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HomeMy WebLinkAboutDEQE - 8/16/1988Daniel S. Greenbaum G�e�%aalrnes�Ca��r�a�iaiu��enr�aL d �rtrrPP�vr�� Commissioner .GQI L Gilbert 1'. Jolt' �Rc � d�iiCaL oZcrA _1&A4.ar_1UMe1& O2347 Regional Dhcetm 9/s7-72,�y, �xL 680-6'8lf ( 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; M-C 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