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70-92 Boston Street - Site Investigation Summary Report Appendix A APPENDIX A EPA FILE REVIEW REPORTS L2005-115 - F t. ejp ENVIRONMENTAL SITE .INVESTIGATION FOR COMPLIANCE WITH MASSACHUSETTS GENERAL LAW- CHAPTER 21E AT 80 BOSTON STREET -SALEM, MASSACHUSETTS 1 SUBMITTED TO: JOHN FLYNN & SONS 80 BOSTON STREET SALEM,; MASSACHUSETTS SUBMITTED BY: SP ENGINEERING, INC. 27 CONGRESS STREET SALEM, MASSACHUSETTS "_U`„� NOVE.M.BER 1988 :y � KEErE v MECHANICAL No. 31446 S10 AL�� i Prepared by: Reviewed by: Leo T. Keefe , P.E . William H.. Mitche professional Engineer Field Engineer/Geo ogist i is -T A B . L _E O F C O -N T E N T S Page l ; . Introduction t Figure : i Locus Plan 3 2. Site Plan 2A . Site Plan 2B. Site Plan ii. Assessment Rationale 5 III . Methods. IV. Surface and Subsurface Geology 5 8 V, Tank Inforimation 9 V;. Site Use and gis.tory 11 'VII. Areas of Concern VIII. Soil and Water Analysis Summary 14 16 IX. DEQE Spill File Review 17- X. Conclusions 22 Barrel Inventory for Disposal Figure: 3. Soil Logs 4. Soil Logs 5. Soil Logs Tables: 1. Metals Analysis 2. EP Tox Soil Analysis 3 . Volatile Organics -Analysis 4. Golatile Organics Analysis I. - Introduction The property being investigated is located at 80 Boston Street, Salem, Massachusetts . The front .side of the property abuts Boston Street and the back side abuts Goodhue Street. The property covers 1. 67 acres , which includes a brick ,' one to three-story structure occupying approximately 60 percent. of the site , with the remaining 40 percent being either asphalt or concrete. The site douses two major parking lots , one to the northwest and the remaining one being to the opposite southeast corner . The property is totally enclosed with a chain-link fe:�ce. On November. 7 , 1988 , a site investigation of . the subsurface was conducted by SP Engineering , Inc .. under. the supervision of William H. Mitchell Jr. , Field Engineer/Geologist. In-house barrel inventory, review of process activities and present waste handling was supervised by Bruce M. Poole , President of SP Engineering , Inc. II. Assessment Rationale The building and surrounding property has been subjected to I a comprehensive investigation to determine whether hazardous waste . materials and/or oils have been released or are contained or located; on the site or in the soil. or groundwater . This report summarizes the conditions encountered on the buildings , grounds and subsurface soils., and groundwater. The certification of materials and soils sampled involves the Resources Conservation and Recovery Act (RCRA) regulations for � � o Z 2 (7. Q ' O y V W ff a ct • 0 O D a 0 cl a O A Q Oo `3 CL aoo 0 o Cl) O Cn u� n o z rz Q m m � oa` 0 m a Z n m C o rrlx� m cn - ' v s o o A G) o 0 n Or c 40 - `s G A� o 0 i • W U a a 4 OVJ m CL o O a m Z to O �rnfri r77 CD i - i 1 analysis of reactivity, corrosivity , ignitability and extraction procedure toxicity. The hazardous material investigations required tests for eight heavy metals in the soil and volatile organics (VOA) , pH and conductivity in groundwater. Since many sites have been developed only to discover that wastes stored below the ground continue to leach heavy metals or carcinogenic solvent fumes that affect human health, the importance of complete site studies is a financial necessity. Many construction techniques and treatment programs can eliminate the risk in industrial site development, but the probleras have to be discovered by chemical analysis. . l Documentation of -the size, character and constituents of any previous landfill activity is essential to the determination of future impacts. The combination of test cores , soil characterization, soil EP toxicity tests, and surface and. groundwater. chemical analysis (if groundwater i-s encountered) reveals the extent of site contamination, if any. The enclosed discussion and engineering report presents the results of previous industrial activity on the site and how it relates to future development potential. All applicable sites must be certified free of hazardous wastes and contaminated groundwater in order to obtain title insurance for the sale , remortgages or building addition to the property. This site survey is conducted by an engineer who has had extensive experience handling the hazardous materials from tanneries, electroplaters , and other industries as well as the design of wastewater treatment systems, -sludge disposal 2 j . facilities and landfills . This experience includes a variety of remedial site clean-up actions. All soils and groundwater are sampled according to EPA protocol 'and analyzed at SP, Inc. ' s in-house chemistry laboratory in Salem, Massachusetts. All sites are subjected to corings and grounds survey to determine natural conditions 'and any areas of man-made fill or disposal. i A material is considered hazardous if it shows : 1._ Ignitability - .Having a flashpoint of less than 140oF; a nonliquid liable to cause fires through -friction, absorption of moisture , spontaneous chemical change or retained heat from manufacturing or. liable when ignited to burn so vigorously and persistently as to create a hazard; ignitable compressed gases; j oxidizers. 2. Co.rrosivity - Aqueous wastes exhibiting a pH of less than. or equal to 2 or greater than or equal. to 12. 5 and liquid wastes. capable of corroding steel at a rate of greater than 0. 25 inches per year. 3. Reactivity - Readily undergo violent chemical change ; react violently or form potentially explosive mixtures with 3 water ;. generate toxic fumes when mixed with water (or when exposed to mild acidic or basic conditions for sulfide or cyanide bearing wastes) , explode when subjected to a strong i a initiating force ; explode at normal temperatures and pressures; or classified as Class A or B explos-ives . 4. Fail the EP Toxicity Tests - The Extraction Procedure .(EP) Toxicity Test is designed to simulate the physical 3 processes which would occur in a landfill. To simulate the acidic leaching medium which occur in. actively decomposing landfills, EPA chose to employ acetic acid: To simulate the leaching process , EPA specified a procedure requiring the mixing of the solid component of the wastes (soil in . this instance) with -the acidic leaching medium for a period of 24 hours. To duplicate. the attenuation in concentration expectedto occur between the point of leachate generation and the point of human or environmental exposure , EPA applied a dilution factor. o-f 100 to the concentration of toxic constituents observed in the test extract. S. Identified as a Priority Pollutant = The RCRA: legislation has classified a minimum of 125 organic and metallic compounds as acutely hazardous to human health. As such, only extremely low levels are tolerated in the environment and non-existence required for .drink.ing water. sources.. These compounds are detected by gas chromatograph and regulated according to their level, mode of toxicity (i .e . . oral, -dermal, inhalation) and health effect (carcinogen, irritant,- or mutagen, ) . In all cases , there are chronic . (long-term) concerns as well as acute {single-exposure] toxicities that have to be evaluated. III . Methods A. six-inch diameter auger coring device was used to penetrate asphalt or soil to refusal or .several feet below the groundwater table. An engineer on site during excavation 4 characterized soil strata type, depth, unnatural material quantities and groundwater levels. This data is _presented in the Soil Logs (Figures 3, 4, 5 & 6) . Any organic material, colored soil or landfill refuse is- sampled as a worst case 'and subjected to the EP Toxicity Test. All - analyses are performed according to Standard Methods 15th- edition 1980, RCRA !. Regulations E.P. Toxicity Extraction Procedures 1978, or the EPA Method 602 for gas chromatographic analysis of petroleum hydrocarbons. ,Quality assurance and sample identification protocol:s .are in accordance . with federal requirements of the National Pollution Discharge Elimination System (NPDES) , a-,d Clean Water Act of 1976. IV. Surface and Subsurface Geology The site is located within the Salem Quadrangle of the USGS- Topographic Map _Series.- The, topography of the site is mostly sloping .to the southeast according to the Quadrangle Map with an average elevation of 35 feet above. sea level. Run-off floras in two major directions . The front side of the property abutting Boston Street, run-off is. to the southeast down Boston Street . On the back side of the property, run-oft is to the northeast' were the North" River presently exists. The area .being investigated is approximately 1.67 acres. . One large 1 conglomerate three-story brick building occupies approximately 60 percent of the site with the remaining 40 percent covered by concrete and asphalt. The asphalt/concrete areas are subdivided j into three sections ; two of the. areas are on the northwest and 5 southeast ends of the property abutting Boston Street with the remaining concrete area abutting Goodhue Street to the northeast. Surrounding the property is commercial/industrial to the northeast and southeast, residential to the northwest and southwest. The subsurface soils are believed to be all fill ranging from sand and gravel to rock. The soil is part of the Urban Land-Udorthenis Association where .soils have been altered or obscured by Urban works and structures or- where- soil material has been excavated and redeposited. An unknown quantity of brick and concrete footing slabs are present in the subsurface due to the remains of an old structure which burned many years ago. Subsurface soils were encountered in all as.pha.lt/concrete areas. Priority areas for drilling were near underground petroleum tanks. On the northwest end of the property, within the parking area and abutting Boston Street, contamination of #6 oil was encountered in Test Hole #1 and. 46. Test Hole 11 was highly contaminated with #6 oil, free flowing at approximately 13. 5 feet. SP, Inc. drilled to a depth of 20 feet before abandoning Test Hole #1. It is likely that contamination continues to a depth greater than 20 feet in Test Hole #1. Test Hole 46 was ` explored to determine if any #6 oil had migrated downgradient from a 20, 000-gallon underground #6 oil tank. Contamination was encountered at 11 feet in Test Hole #6. Drilling was - stopped - due to the lack of day-light. The extent of contamination is assumed to be widespread because of the porous nature of the fill material. Also abutting-Boston Street and to the southeast' behind Dunkin Donuts, SP, Inc. drilled Test Holes #3 and' #4 within the asphalt areas. Both Test Holes had well sorted brown medium sand fill. Subsurface soils in this area appeared -free of any contamination during testing. However, Test Hole #2, drilled -to the east next to Goo&hue 3 - Street, was contaminated with solvents from the 6,000-gallon j underground solvent tank upgradient from the Test Hole. Further upgradient from. Test Hole t2, SP, Inc. drilled two additional I Test Holes, #7 and #8, on November 30, 1988: This area was investigated further due to the solvent detected downgradient from Test Hole #2. Test Hole #7 and.. #8 did posses detectable volatiles possibly from. the solvent tank. The HNU read-ings in the back lot . ranged from 20 to 120 ppm. Due to the multi-contaminated areas on site, the augering. equipment .was. steam cleaned after each encounter with contamination. Groundwater was encountered in Test Hole #2, which was the closest boring to the North' River at approximately 8 feet. Groundwater did possess quantities of v.olatiles believed to be solvent from the suspected leaky underground tanks. The type of i solvent used as a degreaser in sheepskin leather manufacturing , is called Stoddard' s solvent. It is a complex mixture of straight and branched chain paraffins , naphthenes and aromatic i hydrocarbons. A petroleum distillate , it is also called mineral - spirits and has a kerosene odor . It is insoluble in water (specific gravity 0. 79) -and boils between 1540C and 2020c (not very volatile) (see attached fact. sheet in the Appendix) . 7 i r ..V-. -Tank- -Information Information. concerning any petroleum storage containers on-s_ite was. acquired from multiple interviews with employees- and a visit 'to the Salem Fire Department. According to John Keenan, Manager and 31-year employee of John Flynn & Sons, the following tanks exist on-site. 1. (1) 20,000-gallon #6 fuel oil underground tank located in .the northwest parking lot abutting Boston Street. 2. (2) 275-gallon #2 fuel oil aboveground tanks located within the shiping room on the northwest corner of the building. 3 . (3) 275-gallon #2 fuel oil aboveground tanks located within the maintenance shop abutting Goodhue .Street to the .eas_t. 4. (1) 6,000-gallon solvent underground tank located between the maintenance shop and the boiler room within the driveway area. 5. (1) 10,000-gallon abandoned #6 fuel oil underground tank located in. the boiler room abutting Goodhue Street. 6.. Other tanks on site, non-petroleum, involved in effluent treatment, are mixing tanks', clarifier, sludge storage, solvent recovery, caustic soda, alum and polymer. These tanks are above ground fiberglass or steel vessels that will be sold. off as part of a treatment system. 7 . Various steel and fiberglass above ground tanks exist throughout the factory for the storage of process chemicals . These include vessels for salt brine, formic acid, trivalent chromium (15% solution) and fat liquors . While these are not hazardous wastes, the chemicals would still have to be returned to .the seller and the tanks cleaned before. being sold. 8. Wastewater' ''from the tan and color processes are collected in four below floor concrete pits . These pits and associated trenches generally contain accumulations of sludge t that have low levels of chromium, phenolics and solvents. While these are not Hazardous wastes , they still require cleaning, dewateri.ng and disposal in a "special" landfill. VI. Site Use & -History The site, for the past -68 years , has- been utilized, according to an interview with 31 year employee John .Keenan and a Deed Search at the Salem Registry of Deeds, for the manufacture of lea_t.her from pickled sheepskin stock . John Flynn and Sons, at one time , was a world leader in processing, sheepskins into finished. garment leather . The manufacturing activities -require many chemical baths to prepare the skins and color the leather. This facility did not remove the hair 'from the skins , but utilized dehaired acid-pickled raw stock from New Zealand. According to the Deed Search, the buildings and land were purchased from 19.26 to 1950. The following section shows the number of purchases made to acquire the. existing property. November 2, .1928 , Mr . Flynn purchased the three-story structure from Bernard J. Mulligan ', where the business originally began. In addition to this , Mr . Flynn purchased the additional buildings and land from Joseph Polansky in 1935, Charles Kokoras in March of 193.6, Lena -Mahoney in September 1936, William C. Norton in July 1947, Joseph Polansky in May 1948 and finally Charles Kokoras .in August 1950. During this time period and up to the present, John Flynn & Sons * has generated several distinct wastewater operations associated with leather proc-essing. - Included in these processes were solvent degrease, tan, blue soak; retanning, fat liquoring, coloring and finishing . Chemical analyses have been conducted regularly to characterize daily wastewater, sludge and process wastes . Treatment system operation has allowed compliance with Local and Federal effluent discharge limits since 1980. The wastewater is prescreened, chemically coagulated and settled in a primary clarifier. End pro ducts. from processing such as grease andchrome trimmings are either recycled or sold. to other industries . The final effluent is discharged to the SESD Municipal Sewer System for further wastewater treatment befo.re discharge into Salem Harbor. Primary sludge is: dewat.ered by a filter press and d-isposed. of in a special landfill. Also stored in the building are a large number of 55-gallon drums and paper barrels (10 to 20) that contain outdated chemicals ; finish mixes , fly ash, still bottoms and unknowns . Some of these materials are being returned to the sellers and others are not. hazardous. A full barrel inventory-'is being prepared to identify the waste streams, label the barrels and schedule disposal by a licensed hazardous waste firm. The facility .is presently being considered for resale. The facility is presently under-going a clean-up operation . Clean-up includes selling all pretreatment. materials and machinery. While on-site, SP, Inc. observed clean-up operations. The tannery still needs more maintenance, including 10 i . floor cle-aning of chemical spills and sludge clean-up in trenches and pits throughout the basement of the building . SP, Inc. would request a site revisit when Flynn & Sons have finished the .clean-up of- the facility to determine if .any i j hazardous waste remains on-site. i VII. Areas of Concern There are multiple areas of hazardous waste contamination i which were visually observed in the subsurface soils during SP, Znc. ' s site investigation. 1 . Test 'Moles #1 and #o, within the parking area, located I ' on the northwest end. of the site , was highly contaminated with #6 fuel oil..- Apparently .the 20, 000-gallon -#6 fuel oil tank is leaking. The steel t-ank is 38 years old according to the Salem Fire Department. SP, Inc. drilled to a depth of 20 feet and discovered #6 fuel oil at approximately 13 to 20 feet. The oil flowe-d freely into the boring up to 15. feet. HNU readings ranged from 16 to 70. ppm' s . Test Hole #6 was explored downgradient from the 20, 000-gallon #6 fuel oil tank to- i det.ermine potential migration of the fuel oil. Soi1 - i contaminated with fuel oil- was discovered at ll feet. The source of contamination within Test Hole #6 is -believed to be from migrated #6 fuel oil that originated in the upgradient 20, 000-gallon in-ground tank. The porous nature of the sand and gravel found in this area would indicate that the extent of contamination is widespread. The fill material from grade to 11 feet down, did not appear contaminated. The steep grade on the 11 north side of this parking lot did not show any evidence of seepage or oil migration. 2. Abutting Goodhue Street and between the maintenance shop and the boiler room, Test Hole #2 produced high volatile organics. Discovered at approximately 7. feet was possible solvent contamination from the upgradient 6,000-gallon in-ground solvent tank. HNU readings with headspace analysis techniques measured 180 ppm's. The Stoddard' s solvent (mineral spirits) be-lieved .to be present in the soil is insoluble in water and does not evaporate readily. As mentioned previously, almost the entire site is paved or covered with concrete . A tidal canal, the North River , exists downgradient approximately 200 yards from the site. There is a potential risk that the solvent material -may migrate to the river . The river is, however , a Class D waterbody with no recreational or shellf.ishing activities. There are no wells downgradient of the property and no mechanism by which the solvent could become surface run-off. 3. Beneath the boiler room there is a 11, 000-gallon abandoned 16 fuel oil in-ground tank. This tank, was- believed to be leaking when it 's use was discontinued in_ 197.3. The tank was installed in 1939 . SP, Inc. was .unable to test the soils around the tank because they are under a building. Even the adjacent loading dock is covered by a thick concrete pad. The oil, if present , is well contained and does not pose any immediate risk to human health. If the .buildings were demolished and new foundations were excavated, then the oil and soil would have to be removed and properly contained in a secure landfill. 4... The .presence of waste Barre-ls (10 to 20) in the building necessitates- further- inventory , identification and labeling. . John F1ynn :.and. Sons has -followed the RCRA regulations in the i regular disposal and manifesting of routinely produced hazardous wast-e streams that consist of still - bottoms , boiler ash , finish mixes and spent-- laquers . Many of the barrels remaining are not listed hazardous wastes (RCRA 45 CFR Section 261, 31) , but process chemicals that may or may not be usable. Because of certain constituents, they will have to be incinerated or disposed of in a- secure landfill. Overall, these concerns have not _zterferre-d wi_h the present industrial use of the property. Occupational exposure to the subsurface soils. is negligible ; therefore , there has not been, nor is there an imminent threat of any deleterious impact on human health and safety. The industrial mature of the entire area and present condition of the North River also indicates that there is minimal potential for environmental harm. Effective containment of these contaminated soils could allow continued industrial use of the property. Any construction or excavation .would require soil removal. VIII. Soil and Water Analysis Summary Soil sampling was conducted with a hollow stem- continuous flight auger -with a split-spoon sampling device -for each Test Hole. Samples were -taken every foot as material was brought to the surface with the auger flights. Each sample was analyzed for strata and lithology changes. While on site, samples were 13 I then---composited into, one: approved_ DEQE:.c.ontainer .. .per Test dole. for further chemi-cal analyses. :: During drilling, the . soi.I samples did possess obvious volla.tile qualities, excluding Test .Holes 1.4 and #5 which had no- hydrocarbon volati.les . The drilling continued until refusal (ledge or boulders) was reached or 5 feet below .groundwater. A multi-triangular boring configuration and the previously obtained subsurface. information aided in the determination of test holes relative to the site. Each test. hole composite .was subjected to Extraction Procedure Toxicity testing .-(EP Tox) . Three- EP Tox samples were tested.. Soil samples from Test Hole #l .were tested as one unit. Soil samples from Test Hole #2 and.- 13 were composited together as the -second unit, and soil samples from Test Hole #5 and t6 as the. third EP Tox unit. All EP Tox results were free of any hazardous heavy metals. The amount of oil in the soil in the upper parking lot ranged from 8. 0% worst case Hole #1, 6. 3% composite Hole #1 and 1. 33% worst case Hole #6. Hole #6 is 25 feet downgradient of. the oil tank and is -believed to represent (within 10 feet) the extent of oil migration. This is important because with industrial sites u�1. 0$ oil is not considered hazardous .and can remain- on-site. Soil contaminated with #6 fuel- oil from Test Hole #1 was tested for Organochlorine Pesticides and PCB' s. All results from these tests were non-detectable. A VOA (volatile organic analysis) was also conducted on the oil within Test Hole #1. Detectable compounds were benzene at 12500 mg/1 and ethylbenzene 14 I i I at -930----mg/i. Additional VOA were concentrated on Test Hole #2. Soil sample's had. 254 ug/kg benzene, 119 ucg/kg ethylbenzene, 57 ug/kg toluene and 85 ug/kg xylenes. Groundwater was encountered in only Test Hole .#2 (back solvent tank area) . A VOA 'indicated 1870 ug/l benzene , 94 u-g/kg ethylbenzene, 15 ug/kg toluene :and 42 ug/1 xylenes. Oil and grease levels were 0. 12% , and not a problem. in this area. Two of the above contaminants have been recorded with fhe Federal Register of Concerned Pollutants, Volume 45, -No. 23. The following . is stated within this volume. A. Benzene, Saltwater Aquatic Life': The available data for Benzene indicates that acute toxicity to saltwater aquatic life occurs at -concentrations as low as 5,100' ug/l and would occur at lower concentrations among a species that are more sensitive than those . tested. B . Toluene, Saltwater Aquatic Life: The available data for Toluene indicates that acute and chronic toxicity to saltwater aquatic life occurs at concentrations as low as 6, 300 and 5, 000 ug/l, respectively, and would occur at lower concentrations among species that are more sensitive than those tested. IX. DEQE Spill File Review 1. According to the DEQE Incident Files , at 2 Goodhue Street , on the corner of Goodhue and Bridge, a release was I 15 reported in April 1987, Case #370427. The lot is utilized as'.,a parking lot and owned by James Weener 'of JHW Corporation. The source of contamination is believed to be from P. Claiman, who has a 55 year old 10,000-gallon concrete underground tank. According to Jim Weener, the tank was pumped and cleaned this summer. A site assessment was conducted by Target Environmental Service in April 1987 showing high fuel oil, diesel or kerosene in concentrations up to 21 ppm. The case is presently pending. 2. Located. at 12 Hanson Street ; and not recorded in DEQE Incident Files, just northwest from John Flynn & Sons , SP, Inc. conducted a site investigation for Beverly Leather Corporation in March 1987. The site investigation discovered high lead at greater than 5 mg/l, oil and grease at 17. 5 percent and total volatile organics of 39.20 ug/1 within Test Hole #2. The source of contamination is believed to be the finishing air exhaust of the past operation. Remedial action was conducted on April 22, 1988 by SP, Inc. SP, Inc. supervised the removal of 120 . 16 tons of contaminated soil. The soil was transported by Total Waste Management Corporation, Newington, New Hampshire (US EPA ID #NHD980521843) to Sawyer Environmental Recovery of Hampden, Maine . X. Conclusions It is evident that the property has been exposed to discharges of hazardous materials. This being the case , we cannot certify the property free of hazardous materials . The magnitude. of release also means that DEQE will have to be 16 i not-ified accord-i-ng- to -MGL Chapter 21E Two major areas on the i site should be. subjected .to remedial action, with an additional f area of probable #6 fuel oil contamination dealt with if the building is demolished (see Site Plan) . Within the building , more areas of concern exist such as; sludge filled trenches, . chemical spills on floors and the remaining barrel inventory . It may be .concluded that the hazardous constituents present in the soils and groundwater (Test Hole #2) do not, at the: pres ent , pose a threat to human health- or the environment: This is due to the fact that no drinking water wells or natural "resources exist in the area. However, subsurface environmental problems obviously exist. Groundwater was found in only one Test Hole (#2) -. This hole is believed to contain solvents from the upgradient in-ground tank. These solvents could be migrating to the North River. The two #6 fuel oil releases should be contained (non-migrating) due to the high viscosity. of the petroleum product. The sources of #6 fuel oil contamination are suspected to be from the in-ground tanks. { The in-ground 201000-gallon tank, #6 fuel oil, on the i northwest corner of the site, was installed and inspected on July 8 , 1950. The abandoned 10, 000-gallon. tank , #6 fuel. oil , beneath the boiler room, was installed and inspected on December I 1 , 1939. The 20, 000-gallon tank is still in use to heat the major portion of the building. Although the contaminate levels are in excess of the .limits set by DEQE, it is still unclear on how to treat this site's 17 i _ specific problem. According to .DEQE, .any soil contaminated with ' virgin petroleum products reading greater than 10 ppm's of volatiles with the HNU meter, should be removed. It must be emphasized that this is. not a fixed standard.. and DEQE may allow site specific alternative remedial goals whenever it is deemed appropriate. At this point, SP, Inc. would recommend soil and tank removal and an effective in-situ treatment such as recovery wells to treat the solvent area groundwater . To confirm our recommendations, we must- submit this report to .DEQE with a waste contingency plan for further approval. The occupational exposure limits (OSHA) For. benzene . in air is 10 ppm. Levels of 50 to 70 ppm were encountered in the test cores , but were not evident at the surface of the property. Excavation would be the only mechanism by which workers would be exposed to the threshold levels. Removal and stockpiling of the soil would be conducted under the supervision of an engineer and safety precautions such as organic vapor masks. (for workers in the excavation) and plastic covering of material would be followed. As described in the Soil Logs , . the layer of contaminated material is covered by 7 to 11 feet of clean fill. This also minimizes the risk of direct human contact.' Although there is no current danger of migration or further exposure , -the contaminated soil must be removed and -properly disposed of in a licensed landfill. This is a common procedure that can be accomplished safely over a period of several months . Portable volatile meters can identify the contaminated material 18 I during_. excavation for isolation on plastic. The stockpiled soil will" also be completely covered with P y plastic. Composite soil samples will be . taken . after excavation is complete for laboratory analyses that are required for landfill acceptance . Once acceptance is received (2 to 4 weeks) , the material would be loaded. onto licensed trucks and hauled away. The top 7 to 11 feet of clean fill. will be removed to the side and returned to the hole after .the contaminated soil is excavated. Soil samples of the bottom and sides remaining in the excavation will be taken to confirm that all contaminated ;gate= ial was removed . DEQE and other parties will receive all chemical analyses , manifests and a final report documenting the remedial action. The quantity of oily material to be removed from the parking lot is estimated at 1100 cubic yards (60 ' x 60 ' x 8.' average thickness, to below groundwater) . This would represent an expenditure of $170, 500. 00 at $155/ton, if .the material had to be taken to the Sawyer Environmental facility in Maine. However , chemical tests do not indicate any solvent or heavy metal contamination, so the material could be taken to Brock ' s. .Asphalt Plant in Dracut, Massachusetts at $90/ton for $100 ,000 . 00 total . The solvent contaminated soil in the back of the building will also have to be removed or encapsulated. The soil from the groundwater to beneath the pavement contains varying amounts of solvent. The average soil depth is 5 to 8 feet before. refusal (ledge) . The estimated quantity of soil (roughly 1001 x 30' x 19 `61 Is. 700 cubic .yards. Large material (rock and concrete) can remain on-site if not saturated with solvent. Solvent disposal requires transport to a secure landfill in New York -or South Carolina. 'The cost is approximately $225/ton or $160,000.00 if all material has to go. Since the site is not being considered for residential construction, some low level material could remain. nn-site if sealed. to prevent future migration to the North River. The barrels on-site, after characterization, can be disposed of at a rate of $20.0 to $350 per drum, depending upon the materials. Tt is not anticipated that removal would cost more than $7, 000.00. for 20 barrels. After soil removal and backfill in the solvent area, we would recommend the installation of -two. (4" ) groundwater recovery wells. The groundwater would -be pumped to- granular activated carbon filters for removal of the remaining soluble petroleum compounds.. Groundwater , .-after carbon absorption, should contain less than 5 ug/1 of benzene and would be returned to the ground on the property upgradient of the wells. This continuous process will clean the groundwater and flush remaining material from the soils over a period of 3 to 9 months . Monthly analyses of the wells will document the remediation. The installation and operation of this equipment (and final carbon disposal) is estimated to cost $16,000.00 to $18, 000 . 00 . The large 20, 000-gallon fuel oil tank and 6, 000-gallon solvent tank need to be removed, cut open, wiped clean and 20 transported fo-r -disposal as scrap steel. This operation . will i allow access to surrounding soil.- It is estimated to cost $20, 000. 00 to complete the tank removal job. Excavation of i contaminated. soils, with engineering supervision and chemical' analysis would cost approximately $20, 000 to $30 , 000 . The total backfilL material (1800 cy @ $8/cy) and resurfacing of the excavated areas would cost an estimated $2Q, 000 to $25, 000. The r-emediati-on proposed (all items) would cost an estimated $360,000. 00 (worst case) , depending on subsurface conditions encountered. Outlined below are the conventional 't.echniques and costs used for this type of cont-amination. ESTIMATED REMEDIAL COSTS , WORST CASE A. #6 fuel oil soil -contamination front parking lot disposal of-1100 cubic yards. @ $9G/ton- Brock 's Asphalt- Plant $100, 000. 00 B. Solvent contaminated soil disposal of 700 cy @ $225/ton_ Model City, New York .$160, 000 . 00 C. Barrel removal 20 @ $350/barrel $ 7,000 . 00 D. Solvent area, groundwater recovery wells (2) and monthly monitoring (9 mon. ) $ 18,000 .00. E. Tank removal , cleaning and disposal one 20 ,000-gallon #6 one 6 , 000-gallon solvent $ 20, 000 . 00 F. Soil excavation, engineering supervision and chemical analyses. DEQE permit MCP and final report $ 30, 000 . 00 G. Clean back.fi.11ing material 1800 cy @ $8/cy in-place, compacted and resurfaced with . asphalt $ 25, 000. 00 Total $360,000 .00 21 -There are other methodologies that can be used to remediate an industrial site such as this. Some of them will save money , but would result in a site condition that would be .unsuitable for residential housing. At this time, the property is being marketed for commercial use or warehouse activity. The zoning is also industriallcommercial and not likely .to change in the near future since there are many industries nearby. It is anticipated that the old .section of the building would be demolished and a new structure built in its place , without a lot of new foundation work. These considerations mean that the 16 fuel oil contaminated soil at a level of 1% or less can remain in the ground. The section would be sealed in clay on the south and east side to contain any material from migrating as a liquid. The surface of the excavation should be sealed with .asphalt to minimize the amount of rainwater that penetrates into the soils. The solvent contaminated area on the back of -the property would also be sealed from downgradient Goodhue Street and .the North River by a clay. layer . Groundwater encountered in this area (Test Well 12) is not true groundwater , but interstitial rainwater traveling on the subsurface ledge. When excavation and tank removal are in process , ' a portable volatile compound HNU meter will be used to determine which soils are above the 10 ppm limit. In many cases , the action of excavation aerates the soils and releases volatiles causing marginal values of 15 to 20 ppm to decrease and pass the criteria. 22 This . soi-1; after aeration and- large concrete or rock pieces , .can be - returned (after DEQE review of the analyses) to the hole- .as ' backfill. If_ the surface of the excavation is then sealed. by concrete or asphalt, and by clay around the downg.rad.ient perimeter, pump-out wells may not be required. The quantity of material for disposal will also be reduced by 30 to 35 percent. If these techniques are allowed by DEQE, and they .have been used locally before, the following outline of costs would apply. ESTIMATED REMEDIAL COSTS FOR COMMERCIAL SITE ENCAPSULATION A. fuel oil soil contamination front parking lot disposal of 1100 cy @ $90/ton $1001000 . 00 B. Solvent contaminated soil after aeration -disposal of 350 cy-' @ $225/ton -$ 80, 000 . 00. C. Barrel removal 20 @ $350 $ 7, 000 .00 D. No groundwater recovery wells SIC E. Tank removal, cleaning and disposal 20, 00'0 and 6, 000 gallon tanks $ 20, 000 . 00 F; soil excavation, engineering supervision and chemical analyses . DEQE permits MCP and final. report $ 30, 000 . 00 G. Clean backfill material 1200 cy @ $8/cy in - place --compacted and resurfaced with asphalt. Clay layer around . perimeter , both areas 160 cy '@ $12%yd in-place S 25, 000 . 00 Total $262 , 000 . 0.0 23