RECENT ACTIVITIES RELATED TO ASSESSMENT AND REMEDIATION OF IMPACTED SOIL Site: Grand Manor Condominiums 175 Willard Street Lowell, Massachusetts Preparedfor: Grand Manor Condominium Association c/o Great North Property Management, Inc. 100 Daniel Webster Highway Nashua, New Hampshire 03060 Prepared By: CUSHINS, .JAMMALLO & WHEELER, INC. 464 % Street 85 ConstitutionLane, Suite 3B4 Clinton, Massacusetts01510 <Danvers, Massac/tusetts01923 Project No. 5334 April 24, 2009 <0 cor ' <C TABLE OF CONTENTS SECTION PAGE 1.0 INTRODUCTION AND BACKGROUND........................................................................ 1 2.0 APPLICABLE MCP REPORTING CATEGORIES.......................................................... 3 3.0 SOIL EXCAVATION AND SOIL SAMPLING AND TESTING......................................5 4.0 MANAGEGMENT OF IMPACTED, STOCKPILED SOIL .............................................. 7 5.0 HISTORICAL INFORMATION....................................................................................... 7 6.0 C ON C LU SIO N S ....................................................................................................................... 8 7.0 RECEM MIENDATIONS ..................................................................................................... 10 8.0 LIM ITA TIO N S ....................................................................................................................... 10 9.0 R EFE R EN C ES ....................................................................................................................... 12 TABLES Table 1 Summary of Laboratory Testing Results of Soil FIGURES Figure 1 Locus Map Figure 2 Aerial View of Subject Site. Figure 3 MADEP Priority Resource Map Figure 4 Site Plan APPENDICES Appendix A Report by Precision Environmental Management Corporation Appendix B Laboratory Testing Results for Soil Appendix C Manifests and Weight Slips Appendix D Historical Information RECENT ACTIVITIES RELATED TO ASSESSMENT AND REMEDIATION OF IMPACTED SOIL Site: Grand Manor Condominiums 175 Willard Street Lowell, Massachusetts 1.0 INTRODUCTION AND BACKGROUND This report summarizes the recent work which Cushing, Jammallo & Wheeler, Inc. (CJW) performed at Grand Manor Condominiums, located at 175 Willard Street, Lowell, Massachusetts (Site), related to impacted soil initially identified by others as described below. Figure 1 is a locus map showing the location of the Site on a U.S Geological Survey topographic map. Figure 2 is an aerial view of the Site. In November and December 2008, JL Excavating of Dracut, Massachusetts installed new underground drainage utilities on the Site between the condominium building and Humphrey Street and between the condominium building and Willard Street. As part of this work, excess soil was generated and stockpiled at the rear of the Site by JL Excavating in two separate stockpiles. Since Jonathan Leh of JL Excavating observed that soil removed from a portion of the northern area of the Site between the condominium building and Willard Street was different from soil that was removed from other portions of the work area [i.e., it contained various types of debris including broken glass, bottles, metal, vehicle parts (mufflers, etc.), and ash], he wanted to physically separate this soil from the balance of the remaining excavated soil. Precision Environmental Management Corporation of North Billerica, Massachusetts (Precision) subsequently collected soil samples from the two generated stockpiles and submitted the samples to Phoenix Environmental Laboratories, Inc. for testing of various parameters. Testing results from the stockpile (approximate 10 cubic yards) that was generated from the northerly portion of the Site between the condominium building and Willard Street contained the various debris revealed concentrations of various analytes of which four (arsenic, cadmium, chromium, lead, and tetrachloroethene) were identified in concentrations equal to or in excess of their respective Reportable Concentrations (RCs) for soil category RCS-1 under the Massachusetts Contingency Plan (MCP) (310 CMR 40.0000). Other substances were identified in the samples in concentrations above the laboratory's reporting limits but below the RCs. These included petroleum hydrocarbons and polynuclear aromatic hydrocarbons (PAHs). This information is detailed in a letter from Precision Environmental Management Corp. (Precision) to Mr. Jonathan Leh, dated December 31, 2008 (Appendix A). Precision also stated that the exceedences of the RCs constitute a release to the environment ...and the owner is obligated to notify the MADEP CJW Project #5334, Grand Manor Condominiums April 24, 2009 Page 2 [Massachusetts Department of Environmental Protection] within 120 days from knowledge of the release in accordance with.. .310 CMR 40.0315". The focus of our work was to attempt to complete a Limited Removal Action (LRA) (MCP, 310 CMR 40.0318) for the identified contaminated soil at the Site. This action was a result of a decision made by the Grand Manor Condominium Trustees based on information provided during a meeting with a CJW representative on February 26, 2009. A resultant successful LRA would negate the need for Grand Manor Condominium Association to notify the MADEP of this release, in this case, of what are considered hazardous materials. For the LRA to be successful, the following conditions would apply: . In this case, the LRA is restricted to the excavation and off-site recycling, reuse, treatment, and/or disposal of not more than 20 cubic yards of soil contaminated by a release of hazardous material. Approximately 10 cubic yards of contaminated soil had previously been excavated and stockpiled at the Site so that excavation under the direction of CJW was limited to approximately 10 additional cubic yards; . All excavation activities must be completed within 120 days of obtaining knowledge of the release; . Concentrations of hazardous material in soil remaining at the Site following the LRA need to be reduced to levels that are less than the applicable RCs; . All contaminated soil generated as a result of the LRA must be stockpiled, stored, characterized, transported, and recycled, reused, treated, or disposed of as Remediation Waste as defined under the MCP; . Documentation shall include the concentrations of hazardous material in soil remaining at the Site following the LRA and documentation regarding the chemical characterization and volume of soil removed from the Site. This documentation shall be maintained by the responsible party for a minimum of 5 years; and - If the soil management process includes a Bill of Lading, then a Licensed Site Professional (LSP) has to have involvement in the process. CJW Project #5334, Grand Manor Condominiums April 24, 2009 Page 3 2.0 APPLICABLE MCP REPORTING CATEGORIES As described in Section 40.0360 of the MCP, soil and groundwater within the Commonwealth of Massachusetts are defined by categories for the purpose of reporting releases of oil and/or hazardous materials to the MADEP (under the provisions of 310 CMR 40.0315). If the measured concentration of one or more substances (as outlined in 310 CMR 40.1600) in any soil or groundwater sample is equal to or greater than the media and category-specific RC, the concentration constitutes a release and, as such, is to be reported to the MADEP by the responsible party of potentially responsible party. The applicable categories for soil are defined as: Reporting CategoryRCS-1. Reporting category RCS-1 applies to all soil samples obtained: " at or within 500 feet of a residential dwelling, a residentially-zoned property, school, playground, recreational area, or park; or " within the geographic boundaries of a groundwater resource area categorized as RCGW-1 in 310 CMR 40.0362(1)(a). Reporting category RCS-1 is selected whenever and wherever reasonable doubts exist over the selection of the appropriate soil RC category. Reporting Categorv RCS-2. Reporting category RCS-2 applies to all soil samples that are not obtained from category RCS-1 areas. The applicable categories for groundwater are defined as: Reporting Category RCGW-1. Reporting category RCGW-1 applies to all groundwater samples obtained: m within a Current Drinking Water Source Area; or " within a Potential Drinking Water Source Area. CJW Project #5334, Grand Manor Condominiums April 24. 2009 Page 4 A Current Drinking Water Source Area is defined as groundwater located: = within a Zone II of a public water supply; " within an Interim Wellhead Protection Area of a public water supply; - within the Zone A of a Class A surface water body used for a public water supply; or = within 500 feet of a private water supply well. A Potential Drinking Water Source Area is defined as groundwater located: - within 500 feet or more from a public water system distribution pipeline; unless the groundwater is located under a parcel of land or a facility where any portion of that parcel of land or facility is located less than 500 feet from a public water supply distribution pipeline; - within an area designated by a municipality specifically for the protection of groundwater quality to ensure its availability for use as a source of potable water supply; and " within a Potentially Productive Aquifer that has not been excluded as a Non-Potential Drinking Water Source Area. Reporting category RCGW-l applies whenever and wherever reasonable doubts exist over the selection of the appropriate groundwater RC category. Reporting Categorv RCGW-2. Reporting