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45 CONGRESS STREET PHASE III RAP AND PHASE IV RIP HEUEIVED PAKrNER AUG 2 6 2024 Engineering and Science, Inc. CITY OF SALEM BOARD OF HEALTH August 21, 2024 David Greenbaum, Health Agent Board of Health Salem City Hall 98 Washington Street Salem, MA 01970 Subject: Phase III Remedial Action Plan and Phase IV Remedy Implementation Plan Prime Storage Shetland— Building 4 45 Congress Street Salem, Massachusetts 01970 Release Tracking Number(RTN): 3-35818 Dear Mr. Greenbaum: On behalf of Prime Storage Shetland, LLC, this letter is being sent to you to fulfill the public involvement provisions of the Massachusetts Contingency Plan (MCP) for the above-referenced Site. The public involvement provisions [310 CMR 40.1403(3)(e)] require that the Chief Municipal Officer and the Board of Health in the community in which a disposal site is located be notified that a report entitled "Phase III Remedial Action Plan and Phase IV Remedy Implementation Plan" (referred to as the Phase III and IV report) has been completed for the above-named property. A copy of the summary of findings and statement of conclusions included in the Phase III and IV report is enclosed. The Phase III and IV report was submitted electronically to the Massachusetts Department of Environmental Protection. It is available for review using the following link: httpublic.dep.state.ma.us/SearchableSites/Search.asl_ In accordance with the MCP, a copy of the description of the Comprehensive Remedial Action that is discussed in the Phase IV Remedy Implementation Plan has been provided to you. If you have any questions concerning this letter, please contact the undersigned at (508) 876-2660. Sincerely; Partner Engineering and Science, Inc. .-�) ,/Vv A LAU Tom A. Campbell, LSP Susan O'Brien, LSP Senior Project Manager Senior Project Manager Enclosure 800-419-4923 www.PARTNEResi.com 9.0 PHASE IV REMEDY IMPLEMENTATION PLAN In accordance with 310 CMR 40.0874(3), the following information is required for the Phase IV RIP. 9.1 Contact Information The contact information of the owner/operator and Licensed Site Professional (LSP) of the selected Comprehensive Remedial Alternative during and following construction are provided below, along with the party responsible for the operation and maintenance of the selected Comprehensive Remedial Alternative during and following construction. Subject Property Owner/ Prime Storage Shetland, LLC Operator/Responsible Party: 85 Railroad Place Saratoga Springs, New York 12866 Telephone: 518-615-0552 Robert Moser, Manager Licensed Site Professional Thomas A. Campbell, LSP and Party Responsible for Partner Engineering and Science, Inc. Remedy Operations and 495 Old Connecticut Path, Suite 120 Maintenance: Framingham, Massachusetts 01701 Telephone: 508-876-2660 9.2 Overview of the Remedial Action and Remedial Action Goals The goal of the selected Remedial Action Alternative as evaluated in the Phase III RAP is to achieve a Permanent Solution for the Site.A Permanent Solution will be achieved by mitigating vapor intrusion at the Disposal Site to levels that constitute a condition of No Significant Risk for CVOCs in indoor air. This goal been achieved for the majority of the Disposal Site already by mitigating vapor intrusion for current use through sealing of preferential pathways and by the installation and operation of seven SSDSs at Building 4 and one SSDS each at the off-site multi-family residential properties with addresses of 40 and 44 Pingree Street and 78 Palmer Street. The Building 4 SSDSs have been operating since May 2022 and the SSDSs at 40 and 44 Pingree Street have been operating since February 2024. The installation of another SSDS was performed on August 12 and 13, 2024 for another off-site multi-family residential property with an address of 78 Palmer Street,since elevated CVOC concentrations were detected in sub-slab soil gas and indoor air during two sampling rounds conducted in November 2023 and February 2024. A condition of No Significant Risk was achieved for current use but was not achieved for unrestricted future use. Background and sampling details for the 78 Palmer Street property are provided in the Supplemental Phase II Comprehensive Site Assessment report. At 20 Pingree Street, Partner completed a third sampling event due to previously detected elevated soil gas concentrations. In the unfinished basement, TCE was detected in indoor air but below the MassDEP Residential Threshold Values. No other VOCs were detected above laboratory reporting limits. At the soil gas location with the elevated concentration, TCE and PCE were detected but below MassDEP Residential Sub-Slab Soil Gas Screening Values. At a second location, TCE was detected above and PCE below the MassDEP Residential Sub-Slab Soil Gas Screening Values. At a third location TCE and PCE were detected below the MassDEP Residential Sub-Slab Soil Gas Screening Values. In summary, a condition of No Phase III RAP and Phase IV RIP PARTNER Prime Storage Shetland, RTN 3-35818 August 21, 2024 Page 25 Significant Risk exists for current but not future uses based on the results of the sampling performed. Partner will collect additional soil gas samples to further characterize soil gas TCE concentration trends. At Harbor Sweets, the commercial property with an address of 85 Leavitt Street, indoor air samples and soil gas samples were collected on two occasions by Partner. TCE was detected in two indoor air samples but below the MassDEP Commercial/Industrial Threshold Values. TCE was detected in one soil gas above the C/I SV. 1,1,1-TCA was detected in two soil gas samples and PCE was detected in one soil gas sample but below the MassDEP Residential Sub-Slab Soil Gas Screening Values. The second sample event detected TCE in one soil gas above the MassDEP Commercial/Industrial Sub-Slab Soil Gas Screening Values. 1,1,1-TCA was detected in two soil gas samples and PCE was detected in one soil gas sample but below the MassDEP Residential Sub-Slab Soil Gas Screening Values. The second sample event detected TCE and PCE in three indoor air samples but below the MassDEP Commercial/Industrial Threshold Values. In summary, a condition of No Significant Risk exists for current and future commercial use. An AUL will be required to reassess vapor intrusion if the property building and/or use changes. 9.3 Preferential Pathway Sealing Evaluation at 78 Palmer Street Prior to installing a SSDS at 78 Palmer Street, Partner evaluated if any preferential pathway sealing should be performed prior to installing the SSDS. The evaluation did not identify any areas that required sealing and upon system start up, Partner did not detect any audible sounds of indicative of areas that needed sealing. 9.4 SSDS Design, Installation and Start-Up at 78 Palmer Street The SSDS consists of one extraction point installed in the basement slab floor. The extraction point and interior and exterior conveyance piping was constructed of 3-inch diameter schedule 40 PVC piping. The extraction piping was routed to the exterior wall along the south of the building. Horizontal piping was pitched to allow condensation to drain back to the extraction point and all PVC was assembled using compatible PVC primer and cement on all joints and fittings to ensure an air-tight seal. The extraction point vertical riser was fitted with; a'/4-inch FNPT-sample port and threaded plug for airflow and vacuum monitoring, and a Digital Manometer which is an easy-to-read constant vacuum monitoring device. A label with pertinent system installation and operating information was also attached to the riser pipe. At the exterior of the building the inline extraction fan was mounted installed on the exterior south wall. An exterior-rated in-use-covered ground-fault circuit interrupter (GFCI) receptacle and dedicated circuit breaker was previously installed by Bolduc Electric (License MA#15957A) to power the extraction fan.One Obar GBR76-SOE radon fan capable of producing the necessary vacuum and air flow was installed to extract air from the sub-slab and discharge it to the atmosphere through a discharge stack plumbed and mounted above the roof-top parapet. All vertical exterior piping up the backside of the building is 3-inch PVC pipe sealed at each joint and anchored to the block fa4ade.At approximately 4-feet above the roof-top parapet and greater than 10-feet from the nearest building opening, the discharge end point was fitted with a rain guard. Based on the configuration of one extraction point, three permanent vacuum monitoring points (MPs) identified as MP-1, MP-2, and MP-3 were installed throughout the extraction area floor slab to facilitate Phase III RAP and Phase IV RIP PARTNER Prime Storage Shetland, RTN 3-35818 August 21, 2024 Page 26 monitoring of the SSDS. The MPs were sealed to the surrounding concrete floor with putty due to the thinness of the slab floor. An Obar GBR25T digital gauge was installed on the interior exhaust piping downstream of the extraction pipe to monitor vacuum levels and system operation. On August 12, 2024, the SSDS fan was started. Sub-slab vacuum monitoring point verification was subsequently conducted by Partner. Results indicated that the SSDS was maintaining sufficient vacuum influence across the targeted area below -0.004 inches of water column ("w.c.).The Obar installation report is included in Appendix B. Partner is currently scheduling the collection of confirmation indoor air samples to test the effectiveness of the SSDS. 9.5 Design and Construction Schedule at 78 Palmer Street The SSDS was installed in August 2024. 9.6 Indoor Air Testing After SSDS Installation at 78 Palmer Street After the SSDS has been operating for approximately one week, indoor air sampling and monitoring of sub- slab vacuum will be conducted concurrently to determine if the system is meeting the remediation goals. In accordance with MassDEP's Vapor Intrusion Guidance, once a pressure differential across the slab is established, at least one round of indoor air sampling will be conducted during the heating season. If it is determined that the system is effectively reducing indoor air contaminant concentrations, the differential pressure confirmed to be adequate during this sampling can then be used to monitor system effectiveness. 9.7 As-Built Construction Report/Final Inspection Report for 78 Palmer Street Upon completion of the construction activities and initial startup of the SSDS at 78 Palmer Street, the LSP- of-Record will conduct a combined final inspection of the construction and implementation of the selected Remedial Action Alternative to confirm the remedy has been constructed in accordance with the construction plans cited with this Phase IV RIP. The LSP will document the inspection of the SSDS in a Final Inspection Report to be submitted with the Phase IV RIP Completion Statement to the MassDEP. 9.8 Remedial Monitoring Reports for 78 Palmer Street The selected Remedial Action Alternative includes an Active Remedial System as defined in 310 CMR 40.0006.Therefore, the results of the performance monitoring conducted as described in previous sections of Phase IV RIP will be presented in semi-annual Remedial Monitoring Reports. 9.9 Health and Safety Plan for 78 Palmer Street A Site specific Health and Safety Plan for this Disposal Site remediation program has been prepared and addresses activities that personnel may conduct during the implementation, construction, and operation of the selected Remedial Action Alternative as described in this Phase IV RIP.Compliance with the Health and Safety Plan is required for all personnel involved with this remediation program. However, the Health and Safety Plan is not intended to and may not address the activity-specific health and safety needs or requirements of any contractors and their employees and therefore cannot be used as the sole Health and Safety Plan document by contractors or their personnel. As required by the Occupation Safety and Health Phase III RAP and Phase IV RIP PARTNER Prime Storage Shetland, RTN 3-35818 August 21, 2024 Page 27 Administration (OSHA), contractors must provide applicable job hazard analyses for each task/activity they will perform under the Site remediation program. The Site specific Health and Safety Plan may be revised to incorporate additional or updated information made available to health, safety and environmental (HSE) personnel. This information may include monitoring results, changes in remediation activities or equipment, etc. Any changes proposed must be reviewed by HSE staff and are subject to approval by the HSE Manager and the Project Manager.Approved Health and Safety Plan changes will be communicated to all affected on-site personnel. 9.10 Permits, Licensed and Approvals for 78 Palmer Street Construction and implementation of the selected Remedial Action Alternative primarily consisted of the installation of extraction and vapor monitor points and piping. Due to the minor electric work, a permit was not required from the City. Phase III RAP and Phase IV RIP PARTNER Prime Storage Shetland, RTN 3-35818 August 21, 2024 Page 28