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45-49 Congress Street Modified IRA Plan 10-29-21 PARTNER Engineering and Science, Inc: October 29, 2021 RECEIVED David Greenbaum, Health Agent Board of Health NOV 01 2021 Salem City Hall 98 Washington Street CITY OFBOAR OF HEALTH LEM Salem, MA 01970 Subject: Modified Immediate Response Action (IRA) Plan Shetland Park— Building 4 45-49 Congress Street Salem, Massachusetts 01970 RTN: 3-35818 Partner Project Number 19298406 Dear Mr.Greenbaum: Partner Engineering and Science, Inc. (Partner) on behalf of Prime Storage Shetland, LLC (our client), and pursuant to the Massachusetts Contingency Plan (MCP), 310 CMR 40.1403(3)(b), is notifying you of the submittal of a Modified Immediate Response Action (IRA) Plan for Shetland Park located at 45-49 Congress Street, Salem, Massachusetts (subject property) to the Massachusetts Department of Environmental Protection (MassDEP). A copy of the Release Notification Form that has been submitted for this condition has been enclosed. Partner has been conducting assessment activities for a 120-day release condition related to the detection of trichloroethene (TCE) and pyrene in groundwater above the Massachusetts Contingency Plan (MCP) RCGW-2 reportable concentrations. The release is tracked under release tracking number (RTN) 3-35818. Part of the assessment activities included an investigation of a potential vapor intrusion condition. On January 30,2020 Partner conducted an indoor air quality sampling investigation for potential TCE impact to indoor air in the basement level of Building 4, Prime Storage Shetland Park. Laboratory results detected TCE at a maximum concentration of 27.7 micrograms per cubic meter(pg/m3)which represents an Imminent Hazard (IH) condition for sensitive receptors. Partner verbally notified the MassDEP on February 6, 2020 of the IH condition. MassDEP subsequently assigned RTN 3-36124 to the detected IH condition. On April 6, 2020, Partner submitted an IRA Plan to the MassDEP. The proposed objectives of the IRA Plan were to continue the operation of APUs, limit access to the area of investigation for sensitive sub groups, seal preferential pathways,conduct a SSDS pilot test to aid in the design of the system to mitigate the vapor intrusion pathway, and to conduct additional exterior assessment activities to determine the extent of groundwater impact, specifically towards the residential area west of Building 4. 800-419-4923 www.PARTNEResi.com PART, NER Enginee r ag.and Science, Inc: IRA Status Report #1 was submitted on June 5, 2020 which documented that APUs were installed in the area of investigation in basement area of Building 4, sealing of preferential pathways had been performed, and continued access requests were made but without approval to date. IRA Status Report #2 was submitted on December 7, 2020 which documented the installation of two additional APU units in occupied tenant spaces in the basement of Building 4, the completion of an SSDS pilot, the completion of a passive soil gas survey, an additional round of indoor air quality sampling, a building survey, and on going residential sampling efforts. On February 3, 2021, Partner linked RTN 3-36124 (daughter RTN) to RTN 3-35818 (parent RTN). RTN 3- 36124 is now closed and this and future submittals will be made under the parent RTN 3-35818. IRA Status Report#3 was submitted on June 3, 2021, which documented on going IRA activities including an additional Building 4 IAQ, residential IAQ sampling, an APU performance evaluation, monitoring well gauging to determine groundwater flow direction, and a Building 4 survey for the evaluation of a vapor mitigation strategy. This Modified IRA Plan has been prepared for the sealing of preferential pathways using concrete, the installation of a vapor barrier in a dirt floor hallway,and the installation of sub slab depressurization systems. IRA activities are expected to be conducted in November through January 2022. Pursuant to Section 40.1403(9) of the MCP, local officials of a community in which a disposal site is located or in any other communities which are, or are likely to be, affected by a disposal site may request an opportunity for Public Involvement Activities related to any Immediate Response Actions conducted pursuant to 310 CMR 40.0410 or Release Abatement Measures conducted pursuant to 310 CMR 40.0440 and upon Tier Classification pursuant to 310 CMR 40.1404. Such requests shall be made in writing to the person(s) conducting the response actions and copied concurrently to MassDEP. If you have any questions concerning this letter, please contact the undersigned at (508) 876-2660. Sincerely, Partner Engineering and Science, Inc. Tom A. Campbell, LSP� Jerry Ostrander Project Manager Regional Director—Site Mitigation cc: Robert J. Moser, CEO (Prime Storage Shetland, LLC) MassDEP Northeast Region Salem City Hall, Mayor's Office ..a M - .,- .. . 800-419-4923 www.PARTNEResi.com