report complies with the requirements
of the May 21, 1987, Notice of Noncompliance issued to you by this
Department. Based upon available information, including this report, the
Department has determined that a release of hazardous material has
occurred on the property. The prevention and/or mitigation of such a
release is governed by M.G.L., Chapter 21E, the "Massachusetts oil and
Hazardous Materials Release, Prevention and Response Act."
Disposal sites identified so far` include the wood treatment area
north of the Railroad tracks and the earlier #2 fuel oil/
pentachlorophenol storage tank spill (which has been the subject of
cleanup efforts from 1972 - present) detected following seepage into the
Rumford River. Pentachlorophenol, 2,4 dinotrophenol, other phenolics,
mineral spirits, copper, chromium, and arsenic have been found at
excessive levels in ground water near the former ditch by the railroad
tracks and in soils and ground water within and south of the wood
treatment area.
The Department has reason to believe that Hathaway & Patterson Co.,
Inc. is a party with liability as defined under M.G.L., C. 21E, Section
5. The nature of this liability is joint and several without regard to
fault.
The Department is authorized pursuant to M.G.L., C. 21E, Sections
3A(j) and 4 to take such response actions at the site as it deems
necessary should you fail to respond to these releases or threats of
so
releases in an appropriate and timely manner. Any response actions taken
by the Department will be dictated by the individual characteristics of
the site and by the timeliness set out in M.G.L., C. 21E, Section 3A.
Under M.G.L., C. 21E you may be responsible for up to three times the
cost of any and all response actions conducted by the Department due to
the release. Your liability may also include damages for any injury to
or destruction or loss of natural resources resulting from the release.
You may also be liable for up to $100,000 in fines and penalties for each
violation of Chapter 21E, as well as for additional penalties or damages
pursuant to other statutes or common law.
By accepting responsibility for conducting the necessary remedial
actions and hydrogeological investigations, you can avoid:
a. interest charges on the total liability at the statutory
rate of 12% compounded annually, and
b. treble damages.
Be advised that this site has been placed on the Massachusetts
Hazardous Waste Site List in accordance with M.G.L., C. 21E, Section 3,
and progress on this site will be tracked by the Department.
As a party liable for the release/threat of a release at the site,
the Department requires that you or your representative take the steps
outlined below:
1. Provide the Department with a written response to this letter
within ten (10) days of your receipt hereof. This response
must indicate whether you accept responsibility for the
company, and the actions to be taken.
2. Your letter of intent must include provisions for continuing to
contract with a consultant knowledgeable in the area of
hydrogeological investigation and uncontrolled hazardous waste
site assessment and abatement.
3. Submit within thirty (30) days of your receipt of this letter a
Scope of Work (including the estimated time of completion
following approval by the Department) on this site meeting the
Departments requirements for a full Phase II Site Evaluation.
All data generated by the assessment of this site shall be
submitted to the Department for review and approval prior to
implementation of any long term remedial actions.
The Scope of Work shall include the recommendations for further
investigation in the Consultant's report referred to above plus address
the following concerns:
1. Complete the investigation of the physical site characteristics
including the topography, geology, surface drainage and
horizontal and vertical ground water movement east and west of
the Rumford River;
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2. Define the areal extent, depths, and severity of soil and ground
water contamination. Determine the direction(s) and rate(s) of
ground water movement. Show these in appropriate maps/plume maps
and cross sections to delineate the contaminated areas; and
3. Characterize the oil and/or hazardous materials found, evaluate
all possible migration pathways, and assess the impact on and
risk to all possible receptors.
Specific work to be covered in the scope of work shall include:
1. Submission of a topographic map of the site showing the ground
surface elevations, ditches, bedrock outcrops, slope to the
river, railroad beds, prior locations of storage tanks, current
oil recovery system, underground utilities if any laid in
permeable beds, plant water supply wells, floodplain limits, and
any other features which could affect the hydrogeology of this
site;
2. Soil samples to be taken within the area and down slope of the
former ditch by the railroad (Figure 3-7a in the above referenced
report) where contaminants may have flowed, and installation of a
monitoring well if necessary;
3. Soil indices testing to determine the effective porosity and
permeability of selected soil samples;
New Department Standards specify that one well boring on each
site must be continuously sampled, and all others (except
adjacent pairs or triplets) be sampled to TD every five feet and
at every change in lithology. Detailed (not general)
descriptions of the in spoon sample including layering must be
taken. Please include these guidelines in your future overburden
boring program.
4. Test selected soil sample(s) from the new borings on site in a
certified lab for the equivalents of EPA methods 624 & 625 plus
metals, including QA/QC information. Soil samples may be
screened at the site with an HNU, OVA, or portable GC; where
contamination is found the worst sample in each boring should be
sent to the lab;
5. Determine the flow from or to all dry wells, ditches, culverts,
storm drains, oil recovery structures, and plant water supply
wells, and evaluating the impact if any from these on groundwater
levels and movement;
6. Soil borings and installation of at least one monitoring well
within/directly downgradient of the former railroad bulk chemical
storage area west of the river, with groundwater and multilevel
soil samples to be taken and analyzed;
-4-
7. Installation of additional wells as recommended by your
consultant and/or measure soil gas and/or use geophysical methods
east and south of the present monitoring wells until the limits
of the ground water contamination plume are defined. An
additional monitoring well north of MW-2/MW-3 is also needed for
upgradient control;
8. If additional sampling shows MW-4 to be contaminated, or if the
well to be installed near the former railroad bulk chemical
storage area west of the river is contaminated, at least one more
monitoring well will be needed west of the river to delineate the
extent of contamination;
9. Borings and geophysical methods used as necessary to map the
bedrock surface including outcrop(s). both east and west of the
river. Correct the bedrock surfaces shown in crossections A -A'
and B-B' of the above referenced report, and/or make new
crossections (actual, not projected) and maps as needed to show
the bedrock in relation to overburden thickness and ground water
flow. Take cores; determine the rock type(s); determine the
porosity, degree of fracturing, and fracture orientation in the
most expeditious manner; and calculate the Hydraulic
Conductivity, effective porosity/specific yield, and velocity of
ground water movement if any through the bedrock. Determine the
areal and vertical extent of contamination if any in bedrock
under the plant and to the south.
10. Relate the water table elevations as mapped to the water surfaces
in the ditches, streams, the wetland area to the south, and the
Rumford river. Determine if there is any hydrologic connection
between the ground water on site and these surface waters. Take
samples from and evaluate the possible contamination in the
wetlands and Rumford River backwash area to the south; and
11. Test ground water samples from all monitoring wells on site in a
certified lab using EPA methods 624 & 625 plus metals, including
QA/QC information. Your consultant will need to determine the
necessary future sampling methods and frequency from these
results.
A Phase II scope of work must include:
1. The proposed sampling plan including locations for all media,
including geophysical methods if any;
2. A summary of the proposed risk assessment procedure; and
3. The expected completion dates (following approval of the Scope of
Work by the Department) for all work and reports.
The proposed schedule shall allow for prompt submission (following
completion of the Phase II study) of a Phase III scope of work and
schedule. A Phase III study is needed to identify and evaluate remedial
response alternatives and prepare the final Remedial Response Plan (FRRP).
a.-M
If you wish to continue and/or expand the short term remediation
measures at this site, as recommended by your consultant, please submit a
written proposal to the Department. Verbal permission to temporarily use
ground water from existing monitoring well(s) for process water in the
wood treatment facilities was given by Patricia Billingsley on August 3,
1988.
Depending on the information generated by the above work, the
Department may require additional investigations, studies, and actions.
If you fail to take these actions or fail to perform these tasks in
accordance with the standards of the Department, the Department may
perform response actions in your stead and recover its costs in accordance
with the provisions described above.
If you should have any questions regarding this matter, please
contact Patricia Billingsley of this Department. In any correspondence to
this office, please refer to DEQE case number 4-571.
Very tr ly yours,
Chri topher Tilden, P.E., Chief
Hazardous Waste Section
T/PB/bh
CERTIFIED MAIL #P480 968 945
RETURN RECEIPT REQUESTED
cc: DEQE - OIR
ATTN: Ed Benoit
Board of Health
Town Hall
Mansfield, MA 02048
Conservation Commission
Town of Mansfield
50 West Street
Mansfield, MA 02048
Ronald J. O'Toole
Project Manager
Keystone Environmental Resources, Inc.
440 College Park Drive
Monroeville, PA 15146