Fifth Phase V Report0203\Fifth Phase V Report (9/23/05)
Project Number 0203
PHASE V INSPECTION AND
MONITORING REPORT
Former Staab’s Service Station
RTN: 1-0705
September 2005
PENNEY ENGINEERING, INC
ENVIRONMENTAL ENGINEERS & SCIENTISTS
125 HIGH STREET
MANSFIELD, MA 02048
(508) 261-1288
PHASE V INSPECTION AND
MONITORING REPORT
September 2005
Former Staab’s Service Station
459, 480 & 492 Pleasant Street
Northampton, MA 01060
RTN: 1-0705
Prepared For:
PLEASANT JOURNEY USED CARS, INC
459 Pleasant Street
Northampton, MA 02703
(413) 774-6559
Prepared By:
PENNEY ENGINEERING, INC
125 High Street
Mansfield, MA 02048
(508) 261-1288
LSP Who Prepared This Phase V Inspection and Monitoring Report:
Signature: ______________________
Ralph P. Penney, PE, LSP
Title: President
License Number: 7755
Date: ___________________
i PENNEY ENGINEERING, INC
PHASE V INSPECTION AND
MONITORING REPORT
Former Staab’s Service Station
459, 480, 492 Pleasant Street, Northampton, MA
RTN: 1-0705
TABLE OF CONTENTS
PAGE
LIST OF TABLES………………………………………………………………………………………iii
LIST OF ABBREVIATIONS AND ACRONYMS…………………………………………………….iv
1.0 INTRODUCTION ..............................................................................................................1
1.1 Description of Site..................................................................................................21
2.0 SITE HISTORY ...............................................................................................................22
2.1 History of Use at the Site........................................................................................22
2.2 Current Use of the Site...........................................................................................23
3.0 NATURE AND EXTENT OF CONTAMINATION ............................................................23
3.1 Previous Assessment Activities..............................................................................23
3.2 Additional Assessment Activities............................................................................25
3.3 Extent of Free-Phase Gasoline ..............................................................................27
3.4 Extent of Soil Contamination..................................................................................27
3.5 Extent of Groundwater Contamination ...................................................................27
4.0 SUMMARY OF SITE CONDITIONS THAT WARRANTED REMEDIAL ACTIONS .......27
5.0 CONSTRUCTION OF SELECTED REMEDIAL ACTION ALTERNATIVE .....................28
5.1 As-Built Construction Report..................................................................................31
5.2 Final Inspection Report ..........................................................................................31
5.3 Phase IV Completion Statement ............................................................................31
6.0 OPERATION, MAINTENANCE AND MONITORING OF THE TREATMENT
SYSTEMS .......................................................................................................................31
7.0 REMEDY OPERATION STATUS ...................................................................................71
8.0 PUBLIC INVOLVEMENT ACTIVITIES ...........................................................................71
ii PENNEY ENGINEERING, INC
TABLE OF CONTENTS (cont’d)
FIGURES
Locus Map
Figure One – Groundwater Flow on October 11, 2000
Figure Two – Groundwater Flow on April 25, 2002
Figure Three – BTEX Plume on April 25, 2002
Figure Four – C5-C8 Aliphatics Plume on April 25, 2002Table Two – Summary of
Specific 1998 Groundwater Results
Table Three –Summary of Groundwater Results, April 25, 2002
Table Fourteen – Summary of Groundwater Measurements, March 18, 2004
Table Seventeen – Summary of Groundwater Measurements, June 16, 2004
Table Twenty – Summary of Groundwater Measurements, September 21, 2004
Table Twenty-Two – Summary of Groundwater Results, December 9, 2004
Table Twenty-Three - Summary of Groundwater Measurements, December 9, 2004
Table Twenty-Six – Summary of Groundwater Measurements, March 24, 2005
Table Twenty-Nine – Summary of Groundwater Measurements, June 13, 2005
Table Thirty – Historic Summary of Groundwater Results for Influent
Table Thirty-One – Historic Summary of Groundwater Results for MW-9
Table Thirty-Two – Historic Summary of Groundwater Results for MW-10
Groundwater Contour Plan for November 11, 2003
Chart One - Gasoline Recovered During Regeneration of Carbon, September 22, 2003
thru February 26, 2004
Chart Two – Gasoline Recovered During Regeneration of Carbon, March 11, 2004 thru
August 31, 2004
Chart Three – Gasoline Recovered During Regeneration of Carbon, September 7, 2004
thru March 4, 2005
Chart Four – Gasoline Recovered During Regeneration of Carbon, April 6, 2005 thru
August 22, 2005
Chart Five – Plot of Influent Results, June 25, 2003 thru June 13, 2005
Chart Six – Plot of MW-9 Results, June 25, 2003 thru June 13, 2005
Chart Seven – Plot of MW-10 Results, June 25, 2003 thru June 13, 2005
A full-size as-built, Remedial Action Site Plan is included in the rear pocket
iii PENNEY ENGINEERING, INC
TABLE OF CONTENTS (cont’d)
APPENDICES
Appendix A Comprehensive Response Action Transmittal Form (BWSC-108), April
19, 2005 Letter to MHD and May 10, 2005 Response Letter from MHD
Appendix B Monitoring Logs from February 5, 2005 through August 22, 2005
Appendix C Laboratory Analysis Report for the Groundwater Samples Collected on
March 24, 2005 and June 13, 2005
iv PENNEY ENGINEERING, INC
LIST OF TABLES
TABLE
NUMBER NAME LOCATION/
PAGE
ONE History of Ownership 22
TWO Summary of Specific 1998 Groundwater Results Figures
THREE Summary of Groundwater Results – April 25, 2002 Figures
FOUR Removal Rates – June 25, 2003 32
FIVE Summary of Groundwater Results – June 25, 2003 33
SIX Removal Rates – September 22, 2003 35
SEVEN Summary of Groundwater Results – September 22, 2003 36
EIGHT Removal Rates – December 18, 2003 40
NINE Summary of Groundwater Results – December 18, 2003 41
TEN Remedial Additive Monitoring – December 18, 2003 41
ELEVEN Removal Rates – March 18, 2004 43
TWELVE Summary of Groundwater Results – March 18, 2004 44
THIRTEEN Biochemical Evaluation Results and Measurements –
March 18, 2004
45
FOURTEEN Summary of Groundwater Measurements – March 18,
2004
Figures
FIFTEEN Removal Rates – June 16, 2004 47
SIXTEEN Summary of Groundwater Results – June 16, 2004 47
SEVENTEEN Summary of Groundwater Measurements – June 16,
2004
Figures
EIGHTEEN Removal Rates – September 21, 2004 50
NINETEEN Summary of Groundwater Results – September 21, 2004 51
TWENTY Summary of Groundwater Measurements – September
21, 2004
Figures
TWENTY-ONE Removal Rates – December 9, 2004 54
TWENTY-TWO Summary of Groundwater Results – December 9, 2004 Figures
TWENTY-
THREE
Summary of Groundwater Measurements – December 9,
2004
Figures
TWENTY-FOUR Removal Rates – March 24, 2005 58
TWENTY-FIVE Summary of Groundwater Results – March 24, 2005 58
TWENTY-SIX Summary of Groundwater Measurements – March 24,
2005
Figures
v PENNEY ENGINEERING, INC
LIST OF TABLES (cont’d)
TABLE
NUMBER
NAME LOCATION/
PAGE
TWENTY-SEVEN Removal Rates – June 13, 2005 62
TWENTY-EIGHT Summary of Groundwater Results – June 13, 2005 63
TWENTY-NINE Summary of Groundwater Measurements – June 13,
2005
Figures
THIRTY Historical Summary of Groundwater Results for MW-10 Figures
THIRTY-ONE Historical Summary of Results for Influent Figures
THIRTY-TWO Historical Summary of Groundwater Results for MW-10 Figures
vi PENNEY ENGINEERING, INC
LIST OF
ABBREVIATIONS AND ACRONYMS
AAL Allowable Ambient Limits MSDS Material Safety Data Sheet
ACEC Areas of Critical Environmental Concern MTBE methyl tert-butyl ether
ACM Asbestos Containing Material NON Notice of Non-Compliance
ACO Administrative Consent Order NOR Notice of Responsibility
APHs Air-Phase Petroleum Hydrocarbons OSHA Occupational Safety and Health
Agency
AST Aboveground Storage Tank OVM Organic Vapor Meter
ASTM American Society for Testing and Materials PAHs polynuclear aromatic hydrocarbons
AUL Activity and Use Limitation PCBs polychlorinated biphenyls
BWSC Bureau of Waste Site Cleanup PCM Phase Contrast Microscopy
BWP Bureau of Waste Prevention PLM Polarized Light Microscopy
CCA chromium, copper and arsenic ppb parts per billion
cfu/ml colony forming units per milliliter ppm parts per million
CFR Code of Federal Regulations PRP Potentially Responsible Party
cfm cubic feet per minute
CMR Code of Massachusetts Regulations RAM Release Abatement Measure
cy cubic yard RCRA Resource Conservation Recovery
Act
DEP Department of Environmental Protection RFI Request for Information
DHHS Department of Health and Human Services RNF Release Notification Form
DLWD Department of Labor and Workforce
Development
ROS Remedy Operation Status
EDB ethylene dibromide RP Responsible Party
EPA Environmental Protection Agency RTN Release Tracking Number
EPHs extractable petroleum hydrocarbons sf square feet
gpd gallons per day SVOCs semi-volatile organic compounds
gpm gallons per minute TECs Threshold Effects Concentrations
IRA Immediate Response Action TEL Threshold Effect Exposure Limit
LRA Limited Removal Action TEM Transmission Electron Microscopy
LSP Licensed Site Professional THF tetrahydrofuran
MCP Massachusetts Contingency Plan TOC total organic carbon
MEK 2-butanone TPHs total petroleum hydrocarbons
mg/kg milligrams per kilogram TSCA Toxic Substance Control Act
vii PENNEY ENGINEERING, INC
LIST OF
ABBREVIATIONS AND ACRONYMS (cont’d)
mg/l milligrams per liter TVOCs total volatile organic compounds
TWA time weighted average UST Underground Storage Tank
ug/l micrograms per liter UTM Universal Transverse Mercator
Ug/m3 micrograms per cubic meter VOCs volatile organic compounds
UIC Underground Injection Control VPHs volatile petroleum hydrocarbons
USGS United States Geologic Survey
Page 1 PENNEY ENGINEERING, INC
1.0 INTRODUCTION
On behalf of Pleasant Journey Used Cars, Inc, Penney Engineering, Inc is pleased to
submit this fifth Phase V Inspection and Monitoring Report for the treatment systems we
have installed and operate at the former Staab’s Service Station located at 459, 480,
and 492 Pleasant Street (Route 5) in Northampton, MA (“the site”). This report has
been prepared for the period from February 28, 2005 to September 1, 2005. The site is
defined as the area containing significant concentrations of gasoline-related
contaminants in the soil and the groundwater. The site is located at the intersection of
Pleasant and Conz Streets, as shown on the Locus Map located in the Figures section.
We began operating the groundwater treatment system on June 25, 2003 and the soil
vapor extraction system on September 9, 2003. As of August 22, 2005, we had treated
1,804,911 gallons of groundwater and recovered 673.05 gallons of gasoline that has
been or shall be reused off-site as a fuel. On November 23, 2004, we began manually
applying remedial additives to monitoring wells MW- 12 and ECS-5 located at 492
Pleasant Street on a periodic basis. On March 24, 2005, we began to apply remedial
additives to MW-2A, MW-10, MW-12, and ECS-5. We currently apply remedial
additives to MW-2A, MW-10 and MW-12 every two to four weeks. The addition of
remedial additives has greatly enhanced the bioremediation of the petroleum
contaminants at 480 and 492 Pleasant Street.
On October 5, 2004, the affected property owners met to discuss our September 30,
2004 evaluation report and cost estimate to install the remainder of the treatment
systems across Pleasant Street. It was decided that without a financial contribution
from the Massachusetts Highway Department (MHD), the owners would continue to
evaluate the current treatment systems for another year before solely incurring the costs
to install the remainder of the systems at 480 Pleasant Street. We have determined
that the effect of the current groundwater system may be limited to the area between
Recovery Well RW-1 and the Recharge Well; the adjacent section of Pleasant Street;
and potentially the western extent of the properties at 480 and 492 Pleasant Street. We
determined that the recharged groundwater may be short-circuiting by flowing through
channels or the more permeable layer of medium to coarse sand beginning at a depth
of 14 feet. We may begin pulsing the pump in Recovery Well RW-1 off and on to
reduce short-circuiting. We also determined that the gasoline contamination is being
partially drawn back to Recovery Well RW-1 from under the adjacent portion of Pleasant
Street owned by the MHD and potentially 480 Pleasant Street. On September 21,
2004, we detected a dramatic increase of gasoline contaminants in monitoring well MW-
9, which is located immediately to the east of Recovery Well RW-1. Recovery Well RW-
Page 2 PENNEY ENGINEERING, INC
1 maintains a drawdown of approximately one-foot, which is expected to greatly affect
the groundwater over a large area in the low permeability soil at the site. Since
September 19, 2003, we no longer observe free-phase gasoline in any of the monitoring
wells at the entire site. On November 23, 2004, we began manually applying remedial
additives to specific monitoring wells located at 480 and 492 Pleasant Street to
remediate those properties. The remediation shall be much slower than an active
remediation system.
On April 19, 2005, we sent another letter to the MHD, this time only requesting that they
install the piping required to extend the treatment systems across Route 5. On May 10,
2005, Mr. Albert R. Stegemann, the District Two Highway Director, issued us a letter.
Copies of both letters are included in Appendix A. Mr. Stegemann’s letter failed to
respond to our request to have MHD install the piping across its property. Instead Mr.
Stegemann simply states a permit is required, however, he is now willing to waive the
fee. It should be noted that Mr. Stegemann returned our original letter and the
attachment, presumably to keep them out of the public record. A complete copy was
submitted to the Department.
Numerous assessments have been conducted at the site since 1988 when gasoline
was detected in the groundwater being pumped from a test wellpoint at the carwash
located at 492 Pleasant Street. The surrounding properties, that were once part of the
Staab’s Service Station, were found to be contaminated with gasoline. Only very limited
remediation had been previously conducted at the site. On May 15, 2003, we submitted
a combined Phase III Remedial Action Plan and Phase IV Remedy Implementation
Plan. On June 2, 2003, we began installing the groundwater and soil treatment systems
proposed in our May 2003 Phase III/IV Plan. The treatment systems were installed in
accordance with the applicable requirements of 310 CMR 40.0870 and the Phase IV
performance standards described in 310 CMR 40.0872. Only the portions of the
systems at 459 Pleasant Street were installed because we were unable to locate the
former product pipes that reportedly crossed Pleasant Street. We had hoped to utilize
the existing pipes to connect the portion of the treatment systems at 480 Pleasant
Street and avoid having to excavate across Route 5.
On June 25, 2003, we started the groundwater treatment system and began monitoring
it. On July 23, 2003, we received a response letter from the Massachusetts Highway
Department (MHD) stating that they were willing to provide assistance with the
remediation at the site and the crossing of Pleasant Street. On September 9, 2003, we
graded the contaminated soil that had been stockpiled on site, but was not accepted for
asphalt recycling, as a modification of our Phase IV Plan. On September 9, we also
Page 3 PENNEY ENGINEERING, INC
activated the soil vapor extraction (SVE) system and began monitoring it. On
September 11, 2003, the graded soil was covered with bituminous concrete, as
recommended by the Department of Environmental Protection (“the DEP”). The
graded, contaminated soil was allowed to be remediated on-site by the SVE system.
On September 15, 2003, we submitted a combined Final Inspection Report, Phase IV
Completion Report, and Phase V Inspection and Monitoring Report. On March 23,
2004, we submitted our second Phase V Inspection and Monitoring Report. On
September 21, 2004, we submitted our third Phase V Inspection and Monitoring Report.
We hope to have the MHD contribute to the cleanup fund for the site and assist us with
crossing Route 5 in order to install the final portion of the treatment systems at 480
Pleasant Street. The MHD has only offered to assist us with crossing Route 5. We
have evaluated the operation of the existing treatment systems and determined that the
installation of the systems at 480 Pleasant Street would expedite the cleanup of the site.
On September 19, 2003, we observed four inches of gasoline in a monitoring well at
480 Pleasant Street. Since March 18, 2004, we have not observed free-phase gasoline
in any of the wells we inspected at the site. On November 23, 2004, we began applying
remedial additives to specific monitoring wells at 459, 480 and 492 Pleasant Street.
After completing the installation of the systems across Pleasant Street, we shall achieve
Remedy Operation Status in accordance with 310 CMR 40.0893.
The properties at 459, 480 and 492 Pleasant Street were previously under common
ownership and operated as the Staab’s Service Station until 1955 when Pleasant Street
(Route 5) was constructed through the station property. In 2002, we confirmed the
continued presence of free-phase gasoline floating on the groundwater in the area of
the former dispensers and underground storage tanks at 459 Pleasant Street; under the
adjacent portion of Pleasant Street; and extending to the area of the former tanks
directly across Pleasant Street at 480 Pleasant Street. We have also confirmed the
continued presence of significant concentrations of dissolved gasoline contaminants in
the groundwater over a larger area. The dissolved gasoline contaminants were found to
be slowly migrating to the east in the direction of the local groundwater flow. The
conditions at the site warranted the implementation of remedial response actions.
In June 1984, the former tanks at 459 and 480 Pleasant Street were removed.
Reportedly, the tanks at 480 Pleasant Street were used for the original gasoline station
which had dispensers along Conz Street. Conz Street was previously known as Maple
Street, the main route into the center of Northampton. We believe that the tanks at 480
Pleasant Street may have actually been for dispensers on the opposite or both sides of
Pleasant Street. In 1984, Mr. Robert Kalish, the President of Pleasant Journey,
Page 4 PENNEY ENGINEERING, INC
remembered seeing pipes that lead to the former dispensers at 459 Pleasant Street
when the tanks at 480 Pleasant Street were being removed. Reportedly, the tanks at
459 Pleasant Street were the most recent tanks used to supply the dispensers at 459
Pleasant Street. There may still be tanks buried at 459 Pleasant Street that were used
to supply the former dispensers along Conz (Maple) Street. In 1988, a wellpoint was
installed at the car wash at 492 Pleasant Street to evaluate installing a supply well.
Gasoline was detected in the groundwater pumped from the wellpoint. On June 14,
1988, the DEP was notified of a release at 492 Pleasant Street. Site Number 1-0462
was assigned. The gasoline was traced to the former tanks at 459 Pleasant Street, but
no one was sure where the gasoline originated from. Monitoring wells were installed
and up to 12 inches of free-phase gasoline was observed in three wells. Groundwater
was encountered at a depth of eight to 11 feet.
On October 23, 1989, the DEP was first notified of a gasoline release at 459 Pleasant
Street based upon the findings presented in an August 30, 1989 report by the former
Certified Engineering and Testing Company of Weymouth, MA. Site number 1-0705
was assigned and it later became the Release Tracking Number (RTN) for the site. On
January 25, 1990, a Phase II Scope of Work for the site was received by the DEP. On
January 21, 1994, a Settlement Agreement was entered into by the prior and current
owners of the properties that comprised the former Staab’s Service Station property.
The Commonwealth of Massachusetts, as the reported owner of the Route 5 property,
was not included in the Agreement at the time. The Agreement stated that Pleasant
Journey Used Cars, Inc, Mr. Robert Kalish and his former partner, Mr. John Guillot,
would remediate the gasoline contamination at 459 and 492 Pleasant Street. The
owners of 492 Pleasant Street contributed $70,000 to a fund established to pay for the
remediation. The estate of the former owner of the properties also contributed $98,000
to the fund. The former owner of 492 Pleasant Street contributed $2,000. Pleasant
Journey Used Cars, Inc, Mr. Kalish and Mr. Guillot agreed to use the contributed
monies to remediate the contamination and contribute any additional monies required
for the remediation or refund any of the contributed monies not used. Numerous
investigations and limited remedial measures were conducted at the site. On December
4, 1996, the site was recommended to be classified as a Tier II site by Cold Spring
Environmental, Inc of Belchertown. The remedial measures were limited to manual
bailing of the free-phase gasoline from monitoring wells over ten years; a limited
groundwater pump and treat system; and a soil vacuum extraction (SVE) system that
operated intermittently from August 7, 2000 until December 7, 2000.
Page 5 PENNEY ENGINEERING, INC
On December 8, 1998, a Method Three Risk Characterization was prepared for the site
by O’Reilly, Talbot & Okun Associates, Inc of Springfield. It determined that there was
no significant risk associated with the remaining contamination at the site. On March
26, 1999, the Method Three Risk Characterization, a Phase II Report, and a Phase III
Plan were submitted to the DEP by Environmental Compliance Services (ECS), Inc of
Agawam. The document stated that no significant risk was identified at the site at that
time. The application of oxygen-releasing compounds and an Activity and Use
Limitation were recommended as a permanent solution for the site. On June 8, 2000,
free-phase gasoline was again discovered in wells MW-9 and VM-1 at thicknesses of
0.69 and 0.14 feet, respectively. On June 29, 2000, an Immediate Response Action
(IRA) Plan was submitted to the DEP by Acadian Environmental of Springfield. The IRA
Plan originally proposed the installation of a groundwater pump and treat system and a
separate SVE system using vapor phase carbon for air emissions control. Bailing of the
free-phase gasoline was again proposed to be conducted from specific wells. The
groundwater was to be pumped through an oil/water separator and two, 500-lb canisters
of aqueous phase carbon before being discharged into a storm drain. On September 1,
2000, the IRA Plan was modified to allow the SVE system to use a catalytic oxidizer
instead of vapor phase carbon, presumably because of the high concentrations of
gasoline vapors being extracted from the soil.
According to a November 30, 2000 IRA Status Report by Acadian, the SVE system
began operating on August 7, 2000. The pump and treat system only operated at 1.5
gpm from August 8 to 10, 2000 because of mechanical problems. The SVE system
utilized an existing monitoring well and did not include a knockout drum. Reportedly,
the SVE system operated intermittently from August 7, 2000 until it too experienced
mechanical problems on December 7, 2000. The second, June 22, 2001 IRA Status
Report by Acadian stated that a Falco Model #500 catalytic oxidizer had been used with
the SVE system until the second week of December 2000. Reportedly, the oxidizer was
damaged when liquid gasoline was drawn into it.
On January 29, 2002, the DEP issued a Notice of Noncompliance (NON) to Pleasant
Journey for its failure to complete the required Comprehensive Response Actions at the
site. The NON requested that a third IRA Status Report be submitted by March 29,
2002. The NON also requested that a Phase IV Plan be submitted by April 29, 2002. A
Phase IV Plan was originally due by December 4, 1999. The December 4, 1996 Tier II
classification for the site expired on December 3, 2001. No extension application was
submitted 60 days prior to the expiration date.
Page 6 PENNEY ENGINEERING, INC
On March 12, 2002, we inspected the site. Five inches of free-phase gasoline was
measured in monitoring well MW-9 located along Pleasant Street. The gasoline
appeared weathered, but smelled fresh. On March 22, 2002, we were retained by Mr.
Kalish to assume the responsibility of providing Licensed Site Professional (LSP)
services for the site. We briefly reviewed the numerous assessment and status reports
that had been prepared for the site. Reportedly, the properties comprising the site were
previously owned and operated as a gasoline station by Mr. Carlton H. Staab and his
parents from 1912 until 1955 when Route 5 was constructed through the station as part
of the federal highway program. Reportedly, Route 5 is owned by the Commonwealth
of Massachusetts and controlled by the Massachusetts Highway Department. A
gasoline station continued to operate at 459 Pleasant Street until 1983 when the 21,280
square-foot commercial property was purchased by Pleasant Journey and converted to
a retail, used automobile dealership. Reportedly in 1984, four underground gasoline
tanks were removed from 459 Pleasant Street. The capacities of the tanks were 1,500,
3,000, 8,000, and 9,000 gallons.
On March 28, 2002, we submitted a third IRA Status Report to the DEP and proposed
conducting additional assessment activities as an IRA Modification. On April 25, 2002,
we gauged and sampled 19 specific wells at the site. We also conducted limited indoor
air screening in some of the surrounding buildings. We confirmed the continued
presence of free-phase gasoline in the area of the former dispensers along Pleasant
Street at 459 Pleasant Street and in the area of former gasoline tanks that were located
directly across Pleasant Street at 480 Pleasant Street. We assumed that the two areas
of free-phase gasoline were connected under the adjacent section of Pleasant Street.
We also confirmed the continued presence of significant, dissolved gasoline
contaminants in the groundwater over a larger area encompassing the properties
located at 459, 480 and 492 Pleasant Street. Both contaminant conditions warranted
the implementation of remedial response actions at the site. We did not identify a
Critical Exposure Pathway or an Imminent Hazard based upon the available information
and conversations with the DEP. After at least 14 years, the free-phase gasoline had
not significantly migrated to the east toward the Connecticut River.
For the next few months we reviewed the available documents and evaluated a number
of remedial options with Mr. Kalish. We found that the car wash property, at 492
Pleasant Street, was listed as a Tier IB default site with RTN: 1-0462, although ECS
had reported that a Downgradient Property Status Submittal had been submitted for it.
On April 8, 2002, Mr. Michael Scherer from the DEP stated that no Downgradient
Page 7 PENNEY ENGINEERING, INC
Property Status Submittal had been received for RTN: 1-0462. Mr. Scherer agreed to
internally link the two sites under RTN: 1-0705.
The groundwater at the site is classified as GW-2 and GW-3. The groundwater table is
less than 15 feet below grade. Reportedly, there are no private water supply wells
within 500 feet. Municipal drinking water is available along Pleasant Street. There are
no occupied residences within 30 feet of the site. There are only occupied offices and
commercial buildings located within 30 feet of the site. Reportedly, none of the
surrounding buildings have basements. The gasoline-contaminated soil cannot be
excavated because of space restrictions and because it extends under Pleasant Street.
An Activity and Use Limitation is an acceptable remedial option for Pleasant Journey,
but may not be acceptable to the other property owners. The native soil is uniform, fine
sand with a high silt content and very low permeability. Limited hydraulic conductivity
testing has been conducted by others which incorrectly reported relatively high hydraulic
conductivity. The free-phase gasoline had not significantly migrated for at least 14
years, indicating low soil permeability and a low hydraulic gradient. The groundwater
had not been tested for dissolved iron or manganese, but has been found to be
relatively low based on the aeration of the groundwater by the current treatment system.
Sewer and storm water pipes run along Pleasant Street, but may not be preferential
pathways because they may be bedded above the groundwater table measured to be at
eight to 11 feet. Reportedly, there may have been a problem with the prior storm water
discharge from the treatment system installed by Acadian, so that a future discharge
would not be approved by the EPA or the City of Northampton.
During the summer of 2002, we prepared a more accurate plan of the site and adjacent
properties. Our Remedial Action Site Plan was drawn to scale and showed all the
important features. It was used to prepare more accurate figures of the site.
Groundwater contours and contaminant plumes were shown as separate figures.
Copies of the figures are included in the Figures section. We have also evaluated the
presence of an Imminent Hazard, a Condition of Substantial Release Migration and the
presence of a Critical Exposure Pathway. Limited indoor air monitoring was conducted.
No one had reported smelling gasoline in their buildings. According to the June 29,
2000 IRA Plan by Acadian, a Condition of Substantial Release Migration did not exist at
the site even though up to 0.69 feet of free-phase gasoline was observed floating on the
groundwater.
In November 2002, we conducted a focused feasibility study of the applicable treatment
technologies to remediate the gasoline contamination in the soil and the groundwater at
the site. The most applicable technologies were used to develop at least three remedial
Page 8 PENNEY ENGINEERING, INC
alternatives. Each alternative was evaluated in terms of costs, ability to be constructed,
effectiveness, and safety. We met with Mr. Kalish to discuss the three alternatives in
order to select the best remedial alternative to effectively remediate the site. We
determined that the most appropriate alternative included pumping the contaminated
groundwater from one or two recovery wells and treating the water in a biodiffuser, with
vapor phase carbon for air emission controls. Pumping the groundwater would depress
the groundwater table in order to first allow a majority of the free-phase gasoline to be
removed manually with bailers or with automatic skimmers from the large diameter
recovery wells. Once a majority of the available free-phase gasoline was removed, an
SVE system would be activated to remove the bound free-phase gasoline from the pore
spaces of the dewatered saturation zone above the depressed groundwater table.
Once the SVE system removed the bound free-phase gasoline, the biodiffuser would
continue to operate to reduce the dissolved gasoline contaminants below the applicable
Method One GW-2 and GW-3 cleanup standards. The treated groundwater would be
discharged upgradient of the contamination to promote flushing and biological
remediation. Remedial additives may be injected into the discharged groundwater to
enhance bioremediation.
On November 13, 2002, the DEP issued a second Notice of Noncompliance to Pleasant
Journey. It requested that a fourth IRA Status Report or an IRA Completion Report be
submitted for the site within 30 days. It also requested that a Tier II Extension Request
or a Response Action Outcome (RAO) Statement be submitted for the site.
On December 5, 2002, we sent a letter to Mr. Kalish explaining his regulatory options.
We recommended that we close the IRA activities and proceed with the remediation of
the site as a Comprehensive Response Action. We also described a proposed
treatment system and included conceptual design plans. We suggested that he discuss
the installation of a second Recovery Well with the owners of the property at 480
Pleasant Street in order to expedite the remediation. We requested that he seek their
written authorization.
On December 9, 2002, we submitted a letter to the DEP which acknowledged our
receipt of the second NON, reported our ongoing efforts to design a treatment system
for the site and provided notification that we would be submitting an IRA Completion
Report before the December 16, 2002 deadline. On December 10, 2002, we received
written authorization to install a recovery well at 480 Pleasant Street from the owner,
Quickbeam Realty Trust.
Page 9 PENNEY ENGINEERING, INC
On December 12, 2002, we submitted a combined IRA Completion Report and Tier II
Extension Request for the site to the DEP. The submission of the IRA Completion
Report closed the June 29, 2000 IRA Plan submitted by Acadian. The Tier II Extension
Request requested that the DEP grant two, one-year extensions of the Tier II
classification. The two extensions were requested to allow a treatment system to be
installed and Remedy Operation Status to be achieved before the extended Tier II
classification expired again on December 3, 2003.
On December 17, 2002, Mr. Scherer contacted us to say that he received our
December 12, 2002 submission. He also stated that there were violations associated
with prior Notices of Responsibility issued for the site. He wanted to have Pleasant
Journey enter into an Administrative Consent Order (ACO) to eliminate the violations
and specify completion dates for the required Comprehensive Response Actions. We
discussed completion dates with Mr. Scherer. He wanted to meet with Mr. Kalish. He
also stated that the DEP could only issue the requested two, one-year Tier II
classification extensions with an ACO.
On January 8, 2003, Mr. Kalish met with Mr. Scherer at the DEP office in Springfield.
Mr. Kalish agreed to enter into an ACO. On January 17, 2003, the DEP issued a draft
ACO to Mr. Kalish and sent a copy to us. We reviewed the ACO and discussed our
requested revisions with Mr. Kalish. Mr. Kalish had his attorney review the draft ACO
and our revisions. On February 11, 2003, we faxed a markup of the draft ACO to Mr.
Scherer showing our requested revisions. Later on February 11, Mr. Scherer called us
to say that he had no problems with our revisions. He also answered our two questions
that pertained to our ability to install the treatment systems at the site while the Tier II
Extension Request was being reviewed and if the two, one-year extensions could be
written into the final ACO. Mr. Scherer stated that the installation could proceed during
the review period and that the extensions would be written into the ACO. On February
11, the DEP issued an ACO that incorporated all our requested revisions except the
request for two, one-year Tier II classification extensions. Mr. Kalish signed the ACO
and mailed it back to Mr. Scherer. On February 27, 2003, the ACO was signed by Mr.
Michael J. Gorski at the DEP and it became effective.
In February 2003, we sent draft copies of our plans to local contractors for quotations to
assist with the installation of the treatment systems. On February 27, 2003, Mr. Mark
Kalish measured the available space to construct a concrete pad for the treatment
trailer between the Pleasant Journey office building and Fulton Avenue. There was not
enough space for the required setbacks. On February 28, 2003, we met with Mr. Kalish
to discuss the treatment systems. Mr. Kalish offered to relocate all the cars from the
Page 10 PENNEY ENGINEERING, INC
eastern portion of his property during the installation. He also said that he would repave
the entire area we would excavate to install the systems. We discussed upgrading the
electrical service, connecting a dialer from the systems to one of his telephone lines and
saving approximately $20,000 by not installing automatic skimmers to remove the
gasoline from the two proposed recovery wells. Mr. Kalish preferred to manually bail
the gasoline. On April 3, 2003, we met with Mr. Kalish to discuss our latest design
plans. Mr. Kalish directed us to design a third SVE zone to be located at 480 Pleasant
Street to expedite the remediation.
On April 4, 2003, we contacted Mr. Mathew Pitoniak of Quickbeam Realty Trust to
discuss installing a recovery well and third SVE zone at its 480 Pleasant Street
property. Mr. Pitoniak was concerned that the installation would block his northern curb
cut at 480 Pleasant Street so we agreed to relocate the recovery well to the south. We
agreed to send him copies of our latest plans. We requested an accurate plan of his
properties. On April 7, 2003, Mr. Pitoniak faxed us a sketch of the important features
that he personally measured at 480 Pleasant Street.
In April, we setup charge accounts with local vendors. On April 17, 2003, we faxed a
revised plan of Recovery Well RW-2 to Mr. Pitoniak for his approval and ordered the
pre-cast concrete structures from Arrow Concrete Products of Granby, CT. On April 18,
2003, we met with the selected excavation contractor, Grant Brothers Associates of
Mansfield, to discuss the installation of the treatment system. It was agreed to
postpone the scheduled May 5, 2003 start date because of the unseasonably high
groundwater table. A large manhole box or shoring would be used to reduce the need
to conduct costly dewatering. We agreed to begin monitoring the elevation of the
groundwater table on a weekly basis. On May 1 and 2, 2003, Arrow Concrete delivered
the pre-cast concrete structures to the site.
On May 15, 2003, we submitted a Phase III/IV Remedial Action and Remedy
Implementation Plan to the DEP in accordance with the ACO. Approval of the Phase
III/IV Plan by the DEP was not required. The Phase III/IV Plan included a summary of
the previous and our recent assessment activities. It included plans showing our
estimated extent of the free-phase gasoline floating under 459 Pleasant Street, 480
Pleasant Street and the adjacent section of Pleasant Street. Based upon the available
assessment information, the center of the free-phase gasoline and the dissolved plume
appeared to be located directly under Pleasant Street. It also included an evaluation of
the applicable remedial technologies to remove the gasoline contaminants from the
groundwater and soil at the site. It proposed that the contaminated groundwater be
pumped from two recovery wells in order to first depress the groundwater table to allow
Page 11 PENNEY ENGINEERING, INC
a majority of the free-phase gasoline to be removed by manually skimming any
recovered gasoline from inside the large diameter recovery wells. A second recovery
well, to be located at 480 Pleasant Street, was proposed as an option to expedite the
remediation. We hoped to utilize the former product piping under Pleasant Street to
pipe to the second recovery well and avoid the need to excavate across Route 5. The
SVE system was to be installed as three separate zones. The Phase III/IV Plan
included detailed construction plans of the proposed groundwater and soil treatment
systems.
On May 29, 2003, we discussed our Phase III/IV Plan with Mr. Scherer. On May 30,
2003, the DEP issued a letter to Pleasant Journey. The letter required that any soil
stockpiled during the installation be removed within 30 days; that the recovery wells be
vented through the SVE system as we had previously offered to do; that proper safety
equipment would be utilized; that no recharge water shall drain to the adjacent property;
and that any recovered gasoline be properly stored. From April 25 until May 29, 2003,
we monitored the relatively high elevation of the groundwater at the site due to the large
snowmelt. When it returned to normal springtime elevations, we scheduled the
installation of the treatment systems.
On June 2, 3, 4, 5, and 6, 2003, we installed the underground portions of the treatment
systems at 459 Pleasant Street. We also constructed the concrete pad for the
treatment trailer, placed the trailer on the pad, placed the regenerative carbon vessel on
the pad and filled the vessel with approximately 1,300 lbs of vapor phase carbon. We
encountered approximately 100 cubic yards of overtly, gasoline-contaminated soil and
stockpiled it on site. On June 11, 12 and 13, 2003, we completed the setup of the
treatment trailer and tested the equipment. On June 20, 2003, we submitted a
preliminary Bill of Lading form with three attachments to the Ted Ondrick Company, LLC
of Chicopee as a request to recycle the approximately 100 cubic yards of stockpiled
soil.
On June 25, 2003, we installed a chain link fence around the trailer, started the system,
and began monitoring it. We also collected baseline groundwater samples from specific
wells along with influent and effluent samples from the groundwater treatment system.
On June 25, 2003, a representative from Ondrick called and requested three more
samples from the stockpile because the total volatile organic compounds (VOCs) and
the flashpoint exceeded their acceptance criteria. Later that day we collected the
additional soil samples.
Page 12 PENNEY ENGINEERING, INC
On June 27, 2003, revisions to the Massachusetts Contingency Plan became effective.
The revisions did not significantly affect the design, the construction or the operation of
the treatment systems. The revisions only required us to notify the Mayor of
Northampton and the Board of Health of our significant field activities.
On June 27, 2003, we sent a letter to Mr. Kenneth Werner at District Two of the
Massachusetts Highway Department (MHD) in Northampton. The letter briefly
discussed the history of the site and requested that the MHD consider participating in
the cleanup of the site. It also requested their assistance with installing pipes across
Route 5 that may be required to complete the construction of the treatment systems.
On July 7, 2003, the Northampton Fire Department inspected the storage drums and
signed the June 3, 2003 permit to store recovered gasoline. On July 14, 2003, we sent
the additional soil results to Ondrick. The VOC results for the three samples were 677,
2.9 and 7.8 mg/kg. The average was 229 mg/kg, which was below the acceptance
criteria of 500 mg/kg. The flashpoint for all three samples was greater than 165°F,
which was acceptable. On July 16, 2003, Mr. Paul Mullen from Ondrick called to say
that they would pass on recycling the stockpiled soil as recommended by Mr. David
Slowick at the DEP. Reportedly, Mr. Slowick questioned the validity of our additional
soil sampling results. We immediately spoke with Mr. Scherer who agreed to review all
the results which were sent to him later that day. We began to evaluate other recycling
facilities, but all had the same 500 mg/kg total VOCs limit in their permits. After
numerous discussions, Mr. Scherer offered to sample the stockpiled soil himself.
On July 22, 2003, we received a letter from Attorney William F. M. Hicks from the MHD.
The letter stated that the MHD would provide whatever assistance is possible. On July
23, 2003, we received a letter from Mr. John W. Hoey, Jr, the District Highway Director
at District Two of the MHD. Mr. Hoey stated that he had forwarded our June 27, 2003
letter to Chief Counsel at MHD.
On July 31, 2003, Mr. Scherer called us to say he had gotten similar results of 1,000
and 700 mg/kg VOCs. He suggested that we modify our Phase IV Plan to grade the
stockpiled soil on-site, cover it with bituminous concrete and allow it to be vented by the
SVE system. For the next three weeks we attempted to schedule a local contractor to
grade the stockpiled soil and a paving contractor to immediately cover it with bituminous
concrete. On August 27, 2003, we sent a letter to Mr. Scherer modifying our Phase IV
Plan as he suggested and informing him that the grading and paving was tentatively
scheduled for September 4 and 5, 2003. Rain eventually delayed the work until the
following week. On September 9, 2003, we graded the contaminated stockpiled soil
Page 13 PENNEY ENGINEERING, INC
over the area we had excavated to install the treatment systems at 459 Pleasant Street.
On September 9, we also activated the SVE system and began monitoring it. On
September 11, 2003, the graded soil was covered with three inches of bituminous
concrete as recommended by the DEP.
The groundwater treatment system had operated almost continuously since it was
started on June 25, 2003. It had been inspected almost each workday by the
mechanics at Pleasant Journey. The flowrate was initially 5.0 gpm but was gradually
decreased to 1.0 gpm due to low groundwater conditions over the summer. The high
silt content of the groundwater required the discharge filters to be frequently changed. If
a filter became clogged, the biodiffuser would overfill and shutdown the entire
groundwater treatment system. The alarm would sound, the exterior strobe light would
flash and the dialer would call Pleasant Journey, Mr. Penney and Mr. Kalish. After the
filter was changed, it was very difficult to restart the submersible pump in the Recovery
Well because it became clogged with silt. We had to change the pump or tap the riser
pipe to restart the pump. The filters were changed without having to shutdown the
biodiffuser by conducting the replacement between cycles of the discharge pump. As of
September 3, 2003, a total of 168,960 gallons of groundwater had been treated and 9.5
gallons of free-phase gasoline had been recovered by manually skimming.
On September 8, 2003, we called the Northampton Board of Health and notified them
that we would be periodically monitoring the treatment system and sampling monitoring
wells. They were told that we may be wearing white suits and respirators.
On September 12, 2003, we submitted a combined Final Inspection Report, Phase IV
Completion Statement and Phase V Inspection Monitoring Report as the final
requirement of the February 27, 2003 Administrative Consent Order ACO-WE-03-3001
entered into by Pleasant Journey and the DEP to establish interim deadlines. Upon
receipt of the combined document by the DEP, the ACO expired and was terminated.
The combined document described the fabrication, the installation and the operation of
the groundwater and soil treatment systems at 459 Pleasant Street. It included copies
of the permit to store gasoline, the notification letter sent to the public officials, the July
18, 2003 letter from the MHD, our inspection reports of the installation, the associated
laboratory reports and our monitoring logs. It also described the on-site grading of the
contaminated soil stockpiled during the installation and the paving of the excavated
areas.
Since being activated, the groundwater and soil treatment systems were operated and
maintained by Penney Engineering with help from the mechanics at Pleasant Journey.
Page 14 PENNEY ENGINEERING, INC
The mechanics and Mr. Kalish have been trained to safely bail any recovered gasoline
from Recovery Well RW-1 on a weekly basis. Any gasoline that accumulated in RW-1
was manually removed with a newly designed, Kalish skimmer. We have measured the
explosion potential in Recovery Well several times and found it to be well below the
lower explosive limit (LEL) for gasoline. On June 25, 20003, the LEL/oxygen
percentages were 8%/20.6% at the top of RW-1 and 2%/10.5% just above the
groundwater. The systems were inspected almost daily. We monitored them also
every two weeks. We routinely screened the off-gas from the biodiffuser with an
organic vapor meter (OVM) and recorded the results on a monitoring log. During each
inspection the operating parameters of the systems were recorded on monitoring logs.
Copies of the monitoring logs from June 13 to September 3, 2003 were previously
submitted to the DEP with our first Phase V Report.
All the piping was installed underground. The site is currently occupied during the day
by the employees of Pleasant Journey. A notice has been posted on the exterior wall of
the fenced area to alert anyone to contact Pleasant Journey or Penney Engineering if
there are any problems. The biodiffuser is supplied with a high-level shutoff switch
wired to an alarm and an exterior strobe light on the trailer and a dialer to call Pleasant
Journey, Mr. Kalish and Penney Engineering. The moisture separator for the SVE
system is wired similarly.
On September 22, 2003, we collected water samples from the influent, the effluent, well
MW-9 and well MW-10. The samples were analyzed for volatile petroleum
hydrocarbons (VPHs). We also gauged specific wells. Approximately four inches of
free-phase gasoline was observed in well MW-12, located at 480 Pleasant Street. The
influent concentrations had been reduced by approximately 50% from the June 25,
2003 results. Only the C5-C8 aliphatics and the C9-C10 aromatics were above the
applicable GW-3 cleanup standards. Benzene had been reduced to below the cleanup
standard. The removal rates were all above 99.2 percent, even for naphthalene which
is difficult to air strip. Only relatively low concentrations were detected in the effluent
being pumped into the recharge well.
On November 7, 2003, two drums of gasoline were transported from the site by the Oil
Recovery Corporation of West Springfield under a Uniform Straight Bill of Lading. The
approximately 100 gallons of gasoline was transported to the Vexor facility in Medina,
OH to be burnt as a fuel.
On November 11, 2003, we gauged nine monitoring wells at the site to measure the
depth to groundwater and to determine the presence of free-phase gasoline. We also
Page 15 PENNEY ENGINEERING, INC
gauged Recovery Well RW-1 and the recharge well. No free-phase gasoline was
observed in any of the wells, but a sheen was observed in RW-1 and MW-10. Wells
MW-1 RW-1 MW-10, MW-9 MW-12, ECS-5 and MW-2A had a gasoline odor. The
depth to groundwater measurements was used to determine the elevation of the
groundwater table at each well. We wanted to determine the zone of influence for the
recovery well. We used Surfer software to plot the resulting groundwater contours. The
contours showed that the influence of the groundwater treatment system was limited to
the 459 Pleasant Street. Recovery well RW-1 was not significantly affecting the
groundwater at 480 Pleasant Street. A second recovery well located at 480 Pleasant
Street, as proposed, was confirmed to be needed to expedite the cleanup of the entire
site.
On December 2, 2003, we submitted a second Tier II Extension Request to the DEP in
accordance with 310 CMR 40.0560(7). The Tier II classification for the site was due to
expire on January 27, 2004. We requested that it be extended for another year. The
Request was not denied by the DEP within 45 days of receipt so it became effective.
On December 18, 2003, we collected water samples from the treatment system and
monitoring wells MW-10 and MW-12. The four groundwater samples were analyzed for
volatile petroleum hydrocarbons (VPHs) by the DEP method. At a flowrate of 3.0 gpm,
the influent concentrations were much lower than the previous September 22, 2003
results. Only the C9-C10 aromatics fraction was just above the applicable GW-3 cleanup
standard of 4,000 ug/l.
On February 27, 2004, three additional drums of recovered gasoline were transported
from the site by the Oil Recovery Corporation under a Uniform Straight Bill of Lading.
The approximately 150 gallons of gasoline was transported to the Vexor facility in
Medina, OH to be burnt as a fuel.
Between September 22 and December 18, 2003, a total of 149,507 gallons of
groundwater was treated through the biodiffuser. Based upon a 63% reduction of the
total VPH fractions in the influent between September 22 and December 18, 2003, the
groundwater treatment system had removed 8.60 lbs of gasoline-related compounds.
On March 18, 2004, we collected influent and effluent samples from the treatment
system along with groundwater from monitoring wells MW-8, MW-10, MW-12 and ECS-
5. The six groundwater samples were analyzed for VPHs by the DEP method. At a
flowrate of 2.1 gpm, the C5-C8 aliphatics and C9 – C12 aliphatics fractions in the influent
were above the applicable GW-3 cleanup standard of 1,000 ug/l. The gasoline
Page 16 PENNEY ENGINEERING, INC
contaminants in wells MW-10, MW-12, and ECS-5 were above the applicable cleanup
standards.
On March 23, 2004, we submitted our second Phase V Inspection and Monitoring
Report to the DEP. The report included copies of our monitoring logs, the associated
laboratory reports for that period, and the Bills of Lading to transport the recovered
gasoline.
On June 16, 2004, we collected influent and effluent samples from the treatment system
along with groundwater from monitoring wells MW-9, MW-10, MW-12 and ECS-5. The
six groundwater samples were analyzed for VPHs by the DEP method. At a flowrate of
2.4 gpm, all VPH fractions as well as benzene were above the applicable GW-3 cleanup
standards in the influent. The gasoline contaminants in all four wells were above the
applicable cleanup standards.
On June 16, 2004, we also applied for a new permit to store the recovered gasoline.
We were informed by Deputy Fire Chief Dwayne Nichols that the permits run on a
calendar year. Deputy Chief Nichols issued a new permit dated April 15, 2004.
On July 16, 2004, two drums of recovered gasoline were transported from the site by
the Oil Recovery Corporation under a Uniform Straight Bill of Lading. The
approximately 110 gallons of gasoline was transported to the Vexor facility in Medina,
OH to be burnt as a fuel.
On August 31, 2004, two additional drums of recovered gasoline were transported from
the site by the Oil Recovery Corporation under a Uniform Straight Bill of Lading. The
approximately 110 gallons of gasoline was transported to the Vexor facility in Medina,
OH to be burnt as a fuel.
On September 21, 2004, we submitted our third Phase V Inspection and Monitoring
Report to the DEP. The report included copies of our monitoring logs, the associated
laboratory reports for that period, and the Bills of Lading for transporting the recovered
gasoline.
On September 21, 2004, we collected influent and effluent samples from the treatment
system along with groundwater from monitoring wells MW-9, MW-10, MW-12 and ECS-
5. The six groundwater samples were analyzed for VPHs. All the VPH fractions were
above the applicable GW-3 cleanup standards in the influent. Noting was detected in
the effluent. At a flowrate of 0.6 gpm, the biodiffuser continued to remove at least
99.2% of the gasoline-contaminants except for naphthalene which was removed at
Page 17 PENNEY ENGINEERING, INC
98.8. The VPH fractions and ethylbenzene were detected in all four wells above the
applicable cleanup standards.
In September 2004, we also began planning to install the remainder of the treatment
systems at 480 Pleasant Street. We were prepared to excavate along both sides of
Pleasant Street to find the former product piping. On September 30, 2004, we send an
evaluation report and a cost estimate for the installation of the remainder of the
treatment systems to the owners of the affected properties. On October 5, 2004, the
affected property owners met to discuss our evaluation report and cost estimate. It was
decided that without a financial contribution from the Massachusetts Highway
Department, the owners would continue to evaluate the current treatment systems for
another year before incurring the costs to install the remainder of the systems at 480
Pleasant Street. We determined that the effect of the current groundwater system was
limited to the area between Recovery Well RW-1 and the Recharge Well. We had
determined that the recharged groundwater may be short-circuiting by flowing through
channels or the more permeable layer of medium to coarse sand beginning at a depth
of 14 feet. We considered pulsing the pump in Recovery Well RW-1 off and on to
reduce any short-circuiting. We also determined that the gasoline contamination is
being partially drawn back to the Recovery Well RW-1 from under the adjacent portion
of Pleasant Street and 480 Pleasant Street. Since September 19, 2003, we have no
longer observed any free-phase gasoline in any of the wells at the entire site. On
November 23, 2004, we began manually applying remedial additives to specific
monitoring wells located at 480 and 492 Pleasant Street.
On October 5, 2004, the affected property owners met to discuss our September 30,
2004 evaluation report and cost estimate to install the remainder of the treatment
systems across Pleasant Street. It was decided that without a financial contribution
from the Massachusetts Highway Department, the owners would continue to evaluate
the current treatment systems for another year before incurring the costs to install the
remainder of the systems at 480 Pleasant Street. W e have determined that the effect of
the current groundwater system may be limited to the area between Recovery Well RW-
1 and the Recharge Well; the adjacent section of Pleasant Street; and potentially the
western extent of the properties at 480 and 492 Pleasant Street. We determined that
the recharged groundwater may be short-circuiting by flowing through channels or the
more permeable layer of medium to coarse sand beginning at a depth of 14 feet. We
may begin pulsing the pump in Recovery Well RW-1 off and on to reduce short-
circuiting. We also determined that the gasoline contamination is being partially drawn
back to Recovery Well RW-1 from under the adjacent portion of Pleasant Street and
Page 18 PENNEY ENGINEERING, INC
potentially 480 Pleasant Street. On September 21, 2004, we detected a dramatic
increase of gasoline contaminants in monitoring well MW-9, which is located
immediately to the east of Recovery Well RW-1. Recovery Well RW-1 maintains a
drawdown of approximately one-foot, which is expected to greatly affect the
groundwater over a large area in the low permeability soil at the site. Since September
19, 2003, we no longer observe free-phase gasoline in any of the monitoring wells at
the entire site. On November 23, 2004, we began manually applying remedial additives
to specific monitoring wells located at 480 and 492 Pleasant Street. The effects of the
bioremediation shall not be apparent until the free-phase gasoline has been removed.
On November 19, 2004, three additional drums of recovered gasoline from the carbon
regeneration process were transported from the site by the Oil Recovery Corporation
under a Uniform Straight Bill of Lading. The approximately 150 gallons of gasoline was
eventually transported to the Vexor facility in Medina, OH to be burnt as a fuel. On
November 19, 2004, one, 2/3 full 55-gallon of sediment from cleaning the biodiffuser
was also removed by Oil Recovery as oily solids under a hazardous waste manifest.
The drum of sediment was removed to prevent it from freezing during the winter.
On November 23, 2004, we began to also manually apply remedial additives to specific
monitoring wells at 492 Pleasant Street.
On December 9, 2004, we collected groundwater samples of influent and effluent from
the treatment system along with monitoring wells MW-1, MW-9, MW-10, MW-12 and
ECS-5. The seven groundwater samples were analyzed for VPHs. Only the C5–C8
aliphatics fraction and benzene were above the applicable GW-3 cleanup standards in
the influent. Only relatively low concentrations were detected in the effluent. At a
flowrate of 1.6 gpm, the biodiffuser continued to remove at least 99.2% of the
contaminants. A gasoline sheen was observed in wells MW-1, MW-9, MW-10 and MW-
12. Wells MW-1, MW-9, MW-10, MW-12 and ECS-5 had an odor of gasoline. Only the
C5–C8 aliphatics and the C9–C10 aromatics fractions were detected above the applicable
GW-2 and GW-3 cleanup standards in all five wells. No target VOCs were detected
above the GW-2 or the GW-3 cleanup standards in any of the wells.
On December 9, 2004, we again manually applied remedial additives to monitoring
wells MW- 12 and ECS-5 located at 492 Pleasant Street. Five pounds of granular, 20-
20-20 microbe nutrients and ¼ lb of powdered Munox 10x Multiplier were dissolved in
the treated groundwater from the biodiffuser. One gallon of liquid surfactant was added
to each well, and then a small, battery-powdered pump was used to transfer
Page 19 PENNEY ENGINEERING, INC
approximately 27 gallons of the remedial additives solution into each well. Remedial
additives continued to be periodically applied to specific wells.
On December 10, 2004, we submitted a third Tier II Extension Request in order to
continue the remediation of the gasoline contamination the site. The existing
classification was scheduled to expire on January 27, 2005. On December 23, 2004,
the DEP issued a Tier II Extension Approval extending the Tier II classification until
December 4, 2005. The classification date was returned to the initial tier classification
date.
On March 24, 2005, we collected samples of the influent and effluent from the
groundwater treatment system along with groundwater from monitoring wells MW-1,
MW-2A, MW-9, MW-10, MW-12 and ECS-5. The seven groundwater samples were
analyzed for VPHs. We also inspected nine wells for gasoline and measured the
dissolved oxygen, pH and temperature in the influent, effluent, MW-1, MW-2A, MW-5,
MW-7, MW-8, MW-9, MW-10, MW-12, and ECS-5. A gasoline sheen was observed in
wells MW-1, MW-9, MW-10 and MW-12. Wells MW-1, MW-2A, MW-9, MW-10, and
MW-12 had an odor of gasoline. Only relatively low concentrations were detected in the
effluent. At a flowrate of 2.0 gpm, the biodiffuser continued to remove at least 98.3% of
the contaminants. A majority of the VPH fractions were above the applicable GW-2 and
GW-3 cleanup standards in four wells. Well ESC-5 had a high detection limit, which
was above some of the GW-2 cleanup standards. The results for MW-12, located at
492 Pleasant Street, had significantly increased due to the periodic addition of
surfactant beginning on December 9, 2004. The results for wells MW-1, MW-9 and
MW-10 were similar to the previous results. The bacteria counts in MW-12 and ESC-5
were very high due to the periodic addition of remedial additives. The high counts
indicated that enhanced bioremediation was occurring. Nitrate and nitrite were detected
at low concentrations in the influent and MW-10 as a result of our beginning to inject
microbe nutrients into the discharge water. Compared to the influent, the nitrate and
nitrite concentrations were very high in MW-12 and ESC-5 due to the addition of
remedial additives. On March 24 we also began to apply remedial additives to MW-2A,
MW-10, MW-12, and ECS-5.
On June 13, 2005, we collected samples of the influent and effluent from the
groundwater treatment system along with groundwater from monitoring wells MW-1,
MW-2A, MW-9, MW-10, MW-12 and ECS-5. Only six of the groundwater samples were
analyzed for VPHs by the DEP method. The samples from MW-12 and ECS-5 could
not be purged due to foaming caused by the surfactant that had been periodically
applied to those wells. We also inspected nine wells for gasoline and measured the
Page 20 PENNEY ENGINEERING, INC
dissolved oxygen, pH and temperature in the influent, effluent, MW-1, MW-2A, MW-5,
MW-7, MW-8, MW-9, MW-10, MW-12, and ECS-5. No gasoline sheen was observed in
any of the wells. Wells MW-1, MW-2A, MW-8, MW-9, and MW-10 had an odor of
gasoline. All the VPH fractions and target VOCs were below the applicable GW-3
cleanup standards in the influent. Only relatively low concentration of the C9 – C12
aliphatics was detected in the effluent. At a flowrate of 2.0 gpm, the biodiffuser
continued to remove at least 98.6% of the contaminants. The results for MW-1 had
decreased from the previous results. That well is clearly in the area being remediated
by the groundwater treatment system. The results for the other three wells were about
the same as the previous results. It was unfortunate that the samples from MW-12 and
ECS-5 could not be analyzed due to the foaming caused by the surfactant. The results
for the target VOCs were all below the applicable GW-2 and GW-3 cleanup standards in
all four wells
We shall continue to operate and monitor the current treatment systems. We shall
regenerate the vapor phase carbon as needed and store the recovered gasoline on-site
until we accumulate two or three drums for off-site reuse. As of March 3, 2004, a total
of 1,466,895 gallons of groundwater had been treated and 622.80 gallons of gasoline
had been recovered. We shall continue to evaluate the cost-benefit of installing the
remainder of the treatment systems at 480 Pleasant Street. Based upon the current
results, the SVE system has been very effective at removing a majority of the free-
phase gasoline from both sides of Pleasant Street. Since April 25, 2002, we routinely
observed free-phase gasoline in wells MW-1, MW-9, MW-10, MW-12 and ECS-5. On
September 19, 2003, we observed four-inches of free-phase gasoline in well MW-12
located at 492 Pleasant Street. On June 16, 2004, we have only observed a sheen in
wells MW-9, 10, and 12. On September 21, 2004, we only observed a sheen in wells
MW-9, 10, 12 and ECS-5. On December 9, 2004, we only observed a sheen in wells
MW-1, 9, 10, 12 and ECS-5. A third SVE zone located along the 492 and 480 side of
Pleasant Street would allow any remaining free-phase gasoline to be vented from the
pore spaces of the soil from under and across Pleasant Street. The effects of the
bioremediation shall not be apparent until the free-phase gasoline has been removed.
The effect of the current groundwater system may be limited to the area between
Recovery Well RW-1 and the Recharge Well. The results may also indicate that the
gasoline contamination is being partially drawn back to the Recovery Well RW-1 from
under and across Pleasant Street.
The treatment systems shall continue to be operated, maintained and monitored in
accordance with the Response Action Performance Standards. The systems shall be
Page 21 PENNEY ENGINEERING, INC
operated for the next few years until the requirements of a Class A Response Action
Outcome Statement are achieved and the site can be closed. We shall submit a fourth
Tier II Extension Request or a Remedy Operations Status Submittal before the October
20, 2005 submission deadline. Representative soil samples shall be analyzed before
closing the site. We may also conduct a subsurface investigation to determine if there
are any abandoned tanks at the site.
Pleasant Journey Used Cars, Inc has assumed responsibility for installing and operating
the treatment systems in accordance with MGL c. 21E and the Massachusetts
Contingency Plan. The name, address and telephone number of the contact person is:
Mr. Robert P. Kalish, President
PLEASANT JOURNEY USED CARS, INC
459 Pleasant Street
Northampton, MA 01060
(413) 774-6559
The first four sections of this Phase V Report summarize our previous findings. Section
5.0 describes the construction of the groundwater and soil treatment systems. Section
6.0 describes the operation, maintenance and monitoring of the treatment systems.
Section 7.0 describes the public notification process. A Locus Map; fifteen tables of
results; five figures showing the groundwater contours and the extent of the
contamination; four charts showing the gasoline recovered during regeneration of the
carbon; and three charts showing the historical results for the influent, MW-9 and MW-
10 are included in the Figures section. A full-size as-built Remedial Action Site Plan is
included in the rear pocket. Appendix A includes a completed Comprehensive
Response Action Transmittal Form (BWSC-108), an April 19, 2005 letter to MHD and a
May 10, 2005 response letter from MHD. Appendix B includes copies of our monitoring
logs that have been completed from February 5, 2005 to August 22, 2005. Appendix C
includes copies of the laboratory analysis reports for the groundwater samples collected
on March 24, 2005 and June 13, 2005.
1.1 Description of the Site
The site is located at 459, 480 and 492 Pleasant Street in Northampton, MA as shown
on the Locus Map. The site has historically been used as a gasoline service station
from 1912 until 1984. The immediate area is relatively flat. There are commercial
businesses along Conz and Pleasant Streets. There are homes along Pleasant Street
to the north of the site. Pleasant Street is a four-lane highway and part of State Route
Page 22 PENNEY ENGINEERING, INC
5. It is the main route leading into the center of Northampton from the south. As shown
on the Locus Map, there is an active railroad line located along the rear of 480 and 492
Pleasant Street. Reportedly, coal and petroleum products were transported by train and
stored at surrounding properties along Pleasant Street. The Mill River flows from the
area of the site into the Connecticut River located approximately one mile southeast of
the site, as shown on the Locus Map.
According to a May 17, 2002 BWSC Site Scoring Map, the site is not located within an
Interim Wellhead Protection Area, a Zone II or a mapped Potentially Productive Aquifer.
Reportedly, there are no private water supply wells located within 500 feet of the site.
Municipal drinking water is available along Pleasant Street. The depth to groundwater
at the site ranges from eight to 11 feet. There are no occupied residences located
within 30 feet of the site. There are offices and commercial buildings that are occupied
daily, within 30 feet of portions of the site. The groundwater at the site is classified as
GW-2 and GW-3, depending upon its proximity to the occupied offices and commercial
buildings. According to previous reports, the groundwater was classified as GW-1. We
shall continue to classify the groundwater at the site as GW-2 and GW-3 until
information to the contrary becomes available.
2.0 SITE HISTORY
2.1 History of Use at the Site
A title search for the site was not conducted. Based upon the prior reports and the
October 22, 2001 Warranty Deed for 459 Pleasant Street, a list of the prior owners of
459 Pleasant Street is presented in Table One. The deeds have been recorded at the
Hampshire County Registry of Deeds.
TABLE ONE
History of Ownership
459 Pleasant Street
Date of Purchase Owner Book and Page
Number
Ralph T. Staab & Gretchen S. Belz
April 26, 1965 Carlton H. Staab 1461/66
1983 Robert P. Kalish
May 28, 1986 Robert P. Kalish & John Guillot 2730/231
October 22, 2001 Robert P. Kalish
Page 23 PENNEY ENGINEERING, INC
The site was commonly known as Staab’s Gasoline Station from 1912 until 1983 when
the property at 459 Pleasant Street was purchased by Mr. Kalish to be used for selling
used automobiles. The properties at 480 and 492 Pleasant Street were also sold to
others. Reportedly, the properties at 480 and 492 Pleasant Streets are currently owned
by Quickbeam Realty Trust.
2.2 Current Use of the Site
According to the March, 1999 Phase II Report by ECS, the area of the site is zoned for
General Business. There are a number of businesses along Pleasant Street. The
properties within the site are occupied by Pleasant Journey Used Cars, Pro Lube, a car
wash, and an office building. Reportedly, there are no longer any underground gasoline
storage tanks at the site. Automobiles are still serviced in the two-bay garage at
Pleasant Journey and at Pro Lube. Sewer, water, and natural gas are available along
Pleasant Street.
3.0 NATURE AND EXTENT OF CONTAMINATION
3.1 Previous Assessment Activities
In 1988, a wellpoint was installed at 492 Pleasant Street to evaluate installing an on-site
water supply well. Gasoline was detected in the groundwater pumped from the
wellpoint. On October 23, 1989, the DEP was first notified of the gasoline release at
459 Pleasant Street based upon the findings in an August 30, 1989 report by the former
Certified Engineering and Testing Company of Weymouth, MA. Site number 1-0705
was assigned and it later became the Release Tracking Number for the site.
Numerous investigations and limited remedial measures were conducted at the site. On
November 30, 1989, Certified submitted a Phase I Limited Site Investigation Report for
the site. On November 8, 1993, an Interim Phase I Report was prepared by Cold
Spring Environmental, Inc of Belchertown, MA. In December 1996, a Phase I
Completion Report and Tier Classification for the site were submitted by Cold Spring.
Previous reports had also been submitted for 492 Pleasant Street.
On December 8, 1998, a Method Three Risk Characterization for the site was prepared
by O’Reilly, Talbot & Okun Associates, Inc of Springfield. It had determined that there
was no significant risk associated with the remaining contamination at the site. On
March 26, 1999, a Phase II Report and a Phase III Plan were submitted to the DEP by
Environmental Compliance Services (ECS), Inc of Agawam. ECS had conducted a
Page 24 PENNEY ENGINEERING, INC
Phase II Comprehensive Site Assessment at the site to determine the nature and the
extent of the soil and groundwater contamination in order to evaluate risk. In 1997, they
advanced 25 additional soil borings and installed five additional monitoring wells. The
location of all the borings and wells are shown on the four figures and the Remedial
Action Site Plan. The names of the wells have changed over the years. During the
advancement of the borings, ECS conducted headspace screening of the split-spoon
soil samples with an HNu Model 101 photoionizing detector setup with a 10.2 eV lamp
and calibrated to read as benzene. The Model 101 is known to have produced false
readings for wet soil samples. The readings were recorded on their boring logs. Based
upon the headspace results, the soil contamination extended from the office at Pleasant
Journey to the rear of the office building at 492 Pleasant Street. Based upon the
headspace results, only one soil sample from the 18 soil borings advanced on June 25,
1997 was analyzed for aromatic volatile organic compounds by EPA Method 8020. The
single sample was collected from a depth of 12 to 13 feet from boring SB-4 located
adjacent to the northeastern corner of the former dispenser pad at 459 Pleasant Street.
Two other soil samples were reportedly analyzed for “hazardous waste treatability”, but
no results or laboratory reports were reported. The results for the one soil sample
analyzed listed benzene at 43.5 mg/kg, toluene at 363.5 mg/kg, ethylbenzene at 116.5
mg/kg, xylenes at 555.0 mg/kg and methyl tert-butyl ether (MTBE) at 5.8 mg/kg. We
assumed that the most contaminated soil sample was analyzed. Clearly the results
were above the Method One S-1/GW-3 cleanup standards, but we do not understand
why only one soil sample was analyzed or why the results were expressed by mg/kg in
the laboratory report.
On April 2, 1998, ECS collected groundwater samples from 19 wells at the site.
Specific samples were analyzed for volatile aromatic compounds by EPA Method 602, a
method for analyzing drinking water, volatile petroleum hydrocarbons (VPHs), and
extractable petroleum hydrocarbons (EPHs) with target polynuclear aromatic
hydrocarbons (PAHs) by the new DEP method. On July 9, 1998 two groundwater
samples were collected from the Shell Station at 506 Pleasant Street along with another
sample from 492 Pleasant Street. Reportedly, the samples were collected with
dedicated stainless steel bailers, which are very expensive. On July 9, 1998, additional
groundwater samples were collected from the restaurant property at 491 Pleasant
Street with a geoprobe. All the previous and 1998 groundwater sampling results were
listed in three large tables. The VPH results for specific wells and the GW-2 and GW-3
cleanup standards are listed in Table Two included in the Figures section. As shown in
bold, the results for a number of the wells exceeded the GW-2 and GW-3 cleanup
standards. We have determined the applicable cleanup standard based upon the
Page 25 PENNEY ENGINEERING, INC
location of the well and proximity of an occupied office or commercial building. Only
wells MW-1, MW-5, MW-6, ECS-2 and ECS-5 were located within 30 feet of an
occupied office or commercial building and therefore the GW-2 cleanup standard was
applicable. The significant contamination extended from 459 Pleasant Street to MW-12
across Pleasant Street. ECS did not report any free-phase gasoline in any of the wells
they sampled. ECS stated that no significant risk was identified at the site in 1998. The
application of oxygen-releasing compounds and an Activity and Use Limitation were
recommended as a permanent solution. On June 8, 2000, free-phase gasoline was
again discovered in wells MW-9 and VM-1 at thicknesses of 0.69 and 0.14 feet,
respectively. Clearly the presence of free-phase gasoline presented a significant risk.
On June 8, August 2, October 11, 2000 and April 4 and April 18, 2001, Acadian
measured the depths to groundwater and determined the elevation of the groundwater
at specific wells. The results were reported in their June 22, 2001 IRA Status Report.
We have plotted the groundwater contours based upon the fall, October 11, 2000
Acadian results on Figure One. As shown, the local groundwater flow direction is to the
east, toward the Mill River which flows into the Connecticut River. We have also plotted
the groundwater contours based upon our spring, April 25, 2002 results on Figure Two.
As shown, our results also suggest that the local groundwater flow direction is to the
east. ECS had also reported the flow to the east. The direction of the local
groundwater flow is dependent upon the stage of the Connecticut River.
3.2 Additional Assessment Activities
On March 12, 2002, Mr. Ralph Penney from Penney Engineering met with Mr. Kalish to
inspect the site. A few of the wells at 459 Pleasant Street were gauged and inspected.
Five inches of free-phase gasoline was measured in a bailer from MW-9. It was
apparent that remedial response measures were warranted.
On April 25, 2002, we attempted to locate all the monitoring wells at the site. We were
able to inspect and gauge 19 wells. The wells were gauged for depth to water and for
the presence of free-phase gasoline with a Solinst interface probe. Free-phase
gasoline was measured with the probe and confirmed with a bailer in wells MW-9 and
MW-12. Distinct petroleum sheens and/or strong petroleum odors were observed in the
groundwater samples from wells MW-1, 4, 5, 6, 8, 10, 2A, 4CW, ECS-1, and ECS-5.
We collected 13 groundwater samples from wells MW-1, 3, 4, 5, 6, 7, 8, 9, 2A, 8, 12,
ECS-1 and ECS-5 in order to determine the extent of the dissolved gasoline
contamination in the groundwater. A sample was also collected from well Bridal 447 as
requested by Mr. Scherer. The locations of the wells are shown on Figures Three and
Page 26 PENNEY ENGINEERING, INC
Four. Samples could not be collected from MW-2, MW -10 and VM-1. Ten of the
groundwater samples were collected according to DEP procedures and transported to
RI Analytical, Inc of Warwick, RI under chain-of-custody protocol for analysis. The
samples from MW-9 and MW-12 were not analyzed because they contained free-phase
gasoline. The sample from MW-4 was not analyzed because it was located in close
proximity to MW-5, 7 and 9. The 10 samples were analyzed for VPHs by the DEP
method. The results for the compounds detected are summarized and compared to the
applicable GW-2 or GW-3 cleanup standards in Table Three. Table Three also lists the
cumulative total of the concentrations for benzene, toluene, ethylbenzene and xylenes
as total BTEX.
As shown in Table Three, our results were very similar to the 1998 ECS results
presented in Table Two. As shown in bold, a number of gasoline-related contaminants
were detected above the GW-2 and GW-3 cleanup standards. The detection limits on
the most contaminated samples were high because of the relatively high concentrations
of dissolved gasoline-related contaminants in the samples.
We attempted to determine the extent of the dissolved gasoline contaminants by
plotting the results on Figures Three and Four. The iso-contours of the BTEX
compounds are plotted on Figure Three. The iso-contours for the C5-C8 aliphatics
fraction are plotted on Figure Four. We also attempted to show the extent of the free-
phase gasoline based upon our April 25, 2002 gauging and previous reports of free-
phase gasoline as NAPL on both figures. The former dispenser area at 459 Pleasant
Street has been reported as the most likely source of the gasoline release. Both figures
show that the dissolved gasoline contaminants in the groundwater generally coincide
with the estimated extent of free-phase gasoline as it migrates to the east with the local
groundwater flow.
We did not collect any soil samples at the site. Only limited soil boring samples have
been analyzed during previous assessments. Gasoline contaminants were detected in
soil boring samples collected at or above the groundwater table. No soil samples were
collected from beneath Pleasant Street due to access restrictions. No test pitting has
been conducted at the site. We have assumed that the extent of significant soil
contamination is limited to the area of the free-phase gasoline, as shown on Figure
Three.
On April 25, 2002 we also conducted limited indoor air screening with an organic vapor
meter setup with a 10.6 eV lamp and calibrated with an isobutylene standard to read “as
benzene”. We were allowed to conduct screening in the office and the garage at
Page 27 PENNEY ENGINEERING, INC
Pleasant Journey; the office and garage areas at Pro Lube; the car wash; the Sheriff’s
Department office; the Community Corrections office; the Community Development
office and the pet store. We were not allowed to screen the 591 Food Stop restaurant.
None of the buildings had basements. No significant readings were recorded. The
highest reading of 3.1 ppm was recorded in the pet store.
3.3 Extent of Free-Phase Gasoline
Our initial estimated extent of the free-phase gasoline is shown as NAPL on Figures
Three and Four. Our estimate was based upon previous reports of free-phase gasoline
in specific wells and our April 25, 2002 observation of free-phase gasoline in wells MW-
9 and MW-12. The presence of free-phase gasoline is associated with the height of the
groundwater table. We assumed that it extended under Pleasant Street.
3.4 Extent of Soil Contamination
We assumed that the initial extent of the gasoline contamination in the soil paralleled
the extent of the free-phase gasoline shown on Figures Three and Four. Reportedly,
contaminated soil was removed in 1984 when the underground storage tanks were
removed from 459 and 480 Pleasant Street. No contaminated soil has been removed
from the former dispenser area at 459 Pleasant Street. As previously stated in Section
3.1, only one soil sample collected from a depth of 12 to 13 feet below the former
dispenser pad at 459 Pleasant Street was analyzed over 14 years of investigating the
site. The soil sample collected from below the groundwater table contained benzene at
43.5 mg/kg. Clearly, the soil contamination had not been adequately assessed.
3.5 Extent of Groundwater Contamination
The initial extent of the dissolved gasoline contamination in the groundwater is shown
on Figures Three and Four as the 10,000 and the 2,000 iso-contours. Again, our
estimated extent was similar to what had previously been reported by other consultants.
4.0 SUMMARY OF SITE CONDITIONS THAT WARRANTED REMEDIAL
ACTIONS
A Method One risk characterization presented in our Phase III/IV Plan determined that
the groundwater exposure point concentrations at the site were above the applicable
Method One GW-2 and GW-3 cleanup standards. Therefore, remedial actions were
warranted at the site to reduce the risk of harm to human health, public welfare or the
Page 28 PENNEY ENGINEERING, INC
environment. Additional sampling and investigations were required to determine if the
soil contamination presented a risk.
5.0 CONSTRUCTION OF SELECTED REMEDIAL ACTION ALTERNATIVE
From April 25 until May 29, 2003, we monitored the relatively high elevation of the
groundwater at the site due to a large snowmelt. Once the elevation returned to normal
at the end of May, we scheduled the installation of the treatment systems. On June 2,
3, 4, 5 and 6, 2003, we directed Grant Brothers Associates of Mansfield to excavate and
install the recharge well; Recovery Well RW-1; SVE Zones A and B; and all the
associated piping at 459 Pleasant Street, as shown on the Remedial Action Site Plan.
An Inspector’s Daily Record of Work Progress was completed for each day of the
installation. Copies of the records for that period were included in our first Phase V
Report. We also constructed the concrete pad for the treatment trailer; removed the
existing pavement and former dispenser pad; placed the trailer and the regenerative
carbon vessel on the pad; and supplied seven truckloads of crushed stone and clean
gravel. The driver of the concrete truck from Bill Willard, Inc said that he had worked at
the former Staab’s Service Station as a teenager. He remembered seeing used
crankcase oil routinely being drained into a pit in the ground at the former Lubritorium
that was previously located at 459 Pleasant Street. Approximately 100 cubic yards of
overtly contaminated soil was stockpiled on-site. We did not encounter the former
product pipes reportedly leading across Pleasant Street so we were unable to install the
portions of the systems at 480 Pleasant Street. The excavation operator later reported
seeing what could have been the product piping while digging near the southern curb
cut on June 6th. The revised location of the product piping is shown on the Remedial
Action Site Plan.
On June 11, 12 and 13, 2003, we completed the setup of the treatment trailer and
tested the equipment. The Building Inspector conducted his final inspection. We wired
the dialer from the control panel to an existing telephone line in the office. We posted
our emergency numbers on the outside of the treatment trailer.
On June 5, 2003, we had collected one composite soil sample from the stockpiled soil
for waste profile analysis. The 860 mg/kg of VOCs was slightly above the acceptance
criteria of 500 mg/kg, as shown in Table Two. The 120°F flashpoint of the soil also
slightly exceeded the acceptance criteria of greater than 140°F. On June 20, 2003, we
submitted a preliminary Bill of Lading form with three attachments to the Ted Ondrick
Page 29 PENNEY ENGINEERING, INC
Company, LLC of Chicopee as a request to recycle the approximately 100 cubic yards
of gasoline-contaminated soil.
On June 25, 2003, a representative from Ondrick called and requested three more
samples from the stockpile be analyzed because the total VOCs and the flashpoint
exceeded their acceptance criteria. Later that day we collected three additional
composite soil samples from specific sections of the stockpile and had them analyzed
for VOCs and flashpoint.
On July 7, 2003, the Northampton Fire Department inspected the storage drum and
signed the June 3, 2003 permit to store recovered gasoline. A copy of the permit was
included in our first Phase V Report.
On July 14, 2003, we sent the additional soil results to Ondrick. The VOC results for the
three samples were 677, 2.9 and 7.8 mg/kg. The average was 229 mg/kg, which was
below the acceptance criteria of 500 mg/kg. The average value was more
representative of the stockpiled soil in accordance with the April 5, 1995 QA/QC
memorandum from the DEP. The flashpoint for all three samples was greater than
165ºF, which was acceptable. On July 16, 2003, Mr. Paul Mullen from Ondrick called to
say that they would pass on recycling the stockpiled soil as recommended by Mr. David
Slowick at the DEP. Reportedly, Mr. Slowick questioned the validity of our additional
soil sampling results. We immediately spoke with Mr. Scherer who agreed to review all
the results. Later that day we sent the following documents to Mr. Scherer:
Our June 20, 2003 letter to Mr. Paul Mullen at the Ondrick with a preliminary Bill of
Lading, requesting acceptance of approximately 100 cubic yards of gasoline-
contaminated soil;
The July 3, 2003 laboratory report for the three additional soil samples we collected
from the stockpiled soil on June 25, 2003; and
Our July 14, 2003 letter to Mr. Mullen with two summary tables of our additional
sampling results.
In the cover letter to Mr. Scherer, we explained that we excavated the gasoline-
contaminated soil while installing the treatment systems at 459 Pleasant Street. The
soil that we excavated from the area of the former tanks and under the dispenser island
during the second day was highly contaminated. The subsequent soil we excavated
over the subsequent three days was much less contaminated, as indicated by the June
25, 2003 results. Sample Stockpile-2 was collected from the first soil stockpiled.
Page 30 PENNEY ENGINEERING, INC
Mr. Mullen was reluctant to accept the soil for recycling at his facility because of the two
relatively low results for VOCs. As the LSP-of-Record for the site, it was Mr. Ralph
Penney’s opinion that the results accurately represented the soil excavated and
stockpiled at the site. We asked Mr. Scherer to discuss the results with Mr. David
Slowick in Emergency Response and to advise Mr. Mullen if the soil could be accepted
for recycling.
We began to evaluate other recycling facilities, but we found that all had the same 500
mg/kg total VOCs limit in their permits. After numerous discussions, Mr. Scherer
offered to sample the soil himself on or about July 22, 2003. Mr. Kalish agreed to pay
for the additional analysis. On July 31, 2003, Mr. Scherer called us to say he had
gotten similar results of 1,000 and 700 mg/kg VOCs. He suggested that we modify our
Phase IV Plan to grade the stockpiled soil on-site, cover it with bituminous concrete and
allow it to be vented by the SVE system. For the next three weeks we attempted to
schedule a local contractor to grade the stockpiled soil and a paving contractor to
immediately cover it with bituminous concrete. On August 27, 2003, we sent a letter to
Mr. Scherer modifying our Phase IV Plan as he suggested and informing him that the
grading and paving was tentatively scheduled for September 4 and 5, 2003. Rain
eventually delayed the work until the following week.
On September 8, 2003, we called the Northampton Board of Health and the Mayor’s
offices. We informed them that we would be grading the stockpiled soil on September
9th.
On September 9, 2003, we directed the grading of the stockpiled soil. The soil was
graded by Grant Brothers over the approximately 6,000 SF area that had been
disturbed during the installation of the treatment systems. The grade in the lowest spots
was raised approximately five inches. We raised the covers on Recovery Well RW-1
and monitoring wells MW-1, MW-5, MW-6, MW-9 and MW-10 to match the new grade
plus three inches of bituminous concrete. The stockpiled soil was still very wet. We
had anticipated that the wet silty soil would be unstable so we applied 500 lbs of
calcium chloride to help stabilize it and to keep the dust down. The graded soil was
compacted with a dynapact. One area in front of the garage remained wet.
Fortunately, the paving could not be conducted until September 11, so the area was
allowed to dry for one day. The raised wells were surveyed along with the eastern
corners of the buildings, the curb cuts from Pleasant Street, and where we had
extended the piping for Recovery Well RW-2 and SVE Zone C. New concrete caps
were poured around wells MW-1, MW-5, MW-6, MW-7, MW-9 and MW-10. We also
Page 31 PENNEY ENGINEERING, INC
activated the SVE system and began monitoring it. The SVE system was setup to draw
from Zones A and B. The site was secured with caution tape.
On September 11, 2003, the graded soil was covered with three inches of bituminous
concrete by ACME Site Work, Inc of Indian Orchard. Mr. Kalish was on-site to direct the
work.
5.1 As-Built Construction Report
Our September 2003 Final Inspection Report, Phase IV Completion Statement and
Phase V Inspection and Monitoring Report included an As-Built Construction Report.
5.2 Final Inspection Report
Our September 2003 Final Inspection Report, Phase IV Completion Statement and
Phase V Inspection and Monitoring Report included a Final Inspection Report.
5.3 Phase IV Completion Statement
Our September 2003 Final Inspection Report, Phase IV Completion Statement and
Phase V Inspection and Monitoring Report included a Phase IV Completion Statement.
6.0 OPERATION, MAINTENANCE AND MONITORING OF THE
TREATMENT SYSTEMS
At 10:20 AM on June 25, 2003, we started the groundwater treatment system. The
groundwater began being pumped at 5.0 gpm from the large diameter Recovery Well
RW-1 installed where the former dispenser pad had been located. The groundwater
was treated through a reconditioned, Model #BD-5-E8 biodiffuser that was designed
and manufactured by Penney Engineering. The biodiffuser has a built-in oil/water
separator as the first stage followed by seven air stripping stages and a clearwell
chamber. Approximately 92 gallons of treated groundwater is periodically pumped from
the clearwell at approximately 35 gpm into the large diameter Recharge Well installed
where the former tanks were located.
At 5:30 PM, we began collecting water samples from the treatment system and three
groundwater monitoring wells. The five groundwater samples were analyzed for VPHs
by the DEP methods. The system had treated approximately 2,780 gallons of
groundwater before we collected the samples. A summary of the influent and the
effluent results for the compounds detected are shown in Table Four along with the
Page 32 PENNEY ENGINEERING, INC
removal rates and the applicable GW-3 cleanup standards. The results for the
compounds detected in the three wells are summarized and compared to the GW-2 and
GW-3 cleanup standards in Table Five. The applicable cleanup standard depends upon
the location of each well. The groundwater from any well located within 30 feet of an
occupied building is classified as GW-2. The groundwater from any other well is
classified as GW-3. The applicable standards are listed in Table Five. A copy of the
laboratory analysis report was previously submitted to the DEP.
TABLE FOUR
Removal Rates
June 25, 2003
(Flowrate: 5.0 gpm)
Parameters
Influent
Effluent
Percent
Removal
Cleanup
Standards
GW-3
VPH (mg/l)
C5 – C8 aliphatics 20,000 380 98.1 4,000
C9 – C12 aliphatics 4,400 140 96.8 20,000
C9 – C10 aromatics 11,000 310 97.2 4,000
Target VOCs (mg/l)
MTBE < 250 6 UK 50,000
Benzene 11,000 120 98.9 7,000
Toluene 29,000 330 98.9 50,000
Ethylbenzene 3,000 29 99.0 4,000
Xylenes 16,100 204 98.7 50,000
Naphthalene 550 160 70.9 6,000
UK - Unknown
As shown in Table Four, the influent concentrations were relatively high, which resulted
in a very high detection limit for MTBE. Due to the age of the release, MTBE was either
not in the released gasoline or has long since migrated away. As shown in bold, the C5-
C8 aliphatics, the C9-C10 aromatics and benzene were above the GW-3 cleanup
standards. As shown, the removal rates were all above 96.8 percent except for
naphthalene, which does not air strip very well.
Page 33 PENNEY ENGINEERING, INC
TABLE FIVE
Summary of Groundwater Results
June 25, 2003
Cleanup Standards
Parameters MW-5 MW-9 MW-10 GW-2 GW-3
(Applicable Standards) (GW-2) (GW-3) (GW-3)
VPHs (mg/l)
C5–C8 aliphatics 140 36,000 20,000 1,000 4,000
C9–C12 aliphatics <40 28,000 4,200 1,000 20,000
C9–C10 aromatics 270 92,000 18,000 5,000 4,000
Target VOCs (mg/l)
MTBE <10 <1,000 <500 50,000 50,000
Benzene 18 20,000 10,000 2,000 7,000
Toluene 38 63,000 31,000 6,000 50,000
Ethylbenzene 34 4,900 3,700 30,000 4,000
Xylenes 174 31,000 21,000 6,000 50,000
Naphthalene 23 6,100 670 6,000 6,000
As shown in bold in Table Five, many of the results for wells MW-9 and MW-10
exceeded the applicable GW-3 cleanup standards. Wells MW-9 and MW-10 had
previously contained free-phase gasoline. During our June 25, 2003 sampling, no free-
phase gasoline was observed in the three wells sampled. The results from wells MW-9
and MW-10 represented the highest concentrations of dissolved gasoline contaminants
in the area of the release.
Since being activated, the groundwater treatment system was operated and maintained
by Penney Engineering with help from the mechanics at Pleasant Journey. The
mechanics and Mr. Kalish have been trained to safely bail any recovered gasoline from
Recovery Well RW-1 on a weekly basis. Any gasoline that accumulated in RW-1 was
manually removed with a newly designed, Kalish skimmer. We have measured the
explosion potential in Recovery Well several times and found it to be well below the
lower explosive limit (LEL) for gasoline. On June 25, 20003, the LEL/oxygen
percentages were 8%/20.6% at the top of RW-1 and 2%/10.5% just above the
groundwater. The systems were inspected almost daily. We monitored them almost
every two weeks. We routinely screened the off-gas from the biodiffuser with an OVM
and recorded the results on a monitoring log. During each inspection, the operating
parameters of the systems are recorded on monitoring logs. Copies of the monitoring
logs from June 13 to March 4, 2004 were previously submitted to the DEP in our first
Phase V Report.
Page 34 PENNEY ENGINEERING, INC
All the piping was installed underground. The site is occupied during the day by the
employees of Pleasant Journey. A notice has been posted on the exterior wall of the
fenced area to alert anyone to contact Pleasant Journey or Penney Engineering if there
are any problems. The biodiffuser is supplied with a high-level shutoff switch wired to
an alarm and an exterior strobe light on the trailer and a dialer to call Pleasant Journey,
Mr. Kalish and Penney Engineering. The moisture separator for the SVE system is
wired similarly.
On September 8, 2003, we called the Northampton Board of Health and notified them
that we would be periodically monitoring the treatment system and sampling monitoring
wells. They were told that we may be wearing white suits and respirators.
During September, the groundwater treatment system and the SVE system operated
continuously except for brief shutdowns for maintenance, repairs and regeneration of
the vapor phase carbon. They were inspected on September 4, 5, 8, 9, 10, 12, 17, 21,
22, 24, 25, 26, 29, and 30 as listed on the corresponding monitoring logs. It operated at
0.7 to 1.2 gpm due to summertime, low groundwater conditions. We had determined
that the groundwater depth in RW-1 should not exceed 11.25 feet in order to prevent
the submersible pump from shutting down. Due to the high amount of silt in the
groundwater, the submersible pump had difficulty restarting. We had removed the filter
fabric around the leaching pit used to construct Recovery Well RW-1 because it had
immediately clogged with silt causing the leaching pit to float on the groundwater. On
September 9, 2003, we activated the SVE system before all the free-phase gasoline
was removed in order to begin venting the contaminated soil that had been graded at
the site. We continued to monitor the off-gases from the biodiffuser and began
monitoring the contaminated air from the SVE system. That continued until the inlet
concentrations stabilized and the breakthrough period for the vapor phase carbon was
established. The nearest residence was measured to be located approximately 190
feet to the north of the discharge stack. The air from the biodiffuser was initially 49.7
and 56.2 ppm, but quickly dropped and remained below 2.0 ppm. The influent from the
SVE system, screened at sampling port AS-2, was initially 121.0 ppm. On September
17, 2003, an additional gallon of gasoline was recovered from RW-1 by manually
skimming.
On September 17, 2003, we screened the influent from the SVE system and found that
it had decreased to 89.0 ppm. We screened all the air sampling ports and found that
the carbon vessel needed to be regenerated. On September 22, 2003, we conducted
the first steam regeneration of the carbon vessel and recovered 7.5 gallons of gasoline.
We also generated 75 gallons of contaminated condensate. The gasoline was stored in
Page 35 PENNEY ENGINEERING, INC
the same drum used to store the gasoline skimmed from RW-1. The condensate was
stored in two, 55-gallon drums. It was allowed to cool and pumped into the biodiffuser
to be treated.
On September 22, 2003, during the regeneration of the carbon, we collected
groundwater samples from the groundwater treatment system and monitoring wells
MW-9 and MW-10 according to DEP procedures. We also gauged and inspected a
total of eight wells at the site. Four inches of free-phase gasoline was observed floating
on the groundwater in well MW-12, located at 480 Pleasant Street. The locations of the
wells are shown on the Remedial Action Site Plan. The four groundwater samples were
transported to Groundwater Analytical under chain-of-custody protocol and analyzed for
VPHs by the DEP method. A summary of the influent and the effluent results are shown
in Table Six along with the removal rates and the applicable GW-3 cleanup standards.
The results for the compounds detected in the two wells are summarized and compared
to the applicable GW-3 cleanup standards in Table Seven. A copy of the laboratory
analysis report was previously submitted to the DEP.
TABLE SIX
REMOVAL RATES
September 22, 2003
(Flowrate: 1.0 gpm)
Parameters
Influent
Effluent
Percent
Removal
Cleanup
Standards
GW-3
VPH (mg/l)
C5 – C8 aliphatics 5,300 41 99.2 4,000
C9 – C12 aliphatics 5,400 <20 99.8 20,000
C9 – C10 aromatics 7,200 34 99.5 4,000
Target VOCs (mg/l)
MTBE < 250 <5 UK 50,000
Benzene 2,300 <1 99.9 7,000
Toluene 7,500 <5 99.9 50,000
Ethylbenzene 1,200 <5 99.7 4,000
Xylenes 6,700 <5 99.9 50,000
Naphthalene 450 <5 99.4 6,000
UK – Unknown
As shown in Table Six, the influent concentrations had been reduced by approximately
50% from the June 25, 2003 results. Only the C5-C8 aliphatics and the C9-C10 aromatics
were above the applicable GW-3 cleanup standards. Benzene had been reduced below
its cleanup standard. The removal rates were all above 99.2 percent, even for
Page 36 PENNEY ENGINEERING, INC
naphthalene which is difficult to air strip. As of September 30, 2003, a total of 204,300
gallons of contaminated groundwater had been treated.
TABLE SEVEN
Summary of Groundwater Results
September 22, 2003
Parameters MW-9 MW-10 Cleanup Standards
GW-3
VPHs (mg/l)
C5–C8 aliphatics 25,000 18,000 4,000
C9–C12 aliphatics 16,000 16,000 20,000
C9–C10 aromatics 17,000 18,000 4,000
Target VOCs (mg/l)
MTBE < 1,250 < 1,250 50,000
Benzene 21,000 10,000 7,000
Toluene 48,000 27,000 50,000
Ethylbenzene 3,600 3,100 4,000
Xylenes 20,300 14,300 50,000
Naphthalene 1,300 <1,250 6,000
As shown in Table Seven, the results for wells MW-9 and MW-10 were again extremely
high, but lower than the June 25, 2003 results. Wells MW-9 and MW-10 had previously
contained free-phase gasoline. The free-phase gasoline observed in well MW-12
during the gauging confirmed that the groundwater treatment system and SVE system
needed to be extended across Pleasant Street.
On September 29, 2003, the SVE system was temporarily shutdown because the
carbon vessel had broken through. On October 1, 2003, the carbon was again
regenerated and 14.75 gallons of gasoline was recovered. The SVE system was
restarted after the regen.
The systems continued to operate continuously during the month of October except for
brief shutdowns for maintenance, repairs and regeneration of the vapor phase carbon.
They were inspected on October 1, 2, 5, 6, 7, 14, 15, 16, 17, 20, 24, 30 and 31. The
groundwater flowrate averaged 1.4 gpm. As of October 31, 2003, 265,220 gallons of
groundwater had been treated. No additional gasoline accumulated in RW-1, probably
because it was being vented by the SVE system. The influent screening results from
the SVE system decreased to 85.5. It had been screened on October 7, 14, 20, 24, and
30, as listed on the monitoring logs. The carbon was regenerated on October 7, 14, 20,
24, and 30. The volumes of gasoline recovered were 18.3, 17.0 and 15.5, 16.5, and
13.5 gallons, respectively.
Page 37 PENNEY ENGINEERING, INC
In October 2003, the SVE system operated continuously except for brief shutdowns for
the regeneration of the vapor phase carbon. During the regenerations, only the SVE
system was shutdown. The biodiffuser was allowed to operate continuously during the
regenerations so that the submersible pump did not need to be shutdown and restarted.
The off-gas from the biodiffuser was diverted from the carbon vessel and discharged
directly into the atmosphere during the regeneration because the screening results were
less that 2.0 ppm. On October 14, 2003, we discovered that we were recording the air
screening results incorrectly since activating the SVE system on September 9, 2003.
There were actually eight sampling ports, but only seven listed on our monitoring log.
The ports were being screened from downstream to upstream to prevent the OVM from
having to be purged. Port AS-1, from the biodiffuser, was not being screened. The
screening results for port AS-2, from the SVE system, were recorded for AS-1 on
September 17 and 29, 2003. We have changed the names of the ports on the
associated monitoring logs to correct the problem on those two days.
In November 2003, the systems continued to operate continuously except for brief
shutdowns for maintenance, repairs and regeneration of the vapor phase carbon. The
systems were inspected on November 3, 4, 6, 7, 9, 10, 11, 12, 13, 14, 17, 18, 19, 20,
21, 24, 25, and 29. The groundwater flowrate ranged from 1.4 to 2.0 gpm. As of
November 25, a total of 315,138 gallons of groundwater had been treated. No
additional gasoline accumulated in RW-1. To date, only 11.25 gallons of gasoline had
been skimmed from RW-1. The SVE system was screened on November 5, 11, 18,
and 25. We had determined that the carbon needed to be regenerated every seven
days. The volumes of gasoline recovered were 11.5, 12.5, 12.25 and 12.25 gallons,
respectively. The condensate continued to be treated in the biodiffuser.
On November 7, 2003, two drums of gasoline were transported from the site by the Oil
Recovery Corporation of West Springfield under a Uniform Straight Bill of Lading. The
approximately 100 gallons of gasoline was eventually transported to the Vexor facility in
Medina, OH to be burnt as a fuel. A copy of the Uniform Straight Bill of Lading was
previously submitted to the DEP.
On November 11, 2003, we gauged nine monitoring wells at the site to measure the
depth to groundwater and to determine the presence of free-phase gasoline. We also
gauged Recovery Well RW-1 and the recharge well. No free-phase gasoline was
observed in any of the wells, but a sheen was observed in RW-1 and MW-10. Wells
MW-1 RW-1 MW-10, MW-9 MW-12, ECS-5 and MW-2A had a gasoline odor. The
depth to groundwater measurements were used to determine the elevation of the
groundwater table at each well. We wanted to determine the zone of influence for the
Page 38 PENNEY ENGINEERING, INC
recovery well. We used Surfer software to plot the resulting groundwater contours on
the Groundwater Contour Plan included in the Figures section. As shown, the contours
did not accurately show textbook conditions due to the limitations of the software or the
groundwater elevation data. The contours showed that the influence of the groundwater
treatment system was limited to the 459 Pleasant Street and the adjacent section under
Pleasant Street. Recovery Well RW-1 was not affecting the groundwater at 480
Pleasant Street. A second recovery well located at 480 Pleasant Street, as proposed,
was confirmed to be needed to remediate the entire site.
On November 25, 2003, we collected air samples from ports AS-2 and AS-8 for
qualitative analysis. We wanted to identify the compounds in the combined air flows
from the biodiffuser and SVE system. We sampled AS-8 to identify the compounds that
were first breaking through the vapor phase carbon. Both ports were also screened for
total volatile organic compounds with an OVM. The air from AS-2 had a reading of 36.5
ppm and AS-8 had a reading of 16.2 ppm. A copy of the laboratory analysis report was
previously submitted to the DEP. The detection limits were relatively high at 0.5 ppm,
which was equal to the detection limit of the OVM. Only toluene and xylenes were
detected at 2.7 and 1.0 ppm, respectively, in AS-2. The results were much less than
the 36.5 ppm detected by the OVM. Only 2.2 ppm of benzene and 7.5 ppm of toluene
were detected in AS-8. The results did not correlate very well with the OVM readings.
Although the laboratory results were inconclusive, they did indicate that the air
contained benzene, toluene, and xylenes, which are common indicator compounds for
gasoline.
In December 2003, the treatment systems continued to operate continuously except for
brief shutdowns for maintenance, repairs and regeneration of the vapor phase carbon.
They were inspected on December 1, 2, 4, 10, 12, 15, 16, 17, 18, 19, 22, 23, 24, 26, 27,
29, 30 and 31. The groundwater flowrate was gradually increased to 4.1 gpm during
December as a result of a wet fall and a heavy snow fall in December. As of December
31, a total of 393,500 gallons of groundwater had been treated. The SVE system was
screened on December 2, 10, 18, and 29. The breakthrough period for the carbon had
increased to 11 days at the end of the month. The SVE influent screening
concentration had decreased from 39.7 to 10.1 ppm in December. The carbon was
regenerated on December 2, 10, 18, and 29. The volumes of gasoline recovered were
12.0, 12.0, 10.0, and 8.5 gallons, respectively.
On December 4, 2003, we cleaned the biodiffuser. Both systems were shutdown for
approximately six hours. Before being shutdown, the recovery well pump was turned off
and the biodiffuser was allowed to air strip the groundwater for 30 minutes. The
Page 39 PENNEY ENGINEERING, INC
biodiffuser was then shutdown and the treated water was pumped to the recharge well.
The aeration manifold was removed form the biodiffuser and cleaned with muriatic acid.
The 1/8” air holes in the spargers were redrilled to remove the iron precipitate.
Approximately 30 gallons of silt and iron precipitate were removed from the biodiffuser
and stored in a 55-gallon drum in the treatment trailer to prevent freezing. A sample of
the sediment was collected for analysis. The biodiffuser was reassembled and both
systems were restarted. The contactor for the blower on the biodiffuser was found to
have been damaged beyond repair during the day after Thanksgiving when the system
shutdown because the water filter had not been changed. The biodiffuser was left off
until the contactor could be replaced and the SVE system was left running. On
December 10, the blower contactor was replaced during a regen and the groundwater
treatment system was restarted.
On December 10, 2003, we contacted Ms. Kim Brodeur at Browning-Ferris Industries
(BFI) in Chicopee. We explained the operation of the groundwater treatment systems to
her and asked if she would consider allowing us to dump the 30 gallons of sediment
from cleaning the biodiffuser into the on-site BFI dumpster to be disposed of as a solid
waste. We explained that we were awaiting analysis results. Ms. Brodeur requested a
letter and the results. On December 31, we received the laboratory report for the
sediment. The results showed that the sediment contained 5,940 mg/kg total VPH
fractions. The sediment required disposal as a special or hazardous waste
On December 18, 2003, we collected water samples from the treatment system and
monitoring wells MW-10 and MW-12 according to DEP procedures. The samples were
transported to Groundwater Analytical under chain-of-custody protocol. The four
groundwater samples were analyzed for VPHs by the DEP method. A summary of the
influent and the effluent results are shown in Table Eight along with the removal rates
and the applicable GW-3 cleanup standards. The results for the compounds detected in
the two wells are summarized and compared to the applicable GW-3 cleanup standards
in Table Nine. The groundwater from the wells was also analyzed for heterotrophic
bacteria. The bacteria counts are listed and compared to our normal ranges in Table
Ten. A copy of the laboratory analysis report was previously submitted to the DEP.
Page 40 PENNEY ENGINEERING, INC
TABLE EIGHT
Removal Rates
December 18, 2003
(Flowrate: 3.0 gpm)
Parameters
Influent
Effluent
Percent
Removal
Cleanup
Standards
GW-3
VPH (mg/l)
C5 – C8 aliphatics 3,500 37 98.9 4,000
C9 – C12 aliphatics 3,100 20 99.3 20,000
C9 – C10 aromatics 4,400 30 99.3 4,000
Target VOCs (mg/l)
MTBE < 125 <5 UK 50,000
Benzene 2,100 2 99.9 7,000
Toluene 5,200 6 99.8 50,000
Ethylbenzene 840 <5 99.4 4,000
Xylenes 5,000 17 99.6 50,000
Naphthalene 350 19 94.6 6,000
UK – Unknown
As shown in Table Eight, at a flowrate of 3.0 gpm, the influent concentrations were
much lower than the previous September 22, 2003 results. Only the C9-C10 aromatics
fraction was just above the applicable GW-3 cleanup standard of 4,000 ug/l. Between
September 22 and December 18, 2003, a total of 149,507 gallons of groundwater was
treated through the biodiffuser. Based upon a 63% reduction of the total VPH fractions
in the influent between September 22 and December 18, 2003, the groundwater
treatment system had removed 8.60 lbs of gasoline-related compounds. As shown in
Table Eight, the biodiffuser continued to remove at least 98.9% of the contaminants
except for naphthalene which was removed at 94.6%.
Page 41 PENNEY ENGINEERING, INC
TABLE NINE
Summary of Groundwater Results
December 18, 2003
Parameters MW-10 MW-12 Cleanup Standards
GW-3
VPHs (mg/l)
C5–C8 aliphatics 13,000 16,000 4,000
C9–C12 aliphatics 4,300 7,500 20,000
C9–C10 aromatics 7,000 9,200 4,000
Target VOCs (mg/l)
MTBE < 250 350 50,000
Benzene 7,000 3,000 7,000
Toluene 21,000 19,000 50,000
Ethylbenzene 2,300 4,000 4,000
Xylenes 13,600 19,900 50,000
Naphthalene 490 770 6,000
As shown in Table Nine, the results for wells MW-10 and MW-12 were again high, but
lower than the previous September 22, 2003 results. As shown in bold, the C5-C8
aliphatics and C9-C10 aromatics fractions were still above the applicable GW-3 cleanup
standards. All the target VOCs had decreased to be below the GW-3 cleanup
standards. No free-phase gasoline had been observed in either well since the
treatment system was started.
TABLE TEN
Remedial Additive Monitoring
December 18, 2003
Parameter MW-10 MW-12 Normal Range
Bacteria Counts 10,000 35,000 0-100
As shown in Table Ten, the bacteria counts in both wells were high indicating enhanced
biological remediation.
In January 2004, the systems continued to operate continuously except for brief,
shutdowns for maintenance, repairs and regeneration of the vapor phase carbon. They
were inspected on January 2, 4, 5, 6, 7, 8, 9, 10, 12, 13, 14, 15, 16, 19, 20, 21, 22, 23,
26, 28, 29, 30. The groundwater flowrate had to be decreased from 4.2 to 3.0 gpm
during January to prevent the recovery well pump from shutting down due to low water,
although we found that the silt had finally been removed from Recovery Well RW-1.
The pump would restart without having to hit the riser pipe. As of January 29, a total of
533,507 gallons of groundwater had been treated. The SVE system had been screened
Page 42 PENNEY ENGINEERING, INC
on January 12 and 29. The breakthrough period for the carbon had increased to 14
days. The SVE influent screening concentration had slightly increased from 10.1 to
12.8 during the month. The carbon was regenerated on January 12 and 29. The
volumes of gasoline recovered were 5.5 and 10.5 gallons, respectively.
In February 2004, the treatment systems continued to operate continuously except for
brief shutdowns for repairs, maintenance and regeneration of the vapor phase carbon.
They were inspected on February 2, 3, 4, 5, 6, 7, 9, 10, 12, 13, 16, 17, 18, 19, 24, 25,
26, and 27. The groundwater flowrate was gradually decreased from 3.0 to 1.2 gpm
during February due to low groundwater conditions as a result of the winter. As of
February 27, a total of 621,200 gallons of groundwater had been treated. The SVE
system was screened on February 12 and 26, prior to the carbon being regenerated.
The breakthrough period for the carbon had remained at 14 days during the month.
The SVE influent screening concentration had again increased from 17.8 to 22.9.
Apparently, the low groundwater table exposed additional gasoline-contaminated soil for
the SVE to vent. The carbon was regenerated on February 12 and 26. The volumes of
gasoline recovered were 7.5 and 9.0, respectively.
On February 27, 2004, three additional drums of recovered gasoline were transported
from the site by the Oil Recovery Corporation under a Uniform Straight Bill of Lading.
The approximately 150 gallons of gasoline was transported to the Vexor facility in
Medina, OH to be burnt as a fuel. A copy of the Uniform Straight Bill of Lading was
previously submitted to the DEP.
In March 2004, the treatment systems continued to operate continuously except for brief
shutdowns for repairs, maintenance and regeneration of the vapor phase carbon. They
were inspected on March 4, 9, 10, 11, 15, 17, 18, 19, 23, 24, 25, 30 and 31, as shown
on the corresponding monitoring logs. The average groundwater flowrate was
approximately 1.6 gpm during March due to low groundwater conditions as a result of
the winter. As of March 31, 2004, a total of 698,830 gallons of groundwater had been
treated. The SVE system was screened on March 11 and 25, prior to the carbon being
regenerated. The breakthrough period for the carbon had remained at 14 days during
the month. The SVE influent screening concentration had again increased to 26.4 and
32.1 ppm. Apparently, the low groundwater table exposed additional gasoline-
contaminated soil for the SVE to vent. The volumes of gasoline recovered were 13.0
and 14.0, respectively. On March 18, 2004, we again cleaned the biodiffuser. There
was very little sediment, but we needed to drill out the holes in the diffusers to remove
the iron precipitate.
Page 43 PENNEY ENGINEERING, INC
On March 18, 2004, we collected influent and effluent samples from the treatment
system along with groundwater from monitoring wells MW-8, MW-10, MW-12 and ECS-
5 according to DEP procedures. The samples were transported to Groundwater
Analytical under chain-of-custody protocol. The six groundwater samples were
analyzed for VPHs by the DEP method. A summary of the influent and the effluent
results are shown in Table Eleven along with the removal rates and the applicable GW-
3 cleanup standards because Recovery Well RW-1 is located more than 30 feet from an
occupied building. The Recharge Well in located within 30 feet of the occupied garage
so the GW-2 cleanup standards apply. However, the concentrations of contaminants in
the effluent are relatively low, well below the GW-2 cleanup standards. Therefore, the
influent and effluent results are only compared to the GW-3 cleanup standards in Table
Eleven. The results for the compounds detected in the four wells are summarized and
compared to the applicable GW-2 or GW-3 cleanup standards in Table Twelve. The
influent was also analyzed for total phosphorous, alkalinity, heterotrophic bacteria,
nitrates, nitrites, and total organic carbon. We wanted to evaluate the biochemical
conditions in the groundwater being pumped from the Recovery Well. The results, the
measurements and our normal ranges are listed in Table Thirteen. We also measured
the dissolved oxygen, pH and temperature in nine of the wells at the site. Free-phase
gasoline was only observed in well MW-1 at one-sixteenth of an inch. The
measurements and our normal ranges are listed in Table Fourteen, included in the
Figures section. A copy of the laboratory analysis report was previously submitted to
the DEP.
TABLE ELEVEN
Removal Rates
March 18, 2004
(Flowrate: 2.1 gpm)
Parameters
Influent
Effluent
Percent
Removal
Cleanup
Standards
GW-3
VPH (mg/l)
C5 – C8 aliphatics 4,400 21 99.5 4,000
C9 – C12 aliphatics 2,400 < 20 99.6 20,000
C9 – C10 aromatics 3,000 51 98.3 4,000
Target VOCs (mg/l)
MTBE 75 < 5 96.7 50,000
Benzene 1,800 4 99.8 7,000
Toluene 3,700 6 99.9 50,000
Ethylbenzene 660 < 5 99.6 4,000
Xylenes 3,240 12 99.6 50,000
Naphthalene 170 14 91.8 6,000
Page 44 PENNEY ENGINEERING, INC
As shown in bold in Table Eleven, only the C5-C8 aliphatics fractions was above the
applicable GW-3 cleanup standard of 4,000 ug/l. Between December 18, 2003 and
March 18, 2004, a total of 325,627 gallons of groundwater was treated through the
biodiffuser. At a flowrate of 2.1 gpm, the biodiffuser continued to remove at least 98.3%
of the contaminants except for naphthalene which was removed at 91.8%.
TABLE TWELVE
Summary of Groundwater Results
March 18, 2004
Cleanup Standards Parameters MW-8 MW-10 MW-12 ECS-5 GW-2 GW-3
(Applicable Standard) (GW-3) (GW-3) (GW-3) (GW-2)
VPHs (mg/l)
C5–C8 aliphatics 67 27,000 17,000 4,800 1,000 4,000
C9–C12 aliphatics < 20 6,400 8,100 3,600 1,000 20,000
C9–C10 aromatics < 20 9,100 9,300 4,600 5,000 4,000
Target VOCs (mg/l)
MTBE < 5 580 < 250 < 125 50,000 50,000
Benzene < 1 12,000 3,400 1,300 2,000 7,000
Toluene < 5 38,000 21,000 940 6,000 50,000
Ethylbenzene < 5 4,100 4,100 1,300 30,000 4,000
Xylenes < 5 20,800 20,400 4,860 6,000 50,000
Naphthalene < 5 640 620 270 6,000 6,000
As shown in Table Twelve, the results from wells MW -10 and MW-12 were again high.
As shown in bold, the C5-C8 aliphatics and C9-C10 aromatics fractions were still above
the applicable GW-3 cleanup standards. Free-phase gasoline was no longer observed
in either well since the treatment system was started. No significant contamination was
detected in MW-8 indicating that it was located beyond the extent of the contamination
at 480 Pleasant Street. Conversely, significant contamination was detected in ECS-5,
which is located adjacent to the building at 492 Pleasant Street.
Page 45 PENNEY ENGINEERING, INC
TABLE THIRTEEN
Biochemical Evaluation Results and Measurements
March 18, 2004
Parameters Influent Normal Ranges
Total Nitrogen (mg/l) < 0.5 0 – 0.1
Bacteria Counts (cfu/ml) 15,000 0 – 100
Total Organic Carbon, Liquid (mg/l) 7.4 0 – 10
Total Phosphorous (mg/l) < 0.5 0 – 10
Total Alkalinity (mg/l as CaCO3) 63 0 – 100
As shown in Table Thirteen, the bacteria counts in the influent were high indicating
enhanced biological remediation. Nitrogen and phosphorous were not detected
indicating that they needed to be added to enhance the bioremediation.
As shown in Table Fourteen, the temperature, dissolved oxygen and pH were all within
our normal ranges.
The treatment systems continued to operate continuously in April 2004, except for brief
shutdowns for repairs, maintenance and regeneration of the vapor phase carbon. They
were inspected on April 5, 6, 7, 8, 9, 11, 12, 13, 14, 15, 16, 19, 20, 22, 26, 27 and 29, as
shown on the corresponding monitoring logs. The groundwater flowrate averaged 3.2
gpm during April. As of April 29, 2004, a total of 828,210 gallons of groundwater had
been treated. The SVE system was screened on April 6 and 19, prior to the carbon
being regenerated. The breakthrough period for the carbon had remained at 14 days
during the month. The SVE influent screening concentration was 22.3 and 16.7 ppm,
respectively. The volumes of gasoline recovered were 12.0 and 10.0 gallons,
respectively.
In May 2004, the treatment systems continued to operate continuously except for brief
shutdowns for repairs, maintenance and regeneration of the vapor phase carbon. They
were inspected on May 1, 3, 5, 7, 10, 13, 15, 17, 18, 20, 22, 24, 25, 26, 27, 28 and 31,
as shown on the corresponding monitoring logs. The groundwater flowrate averaged
3.2 gpm during May. As of May 31, 2004, a total of 977,288 gallons of groundwater had
been treated. The SVE system was screened on May 3, 13 and 24, prior to the carbon
being regenerated. The breakthrough period for the carbon decreased to 11 days
during the month. The SVE influent screening concentration had again increased to
14.3, 15.1 and 25.1. Apparently, the low groundwater table exposed additional
gasoline-contaminated soil for the SVE to vent. The volumes of gasoline recovered
were 14.0, 10.0 and 11.0 gallons, respectively. On May 13, 2004, we began injecting
Page 46 PENNEY ENGINEERING, INC
microbe nutrients to the clearwell of the biodiffuser to enhance bioremediation, as listed
on the monitoring logs.
In June 2004, the treatment systems continued to operate continuously in June 2004,
except for brief shutdowns for repairs, maintenance and regeneration of the vapor
phase carbon. They were inspected on June 1, 2, 3, 4, 5, 6, 7, 8, 9, 11, 12, 14, 15,16,
18, 19, 22, 26, 28 and 29, as shown on the corresponding monitoring logs. The
groundwater flowrate averaged 2.2 gpm during June. As of June 29, 2004, a total of
1,064,190 gallons of groundwater had been treated. The SVE system was screened on
June 4, 16 and 29, prior to the carbon being regenerated. The SVE influent screening
concentration had again fluctuated to 25.7, 17.5 and 26.1 ppm. The volumes of
gasoline recovered were 11.0, 12.0 and 13.0 gallons, respectively.
On June 16, 2004, we collected influent and effluent samples from the treatment system
along with groundwater from monitoring wells MW-9, MW-10, MW-12 and ECS-5
according to DEP procedures. The samples were transported to Groundwater
Analytical under chain-of-custody protocol. The six groundwater samples were
analyzed for VPHs by the DEP method. A summary of the influent and the effluent
results are shown in Table Fifteen along with the removal rates and the applicable GW-
3 cleanup standards. The results for the compounds detected in the four wells are
summarized and compared to the applicable GW-2 or GW-3 cleanup standards in Table
Sixteen. The influent and wells MW-10 and MW-12 were also analyzed for nitrates,
nitrites and heterotrophic bacteria. We wanted to again evaluate the biochemical
conditions in the groundwater being pumped from the Recovery Well. We also
measured the dissolved oxygen, pH and temperature in all the samples. Only a
gasoline sheen and odor were observed in wells MW-9, MW-10 and MW-12. The
measurements and our normal ranges are listed in Table Seventeen, included in the
Figures section. A copy of the laboratory analysis report was previously submitted to
the DEP.
Page 47 PENNEY ENGINEERING, INC
TABLE FIFTEEN
Removal Rates
June 16, 2004
(Flowrate: 2.4 gpm)
Parameters
Influent
Effluent
Percent
Removal
Cleanup
Standards
GW-3
VPH (mg/l)
C5 – C8 aliphatics 5,300 21 99.6 4,000
C9 – C12 aliphatics 2,400 < 20 99.6 20,000
C9 – C10 aromatics 4,600 25 99.5 4,000
Target VOCs (mg/l)
MTBE < 125 < 5 UK 50,000
Benzene 2,600 1 99.9 7,000
Toluene 4,900 < 5 99.9 50,000
Ethylbenzene 860 < 5 99.7 4,000
Xylenes 4,000 < 5 99.9 50,000
Naphthalene 220 < 5 98.8 6,000
UK – Unknown
As shown in bold in Table Fifteen, only the C5 – C8 aliphatics and the C9 – C10 aromatics
fractions in the influent were detected above the GW-3 cleanup standards. At a flowrate
of 2.4 gpm, the biodiffuser continued to remove at least 99.5% of the contaminants
except for naphthalene which was removed at 98.8%.
TABLE SIXTEEN
Summary of Groundwater Results
June 16, 2004
Cleanup Standards Parameters MW-9 MW-10 MW-12 ECS-5 GW-2 GW-3
(Applicable Standard) (GW-3) (GW-3) (GW-3) (GW-2)
VPHs (mg/l)
C5–C8 aliphatics 21,000 26,000 14,000 5,800 1,000 4,000
C9–C12 aliphatics 6,700 9,200 6,700 3,400 1,000 20,000
C9–C10 aromatics 16,000 13,000 11,000 5,700 5,000 4,000
Target VOCs (mg/l)
MTBE < 1,000 < 1,250 < 500 < 125 50,000 50,000
Benzene 12,000 5,300 3,400 970 2,000 7,000
Toluene 28,000 42,000 16,000 650 6,000 50,000
Ethylbenzene 2,700 4,700 3,000 1,300 30,000 4,000
Xylenes 16,700 25,500 15,700 4,380 6,000 50,000
Naphthalene 1,000 < 1,250 570 270 6,000 6,000
Page 48 PENNEY ENGINEERING, INC
As shown in bold in Table Sixteen, the C5-C8 aliphatics and C9-C10 aromatics fractions
were above the applicable GW-2 and GW-3 cleanup standards in all four wells.
Benzene was only detected above the GW-3 cleanup standard in well MW-9.
Ethylbenzene was only detected above the GW-3 cleanup standard in well MW-10.
As shown in Table Seventeen, the dissolved oxygen was high in the effluent as
expected for aerated water, but it was also high in the influent indicating that the
groundwater between the Recharge Well and Recovery Well RW-1 was highly
oxygenated. We expected the dissolved oxygen in wells MW-9 and MW-10 to be higher
as a result. The dissolved oxygen results may have indicated short circuiting of the
recharge water or consumption of oxygen by bacteria. The bacteria counts in the
influent were very low. Nitrite and nitrate were now detected in the groundwater as a
result of our injecting microbe nutrients.
On June 16, 2004, we also applied for a new permit to store the recovered gasoline.
We were informed by Deputy Fire Chief Dwayne Nichols that the permits ran on a
calendar year. Deputy Chief Nichols issued a new permit dated April 15, 2004. A copy
was posted at the site and a copy was submitted to the DEP.
On July 16, 2004, two drums of recovered gasoline were transported from the site by
the Oil Recovery Corporation under a Uniform Straight Bill of Lading. The
approximately 110 gallons of gasoline was eventually transported to the Vexor facility in
Medina, OH to be burnt as fuel. A copy of the Uniform Straight Bill of Lading was
previously submitted to the DEP.
In July 2004, the treatment systems continued to operate continuously except for brief
shutdowns for repairs, maintenance and regeneration of the vapor phase carbon. They
were inspected on July 1, 5, 8, 9, 12, 15, 20, 21, 23 and 28, as shown on the
corresponding monitoring logs. The groundwater flowrate averaged 1.1 gpm during
July. As of July 28, 2004, a total of 1,103,580 gallons of groundwater had been treated.
The SVE system was screened on July 12, 21 and 28, prior to the carbon being
regenerated. The SVE influent screening concentration had again increased to 29.3,
34.3 and 38.5 ppm. Apparently, the low groundwater table exposed additional gasoline-
contaminated soil for the SVE to vent. The volumes of gasoline recovered were 13.0,
9.0 and 7.0 gallons, respectively.
In August 2004, the treatment systems continued to operate continuously, except for
brief shutdowns for repairs, maintenance and regeneration of the vapor phase carbon.
They were inspected on August 2, 3, 5, 9, 16, 18, 20, 23, 25, 30 and 31, as shown on
Page 49 PENNEY ENGINEERING, INC
the corresponding monitoring logs. The groundwater flowrate remained at 0.6 gpm
during August. As of August 31, 2004, a total of 1,141,230 gallons of groundwater had
been treated. The SVE system was screened on August 3, 9, 16, 20, 25 and 31, prior
to the carbon being regenerated. The SVE influent screening concentration had again
increased to 37.1, 42.3, 43.7, 40.2, 42.8 and 37.1 ppm. The low groundwater table
exposed additional gasoline-contaminated soil for the SVE to vent. The volumes of
gasoline recovered were 13.5, 13.0, 14.0, 15.0 15.75 and 14.0 gallons, respectively.
On August 31, 2004, two drums of recovered gasoline were transported from the site by
the Oil Recovery Corporation under a Uniform Straight Bill of Lading. The
approximately 110 gallons of gasoline was eventually transported to the Vexor facility in
Medina, OH to be burnt as fuel. A copy of the Uniform Straight Bill of Lading was
previously submitted to the DEP.
In September 2004, the treatment systems continued to operate continuously, except
for brief shutdowns for repairs, maintenance and regeneration of the vapor phase
carbon. They were inspected on September 2, 7, 9, 13, 15, 20, 21, 23, 25, 27, 28, 29
and 30, as shown on the corresponding monitoring logs. The groundwater flowrate
remained at 0.6 gpm but increased to 1.0 gpm at the end of the month. As of
September 30, 2004, a total of 1,168,780 gallons of groundwater had been treated. The
SVE system was screened on September 7, 13, 21, and 27, prior to the carbon being
regenerated. The SVE influent screening concentration had again increased to 41.1,
39.4, 36.7 and 32.8 ppm. The low groundwater table exposed additional gasoline-
contaminated soil for the SVE to vent. The volumes of gasoline recovered were 14.25,
14.25, 13.00 and 11.75 gallons, respectively.
On September 15, 2004, we started injecting a solution of remedial additives into the
clearwell on the biodiffuser. The solution was made by filling a 55-gallon drum with
treated groundwater from the biodiffuser. Twenty pounds of granular, 20-20-20,
microbe nutrients was dissolved in the water. A dosing pump was mounted on the drum
in the treatment trailer to continuously inject the 55 gallons of remedial additives solution
over an eight-day period. On September 27, 2004, a second drum of remedial additives
solution was prepared as described above except ¼ l b of powdered Munox 10x
Multiplier, a mixture of 35 varieties of petroleum metabolizing bacteria, was also
dissolved in the water.
On September 21, 2004, we collected samples of the influent and effluent from the
treatment system along with groundwater from monitoring wells MW-9, MW-10, MW-12
and ECS-5 according to DEP procedures. The samples were transported to
Page 50 PENNEY ENGINEERING, INC
Groundwater Analytical under chain-of-custody protocol. The six groundwater samples
were analyzed for VPHs by the DEP method. A summary of the influent and the
effluent results are shown in Table Eighteen along with the removal rates and the
applicable GW-3 cleanup standards. The results for the compounds detected in the
four wells are summarized and compared to the applicable GW-2 or GW-3 cleanup
standards in Table Nineteen. The influent and wells MW-10 and MW-12 were also
analyzed for nitrates and nitrites. We wanted to again evaluate the biochemical
conditions in the groundwater being pumped from the recovery well. We also inspected
nine wells for gasoline and measured the dissolved oxygen, pH and temperature in the
influent, effluent, MW-9, MW-10, MW-12, and ECS-5. The influent was analyzed for
heterotrophic bacteria. A gasoline sheen was observed in wells MW-9, MW-10, MW-12
and ECS-5. Only wells MW-9, MW-10, MW-12 and ECS-5 had an odor of gasoline.
There was no sheen or odor in wells MW-1, MW-2A, MW -5, MW-7 or MW-8. The
measurements and our normal ranges are listed in Table Twenty, included in the
Figures section. A copy of the laboratory analysis report is included in Appendix C.
TABLE EIGHTEEN
Removal Rates
September 21, 2004
(Flowrate: 0.6 gpm)
Parameters
Influent
Effluent
Percent
Removal
Cleanup
Standards
GW-3
VPH (mg/l)
C5 – C8 aliphatics 4,600 < 20 99.8 4,000
C9 – C12 aliphatics 1,400 < 20 99.2 20,000
C9 – C10 aromatics 4,600 < 20 99.8 4,000
Target VOCs (mg/l)
MTBE < 125 < 5 UK 50,000
Benzene 1,600 < 1 99.9 7,000
Toluene 3,700 < 5 99.9 50,000
Ethylbenzene 630 < 5 99.6 4,000
Xylenes 3,160 < 5 99.9 50,000
Naphthalene 210 < 5 98.8 6,000
UK – Unknown
As shown in bold in Table Eighteen, the C5 – C8 aliphatics and the C9 – C10 aromatics
fractions were slightly above the applicable GW-2 cleanup standards in the influent.
Nothing was detected in the effluent. At a flowrate of 0.6 gpm, the biodiffuser continued
to remove at least 99.2% of the contaminants except for naphthalene which was
removed at 98.8%.
Page 51 PENNEY ENGINEERING, INC
TABLE NINETEEN
Summary of Groundwater Results
September 21, 2004
Cleanup Standards Parameters MW-9 MW-10 MW-12 ECS-5 GW-2 GW-3
(Applicable Standard) (GW-3) (GW-3) (GW-3) (GW-2)
VPHs (mg/l)
C5–C8 aliphatics 84,000 24,000 14,000 6,700 1,000 4,000
C9–C12 aliphatics 30,000 5,100 4,500 1,500 1,000 20,000
C9–C10 aromatics 73,000 11,000 14,000 4,700 5,000 4,000
Target VOCs (mg/l)
MTBE < 1,000 < 1,000 < 250 240 50,000 50,000
Benzene 14,000 6,500 1,800 3,100 2,000 7,000
Toluene 43,000 26,000 7,600 1,700 6,000 50,000
Ethylbenzene 5,800 3,300 1,900 990 30,000 4,000
Xylenes 32,000 16,200 10,200 3,040 6,000 50,000
Naphthalene 2,500 < 1,000 460 180 6,000 6,000
As shown in bold in Table Nineteen, a majority of the VPH fractions were above the
applicable GW-2 and GW-3 cleanup standards in all four wells. Ethylbenzene was the
only target VOC that was detected above the GW-3 cleanup standard in well MW-9.
As shown in Table Twenty, the dissolved oxygen was high in the effluent as expected
for aerated water, but it was also high in the influent indicating that the groundwater
between the Recharge Well and Recovery Well RW-1 was highly oxygenated. Next
time we shall measure the dissolve oxygen in well MW-1. We expected the dissolved
oxygen in wells MW-9 and MW-10 to be higher as a result. The results may indicate
short-circuiting of the recharge water or consumption of oxygen by bacteria. The pH of
the influent, the effluent, MW-9 and MW-10 were relatively low. The bacteria counts in
the influent had decreased. Nitrate and nitrite were detected in the influent, MW-9 and
MW-10 as a result of our beginning to inject microbe nutrients into the discharge water.
Compared to the influent, the concentrations were twice as high in MW-9 and MW-10.
In October 2004, the treatment systems continued to operate continuously, except for
brief shutdowns for repairs, maintenance and regeneration of the vapor phase carbon.
They were inspected on October 2, 4, 6, 8, 11, 12, 15, 18, 20, 28 and 31, as shown on
the corresponding monitoring logs. The groundwater flowrate ranged from 0.8 to 1.0
gpm during the month. As of October 28, 2004, a total of 1,201,982 gallons of
groundwater had been treated. The SVE system was screened on October 4, 12, 20,
and 28, prior to the carbon being regenerated. The SVE influent screening
concentration was measured at 30.8, 43.7, 28.9, and 20.2 ppm, respectively. The low
Page 52 PENNEY ENGINEERING, INC
groundwater table continued to expose additional gasoline-contaminated soil for the
SVE system to vent. The volumes of gasoline recovered during each regeneration of
the carbon were 13.50, 12.75, 11.00 and 10.50 gallons, respectively.
On October 4, 2004, we added ¼ lb of powdered Munox 10x Multiplier to the clearwell.
A drum of remedial additive solution was prepared as previously described and setup to
be injected onto the clearwell over an eight-day period.
On October 12, 2004, we cleaned the biodiffuser during a regeneration of the carbon.
Both systems were shutdown for approximately six hours. Before being shutdown, the
recovery well pump was turned off and the biodiffuser was allowed to air strip the
groundwater for 30 minutes. The biodiffuser was then shutdown and the treated water
was pumped to the Recharge Well. The aeration manifold was removed from the
biodiffuser and cleaned with muriatic acid. The 1/8” air holes in the spargers were
redrilled to remove the iron precipitate. Approximately 30 gallons of silt and iron
precipitate were removed from the biodiffuser and stored in the 55-gallon drum of
sediment outside the treatment trailer. The biodiffuser was reassembled and both
systems were restarted.
On October 20 2004, a drum of remedial additive solution was prepared as previously
described, but with only 15 lbs of 20-20-20 microbe nutrients and setup to be injected
onto the clearwell over an eight-day period.
On October 28 2004, a drum of remedial additive solution was prepared as previously
described with 20 lbs of 20-20-20 microbe nutrients and setup to be injected into the
clearwell over an eight-day period.
In November 2004, the treatment systems continued to operate continuously, except for
brief shutdowns for repairs, maintenance and regeneration of the vapor phase carbon.
They were inspected on November 9, 10, 12, 17, 19 and 23, as shown on the
corresponding monitoring logs. The groundwater flowrate remained at 1.5 gpm during
the month. As of November 23, 2004, a total of 1,244,220 gallons of groundwater had
been treated. The SVE system was screened on November 9 and 23, prior to the
carbon being regenerated. The SVE influent screening concentration was measured at
17.8 and 15.2 ppm, respectively. The rising groundwater table exposed less gasoline-
contaminated soil for the SVE system to vent. Also, there was less gasoline remaining
in the soil. The volumes of gasoline recovered during each regeneration of the carbon
were 9.00 and 9.00 gallons, respectively. As of November 23, 2004, we had recovered
Page 53 PENNEY ENGINEERING, INC
595.55 gallons of gasoline from Recovery Well RW-1 and from regenerating the vapor
phase carbon. A majority of the gasoline was from the SVE system.
On November 19, 2004, three additional drums of recovered gasoline from the carbon
regeneration process were transported from the site by the Oil Recovery Corporation
under a Uniform Straight Bill of Lading. The approximately 150 gallons of gasoline was
eventually transported to the Vexor facility in Medina, OH to be burnt as a fuel. On
November 19, 2004, one, 2/3 full, 55-gallon of sediment from cleaning the biodiffuser
was also removed by Oil Recovery as oily solids under a hazardous waste manifest.
The drum of sediment was removed to prevent it from freezing over the winter. Copies
of the Uniform Straight Bill of Lading and Manifest MA Q 834730 are included in
Appendix A.
On November 23, 2004, we began manually applying remedial additives to monitoring
wells MW- 12 and ECS-5 located at 492 Pleasant Street. A 55-gallon drum was filled
with treated groundwater from the biodiffuser. Five pounds of granular, 20-20-20
microbe nutrients and ¼ lb of powdered Munox 10x Mu ltiplier, a mixture of 35 varieties
of petroleum metabolizing bacteria, were dissolved in the water. A small, battery-
powdered pump was used to transfer approximately 27 gallons of the remedial additives
solution into each well.
In December 2004, the treatment systems continued to operate continuously, except for
brief shutdowns for repairs, maintenance and regeneration of the vapor phase carbon.
They were inspected on December 4, 9, 11, 22, 27 and 28, as shown on the
corresponding monitoring logs. The groundwater flowrate ranged from 1.6 to 2.0 gpm
during the month. As of December 28, 2004, a total of 1,331,602 gallons of
groundwater had been treated. The SVE system was screened on December 9 and 28,
prior to the carbon being regenerated. The SVE influent screening concentration was
measured at 10.7 and 6.5 ppm, respectively. The rising groundwater table exposed
less gasoline-contaminated soil for the SVE system to vent. Also, there was less
gasoline remaining in the soil. The volumes of gasoline recovered during each
regeneration of the carbon were 9.50 and 4.25 gallons, respectively. As of December
28, 2004, we had recovered 609.30 gallons of gasoline from Recovery Well RW-1 and
from regenerating the vapor phase carbon. A majority of the gasoline was from the
SVE system.
On December 9, 2004, we collected samples of the influent and effluent from the
groundwater treatment system along with groundwater from monitoring wells MW-1,
MW-9, MW-10, MW-12 and ECS-5 according to DEP procedures. The samples were
Page 54 PENNEY ENGINEERING, INC
transported to Groundwater Analytical under chain-of-custody protocol. The seven
groundwater samples were analyzed for VPHs by the DEP method. A summary of the
influent and the effluent results are shown in Table Twenty-One along with the removal
rates and the applicable GW-3 cleanup standards. The results for the compounds
detected in the five wells are summarized and compared to the applicable GW-2 or GW-
3 cleanup standards in Table Twenty-Two, included in the Figures section. The influent
and wells MW-10 and MW-12 were also analyzed for nitrates and nitrites. The influent
and MW-12 were analyzed for heterotrophic bacteria. We wanted to again evaluate the
biochemical conditions in the groundwater. We also inspected the five wells for
gasoline and measured the dissolved oxygen, pH and temperature in the influent,
effluent, MW-1, MW-9, MW-10, MW-12, and ECS-5. A gasoline sheen was observed in
wells MW-1, MW-9, MW-10 and MW-12. Wells MW-1, MW-9, MW-10, MW-12 and
ECS-5 had an odor of gasoline. The measurements and our normal ranges are listed in
Table Twenty-Three included in the Figures section. A copy of the laboratory analysis
report is included in Appendix C.
TABLE TWENTY-ONE
Removal Rates
December 9, 2004
(Flowrate: 1.6 gpm)
Parameters
Influent
Effluent
Percent
Removal
Cleanup
Standards
GW-3
VPH (mg/l)
C5 – C8 aliphatics 4,200 < 20 99.8 4,000
C9 – C12 aliphatics <500 < 20 UK 20,000
C9 – C10 aromatics 4,700 21 99.5 4,000
Target VOCs (mg/l)
MTBE < 125 < 5 UK 50,000
Benzene 2,100 2 99.9 7,000
Toluene 4,600 6 99.9 50,000
Ethylbenzene 820 < 5 99.6 4,000
Xylenes 3,700 < 5 99.9 50,000
Naphthalene 330 < 5 99.2 6,000
UK – Unknown
As shown in bold in Table Twenty-One, the C5–C8 aliphatics and the C9 – C10 aromatics
fractions remained slightly above the applicable GW -3 cleanup standards in the influent.
Only relatively low concentrations were detected in the effluent. At a flowrate of 1.6
gpm, the biodiffuser continued to remove at least 99.2% of the contaminants.
Page 55 PENNEY ENGINEERING, INC
As shown in bold in Table Twenty-Two, only the C5–C8 aliphatics and the C9–C10
aromatics fractions were above the applicable GW-2 and GW-3 cleanup standards in all
five wells. No target VOCs that was detected above the GW-2 or the GW-3 cleanup
standards.
As shown in Table Twenty-Three, the dissolved oxygen was high in the effluent as
expected for aerated water, but it was also high in the influent again indicating that the
groundwater between the Recharge Well and Recovery Well RW-1 was highly
oxygenated. The dissolved oxygen in well MW-1 was only 1.9 mg/l, which was one of
the lowest readings, indicating that the recharged water may have developed “channels”
between the Recharge Well and Recovery Well RW-1. We had determined that the
recharged groundwater may be short-circuiting by flowing through channels or the more
permeable layer of medium to coarse sand beginning at a depth of 14 feet. The results
may also indicate the consumption of oxygen by bacteria because the contaminants in
the well were high. The bacteria counts and nitrate/nitrite in MW-12 were very high as a
result of our manual addition of remedial additives. Low concentrations of nitrate and
nitrite were detected in the influent, MW-9 and MW-10 as a result of our injecting
microbe nutrients into the discharge water.
On December 9, 2004, we again manually applied remedial additives to monitoring
wells MW- 12 and ECS-5 located at 492 Pleasant Street. A 55-gallon drum was filled
with treated groundwater from the biodiffuser. Five pounds of granular, 20-20-20
microbe nutrients and ¼ lb of powdered Munox 10x Mu ltiplier were dissolved in the
water. One gallon of liquid surfactant was added to each well, and then a small,
battery-powdered pump was used to transfer approximately 27 gallons of the remedial
additives solution into each well.
In January 2005, the treatment systems continued to operate continuously, except for
brief shutdowns for repairs, maintenance and regeneration of the vapor phase carbon.
They were inspected on January 2, 7, 13, 15, 18, 20, 21, 22, 25, 27, and 28, as shown
on the corresponding monitoring logs. The groundwater flowrate ranged from 1.5 to 2.0
gpm during the month. As of January 28, 2005, a total of 1,401,269 gallons of
groundwater had been treated. The SVE system was screened only on January 27,
prior to the carbon being regenerated one time during the month. The SVE influent
screening concentration was measured at 21.3 ppm, which was similar to the 17.8 ppm
we measured the prior year on January 29, 2004. The cold temperatures resulted in
lower vapor pressure for the globules of gasoline trapped within the pore spaces of the
soil. The volume of gasoline recovered during the regeneration of the carbon was 7.00
gallons. As of January 28, 2005, we had recovered 616.30 gallons of gasoline from
Page 56 PENNEY ENGINEERING, INC
Recovery Well RW-1 and from regenerating the vapor phase carbon. A majority of the
gasoline was from the SVE system.
On January 27, 2005, we manually applied remedial additives to monitoring wells MW-
12 and ECS-5 located at 492 Pleasant Street. A 55-gallon drum was filled with treated
groundwater from the biodiffuser. Approximately 2.5 pounds of granular, 20-20-20
microbe nutrients and 1/8 lb of powdered Munox 10x Multiplier were dissolved in the
water. One gallon of liquid surfactant was added to each well. Then a small, battery-
powdered pump was used to transfer approximately 150 gallons of the remedial
additives solution into each well. A drum of remedial additive solution was also
prepared as previously described with 15 lbs of 20-20-20 microbe nutrients and setup to
be injected onto the clearwell over an eight-day period. We also added ¼ lb of
powdered Munox 10x Multiplier to the clearwell.
On January 28, 2005, we cleaned the biodiffuser. Both systems were shutdown for
approximately six hours. Before being shutdown, the recovery well pump was turned off
and the biodiffuser was allowed to air strip the groundwater for 30 minutes. The
biodiffuser was then shutdown and the treated water was pumped to the Recharge
Well. The aeration manifold was removed form the biodiffuser and cleaned with
muriatic acid. The 1/8” air holes in the spargers were redrilled to remove the iron
precipitate. Approximately 30 gallons of silt and iron precipitate were removed from the
biodiffuser and stored in a 55-gallon drum in the treatment trailer to prevent freezing.
The biodiffuser was reassembled and both systems were restarted.
In February 2005, the treatment systems continued to operate continuously, except for
brief shutdowns for repairs, maintenance and regeneration of the vapor phase carbon.
They were inspected on February 5 and 19, as shown on the corresponding monitoring
logs. The groundwater flowrate was not recorded. The SVE system was not screened
in February because the carbon did not need to be regenerated.
In March 2005, the treatment systems continued to operate continuously, except for
brief shutdowns for repairs, maintenance and regeneration of the vapor phase carbon.
They were inspected on March 2, 4, 12 and 24, as shown on the corresponding
monitoring logs. The groundwater flowrate ranged from 1.5 to 2.0 gpm during the
month. As of March 24, 2005, a total of 1,504,165 gallons of groundwater had been
treated. The SVE system was screened on March 2, 4, and 24. The SVE influent
screening concentrations were measured at 15.7, 10.5 and 13.5 ppm, respectively. The
SVE influent screening concentration was measured at 39.7 ppm last year on March 17,
2004. The cold temperatures resulted in lower vapor pressure from the globules of
Page 57 PENNEY ENGINEERING, INC
gasoline trapped within the pore spaces of the soil. The volume of gasoline recovered
during the March 4 regeneration of the carbon was 6.50 gallons. Last year on March 11
and 25, 2004, the regenerations of the carbon yielded 13.0 and 14.0 gallons of gasoline,
respectively. The amount of gasoline recovered had decreased by approximately 52%.
As of March 4, 2005, we had recovered 622.80 gallons of gasoline from Recovery Well
RW-1 and from regenerating the vapor phase carbon. Only a total 11.25 gallons of the
gasoline was recovered from RW-1.
On March 2, 2005, we applied remedial additives to monitoring wells MW-12 and ECS-5
located at 492 Pleasant Street. On March 24 we began to periodically apply remedial
additives to wells MW-2A, MW-10, MW-12, and ECS-5. A 55-gallon drum was filled
with treated groundwater from the biodiffuser. Approximately 2.5 pounds of granular,
20-20-20 microbe nutrients and 1/8 lb of powdered Munox 10x Multiplier were dissolved
in the water. One gallon of liquid surfactant was added to each well. Then a small,
battery-powdered pump was used to transfer approximately 25 gallons of the remedial
additives solution into each well. A drum of remedial additive solution was also
prepared as previously described with 15 lbs of 20-20-20 microbe nutrients and setup to
be injected onto the clearwell over an eight-day period. We also added ¼ lb of
powdered Munox 10x Multiplier to the clearwell.
On March 24, 2005, we collected samples of the influent and effluent from the
groundwater treatment system along with groundwater from monitoring wells MW-1,
MW-2A, MW-9, MW-10, MW-12 and ECS-5 according to DEP procedures. The
samples were transported to Groundwater Analytical under chain-of-custody protocol.
The seven groundwater samples were analyzed for VPHs by the DEP method. A
summary of the influent and the effluent results are shown in Table Twenty-Four, along
with the removal rates and the applicable GW-3 cleanup standards. The results for the
compounds detected in the six wells are summarized and compared to the applicable
GW-2 or GW-3 cleanup standards in Table Twenty-Five. The influent and wells MW-10,
MW-12 and ECS-5 were also analyzed for nitrates and nitrites. The influent, MW-1,
MW-2A, MW-9, MW-10, MW-12 and ECS-5 were analyzed for heterotrophic bacteria.
We wanted to evaluate the biological activity in the groundwater. We also inspected
nine wells for gasoline and measured the dissolved oxygen, pH and temperature in the
influent, effluent, MW-1, MW-2A, MW-5, MW-7, MW-8, MW-9, MW-10, MW-12, and
ECS-5. A gasoline sheen was observed in wells MW-1, MW-9, MW-10 and MW-12.
Wells MW-1, MW-2A, MW-9, MW-10, and MW-12 had an odor of gasoline. The
measurements and our normal ranges are listed in Table Twenty-Six included in the
Figures section. A copy of the laboratory analysis report is included in Appendix C.
Page 58 PENNEY ENGINEERING, INC
TABLE TWENTY-FOUR
Removal Rates
March 24, 2005
(Flowrate: 2.0 gpm)
Parameters
Influent
Effluent
Percent
Removal
Cleanup
Standards
GW-3
VPH (mg/l)
C5 – C8 aliphatics 4,000 <20 99.9 4,000
C9 – C12 aliphatics 590 <20 98.3 20,000
C9 – C10 aromatics 4,700 <20 99.8 4,000
Target VOCs (mg/l)
MTBE <125 <5 UK 50,000
Benzene 2,100 2 99.9 7,000
Toluene 4,400 6 99.9 50,000
Ethylbenzene 780 <5 99.7 4,000
Xylenes 3,700 <5 99.9 50,000
Naphthalene 210 <5 98.8 6,000
UK – Unknown
As shown in bold in Table Twenty-Four, the C9–C10 aromatics fractions remained
slightly above the applicable GW-3 cleanup standards in the influent. Only relatively low
concentrations were detected in the effluent. At a flowrate of 2.0 gpm, the biodiffuser
continued to remove at least 98.3% of the contaminants.
TABLE TWENTY-FIVE
Summary of Groundwater Results
March 24, 2005
MW-1
Cleanup Standards
Parameters
MW-9 MW-10 MW-12 ECS-5
GW-2 GW-3
(Applicable Standard) (GW-2) (GW-3) (GW-3) (GW-3) (GW-2)
VPHs (mg/l)
C5–C8 aliphatics 3,100 14,000 16,000 940,000 <2,000 1,000 4,000
C9–C12 aliphatics 2,100 <2,000 <4,000 400,000 <2,000 1,000 20,000
C9–C10 aromatics 21,000 12,000 13,000 700,000 <2,000 5,000 4,000
Target VOCs (mg/l)
MTBE <50 560 <1,000 <50,000 <500 50,000 50,000
Benzene 58 5,500 5,600 <10,000 <100 2,000 7,000
Toluene 740 24,000 37,000 54,000 <500 6,000 50,000
Ethylbenzene 410 2,700 3,800 <50,000 <500 30,000 4,000
Xylenes 5,900 15,000 22,400 217,000 <500 6,000 50,000
Naphthalene 470 780 <1,000 <50,000 <500 6,000 6,000
Page 59 PENNEY ENGINEERING, INC
As shown in bold in Table Twenty-Five, a majority of the VPH fractions were above the
applicable GW-2 and GW-3 cleanup standards in four wells. Well ESC-5 had a high
detection limit, which was above some of the GW-2 cleanup standards. The results for
MW-12, located at 492 Pleasant Street, had significantly increased due to the periodic
addition of surfactant beginning on December 9, 2004. On September 19, 2003, we last
observed four-inches of free-phase gasoline in MW-12 indicating that the soil
surrounding the well was saturated with gasoline. The results for wells MW-1, MW-9
and MW-10 were similar to the previous results.
As shown in Table Twenty-Six in the figures section, the dissolved oxygen was high in
the effluent as expected for aerated water, but it was also high in the influent indicating
that the groundwater between the Recharge Well and Recovery Well RW-1 was highly
oxygenated. The dissolved oxygen in all the wells was relatively high, partially due to
the spring thaw. The results for the influent may indicate short-circuiting of the recharge
water or consumption of oxygen by bacteria. The pH of all the wells except MW-2A was
similar. Well MW-2A is located in the former tank area at 480 Pleasant Street. The
bacteria counts in MW-12 and ESC-5 were very high due to the periodic addition of
remedial additives. The high counts indicated that enhanced bioremediation was
occurring. Nitrate and nitrite were detected at low concentrations in the influent and
MW-10 as a result of our beginning to inject microbe nutrients into the discharge water.
Compared to the influent, the nitrate and nitrite concentrations were very high in MW-12
and ESC-5 due to the addition of remedial additives.
In April 2005, the treatment systems continued to operate continuously, except for brief
shutdowns for repairs, maintenance and regeneration of the vapor phase carbon. They
were inspected on April 6, 12 and 26, as shown on the corresponding monitoring logs.
On April 12 the biodiffuser and the SVE systems were shutdown because water was
being drawn into the moisture separator. On April 26 the biodiffuser was restarted. The
groundwater flowrate ranged from 2.0 to 5.0 gpm during the month. As of April 6, 2005,
a total of 1,528,519 gallons of groundwater had been treated. The SVE system was
only screened on April 6 during a regeneration of the carbon. The SVE influent
screening concentration was measured at 5.5 ppm. The cold temperatures resulted in
lower vapor pressure from the globules of gasoline trapped within the pore spaces of
the soil. The volume of gasoline recovered during the April 6 regeneration of the carbon
was 7.25 gallons. As of April 6, 2005, we had recovered 630.05 gallons of gasoline
from Recovery Well RW-1 and from regenerating the vapor phase carbon. Only a total
of 11.25 gallons of the gasoline was recovered from RW-1.
Page 60 PENNEY ENGINEERING, INC
On April 6, 2005, we manually applied remedial additives to monitoring wells MW-2A,
MW-10, MW-12 and ECS-5. A 55-gallon drum was filled with treated groundwater from
the biodiffuser. Approximately 2.5 pounds of granular, 20-20-20 microbe nutrients and
1/8 lb of powdered Munox 10x Multiplier were dissolved in the water. One gallon of
liquid surfactant was added to each well. Then a small, battery-powdered pump was
used to transfer approximately 18 gallons of the remedial additives solution into each
well. A drum of remedial additive solution was also prepared as previously described
with 15 lbs of 20-20-20 microbe nutrients and setup to be injected onto the clearwell
over an eight-day period. We also added ¼ lb of po wdered Munox 10x Multiplier to the
clearwell.
In May 2005, the treatment systems continued to operate continuously, except for brief
shutdowns for repairs, maintenance and regeneration of the vapor phase carbon. They
were inspected on May 2, 3, 5, 8, 11, 12, 16, 17, 23, and 25, as shown on the
corresponding monitoring logs. On May 2 the SVE system was restarted with the
dilution valve slightly open to prevent water from the very high groundwater table from
being drawn into the moisture separator. The groundwater flowrate ranged from 4.0 to
3.0 gpm during the month. As of May 23, 2005, a total of 1,676,637 gallons of
groundwater had been treated. The SVE system was only screened on May 17 during
a regeneration of the carbon. The SVE influent screening concentration was measured
at 8.3 ppm. The concentration was much lower than the 25.1 ppm detected last year on
May 24, 2004. The volume of gasoline recovered during the May 17 regeneration of the
carbon was 7.25 gallons. As of May 17, 2005, we had recovered 637.30 gallons of
gasoline from Recovery Well RW-1 and from regenerating the vapor phase carbon.
Only a total of 11.25 gallons of the gasoline was recovered from RW-1.
On May 17, 2005, we manually applied remedial additives to monitoring wells MW-2A,
MW-10, MW- 12 and ECS-5. A 55-gallon drum was filled with treated groundwater from
the biodiffuser. Approximately 2.5 pounds of granular, 20-20-20 microbe nutrients and
1/8 lb of powdered Munox 10x Multiplier were dissolved in the water. One gallon of
liquid surfactant was added to each well. Then a small, battery-powdered pump was
used to transfer approximately 15 gallons of the remedial additives solution into each
well. A drum of remedial additive solution was also prepared as previously described
with 15 lbs of 20-20-20 microbe nutrients and setup to be injected onto the clearwell
over an eight-day period. We also added ¼ lb of po wdered Munox 10x Multiplier to the
clearwell.
On May 23, 2005, we cleaned the biodiffuser. Both systems were shutdown for
approximately six hours. Before being shutdown, the recovery well pump was turned off
Page 61 PENNEY ENGINEERING, INC
and the biodiffuser was allowed to airstrip the groundwater for 30 minutes. The
biodiffuser was then shutdown and the treated water was pumped to the Recharge
Well. The aeration manifold was removed form the biodiffuser and cleaned with
muriatic acid. The 1/8” air holes in the spargers were redrilled to remove the iron
precipitate. Approximately 30 gallons of silt and iron precipitate were removed from the
biodiffuser and stored in a 55-gallon drum in the fenced area. The biodiffuser was
reassembled and restarted. The SVE blower could not be restarted because it kept
tripping the circuit breaker.
In June 2005, the treatment systems continued to operate continuously, except for brief
shutdowns for repairs, maintenance and regeneration of the vapor phase carbon. They
were inspected on June 2, 3, 7, 11, 13, and 29, as shown on the corresponding
monitoring logs. The groundwater flowrate ranged from 2.25 to 1.0 gpm during the
month. As of June 29, 2005, a total of 1,748,188 gallons of groundwater had been
treated. On June 13 a rebuilt SVE blower was installed and the SVE system was
restarted. The dilution valve had to be left partially open to prevent water from being
drawn into SVE Zone-A. The SVE system was screened on May 13 and 29. The SVE
influent screening concentrations were measured at 6.0 and 25.2 ppm, respectively.
The concentrations were about the same as detected last year. The volume of gasoline
recovered during the May 29 regeneration of the carbon was 6.75 gallons. As of June
29, 2005, we had recovered 644.05 gallons of gasoline from Recovery Well RW-1 and
from regenerating the vapor phase carbon. Only a total of 11.25 gallons of the gasoline
was recovered from RW-1.
On June 13, 2005, we collected samples of the influent and effluent from the
groundwater treatment system along with groundwater from monitoring wells MW-1,
MW-2A, MW-9, MW-10, MW-12 and ECS-5 according to DEP procedures. The eight
samples were transported to Groundwater Analytical under chain-of-custody protocol.
Only six of the groundwater samples were analyzed for VPHs by the DEP method. The
samples from MW-12 and ECS-5 could not be purged due to foaming caused by the
surfactant that had been periodically applied to those wells. A summary of the influent
and the effluent results are shown in Table Twenty-Seven along with the removal rates
and the applicable GW-3 cleanup standards. The results for the compounds detected in
the four wells are summarized and compared to the applicable GW-2 or GW-3 cleanup
standards in Table Twenty-Eight. The influent and wells MW-10 and ECS-5 were also
analyzed for nitrates and nitrites. The influent, MW-2A, MW-9, MW-10, MW-12 and
ECS-5 were analyzed for heterotrophic bacteria to evaluate the biological activity in the
groundwater. We also inspected nine wells for gasoline and measured the dissolved
Page 62 PENNEY ENGINEERING, INC
oxygen, pH and temperature in the influent, effluent, MW-1, MW-2A, MW-5, MW-7, MW-
8, MW-9, MW-10, MW-12, and ECS-5. No gasoline sheen was observed in any of the
wells. Wells MW-1, MW-2A, MW-8, MW-9, and MW-10 had an odor of gasoline. The
measurements and our normal ranges are listed in Table Twenty-Nine, included in the
Figures section. A copy of the laboratory analysis report is included in Appendix C.
TABLE TWENTY-SEVEN
Removal Rates
June 13, 2005
(Flowrate: 2.0 gpm)
Parameters
Influent
Effluent
Percent
Removal
Cleanup
Standards
GW-3
VPH (mg/l)
C5 – C8 aliphatics 4,000 <20 99.8 4,000
C9 – C12 aliphatics 710 22 UK 20,000
C9 – C10 aromatics 3,600 <20 99.7 4,000
Target VOCs (mg/l)
MTBE <125 <5 UK 50,000
Benzene 1,500 <1 99.9 7,000
Toluene 3,000 <5 99.9 50,000
Ethylbenzene 530 <5 99.5 4,000
Xylenes 2,650 <5 99.9 50,000
Naphthalene 180 <5 98.6 6,000
UK – Unknown
As shown in bold in Table Twenty-Seven, all the VPH fractions and target VOCs were
below the applicable GW-3 cleanup standards in the influent. Only relatively low
concentration of the C9 – C12 aliphatics was detected in the effluent. At a flowrate of 2.0
gpm, the biodiffuser continued to remove at least 98.6% of the contaminants.
Page 63 PENNEY ENGINEERING, INC
TABLE TWENTY-EIGHT
Summary of Groundwater Results
June 13, 2005
MW-1
MW-2A
Cleanup Standards
Parameters
MW-9 MW-10
GW-2 GW-3
(Applicable Standard) (GW-2) (GW-2) (GW-3) (GW-3)
VPHs (mg/l)
C5–C8 aliphatics 260 1,700 20,000 16,000 1,000 4,000
C9–C12 aliphatics 1,300 1,100 <2,000 <5,000 1,000 20,000
C9–C10 aromatics 17,000 1,300 15,000 20,000 5,000 4,000
Target VOCs (mg/l)
MTBE <50 <250 <500 <1,250 50,000 50,000
Benzene <10 730 5,200 3,100 2,000 7,000
Toluene 73 1,600 21,000 38,000 6,000 50,000
Ethylbenzene 96 270 3,100 3,500 30,000 4,000
Xylenes 3,600 1,440 16,200 24,900 6,000 50,000
Naphthalene 590 <250 720 <1,250 6,000 6,000
As shown in Table Twenty-Eight, the results for MW-1 had decreased from the previous
results. That well is clearly in the area being remediated by the groundwater treatment
system. The results for the other three wells were about the same as the previous
results. It was unfortunate that the samples from MW-12 and ECS-5 could not be
analyzed due to the foaming caused by the surfactant. The results for the target VOCs
were all below the applicable GW-2 and GW-3 cleanup standards in all four wells.
As shown in Table Twenty-Nine in the figures section, the dissolved oxygen was high in
the effluent as expected for aerated water. The dissolve oxygen in all the wells was
slightly elevated. The pH of the effluent was high, which may have been cause by the
surfactant we have been periodically applying to MW -10. The bacteria counts in the
wells continued to increase, which indicated that enhanced bioremediation was
occurring. The counts remained very high in MW-12 and ECS-5. Nitrate and nitrite
were detected in the influent and MW-10 as a result of our injecting microbe nutrients
into the clearwell of the biodiffuser. They were also detected in ECS-5 relatively high.
On June 29, 2005, we manually applied remedial additives to monitoring wells MW-2A,
MW-10, and MW- 12. We no longer applied remedial additives into well ECS-5. A 55-
gallon drum was filled with treated groundwater from the biodiffuser. Approximately 2.5
pounds of granular, 20-20-20 microbe nutrients and 1/8 lb of powdered Munox 10x
Page 64 PENNEY ENGINEERING, INC
Multiplier were dissolved in the water. One gallon of liquid surfactant was added to
each well. Then a small, battery-powdered pump was used to transfer approximately
18 gallons of the remedial additives solution into each well. A drum of remedial additive
solution was also prepared as previously described with 15 lbs of 20-20-20 microbe
nutrients and setup to be injected onto the clearwell over an eight-day period. We also
added ¼ lb of powdered Munox 10x Multiplier to the clearwell.
In July 2005, the treatment systems continued to operate continuously, except for brief
shutdowns for repairs, maintenance and regeneration of the vapor phase carbon. They
were inspected on July 10, 13, 17, 25, and 30, as shown on the corresponding
monitoring logs. The groundwater flowrate ranged from 1.0 to 2.0 gpm during the
month. As of July 13, 2005, a total of 1,755,894 gallons of groundwater had been
treated. The dilution valve had to be left partially open to prevent water from being
drawn into SVE Zone-A. The SVE system was screened on July 13 and 30. The SVE
influent screening concentrations were measured at 22.9 and 22.4 ppm, respectively.
The concentrations were about half of what was detected last year. The volume of
gasoline recovered during the July 29 regeneration of the carbon was 6.75 gallons. As
of July 29, 2005, we had recovered 650.80 gallons of gasoline from Recovery Well RW-
1 and from regenerating the vapor phase carbon. Only a total of 11.25 gallons of the
gasoline was recovered from RW-1.
On July 13, 2005, we manually applied remedial additives to monitoring wells MW-2A,
MW-10, and MW- 12. A 55-gallon drum was filled with treated groundwater from the
biodiffuser. Approximately 2.5 pounds of granular, 20-20-20 microbe nutrients and 1/8
lb of powdered Munox 10x Multiplier were dissolved in the water. One gallon of liquid
surfactant was added to each well. Then a small, battery-powdered pump was used to
transfer approximately 18 gallons of the remedial additives solution into each well. A
drum of remedial additive solution was also prepared as previously described with 15
lbs of 20-20-20 microbe nutrients and setup to be injected onto the clearwell over an
eight-day period. We also added ¼ lb of powdered Munox 10x Multiplier to the
clearwell.
In August 2005, the treatment systems continued to operate continuously, except for
brief shutdowns for repairs, maintenance and regeneration of the vapor phase carbon.
They were inspected on August 3, 5, 16, 22, 25, and 30, as shown on the
corresponding monitoring logs. The groundwater flowrate ranged from 2.0 to 1.0 gpm
during the month. As of August 22, 2005, a total of 1,804,911 gallons of groundwater
had been treated. The dilution valve remained partially open to prevent water from
being drawn into SVE Zone-A. The SVE system was screened on August 22. The SVE
Page 65 PENNEY ENGINEERING, INC
influent screening concentration was measured at 27.4 ppm. The concentration was
much less than the 40.2 ppm that was detected last year on August 20, 2004. The
volume of gasoline recovered during the August 22 regeneration of the carbon was
12.00 gallons. As of August 29, 2005, we had recovered 673.30 gallons of gasoline
from Recovery Well RW-1 and from regenerating the vapor phase carbon. Only a total
of 11.25 gallons of the gasoline was recovered from RW-1.
On August 3 and 22, 2005, we manually applied remedial additives to monitoring wells
MW-2A, MW-10, and MW- 12. A 55-gallon drum was filled twice with approximately 75
gallons of treated groundwater from the biodiffuser. Approximately 2.5 pounds of
granular, 20-20-20 microbe nutrients and 1/8 lb of powdered Munox 10x Multiplier were
dissolved in the water. One gallon of liquid surfactant was added to each well. Then a
small, battery-powdered pump was used to transfer approximately 25 gallons of the
remedial additives solution into each well. A drum of remedial additive solution was
also prepared as previously described with 15 lbs of 20-20-20 microbe nutrients and
setup to be injected onto the clearwell over an eight-day period. We also added ¼ lb of
powdered Munox 10x Multiplier to the clearwell.
In order to evaluate the effectiveness of the SVE and the groundwater treatment
systems at 459 Pleasant Street, we reviewed our monitoring results. To evaluate the
SVE system, we reviewed the influent screening concentrations, the volume of gasoline
recovered during each regeneration of the vapor phase carbon, the elevation of the
groundwater table, and the duration between breakthroughs of the carbon.
The initial SVE influent concentration on September 9, 2003 was 121.0 ppm. After the
first month of operation it had decreased to 95.0 ppm on October 7, 2003. During the
next two months it decreased further to 60.2 ppm on November 5 and 39.7 ppm on
December 2, 2003. On January 12, 2004, it had decreased to 13.1 ppm. On February
12, 2004, it had increased slightly to 18.3 ppm. By February 26, 2004, it had risen to
22.9 ppm. The increase was attributed to the dropping of the groundwater table
allowing more contaminated soil to be exposed and vented by the SVE system. It
continued to rise to 32.1 ppm on March 25, 2004 and then began to decrease as the
groundwater table rose in the spring. On May 24, 2004, the SVE system influent
screening concentration began to rise with the summertime drop of the groundwater
table. As a result, the quantity of gasoline we recovered during each regeneration also
increased to 11 gallons. On August 16, 2004, the influent peaked at 43.7 ppm and we
recovered 14 gallons of gasoline. So after one year of operating the SVE system, the
influent had decreased from 121.0 to 43.7 ppm. As of August 31, 2004, we had
recovered a total of 11.25 gallons of gasoline by manually bailing from Recovery Well
Page 66 PENNEY ENGINEERING, INC
RW-1 and 465.30 gallons from regenerating the vapor phase carbon. Clearly, a
majority of the recovered gasoline came from the SVE system. That was a substantial
amount in one year, considering that a majority of the recovered gasoline originated as
gasoline vapors drawn from the pore spaces of the soil and because of the very low
intrinsic permeability of the soil.
From September 7, 2004 until January 27, 2005, the SVE system influent decreased
from 41.1 to 21.3 ppm. We also recovered an additional 139.75 gallons of gasoline
during the period. On March 4, 2005, the SVE influent concentration had decreased to
10.5 ppm and we only recovered 6.50 gallons of gasoline although the system had
operated for 36 days. On April 6, 2005, the influent further decreased to 5.5 ppm, and
we recovered 7.25 gallons of gasoline after 32 days of operation. On May 17, 2005, the
groundwater table was dropping, the SVE influent rose to 41.0 ppm and 7.25 gallons of
gasoline was recovered after 41 days of operation. In July and August 2005, the
groundwater table continued to drop exposing the gasoline globules trapped in the
previously submerged soil. The amount of gasoline recovered increased and the
duration decreased to 14, 21 and 19 days. Last year the durations were 13, 9, 7, 6, 6,
7, 4, 5 and 6 for the same two months. The amount of gasoline recovered was slightly
more. The increased duration means that the volume of gasoline trapped in the pores
spaces has greatly decreased. We shall begin to plot the ratio of gasoline recovered to
duration over time.
The SVE system influent concentrations, the volumes of gasoline recovered during
each regeneration and the number of days between each regeneration have been
plotted on Charts One, Two, Three and Four, included in the Figures section. Charts
Three and Four also show the elevation of the groundwater table in well MW-5, located
east of the office building at 459 Pleasant Street. The amount of gasoline recovered
during regeneration is a direct indicator of the effectiveness of the SVE system. Chart
Three also shows that the rising groundwater table decreased the SVE system influent
concentration and the volume of gasoline we recovered but increase the duration
between regenerations of the carbon. That response indicates that there were still
globules of gasoline remaining in the pore spaces of the soil in the smear zone at the
groundwater table. Chart Four shows that the falling groundwater table increased the
SVE system influent concentration and the volume of gasoline we recovered but
decreased the duration between regenerations. In summary, the soil at 459 Pleasant
Street was highly contaminated with gasoline and the SVE system has been very
effective at removing it. It may also be removing gasoline that has been drawn back to
Page 67 PENNEY ENGINEERING, INC
Recovery Well RW-1 from under the adjacent section of Pleasant Street and the
properties at 480 and 492 Pleasant Street.
In order to evaluate the effect of the groundwater treatment system, we monitored the
presence of free-phase gasoline, developed a plan of the groundwater elevation
contours in order to determine the zone of influence of the Recovery Well RW-1, and
conducted quarterly sampling of specific wells. Since April 25, 2002, we routinely
observed free-phase gasoline in wells MW-1, MW-9, MW-10, MW-12 and ECS-5. On
September 19, 2003, we observed four-inches of free-phase gasoline in well MW-12.
On November 11, 2003, after staring the SVE system on September 12, 2003, we
gauged nine monitoring wells at the site to measure the depth to groundwater and
inspect for the presence of free-phase gasoline. W e also gauged Recovery Well RW-1
and the Recharge Well. No free-phase gasoline was observed in any of the wells, but a
sheen was observed in RW-1 and MW-10. Wells MW-1, RW-1, MW-9, MW-10, MW-12,
ECS-5 and MW-2A had a gasoline odor. On June 16, 2004, we only observed a sheen
in wells MW-9, 10, and 12. On September 21, 2004, we only observed a sheen in wells
MW-9, 10, 12 and ECS-5. On December 9, 2004, we only observed a sheen in wells
MW-1, 9, 10, 12 and ECS-5. The depth to groundwater measurements were used to
determine the elevation of the groundwater table at each well. We plotted the resulting
groundwater contours on the Groundwater Contour Plan included in the Figures section.
Although the data was limited, the contours showed that the influence of the
groundwater treatment system was limited to the 459 Pleasant Street, the adjacent
section of Pleasant Street and potentially the western extent of the properties at 480
and 492 Pleasant Street. Recovery well RW-1 was not significantly affecting the
groundwater at 480 Pleasant Street. The groundwater was being circulated between
the Recharge Well and Recovery Well RW-1. As shown on Figure Two, on April 25,
2002 the groundwater table at the site was relatively flat. The elevation only decreased
from approximately 90.15 to 89.75 feet across the site. On November 11, 2003,
Recovery Well RW-1 had created a drawdown of approximately one-foot, which is
expected to greatly affect the groundwater over a large area in the low permeability soil
at the site. As shown on the large Remedial Action Site Plan, the installation of
Recovery Well RW-2 would allow the groundwater treatment system to circulate treated
groundwater through the contaminant plume that is shown on Figures One and Two.
In order to evaluate the effect of the groundwater treatment system, we also tabulated
and plotted the quarterly monitoring results for the influent from Recovery Well RW-1.
Influent results are normally a better indicator of the overall groundwater conditions
because the water is actively being drawn from a large area, as opposed to a
Page 68 PENNEY ENGINEERING, INC
monitoring well that is one stagnant point. The results are summarized and compared
to the applicable GW-3 cleanup standards in Table Thirty, included in the Figures
section. The results for the C5-C8 aliphatics and the C9-C10 aromatics fractions are
plotted in Chart Five also included in the Figures section. The 4,000 ug/l GW-3 cleanup
standard, which is common to both fractions, is also plotted.
As shown in Table Twenty-Four, the treatment system reduced the two VPH fractions
by 50% between June 25 and September 22, 2003 and by 65% between September 22
and December 18, 2003. From December 18, 2003 to June 13, 2005, the influent
concentrations have remained relatively constant, which indicates that gasoline was
being drawn in Recovery Well RW-1. The reductions are more apparent in Chart Five.
The influent concentrations only slightly increased with the springtime rise of the
groundwater table which indicated that the soil within the zone of influence was being
remediated. No further reductions can occur until all the globules of free-phase
gasoline are removed from the pore spaces of the contaminated soil by the SVE
system. The installation of Recovery Well RW-2 at 480 Pleasant Street would greatly
increase the radius of the groundwater treatment system and force the aerated, nutrient
rich discharge water to move through the contaminant plume under Pleasant Street. It
would also allow us to periodically alternate the flow patterns between the Recharge
Well and the two recovery wells.
In order to evaluate the groundwater treatment system, we also tabulated the quarterly
monitoring results for well MW-9, which is located east of Recovery Well RW-1. The
results are shown in Table Thirty-One, included in the Figures section. As shown, the
results decreased since we activated the groundwater treatment system on June 25,
2004 until September 21, 2004 when there was a dramatic increase. The results for the
C5-C8 aliphatics and the C9-C10 aromatics are plotted in Chart Six, included in the
Figures section. The plotted results show the dramatic increase. The results indicate
that the groundwater in the area of MW-9 was re-contaminated sometime between our
June 16 and September 21, 2004 sampling. The increase may have been caused by
free-phase gasoline being drawn back to the Recovery Well RW-1 from under and
across Pleasant Street during the low, summertime level of the groundwater table.
In order to evaluate the groundwater treatment system, we also tabulated the quarterly
monitoring results for well MW-10, which is located in the southern curbcut along 459
Pleasant Street, downgradient of the area between Recovery Well RW-1 and the
Recharge Well. The results are shown in Table Thirty-Two, included in the Figures
section. As shown, the results have remained relatively the same since we activated
the groundwater treatment system on June 25, 2003. The results for the C5-C8
Page 69 PENNEY ENGINEERING, INC
aliphatics and the C9-C10 aromatics are plotted in Chart Seven, included in the Figures
section. The plotted results show a slight increase in the Spring of 2004 followed by a
gradual decrease. The results indicate that the groundwater treatment system has had
very little affect on the groundwater around well MW-10. The results may also indicate
that the gasoline contamination is being partially drawn back to toward Recovery Well
RW-1 from under and across Pleasant Street. The contamination being detected in
MW-10 shall not decrease until gasoline is no longer being drawn to Recovery Well
RW-1 from under Pleasant Street. On March 24, 2005, we began to apply remedial
additives the MW-10. The dramatic increase of the subsequent, June 13, 2005 result
was caused by the surfactant dissolving the gasoline trapped in the surrounding soil.
In order to evaluate the groundwater treatment system, we also tabulated the
temperature and the dissolved oxygen measurements of the groundwater from specific
wells along with the influent and the effluent from the treatment system. The
measurements for March 18 and June 16, 2004 are listed in Tables Fourteen and
Seventeen in the Figures section of the report. The subsequent measurements are
shown in Tables Twenty, Twenty-Three, Twenty-Six and Twenty-Nine. The dissolved
oxygen (DO) results in the tables show that the treatment system is drawing in
groundwater from Recovery Well RW-1 with a very high DO concentration and
discharging the aerated water to the Recharge Well at higher concentrations. A cold,
mountain stream has the highest DO content of 9.0 mg/l, so the biodiffuser is doing a
great job of aerating the water to enhance aerobic bacteria to metabolize the gasoline
contamination. It is a different story with the wells. The DO content from all the
monitoring wells is within our normal range of 1.0 to 3.0 mg/l. The DO results indicate
that the discharged groundwater may have developed channels and is flowing directly
back to recovery well RW-1. We had determined that the recharged groundwater may
be short-circuiting by flowing through channels or the more permeable layer of medium
to coarse sand beginning at a depth of 14 feet. This is one more reason to install a
second Recovery Well.
Since April 25, 2002, we routinely observed free-phase gasoline in wells MW-1, MW-9,
MW-10, MW-12 and ECS-5. On September 19, 2003, we observed four-inches of free-
phase gasoline in well MW-12. On June 16, 2004, we only observed a sheen in wells
MW-9, 10, and 12. On September 21, 2004, we only observed a sheen in wells MW-9,
10, 12 and ECS-5. On December 9, 2004, we only observed a sheen in wells MW-1, 9,
10, 12 and ECS-5. On March 24, 2005, we observed a sheen in MW-1, MW-7, MW-10
and MW-12. On June 13, 2005, there was no sheen in any of the wells. The current
SVE system may have removed a majority of the free-phase gasoline from both sides of
Page 70 PENNEY ENGINEERING, INC
Pleasant Street. A third SVE located along the 492 and 480 sides of Pleasant Street
would allow any remaining free-phase gasoline to be vented from the pore spaces of
the soil. The effects of the bioremediation shall not be apparent until the free-phase
gasoline has been removed.
Everyone has assumed that the source of the gasoline release was limited to the tanks
and dispensers at 459 Pleasant Street. The former tanks and piping at 480 Pleasant
Street may have been a second source. There may also have been additional tanks
that supplied the former dispensers along Conz Street.
On March 18, 2004, we analyzed the influent from Recovery Well RW-1 for biochemical
parameters. We found that the counts of naturally occurring heterotrophic bacteria was
very high at 15,000 cfu/ml. However, no nitrogen or phosphorous was detected. Most
bacteria require nitrogen and phosphorous. On September 21, 2004, we began
continuously injecting liquid fertilizer into the discharge water, as previously described.
On March 18, 2004, we began to monitor the bacteria counts in specific wells. The
counts are shown in Tables Thirteen, Fourteen, Seventeen, Twenty, Twenty-Three,
Twenty-Six and Twenty-Nine. High bacteria counts generally indicate high biological
activity associated with the bioremediation of contaminants. The counts have greatly
increased since we began injecting microbe nutrients into the biodiffuser and applying
remedial additives to specific wells. Tables Twenty-Six and Twenty-Nine show the most
recent counts. The three wells across Pleasant Street, MW-2A, MW-12 and ECS-5,
had bacteria counts over one million. The counts indicate that the remedial additives
are effectively bioremediating the petroleum contamination in the area of the wells.
The treatment system shall continue to be operated in accordance with our August 2002
Phase III/IV Remedial Action and Remedy Implementation Plan, the Phase IV
Performance Standards, described in 310 CMR 40.0872, and the Response Action
Performance Standards, as defined in 310 CMR 40.0191, until the significant risk has
been reduced and the conditions for a Class A-2 Response Action Outcome have been
achieved. Remedial additives, including microbe nutrients and specific bacteria, shall
be injected into the biodiffuser and manually applied to specific wells. We shall continue
to conduct quarterly monitoring of the groundwater. We shall also sample the
contaminated soil to insure that it has been adequately remediated. We shall also
continue to attempt to evaluate the potential worker exposure to the indoor air in
Building A. A fifth Phase V Inspection and Monitoring Report shall be submitted to the
DEP before the March 15, 2006 deadline. We shall submit a fourth Tier II Extension
Request or a Remedy Operations Status Submittal before the October 20, 2005
Page 71 PENNEY ENGINEERING, INC
submission deadline. We may also conduct a subsurface investigation to determine if
there are any abandoned tanks at the site.
7.0 REMEDY OPERATION STATUS
We shall continue to evaluate the need to install the remainder of the treatment systems
with the affected property owners. We plan to achieve Remedy Operation Status once
a permanent solution is in place. We shall submit an As-Built Plan, a Final Inspection
Report and a Phase IV Completion Statement for the installation of the treatment
systems across Pleasant Street. Upon receipt of the Phase IV Completion Statement,
Remedy Operation Status shall be achieved. The annual compliance fee shall be
reduced and all the deadlines shall be suspended. The operating treatment systems at
459 and 480 Pleasant Street shall be considered to be a permanent solution for the
gasoline contamination. The systems shall be operated and maintained until the
contamination is adequately remediated to acceptable concentrations that no longer
pose a significant risk of harm to health, safety, public welfare and the environment.
Phase V Inspection and Monitoring Reports shall continue to be prepared and
submitted to the DEP every six months while the systems are operated.
8.0 PUBLIC INVOLVEMENT ACTIVITIES
There is no requirement for any public notification for the submission of this document.
In accordance 310 CMR 40.1403(3)(a), which became affective on June 27, 2003, we
orally notified the Northampton Mayor’s Office and the acting Health Agent of our
September 8 and 9, 2003 grading and paving at the site. We shall not provide
notification of the routine maintenance of the treatment systems or sampling of the wells
at the site. Emergency telephone numbers have been posted on the outside of the
treatment trailer. The Northampton Fire and Police Departments have been provided
with telephone numbers to be called for routine questions and in emergencies. We
have also provided oral and written notification of our activities to the Northampton
Mayors office and the Board of Health. Copies of the letters were previously submitted
to the DEP.
FIGURES
APPENDIX A
COMPREHENSIVE RESPONSE ACTION TRANSMITTAL FORM (BWSC-108),
APRIL 19, 2005 LETTER TO MHD AND
MAY 10, 2005 RESPONSE LETTER FROM MHD
APPENDIX B
MONITORING LOGS FROM
FEBRUARY 5, 2005 TO AUGUST 30, 2005
APPENDIX C
LABORATORY ANALYSIS REPORTS FOR THE
GROUNDWATER SAMPLES COLLECTED ON
MARCH 24, 2005 AND JUNE 13, 2005