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12th Phase V Report 3-09 Project Number 0203 PHASE V STATUS REPORT, REMEDIAL MONITORING REPORT AND ROS SUBMITTAL Pleasant Street Cleanup Project RTN: 1-0705, RFA: 09092 March 2009 PENNEY ENGINEERING, INC ENVIRONMENTAL ENGINEERS & SCIENTISTS 125 HIGH STREET MANSFIELD, MA 02048 (508) 261-1288 www.PenneyEngineering.com 0203\Phase V Reports\Twelfth Phase V Report (4/2/09) PHASE V STATUS REPORT, REMEDIAL MONITORING REPORT AND REMEDY OPERATION STATUS SUBMITTAL March 2009 Pleasant Street Cleanup Project 459, 480 & 492 Pleasant Street Northampton, MA 01060 RTN: 1-0705, RFA: 09092 Prepared For: ROBERT P. KALISH, INC 504 Lampblack Road Greenfield, MA 01301 (413) 218-8153 And CITY OF NORTHAMPTON MAYOR’S OFFICE OF ECONOMIC DEVELOPMENT 210 Main Street Northampton, MA 01060 (413) 587-1249 Prepared By: PENNEY ENGINEERING, INC 125 High Street Mansfield, MA 02048 (508) 261-1288 LSP who prepared this Phase V Status Report, Remedial Monitoring Report and Remedy Operation Status Submittal Ralph P. Penney, PE, LSP Title: President , Penney Engineering, Inc License Number: 7755 PHASE V STATUS REPORT, REMEDIAL MONITORING REPORT AND REMEDY OPERATION STATUS SUBMITTAL Pleasant Street Cleanup Project 459, 480, 492 Pleasant Street, Northampton, MA RTN: 1-0705, RFA: 09092 TABLE OF CONTENTS PAGE LIST OF ABBREVIATIONS AND ACRONYMS…………………………………………………….iv 1.0 INTRODUCTION ..............................................................................................................1 1.1 Description of Site ..................................................................................................14 2.0 SITE HISTORY ...............................................................................................................15 2.1 History of Use at the Site........................................................................................15 2.2 Current Use of the Site...........................................................................................16 3.0 NATURE AND EXTENT OF CONTAMINATION ............................................................16 3.1 Previous Assessment Activities..............................................................................16 3.2 Additional Assessment Activities............................................................................18 3.3 Extent of Free-Phase Gasoline ..............................................................................20 3.4 Extent of Soil Contamination..................................................................................20 3.5 Extent of Groundwater Contamination ...................................................................20 4.0 SUMMARY OF SITE CONDITIONS THAT WARRANTED REMEDIAL ACTIONS .......20 5.0 CONSTRUCTION OF SELECTED REMEDIAL ACTION ALTERNATIVE .....................21 5.1 Installation of Initial Treatment Systems.................................................................21 5.2 Completion of Installation of Treatment Systems...................................................25 5.3 Licenses, Permits and Approvals...........................................................................30 5.4 As-Built Construction Report..................................................................................30 5.5 Final Inspection Report ..........................................................................................30 5.6 Phase IV Completion Statement ............................................................................31 6.0 OPERATION, MAINTENANCE AND MONITORING OF THE TREATMENT SYSTEMS .......................................................................................................................31 6.1 Monitoring Plan ......................................................................................................31 6.2 Evaluation of Changes to the Applicable Regulations ............................................33 6.3 Prior Operation, Maintenance and Monitoring Activities.........................................35 6.4 Most Recent Operation, Maintenance and Monitoring Activities ............................37 6.5 Summary of Historical Results ...............................................................................47 i PENNEY ENGINEERING, INC TABLE OF CONTENTS (cont’d) PAGE 6.6 Update of the Conceptual Site Model.....................................................................55 7.0 REMEDY OPERATION STATUS OPINION ...................................................................56 8.0 PUBLIC INVOLVEMENT ACTIVITIES ...........................................................................57 FIGURES Locus Map BWSC Site Scoring Map dated March 5, 2009 Table Two – Summary of Specific 1998 Groundwater Results Table Three – Summary of Groundwater Results, April 25, 2002 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, 2002 Groundwater Contour Plan for November 11, 2003 Photographs of the installation taken in November 2008 Sampling Plan Historical Table One – Historic Summary of Groundwater Results for RW-1 Influent Historical Table Two – Historic Summary of Groundwater Results for MW-9 Historical Table Three – Historic Summary of Groundwater Results for MW-10 Historical Table Four – Historic Summary of Groundwater Results for MW-12 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 May 3, 2006 Chart Five – Plot of RW-1 Influent Results, June 25, 2003 thru March 21, 2006 Chart Six – Plot of MW-9 Results, June 25, 2003 thru March 21, 2006 Chart Seven – Plot of MW-10 Results, June 25, 2003 thru March 21, 2006 Chart Eight – Plot of MW-12 Results, December 18, 2003 thru March 21, 2006 Regression Chart One – Gasoline Recovered/Duration during Regeneration of Carbon, October 1, 2003 thru May 3, 2006 ii PENNEY ENGINEERING, INC TABLE OF CONTENTS (cont’d) APPENDICES Appendix A Comprehensive Response Action Transmittal Form (BWSC-108), CRA Remedial Monitoring Reports (BWSC-108A) for each system, Notice of Environmental Sampling (BWSC-123), copies of the current Fire Department Permit to store flammable liquids, the October 6, 2008 MHD permit to cross Route 5, the October 21, 2008 Trench Permit from the City of Northampton, the November 1, 2008 Right of Entry Authorization from the owners of the properties at 480 and 492 Pleasant Street, and the Electrical Permit received on December 13, 2008 Appendix B Monitoring Logs from December 15, 2008 to March 1, 2009 Appendix C Monitoring Well Sampling Logs and laboratory analysis reports for the groundwater samples collected on September 18, 2008, February 13, and February 28, 2009 Appendix D Laboratory analysis report for the soil samples collected on November 5, 2008 A full size, as-built Remedial Action Site Plan is included in the rear pocket. iii 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 PCA tetrachloroethane BWSC Bureau of Waste Site Cleanup PCBs polychlorinated biphenyls BWP Bureau of Waste Prevention PCE tetrachloroethene CCA chromium, copper and arsenic PCM Phase Contrast Microscopy cfu/ml colony forming units per milliliter PLM Polarized Light Microscopy CFR Code of Federal Regulations PPA Potentially Productive Aquifer CMR Code of Massachusetts Regulations ppb parts per billion cy cubic yard ppm parts per million DCE dichloroethene PRP Potentially Responsible Party DEP Department of Environmental Protection RAM Release Abatement Measure DHHS Department of Health and Human Services RCRA Resource Conservation Recovery Act EDB ethylene dibromide RFI Request for Information EPA Environmental Protection Agency RNF Release Notification Form EPHs extractable petroleum hydrocarbons ROS Remedy Operation Status gpd gallons per day RP Responsible Party gpm gallons per minute RTN Release Tracking Number IRA Immediate Response Action sf square feet LRA Limited Removal Action SVOCs semi-volatile organic compounds LSP Licensed Site Professional TCA trichloroethane MCP Massachusetts Contingency Plan TCE trichloroethene MEK 2-butanone TECs Threshold Effects Concentrations mg/kg milligrams per kilogram TEL Threshold Effect Exposure Limit mg/l milligrams per liter TEM Transmission Electron Microscopy iv PENNEY ENGINEERING, INC LIST OF ABBREVIATIONS AND ACRONYMS (cont’d) THF tetrahydrofuran ug/m3 micrograms per cubic meter TOC total organic carbon UIC Underground Injection Control TPHs total petroleum hydrocarbons USGS United States Geologic Survey TSCA Toxic Substance Control Act UST underground storage tank TWA time weighted average UTM Universal Transverse Mercator TVOCs total volatile organic compounds VOCs volatile organic compounds ug/l micrograms per liter VPHs volatile petroleum hydrocarbons v PENNEY ENGINEERING, INC 1.0 INTRODUCTION On behalf of Robert P. Kalish, Inc and the City of Northampton, Penney Engineering, Inc hereby submits this twelfth Phase V Status Report, Remedial Monitoring Report and Remedy Operation Status Submittal for the remediation of the gasoline contamination in the area of the former Staab’s Service Station located along Pleasant Street (Route 5) in Northampton, MA (“the site”). The site is located at the intersection of Pleasant and Conz Streets, as shown on the Locus Map included in the Figures section. This report has been prepared for the period from September 1, 2008 to February 28, 2009. It describes the extension of the treatment systems across Route 5; the operation and maintenance of the treatment systems; the sampling of the soil and groundwater; and the installation of an anti-foaming system. Currently there are no Imminent Hazards or Conditions of Substantial Release Migration at the site. Therefore a Remedial Monitoring Report is only due every six months in accordance with the most current, December 14, 2008 version of 310 CMR 40.0027 and 40.0892. On May 15, 2003, we submitted a combined Phase III Remedial Action Plan and Phase IV Remedy Implementation Plan in which we proposed the installation of groundwater and soil treatment systems on the private properties located at 459, 480 and 492 Pleasant Street. The site had been assessed since June 1984 when tanks were removed from 459 Pleasant Street. In June 2003, we installed only the portions of the systems located at 459 Pleasant Street because we were unable to locate the product pipes that reportedly crossed Route 5. On June 25, 2003, we began operating the groundwater treatment system at 459 Pleasant Street. On September 9, 2003, we began operating the soil vapor extraction system at 459 Pleasant Street. On September 15, 2003, submitted a combined Final Inspection Report and a Phase IV Completion Statement for the installation of the portion of the treatment systems at 459 Pleasant Street. As a result, the site achieved Phase V status. The two systems were operated continuously until June 30, 2006 with shutdowns for maintenance, high groundwater, and low groundwater. We treated a total of 2,214,239 gallons of groundwater and recovered 729 gallons of gasoline that was recycled off-site. Significant gasoline remained under Route 5 that could not be effectively removed by the treatment systems at 459 Pleasant Street. For the next two years, Mr. Robert Kalish, the President of Pleasant Journey Used Cars, Inc, searched for funding to complete the remediation. We had determined that a majority of the gasoline contamination remained under the adjacent section of Route 5. In December 2005, the Massachusetts Highway Department (MHD) applied for a Page 1 PENNEY ENGINEERING, INC Brownfields Grant from the Environmental Protection Agency (EPA). On May 12, 2006, we were notified that the EPA awarded a $200,000 grant to MHD and $40,000 was contributed by Mr. Kalish. On March 4, 2008, we were notified that the MHD had entered into an agreement with the City of Northampton to administer the grant. On September 5, 2008, the City entered into a contract with Penney Engineering to extend the treatment systems across Route 5 and operate the systems for 11 months. In November 2008, we were able to run new pipes across Route 5 and complete the installation of the remainder of the treatment systems at 480 and 492 Pleasant Street in order to remediate the gasoline contamination under Route 5. The treatment systems have been designed to adequately remediate the gasoline contamination in the soil and groundwater at the site over time in order to achieve a permanent solution. The systems shall be operated in accordance with 310 CMR 40.0891 and all applicable permits, approvals and licenses. Now the operation and maintenance of the completed treatment systems is considered a Comprehensive Remedial Action. We have now met the requirements of Remedy Operation Status in accordance with 310 CMR 40.0893. This document includes an As-Built Plan, a Final Inspection Report, a Phase IV Completion Statement for the installation of the entire the treatment systems and a Remedy Operation Status Opinion in order to achieve Remedy Operation Status. We are hereby applying for Remedy Operation Status which shall suspend the deadline to achieve a Response Action Outcome within five years, reduce the next subsequent annual compliance fees from $2,000 to $800, and eliminate the need to annually extend the Tier II classification. The properties at 459, 480 and 492 Pleasant Street were previously under common ownership and operated as a gasoline station until 1955 when Pleasant Street (Route 5) was constructed through the station property. The former tanks at 480 Pleasant Street were reportedly for the original gasoline station, which had dispensers along Conz Street. Reportedly, Conz Street was previously known as Maple Street, the main route into the center of Northampton. We believe that the tanks may have actually been for a gasoline station with dispensers on the opposite or both sides of Pleasant Street. In 1984, Mr. Robert Kalish, the former President of Pleasant Journey Used Cars, Inc, current President of Robert P. Kalish, Inc, and owner of the property at 459 Pleasant Street, 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 Page 2 PENNEY ENGINEERING, INC 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 Department of Environmental Protection (“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 his partner, Mr. John 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 system that operated intermittently from August 7, 2000 until December 7, 2000. Numerous assessments have been conducted at the site since 1988. 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 over 11 years. On December 8, 1998, a Method Three Risk Characterization was prepared for the site by O’Reilly, Talbot & Okun Associates, Inc of Page 3 PENNEY ENGINEERING, INC Springfield. It determined that there was no significant risk associated with the remaining contamination in the groundwater. There were only very limited results of the gasoline contamination in the soil. Only two soil samples had been analyzed. 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 soil vacuum extraction 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 soil vacuum extraction 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 soil vacuum extraction 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 soil vacuum extraction system utilized an existing monitoring well and did not include a knockout drum. Reportedly, the soil vacuum extraction 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 stated that a Falco Model #500 catalytic oxidizer had been used with the soil vacuum extraction system until the second week of December 2000. According to Mr. Kalish, the oxidizer was damaged when liquid gasoline was drawn into it and exploded. 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 Page 4 PENNEY ENGINEERING, INC classification for the site expired on December 3, 2001. No extension application was submitted 60 days prior to the expiration date. Mr. Kalish was told of our successful work on a similar site in Wellesley and he contacted Penney Engineering. On March 12, 2002, Mr. Penney inspected the site. He measured five inches of free-phase gasoline in monitoring well MW-9 located along Pleasant Street. The gasoline appeared weathered, but smelled fresh. On March 22, 2002, Penney Engineering was 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 Mr. Kalish and converted to a retail, used car 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 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 also confirmed the continued presence of significant concentrations of dissolved gasoline contaminants in the groundwater over a larger area encompassing the properties located at 459, 480 and 492 Pleasant Street. The dissolved gasoline contaminants were found to be slowly migrating to the east in the direction of the local groundwater flow. 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 Page 5 PENNEY ENGINEERING, INC 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 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 of the site. 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 could not be excavated because of space restrictions and because it extended under Pleasant Street. An Activity and Use Limitation was an acceptable remedial option for Pleasant Journey, but may not have been 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 was 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 was 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 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. Page 6 PENNEY ENGINEERING, INC 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 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, a soil vapor extraction (SVE) system would be activated to remove the trapped, free- phase gasoline from the pore spaces of the dewatered saturation zone above the depressed groundwater table. Once the SVE system removed the trapped, free-phase gasoline it would be turned off and 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 were to be injected into the discharged groundwater to enhance bioremediation. On November 13, 2002, the DEP issued a second NON 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 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. 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 Page 7 PENNEY ENGINEERING, INC 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 May 15, 2003, we submitted a combined Phase III Remedial Action Plan and Phase IV 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 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 under Pleasant Street and at the 480 and 492 Pleasant Street properties. We hoped to utilize the former product piping reportedly still intact under Pleasant Street to pipe to the second recovery well and avoid the need to excavate across Route 5, as recommended by Mr. Kalish. 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 June 2, 3, 4, 5 and 6, 2003, we installed one recovery well, the recharge well and two of the SVE zones on the western side of Pleasant Street once the groundwater table receded. 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 filled the vessel with approximately 1,300 lbs of vapor phase carbon. The driver of the concrete truck from Bill Willard, Inc said that he had Page 8 PENNEY ENGINEERING, INC 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 in the area of the current garage at 459 Pleasant Street. During the excavation we encountered approximately 100 cubic yards of overtly, gasoline-contaminated soil and stockpiled it on site. 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. On June 11, 12 and 13, 2003, we completed the setup of the treatment trailer and tested the equipment. 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. On June 25, 2003, we started the groundwater treatment system and began monitoring it. On September 9, 2003, we graded the contaminated soil that had been stockpiled on site during the installation, but was not accepted for asphalt recycling. On September 9, we also activated the SVE system and began monitoring it. The approximately 100 cubic yards of stockpiled soil was found to be unacceptable for recycling because the total volatile organics concentration exceeded 500 mg/kg. On September 11, 2003, the graded soil was covered with bituminous concrete. The graded, contaminated soil was allowed to be remediated on-site by the SVE system as recommended by the DEP. On November 3, 2005, Mr. Baffour Kyei from the DEP conducted a Remedial Inspection of the treatment systems. Mr. Kyei found no problems or violations. Mr. Kyei was told that we had not observed free-phase gasoline in any of the monitoring wells at the site since March 18, 2004. We operated the treatment systems for two years and recovered over 700 gallons of gasoline. We conducted groundwater monitoring and saw the contaminant concentrations on the western side of Pleasant Street decrease. There were only limited reductions on the eastern side of Pleasant Street. On July 13, 2006, we sent written notification to the DEP that the treatment systems had been temporarily shut down on June 30 until we could extend the treatment system across Pleasant Street. We also continually monitored the influent to the groundwater treatment and the groundwater from specific wells on a quarterly annual basis. Our groundwater monitoring program is fully described in Section 6.0. For the past five years, we have submitted Tier II Extension Requests to the DEP on an annual basis requesting that the Tier II classification for the site be extended for another year. We have also submitted Page 9 PENNEY ENGINEERING, INC semi-annual Phase V Status and Remedial Monitoring Reports to the DEP which described the operation of the treatment systems and included copies of our monitoring logs, the associated laboratory reports for those periods, and the Bills of Lading used for transporting the recovered gasoline. We have annually applied to the Northampton Fire Department for a renewal of the permit to store the recovered gasoline. On January 31, 2007, Extra Mile, Inc purchased the used car business from Pleasant Journey Used Cars, Inc and began renting the property at 459 Pleasant Street. The new business operates under the name of Pleasant Journey Used Cars. Mr. Kalish formed Robert P. Kalish, Inc, which owns the 459 Pleasant Street property and assumed responsibility for the remediation of the gasoline contamination that reportedly originated at its 459 Pleasant Street property. On September 5, 2008, we received a signed contract from the City of Northampton and were authorized to begin work immediately. On September 18, 2008, we held an informal meeting at the site with the two owners of the affected private properties and Ms. Teri Anderson, the Economic Development Coordinator for the City of Northampton. We discussed trenching across Route 5 and installing the second recovery well and third SVE zone at the 480 and 492 Pleasant Street properties. The Pro Lube oil change business operates six days a week at 480 Pleasant Street. The building at 492 Pleasant Street houses a car wash, offices and a night club. It was agreed that we could close the exit from Pro Lube for two days during the crossing of Route 5. We could then close the car wash and use the area between the two buildings as a staging area and to install Recovery Well RW-2 and SVE Zone C. The work area was to be secured with temporary fencing. On September 18, 2008, we also collected groundwater samples from monitoring wells MW-2A, MW-9, MW-10 and ECS-5. Unfortunately the worst well, MW-12, had been damaged and could not be sampled. The four samples were analyzed for volatile petroleum hydrocarbons (VPHs) with target volatile organic compounds (VOCs), total and dissolved lead, nitrate plus nitrite and total phosphorus. The results for MW-2A, located at 480 Pleasant Street, were still relatively high. The concentrations of the C5- C8 aliphatics and benzene in MW-2A were above the GW-2 cleanup standards but below the GW-3 cleanup standards. The concentrations of xylenes in MW-10 were above the applicable GW-3 cleanup standard. The bacteria counts in MW-2A were above our normal range which indicated that enhanced bioremediation was occurring. Page 10 PENNEY ENGINEERING, INC On November 3, 4, 5, 6, 7, 11 and 12, 2008, we installed the remainder of the treatment systems under Route 5 and at 480 and 492 Pleasant Street as described in Section 5.2. A trench was dug across Route 5 and the required piping was installed. We installed Recovery Well RW-2 and two trenches for SVE Zone C at 480 and 492 Pleasant Street. 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. On November 5, 2008, we collected three composite soil samples from the excavation for Recovery Well RW-2 and had them analyzed for VPHs with target VOCs. Gasoline- related contaminants were detected in all three samples but all the results were below the S-1/GW-3 and S-2/GW-3 cleanup standards. No MTBE was detected which indicated that the gasoline was formulated prior to 1978 or the MTBE had been washed away. On January 14, 2009, we tapped the Discharge Pump controller and it began to work fine. The system was started with RW-1 pumping at 1.2 gpm. On January 15, the system was checked and was found to still be running. On January 19, we inspected the system and attempted to diagnose the problem with RW-2. A total of 5,462 gallons of water had been pumped from RW-1 since January 15. The Discharge Pump continued to operate automatically. Everything indicated that there was a crack or leak in the piping from RW-2. It was agreed to keep the control valve open to minimize the possible leak. The groundwater system was left running with RW-1 pumping at 1.0 gpm and RW-2 pumping at 1.2 gpm. On February 13, 2009, we conducted the quarterly groundwater sampling at the site by collecting samples from monitoring wells WS-1, MW-9, MW-10 and the influent from RW-2 for VPH analysis. Unfortunately, monitoring wells MW-2A, MW-8, and MW-12 had been damaged and ESC-5 was covered with ice and snow. The pump in Recovery Well RW-1 could not be restarted so it could not be sampled. The four samples were analyzed for VPHs with target VOCs and measured for heterotrophic bacteria counts. The sample from RW-2 was also analyzed for dissolved and total lead; nitrate plus nitrite; and total phosphorus. The sample from RW-2 was also analyzed for surfactants to determine the source of the soap causing the foaming problem. The concentrations of the C5-C8 aliphatics and the C9-C10 aromatics in WS-1 were above the applicable GW-2 cleanup standards. Xylenes were detected in wells MW-9 and MW-10 above the applicable GW-3 cleanup standard. The results showed that the plume was still centered under Pleasant Street. The groundwater results were indicators of the soil contamination. The results for recovery well RW-2 were relatively low. The bacteria Page 11 PENNEY ENGINEERING, INC counts were highest on the eastern side of Pleasant Street. Although the counts are not specific for petroleum metabolizing bacteria, they may be a direct indicator of petroleum contamination. A significant concentration of surfactants was detected in RW-2 which indicated that the groundwater in the area of RW-2 contained soap. On February 26, 2009, we sent a letter to Mr. Scherer at the DEP notifying him of the anti-foaming system we had designed and intended on installing as a minor modification of our Phase IV Plan. The letter included information on all the remedial additives we intended to inject. On February 28, 2009, we collected a groundwater sample from monitoring well WS-1, located closest to the car wash. The samples was analyzed for nitrate plus nitrite, and surfactants and measured for heterotrophic bacteria counts. The level of surfactants in WS-1 was much higher than the level measured in RW-2 on February 13, 2009, indicating higher levels of surfactants in the groundwater closer to the car wash. On February 28, 2009, we also installed a system to continuously inject an anti-foaming agent into the influent from Recovery Well RW-2. In order to evaluate the effectiveness of the SVE and the groundwater treatment systems previously installed at 459 Pleasant Street, we continually 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 vapor phase carbon. To evaluate 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 evaluated the quarterly groundwater and influent monitoring results. A summary of the historical results is discussed in Section 6.5. The treatment systems shall be operated in accordance with our May 15, 2003 Phase III/IV Remedial Action and Remedy Implementation Plan as modified, the Phase IV Performance Standards, described in 310 CMR 40.0872, and the Response Action Performance Standards, as defined in 310 CMR 40.0191. The treatment systems are achieving the objectives of our Phase IV Plan. They shall operate until the significant risk has been reduced and the conditions for a Class A-2 Response Action Outcome have been achieved. 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. We shall submit an LSP Opinion regarding air emissions controls and the establishment Page 12 PENNEY ENGINEERING, INC of a discharge limit for total volatile organic compounds (TVOCs). Vapor phase carbon adsorption is one of the Best Available Control Technologies (BACT) for TVOCs. The annual loading shall be less than 2,000 lbs. The vapor phase carbon vessel is being used for both the off-gas from the groundwater treatment system and the SVE system. The TVOC concentrations in the off-gas from the groundwater system are relatively low at 1.0 to 3.0 ppm. The TVOC concentrations in the influent from the SVE systems have recently been measured to range from 17.0 to 33.0 ppm. We shall attempt to maintain a removal rate of at least 95% and use an interim discharge limit of 8.0 ppm TVOCs. The property line of the nearest residence from the discharge is approximately 250 to the north. Remedial additives, including micronutrients, anti-foaming agent and specific bacteria, shall be injected into the biodiffuser and manually applied to specific wells. We shall monitor the remedial additives on a monthly basis. 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. A thirteenth Phase V Remedy Operation Status and Remedial Monitoring Report shall be submitted to the DEP before the September 15, 2009 deadline. We may also conduct a subsurface investigation to determine if there are any abandoned tanks or other sources of contaminants at the site. Robert P. Kalish, Inc has now 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 ROBERT P. KALISH, INC 504 Lampblack Road Greenfield, MA 01301 (413) 218-8153 The name, address and telephone number of the Licensed Site Professional-of-Record for the site is: Mr. Ralph P. Penney, President PENNEY ENGINEERING, INC 125 High Street Mansfield, MA 02048 (508) 261-1288 LSP #7755 The first four sections of this Phase V Status Report, Remedial Monitoring Report and Remedy Operation Status Submittal summarize our previous findings. Section 5.0 describes the initial installation of a portion of the treatment systems and the recent Page 13 PENNEY ENGINEERING, INC extension of the groundwater and soil treatment systems across Route 5. Section 6.0 describes the operation, maintenance and monitoring of the treatment systems for the most recent period from September 1, 2008 to February 28, 2009. Section 7.0 discusses Remedy Operation Status. Section 8.0 describes the public notification process. A Locus Map; a March 5, 2009 BWSC Site Scoring Map; sixteen tables of results; five figures showing the groundwater contours and the extent of the contamination; a Sampling Plan; photographs of the installation across Pleasant Street; four charts showing the historical results for the influent, MW-9, MW-10, and MW-12; four charts showing the gasoline recovered during regeneration of the carbon; and a regression chart showing the plot of the ratio of gasoline recovered to duration of operation are included in the Figures section. Appendix A includes a completed Comprehensive Response Action Transmittal Form (BWSC-108), two CRA Remedial Monitoring Reports, a Notice of Environmental Sampling (BWSC-123), and copies of the current Fire Department permit to store flammable liquids, the October 6, 2008 MHD permit to cross Route 5, the October 21, 2008 Trench Permit from the City of Northampton, the November 1, 2008 Right of Entry Authorization from the owners of the properties at 480 and 492 Pleasant Street and the Electrical Permit received on December 13, 2008. Appendix B includes copies of our monitoring logs that have been completed from December 15, 2008 to March 1, 2009. Appendix C includes copies of our Monitoring Well Sampling Logs and the laboratory analysis reports for the groundwater samples collected on September 18, 2008, February 13, and February 28, 2009. Appendix D includes a copy of the laboratory analysis report for the soil samples collected on November 5, 2008. A full-size as-built Remedial Action Site Plan is included in the rear pocket. 1.1 Description of the Site The site is located at 459, 480 and 492 Pleasant Street along with the adjacent section of Route 5 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 two-lane highway and part of State Route 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 Page 14 PENNEY ENGINEERING, INC Connecticut River located approximately one mile southeast of the site, as shown on the Locus Map. According to a March 5, 2009 BWSC Site Scoring Map included in the Figures section, the site is not located within an Interim Wellhead Protection Area, a Zone II or a mapped Potentially Productive Aquifer. It is located in a Non-Potential Drinking Water Source Area. 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 Book and Page NumberDate of Purchase Owner 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 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 Page 15 PENNEY ENGINEERING, INC 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 in the large garage 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 for the car wash. 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 ECS. ECS had conducted a 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 had advanced 25 additional soil borings and installed five additional monitoring wells. The location of all the borings and wells are shown on the Page 16 PENNEY ENGINEERING, INC 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 μg/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, VPHs, and extractable petroleum hydrocarbons (EPHs) with target polynuclear aromatic hydrocarbons (PAHs) by the new DEP methods. 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 determined the applicable cleanup standard based upon the location of the well and its proximity to 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- Page 17 PENNEY ENGINEERING, INC 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 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 Page 18 PENNEY ENGINEERING, INC 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 April 25, 2002 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 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. Page 19 PENNEY ENGINEERING, INC 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 was associated with the height of the groundwater table. We assumed that it extended across 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 and one sample from the 18 borings advanced by ECS in 1997 were analyzed over 14 years of investigating the site. The soil sample collected from below the groundwater table at the dispenser pad contained benzene at 43.5 mg/kg. The boring sample was collected from soil boring SB-4 located adjacent to the northeast corner of the dispenser pad. 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 20 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 5.1 Installation of Initial Portions of Treatment Systems 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 September 2003 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; filled the vessel with approximately 1,300 lbs of vapor phase carbon; 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. We encountered approximately 100 cubic yards of overtly, gasoline-contaminated soil and stockpiled it 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 on the eastern side of 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. 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. 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. On June 25, 2003, a representative from the Ted Ondrick Company, LLC, a soil recycling company, called and requested three more samples from the stockpile be analyzed because the TVOCs and the flashpoint exceeded their acceptance criteria. Page 21 PENNEY ENGINEERING, INC 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 June 25, 2003, we also started the groundwater treatment system and began monitoring it. Groundwater was pumped from Recovery Well RW-1 at 5.0 gpm. We also collected baseline groundwater samples from specific wells along with influent and effluent samples from the groundwater treatment system. On July 7, 2003, the Northampton Fire Department inspected the storage drums 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 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. 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 22 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. We also 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 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 once it dried at the surface. 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 Page 23 PENNEY ENGINEERING, INC caps were poured around wells MW-1, MW-5, MW-6, MW-7, MW-9 and MW-10. We also activated the SVE system and began monitoring it. The SVE system was set up 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. 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 Fire Department permit to store gasoline, the notification letter sent to the public officials, a July 18, 2003 letter from the MHD regarding a permit to cross Route 5, 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. On November 11, 2003, we measured the depths to groundwater in a number of wells in order to determine the influence of the groundwater treatment system. 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 November 11, 2003 Groundwater Contour Plan, included in the Figures section. Although the data was limited, the contours showed that the influence of the groundwater treatment system pumping from RW-1 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 Figures One and Two, on October 11, 2000 and April 25, 2002, respectively, 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 was expected to greatly affect the groundwater over a large area in the low permeability soil at the site. As shown on the Remedial Action Site Plan, the installation of Recovery Well RW-2 across Pleasant Street would allow the Page 24 PENNEY ENGINEERING, INC groundwater treatment system to circulate treated groundwater through the contaminant plume under Pleasant Street that is shown on Figures Three and Four. In September 2004, we 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 sent 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 was being partially drawn back to the Recovery Well RW-1 from under the adjacent portion of Pleasant Street and 480 Pleasant Street. Since March 18, 2004, we had no longer observed any free-phase gasoline in any of the wells at the entire site. 5.2 Completion of Installation of Treatment Systems On September 18, 2008, we held an informal meeting at the site with the two owners of the affected private properties and Ms. Teri Anderson, the Economic Development Coordinator for the City. We discussed trenching across Route 5 and installing the second recovery well and third SVE zone at the 480 and 492 Pleasant Street properties. The Pro Lube oil change business operates six days a week at 480 Pleasant Street. The building at 492 Pleasant Street houses a car wash, offices and a night club. It was agreed that we could close the exit from Pro Lube for two days during the crossing of Route 5. We could then close the car wash and use the area between the two buildings as a staging area and to install Recovery Well RW-2 and SVE Zone C. The work area was to be secured with temporary fencing. We marked the pavement so everyone could see the approximate locations where we were going to excavate to install Recovery Well RW-2 and the two trenches for SVE Zone C. Ms. Anderson agreed to prepare the required access agreements. We checked the piping and the pre-cast concrete structures that had been stored at the property since 2003. Mr. Matthew Pitoniak, a trustee of Quickbeam Realty Trust, pointed out the location of the former Page 25 PENNEY ENGINEERING, INC underground storage tanks at his 480 Pleasant Street property. Mr. Pitoniak had previously provided us with all his reports and other documents regarding the tanks. We also sampled specific wells to determine the current contaminant conditions, as discussed in Section 6.4. For the next month we reviewed Mr. Pitoniak’s reports and our sampling results. We attempted to determine the best locations for RW-2 and SVE Zone C. We revised our plans accordingly. The City used our plans to request bids to excavate across Pleasant Street. We also used the plans to prepare a MHD Permit Application to Access Route 5 and a City of Northampton Trench Permit Application. On October 17, 2008, we submitted our site-specific Health and Safety Plan along with an Analysis of Brownfields Cleanup Alternatives Report to the EPA for approval. On October 23, we were informed that our two documents seemed to be fine and that a public hearing on the project would be held at 7:00 PM on November 5, 2008 at the City Hall. On October 24, 2008, we sent written notification of our upcoming field work at the site to the Northampton Fire and Police Chiefs. On October 30, 2008, we submitted a Quality Assurance Project Plan (QAPP) for our proposed sampling and analysis to the EPA for approval. On November 3, 4, 5, 6, 7, 11 and 12, 2008, we directed Grant Brothers Associates to excavate and assist us with the installation of Recovery Well RW-2, SVE Zone C and all the associated piping at 480 Pleasant Street, as shown on the Remedial Action Site Plan. On November 3, 2008, we directed Bay State Fence to set up fencing at the site according to our Fencing Plan without blocking the exit from the Pro Lube facility. We reviewed the plans and the Health and Safety Plan with Grant Brothers, Mr. Pitoniak, Mr. Edmund Kamansky and the manager of the Pro Lube facility. We attempted to locate the stubbed pipes at 459 Pleasant Street that were installed back in 2003. We had run a metal snake down the 1½” PVC conduit for RW-2 from the control panel in the treatment trailer. We charged it and tried to trace it. The parked cars and buried metal caused interference. We dug in the area of MW-9, but only found the perforated pipe for the eastern most leg of SVE Zone B. We cut the pavement and dug a trench back to the northern side of RW-1. We could not locate the stubbed pipe. On November 4, 2008, Gomes Construction Company, Inc of Ludlow was on-site to excavate across Route 5. Gomes had been retained directly by the City of Northampton. We had marked the best location to cross Route 5 thinking that we would Page 26 PENNEY ENGINEERING, INC locate the stubbed pipes after the crossing. Gomes cut the pavement to the center of the exit from Pro Lube, as shown on the Remedial Action Plan. Gomes cut the thick pavement and turned to the Pro Lube sign. Grant Brothers removed the pavement for the recovery well and hauled it away to Bill Willard, returning with 2” washed stone and engineered sand mixed. Gomes started trenching at the Pro Lube end and dug across Route 5. Fortunately, we hit a PVC witness for the stubbed pipes approximately 10 feet south of MW-9, as shown in Photograph One. It looked like we had extended the pipe straight from the main trench, past the RW-1 to the landscape area along Pleasant Street. We laid pipe and Gomes covered it with a small amount of native soil and then flowable fill, as shown on Photograph Two. Grant Brothers set up the shoring and moved the pre-cast structures that had been stored behind the garage at Pleasant Journey since 2003 onto the low bed. Gomes set road plates over the backfilled trench for the night. On November 5, 2008, Gomes cut down the flowable fill to 9” and paved the trench across Route 5. Grant Brothers loaded out a second load of clean fill and brought back a second and third load of the 2” stone and sand mixture from Willard. We excavated a pit to install RW-2. The contaminated soil encountered just above the groundwater table was stockpiled in the containment area constructed along the southern section of the Staging Area. The shoring was placed in the excavation and the pit was extended to six feet below the groundwater table. Crushed stone was placed at the bottom and the pre-cast leaching pit sections were placed, as shown in Photograph Three. We placed the stone and sand mixture around the leaching pit to act as a ground pack to hold the silt out of the leaching pit. We laid filter fabric over the top of the stone and sand mixture and then started placing the contaminated soil back into the excavation. Some clean soil was mixed with the contaminated soil to tighten it. The shoring was disassembled, swept clean, and loaded on the low bed to be returned the next day. On November 5, 2008, Mr. Penney also spoke with the electrician, Mr. Jim Mailloux of Mailloux Electric. Mr. Mailloux told Mr. Penney that Mr. George Fournier, the Wiring Inspector, was only in from 8:30 to 9:30 AM. Mr. Penney went to the Building Department at 9 AM and spoke with Roger and a secretary who said she would give Mr. Fournier a message to call Mr. Penney on Friday as he was away. Mr. Penney returned to the site and reviewed the wiring and confirmed that the Warrick 2701EA pump controller sent a 120 VAC signal so there was no low voltage and only one conduit to RW-2 was needed. He also checked the historic SVE inlet concentrations. They started at approximately 100 ppm and were down to 10-20 ppm over time. He met with Rick of Mailloux Electric who had wired a couple of gasoline stations and understood Page 27 PENNEY ENGINEERING, INC what was needed. Rick agreed that the one conduit could be used for the supply and conductivity probes from the intrinsically safe controller. He also agreed that the maximum bends were limited to 360o. The only issue would be if the wiring inspector also wanted a vapor barrier seal off at the well. A barrier was already in place just outside the trailer. During the installation of RW-2, we collected three composite soil samples from the excavation for analysis as discussed in Section 6.4. We were to meet with the wiring inspector the next morning. On November 5, 2008 at 7:00 PM, Mr. Penney attended a Public Information Meeting at the Bridge Street School Library as part of the required Community Outreach Program. It was attended by fewer than 10 local property owners. One owner stated that there were above ground kerosene tanks at 480 Pleasant Street and next door at the Hampden Zimmerman property. On November 6, 2008, we began to excavate the two trenches for SVE Zone C. We cut the pavement for the two SVE trenches. We loaded out another load of clean soil and returned with a load of ¾” washed stone. We cleaned up and loaded out another load of clean soil and returned with bank gravel. We attempted to excavate the ends of the trench to within 20 feet of the car wash but we hit a buried concrete apron. We loaded out the clean soil from the SVE trenches and returned with another load of ¾” stone. We completed the northwestern ends of both SVE trenches so we could partially backfill around RW-2. We could not complete the eastern trench to the carwash. We had to backfill and dig from the backfilled area. We set the pump in the well. The depth from the rim to the outlet tee was 44½”. The rim had to be raised approximately four inches. Mr. Ed Kaminsky wants to eventually connect the leaching catch basin to the leaching pit when we are done. On November 7, 2008, Mr. Mailloux called to say he couldn’t make it that day either. We needed to close the hole to allow the carwash to open on Saturday, the next day. Mr. Pitoniak called Mr. Mailloux who said Rick would be there within an hour and would pull the permit himself. We cleaned up the area excavated to find the stubbed pipes. We started coring the conical section of the manhole 48” below grade to run the water line. Rick arrived and set up to blow a mouse through the conduit. We had connected to the 1½” stubbed conduit and ran it to the western trench for SVE Zone C, opposite RW-2. We also ran 1” conduit from the stubbed pipe area back to the same location based upon the first electrician saying we had to run the pump controls in separate conduit. It was capped on both ends and not used. We blew the mouse with a light string from RW-2 to the trailer but it got stuck. We fished the metal snake from the trailer and pulled out the heavy pull string we had left in the stubbed conduit along with Page 28 PENNEY ENGINEERING, INC the mouse. Our string had been tied off in the control panel. Someone had untied it since the systems were shut down in 2006. We tried to pull through the heavy cord but it got stuck toward the trailer end. We spent the next three hours trying to snake through the conduit. We also cored through the manhole for the electric conduit. Mr. Louie Owens inspected the conduit and said everything was fine. He had previously inspected the site in 2003. We mixed hydraulic cement for the water pipe. We backfilled the entire area and waterline. We checked the sign at the Car Wash and found it not to be working. Grant Brothers had hit the ½” metal conduit pretty hard when backfilling. Rick checked and the current ended at the southern end of the SVE trench and wires were pulled in the panel. It would need to be fixed. On Tuesday, November 11, 2008, we returned to the site. We blew the mouse to the trailer with light pull rope the first time. Light pull string came out with the mouse. It may have been the remainder of the pieces broken on November 5 by the electrician. We pulled wire and finished laying the conduit to Recovery Well RW-2. We pulled the pump to check the wiring of the probes. We dug out the broken conduit to the Car Wash sign. Mr. Mailloux spliced in 20 feet of ½” PVC conduit and pulled new wire to the sign from the junction box inside the car wash building. The sign still did not work but we showed Mr. Kamansky that he had power to the sign. It may not have worked when we started. We removed the 12” nipple to raise the pump to be 12” above the bottom of the pit. There was approximately 6-8” of silt and stone at the bottom of the pit. We wired the pump and tested it. Water went into a bucket in the trailer. The riser from the pump was removed and found to be full of water indicating a check valve or foot valve in the pump. We loosened the union to drain the pipe from the trailer. The short riser from the pump was capped. We pulled a string from west to east across the pavement to determine the height of the manhole rim for RW-2. It did have to be raised four inches. We set bricks and mortar around the manhole and secured the area for the night. On November 12, 2008, the fencing was removed and we graded and compacted the site. The parking lot was swept late that day by Mohawk Sweeping Service of Northampton. On November 13, 2008, the excavated areas at 459, 480 and 492 Pleasant Street were finish graded, saw cut and paved with 2½” of ¾ binder by Zak’s Construction of Easthampton. The finish grade was left down approximately 1” to accept a top course in the spring if needed to correct for settling. The seams were sealed with emulsion and sand. Page 29 PENNEY ENGINEERING, INC 5.3 Licenses, Permits and Approvals On September 30, 2008, we submitted a permit application for crossing Route 5 to Mass Highway. The City of Northampton was listed as the applicant. On October 6, 2008, Permit #2-2008-0518 was issued to the City of Northampton. A copy of the permit is included in Appendix A. On October 1, 2008, we submitted a trenching permit application for excavating on the private properties to the City of Northampton. The applicants were Penney Engineering, Inc and Grant Brothers Associates. On October 21, 2008, Trench Permit DS#2008-380-7372 was approved. A copy of the Trench Permit is included in Appendix A. On November 1, 2008, Mr. Matthew M. Pitoniak and Mr. Edmund Kamansky of Quickbeam Realty Trust, signed a Right of Entry Authorization for the City of Northampton, the Massachusetts Highway Department, or its duly authorized agents and contractors to enter upon their property located at 480 and 492 Pleasant Street. A copy of the Right of Entry Authorization is included in Appendix A. On December 3, 2008, we submitted an application to the City of Northampton Fire Department to renew the drum storage permit for Robert P. Kalish, Inc for the gasoline we recover from the treatment systems. A copy of the permit is included in Appendix A. On December 13, 2008, we finally received the Electrical Permit that we had applied for on November 3, 2008. A copy of the permit is included in Appendix A. 5.4 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 for the initial portions of the treatment systems. This document and the as-built Remedial Action Site Plan are hereby submitted as an As-Built Construction Report for the completion of all the treatment systems. 5.5 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 for the initial portions of the treatment systems. This document is hereby submitted as an As- Built Construction Report for the completion of all the treatment systems. Page 30 PENNEY ENGINEERING, INC 5.6 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 for the initial portions of the treatment systems. This document is hereby submitted as a revised Phase IV Completion Statement for the completion of all the treatment systems. It is the opinion of Mr. Ralph P. Penney, as the LSP-of-Record for the site, that the installation of the remainder of the treatment systems at 480 and 492 Pleasant Street has been conducted in accordance with our May 2003 Phase IV Remedy Implementation Plan, as modified, the applicable requirements of 310 CMR 40.0870 and the Phase IV performance standards described in 310 CMR 40.0872. The completion of the treatment systems represents a permanent solution for the gasoline contamination at the site and we are therefore applying for Remedy Operation Status. 6.0 OPERATION, MAINTENANCE AND MONITORING OF THE TREATMENT SYSTEMS 6.1 Monitoring Plan Since being activated in 2003, the groundwater and soil treatment systems at 459 Pleasant Street have been operated and maintained by Penney Engineering personnel with help from Mr. Kalish and the mechanics at Pleasant Journey. The systems were inspected almost daily by the mechanics. We monitored them almost every two weeks. During each inspection, the operating parameters of the systems were recorded on monitoring logs. Copies of the monitoring logs were submitted to the DEP in our Phase V Reports. The sampling locations are shown on the Sampling Plan, included in the Figures section. We routinely screened the off-gas from the Biodiffuser and the vapor phase carbon vessel with an organic vapor meter (OVM). We regenerated the vapor phase carbon as needed. The two treatment systems continuously except for shutdowns for maintenance, high groundwater and low groundwater until June 30, 2006. We treated a total of 2,214,239 gallons of groundwater and recovered 729 gallons of gasoline. Now that all the treatment systems have been installed, we shall continue to operate and maintain the treatment systems with help from Mr. Kalish and the mechanics at Pleasant Journey. Initially, the systems shall be inspected daily until the groundwater flow rates are determined, the inlet concentrations stabilize and the breakthrough period for the vapor phase carbon is established. We may not activate the SVE system until Page 31 PENNEY ENGINEERING, INC the groundwater table recedes or is depressed. The system shall then be inspected weekly or more often as needed in accordance with 310 CMR 40.0191. All piping shall is installed underground. The treatment trailer is locked and enclosed within a locked, fenced area. The site is currently occupied during each day of the week by the employees of Pleasant Journey and Pro Lube. A notice has been posted on the exterior wall of the fenced area to alert residents to contact Pleasant Journey or Penney Engineering if there are any problems. The Biodiffuser has a high water level shutoff switch wired to an alarm and an exterior strobe light on the trailer. It also activates a dialer that calls Mr. Kalish, Mr. Penney, and Penney Engineering. The moisture separator for the SVE system is wired similarly. There is thermo-overload protection on all the electric motors. The Northampton Fire and Police Departments have been provided with telephone numbers to be called for routine questions and in emergencies. Groundwater samples shall be periodically collected from the two influents and the effluent and submitted to a Massachusetts-qualified laboratory for VPH analysis. The Biodiffuser is expected to remove up to 95% of the gasoline contaminants. The Biodiffuser has not been designed to remove 100% of the contaminants because the treated water shall be discharged into the groundwater, upgradient of the contamination to be recaptured by one of the recovery wells. Specific monitoring wells shall be sampled immediately before the anti-foaming system is started to determine antecedent conditions. The same wells shall be sampled on a monthly basis to monitor for the remedial additives. The samples shall include MW-5 and WS-1 or ECS-5. The samples shall be analyzed for heterotrophic bacteria, pH, temperature, dissolved oxygen, nitrites and nitrates to monitor for remedial additives and evaluation the biochemical conditions. The samples and analysis may be revised as warranted. Specific monitoring wells, the influents, and the effluent shall be sampled on a quarterly basis. The groundwater samples shall be analyzed for concentrations of VPHs by the DEP method. Initially, the influent from RW-1, the influent from RW-2, the effluent, MW- 9, MW-10, and ECS-5 or WS-1 shall be sampled. Once the wells are repaired, MW-2A, MW-8, and MW-12 may also be sampled along with MW-1 and ESC-2. The samples and analysis shall be revised as warranted. We may also conduct additional analysis to evaluate the biochemical conditions of the groundwater and the migration of the remedial additives. Page 32 PENNEY ENGINEERING, INC Initially, the air from the SVE system and the biodiffuser shall be periodically screened with an organic vapor meter for the first two weeks until the carbon breakthrough period is determined. One air sample may be analyzed by a Massachusetts-certified laboratory for identification of the specific contaminants. After the first week of operation, the system shall be inspected and air samples shall be screened weekly or as warranted. Until an LSP opinion is submitted, a discharge limit of 12 ppm TVOCs shall be used. In 1997, ECS conducted an extensive indoor air sampling program in the utilities and the four buildings. No significant vapors were detected. On April 25, 2002, we failed to detect any significant vapors while screening the four buildings with an OVM. Based upon the results of these two air sampling events, no additional air sampling was conducted. The February 13, 2009 results for WS-1 exceeded the GW-2 cleanup standards which warrants additional indoor air monitoring in the Car Wash building. We shall request authorization from the owner and conduct indoor air monitoring within the next few weeks. The results of the groundwater analyses, air sampling and monitoring logs shall be included in our Phase V reports sent to the DEP every six months, in accordance with 310 CMR 40.0892, until the groundwater remains below the GW-2 and the GW-3 cleanup standards for a 12-month period. The monitoring reports shall describe the dates of the inspections. They shall describe any significant modifications made to the treatment systems since the prior report. They shall describe any problems and what measures were implemented to resolve the problems. The reports shall bear the name, license number, signature and seal of Ralph P. Penney as the LSP-of-Record for the site. Any unusual results shall be immediately orally reported to the DEP. 6.2 Evaluation of Changes to the Applicable Regulations Our May 15, 2003 Phase III/IV Remedial Action and Remedy Implementation Plan were prepared in accordance with the October 29, 1999 version of the Massachusetts Contingency Plan (“the MCP”). On June 27, 2003, the MCP was revised. The major revisions that affected the site were as follows: • There was an opportunity to submit documents to the DEP electronically; • Tier ID Disposal Sites were defined as default sites; and • The procedure for applying for a Grant of Environmental Restriction was streamlined. Page 33 PENNEY ENGINEERING, INC On April 3, 2006, the long awaited Wave Two Revisions to the MCP were finally promulgated. The revisions that affected the site were as follows: • The BWSC-108 transmittal form could now only be completed online, which was part of DEP’s plan to have all documents eventually submitted electronically. It could also be printed online and submitted as a hard copy; • Section 40.0046 required that monitoring be conducted prior to subsequent applications of remedial additives. This revision may have required that we sample the groundwater weekly. However, the DEP was re-evaluating the implementation of this requirement especially for systems that continuously inject remedial additives; • Sections 40.0027 and 40.0892 required that a Remedial Monitoring Report and attachments be submitted to the DEP monthly if there was an Imminent Hazard or a Condition of Substantial Release Migration at a site and every six months if not. The reports were only required if there was an active response measure. The form was an attachment to forms BWSC-105, 106, 108 and 119. Alternatively, an Interim Remedial Monitoring Report Checklist could be submitted until April 3, 2007. After April 3, 2007, all Remedial Monitoring Reports must be submitted to the DEP electronically. The Remedial Monitoring Report could still only be completed online then printed or submitted electronically; • In accordance with the Public Involvement Provisions, if samples were to be collected from an adjacent property, the owner must be provided with the results and a summary of the public involvement opportunities within 15 days of receiving the results. We had routinely sampled at the properties across Pleasant Street and provided the owners with status reports every six months. We shall now submit the sampling results to the owners within 15 days of our receipt; • Section 40.0892 renamed the Phase V Inspection and Monitoring Reports to Phase V Status and Remedial Monitoring Reports; • Section 40.0892(2)(c) required an evaluation of the performance of a treatment system for the reporting period. Its performance must meet the goals of the related Phase IV Remedy Implementation Plan. We already included an evaluation in each of our status reports; and Page 34 PENNEY ENGINEERING, INC • Section 40.0926 clarified the averaging of soil results to determine the exposure point concentrations. This revision shall influence the final soil sampling. On February 14, 2008, the December 14, 2007 Supplemental Amendments to the MCP were promulgated. The amendments that affected the site were as follows: • Section 40.0015(7)(c) no longer required hard copies of documents that have been submitted electronically; • Section 40.0015(7)(a) required that all LSP Opinions be submitted electronically on and after January 1, 2009; • Section 40.0028 required that monitoring wells be secured and maintained to prevent the introduction of contaminants and the vertical migration of contaminants; • Section 40.0046 required pre-application monitoring for remedial additives only once a month if the remedial additives are applied more than once a month; • Section 40.0570 allowed tenants and new owners to take over a site. New deadlines would be established. These are known as “White Knight” provisions; and • The reportable concentrations and cleanup standards for a number of compounds were substantially revised. We had not conducted any sampling during the time the April 3, 2006 revisions were in place. The GW-3 cleanup standards for the three VPH fractions were raised to 50,000 ug/l. The GW-3 cleanup standards were raised to 10,000 for benzene and to 20,000 for naphthalene. The GW-3 cleanup standard for xylenes was changed to 5,000 ug/l. In the June 27, 2003 MCP, the GW-3 cleanup standard for xylenes was 50,000 ug/l. 6.3 Prior Operation, Maintenance and Monitoring Activities At 10:20 AM on June 25, 2003, we started the groundwater treatment system installed on the western side of Pleasant Street. 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 Page 35 PENNEY ENGINEERING, INC groundwater was automatically pumped from the clearwell at approximately 35 gpm and discharged into the large diameter Recharge Well located where the former tanks were located, as shown on the Remedial Action Site Plan. 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 were 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. 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. We conducted quarterly groundwater monitoring by sampling the influent from the groundwater treatment system along with groundwater from monitoring wells. 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 micronutrients and ¼ lb of powdered Munox 10x Multiplier, strains of lyophilized (freeze- dried) Pseudomonas petroleum metabolizing bacteria cultures, 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. On March 24, 2005, we began to periodically apply remedial additives to wells MW-2A, MW-10, MW-12, and ECS-5. The treatment systems continued to operate continuously, except for brief shutdowns for repairs, maintenance, high groundwater, low groundwater and regeneration of the vapor phase carbon until December 2005. On December 14, 2005, we temporarily shut down the SVE system for the winter. On March 21, 2006, we attempted to restart the SVE system but found that the blower had been damaged. On April 18, 2006, we replaced the blower and restarted the SVE system. As of May 31, 2006, we had treated 2,214,239 gallons of groundwater and as of May 3, 2006, we had recovered 729.05 gallons of gasoline that has been or shall be recycled off-site as a fuel. On June 30, 2006, we temporarily shut down the treatment systems located at the 459 Pleasant Street property to evaluate how best to install the remainder of the systems across Route 5 at 480 and 492 Pleasant Street. We also temporarily suspended injecting remedial additives into the effluent from the biodiffuser and periodically, manually applying remedial additives to specific wells. Our monitoring results showed that we have significantly reduced the gasoline contamination at 459 Pleasant Street. On November 16, 2006, Mr. Penney drained and winterized the groundwater and the SVE treatment systems. The systems remained off until the remaining portions of the Page 36 PENNEY ENGINEERING, INC treatment systems were installed in November 2008 and the system was restarted in January 2009. We continued to submit semi-annual Phase V Status and Remedial Monitoring reports to the DEP, but there was very little to report. The most complete prior summary was included in our seventh Phase V Status and Remedial Monitoring Report dated September 21, 2006. 6.4 Most Recent Operation, Maintenance and Monitoring Activities On September 18, 2008, we collected groundwater samples from monitoring wells MW- 2A, MW-9, MW-10 and ECS-5 according to DEP procedures. Unfortunately the worst well, MW-12, had been damaged and could not be sampled. The samples were transported to Groundwater Analytical under chain-of-custody protocol. The four samples were analyzed for VPHs with target VOCs by the DEP method and for total and dissolved lead. The results for the compounds detected are summarized and compared to the applicable GW-2 or GW-3 cleanup standards in Table Four. The four samples were also analyzed for nitrate plus nitrite and total phosphorus. The samples from MW-2A, MW-9 and ESC-5 were also measured for heterotrophic bacteria. We also inspected the four wells for gasoline and measured the pH in wells MW-9 and MW- 10 and the dissolved oxygen and temperature in well MW-9. The measurements and our normal ranges are listed in Table Four. Copies of our Monitoring Well Sampling Log and the laboratory analysis report are included in Appendix C. As stated in the report, the samples were collected in the appropriate containers with the required preservatives. No duplicate samples were collected because the total number of samples was less than 20. The samples adequately represented the groundwater in the area of each well. No holding times were exceeded. There was one modification of the methods. All four samples were diluted to keep the target analytes with calibration prior to VPH analysis. There were no non-conformances and no analysis issues. Only lead was requested to be reported by EPA Method 6010B, not all 14 of the MCP metals. The laboratory filtered and then preserved the samples to be analyzed for dissolved lead. All the surrogate recoveries were within the quality control limits. Quality control protocols were conducted and met the prescribed recovery limits. The detection limits were below the applicable cleanup standards. The results appear to have achieved presumptive certainty under the Compendium of Analytical Methods for the field collection and laboratory analysis. The laboratory report met the requirements of 310 CMR 40.0017. Page 37 PENNEY ENGINEERING, INC TABLE FOUR Summary of Groundwater Results September 18, 2008 Cleanup Standards Parameters (ug/l)MW-2A MW-9 MW-10 ECS-5 GW-2 GW-3 (Applicable Standard)(GW-2)(GW-3)(GW-3)(GW-2) VPHs C5-C8 aliphatics 9,000 9,500 15,000 410 3,000 50,000 C9-C12 aliphatics 5,000 6,300 17,000 380 5,000 50,000 C9-C10 aromatics 3,400 6,600 18,000 390 7,000 50,000 Target VOCs MTBE <250 <120 <250 <50 50,000 50,000 Benzene 3,400 2,400 1,500 82 2,000 10,000 Toluene 6,600 4,200 11,000 <50 50,000 40,000 Ethylbenzene 1,000 780 2,100 73 20,000 5,000 Xylenes 4,200 3,900 13,000 110 9,000 5,000 Naphthalene <250 240 540 <50 1,000 20,000 Metals Lead, Total 23 <5 <5 <5 NS NS Lead, Dissolved <5 <5 <5 <5 NS 10 NS – Not specified As shown in bold in Table Four, the results for MW-2A, located at 480 Pleasant Street, were still relatively high. The concentrations of the C5-C8 aliphatics and benzene in MW-2A were above the GW-2 cleanup standards but below the GW-3 cleanup standards. The C9-C12 aliphatics were at the GW-2 cleanup standard. Because the GW-3 cleanup standards for the VPH fractions had increased from 4,000 to 50,000 on December 14, 2007, the VPH concentrations in MW-9 and MW-10 were below the applicable cleanup standards. The concentrations of xylenes in MW-10 were above the applicable GW-3 cleanup standard. Page 38 PENNEY ENGINEERING, INC TABLE FIVE Summary of Groundwater Measurements September 18, 2008 Normal RangesParametersMW-2A MW-9 MW-10 ESC-5 ORP (mV) NT (-)134.7 NT NT 50 - 300 Dissolved Oxygen (mg/l) NT 0.49 NT NT 1.0 – 3.0 pH NT 6.9 6.9 NT 5.7 – 8.2 Temp (°C) NT 18.2 NT NT 5.0 – 20.0 Bacteria Counts (cfu/ml) 60,000 <10,000 NT 1,000 0 – 2,500 Nitrate plus Nitrite (mg/l) 23 0.34 0.05 23 0 – 0.5 Total Phosphorus (mg/l) 19 290 6.0 1.0 0 – 20.0 NT – Not tested As shown in Table Five, the bacteria counts in MW-2A were above our normal range which indicated that bioremediation was occurring. Nitrate plus nitrite were also above our normal range in both MW-2A and ESC-5. Total phosphorus was significantly above our normal range in MW-9. On November 5, 2008, we collected three, composite soil samples from the excavation for Recovery Well RW-2. Composite samples were collected to represent the general soil conditions in the specific sampling area. The samples were collected just above the groundwater table at depths from eight to ten feet and labeled as S-1 Pit, S-2 Pit and S- 3 Pit. The three samples were transported to Groundwater Analytical under chain-of- custody protocol. The samples were analyzed for VPHs with target VOCs. The results for the compounds detected are summarized and compared to the S-1/GW-3 and S- 2/GW-3 cleanup standards in Table Six. A copy of the laboratory analysis report is included in Appendix C. As stated in the report, the samples were collected in the appropriate containers with the required preservatives. No duplicate samples were collected because the total number of samples was less than 20. Composite samples were collected to represent the general soil conditions in the specific sampling area. No holding times were exceeded. There was one modification of the method by dilution and one non-conformance. The non-conformance was because Mr. Penney did not record the collection times on the Chain-of-Custody form so the samples were reported with a sampling collection time of 00:00 by the laboratory. The sample S-1 Pit (8-10’) was diluted prior to analysis due to matrix interference. There were no analysis issues. All the surrogate recoveries were within the quality control limits. Quality control protocols were conducted and met the prescribed recovery limits. Nothing was detected in the method blank. The detection limits were below the applicable cleanup Page 39 PENNEY ENGINEERING, INC standards. The results appeared to have achieved Presumptive Certainty under the Compendium of Analytical Methods for the field collection and laboratory analysis. The sampling, analysis and laboratory report met the requirements of 310 CMR 40.0017. TABLE SIX Summary of Soil Results November 5, 2008 Cleanup StandardsParameters (mg/kg) (Depth)(ft) S-1 Pit (8-10) S-2 Pit (8-10) S-3 Pit (8-10) S-1/GW-3 S-2/GW-3 VPHs C5-C8 aliphatics 29 50 16 100 500 C9-C12 aliphatics 35 76 21 1,000 3,000 C9-C10 aromatics 39 65 17 100 500 Target VOCs MTBE <0.15 <0.08 <0.07 100 500 Benzene 0.73 0.73 0.75 30 200 Toluene 2.7 3.7 1.3 500 1,000 Ethylbenzene 1.7 1.9 0.58 500 1,000 Xylenes 7.1 7.1 2.07 500 1,000 Naphthalene 1.7 1.4 <0.68 500 1,000 As shown in Table Six, gasoline-related contaminants were detected in all three samples but all the results were below the S-1/GW-3 and S-2/GW-3 cleanup standards. No MTBE was detected which indicated that the gasoline was formulated prior to 1978 or the MTBE has been washed away. On December 15, 2008, the system was inspected as shown on the monitoring log, included in Appendix B. We checked all the equipment, reassembled the piping to connect RW-2 and attempted to restart the system. The biodiffuser blower was seized after being off for two years and we could not free it. We removed the biodiffuser blower for service. We measured the depth to groundwater in RW-2 to be 8.04 feet from the rim. On January 9, 11, 12, 14, 15, and 19, 2009, the system was inspected as shown on the corresponding monitoring logs. On January 9, we installed a new biodiffuser blower. We checked the piping and started RW-2. It started and pumped at 1.8 gpm with the valve open one turn. We increased it to two turns and it pumped at 2.4 gpm. We increased it again to three turns and it pumped at 2.5 gpm. It pumped 25 gallons and stopped. It would run for 10 to 20 seconds, the meter would spin and air would come out of the sampling port, then it would stop. The pump would continue to draw 7.0 A so it was spinning. This was repeated numerous times. We finally pulled the pump out and installed a brand new pump, but had the same problem. We found approximately Page 40 PENNEY ENGINEERING, INC 8” of silt at the bottom of RW-2. The screen was approximately 1½ feet above the silt. The water was clean. We pulled the water meter and it was clean. We started RW-1. It ran fine at 1.0 gpm. We tried to fill the biodiffuser. We shut down RW-1 and opened the sampling ports to let water drain back to RW-1 and RW-2 through the leaking check valve. We set up an electric heater and plugged in the heat tape for the water pipes under the trailer. The insulation around the pipes was pretty tight and we assumed the heat tape was working. On January 12, Mr. Kalish filled the biodiffuser with water from RW-1. RW-2 still would spin the meter for a while and then stop. He primed the discharge pump and purged air from the filter. He let the biodiffuser fill and the discharge pump came on but did not shut off at the low level in the clearwell. The controller was assumed to be bad after being off for over two years. The electric heater had maintained the temperature inside the trailer at 48° F with the outside temperature at 26° F without any of the electric motors running. It was going to get colder and a second electric heater was thought to be needed to prevent the water in the piping and biodiffuser from freezing. On January 14, we tapped the Discharge Pump controller and it began to work fine. The system was started with RW-1 pumping at 1.2 gpm. On January 15, the system was checked and was found to still be running. The outside temperature was down to 18° F but the temperature inside the trailer was 43°. On January 19, we inspected the system and attempted to diagnose the problem with RW-2. A total of 5,462 gallons of water had been pumped from RW-1 since January 15. The Discharge Pump continued to operate automatically. The pump for RW-2 may have been left on since January 16th. We disconnected the water meter for RW-2 and connected a hose from city water. We turned it on and water could he heard flowing into the pipe. The pressure only went to 12 psi on the old gauge. The foot valve on the brand new pump may have been leaking or there was poor pressure from the water supply or there was a leak in the pipe. We removed the cap from pump RW-2 riser pipe and turned the supply water on. Water flowed out at approximately 5 gpm. We shut off the supply and turned on RW-2. Water flowed out of the riser at approximately 5 to 6 gpm. We removed the hose, replaced the meter and ran the pump. Water flowed at 2 gpm after waiting a few minutes for the 1½” pipe to fill with 22 gallons of water. The meter was leaking so we shut off the pump and loosened the meter. There was a sucking sound from the water rushing back so the foot valve was leaking or maybe there was a leak or crack in the pipe. We turned the pump on again and adjusted the flow rate. We could only get a maximum flow rate of 1.5 gpm with the valve wide open. Page 41 PENNEY ENGINEERING, INC We turned off the valve and got no pressure. We switched gauges and still got no pressure. We let it run at 1.4 gpm over lunch and it was still running when we returned. The pump in RW-2 continued to draw only 7.0 amps. Everything indicated that there was a crack or leak in the piping from RW-2. It was agreed to keep the control valve open to minimize the possible leak. The filter pressure was still low. We started the SVE system blower. It ran but then set off the alarm. There was no water in the moisture separator. We isolated the SVE Zones and screened the effluent with an OVM. The results were recorded on the Monitoring Log. Zones A and C were high. We set up the dialer to call Mr. Kalish’s cell phone, the Penney Engineering office and Mr. Penney’s cell phone. The union in RW-1 was leaking. There was a strong gasoline smell in RW-1. The groundwater system was left running with RW-1 pumping at 1.0 gpm and RW-2 pumping at 1.2 gpm. On February 2, 13 and 28, 2009, the system was inspected as shown on the corresponding monitoring logs. On February 2, the system was running. The system had pumped 61,683 gallons since we began pumping groundwater from both RW-1 and RW-2 on January 14, 2009. On February 11, Mr. Kalish inspected the system and observed that the water meter for RW-1 was not spinning. He called Mr. Penney and was directed to shut off RW-1. The system continued to operate with RW-2 at 2.0 gpm. On February 12 at 6:12 AM, the dialer called out to warn that the system had shut down. At 9:00 AM, one of the mechanics at Pleasant Journey shut off the alarms and the treatment systems when he arrived for work. Later that day, Mr. Kalish changed the water filter and attempted to restart the system. Foam quickly formed on top of the water in the biodiffuser. Mr. Kalish was instructed to leave the system off. On February 13, Mr. Penney and Mr. Kalish inspected the system and conducted the quarterly groundwater monitoring. After sampling the groundwater monitoring wells, we began to diagnose the problems with the groundwater treatment system. There was water in the biodiffuser blower. It was disconnected and operated until it dried itself. The Discharge Pump operated correctly and the water filter had been changed on February 12. We started the biodiffuser and foam quickly formed on top of the water and began being drawn into the blower. We had noted earlier that the sample collected from monitoring well WS-1 had foam on the water making it difficult to close the VOA vials without any bubbles. The samples from RW-2 also contained foam when agitated. We determined that the groundwater being pumped exclusively from RW-2 since February 11 contained soap, possibly from the Car Wash. An anti-foaming system was needed. The system was left off. The pump in RW-1 drew 20 amps indicating that it needed to be replaced. Page 42 PENNEY ENGINEERING, INC On February 13, 2009, we also conducted the quarterly groundwater monitoring by collecting groundwater samples from monitoring wells WS-1, MW-9, MW-10 and the influent from RW-2 according to DEP procedures. We had planned to also sample the influent from RW-1, the effluent, MW-12, and ESC-5. Unfortunately, monitoring wells MW-2A, MW-8, and MW-12 had been damaged. Well ESC-5 was covered with ice and snow. The pump in Recovery Well RW-1 could not be restarted so it could not be sampled. The groundwater treatment system had automatically shutdown at 6:12 AM on February 12, 2009 due to foaming in the biodiffuser. At 1:47 PM on February 13, the pump in RW-2 was restarted. The system was allowed to operate for approximately 1.25 hours before a sample from RW-2 was collected. The wells were purged so that the samples adequately represented the groundwater in the area of each well. The samples were transported to Groundwater Analytical under chain-of-custody protocol. The four samples were analyzed for VPHs with target VOCs by the DEP method. The sample from RW-2 was also analyzed for dissolved and total lead; nitrate plus nitrite; and total phosphorus. The results for the compounds detected are summarized and compared to the applicable GW-2 or GW-3 cleanup standards in Table Seven. All four samples were also measured for heterotrophic bacteria counts. The sample from RW-2 was also analyzed for surfactants to determine the concentration of the soap causing the foaming problem. We also measured the pH, dissolved oxygen and temperature in wells MW-9, MW-10 and WS-1. The measurements and our normal ranges are listed in Table Eight. Copies of our Monitoring Well Sampling Log and the laboratory analysis report are included in Appendix C. The results and a Notice of Environmental Sampling (BWSC-123) are being sent to the property owners concurrently with this report. A copy of the Notice of Environmental Sampling (BWSC-123) is included in Appendix A. As stated in the report, the samples were collected in the appropriate containers with the required preservatives. No duplicate samples were collected because the total number of samples was less than 20. No holding times were exceeded. There was one modification of the methods. All four samples were diluted to keep the target analytes with calibration prior to VPH analysis. The sample from RW-2 was diluted because of foaming. There were no non-conformances and no analysis issues. Only lead was requested to be reported by EPA Method 6010B, not all 14 of the MCP metals. The laboratory filtered and then preserved the sample to be analyzed for dissolved lead. All the surrogate recoveries were within the quality control limits. Quality control protocols were conducted and met the prescribed recovery limits. Nothing was detected in the method blanks. The detection limits were below the applicable cleanup standards. The results appeared to have achieved presumptive certainty under the Page 43 PENNEY ENGINEERING, INC Compendium of Analytical Methods for the field collection and laboratory analysis. The laboratory report met the requirements of 310 CMR 40.0017. TABLE SEVEN Summary of Groundwater Results February 13, 2009 Cleanup Standards RW-2 Influent Parameters (ug/l)WS-1 MW-9 MW-10 GW-2 GW-3 (Applicable Standard)(GW-2)(GW-3)(GW-3)(GW-2) VPHs C5-C8 aliphatics 6,200 12,000 21,000 730 3,000 50,000 C9-C12 aliphatics 1,500 2,200 5,400 <200 5,000 50,000 C9-C10 aromatics 8,200 7,800 17,000 680 7,000 50,000 Target VOCs MTBE <250 <500 <1,000 <50 50,000 50,000 Benzene 86 4,900 2,800 130 2,000 10,000 Toluene 290 14,000 24,000 350 50,000 40,000 Ethylbenzene 1,100 1,400 3,500 79 20,000 5,000 Xylenes 3,530 8,200 19,200 380 9,000 5,000 Naphthalene <250 <500 <1,000 <50 1,000 20,000 Metals Lead, Total NT NT NT 11 NS NS Lead, Dissolved NT NT NT <5 NS 10 NS – Not specified NT – Not tested As shown in bold in Table Seven, the concentrations of the C5-C8 aliphatics and the C9- C10 aromatics in WS-1 were above the applicable GW-2 cleanup standards. The results from WS-1 may warrant indoor air monitoring in the Car Wash building. Xylenes were detected in wells MW-9 and MW-10 above the applicable GW-3 cleanup standard. The results showed that the plume was still centered under Pleasant Street. The groundwater results are indicators of the soil contamination. The results for pumping well RW-2 were relatively low. Page 44 PENNEY ENGINEERING, INC TABLE EIGHT Summary of Groundwater Measurements February 13, 2009 RW-2 Influent Normal RangesParametersWS-1 MW-9 MW-10 Dissolved Oxygen (mg/l) 0.8 1.6 2.0 NT 1.0 – 3.0 pH 7.8 7.6 7.7 NT 5.7 – 8.2 Temp (°C) 13.8 12.0 11.04 NT 5.0 – 20.0 Bacteria Counts (cfu/ml) 88,000 64,000 15,500 78,000 0 – 2,500 Nitrate plus Nitrite (mg/l) NT NT NT 0.11 0 – 0.5 Total Phosphorus (mg/l) NT NT NT <0.5 0 – 20.0 Surfactants (mg/l) NT NT NT 1.62 Not detected NT – Not tested As shown in bold in Table Eight, the bacteria counts were highest on the eastern side of Pleasant Street. Although the counts are not specific for petroleum metabolizing bacteria, they may be a direct indicator of petroleum contamination. The dissolved oxygen, pH, and temperature were within our normal ranges for all wells tested. A significant concentration of surfactants was detected in RW-2 which indicated that the groundwater in the area of RW-2 contained soap. After observing the foaming in the Biodiffuser on February 13 and receiving the surfactant results for WS-1, we began to design an anti-foaming system. A biodegradable dimethylsilicone anti-foaming agent was selected. We did not have a budget to conduct jar tests so we estimated the required dose based upon prior experience. On February 25, we notified Mr. Scherer at the DEP of the proposed injection of an anti-foaming agent as a remedial additive. We fabricated most of the system from materials we had in our shop and ordered what we needed. On February 26, we send a description of the proposed anti-foaming system and information on the remedial additives as a minor modification of our Phase IV Plan. On February 28, we installed an anti-foaming system, a new 7 gpm pump in RW-2 and moved the newer 5 gpm pump from RW-2 to RW-1. The pump in RW-1 was found to be submerged in silt and the motor was loose. We set up a dosing pump to inject a solution of remedial additives into the first stage of the Biodiffuser to reduce the foaming and enhance the bioremediation of the gasoline contaminants. The solution to be injected was made by filling a 55-gallon drum with treated groundwater from the biodiffuser and adding one gallon of PlantPro Sewer Anti-Foam Concentrate (anti- foaming agent), one lb of Woodace water soluble micronutrients, and 1/4 lb of powdered Munox 10x Multiplier, freeze-dried Pseudomonas bacteria cultures. The Page 45 PENNEY ENGINEERING, INC dosing pump was mounted on the drum and set to continuously inject the 55 gallons of remedial additives solution into the first stage of the Biodiffuser over an eight-day period. We also added one quart of the anti-foaming agent directly into the Biodiffuser to quickly reduce the foam. When we started the Biodiffuser there was no foaming. We set the flow rate to be 1.0 gpm from RW-1 and 2.0 gpm from RW-2. The dose of the anti-foaming agent was based upon a flow rate of 2.0 gpm from RW-2. On February 28, 2009, we also collected a groundwater sample from monitoring well WS-1, located closest to the car wash, according to DEP procedures. The well was purged so that the sample adequately represented the groundwater in the area of the well. The sample was transported to Groundwater Analytical under chain-of-custody protocol. The samples were analyzed for nitrate plus nitrite and surfactants and measured for heterotrophic bacteria counts. We also measured the pH, dissolved oxygen and temperature in well WS-1. The measurements and our normal ranges are listed in Table Nine. Copies of our Monitoring Well Sampling Log and the laboratory analysis report are included in Appendix C. As stated in the report, the samples were collected in the appropriate containers with the required preservatives. No duplicate samples were collected because the total number of samples was less than 20. There was one non-conformance and analysis issue. The bacteria counts were analyzed outside of the recommended holding time. There were no sample collection times listed on the Chain-of-Custody, so the samples were reported with a sampling collection time of 00:00 by the laboratory. There were no modification of the methods. All the surrogate recoveries were within the quality control limits. Quality control protocols were conducted and met the prescribed recovery limits. Nothing was detected in the method blanks. The detection limits were below the applicable cleanup standards. The results appeared to have achieved presumptive certainty under the Compendium of Analytical Methods for the field collection and laboratory analysis. The laboratory report met the requirements of 310 CMR 40.0017. Page 46 PENNEY ENGINEERING, INC TABLE NINE Summary of Groundwater Measurements February 28, 2009 Parameters WS-1 Normal Ranges Dissolved Oxygen (mg/l) 1.0 1.0 – 3.0 pH 7.6 5.7 – 8.2 Temp (°C) 13.6 5.0 – 20.0 Bacteria Counts (cfu/ml) 200,000 0 – 2,500 Nitrate plus Nitrite (mg/l) 0.32 0 – 0.5 Surfactants (mg/l) 6.00 Not detected As shown in bold in Table Nine, the level of surfactants in WS-1 was much higher than the level measured in the sample collected from RW-2 on February 13, 2009, that the source of the soap may be the Car Wash. 6.5 Summary of Historical Results In order to evaluate the effectiveness of the SVE and the groundwater treatment systems at 459 Pleasant Street, we continually 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 vapor phase carbon vessel. The initial SVE influent concentration on September 9, 2003 was 121.0 ppm, measured as air sample AS-2. 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 RW-1 and 465.30 Page 47 PENNEY ENGINEERING, INC 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 at the site. 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 found to be 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. The prior summer the durations were 13, 9, 7, 6, 6, 7, 4, 5, and 6 days for the same two months. The amount of gasoline recovered was slightly more. The increased duration meant that the volume of gasoline trapped in the pores spaces had greatly decreased. From January 27, 2005 until December 14, 2005, the SVE system influent continued to fluctuate with the groundwater table. The SVE influent concentrations were much lower, the durations of operation between regenerations were longer and the volume of gasoline recovered during comparable regenerations was less, but there was still a direct correlation between the height of the groundwater and the performance or effectiveness of the SVE system. The correlation was a result of the smear zone above the groundwater being more exposed when the groundwater table drops and less exposed when the groundwater table rises. From December 14, 2005 until June 30, 2006, when both systems were shut down, the SVE system had only operated for 72 days. On December 14, 2005, we had shut down the SVE system because of the low recovery expected during the winter months. The SVE system was not restarted until April 18, 2006 after we replaced the damaged blower. The SVE influent concentrations were only 0.4, 3.1, and 1.8 ppm during this period. On May 3, 2006, we regenerated the carbon after 14 days of known operation and 1,535 hours or 64 days of assumed operation over the winter. We recovered only 3.5 gallons of gasoline. Page 48 PENNEY ENGINEERING, INC In order to better evaluate the SVE system data, we prepared a series of plots. 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 shows that the fall of 2004 rising of the groundwater table caused decreases in the SVE system influent concentrations and the volumes of gasoline recovered, but increases in the duration between regenerations of the carbon. The response was repeated in the fall of 2005, as shown in Chart Four. Chart Four also shows that the falling groundwater table in the summer of 2005 caused increases in the SVE system influent concentrations and the volumes of gasoline recovered, but decreases in the duration between regenerations. Those responses clearly indicate that there were still globules of gasoline remaining in the pore spaces of the soil in the smear zone at the groundwater table. As shown in Charts One through Four, the volume of gasoline recovered during each regeneration has steadily decreased. Clearly the SVE system has almost adequately remediated the gasoline in the pore spaces of the soil at 459 Pleasant Street. In October, 2005 we began to plot the ratio of the gasoline recovered during each regeneration of the carbon to the duration of operation and the date of the regeneration since we began regenerating the carbon on September 22, 2003. Regression Chart One, included in the Figures section, shows dramatic increasing during the late summers of 2003 and 2004. In the late summer of 2005, there was only a slight increase, which indicated that much less gasoline remained trapped in the pore spaces of the contaminated soil at the site. The chart also shows that the SVE system was removing much less gasoline after January 2005. In summary, the soil at 459 Pleasant Street was highly contaminated with gasoline and the SVE system has been very effective at removing it, but there are still gasoline globules left to vent. It may also be removing gasoline that has been drawn back to 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 evaluated the quarterly groundwater and influent monitoring results. Since April 25, Page 49 PENNEY ENGINEERING, INC 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 starting the SVE system on September 12, 2003, we gauged nine monitoring wells at the site to measure the depth to groundwater and to inspect each for 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-9, MW-10, MW-12, ECS-5 and MW-2A had a gasoline odor. On March 18, 2004, we observed one-sixteenth inch of free-phase gasoline in well MW-1. On September 21, 2004, we only observed a sheen in wells MW-9, MW-10, MW-12, and ECS-5. On December 9, 2004, we only observed a sheen in wells MW-1, MW-9, MW-10, MW-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 November 11, 2003 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 Figures One and Two, on October 11, 2000 and April 25, 2002, respectively, 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 was expected to greatly affect the groundwater over a large area in the low permeability soil at the site. As shown on the 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 Three and Four. 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 monitoring well that is one stagnant point. The results are summarized and compared to the applicable GW-3 cleanup standards in Historical Table One, included in the Figures section. The results for the C5-C8 aliphatics and the C9-C10 aromatics fractions Page 50 PENNEY ENGINEERING, INC 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. On December 14, 2007, the GW-3 cleanup standards for the VPH fractions increased to 50,000 ug/l. As shown in Historical Table One, 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 December 14, 2005, the influent concentrations remained relatively constant, which indicated that gasoline was being drawn into Recovery Well RW-1. The reductions are more apparent in Chart Five. Only gradual 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 last three rounds of VPH influent results were at or below the GW-3 cleanup standards in effect at that time and well below the GW-3 cleanup standards in effect as of December 14, 2007. The installation of Recovery Well RW-2 at 480 Pleasant Street shall greatly increase the radius of influence of the groundwater treatment system and force the aerated, nutrient rich discharge water to move through the contaminant plume under Pleasant Street. It shall 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 Historical Table Two, 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 Recovery Well RW-1 from under and across Pleasant Street during the low, summertime level of the groundwater table. On March 24, 2005, we began to periodically manually apply surfactant and remedial additives to well MW-9. Initially, the results slightly increased, as shown by the June 13, 2005 results, but have since shown a steady decrease. The March 21, 2006 results were all below the GW-3 cleanup standards in effect at that time. The most recent September 18, 2008 results showed an increase as the system had not been fully operational for almost three years. However, the increase was still below the levels prior to March 2006 and was well below the GW-3 cleanup standards in effect since December 14, 2007. Again, only moderate decreases can be expected until the globules of gasoline in Page 51 PENNEY ENGINEERING, INC the pore spaces can be removed by the SVE system and the gasoline under the adjacent section of Pleasant Street is remediated. 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 Historical Table Three, 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 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 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 for the C9-C10 aromatics was probably caused by the surfactant dissolving the gasoline trapped in the surrounding soil. Because of changes in the cleanup standards on December 14, 2007, the most recent September 18, 2008 results for the VPH fractions were below the GW-3 cleanup standards and xylenes were above the GW-3 cleanup standards. In order to evaluate the groundwater treatment system, we also tabulated the quarterly monitoring results for well MW-12, which is located across Pleasant Street at 492 Pleasant Street, as shown on the Remedial Action Site Plan. The results are shown in Historical Table Four, included in the Figures section. As shown, the results remained relatively the same since we activated the groundwater treatment system on June 25, 2003 until December 9, 2004 when we began to periodically manually apply remedial additives directly into well MW-12. The results for the C5-C8 aliphatics and the C9-C10 aromatics are plotted in Chart Eight, included in the Figures section. The plotted results remained relatively constant until March 24, 2005. The results show that the groundwater treatment system had very little effect on the groundwater around well MW-12. The dramatic increase of the March 24, 2005 results was probably caused by the surfactant dissolving the gasoline trapped in the surrounding soil. The most recent March 21, 2006 results were all below the GW-3 cleanup standards. The effectiveness of the manually applied remedial additives may be limited to the area immediately around well MW-12, but the effects were significant. Page 52 PENNEY ENGINEERING, INC 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 were listed in Tables Fourteen, Seventeen, Twenty, Twenty-Three, Twenty-Six, Twenty-Nine, Thirty-Two, Thirty-Five and Thirty-Eight previously submitted to the DEP. 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. The current recirculation of the groundwater is producing a large area of oxygen and nutrient rich groundwater that is naturally migrating under and across Pleasant Street to enhance the bioremediation of the downgradient contaminants. 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. March 18, 2004, we observed one-sixteenth inch of free-phase gasoline in well MW-1. 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 previous SVE system may have removed a majority of the free-phase gasoline from both sides of Pleasant Street. The new, third SVE located along the 492 and 480 sides of Pleasant Street shall 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. 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 Page 53 PENNEY ENGINEERING, INC 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 were shown in Tables Thirteen, Fourteen, Seventeen, Twenty, Twenty-Three, Twenty-Six, Twenty-Nine, Thirty-Two, Thirty-Five and Thirty-Eight previously submitted to the DEP. High bacteria counts generally indicate high biological activity associated with the bioremediation of contaminants. The counts greatly increased since we began injecting microbe nutrients into the biodiffuser and applying remedial additives to specific wells. The three wells across Pleasant Street, MW-2A, MW-12 and ECS-5, had bacteria counts over one million. The bacteria counts in wells MW-9 and MW-10, located at 459 Pleasant Street, steadily decreased, indicating that we were achieving adequate remediation of that portion of the site. The counts indicated that the remedial additives were effectively bioremediating the petroleum contamination in the immediate area of the wells. Prior consultants have assumed that the source of the gasoline release was limited to the tanks and dispensers at 459 Pleasant Street. The former tanks at 480 Pleasant Street and the piping across Pleasant Street may be other sources. The extremely high bacteria counts in well MW-2A may indicate a source of petroleum, possibly diesel, contamination in the area of the former tanks. There may also have been additional tanks that supplied the former dispensers along Conz Street. The treatment systems shall be operated in accordance with our May 15, 2003 Phase III/IV Remedial Action and Remedy Implementation Plan as modified, the Phase IV Performance Standards, described in 310 CMR 40.0872, and the Response Action Performance Standards, as defined in 310 CMR 40.0191. The treatment systems are achieving the objectives of our Phase IV Plan. They shall operate until the significant risk has been reduced and the conditions for a Class A-2 Response Action Outcome have been achieved. 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. We shall submit an LSP Opinion regarding air emissions controls and the establishment of a discharge limit for TVOCs. Vapor phase carbon adsorption is one of the BACT for TVOCs. The annual loading shall be less than 2,000 lbs. The vapor phase carbon vessel is being used for both the off-gas from the groundwater treatment system and the SVE system. The TVOC concentrations in the off-gas from the groundwater system are relatively low at 1.0 to 3.0 ppm. The TVOC concentrations in the influent from the SVE systems have recently been measured to range from 17.0 to 33.0 ppm. We shall attempt to maintain a removal rate of at least 95% and use an interim discharge limit of Page 54 PENNEY ENGINEERING, INC 8.0 ppm TVOCs. The property line of the nearest residence from the discharge is approximately 200 to the north. Remedial additives, including micronutrients, anti- foaming agent and specific bacteria, shall be injected into the biodiffuser and manually applied to specific wells. We shall monitor the remedial additives on a monthly basis. 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. A thirteenth Phase V Remedy Operation Status and Remedial Monitoring Report shall be submitted to the DEP before the September 15, 2009 deadline. We may also conduct a subsurface investigation to determine if there are any abandoned tanks or other sources of contaminants at the site. 6.6 Update of Conceptual Site Model The site has historically been used as a gasoline service station from 1912 until 1984. 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 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. 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 (previously 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. The site is located in the Connecticut River Plain. The area is relatively flat. There are no visible bedrock outcrops and bedrock was not encountered during the advancement of any soil borings. The depth to bedrock has been estimated to be 120 to 170 feet. It is known to be New Haven Arkose, a sandstone, according to ECS. According to the Phase II Report by ECS, the soil at the site is Hadley-Winooski associated soils and Hinckley loamy sands. The groundwater is at a depth of approximately eight to 10 feet. The medium to coarse sand at 14 to 16 feet is expected to be of relatively high hydraulic conductivity to allow significant groundwater flow, however, the Connecticut River Plain is known to contain silt which restricts groundwater flow. The local groundwater flow direction is to the east, toward the Mill River which flows into the Connecticut River. The Mill River is located Page 55 PENNEY ENGINEERING, INC approximately 600 feet east of the site. The direction of the local groundwater flow is dependent upon the stage of the Connecticut River. In 2002, the dissolved gasoline contaminants were found to be slowly migrating to the east in the direction of the local groundwater flow. 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. In 1997, ECS conducted an extensive indoor air sampling program in the utilities and in four of the buildings located on the site. No significant vapors were detected. On April 25, 2002, we failed to detect any significant vapors while screening the four buildings with an OVM. 7.0 REMEDY OPERATION STATUS OPINION In November 2008, we were able to run new pipes across Pleasant Street and complete the installation of the remainder of the treatment systems at 480 and 492 Pleasant Street in order to remediate the gasoline contamination under Route 5. The treatment systems have been designed to adequately remediate the gasoline contamination in the soil and groundwater at the site in a predictable period of time in order to achieve a permanent solution. The systems shall be operated in accordance with 310 CMR 40.0891 and all applicable permits approvals and licenses. Once the vapor concentrations from a specific SVE zone have been adequately reduced, that zone shall be turned off. Eventually, the entire SVE system shall be shut down. The groundwater treatment system shall continue to operate until the quarterly groundwater monitoring results consistently remain below the applicable GW-2 and GW-3 cleanup standards for four consecutive quarters or as warranted. The groundwater system may be shutdown or intermittently operated to promote enhanced bioremediation. We may continue to remediate the site with Monitored Natural Attenuation. The groundwater shall be monitored at least quarterly. Representative soil samples shall be collected and analyzed to determine if any residual gasoline contaminants pose a significant risk before closing the site. Now the operation and maintenance of the completed treatment systems are considered a Comprehensive Remedial Action. We have met the requirements of Remedy Operation Status in accordance with 310 CMR 40.0893. The systems shall be operated and maintained until the contamination is adequately remediated to Page 56 PENNEY ENGINEERING, INC acceptable concentrations that no longer pose a significant risk of harm to health, safety, public welfare and the environment. We are hereby applying for Remedy Operation Status which shall suspend the deadline to achieve a Response Action Outcome within five years, reduce the next subsequent annual compliance fees from $2,000 to $800, and eliminate the need to annually extend the Tier II classification. Phase V Remedy Status Reports and Remedial Monitoring Reports shall continue to be prepared and submitted to the DEP every six months while the systems are operated. It is the opinion of Ralph Penney, as the LSP-of-Record for the site, that the site has now achieved Remedy Operation Status. 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 effective 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 may provide notification of the routine maintenance of the treatment systems or sampling of the wells at the site. All our reports are being posted on the City of Northampton website under the Pleasant Street Cleanup Project. 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. Page 57 PENNEY ENGINEERING, INC FIGURES SOURCE: USGS, EASTHAMPTON AND MT. HOLYOKE, MA QUADS, BOTH PHOTOREVISED 1979 PENNEY ENGINEERING, INC 0203/LOCUS MAP (3/12/09) SCALE = 1:25,000 LOCUS MAP PLEASANT STREET CLEANUP NORTHAMPTON, MA N SITE UTM 4 686 930 N 695 742 E PENNEY ENGINEERING, INC 0203/Phase V Reports/Table Two (3/23/04) TABLE TWO Summary of Specific 1998 Groundwater Results Cleanup Standards Parameter MW-1 MW-4 MW-5 MW-6 MW-8 MW-9 MW-12 ECS-1 ECS-2 ECS-4 ECS-5GW-2 GW-3 (Applicable Standard) (GW-2) (GW-3) (GW-2) (GW-2) (GW-3) (GW-3) (GW-3) (GW-3) (GW-2) (GW-3) (GW-2) VPH (μg/l) C5-C8 aliphatics < 200 1,300 3303,4003506,3001,600 1,500 < 200 < 2001,400 1,000 4,000 C9-C12 aliphatics 30,000 19,000 2,800 15,0001,70033,000 27,000 3,500 < 200 1,0002,400 1,000 20,000 C9-C10 aromatics 11,000 8,600 1,2006,9001,20014,000 15,000 2,600 < 200 460 1,3005,000 4,000 Target (μg/l) MTBE 310 200 14 74 27 420 360 63 < 5 < 10 < 20050,000 50,000 Benzene 10,100 4,800 170 720 778,700 7,500 630 < 5 11 1,7002,000 7,000 Toluene 12,900 5,000 500 990 31 19,700 18,500 450 < 5 15 4,2006,000 50,000 Ethylbenzene 3,800 1,400 290 860 27 3,4004,500 170 < 5 11 2,60030,000 4,000 Xylenes 17,300 8,100 970 2,160 109 18,600 22,700 855 < 5 5612,300 6,000 50,000 Naphthalene 400 350 61 430 45 1,000 1,100 77 < 5 38 6706,000 6,000 NS – No Standard PENNEY ENGINEERING, INC 0203/Phase V Reports/Table Three (3/18/04) TABLE THREE Summary of Groundwater Results April 25, 2002 Cleanup Standards Parameter MW-1 MW-3 MW-5 MW-6 MW-7 MW-8 MW-2A ECS-1 ECS-5 BRIDAL-447 GW-2 GW-3 (Applicable Standards) (GW-2) (GW-2) (GW-2) (GW-2) (GW-3) (GW-3) (GW-2) (GW-3) (GW-2) (GW-2) VPH (μg/l) C5-C8 aliphatics 34,000 <10 5907,100<10 1,00015,0002,40012,000161,000 4,000 C9-C12 aliphatics 9,500 <10 3102,800<10 1204,3007603,400301,000 20,000 C9-C10 aromatics 18,000 <10 51011,000<10 3509,8002,7007,100125,000 4,000 Target VOCs (μg/l) MTBE <500 <5 <5 <50 <5 7 <50 <5 <50 <550,000 50,000 Benzene 12,000 <5 22 460 <5 <5 1,500 3204,700<52,000 7,000 Toluene 32,000 <5 380 900 <5 <511,00061 3,300 <56,000 50,000 Ethylbenzene 4,700 <5 150 670 <5 <5 2,200 180 1,600 <530,000 4,000 Xylenes 23,500 <10 680 3,230 <10 <109,300714 5,100 <106,000 50,000 Naphthalene <500 <5 24 200 <5 <5 400 79 300 426,000 6,000 Total BTEX 72,200 <25 1,232 5,260 <25 <25 24,000 1,275 14,700 <25NS NS NS - No Standard PENNEY ENGINEERING, INC Main/0810/Photographs (3/18/09) PHOTOGRAPH ONE November 4, 2008 Western View of Stubbed Pipes Connections at 459 Pleasant Street PHOTOGRAPH TWO November 5, 2008 Northeastern View of Route 5 Crossing PENNEY ENGINEERING, INC Main/0810/Photographs (3/18/09) PHOTOGRAPH THREE November 5, 2008 Eastern View of RW-2 Leaching Pit Placed PHOTOGRAPH FOUR November 11, 2008 Plan View of Recovery Well RW-2 PENNEY ENGINEERING, INC 0203/Phase V Reports/Historical Table One – RW-1 Influent (3/12/09) HISTORICAL TABLE ONE Historical Summary of Results for RW-1 Influent Sampling Dates Parameters 6/25/03 9/22/0312/18/033/18/046/16/049/21/04 12/9/043/24/056/13/056/27/03 Cleanup Stds GW-3 VPHs (μg/l) C5–C8 aliphatics 20,000 5,3003,5004,400 5,300 4,600 4,200 4,000 4,000 4,000 C9–C12 aliphatics 4,400 5,400 3,100 2,400 2,400 1,400 <500 590 71020,000 C9–C10 aromatics 11,000 7,200 4,4003,0004,600 4,600 4,700 4,7003,6004,000Target VOCs (μg/l) MTBE < 250 < 250 < 125 75 < 125 < 125 < 125 <125 <12550,000 Benzene 11,000 2,300 2,100 1,800 2,600 1,600 2,100 2,100 1,5007,000 Toluene 29,000 7,500 5,2003,700 4,900 3,700 4,600 4,400 3,00050,000 Ethylbenzene 3,000 1,200 840 660 860 630 820 780 5304,000 Xylenes 16,100 6,700 5,000 3,240 4,000 3,160 3,700 3,700 2,65050,000 Sampling Dates Cleanup Standards GW-3 Parameters 3/24/05 6/13/05 9/21/05 12/14/05 3/21/06 9/18/08 6/27/0312/14/07VPHs (μg/l) C5–C8 aliphatics 4,000 4,0002,500 3,100 2,300 NS4,000 50,000 C9–C12 aliphatics 590 710 550 1,200 1,200 NS20,000 50,000 C9–C10 aromatics 4,700 3,600 2,400 3,3004,000NS4,000 50,000Target VOCs (μg/l) MTBE <125 <125 <50 <125 <125 NS50,000 50,000 Benzene 2,100 1,500 910 1,700 1,600 NS7,000 10,000 Toluene 4,400 3,000 1,500 3,300 2,900 NS50,000 40,000 Ethylbenzene 780 530 220 290 470 NS4,000 5,000 Xylenes 3,700 2,650 1,740 3,140 3,110 NS50,000 5,000 NS – Not Sampled PENNEY ENGINEERING, INC 0203/ Phase V Reports/Historical Table Two - MW-9 (1/21/09) HISTORICAL TABLE TWO Historical Summary of Groundwater Results for MW-9 Sampling Dates Parameters 6/25/03 9/22/03 12/18/03 3/18/04 6/16/04 9/21/04 12/9/04 6/27/03 Cleanup Stds GW-3 VPHs (μg/l) C5–C8 aliphatics 36,000 25,000NS NS21,000 84,000 17,000 4,000 C9–C12 aliphatics 28,00016,000 NS NS 6,70030,000<5,00020,000 C9–C10 aromatics 92,000 17,000NS NS16,000 73,000 12,000 4,000Target VOCs (μg/l) MTBE <1,000 < 1,250 NS NS < 1,000 < 1,000 < 1,25050,000 Benzene 20,000 21,000NS NS12,000 14,0004,2007,000 Toluene 63,00048,000 NS NS 28,000 43,000 29,00050,000 Ethylbenzene 4,9003,600 NS NS 2,7005,8003,4004,000 Xylenes 31,000 20,300 NS NS 16,700 32,000 16,30050,000 Naphthalene 6,1001,300 NS NS 1,000 2,500 <1,2506,000 NS – Not Sampled Sampling Dates Cleanup Standards GW-3 Parameters 3/24/05 6/13/059/21/05 12/14/05 3/21/06 9/18/08 6/27/0312/14/07VPHs (μg/l) C5–C8 aliphatics 14,000 20,000 17,000 13,0001,600 9,5004,000 50,000 C9–C12 aliphatics <2,000 <2,000 2,200 4,400 430 6,30020,000 50,000 C9–C10 aromatics 12,000 15,000 6,600 9,0001,700 6,6004,000 50,000Target VOCs (μg/l) MTBE 560 <500 <500 <250 <25 <12050,000 50,000 Benzene 5,500 5,2008,5001,000 71 2,4007,000 10,000 Toluene 24,000 21,000 24,000 9,900 310 4,20050,000 40,000 Ethylbenzene 2,700 3,100 2,900 2,900 50 7804,000 5,000 Xylenes 15,000 16,200 16,400 14,200 870 3,90050,000 5,000 Naphthalene 780 720 <500 550 26 2406,000 20,000 PENNEY ENGINEERING, INC 0203/ Phase V Reports/Historical Table Three - MW-10 (1/21/09) HISTORICAL TABLE THREE Historical Summary of Groundwater Results for MW-10 Sampling Dates Parameters 6/25/03 9/22/03 12/18/03 3/18/04 6/16/04 9/21/04 12/9/04 6/27/03 Cleanup Stds GW-3 VPHs (μg/l) C5–C8 aliphatics 20,000 18,000 13,000 27,000 26,000 24,000 16,000 4,000 C9–C12 aliphatics 4,200 16,0004,300 6,400 9,200 5,100 <5,00020,000 C9–C10 aromatics 18,000 18,000 7,000 9,100 13,000 11,000 12,000 4,000Target VOCs (μg/l) MTBE <500 < 1,250 < 250 580 < 1,250 <1,000 <1,25050,000 Benzene 10,000 10,0007,00012,0005,300 6,500 6,1007,000 Toluene 31,000 27,000 21,000 38,000 42,000 26,000 33,00050,000 Ethylbenzene 3,700 3,100 2,3004,100 4,7003,300 3,7004,000 Xylenes 21,000 14,300 13,600 20,800 25,500 16,200 19,30050,000 Naphthalene 670 <1,250 490 640 < 1,250 <1,000 <1,2506,000 Sampling Dates Cleanup Standards GW-3 Parameters 3/24/05 6/13/05 9/21/05 12/14/05 3/21/06 9/18/08 6/27/0312/14/07VPHs (μg/l) C5–C8 aliphatics 16,000 16,000 17,000 15,000 16,00015,0004,000 50,000 C9–C12 aliphatics <4,000 <5,000 2,200 5,600 5,100 17,00020,000 50,000 C9–C10 aromatics 13,000 20,000 6,600 13,000 16,00018,0004,000 50,000Target VOCs (μg/l) MTBE <1,000 <1,250 <500 <500 <1,000 <25050,000 50,000 Benzene 5,600 3,100 5,900 2,400 2,500 1,5007,000 10,000 Toluene 37,000 38,000 23,000 24,000 27,000 11,00050,000 40,000 Ethylbenzene 3,800 3,500 2,100 2,900 3,200 2,1004,000 5,000 Xylenes 22,400 24,900 11,500 16,900 19,00013,00050,000 5,000 Naphthalene <1,000 <1,250 <500 <500 <1,000 5406,000 20,000 PENNEY ENGINEERING, INC 0203/ Phase V Reports/Historical Table Four - MW-12 (1/21/09) HISTORICAL TABLE FOUR Historical Summary of Groundwater Results for MW-12 Sampling Dates Parameters 6/25/03 9/22/03 12/18/03 3/18/04 6/16/04 9/21/04 12/9/04 6/27/03 Cleanup Stds GW-3 VPHs (μg/l) C5–C8 aliphatics NS NS16,000 17,000 14,000 14,000 7,400 4,000 C9–C12 aliphatics NS NS 7,500 8,100 6,700 4,500 <1,00020,000 C9–C10 aromatics NS NS9,200 9,300 11,000 14,000 11,000 4,000Target VOCs (μg/l) MTBE NS NS 350 < 250 < 500 < 250 < 25050,000 Benzene NS NS 3,000 3,400 3,400 1,800 1,1007,000 Toluene NS NS 19,000 21,000 16,000 7,600 7,60050,000 Ethylbenzene NS NS 4,0004,1003,000 1,900 1,9004,000 Xylenes NS NS 19,900 20,400 15,700 10,200 8,90050,000 Naphthalene NS NS 770 620 570 460 5906,000 NS – Not Sampled Sampling Dates Cleanup Standards GW-3 Parameters 3/24/05 6/13/05 9/21/05 12/14/053/21/06 9/18/08 6/27/0312/14/07VPHs (μg/l) C5–C8 aliphatics 940,000 NA NA <2,000 <1,000 NS4,000 50,000 C9–C12 aliphatics 400,000 NA NA <2,000 <1,000 NS20,000 50,000 C9–C10 aromatics 700,000 NA NA4,9002,400 NS4,000 50,000Target VOCs (μg/l) MTBE <50,000 NA NA <500 <250 NS50,000 50,000 Benzene <10,000 NA NA 490 280 NS7,000 10,000 Toluene 54,000 NA NA 3,700 1,500 NS50,000 40,000 Ethylbenzene <50,000 NA NA <500 <250 NS4,000 5,000 Xylenes 217,000 NA NA 6,100 1,490 NS50,000 5,000 Naphthalene <50,000 NA NA <500 <250 NS6,000 20,000 NS – Not Sampled NA – Not Analyzed Due to Foaming Date 9/22/03 10/1/03 10/7/03 10/14/03 10/20/03 10/24/03 10/30/03 11/5/03 11/11/03 11/18/03 11/25/03 12/2/03 12/10/03 12/18/03 12/29/03 1/12/04 1/29/04 2/12/04 2/26/04TotalGallons 7.50 14.75 18.30 17.00 15.50 16.50 13.50 11.50 12.50 12.25 12.25 12.00 12.00 10.00 8.50 5.50 10.50 7.50 9.00226.55Duration (days) 96764666777881114171414157SVE Influent (ppm) 95 89.7 100.7 90.2 85.5 60.2 54.2 47.5 36.5 39.7 33.4 27.5 10.1 13.1 17.8 18.3 22.9CHART ONE Gasoline Recovered During Regeneration of CarbonSeptember 22, 2003 thru February 26, 200410.509.007.5010.005.507.5014.7517.0016.5013.5012.0012.0018.3015.5011.5012.2512.2512.508.500.002.004.006.008.0010.0012.0014.0016.0018.0020.009/22/03 10/6/03 10/20/03 11/3/03 11/17/03 12/1/03 12/15/03 12/29/03 1/12/04 1/26/04 2/9/04 2/23/04Gasoline Recovered (gallons)SVE System Activated 9/9/03Area Paved 9/11/03PENNEY ENGINEERING, INCMain/0203/Remediation/Recovery Chart to 2-26-04(9/2/04) Date 3/11/04 3/25/04 4/6/04 4/19/04 5/3/04 5/13/04 5/24/04 6/4/04 6/16/04 6/29/04 7/12/04 7/21/04 7/28/04 8/3/04 8/9/04 8/16/04 8/20/04 8/25/04 8/31/04TotalGallons 13.00 14.00 12.00 10.00 11.00 9.00 11.00 11.50 11.50 13.50 12.50 11.50 13.00 13.50 13.00 14.00 15.00 15.75 14.00238.75Duration (days) 14 14 12 13 14 10 11 11 12 13 13 97667456181SVE Influent (ppm) - AS-2 26.4 32.1 22.3 16.7 14.3 15.1 25.1 25.7 17.5 26.1 29.3 34.3 38.5 37.1 42.3 43.7 40.2 42.8 37.1CHART TWOGasoline Recovered During Regeneration of CarbonMarch 11, 2004 thru August 31, 200414.0015.0014.0013.0013.5013.0014.0012.0010.0011.009.0011.0011.5011.5013.5012.5011.5013.0015.750.002.004.006.008.0010.0012.0014.0016.0018.003/11/04 3/25/04 4/6/04 4/19/04 5/3/04 5/13/04 5/24/04 6/4/04 6/16/04 6/29/04 7/12/04 7/21/04 7/28/04 8/3/04 8/9/04 8/16/04 8/20/04 8/25/04 8/31/04GallonsPENNEY ENGINEERING, INCMain/0203/Remediation/Recovery Chart to 8-31-04(9/21/04) Date 9/7/04 9/13/04 9/21/04 9/27/04 10/4/04 10/12/04 10/20/04 10/28/04 11/9/04 11/23/04 12/9/04 12/28/04 1/27/05 3/4/05TOTALSGallons 14.25 14.25 13.00 11.75 13.50 12.75 11.00 10.50 9.00 9.00 9.50 4.25 7.00 6.50146.25Duration (days)76867888121416193036185MW-5 GW EL 89.58 89.33 89.63 89.39 89.28 89.46 89.63 89.53 90.08 90.38 90.23 89.63SVE Influent (ppm) 42.9 39.7 36.7 32.8 16.4 43.7 28.9 20.2 17.8 15.2 10.7 6.5 4.0 10.5CHART THREEGasoline Recovered During Regeneration of Carbonand Groundwater Elevations of MW-5September 7, 2004 through March 4, 20059.507.006.504.259.009.0010.5014.2514.2513.0011.7513.5012.7511.0089.6390.0890.3890.2389.4689.6389.5389.5889.3389.6389.3989.280.002.004.006.008.0010.0012.0014.0016.00Gallons of Gasoline Recovered88.688.88989.289.489.689.89090.290.490.6MW-5 Groundwater ElevationGallons14.25 14.25 13.00 11.75 13.50 12.75 11.00 10.50 9.00 9.00 9.50 4.25 7.00 6.50MW-5 GW EL89.58 89.33 89.63 89.39 89.28 89.46 89.63 89.53 90.08 90.38 90.23 89.639/7/04 9/13/04 9/21/04 9/27/04 10/4/04 10/12/04 10/20/04 10/28/04 11/9/04 11/23/04 12/9/04 12/28/04 1/27/05 3/4/05PENNEY ENGINEERING, INC0203\Remediation\Recovery Chart to 3-4-05 (3/12/2009) PENNEY ENGINEERING, INC 0203\Remediation\Recovery Chart to 5/3/06 (9/18/06)CHART FOURGasoline Recovered During Regeneration of Carbonand Groundwater Elevations of MW-5April 6, 2005 through May 3, 20063.504.7511.5012.0010.506.506.757.257.2510.509.2511.505.0089.8891.5889.0889.2089.4889.9390.0390.8888.8388.6392.1391.0792.160.002.004.006.008.0010.0012.0014.00Gallons of Gasoline Recovered8687888990919293MW-5 Groundwater ElevationGallons7.25 7.25 6.75 6.50 10.50 12.00 11.50 10.50 9.25 11.50 4.75 5.00 3.50MW-5 GW EL92.16 90.88 90.03 89.93 89.48 89.20 89.08 88.83 88.63 92.13 91.58 91.07 89.884/6/05 5/17/05 6/29/05 7/13/05 8/3/05 8/22/05 9/9/05 9/21/05 10/6/05 10/24/05 11/9/05 12/14/05 5/3/06 6/25/03 9/22/03 12/18/03 3/18/046/16/04 9/21/04 12/9/04 3/24/05 6/13/05 9/21/05 12/14/05 3/21/06GW-3 Std C5–C8 aliphatics20,000 5,3003,5004,4003,5004,400 5,300 4,000 4,0002,500 3,100 2,3004,000 C9–C10 aromatics11,000 7,200 4,4003,0004,4003,0004,600 4,7003,600 2,400 3,300 4,0004,000CHART FIVEPlot of RW-1 Influent ResultsJune 25, 2003 thru March 21, 20062,3003,1002,5004,0004,0004,4005,30020,0005,3003,5004,4003,5004,0003,3002,4003,6004,7004,6003,00011,0007,2004,4003,0004,40005,00010,00015,00020,00025,0006/1/037/1/038/1/039/1/0310/1/0311/1/0312/1/031/1/042/1/043/1/044/1/045/1/046/1/047/1/048/1/049/1/0410/1/0411/1/0412/1/041/1/052/1/053/1/054/1/055/1/056/1/057/1/058/1/059/1/0510/1/0511/1/0512/1/051/1/062/1/063/1/064/1/06Results (ug/l) C5–C8 aliphatics C9–C10 aromaticsCleanup StandardsGW System Activated 6/25/03SVE System Activated 9/12/03PENNEY ENGINEERING, INC 0203/Phase V Reports/Influent Plot to 3-21-06 (3/12/09) 6/25/03 9/22/036/16/04 9/21/04 12/9/04 3/24/05 6/13/05 9/21/05 12/14/05 3/21/06GW-3 Std C5–C8 aliphatics36,000 25,000 21,000 84,000 17,000 14,000 20,000 17,000 13,0001,6004,000 C9–C10 aromatics92,000 17,000 16,000 73,000 12,000 12,000 15,000 6,600 9,0001,7004,000CHART SIXPlot of MW-9 ResultsJune 25, 2003 thru March 21, 20066,6001,60017,00084,00021,00025,00036,00020,00014,00017,00013,0001,70012,00073,00016,00017,00092,00012,00015,0009,000010,00020,00030,00040,00050,00060,00070,00080,00090,000100,0006/1/037/1/038/1/039/1/0310/1/0311/1/0312/1/031/1/042/1/043/1/044/1/045/1/046/1/047/1/048/1/049/1/0410/1/0411/1/0412/1/041/1/052/1/053/1/054/1/055/1/056/1/057/1/058/1/059/1/0510/1/0511/1/0512/1/051/1/062/1/063/1/064/1/06Results (ug/l) C5–C8 aliphatics C9–C10 aromaticsCleanup StandardsGW System Activated 6/25/03SVE System Activated 9/12/03Surfactant Began Being Applied to MW-9 3/24/05PENNEY ENGINEERING, INC 0203/Phase V Reports/MW-9 Plot to 3-21-06 (9/18/06) 6/25/03 9/22/03 12/18/033/18/04 6/16/04 9/21/04 12/9/04 3/24/05 6/13/05 9/21/05 12/14/05 3/21/06GW-3 Std C5–C8 aliphatics20,000 18,000 13,00027,000 26,000 24,000 16,000 16,000 16,000 17,000 15,000 16,000 4,000 C9–C10 aromatics18,000 18,000 7,0009,100 13,000 11,000 12,000 13,000 20,000 6,600 13,000 16,000 4,000CHART SEVENPlot of MW-10 ResultsJune 25, 2003 thru March 21, 200616,00017,00015,00026,00027,00013,00018,00020,00024,00016,00016,00016,00016,00013,0006,60013,0009,1007,00018,00018,00012,00011,00013,00020,00005,00010,00015,00020,00025,00030,0006/1/037/1/038/1/039/1/0310/1/0311/1/0312/1/031/1/042/1/043/1/044/1/045/1/046/1/047/1/048/1/049/1/0410/1/0411/1/0412/1/041/1/052/1/053/1/054/1/055/1/056/1/057/1/058/1/059/1/0510/1/0511/1/0512/1/051/1/062/1/063/1/064/1/06Results (ug/l) C5–C8 aliphatics C9–C10 aromaticsCleanup StandardsGW System Activated 6/25/03SVE System Activated 9/12/03Surfactant Began Being Applied to MW-10 3/24/05PENNEY ENGINEERING, INC 0203/Phase V Reports/MW-10 Plot to 3-21-06(9/18/06) 12/18/03 3/18/046/16/04 9/21/04 12/9/04 3/24/05 12/14/05 3/21/06GW-3 Std C5–C8 aliphatics16,000 17,00014,000 14,000 7,400 940,0002,000 1,0004,000 C9–C10 aromatics9,200 9,30011,000 14,000 11,000 700,000 4,9002,4004,000CHART EIGHTPlot of MW-12 ResultsDecember 18, 2003 thru March 21, 20067,40014,00014,00017,00016,0002,000940,0001,0002,40011,00014,00011,0009,3009,200700,0004,9000100,000200,000300,000400,000500,000600,000700,000800,000900,0001,000,00012/1/031/1/042/1/043/1/044/1/045/1/046/1/047/1/048/1/049/1/0410/1/0411/1/0412/1/041/1/052/1/053/1/054/1/055/1/056/1/057/1/058/1/059/1/0510/1/0511/1/0512/1/051/1/062/1/063/1/064/1/06Results (ug/l) C5–C8 aliphatics C9–C10 aromaticsCleanup StandardsSurfactant Began Being Applied to MW-12 12/9/04 PENNEY ENGINEERING, INC 0203/Phase V Reports/MW-12 Plot to 3-21-06(9/18/06) Date 9/22/03 10/1/03 10/7/03 10/14/03 10/20/03 10/24/03 10/30/03 11/5/03 11/11/03 11/18/03 11/25/03 12/2/03 12/10/03 12/18/03 12/29/03 1/12/04 1/29/04 2/12/04 2/26/04 3/11/04Gallons 7.50 14.75 18.30 17.00 15.50 16.50 13.50 11.50 12.50 12.25 12.25 12.00 12.00 10.00 8.50 5.50 10.50 7.50 9.00 13.00Duration (days) 9676466677788111417141414SVE Influent (ppm) 95 89.7 100.7 90.2 85.5 60.2 54.2 47.5 36.5 39.7 33.4 27.5 10.1 13.1 17.8 18.3 22.9 26.4REGRESSION CHART ONEGasoline Recovered/Duration During Regeneration of CarbonOctober 1, 2003 thru May 3, 200600.511.522.533.544.510/1/0311/1/0312/1/031/1/042/1/043/1/044/1/045/1/046/1/047/1/048/1/049/1/0410/1/0411/1/0412/1/041/1/052/1/053/1/054/1/055/1/056/1/057/1/058/1/059/1/0510/1/0511/1/0512/1/051/1/062/1/063/1/064/1/065/1/066/1/06Gallons Recovered/Duration (gal/day)Summer 2003Summer 2004Summer 2005PENNEY ENGINEERING, INCMain/0203/Remediation/Recovery-Duration Chart to 10-6-005 (9/20/06) APPENDIX A COMPREHENSIVE RESPONSE ACTION TRANSMITTAL FORM (BWSC-108) CRA REMEDIAL MONITORING REPORTS (BWSC-108A), NOTICE OF ENVIRONMENTAL SAMPLING (BWSC-123) AND COPIES OF THE CURRENT FIRE DEPARTMENT PERMIT TO STORE FLAMMABLE LIQUIDS, THE OCTOBER 6, 2008 MHD PERMIT TO CROSS ROUTE 5, THE OCTOBER 21, 2008 TRENCH PERMIT FOR THE CITY OF NORTHAMPTON, THE NOVEMBER 1, 2008 RIGHT OF ENTRY AUTHORIZATION FROM THE OWNERS OF THE PROPERTIES AT 480 AND 492 PLEASANT STREET, AND THE ELECTRICAL PERMIT RECEIVED ON DECEMBER 13, 2008 NOTICE OF ENVIRONMENTAL SAMPLING As required by 310 CMR 40.1403(10) of the Massachusetts Contingency Plan BWSC 123 This Notice is Related to Release Tracking Number A. The address of the disposal site related to this Notice and Release Tracking Number (provided above): 1. Street Address: ___________________________________________________ City/Town: _________________________ Zip Code: ____________ B. This notice is being provided to the following party: 1. Name: __________________________________________ 2. Street Address: ___________________________________________________ City/Town: _________________________ Zip Code: ____________ C. This notice is being given to inform its recipient (the party listed in Section B): 1. That environmental sampling will be/has been conducted at property owned by the recipient of this notice. 2. Of the results of environmental sampling conducted at property owned by the recipient of this notice. 3. Check to indicate if the analytical results are attached. (If item 2. above is checked, the analytical results from the environmental sampling must be attached to this notice.) D. Location of the property where the environmental sampling will be/has been conducted: 1. Street Address: ___________________________________________________ City/Town: _________________________ Zip Code: ____________ 2. MCP phase of work during which the sampling will be/has been conducted: Immediate Response Action Phase III Feasibility Evaluation Release Abatement Measure Phase IV Remedy Implementation Plan Utility-related Abatement Measure Phase V/Remedy Operation Status Phase I Initial Site Investigation Post-Class C Operation, Maintenance and Monitoring Phase II Comprehensive Site Assessment Other __________________________ (specify) 3. Description of property where sampling will be/has been conducted: residential commerical industrial school/playground Other____________________ (specify) 4. Description of the sampling locations and types (e.g., soil, groundwater) to the extent known at the time of this notice. E. Contact information related to the party providing this notice: Contact Name: _____________________________________________ Street Address: ___________________________________________________ City/Town: _________________________ Zip Code: ____________ Telephone: __________________________ Email: ______________________________ NOTICE OF ENVIRONMENTAL SAMPLING As required by 310 CMR 40.1403(10) of the Massachusetts Contingency Plan MASSACHUSETTS REGULATIONS THAT REQUIRE THIS NOTICE This notice is being provided pursuant to the Massachusetts Contingency Plan and the notification requirement at 310 CMR 40.1403(10). The Massachusetts Contingency Plan is a state regulation that specifies requirements for parties who are taking actions to address releases of chemicals (oil or hazardous material) to the environment. THE PERSON(S) PROVIDING THIS NOTICE This notice has been sent to you by the party who is addressing a release of oil or hazardous material to the environment at the location listed in Section A on the reverse side of this form. (The regulations refer to the area where the oil or hazardous material is present as the “disposal site”.) PURPOSE OF THIS NOTICE When environmental samples are taken as part of an investigation under the Massachusetts Contingency Plan at a property on behalf of someone other than the owner of the property, the regulations require that the property owner (listed in Section B on the reverse side of this form) be given notice of the environmental sampling. The regulations also require that the property owner subsequently receive the analytical results following the analysis of the environmental samples. Section C on the reverse side of this form indicates the circumstance under which you are receiving this notice at this time. If you are receiving this notice to inform you of the analytical results following the analysis of the environmental samples, you should also have received, as an attachment, a copy of analytical results. These results should indicate the number and type(s) of samples (e.g., soil, groundwater) analyzed, any chemicals identified, and the measured concentrations of those chemicals. Section D on the reverse side of this form identifies the property where the environmental sampling will be/has been conducted, provides a description of the sampling locations within the property, and indicates the phase of work under the Massachusetts Contingency Plan regulatory process during which the samples will be/were collected. FOR MORE INFORMATION Information about the general process for addressing releases of oil or hazardous material under the Massachusetts Contingency Plan and related public involvement opportunities may be found at http://www.mass.gov/dep/cleanup/oview.htm. For more information regarding this notice, you may contact the party listed in Section E on the reverse side of this form. Information about the disposal site identified in Section A is also available in files at the Massachusetts Department of Environmental Protection. See http://mass.gov/dep/about/region/schedule.htm if you would like to make an appointment to see these files. Please reference the Release Tracking Number listed in the upper right hand corner on the reverse side of this form when making file review appointments. APPENDIX B MONITORING LOGS FROM DECEMBER 15, 2008 TO MARCH 1, 2009 APPENDIX C MONITORING WELL SAMPLING LOGS AND LABORATORY ANALYSIS REPORTS FOR THE GROUNDWATER SAMPLES COLLECTED ON SEPTEMBER 18, 2008, FEBRUARY 13 AND 28, 2008 ! "#"! ##$"!%! " "&’(&)’! *"! "" !"% ""#"!"! "+#!" %#!" ! ,- ./# ,-0 /!/’12134 .5!2114 / ##! 627,# Page 1 of 36 Groundwater Analytical, Inc. P.O. Box 1200 228 Main Street Buzzards Bay, MA 02532 Telephone (508) 759-4441 FAX (508) 759-4475 www.groundwateranalytical.com !!"# $$%%&%& ! ’#()*#(+,-)*+.*/ "#$#%"&"’(&#)%*"+*$+"#,$’-./01 #(0*1’1’-.- "$+",+2 3$.4.56,$377 /&88$$$3&#3&$+$8&#"&$+ "$+",72 3$.4.56,$377 /&88$$$3&#3&$+$8&#"&$+ "$+",22 3$.4.56,$377 /&88$$$3&#3&$+$8&#"&$+ ’#()*#(+,-)*+.*/ "#$#%"&#’(&%)%*"+*$+""#8 ’-./01 #(0*1’1’-.- "$+",%%3$.4.56,$377 /&88$$$3&#3&$+$8&#"&$+ "$+",%+3$.4.56,$377 /&88$$$3&#3&$+$8&#"&$+ "$+",%7 3$.4.56,$377 /&88$$$3&#3&$+$8&#"&$+ ’#()*#(+,-)*+.*/ "#$#%"&,’(&"$)%*"+*$+"#$$’-./01 #(0*1’1’-.- "$+",+%3$.4.56,$377 /&88$$$3&#3&$+$8&#"&$+ "$+",++3$.4.56,$377 /&88$$$3&#3&$+$8&#"&$+ "$+",+7 3$.4.56,$377 /&88$$$3&#3&$+$8&#"&$+ ’#()*#(+,-)*+.*/ "#$#%"&3 -&8 )%*"+*$+",$$’-./01 #(0*1’1’-.- "$+",7%3$.4.56,$377 /&88$$$3&#3&$+$8&#"&$+ "$+",7+3$.4.56,$377 /&88$$$3&#3&$+$8&#"&$+ "$+",77 3$.4.56,$377 /&88$$$3&#3&$+$8&#"&$+ ’#()*#(+,-)*+.*/ "#$#%"&8 ’(&#)%*"+*$+"#,$-2$"$5 #(0*1’1’-.- "$3$77"#8$56#%8+%/94,&838+$#&$7&$+* ’#()*#(+,-)*+.*/ "#$#%"&2 ’(&%)%*"+*$+""#8 -2$"$5 #(0*1’1’-.- "$3$773 #8$56#%8+%/94,&838+$#&$7&$+* ’#()*#(+,-)*+.*/ "#$#%"&7 ’(&"$)%*"+*$+"#$$-2$"$5 #(0*1’1’-.- "$3$7#2 #8$56#%8+%/94,&838+$#&$7&$+* ’#()*#(+,-)*+.*/ "#$#%"&+-&8 )%*"+*$+",$$-2$"$5 #(0*1’1’-.- "$3$7+##8$56#%8+%/94,&838+$#&$7&$+* ’#()*#(+,-)*+.*/ "#$#%"&%’(&#)%*"+*$+"#,$-2$"$5 #(0*1’1’-.- """%%%3 #8$**/94,*** -)2-2- :0;<;<4<5="#$$;##+’;5>>5;’$#8,# Page 2 of 36 !!"# $$%%&%& ! ’#()*#(+,-)*+.*/ "#$#%"&"$’(&%)%*"+*$+""#8 -2$"$5 #(0*1’1’-.- """%2%8 #8$**/94,*** ’#()*#(+,-)*+.*/ "#$#%"&""’(&"$)%*"+*$+"#$$-2$"$5 #(0*1’1’-.- """%2%3 #8$**/94,*** ’#()*#(+,-)*+.*/ "#$#%"&"#-&8 )%*"+*$+",$$-2$"$5 #(0*1’1’-.- "",$$$$#8$**/94,*** ’#()*#(+,-)*+.*/ "#$#%"&",’(&#)%*"+*$+"#,$"$&"$7&$3&"& ’38$$&94,?!99 "$&""8&$"&"& -,28<3! #(0*1’1’-.- "$$222%#8$56#%3#8 /#43 **$#&#%&$+ ’#()*#(+,-)*+.*/ "#$#%"&"3 ’(&%)%*"+*$+""#8 "$&"$7&$3&"& ’38$$&94,?!99 "$&""8&$"&"& -,28<3! #(0*1’1’-.- """%+#7 8$$**/#43 *** ’#()*#(+,-)*+.*/ "#$#%"&"8 ’(&"$)%*"+*$+"#$$"$&"$7&$3&"& ’38$$&94,?!99 "$&""8&$"&"& -,28<3! #(0*1’1’-.- """%+#+8$$**/#43 *** ’#()*#(+,-)*+.*/ "#$#%"&"2 -&8 )%*"+*$+",$$"$&"$7&$3&"& ’38$$&94,?!99 "$&""8&$"&"& -,28<3! #(0*1’1’-.- "$$2287 #8$56#%3#8 /#43 **$#&#%&$+ ’#()*#(+,-)*+.*/ "#$#%"&"7 ’(&#)%*"+*$+"#,$’%#"85/ #(0*1’1’-.- "",$$$""#$**9 *** ’#()*#(+,-)*+.*/ "#$#%"&"+’(&%)%*"+*$+""#8 ’%#"85/ #(0*1’1’-.- "",$$$#"#$**9 *** ’#()*#(+,-)*+.*/ "#$#%"&#$-&8 )%*"+*$+",$$’%#"85/ #(0*1’1’-.- "",$$$3 "#$**9 *** -)2-2-3*4 :0;<;<4<5="#$$;##+’;5>>5;’$#8,# Page 3 of 36 !" #$%&’&(%)%*)&*)+*), -’%’.%&’&(%)/*)-*)0*)1*)(*)%’*)%%*)%& 2 34!567 282 57 9":57 ;57 2:)1,-1&-’.57 1%/%57 1++’57 -’%’.567 0,0’8%57 <1&0’57 1’1%57 #$567 -’&’57 (’%&&57 1’1&57 1’&%.57 $57 0’’’2 +57 ;57 %=9"457* 9!= &=2:)1,-(’%&5>4(’%,7?"??57 +=2)2:)1,-0’’’2=4?= >4*.*>4 @4?@4= =:??! ) )4?4 A B .=:C8C4>4 ?57 4 !*4">4 4C "4A B =?4>4 @4?*@2&=’ 4#* A B =#$$?:#$$4!4 " * 2%%=+A B >4!>4 @4?@4= =:C A B =:4 ?)48 57A !"""##"$ I, the undersigned, attest under the pains and penalties of perjury that, based upon my personal inquiry of those responsible for obtaining the information, the material contained in this analytical report is, to the best of my knowledge and belief, accurate and complete. 2"4 ;" $=D %&’ (()* %’)’+)’1 59?7 4 ? = +%&,"-’+#" Groundwater Analytical, Inc., P.O. 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" "#14*"%& # ’5#16*7+ 3 ()08&)28%20%95()()$#"’-:0 "*+2008 3228422&5;2&2(2:22595()()$-"* ’ ""*+205200 08(228%20%<)=)<2(02’ ""+2008(:2 50%95()5%#$0(0290444’ ""$+ *))&&280202>20820;0 2:;02&:&:22000:22 42243&)2? @20<)2&42&6A 25A??0A)*Page 30 of 36 !"# # !$$%&##### ’()*$!+#, -./01’-0+ !"# #-0 !$$%&##2$ 3 ’()*# +#, 0’01+ #"#!04*%&##2!# ’5!06*7+#3 0’01+ #"#!04*%&##2!# ’5!06*7+#3 /8&)18%1/%95()()$!2 ’:/#"*+1//8 3118411&5;1&1(1:11595()()$*#’#*+1/51// /8(118%1/%<)=)<1(/1’#"+1//8(:1 5/%95()5%"!$/(/19/444’#$+ ! 41/&&1&1181;<1811<&1&11&1; ;>18/1/1;1&1/11/./8?1//1 1 #41143&")1? @1/<)1&41&6# "15??/) * Page 31 of 36 !"#$%$&’()$&*!"’$%$&%"’$$$*+ !"#$%$&’()$&*!"’$%$&%"’$$$*+ )(’,&,-&%!./$(/)./$(/) !0$&%-$1 -$1 "#$%$ "#$%2"3 *4"4*&0(#4"45%,,#6/ #% 2 / !274 37 33 3 / $,&-’&$0$0.0 $,&-(&$0%-%0 $,&-’&$0$0.0 $,&-(&$0%--’ &’# ’# #’ $(’ & $(’ $ 8 94/4/:/%-$$4--04 4$-.’-Page 32 of 36 !"!#$%&!#’$!"!(!)#"$!!!’* &%$+#+,#")*)-)!.!!("!+#,%#!/","( !"! !012’343’#/% 30345"++ 6. !*)313781.*87 7917.*:1;. <<. " #$ !+#,$#!/!/(/ =83.3.>.",!!3,,/3;;3!,($,Page 33 of 36 ! "## ""#$% ! &’""#$" ()##$* +#", --. $% &’()(*" +/,0 $$.1 )+ ##&2&#,/&#3,#,/#,#,4,#"52&#6 2&#&’7-.$$,-"."#/*%0 ,&# %#1$# &’&#1 88#,"9#4,&, #%*-$. 2," 2 .!1% !2 #3 7# 4"### $# 4"#1,!5677668%,++,#%"769:6 Page 34 of 36 !"#$ %&# ’()’() ! " #"$%&!"’ "’"( "() )’)’ )()( !*!"* !*’!"*’ !"*!!+ ’ !"*’!,-"./%&! /*/* /*’/*’ ** 0)/*1 %&2 ,-"./%& */ ’ / ’$0)/*%&2 "/$* 3$/)*4 &52%&(1 *’ 3$/)*4 6%*%&( 3$/)*4 &52%&(2 ’ 173%*84 &1%&( 1*/’ 1*/%&1 ( +*%&(!"/$ /’ ’ /( ’ &*"$ ’ #!+ ’ #’/ ’ /)*79 ’ /)*799 ’ /)*7%*7 ’ / ’ +%&+!//"/ ’ %*’1*/ %*(2!+ ’ %:+/))3,4$ %:’+/))3,4$%&! %/*+ ’ %*7 +-/ ’ $*’9 $*(;</ $73$/)*4 6%*%&(/ $73$/)*4 &1%&(!/( $)):/%/)%&&.)* $)&.) $*/"%&!&.)’ =,.*/)&*" &"/* $ %&#&"/*’ ’()# #’ / ’#( #"$ !+ ’ **10)/*%& **’,/2) )//)-)")7"/<: 2*/>")&)):"77"/)/ "))/>"))77/")/*//>&))7 %)% 2*/>"9,!-’&%!*66/)!"& Page 35 of 36 ! "#$ %&’ ! "#"$%&’( "#"$)%&( *+ *+ *( *, -+ # *+ .!# -" *+ ./ 0!#12 & 0!’3 12 & *+ *( *, *+ 4-##! 5!2 / 1 &( 0# *+ 0# *( 0*& 0*& 02 & 6 + 6 ( ##1*"2."#7- 8 #9"*4-*2".."*## "#29"..#"# ##94. "’" 8 #9":1( ;;#"/ Page 36 of 36 ! "#"! ##$"!%! " "&’(&)’! *"! "" !"% ""#"!"! "+#!" %#!" ! ,- ./# ,-0" /!/’12134 /5!2116 / ##! 728,# Page 1 of 29 Groundwater Analytical, Inc. P.O. Box 1200 228 Main Street Buzzards Bay, MA 02532 Telephone (508) 759-4441 FAX (508) 759-4475 www.groundwateranalytical.com !"#"#$ ! %&’()’*+,)*-). "#$%&’(")*(+,#-"$-.+"."#)/0123 ’/)0%1 0%- """4&#$%.050 67$#"#%1 (88.."#(.#(.&"#(##(.& """4&##%.050 67$#"#%1 (88.."#(.#(.&"#(##(.& """4&#"%.050 67$#"#%1 (88.."#(.#(.&"#(##(.& %&’()’*+,)*-). "#$%&’(#)*(".,#-"$-.+".8.)/0123 ’/)0%1 0%- """4#4#%.050 67$#""’1 (88..""(#8(.&"#(##(.& """4#8&%.050 67$#""’1 (88..""(#8(.&"#(##(.& """4#8’%.050 67$#""’1 (88..""(#8(.&"#(##(.& %&’()’*+,)*-). "#$%&’($*(",#-"$-.+""88 )/0123 ’/)0%1 0%- """4#48 %.050 67$#""’1 (88..""(#8(.&"#(##(.& """4#4%%.050 67$#""’1 (88..""(#8(.&"#(##(.& """4#4$%.050 67$#""’1 (88..""(#8(.&"#(##(.& %&’()’*+,)*-). "#$%&’(%*(#,#-"$-.+"8.%)/0123 ’/)0%1 0%- """4&"#%.050 67$#"#%1 (88.."#(.#(.&"#(##(.& """4&""%.050 67$#"#%1 (88.."#(.#(.&"#(##(.& """4&."%.050 67$#"#%1 (88.."#(.#(.&"#(##(.& %&’()’*+,)*-). "#$%&’(8 *(#,#-"$-.+"8"#/4.".6 ’/)0%1 0%- ""$#%"%#8.--195$--- %&’()’*+,)*-). "#$%&’(4 *(#,#-"$-.+"8"8 /4.".6 ’/)0%1 0%- ".%.&’&#8.67#+8&+195$(8%8&.#(.’(.&- %&’()’*+,)*-). "#$%&’(’*(#,#-"$-.+"8".".(".’(.%("( )%8..(95$:!99 ".(""8(."("( /$48;%! ’/)0%1 0%- ""$#%.+8..--1#5%--- %&’()’*+,)*-). "#$%&’(&)*(+,#-"$-.+"."#)+#"861 ’/)0%1 0%- ""$#%"8 "#.--9 --- %&’()’*+,)*-). "#$%&’(+)*(".,#-"$-.+".8.)+#"861 ’/)0%1 0%- ""$#%"4 "#.--9 --- ,2 2 <2=;=;5;6>"#..=##&)=6??6=).#8$# Page 2 of 29 !"#"#$ ! %&’()’*+,)*-). "#$%&’(".*(",#-"$-.+""88 )+#"861 ’/)0%1 0%- ""$#%4&"#.--9 --- %&’()’*+,)*-). "#$%&’(""*(#,#-"$-.+"8.4 )+#"861 ’/)0%1 0%- ""$#%4+"#.--9 --- %&’()’*+,)*-). "#$%&’("#*(#,#-"$-.+"8"#/%#8;" ’/)0%1 0%- ""$#%’."--9 --- ,2 23)4 <2=;=;5;6>"#..=##&)=6??6=).#8$# Page 3 of 29 !" #$%&’()*+%,+&,+’,+( -.%./%&’()*+0,+- 1 23!456 171 46 8"9 46 :46 19+)(-)&-./46 )%0%46 )’’.46 -.%./456 *(*.7%46 ;)&*.46 ).)%46 #$456 -.&.46 <.%&&46 ).)&46 ).&%/46 $46 *...1 ’46 :46 %=8"346, 8!= &=19+)(-<.%&4>3<.%(6?"??46 ’=1+19+)(-*...1=3?= >3,/,>3 @3?@3= =9??! + +3?3 A B /=9C7C3>3 ?46 3 !,3">3 3C "3A B =?3>3 @3?,@1&=. 3#, A B =#$$?9#$$3!3 " , 1%%=’A B >3!>3 @3?@3= =9C A B =93 ?+37 46A !"""##" $% I, the undersigned, attest under the pains and penalties of perjury that, based upon my personal inquiry of those responsible for obtaining the information, the material contained in this analytical report is, to the best of my knowledge and belief, accurate and complete. 1"3 :" $=D &’ (()* .’+.’+.< 48?6 3 ? = +& ,", ’+# " Groundwater Analytical, Inc., P.O. 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"#$% &’()*"+ , -&-.+ /! #)!-0"#$% /" &1"-2)3+ 4 -&-.+ /! #)!-0"#$% /" &1"-2)3+ 4 56%(.6$.5$71’(’(*"/!&85 !#)+.556 4..60..%19.%.’.8..171’(’(*!) & !!)+.51.55 56’..6$.5$:(;(:.’5.& !!#+.556’8. 15$71’(1$#"*5’5.75000& !!*+ ! 0.5%%.%..6.9:.6..:%.%..%.9 9<.65.5.9.%.5..5=56>.55. . 0..04%#(.> ?.5:(.%0.%2 #.1>>5() Page 24 of 29 !"#$%$&’#(’&)!"’$%$&%"’$$$* !"#$%$&’#(’&)!"’$%$&%"’$$$* +(’,&,-&%!./$(/#./$(/. !0$&%-$1 -$1 "#$%$ "#$%2"3 )4"4)&0(#4"45%,,#6/ #% 2 / !274 37 33 3 / $-&%,&$,$,-%$-&%,&$,-$.- $-&%,&$,$,-%$-&%,&$,-$.0 &’# ’# #’ $(’ & $(’ $ 8 94/4/:/%-$$4--04 4$-.’-Page 25 of 29 !"!#$ %$#&$!"!’!(#"$!!!) *%$+#+,#"(-(.(!/!!’"!,#"+#!+,!%+ !"! !012&343&#5% 30346"++ 7/ !-(313891/-98 8:18/-;1</ ))/ " #$ !,#"+#!+!+," =93/3/>/",!!3,,53<<3!,’$,Page 26 of 29 ! "## ""#$% ! &’""#$" ()##$* +#", --. $% &’()(*" +/,0 $$.1 )+ ##&2&#,/&#3,#,/#,#,4,#"52&#6 2&#&’7-.$$,-"."#/*%0 ,&# %#1$# &’&#1 88#,"9#4,&, #%*-$. 2," 2 .!1% !2 #3 7# 4"### $# 4"#1,!5677668%,++,#%"769:6 Page 27 of 29 !"#$ %&# ’()’() ! " #"$%&!"’ "’"( "() )’)’ )()( !*!"* !*’!"*’ !"*!!+ ’ !"*’!,-"./%&! /*/* /*’/*’ ** 0)/*1 %&2 ,-"./%& */ ’ / ’$0)/*%&2 "/$* 3$/)*4 &52%&(1 *’ 3$/)*4 6%*%&( 3$/)*4 &52%&(2 ’ 173%*84 &1%&( 1*/’ 1*/%&1 ( +*%&(!"/$ /’ ’ /( ’ &*"$ ’ #!+ ’ #’/ ’ /)*79 ’ /)*799 ’ /)*7%*7 ’ / ’ +%&+!//"/ ’ %*’1*/ %*(2!+ ’ %:+/))3,4$ %:’+/))3,4$%&! %/*+ ’ %*7 +-/ ’ $*’9 $*(;</ $73$/)*4 6%*%&(/ $73$/)*4 &1%&(!/( $)):/%/)%&&.)* $)&.) $*/"%&!&.)’ =,.*/)&*" &"/* $ %&#&"/*’ ’()# #’ / ’#( #"$ !+ ’ **10)/*%& **’,/2) )//)-)")7"/<: 2*/>")&)):"77"/)/ "))/>"))77/")/*//>&))7 %)% 2*/>"9,!-’&%!*66/)!"& Page 28 of 29 ! "#$ %&’ ! "#"$%&’( "#"$)%&( *+ *+ *( *, -+ # *+ .!# -" *+ ./ 0!#12 & 0!’3 12 & *+ *( *, *+ 4-##! 5!2 / 1 &( 0# *+ 0# *( 0*& 0*& 02 & 6 + 6 ( ##1*"2."#7- 8 #9"*4-*2".."*## "#29"..#"# ##94. "’" 8 #9":1( ;;#"/ Page 29 of 29 ! "#"! ##$"!%! " "&’(&)’! *"! "" !"% ""#"!"! "+#!" %#!" ! ,- ./# ,-0" /!/’12134 /56!2117 / ##! 528,# Page 1 of 13 Groundwater Analytical, Inc. P.O. Box 1200 228 Main Street Buzzards Bay, MA 02532 Telephone (508) 759-4441 FAX (508) 759-4475 www.groundwateranalytical.com ! "#"$ ! %&’()’*+,-.)*)/ "#$%"&’"(’")#*#+*&,&&&"&’"&%’&-’"’ .-/&&’01$2!00 ’0)1%2 1%.,. ""$#%++/&&**3#1-*** %&’()’*+,-.)*)/ "#$%"&’#(’")#*#+*&,&&&.,#"/43 ’0)1%2 1%.,. ""$#%+%"#&**0 *** %&’()’*+,-.)*)/ "#$%"&’$(’")#*#+*&,&&&5-#/6" ’0)1%2 1%.,. ""$#%+7 "**0 *** ,-.3!.3. 89:6:6164;"#&&:##+.:4<<4:.&#/$# Page 2 of 13 !" #$%& ’!()# *+*),-./0 12 30 !& "#$#%&’#()#%)#*&*#+)+#(*),-&#)&#.)#+)&) +’##)/(!& 30*4!-0-120,,3451351)6##"+).*#)#%#&*7(!3-0- 0 53451351"6##")*("&##&**(!3 -0-50,,831913:8-5&**7!3:-05 ,34513,)7+63:-534&**6!$ *56!;30238 02$ -8- 2<02 $ 0=$ $ $ &-7###12= >8123$3$/$;&%##3%%73;==;231#%’(% Page 3 of 13 !"#$ %& ’()*+,-., !!"""#$"%$"&%"’($!%’)$*&%!(+,- ,’/0 ./.**01221-0/3!&&)41-. / 5*16/21*$)’71-/163!&&748 ’120 8 3 40 %4506 #69 : 021818;8+!%""1%%)1+ <<+12"%(#% Page 4 of 13 !"#$! %" Page 5 of 13 ! "#$%$$"# &$’ ! (! ) (*+ ,&,(-.)& -$%/ $! !"#$ %&!’(!)!((’! *+!)+!),!#!!,!()-.$! 0! ) (*+ ,& &(&*$! ),,,,$$! Groundwater Analytical, Inc., P.O. Box 1200, 228 Main Street, Buzzards Bay, MA 02532Page 6 of 13 Page 7 of 13 !"#$$%&’$()*’$+ !,#’-.///()**.+ 01!(1!+ 1! ! 232 2322 2430&" 0&")5 232 20 6 3 35- 70 2 3!870 "62 "622 2 30 ! 80 ! "#" /!163)5$$55’"6996"$5%:5 Page 8 of 13 ! "#$% !"#$ %&’() &’% !"#$ %&’() ()#*+#",-,+!*!./%01-.01-2$34*.*#*+# )+ "%56"04,%7,./%01-.01-23.*%** #*+#0+!*!8.-19-.:8#0*.*:#*+04,5 %,*!./%01-.%!2.:#*0*./7* 2 *)-,,","5,7+*75*;5,,*+*6##*,. ,4,6*57##",4"47,55#***45 5 )"#-5,< =5*8-,",. ".1’>.%.>5<<*>.-&Page 9 of 13 ! "#$% & ’()* ! "#$% & ’()* $+,$#-.-,"+"/0&12./12.3 %4+/+$+,$ *,!#&56#14-&7-/0&12./12.3/+&++ $+,$1,"+"8/.29./:8$1+/+:$+,14-5 &-+"/0&12./&" 3/:$+1+/07+!!!3 ! !+###/,/6-87-,-7-$-8##$#6 -6-;5,+5+5-67#+7-+<5+,7-=++-5 7 !5!*#$.5-= >5+8.-#-/!#/2(/&/5==+/.’ Page 10 of 13 ! "## ""#$% ! &’""#$" ()##$* +#", --. $% &’()(*" +/,0 $$.1 )+ ##&2&#,/&#3,#,/#,#,4,#"52&#6 2&#&’7-.$$,-"."#/*%0 ,&# %#1$# &’&#1 88#,"9#4,&, #%*-$. 2," 2 .!1% !2 #3 7# 4"### $# 4"#1,!5677668%,++,#%"769:6 Page 11 of 13 !"#$ %&# ’()’() ! " #"$%&!"’ "’"( "() )’)’ )()( !*!"* !*’!"*’ !"*!!+ ’ !"*’!,-"./%&! /*/* /*’/*’ ** 0)/*1 %&2 ,-"./%& */ ’ / ’$0)/*%&2 "/$* 3$/)*4 &52%&(1 *’ 3$/)*4 6%*%&( 3$/)*4 &52%&(2 ’ 173%*84 &1%&( 1*/’ 1*/%&1 ( +*%&(!"/$ /’ ’ /( ’ &*"$ ’ #!+ ’ #’/ ’ /)*79 ’ /)*799 ’ /)*7%*7 ’ / ’ +%&+!//"/ ’ %*’1*/ %*(2!+ ’ %:+/))3,4$ %:’+/))3,4$%&! %/*+ ’ %*7 +-/ ’ $*’9 $*(;</ $73$/)*4 6%*%&(/ $73$/)*4 &1%&(!/( $)):/%/)%&&.)* $)&.) $*/"%&!&.)’ =,.*/)&*" &"/* $ %&#&"/*’ ’()# #’ / ’#( #"$ !+ ’ **10)/*%& **’,/2) )//)-)")7"/<: 2*/>")&)):"77"/)/ "))/>"))77/")/*//>&))7 %)% 2*/>"9,!-’&%!*66/)!"& Page 12 of 13 ! "#$ %&’ ! "#"$%&’( "#"$)%&( *+ *+ *( *, -+ # *+ .!# -" *+ ./ 0!#12 & 0!’3 12 & *+ *( *, *+ 4-##! 5!2 / 1 &( 0# *+ 0# *( 0*& 0*& 02 & 6 + 6 ( ##1*"2."#7- 8 #9"*4-*2".."*## "#29"..#"# ##94. "’" 8 #9":1( ;;#"/ Page 13 of 13 APPENDIX D LABORATORY ANALYSIS REPORT FOR THE SOIL SAMPLES COLLECTED ON NOVEMBER 5, 2008 ! "#"! ##$"!%! " "&’(&)’! *"! "" !"% ""#"!"! "+#!" %#!" ! ,- ./# ,-0" /!/’12134 &"56!2114 / ##! 527,# Page 1 of 14 Groundwater Analytical, Inc. P.O. Box 1200 228 Main Street Buzzards Bay, MA 02532 Telephone (508) 759-4441 FAX (508) 759-4475 www.groundwateranalytical.com !"!## ! $%&’(&)*+,-()(. "#"$%#&"&" ’&"()!""*$*(’(((+,-./0 &/(0$1 0$-+- 1"2%1$3(-4-56"7"’%+&32"3 "#&"3&($("&"(&(2 ’732$2 3(-4-56#3237 8 *** $%&’(&)*+,-()(. "#"$%#&#&# ’&"()!""*$*(’(((+,-./0 &/(0$1 0$-+- 1"23#%3(-4-56"7"’%+&32"3 "#&"3&($("&"(&(2 ’732""3(-4-56#3237 8 *** $%&’(&)*+,-()(. "#"$%#&%&% ’&"()!""*$*(’(((+,-./0 &/(0$1 0$-+- 21133%3(-4-56"2’1$+&3%2’9 (2&"$&($(1&#’&($ ’7323$3(-4-56#3237 8 *** +,-2 -2- 9/:;:;4;5<"#((:##’+:5==5:+(#$%# Page 2 of 14 !" #$%&%’(&)%*)&*)( +,-!./+0+.1/2"3 ./4 ./ +3)567 5&789 ./5%’%./5((8 ./78%89 ./:6:80%./ ;5&:8 ./585%./#$.1/78&8 ./<8%&&./ 585&./58&%9 ./$./:888+(./4 ./ %=2"-./* 2!= &=+3)567<8%&.>-<8%6/?"??./ (=+)+3)567:888+=-?= >-*9*>- @-?@-= =3??! ) )-?- A B 9=3C0C->- ?./ - !*-">- -C "-A B =?->- @-?*@+&=8 -#* A B =#$$?3#$$-!- " * +%%=(A B >-!>- @-?@-= =3C A B =3- ?)-0 ./A B !" I, the undersigned, attest under the pains and penalties of perjury that, based upon my personal inquiry of those responsible for obtaining the information, the material contained in this analytical report is, to the best of my knowledge and belief, accurate and complete. +"-4" $=D #$ %%&’ %%)%:)85 .2?/ - ? = (#)* +)$( Groundwater Analytical, Inc., P.O. Box 1200, 228 Main Street, Buzzards Bay, MA 02532Page 3 of 14 !"#$ %"!"&"’() **+, -./-.0 /.!0" !"#&* $%& .’ $%12 ’!- - 2*3 4 ()(*$+, -0 #-.#/01 (2(34$+,˜/.#-.#/01 (2(31$+,/0 #-.#/01 5 ()(*$+,//#-.#/01 5 (2(34$+,*4 #-.#/01 )3 ))3 4 36/7(17(7 ( 8 !#-.#103) 93(7/(4 %",5/#-.#10/1 31*(**(/: -,5 #-.#10/1 311(73(7 8%;,5 #-.#10/1 31*(/*(/316(74(/<(<;6,"#-.#10/1 2)(79(6 <;,#-.#10/1 23(41(/=,5 #-.#30) 7*8 89 2:7’ 4>)( ?@ /0*70//’91(3/1’ 4>)( ?@ /0*703 "!’91(3/1’ 30"$- A BCD E 40"B-BA $- D E /0"#BB>B330/0403D = (BC>#A 0!B %##0:#> A B0 2;<BB& +>$8?!303>4117@0 ! C#0 283<!>B>C#B0!#C A B #0!# B% 0 ,+# B #?@- ##0 ()(*$+# #0 ˜ (2(34$+# # B(2(31$+#0 $ ()(*$+#0 ;$ (2(34$+#0 "."!""<"" ""!6<"- 28*’ 7)7; 28*’ -"!""<. 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Box 1200, 228 Main Street, Buzzards Bay, MA 02532Page 7 of 14 Page 8 of 14 !"#$$%&’$()*’$+ !,#’-.///()**.+ 01!(1!+ 1! ! 232 2322 2430&" 0&")5 232 20 6 3 35- 70 2 3!870 "62 "622 2 30 ! 80 ! "#" /!163)5$$55’"6996"$5%:5 Page 9 of 14 !" #$ %&&$’%&&$’% !! 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"## ""#$% ! &’""#$" ()##$* +#", --. $% &’()(*" +/,0 $$.1 )+ ##&2&#,/&#3,#,/#,#,4,#"52&#6 2&#&’7-.$$,-"."#/*%0 ,&# %#1$# &’&#1 88#,"9#4,&, #%*-$. 2," 2 .!1% !2 #3 7# 4"### $# 4"#1,!5677668%,++,#%"769:6 Page 12 of 14 !"#$ %&# ’()’() ! " #"$%&!"’ "’"( "() )’)’ )()( !*!"* !*’!"*’ !"*!!+ ’ !"*’!,-"./%&! /*/* /*’/*’ ** 0)/*1 %&2 ,-"./%& */ ’ / ’$0)/*%&2 "/$* 3$/)*4 &52%&(1 *’ 3$/)*4 6%*%&( 3$/)*4 &52%&(2 ’ 173%*84 &1%&( 1*/’ 1*/%&1 ( +*%&(!"/$ /’ ’ /( ’ &*"$ ’ #!+ ’ #’/ ’ /)*79 ’ /)*799 ’ /)*7%*7 ’ / ’ +%&+!//"/ ’ %*’1*/ %*(2!+ ’ %:+/))3,4$ %:’+/))3,4$%&! %/*+ ’ %*7 +-/ ’ $*’9 $*(;</ $73$/)*4 6%*%&(/ $73$/)*4 &1%&(!/( $)):/%/)%&&.)* $)&.) $*/"%&!&.)’ =,.*/)&*" &"/* $ %&#&"/*’ ’()# #’ / ’#( #"$ !+ ’ **10)/*%& **’,/2) )//)-)")7"/<: 2*/>")&)):"77"/)/ "))/>"))77/")/*//>&))7 %)% 2*/>"9,!-’&%!*66/)!"& Page 13 of 14 ! "#$ %&’ ! 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