Soil and Groundwater Management Plan - October 2015
SOIL & GROUNDWATER MANAGEMENT PLAN
and
HEALTH and SAFETY PLAN
Former Universal Steel & Trading Company Site
297 – 305 Bridge Street
Salem, Massachusetts
Release Tracking Number (RTN) 3-11726
October 2015
Prepared for:
Mr. Robert Mucciarone
F.W. Webb Company
160 Middlesex Turnpike
Bedford, Massachusetts 01730
Prepared by:
One Mifflin Place, Suite 400
Cambridge, Massachusetts 02138
Felix A. Perriello, CHMM, CPG, LSP, LEP
Principal Scientist
Richard C. Hittinger
President
Joel Walcott, PE
Senior Engineer
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297-305 Bridge Street, Salem, MA October 2015
TABLE OF CONTENTS
1.0 INTRODUCTION ................................................................................................................... 1
2.0 SITE DESCRIPTION ............................................................................................................. 1
3.0 BACKGROUND ..................................................................................................................... 1
4.0 ACTIVITY AND USE LIMITATION ....................................................................................... 3
5.0 PROPOSED BUILDING ACTIVITIES ..................................................................................... 5
6.0 SOIL MANAGEMENT PLAN ................................................................................................. 5
6.1 SOIL MANAGEMENT PRACTICES ................................................................................... 5
6.2 SOIL TRANSPORTATION PRACTICES .............................................................................. 6
6.3 DUST CONTROL PRACTICES .......................................................................................... 7
6.4 EROSION CONTROL PRACTICES .................................................................................... 8
7.0 GROUNDWATER MANAGEMENT PLAN .............................................................................. 8
7.1 GROUNDWATER MANAGEMENT PRACTICES ................................................................. 8
7.2 GROUNDWATER TRANSPORTATION PRACTICES ............................................................ 9
8.0 HEALTH AND SAFETY PLAN ............................................................................................... 9
8.1 HAZARD EVALUATION AND CONTAMINANTS OF CONCERN .......................................... 9
8.2 SITE CONTROL ............................................................................................................ 10
8.3 NOISE CONTROL ......................................................................................................... 10
8.4 PERSONAL PROTECTIVE EQUIPMENT .......................................................................... 11
9.0 DECONTAMINATION PLAN ............................................................................................... 12
9.1 EQUIPMENT DECONTAMINATION PROCEDURE ............................................................ 12
9.2 PERSONNEL DECONTAMINATION PROCEDURE ............................................................ 15
9.3 CONSTRUCTION VEHICLE DECONTAMINATION PROCEDURE ...................................... 16
10.0 COMMUNICATION AND EMERGENCY PROCEDURES ........................................................ 16
FIGURES
Figure 1 Site Locus Map
Figure 2 Site Plan
Figure 3 Proposed F.W. Webb Building Layout
APPENDICES
Attachment A Plan Approval Agreement
Attachment B Compliance Agreements
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297-305 Bridge Street, Salem, MA October 2015
1.0 INTRODUCTION
Alliance Environmental Group, Inc. (AEG) has prepared this combined Soil and Groundwater
Management Plan (S&GMP) and Health and Safety Plan (HASP) on behalf of F.W. Webb
Company (F.W. Webb) for the proposed building construction at the Former Universal Steel &
Trading Company Site located at 297-305 Bridge Street, Salem, Massachusetts (Site). The
Massachusetts Department of Environmental Protection (MassDEP) assigned Release Tracking
Number (RTN) 3-11726 to the Site. The Site Contractor must review this S&GMP carefully and
make any changes necessary for them to accept the Plan in its entirety. This Plan, as modified
and accepted, will then be the operative Plan that the Contractor will follow at this Site.
The proposed building will include a two-story warehouse, office space, and a showroom center.
Please refer to Figures 1 through 3 for details.
2.0 SITE DESCRIPTION
The former Universal Steel & Trading Company property is located at 297-305 Bridge Street in
Salem, Massachusetts. The Site location is shown in Figure 1 (Locus Map).
Regulations applicable to Universal Steel & Trading Company include the following:
- 40 CFR 761
- 310 CMR 40.0000
- 310 CMR 40.0030 et seq
- 310 CMR 40.0018
The Site consists of an approximately 1.2 acre parcel located in an area of mixed commercial and
residential use. The area surrounding the Site is shown in Figure 2 (Site Plan). As shown in
Figure 2, the Site is abutted by Bridge Street to the north, a F.W. Webb plumbing supply store to
the east, residential properties to the south, and Beckford Street to the west. Historically, the Site
was developed and contained several structures, including a two-story warehouse building, two
large concrete pads, and several ancillary features (i.e., truck scale and paved loading areas).
The historical warehouse building was demolished in 2012. The remaining Site features were
demolished and removed as part of Site remediation completed in 2013.
Currently, the Site is used as a temporary parking lot for a nearby Massachusetts Bay
Transportation Authority (MBTA) train station. The parking lot was opened by the City of
Salem in October 2013 following Site remediation. The parking lot consists of a large central
paved area with small landscaped islands and vegetative buffer areas along the perimeter of the
Site. In addition, two sediment forebays are located at each corner of the parcel along Bridge
Street.
3.0 BACKGROUND
In October 1994, MassDEP assigned Release Tracking Number (RTN) 3-11726 to the Site
following notification of a release to soil and groundwater of polychlorinated biphenyls (PCBs),
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297-305 Bridge Street, Salem, MA October 2015
metals and petroleum. The release was identified during soil and groundwater assessment
activities completed at the Site from November 1993 until July 1994. The source of
contamination was attributed to the former metals recycling and reclamation activities conducted
by the Universal Steel & Trading Company at the Site.
Since the release was discovered, several subsurface investigations and preliminary response
actions were conducted at the Site. In 2011, Weston & Sampson (W&S) completed a Phase II
Comprehensive Site Investigation (CSA) to evaluate the current nature and extent of
contamination at the Site, and a Site-specific Method 3 Risk Characterization (M3RC) to
evaluate risk to human health, safety, public welfare, and the environment. The 2011 M3RC
indicated that a condition of No Significant Risk (NSR) to human health did not exist due to the
potential exposure to PCBs in soil.
Based on the findings of the Phase II CSA and M3RC, W&S evaluated several remedial options
for the Site under the direction of the MassDEP and the U.S. Environmental Protection Agency
(USEPA) from June 2011 until October 2011. Subsequently, a multi-agency team consisting of
MassDEP, USEPA, the City of Salem, and MassDevelopment agreed to fund and implement a
risk-based cleanup of the Site. The risk-based cleanup approved by MassDEP and USEPA
included the excavation and removal of the top foot of soil across the Site and the select removal
of deeper PCB-impacted soils with concentrations greater than 50 parts per-million (ppm). At
the conclusion of the removal actions, the construction of a pavement cap and implementation of
an Activity and Use Limitation (AUL) was proposed to mitigate future direct exposure to
residual PCB impacts at the Site.
The applicable USEPA regulations for the Site included the following Risk Based Cleanup
Standards:
- 40 CFR 761.61(c)
- 40 CFR 761.61(a)(3)
- 40 CFR 761.62(c)
The applicable MassDEP regulation for the Site included 310 CMR 40.0321(2)(b) - Imminent
Hazards.
The excavation and removal of PCB-impacted materials was completed as a Removal Action
under USEPA’s Emergency Response and Removal Program (ERRP). The Removal Action was
initiated in December 2012 and was completed in September 2013. In total, approximately
6,380 cubic yards of PCB-impacted soil and concrete were excavated and disposed off-site as
part of the Removal Action, and 81 post-excavation confirmatory soil samples were collected to
verify the limits of remediation. EPA subsequently backfilled and compacted the Site with
gravel, and Manter Construction installed a paved parking lot and stormwater control features
(i.e., sediment forebays). The parking lot cap construction was completed in October 2013.
Weston & Sampson utilized the 2013 EPA post-excavation soil analytical results and historical
data sets for contaminants of concern remaining below the final USEPA excavation depths to
perform an updated M3RC for the Site. The updated M3RC indicated that the MassDEP and
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297-305 Bridge Street, Salem, MA October 2015
USEPA risk-based cleanup achieved a condition of NSR for current and future Site use with the
implementation of an AUL. Therefore, the requirements for a Permanent Solution with
Conditions Statement were achieved at the Site.
4.0 ACTIVITY AND USE LIMITATION
The risk-based cleanup plan included the excavation and off-site disposal of PCB contaminated
soil and concrete, capping the Site with asphalt, and implementing an AUL to mitigate and
control the direct exposure to residual PCBs in soil.
The AUL was executed in December 2014.
Activities and Uses Consistent with Maintaining No Significant Risk Condition at the Site
included the following:
Industrial uses including, but not limited to, a parking lot.
Activities and uses including, but not limited to, normal commercial and industrial operations,
pedestrian and/or vehicle traffic, and vehicle parking.
Any landscaping activities including, but not limited to, lawn mowing, mulching, weeding,
and/or planting of flowers, trees, and shrubs, provided the pavement, orange geotextile liner and
soils located beneath the liner at 1.5 feet or more below the surface grade are not disturbed by the
landscaping activities.
Underground utility and/or construction activities including maintenance or repair of Site
improvements, or utility repair and maintenance, excavation, movement and handling of soils
below the geotextile liner at depths greater than 1.5 feet or more provided that such activities are
conducted in accordance with a Soil Management Plan (SMP) and a Health and Safety Plan
(HASP) in accordance with Conditions of the AUL.
Such other activities or uses which, in the Opinion of a Licensed Site Professional (LSP), shall
present no greater risk of harm to health, safety, public welfare or the environment than the
activities and uses set forth in the AUL.
Such other activities and uses not identified in the AUL as being Activities and Uses Inconsistent
with Maintaining No Significant Risk Conditions.
Activities and Uses Inconsistent with Maintaining No Significant Risk Conditions included the
following:
Residential uses, including but not limited to, one family or two-family dwellings, apartments,
tenement houses, condominiums or town houses, mobile homes, lodging houses, nursing or rest
homes, or dormitories.
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Agricultural uses, including but not limited to, tilling and planting of gardens or crops for human
consumption.
Institutional uses, including but not limited to, public or private schools and day care facilities.
Activities or uses which are likely to involve the removal and/or disturbance of the contaminated
soil located beneath the geotextile liner at the Property with the exception of underground utility
and/or construction work carried out in accordance with the Conditions set forth in the AUL,
unless an LSP renders an Opinion which states that a Level of No Significant Risk is maintained
at the Site consistent with the Massachusetts Contingency Plan (MCP).
Any use or activity that may involve direct ongoing contact to the contaminated soil located
beneath the geotextile liner, or any use or activity that may not comply with the Conditions set
forth in the AUL.
Such other activity and uses not identified in the AUL, but identified as being Activities and
Uses Inconsistent with Maintaining No Significant Risk Conditions.
The following obligations and/or conditions are necessary and must be undertaken and/or
maintained at the Property to maintain a Permanent Solution and a condition of No Significant
Risk.
Maintain existing asphalt pavement, concrete blocks, and sidewalks such that the physical
integrity of each surface is not compromised.
Maintain existing landscaped areas such that soil erosion does not degrade and compromise the
existing asphalt pavement.
Perform annual inspections to confirm that existing asphalt pavement, concrete blocks, sidewalks
and landscaping are properly maintained.
A SMP must be prepared by an LSP in accordance with the remediation waste management
procedures of the MCP and the Toxic Substances Control Act (TSCA), and implemented at the
commencement of any activity that may disturb contaminated soil located beneath the geotextile
liner at the Property. The SMP should describe appropriate soil excavation, characterization,
handling, storage, transport, and disposal procedures and include a description of the engineering
controls and air monitoring procedures necessary to ensure that workers and receptors in the
vicinity are not affected by fugitive dust or particulates. On-site workers who may come in
contact with the contaminated soil should be appropriately trained on the requirements of the
SMP, and the plan must be available on-site throughout the course of a project.
A HASP must be prepared by a certified Industrial Hygienist or other qualified individual
sufficiently trained in worker health and safety requirements, and implemented prior to the
commencement of any activity that may disturb contaminated soil located beneath the geotextile
liner at the Property. The HASP should specify the type of personal protection (i.e., clothing and
respirators), engineering controls, and environmental monitoring necessary to prevent worker
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exposures to contaminated soil through dermal contact, ingestion, and/or inhalation. On-site
workers who may come in contact with the contaminated soil should be appropriately trained on
the requirements of the HASP, and the plan must be available on-site throughout the course of a
project.
The contaminated soil located beneath the geotextile liner must remain at depth and may not be
relocated, unless such activity is first appropriately evaluated by an LSP who renders an Opinion
which states that such relocation is consistent with maintaining a condition of No Significant
Risk.
5.0 PROPOSED BUILDING ACTIVITIES
F.W. Webb is proposing to construct a single-story warehouse with adjoining two-story
showroom at the Site. The warehouse will encompass 15,875 ft2 and the showroom 10,225 ft2
for a total footprint of about 26,000 ft2. F.W. Webb will utilize Vibro-Stone Columns (VSC) to
construct the new building foundations. VSC are continuous vertical columns of dense
interlocking aggregate that are formed by inserting a vibratory probe to incorporate granular
material into the ground and create vertical inclusions with high stiffness, shear strength and
draining characteristics. VSC are a highly efficient and cost-effective solution for improving soil
prior to construction of foundations and slabs for commercial, industrial and residential
buildings; to reduce settlement in areas of landfills; and to reduce the risk of liquefaction under
roadways, airport runways, embankments and bridges.
The use of VSC will significantly reduce the volume of soil that will require off-site disposal.
6.0 SOIL MANAGEMENT PLAN
6.1 Soil Management Practices
During redevelopment, the movement and regrading of Site soils will be required. Currently, the
Site is being managed under an AUL which, as detailed in Section 4.0, mandates certain Site
uses and activities. The AUL does allow construction activities to occur within the top 1.5 feet
(above the geotextile liner) at the Site. However, at depths below the liner located at 1.5 feet
below ground surface (bgs), soils will be encountered in some areas of the Site that contain PCBs
at concentrations that exceed the allowable risk levels. For this reason, great care must be
implemented when work may extend beyond the 1.5 feet depth of the geotextile demarcation. It
is also noted that during the 2013, PCB-impacted soils were excavated to depths between 1.5 and
4.0 feet bgs. As such, all soils located above the completion depths of the excavation currently
consist of clean fill material and will be suitable for reuse on-Site.
As previously agreed upon by USEPA and MassDEP, excavated material with PCB levels below
10 milligrams per kilogram (mg/kg) can be reused on-Site under a cap. Materials exhibiting PCB
concentrations above 10 mg/kg materials will be segregated into two waste streams: materials
with PCB concentrations in excess of 50 mg/kg and materials with PCB concentrations less than
50 mg/kg. The excavated materials will be segregated into two waste streams since USEPA and
MassDEP indicated that soils with PCB levels above 50 mg/kg would need to be disposed off-
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Site as TSCA bulk remediation waste at a TSCA-certified landfill. Alternatively, soils with PCB
concentrations less than 50 mg/kg could be disposed off-Site as non-TSCA waste at a Subtitle D
landfill facility.
As stated previously in Section 4.0, F.W. Webb and its construction manager, Green Leaf
Construction (GLC), plan to limit soil excavation by installing soil foundations using VSC. The
installation of the VSC will likely extend to depths of to 8 to 10 feet bgs or greater; however, this
method does not result in the generation of drill cuttings that would require management. The
primary construction activities that will result in the generation of potentially impacted soil
include the following:
- Installation of the F.W. Webb building foundation walls; and
- Installation of the storm water catch basins and associated drainage lines to the south and
east of the proposed building location.
During any excavation activities, soils required to be stockpiled shall be placed on (and covered
with) 6-mil polyethylene sheeting at all times. During cases where soils are to be stockpiled for
an extended period of time (i.e., greater than one week), daily inspection of the stockpile shall be
made to ensure controls are maintained and, if needed, repaired. If stockpiling is necessary, a
berm with hay bales to filter and prevent run-off will be installed around the stockpile. In
addition, the stockpile will be located away from storm drains and encircled with temporary
fencing and signage.
Proper application and disposal at a licensed facility will be required for all excavated soils
exhibiting PCB levels above 10 mg/kg. This will entail, at a minimum, sampling of stockpiled
soils for the permitted facility’s requirements and detailed documentation for record keeping
purposes. In addition, the stockpiled soils will be analyzed for PCBs using EPA Method 8082
with soxhlet extraction. Soil disposal shall be completed using the Bill of Lading (BOL)
process, pursuant to the MCP (310 CMR 40.0000) requirements.
All stockpiled soils will be thoroughly characterized prior to transporting such stockpile(s) for
off-site disposal. Representative soil samples will be collected from any stockpiles to determine
whether such soil does or does not exceed any applicable analytical performance standards (such
as the MCP Risk Characterization Standards or a selected receiving facility’s acceptance
criteria). All soil testing will be completed by a Commonwealth of Massachusetts-certified
analytical laboratory in accordance with MassDEP regulations and guidelines.
Non-TSCA PCB-impacted materials will be transported off-site under a Massachusetts BOL.
The PCB-impacted materials disposed of as TSCA bulk remediation waste will be transported
off-site using uniform hazardous waste manifests.
6.2 Soil Transportation Practices
F.W. Webb and GLC will retain a transportation and disposal (T&D) contractor to transport and
dispose of any excavated soils in compliance with applicable legal requirements; that is, at a
TSCA-certified landfill for PCB-impacted soils above 50 mg/kg and a Subtitle D landfill facility
for PCB-impacted, non-TSCA soils (below 50 mg/kg and above 10 mg/kg).
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Anti-Tracking: F.W. Webb and GLC will employ anti-tracking measures (street sweepers, anti-
tracking pads, stone tracking pad, etc.) at the Staging, Transfer and/or Temporary Storage Areas
designated at the Site during the new building construction to ensure that vehicles that have
entered the Staging, Transfer and/or Temporary Storage Area do not track soils from the Site
onto a public roadway at any time. Construction entrance anti-tracking pads shall be constructed
in a manner that is consistent with applicable Best Management Practices (BMPs).
Transporter Practices: The permittee shall instruct the transporters of contaminated soil and/or
sediment of BMPs for the transportation of such soil (proper tarping of hauling dump bodies,
removing loose material from dump bodies, etc.).
Queuing and Idling of Transport Vehicles: GLC or its designated representative will control all
traffic related to the operation of the facility in such a way as to mitigate the queuing of vehicles
off-site and/or an excessive or unsafe traffic impact in the area surrounding the Site.
6.3 Dust Control Practices
Preventative measures shall be made during all on-Site construction and remedial activities to
minimize the generation of dust at the Site. During the progress of work, dust control shall be
maintained by applying a spray mist of water to on-Site soils to minimize the creation and
dispersion of dust. Site soils shall be lightly misted (not saturated) continuously throughout the
entire workday or controlled by some other LSP-approved method. The contractor shall provide
the labor, water, and sprayer for misting purposes.
During earthwork activity, a perimeter-monitoring program shall be conducted. At least two air
monitors shall be positioned at the perimeter of the Site downwind from the subject activity, and
one upwind (together creating roughly an equilateral triangle). These monitors shall be capable
of reading PM-10 particulates on real-time and time-weighted-average (TWA) to 0.001 mg/m3.
The meters shall be monitored at a minimum of every hour.
Based on the background level monitoring, AEG will develop an action level that will ensure
Site activities will be conducted in a manner that will not generate unacceptable levels of fugitive
dust. The background particulate level shall be based on the upwind level concentrations. The
upwind dust concentration can be subtracted from the downwind dust concentration in order to
measure the impacts from the monitored site.
As stated previously, the dust action level will be established using risk-based calculations for
Site contaminants as well as the MassDEP Real-Time Air Monitoring at Construction and
Remediation Sites guidance document dated October 1997. From the MassDEP guidance, the
action level will be established as 0.02 mg/m3 above background.
During the proposed activities, any time that the difference between downwind and upwind 10-
minute TWA readings exceeds the established action level, Site activities shall cease until
operation modifications are implemented to lower the exceedance.
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Dust Controls: GLC shall minimize wind erosion and dust transport from the stockpiles and the
travel areas of the Staging, Transfer and/or Temporary Storage Areas by ensuring that all
necessary dust controls (tarps, dust suppressants, routine street sweeping, etc.) are implemented
and maintained at all times during periods of operation.
6.4 Erosion Control Practices
As discussed in the section above, proper misting of exposed Site surfaces will be implemented
to prevent fugitive dust. Mitigation measures shall also be implemented to prevent movement of
soils across the Site through precipitation events and adverse weather conditions including heavy
rain or excessive wind. To prevent off-site movement of soils, proper erosion controls shall be
placed along the perimeter of the work area. These measures shall entail the use of silt fencing
in conjunction with hay bales or straw wattles.
GLC or its designated representatives shall place the soil stockpiles on an impervious surface to
prevent or minimize the transfer or infiltration of contaminants from the soil stockpiles into the
ground surface. In addition, GLC shall minimize or control stormwater run-on and run-off. As
discussed previously, soil stockpiles shall be covered at the end of each operating day or at any
time that the Staging, Transfer and/or Temporary Storage Areas are unattended. Run-on/run-off
controls shall be consistent with applicable BMPs.
Proper care and maintenance shall be conducted on all erosion controls. The controls shall be
inspected weekly and after storm events to ensure their integrity is maintained.
7.0 GROUNDWATER MANAGEMENT PLAN
7.1 Groundwater Management Practices
The depth to groundwater at the Site is typically between four and six feet bgs. As such,
excavation dewatering will likely be required to facilitate the installation of the Site utilities and
certain sections of the building foundation wall. Based on the results of previous environmental
investigations, groundwater in certain areas of the Site contain cadmium and chlorobenzene at
concentrations above the associated MCP GW-2 and/or GW-3 Groundwater Standards. As such,
groundwater containment and disposal processes during construction will be carefully managed
to minimize the potential risk of exposure to the residual dissolved-phase contaminants.
The volume of groundwater to be generated during station construction activities is not expected
to exceed approximately 30,000 gallons. The dewatering estimate was based on a Site hydraulic
conductivity of 0.168 feet/day obtained by W&S during the implementation of Phase II
activities. The calculated groundwater infiltration rate is estimated at 500 gallons per day. Given
the relatively small volume anticipated to be generated, it is recommended that any groundwater
infiltrating the excavations and/or trenches be pumped from the excavation into fractionation
tanks to be staged on-Site during construction. Disposal of the recovered groundwater will
require proper application to and disposal at a licensed water disposal facility. This will entail, at
a minimum, sampling of groundwater within the fractionation tank for the permitted facility’s
requirements and detailed documentation for record keeping purposes. All groundwater testing
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will be completed by a Commonwealth of Massachusetts-certified analytical laboratory in
accordance with MassDEP guidelines. Groundwater disposal shall be completed pursuant to the
applicable MCP (310 CMR 40.0000) requirements.
At the conclusion of the dewatering activities, and prior to removal from the Site, the
fractionation tank will require cleaning to remove any sediment buildup at the bottom. The
cleaning will be conducted by a safety-trained contractor licensed to perform permitted confined
space entry. Sediment accumulated within fractionation tanks is usually shoveled into
Massachusetts Department of Transportation (MassDOT) approved 55-gallon steel, ring-topped
drums. Pending waste characterization, if required to supplement the soil and groundwater
profiling data, the drums will be transported by a licensed waste hauler to an approved facility
for disposal or recycling.
7.2 Groundwater Transportation Practices
Transporter Practices: F.W. Webb and GLC will contract a licensed vacuum truck operator to
transport and dispose of the groundwater pumped into the fractionation tank(s) in compliance
with applicable legal requirements and in accordance with applicable MassDOT regulations. The
permittee shall inform the vacuum truck operator of available BMPs for the pumping and
transportation of potentially impacted groundwater.
Queuing and Idling of Transport Vehicles: GLC or its designated representative will control all
traffic related to the operation of the facility in such a way as to mitigate the queuing of vehicles
off-site and/or the excessive or unsafe traffic impact in the area surrounding the Site.
8.0 HEALTH AND SAFETY PLAN
8.1 Hazard Evaluation and Contaminants of Concern
In accordance with MassDEP risk assessment guidance (July 1995), chemical contaminants
detected at a Site may be eliminated from the risk characterization as a contaminant of concern
(COC) based on any of the following criteria:
- The chemical is present at a low frequency of detection and at low concentrations.
- The chemical concentration is consistent with background levels and there is no
evidence that the chemical is associated with site activities.
- The chemical is a laboratory or field contaminant.
For the M3RC prepared for the Site by W&S, selenium was the only metal that was not detected
above RLs in any prior sample and was eliminated as a COC. No other metals, PCBs,
extractable petroleum hydrocarbons (EPH) or polycyclic aromatic hydrocarbons (PAHs) were
eliminated as COCs based on low detection frequency (typically considered less than 10%) or
based on comparison to MassDEP’s published background concentrations for metals and PAHs
in urban fill containing coal and wood ash (MassDEP, May 2002). MassDEP’s background
policy states that all detections must be below the background criteria to be screened out as a
COC unless there is site-specific information indicating otherwise.
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The highest concentrations at the Site were detected in the urban fill unit from approximately 0-4
feet bgs, but given the historic use of the Site as a scrap metal yard, it would be difficult to
identify the source of elevated contaminant concentrations. Therefore, all PAHs and metals were
retained as COCs. In summary, the COCs present at the Site consist of PCBs, VOCs, EPH
aliphatic and aromatic parameters, the 17 target PAHs, and 7 Resource Conservation and
Recovery Act (RCRA) metals (since selenium was eliminated).
The threat from these contaminants arises through chronic long-term exposure through dermal
contact, ingestion, or inhalation of contaminated dust. The proper precautions involve
intercepting these exposure routes prior to introduction to the receptor.
An updated M3RC (provided under separate cover) was prepared in support of the recent
Release Abatement Measure (RAM) Plan submittal for the proposed Site construction activities.
8.2 Site Control
The Site control program limits the movement of people and equipment in order to minimize
potential exposure to contamination. In order to control access to the Site during redevelopment,
only individuals involved in the Site activities shall be allowed onto the Site. In addition, to
control access to the Site from unauthorized individuals, the construction area will be fenced to
control pedestrian or vehicular entry, except at controlled points (i.e., gates). Gates will be
closed and locked during non-construction hours. "No Trespassing" signs will be posted at a
minimum of every 500 feet along the perimeter fencing.
People visiting the Site for the first time shall be informed of this HASP and S&GMP, and will
be held to the requirements described herein. To ensure their understanding, the Project
Superintendent (PS) and Site Health and Safety Associate (HASA) shall be responsible for
briefing individuals visiting the Site. Signatures of all visitors shall be required to document their
understanding of the HASP requirements. These records shall be maintained on-Site by the PS
and HASA.
8.3 Noise Control
GLC and its subcontractor will utilize BMPs to control and limit noise production during the
new building construction activities. In addition, GLC will provide hearing protection to
employees involved in the construction activities to minimize potential exposures to high noise
levels.
Project workers must be protected against the deleterious effects of noise exposure when sound
levels exceed the Occupational Safety and Health Administration (OSHA) permissible exposure
levels specified in Table G-16 of 1910.95. These exposures are presented in Table 1 below.
When workers are subjected to noise exceeding the levels shown in Table 1, feasible engineering
or administrative controls should be used. If such controls fail to reduce the noise to the
specified levels, hearing protectors must be provided. Employing administrative controls, (i.e.,
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rotating employees or limiting their duration of exposure) for compliance purposes in lieu of
engineering controls is acceptable; however, it constitutes poor industrial hygiene practice.
8.4 Personal Protective Equipment
Based on an evaluation of the anticipated hazards, at a minimum, Level D personal protection
equipment (PPE) will be required for any construction worker entering the Site. Level D PPE
(steel-toed boots, eye protection, protective gloves, dust masks, etc.) will be provided by the
contractor, and Level “D” will be acceptable for all tasks where workers will not be directly
engaged with contaminated or potentially contaminated soils.
In the event workers are to enter an OSHA compliant excavation as part of potential drainage or
utility work, these workers have a greater potential of contacting contaminated soil via
inhalation, skin absorption, ingestion and/or eye contact. Consequently, these workers will be
required to wear a particulate filtration respirator (Level C). Level C protection shall include a
particulate filtration respirator that is to be worn when working in and around soil along with the
Level D protection measures listed below.
All other workers at the Site not involved with the direct handling and contact of soil shall
implement basic Level D protection.
DURATION PER DAY
(HOURS)
SOUND LEVEL SLOW RESPONSE
(DBA*)
8 90
6 92
4 95
3 97
2 100
1.5 102
1 105
0.5 110
0.25 115**
* Decibels A-weighted.
** Maximum exposure of 115 dBA for 15 minutes or less.
1When the daily noise exposure is composed of two or more periods of noise exposure of
different levels, their combined effect should be considered, rather than the individual effect of
each. If the sum of the following fractions: C(1)/T(1) + C(2)/T(2) C(n)/T(n) exceeds unity, then,
the mixed exposure should be considered to exceed the limit value. Cn indicates the total time of
exposure at a specified noise level, and Tn indicates the total time of exposure permitted at that
level. Exposure to impulsive or impact noise should not exceed 140 dB peak sound pressure
level.
Impact (impulsive) noise limited to a maximum of 140 dBA (peak);
Various combinations of duration and intensity are permissible; and Exposure limits for various
durations, pursuant to Table G-16 of 29 CFR 1910.95.
Table 1 - Permissible Noise Exposures1
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297-305 Bridge Street, Salem, MA October 2015
The following PPE will be used at a minimum for Level D protection:
- Coveralls/uniform
- Safety boots
- Gloves
- Eye protection
Level C PPE includes the following:
- Coveralls/uniform
- Safety boots
- Gloves
- Eye protection
- Half Face Respirator
(recommended 3M Particulate Respirator 8233 with N100 Filter)
Any general construction work in the AUL areas containing PCB-impacted soils will require the
proper PPE. Since PCBs bio-accumulate, it is imperative that workers avoid all exposure to skin
and eyes and avoid any potential for accidental ingestion by wearing, at a minimum, the
following:
- Suitable chemical and/or oil resistant gloves (see the glove manufacturer’s
specifications for suitability)
- Goggles if there is potential for a chemical or oil splash hazard
- Protective clothing such as a Tyvek® coveralls/suit
Strict adherence to this plan will reduce to a minimal level, but not eliminate, the potential for
harm from impacted media at the Site. Therefore, AEG cannot and does not guarantee the health
and safety of on-Site personnel or individuals who may come into contact with Site soil or
groundwater. It is the responsibility of on-Site personnel to report all potential hazards to the PS,
whose job it is to implement and enforce this HASP.
Note that all workers managing soil from depths greater than 3 feet bgs must have 40-hours of
OSHA Hazardous Waste Operations and Emergency Response Standard (HAZWOPER)
training. The PS shall keep the Site HASA informed of any HASP-related issues and shall
assume all routine, on-Site health and safety responsibilities. If emergency conditions arise or
operational changes occur or are anticipated (e.g., work practices are altered, Site conditions
change), the PS shall immediately confer with the Site HASA.
9.0 DECONTAMINATION PLAN
9.1 Equipment Decontamination Procedure
According to the USEPA1, physical decontamination procedures can be used to remove gross
contamination from construction equipment and vehicles. These methods, which can be abrasive
as well as non-abrasive, include the use of brushes, air blasting, wet blasting, and high or low
pressure water cleaning. Typically, the first step is a soap and water wash that removes all visible
1 USEPA, Sampling Equipment Decontamination; SOP#: 2006, Date 08/11/94
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297-305 Bridge Street, Salem, MA October 2015
particulate matter and residual oils and grease, which may be preceded by a steam or high
pressure water wash. The second step involves a tap water rinse and a distilled or deionized
water rinse to remove the detergent. The third step is the performance of a high purity solvent
rinse for the removal of trace organics, which include PCBs. Solvents commonly used for the
removal of organic contaminants include acetone, hexane and water. The solvent must be
allowed to evaporate completely, and then a final distilled/ deionized water rinse is performed.
This rinse removes any residual traces of the solvent.
The decontamination process line is typically set up so that the first station is used to clean the
most contaminated item and progresses to the last station, where the least contaminated item is
cleaned. To reduce the spread of contaminants, each decontamination station should be
separated by a minimum of 3 feet. A site is typically divided up into the following boundaries:
- Hot Zone or Exclusion Zone (EZ);
- Contamination Reduction Zone (CRZ); and
- Support or Safe Zone (SZ).
The decontamination process should be set up in a Contamination Reduction Corridor (CRC)
within the CRZ. The CRC is used to control access into and out of the EZ and to confine the
decontamination activities. The far end of the CRC is called the hotline and is the boundary
between the EZ and the CRZ. The size of the decontamination corridor depends on the number
of stations in the process and the dimensions/space available for use. Another corridor may be
required for the entry and exit of heavy equipment. All personnel in the CRC shall wear the
appropriate level of PPE designated for the decontamination process. Sampling and monitoring
equipment and sampling supplies shall be maintained outside of the CRC.
The minimum required steps in the decontamination procedure (including setup) are outlined
below. It is noted that intermediate steps such as the physical removal of contaminated media
using a high-pressure washer, use of additional rinsing stations, etc., may be added to the
procedure as appropriate.
9.1.1 Decontamination Setup
Station 1: Segregate Equipment Drop
Place plastic sheeting on the ground. The dimensions will depend on the amount of equipment
to be decontaminated. Provide containers lined with plastic if the equipment is to be segregated,
which may be required if sensitive or mildly impacted equipment is used at the same time as
grossly contaminated equipment.
Station 2: Physical Removal with Brushes and a Wash Basin
Fill a large bucket, wash basin or children’s swimming pool with tap water and a non-phosphate
detergent. Select the brushes to be used for physical contaminant removal.
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Station 3: Water Basin Station
Fill a large bucket, wash basin or children’s swimming pool with tap water. Several brushes
should be selected and dedicated to this station.
Station 4: Low-Pressure Sprayers
Fill a low-pressure sprayer with distilled or deionized water. Provide a 5-gallon bucket or basin
for the collection of rinse water generated during rinsing.
Station 5: Organic Solvent Sprayers
Fill a spray bottle with organic solvent. The amount of solvent needed will depend on the
amount of equipment required to be decontaminated. After each solvent rinse, the equipment
should be rinsed with distilled or deionized water and dried. Provide a 5-gallon bucket or basin
for the collection of solvent generated during rinsing.
Station 6: Low-Pressure Sprayers
Fill a low-pressure sprayer with distilled or deionized water. Provide a 5-gallon bucket or basin
for the collection of rinse water generated during the rinsate process.
Station 7: Clean Equipment Drop
Place a clean piece of plastic sheeting over the bottom plastic layer, which will allow for easy
removal of the plastic if it should become dirty. Provide plastic, aluminum foil or other
protective material to wrap the cleaned equipment.
9.1.2 Decontamination Process
Station 1: Segregate Equipment Drop
Deposit the equipment used on-site such as tools, sampling devices, containers, monitoring
instruments, radios, clipboards, etc., on the plastic sheeting or in different containers with plastic
liners. Segregation at this stage reduces the possibility of cross contamination. Loose data
sheets and maps can be placed in plastic zip lock bags if contamination is suspected.
Station 2: Physical Removal with Brushes and a Wash Basin
Scrub the equipment with soap and water using bottle brushes and/or bristle brushes. Only
sensitive equipment that is waterproof should be cleaned in this manner. Equipment that is not
waterproof should have the plastic bags removed and be wiped down with a damp cloth. Note
that organic solvent rinses may also ruin sensitive equipment, and the manufacturers should be
contacted for recommended decontamination solutions.
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297-305 Bridge Street, Salem, MA October 2015
Station 3: Water Basin Station/Equipment Rinse
Wash the soap off of the equipment with water by immersing the equipment in the water while
brushing. Repeat this step as many times as is necessary.
Station 4: Low-Pressure Sprayers
Rinse the sampling equipment with distilled or deionized water using a low-pressure sprayer.
Station 5: Organic Solvent Sprayers
Rinse the sampling equipment with the selected organic solvent. Begin by spraying the inside
and outside of the equipment at one end, allowing the solvent to drip to the other end and into a
5-gallon bucket or basin. Allow the solvent to evaporate from the equipment before proceeding
to the next station.
Station 6: Low-Pressure Sprayers
Rinse the sampling equipment with distilled or deionized water using a low-pressure washer.
Station 7: Clean Equipment Drop
Lay the clean equipment on plastic sheeting. Once air-dried, wrap the sampling equipment with
plastic, aluminum foil or other protective material.
9.1.3 Post-Decontamination Procedures
The solid and liquid wastes should be collected and stored in appropriate MassDOT approved
55-gallon drums or other approved containers. The organic solvent, detergent and water liquid
wastes from the sprayers, 5-gallon buckets, children’s pools and/or collection basins should also
be stored in appropriate containers.
All solid waste materials generated from the decontamination area such as used gloves, plastic
sheeting, etc., should be placed in MassDOT approved 55-gallon drums.
Appropriate labels should be prepared for all waste containers to facilitate appropriate off-site
disposal.
Examples of a typical equipment wash station layout and equipment wash station cross section
are included as Figures 4 and 5, respectively.
9.2 Personnel Decontamination Procedure
Prior to conducting work in the potentially impacted areas, cabinets or lockers should be
assembled for the storage of clean clothing, decontaminated clothing, and PPE.
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297-305 Bridge Street, Salem, MA October 2015
Outer protective clothing exhibiting or suspected of gross impacts can be deposited on drop
cloths made of plastic or other suitable material. Lined boxes can also be used for wiping or
rinsing off gross solid or liquid contaminants. Long-handled, soft-bristled brushes can be
utilized to help remove contaminants during the washing and rinsing process. The wash and
rinse solutions should be selected based on the contaminants present at the site. For the subject
Site, organic solutions are preferred for the residual PCB impacts that may be encountered. A
children’s pool, galvanized tub or other large basin is recommended for the washing and rinsing
process, and should be large enough to place a booted foot inside.
Paper or cloth towels should be provided for drying of the protective clothing and other PPE
cleaned or decontaminated during the above process. All personnel should also wash their hands
thoroughly after removing gloves and other outer clothing materials.
Similar to the equipment decontamination waste discussed above in Section 9.1, MassDOT
approved 55-gallon drums should be used for the storage of used PPE and other wastes generated
during personnel decontamination activities. These drums should be appropriately labeled and
disposed of off-site in a manner similar to the equipment decontamination wastes.
9.3 Construction Vehicle Decontamination Procedure
Prior to leaving the Site, any vehicle used for the excavation or transport of impacted soil shall
be suitably cleaned of gross soil that could fall off onto public ways or create dust. Excavation
equipment buckets used to remove materials from below the existing geotextile layer (between
1.5 and 4 feet bgs) should be rinsed within the excavation to prevent mixture with overlying
soils.
A construction entrance in the form of large (4” plus) angular stone shall be constructed to
prevent vehicular dispersal of soils beyond the limits of work. Heavy soils must be brushed from
vehicle tires prior to leaving the Site. In the event soils are tracked onto nearby roadways, the
roadways will be swept clean and the materials deposited back on the Site.
10.0 COMMUNICATION AND EMERGENCY PROCEDURES
The following items should be located and discussed with all field personnel prior to the
initiation of work at the Site.
1) Personal Protective Equipment
2) Project HASA Contact
3) Location of Nearest Hospital
In the event of an emergency, development of hazardous Site conditions, or significant changes
in the work plan, communication will be established as soon as is practicable.
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297-305 Bridge Street, Salem, MA October 2015
Direction to North Shore Medical Center:
1. Start out going southwest on Bridge Street/MA-107 toward Lynn Street (0.5 mi).
2. Turn left onto Boston Street/MA-107. Boston St is just past Goodhue Street (0.2 mi)
3. Turn right onto Essex St/MA-107. Continue to follow MA-107 (0.5 mi)
4. 81 Highland Avenue is on the left.
Environmental Firm Site HASA Telephone
Alliance Environmental Group, Inc.
Felix A. Perriello, CHMM, CPG, LSP, LEP
Office: 401-732-7600 Ext 306
Cell: 617-699-8678
Agency Telephone
Police Dept. (Salem, MA) 911 or (978)-744-0171
Fire Dept. (Salem, MA) 911 or (978)-744-1235
Public Health Officer (Salem, MA) (978)-741-1800
DigSafe 1-888-DIG-SAFE
(1-888-344-7233)
City Hall (Salem, MA) (978) 745-9595
Massachusetts State Police (978) 538-6161
State Poison Control Center (800) 222-1222
MassDEP Hotline (888)-304-1133
North Shore Medical Center
81 Highland Avenue
Salem, MA
(978) 741-1215
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Safety Precautions/Work Practices
Safety precautions and good work practices shall be implemented at all times to maintain strong
safety awareness. A list of standing orders will be developed to ensure that all persons are
cognizant of potential hazards during the Site work activities. These standing orders will be
reviewed by the PS. Any changes in the orders will be announced officially during the
scheduled safety meetings.
The following orders apply:
• Prescribed personal protective equipment shall be worn as directed by the PS and the Site
HASA.
• Assumptions will not be made concerning the nature of suspect materials found on the
Site. Should any unusual situations occur or materials be encountered, operations will
cease and the PS or Site HASA shall be contacted for further direction.
• Consultation with the PS in a requirement to verify any uncertainties.
• The PS and Site HASA shall be informed when:
- Unusual or suspect odors are detected;
- Visual evidence of suspect soil is noted; or
- Symptoms of chemical exposure or suspicious health conditions become
apparent.
• Any unsafe conditions shall be reported immediately.
• Workers shall minimize contact with hazardous materials by:
- Avoiding areas of obvious or likely contamination;
- Using polyethylene sheeting to help contain contaminants, when identified or
suspected; and
- Avoiding direct contact with potentially contaminated materials.
• Only essential personnel shall be permitted in the work zones.
• Whenever possible, personnel will be located upwind during material handling.
Ancillary Health and Safety Items Considerations
This HASP is intended to cover workers who are exposed to greater hazards than the general
employee/visitor population. Consequently, a clerk in an office on the periphery of the Site who
does not enter the operations part of the Site and is exposed only to background levels of
hazardous substances is not covered under this HASP. Employees who regularly enter the
operations areas of the Site and who are exposed to levels significantly above background are
covered by this HASP.
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This HASP concentrates on those substances that will create the greatest risk to Site employees
and visitors. Risk assessment considers the following: substance toxicity, potential for exposure,
proximity to toxic substance, and availability of controls. For example, a level of exposure to a
general population that is not likely to exceed background levels would not normally require
notification. Similarly, a level of exposure above background but below established permissible
exposure limits would also not require specific notification.
As a precaution, however, if levels are unknown, employees, contractors and subcontractors will
be informed of the potential for exposure.
Safety Meeting
Weekly safety meetings will be held to discuss the following:
- Contents of the Site HASP;
- Hazards of chemicals potentially present; and
- Safety precautions/work practices.
An attendance sheet shall be completed at the Safety Meeting and a log will be kept of the Safety
Meeting discussion topics, questions, and resolutions. These sheets will be maintained in the
project file.
Soil & GW Management Plan and HASP
297-305 Bridge Street, Salem, MA October 2015
FIGURES
Date: 7/27/2015 Drawn by: DTC Checked by: FAP
FIGURE 2 - SITE LOCUS MAP
297-305 BRIDGE STREET
SALEM, MA
DERIVED FROM:
WESTON & SAMPSON MASSDEP SARSS PROJECT
NOTES:
Approximate
Site Location:
ABCDEF12345678SDDDDDDDDDDDDDD DDDDDDDDDDDDD020401020100 JEFFERSON BLVD., SUITE 220WARWICK, RI 02888PHONE: 401-732-7600FAX: 401-732-7670WWW.ALLIANCEEGI.COMFIGURE 2SITE/CONSTRUCTION OVERLAY PLAN297-305 BRIDGE STREETSALEM, MA 019702261-0210/6/20151"=40'1 of 10-9.9 ppm10-49.9 ppm50+ ppmRemaining PCBConcentrations:Property Line:30' DeepGeotechnicalBoringWater UtilitySewer UtilityWSDrainage LineDGas UtilityElectric UtilityOverheadWiringStoneFoundationColumn
Soil & GW Management Plan and HASP
297-305 Bridge Street, Salem, MA October 2015
ATTACHMENT – A
Plan Approval Agreement
The following individuals have reviewed the Site-specific Health and Safety Plan (HASP) for the
297-305 Bridge Street, Salem, Massachusetts project. They are responsible for implementing
and enforcing the procedures and items covered by this HASP. In addition, the Alliance
Environmental Group, Inc. (AEG) Manager of Occupational Health and Safety, Mr. Felix A.
Perriello, CHMM, CPG, LSP, LEP must approve any revisions or alterations to this plan prior to
implementation.
Notify Felix A. Perriello or Richard Hittinger of AEG of any alterations or deviations from the
procedures, requirements, etc., listed in this HASP. Once signed below, return a signed copy of
this document to AEG.
__________________________________________ ________________________
Project Superintendent Date
__________________________________________ ________________________
Felix A. Perriello, CHMM, CPG, LSP, LEP, Date
Alliance Environmental Group, Inc.
HASA
Soil & GW Management Plan and HASP
297-305 Bridge Street, Salem, MA October 2015
ATTACHMENT – B
Compliance Agreements
All appropriate on-Site personnel (i.e., Contractor employees and subcontractors) must complete
and sign this section to be allowed access to the 297-305 Bridge Street, Salem, Massachusetts
Site. This copy of the Health and Safety Plan (HASP) will be maintained by AEG.
I have read and understood the contents of this Site-Specific HASP, and have had all relevant
questions answered to my satisfaction. In addition, I agree to comply with the conditions/
provisions outlined therein.
NAME (print) SIGNATURE COMPANY DATE