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Re1Release Abatement Mea (RAM)Ptan AmendmentN. 2&tStat RRepnrN. RTN2-0016646. 40 HaywardStreet Franklin,Massachusetts Dearl.v ....... EneetlesaM een blmrtM aue( M)PmadSau em o he prprylu e t4 aw r Ireti rnln ascuet.Teproe hisNIARINCoiiainisomaprt h seafpia u enngnt o|hIr Release Abatement Measure (RAM) Plan Amendment No. 2 & Status Report No. 2 RECNu 1 2 2007 DEC for RTN 2-0016646 Franklin DPW Facility 40 Hayward Street Franklin, Massachusetts December 2007 Prepared For: Franklin Department of Public Works 257 Fisher Street Franklin, MA 02038 Prepared By: Comprehensive Environmental Inc. 64 Dilla Street Milford, MA 01757 Table of Contents Section Page 1.0 Introdu ction .......................................................................................................................... I 1.1 RAM Responsibility................................................................................................1 2.0 Description of Site Conditions and Surrounding Receptors .......................................... 2 2.1 Description of the Site Conditions...................................................................... 2 2.2 Surrounding Receptors......................................................................................... 2 2.3 Initial Site Investigation...................................................................................... 3 2.4 Description of the Release ................................................................................. 3 3.0 Status of Response Operations......................................................................................... 4 4.0 Significant New Site Information & Data ...................................................................... 5 5.0 Objectives and Implementation Schedule....................................................................... 7 5.1 Objectives ........................................................................................................ 7 5.2 In-situ Treatment Evaluation ............................................................................. 8 5.3 Specific Plans...................................................................................................... 8 5 .4 S ch edu le ................................................................................................................... 9 6.0 Monitoring Plan ................................................................................................................... 9 7.0 Management of Remediation W aste..................................................................................11 8 .0 P erm ittin g ........................................................................................................................... 1 1 9.0 Licensed Site Professional Opinion................................................................................I I List of Figures Figure 1. Site Locus Map Figure 2. DEP Priority Resource Map Figure 3. Site Plan List of Tables Table 1. Summary of Remedial Additive Monitoring Data Table 2. Summary of Groundwater Analytical Results List of Appendices Appendix A MassDEP Approval for In-situ Treatment Appendix B Laboratory Analytical Reports Appendix C Updated Health & Safety Plan for In-situ Treatment Appendix D Waste Disposal Documentation Appendix E BWSC-106 Form Release Abatement Measure (RAM) Amendment No. 2 & Status Report No. 2, RTN 2-0016646 1.0 Introduction Comprehensive Environmental Inc. (CEI) is filing this Release Abatement Measure (RAM) Plan Amendment and Status Report on behalf of the Town of Franklin for the property located at 40 Hayward Street in Franklin, MA. The April 2007 RAM Plan outlined the remedial activities to address petroleum impacted soils that included the excavation, removal/stockpile, and testing for off-site recycling or on-site recycling with off-site reuse of petroleum impacted soils at the site. The RAM Plan also included the dewatering, treatment, and discharge of impacted groundwater from the excavation during the contaminated soil removal activities. A RAM Amendment was submitted in June 2007 and outlined the specific plans to incorporate the use of injection wells for in-situ hydrogen peroxide treatment of impacted soils remaining beneath a portion of the DPW garage building. Impacted soils in the vicinity of soil boring B-205 could not be removed as part of the RAM excavation activities without compromising the structural integrity of the building. The June 2007 RAM Amendment Plan was also submitted to provide notice of the increased volume of soil remediation waste and that sufficient financial resources exist to comply with 310 CMR 40.0030, as outlined in 310 CMR 40.0442(5). This RAM Amendment and Status Report has been prepared in accordance with 310 CMR 40.0444 and 40.0445 of the Massachusetts Contingency Plan (MCP). The purpose of this RAM Amendment is to incorporate the use of potassium permanganate to address the dissolved fraction as part of the current in-situ treatment program that was approved August 13, 2007. The use of this chemical was not specifically outlined in the June 2007 RAM Amendment and requires written approval by MassDEP, as outlined at 310 CMR 40.0046(3). The proposed modifications and status update to the June 2007 RAM Amendment are outlined below by section, as applicable. Sections that remain unchanged are noted and the original RAM Plan text is shown in italics for reference. 1.1 RAM Responsibility No Change. The responsibleparty for conducting the response action as discussed herein is: Robert Cantoreggi,DPWDirector Franklin Department of Public Works 257 FisherStreet Franklin,MA 02038 Phone: (508) 520-4910 Relationship to Site: Operator Page 1 Release Abatement Measure (RAM) Amendment No. 2 & Status Report No. 2, RTN 2-0016646 2.0 Description of Site Conditions and Surrounding Receptors 21 Description of the Site Conditions No Chanee. The site is located at 40 HaywardStreet in Franklin, Massachusetts and a locus map is provided as Figure1. The site consists of approximately 8.78-acre and is owned by the Town of Franklin with DPW administrativeoffices located at 257 Fisher Street, Franklin, MA. The Highway Facility consists of a garage building, two salt sheds, and a fueling station. The garage building houses the Highway Department offices, vehicle maintenance area, vehicles, and equipment. The onsite fueling station is used to fuel all Town owned vehicles. The site is serviced by public water and sewer utilities. Southwest of the primarygarage building are two buildings that house equipment and materialsfor the Franklin Water Department. The larger of these two buildings is referred to as the former DPW Garage and southwest of this building is the area subject to the release described herein, referred to as the site. According to DPW representatives,fuel dispensingpumps and undergroundstorage tanks were located at this building. The site is bounded by vacant land and HaywardStreet to the north, wetlands and forested land to the south and west, and the MBTA railroadto the east, beyond which are commercialproperties. The FranklinAnimal Control building, Water Treatment Plant and DPWAdministrative Office building are located to the east/southeastof the site. According to the U.S. Geological Survey topographicquadrangle map of the area (Franklin Quadrangle,1997) the site consists of an elevation of approximately 236feet (72 meters) above mean sea level, and with rising elevations to the north, southeast, and east of the site. Mine Brook abuts the site to the west andflows in a northerly direction from the Miscoe Brook past the site to the Charles River. The U.S. Geological Survey maps indicate that regionalgroundwater flow is generally toward the north,flowing along the similar direction as Mine Brook Localized groundwaterflow direction in the immediate vicinity of the release area is toward the west, but may vary as a result of heterogeneous subsurface conditions. 2.2 Surrounding Receptors No Chanze. The subject site is located in a commercial area of Franklin, with nearby businesses to the east along Hayward Street and Fisher Street. Abutting sites are owned and operated by the Town of Franklin beyond which is the MBTA rail line. To the south and west are forested land, wetlands and Mine Brook. Beaver Pond is located approximately 1,250 feet west of the site. The Town of Franklin has two public water supply wells located approximately 500 feet southwest of the site and the site is currently located within the Zone II groundwaterrecharge areafor these wells. Protectedopen space and estimated habitat of rare wildlife in wetland areas are located in close proximity to the site. Additional receptor information is provided on the DEP PriorityResource Map included as Figure2. Page 2 Release Abatement Measure (RAM) Amendment No. 2 & Status Report No. 2, RTN 2-0016646 2.3 Initial Site investigation No Chanee; refer to the April 2007 RAM Plan for Figures, Tables and Appendices. Rizzo conducted a subsurface site investigation to assess the extent ofpetroleum impacts observed during utility work at the site. On December 14 and 28, 2006, Rizzo installed 43 soil borings in which 6 were completed as groundwatermonitoring wells. The soil borings were installed to assess the extent ofpetroleum impacts at the site. The locations of the soil boring/ monitoring wells are depicted on Figure 3. Soil headspace screening results indicated elevated petroleum compounds in soils (>100 ppm) at numerous locations and Rizzo collected selected soil samplesfrom across the impacted