Download BWSC107 Sec B Q 2 - Tier Classification Submittal Document

1.0
INTRODUCTION
Capaccio Environmental Engineering, Inc. (CAPACCIO) was retained by Bodycote
Thermal Processing, Inc. (BODYCOTE) to complete a Phase 1 – Initial Site Investigation
Report (Phase I) and Tier Classification for a release of oil at BODYCOTE’s 284 Grove
Street, Worcester, MA facility, hereafter referred to as the “Site”. A Site Location Map is
included as Figure 1.
On May 18, 2004, the two-inch-diameter monitoring well MW-9 was installed outside of the
BODYCOTE facility in the sidewalk along Brookfield Street. This monitoring well was
installed as part of continuing Phase II soil and groundwater delineation activities being
conducted for Massachusetts Department of Environmental Protection (MADEP) Release
Tracking Number (RTN) 2-14062.
A Site Plan is attached as Figure 2.
Following
installation, groundwater samples from monitoring well MW-9 were collected; no liquidphase hydrocarbon (LPH) was present. LPH was first recorded in monitoring well MW-9
during the August 2004 groundwater sampling event. The descriptions provided from the
monitoring indicated LPH similar to that previously being remediated under Remedy
Operating Status (ROS) under MADEP RTN 2-12660. Overall groundwater flow direction
is to the east, toward the Mill Brook Culvert, which locates monitoring well MW-9 in the
upgradient direction. However, groundwater gauging data has indicated a component of
flow toward monitoring well MW-9. Based on this, it was believed that the LPH detected in
monitoring well MW-9 was from the same source as that in the monitoring wells in the ROS
area. The January 2005 groundwater sampling event indicated that monitoring well MW-9
was clear of LPH.
However, continued groundwater monitoring after January 2005
continued to indicate the presence of LPH in thicknesses ranging from 0.27 feet to 1.87
feet. Based on this, CAPACCIO determined that it would be prudent to collect an LPH
sample for comparison to LPH samples collected in 2002 from monitoring wells MW-S4,
MW-S7 and MW-S11 (located in the ROS area) to ensure that the source of the LPH was
consistent. The LPH sample was collected on April 7, 2005 and submitted to Worldwide
Geosciences, Inc. (WGI) of Houston, Texas. On May 3, 2005, CAPACCIO received verbal
notification from WGI that the LPH from monitoring well MW-9 was that of a severely
biodegraded diesel/fuel oil product with a most probable exposure time of twenty years or
more. Although the exposure time is consistent with the LPH in the ROS area, WGI
concluded that the LPH in monitoring well MW-9 was not related to any of the 2002
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samples.
Therefore, the indication of a differing source constituted a new release
condition, that, in accordance with the Massachusetts Contingency Plan (MCP) 310 CMR
40.0313, met the 72-hour reportable condition requirements and, per 310 CMR 40.0412, a
condition where an Immediate Response Action (IRA) is required. The MADEP assigned
RTN #2-15735 and verbally approved continued manual bailing and assessment as the
IRAs. BODYCOTE received a Notice of Responsibility (NOR) from the MADEP dated June
13, 2005. The following documents were submitted to DEP since release reporting:

IRA Plan, July 7, 2005;

IRA Plan Modification, November 3, 2005;and,

IRA Status Report, May 11, 2006.
This report documents the results of the Phase I in accordance with the MCP, 310 CMR
40.0480.
1.1
Purpose and Scope of Work
The purpose of this Phase I investigation is to 1) evaluate the release of oil and/or
hazardous materials to the soil and groundwater at the property, 2) identify source(s) or
potential source(s) to the release, 3) define the general nature and extent of the release
including that anticipated in order to define conceptual Phase II activities, 4) identify
human and environmental receptors, and, 5) collect additional information necessary to
complete a Tier Classification for the site.
CAPACCIO performed the following tasks in order to accomplish this investigation:
1)
The following organizations and agencies were contacted to determine past
ownership of the property and whether there were any complaints or violations
concerning the environmental quality of the property:
a)
b)
c)
d)
e)
f)
g)
h)
i)
The City of Worcester Assessor’s Office;
The City of Worcester Department of Public Health;
The City of Worcester Building Department;
The City of Worcester City Clerk’s Office;
The City of Worcester Fire Department;
The City of Worcester Water Department;
The City of Worcester Public Works Department;
The Massachusetts Department of Environmental Protection;
The Massachusetts Geographic Information System; and,
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j)
The Environmental Protection Agency’s CERCLIS, NPL and RCRA listings.
2)
CAPACCIO conducted a visual inspection of the property and a review of
neighboring properties.
3)
CAPACCIO has performed field activities relating to this release since May 18,
2005, including the installation and gauging of groundwater monitoring wells and
the collection of soil and groundwater samples for laboratory analyses.
4)
CAPACCIO developed Site drawings and summarized analytical and gauging
data.
2.0
LOCATION DESCRIPTION
2.1
Property Location, Local Land Uses and Demographics
A Site Location Map is provided as Figure 1. Geographically, the Site is located at UTM
coordinates northing 4,684,713.893, easting 268,621.987. The Site is located at the corner
of Grove Street and Brookfield Street in an area of mixed land use with a population of
greater than 4,400 people per square mile. Commercial and industrial companies are
located along Grove Street. Residential homes and apartment buildings are located east of
the Site along Brookfield Street.
There are no public institutions located within 500 feet of the Site. The nearest school to
the Site is the Worcester Center for Crafts, located approximately 0.1 mile to the southwest.
2.2
Local Natural Resources
A review of MADEP Priority Resource Maps for the local area indicated that there are no
Vernal Pools, Threatened or Endangered Species Habitats within a one-quarter-mile radius
of the Site.
The nearest is located approximately 0.09 mile southeast of the Site. The
nearest Protected Open Space is located approximately 0.0.9 mile southeast of the Site.
The Site is not located within a Sole Source Aquifer, an Interim Wellhead Protection Area,
or a Zone A or Zone II of a public drinking water well.
The nearest surface water body is the West Mill Brook Culvert, located on the Site. The
culvert is a twin-box (i.e. west and east) culvert located underground having a combined
dimension of 24 feet wide by seven feet high. The culvert discharges water from Indian
Lake directly to Salisbury Pond.
Salisbury Pond is a Class B surface water body
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designated by MADEP as suitable for fish habitat and other aquatic life, wildlife, primary
and secondary contact recreation, and as a public water supply source with treatment. The
Worcester Department of Public Health (WDPH) reports that contact recreation, fishing and
boating is not allowed at the pond and is indicated to the public by posted signs. The pond
does reportedly support fish. Therefore, in accordance with 1997 MADEP guidance on
completing the numerical ranking, a fish habitat is considered to be “on-site” because water
in the underground culvert supports fish habitat in the pond.
The Site is located over an MADEP-designated medium-yield non-potential drinking water
source area. There are no drinking water supply reservoirs within a one-quarter-mile radius
and no public drinking water supply wells are located within a one-quarter-mile radius of the
Site.
2.3
Site Description
2.3.1
Site Structures and Land Surface Description
The BODYCOTE facility occupies two parcels of land, 284 Grove Street and 280 Grove
Street, which are located on either side of Brookfield Street. According to BODYCOTE and
based on CAPACCIO’s inspection of both locations, lead and chlorinated solvent use were
limited to 284 Grove Street. One two-story brick building, constructed on a reinforced
concrete slab approximately six inches thick, is located at 284 Grove Street. Land located
behind the facility is used for shipping and receiving and storage of finished and unfinished
customer product.
The area of land located behind the facility was not paved until
approximately 1989, when it was paved with asphalt.
Surface topography is relatively level at an elevation of approximately 502 feet above
sea level.
Hills to the north, east and west of the Site rise to an elevation of
approximately 590 feet above sea level, while topography to the south slopes toward the
Salisbury Pond at an elevation of approximately 492 feet above sea level.
2.3.2
Site Utilities
Natural gas is used to heat the facility and run the heat treating furnaces. Water and
sewer is provided by the City of Worcester. Storm water at the rear of the property flows
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to two catch basins located on-site which discharge directly to the Mill Brook Culvert.
The underground culvert discharges to Salisbury Pond to the south.
2.4
Site History
BODYCOTE performs hardening of metal products via heat treating and employs
approximately 40 on-site workers. The process strengthens the metal product for their
intended use. A current floor plan is included as Figure 3. In reference to this figure, the
facility contains several areas with varying types of heat treating furnaces and associated
tempering units. An area at the rear of the facility is used for shot blasting and tumbling to
debur metal products. The heat treating furnaces utilized fuel oil prior to 1991, when they
were converted to burn natural gas. The fuel oil was stored in underground storage tanks
(USTs) located beneath the facility and were properly abandoned in place from February to
August 1991 (discussed further in Section 3.2.1) when the furnaces switched to natural
gas.
Natural gas is used to heat the facility and run the heat treating furnaces. Water and sewer
is provided by the City of Worcester. Storm water at the rear of the property flows to two
catch basins located on-site which discharge directly to the Mill Brook Culvert.
The
underground culvert discharges to Salisbury Pond to the south.
Land use around the site includes:

A metal stamping facility (the Thomas Smith Company) to the north;

Brookfield Street to the south. The other BODYCOTE facility (280 Grove Street) is
located beyond Brookfield Street;

A Massachusetts Electric Company substation to the east. Residential homes are
located to the southeast and apartment buildings are located beyond the substation;
and,

Grove Street to the west.
The Worcester Regional Transit Authority’s (RTA)
maintenance facility is located beyond Grove Street.
Activities at 280 Grove Street include heat treating using ammonia and nitrogen
atmospheres, product inspection, maintenance, shipping/receiving of customer orders, and
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manual sand blasting. Liquid ammonia and liquid nitrogen above ground storage tanks are
located at the rear (east side) of the property. Underground piping from the ASTs supplies
ammonia and nitrogen to furnaces at both 280 and 284 Grove Street. Prior to using
ammonia and nitrogen, heat treating using neutral salts such as sodium nitrate. Cold water
quenching was conducted. No quench oil was used at this location and no waste storage
was located here.
2.5
Database Information for Nearby Properties
The Environmental FirstSearch Report, prepared by FirstSearch Technology Corporation
addresses the area surrounding the Site.
The FirstSearch Report is included as
Appendix A. The following is a brief summary of database information for the surrounding
area:

No properties exist within a one-mile radius of the Site that are included on the U.S.
Environmental Protection Agency’s (USEPA) National Priority List (NPL).

No properties exists within a half-mile radius of the Site that is included on the
Comprehensive Environmental Response Compensation and Liability Information
System (CERCLIS) List.

There are eight (including the BODYCOTE facility) Resource Conservation and
Recovery Act (RCRA) generators located within one-quarter mile of the Site, four of
which are located within 500 feet of the Site.
These include the Worcester Area
Transportation Company, located 0.02 mile to the northwest, the Thomas Smith
Company, located 0.04 mile to the northeast, L&J of New England, Inc., located 0.06
mile to the southwest and Howard Product, Inc., located 0.06 mile to the southeast.

There are fifty-eight MADEP Sites located within one mile of the BODYCOTE Site,
which includes the releases at BODYCOTE’s 284 Grove Street facility (RTNs 2-12660
and 2-14062). Excluding releases reported at BODYCOTE, three of the 49 Sites are
located within one-quarter mile of the BODYCOTE Site. These include petroleum
releases at the Worcester Regional Transit Authority (RTA), located 0.03 mile to the
northwest, which is located across Grove Street from BODYCOTE, the Health
Foundation of Central Massachusetts, located 0.05 mile northwest of the Site and the
Texaco service station, located 0.19 mile to the northwest.
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
There are seventy-seven spills reported since 1990 within a half-mile radius of the Site
and sixteen spills (excluding BODYCOTE) reported between 1980 and 1990 within a
quarter-mile of the Site. Nine of these spills are located within 500 feet of the Site.
These include seven releases at the Worcester RTA , located 0.01 mile northwest and
two
releases
at
the
Health
Foundation
of
Central
Massachusetts/Central
Massachusetts Health Care, located 0.05 mile to the northwest.

There are four properties (including the BODYCOTE facility) with registered USTs
present within a one-quarter mile radius of the Site. These include the Worcester
Regional Transit Authority (RTA), located 0.02 mile to the northwest and across Grove
Street from the BODYCOTE facility, the Thomas Smith Company located 0.04 mile to
the northeast and adjacent to the BODYCOTE facility, and the Shell service station,
located 0.17 mile to the northwest.

There are no reported leaking USTs, no solid waste landfills and no RCRA Treatment,
Storage and Disposal facilities within a half-mile radius of the Site.
3.0
SITE HISTORY
3.1
Ownership and Operations
Information in this section was obtained from BODYCOTE personnel and from records
obtained at Worcester Municipal Offices. The property was first developed in in 1920 by
Greenman Steel Treating, Inc. New England Metalurgical, Inc. purchased the property is
the 1950’s and Lindberg Heat Treating, Inc. purchased the property in 1966. BODYCOTE
purchased the property from Lindberg Heat Treating, Inc. in 2001. Each of the companies
operated at the property and conducted similar metal heat treating operations. The building
was built in 1920 and later expanded by the late 1950’s. BODYCOTE refers to the current
284 Grove Street facility as Building Numbers 1 & 2. Building Numbers 3 & 4 are located
at 280 Grove Street.
Information in this section was obtained from BODYCOTE personnel and from records
obtained at Worcester Municipal Offices. The property was first developed in 1920 by
Greenman Steel Treating, Inc.. New England Metallurgical, Inc. purchased the property in
the 1950’s and Lindberg Heat Treating, Inc. purchased the property in 1966. BODYCOTE
purchased the property from Lindberg Heat Treating, Inc. in 2001. Each of the companies
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operated at the property and conducted similar metal heat treating operations. The building
was built in 1920 and later expanded by the late 1950’s. BODYCOTE refers to the current
284 Grove Street facility as Building Numbers 1 and 2.
3.2
Oil and Hazardous Material Management
CAPACCIO reviewed BODYCOTE’s use and handling of oil and hazardous material at the
Site. Current and past petroleum, lead and chlorinated hydrocarbon uses are summarized
below.
3.2.1
Petroleum Use
BODYCOTE used petroleum products for two primary operations - fuel oil until 1991 to run
furnaces, and quench oil to cool metal parts after heat treating. Quench oil in Building #1
(see Figure 2) was formerly stored in a 2,500-gallon UST and a 4,000-gallon partially
below-grade open-top tank until 1986 when the 2,500-gallon tank was closed in
accordance with applicable state and federal regulations. Quench oil in Building #2 was
formerly stored in a 600-gallon UST and a 110-gallon partially below-grade open-top tank.
The 600-gallon UST was abandoned in August of 1991. The 110-gallon tank was used
until February 1991, when it was replaced with an AST. Quench oil was also stored in
ASTs located at the rear of the building.
Currently, quench oil is stored in an 1,800-gallon AST, as shown on Figure 2, and in ASTs
located inside the facility. Waste quench oil is collected and stored in a 1,000-gallon AST
located in a storage building (shown on Figure 2), along with 55-gallon drums of waste oily
solids. This material is transported and disposed off-site by United Industrial Services, Inc.
for disposal at United Oil Recovery, Inc. in Meriden, Connecticut as hazardous waste. Two
furnace oil coolers which contain approximately 200-gallon above-ground oil circulation
tanks are located in a shed attached to the facility (see Figure 2).
Fuel oil was previously used to fire the furnaces. Three #2 fuel oil USTs were located on
the Site. Two of these USTs (5,000 gallons and 8,000 gallons) were located at the rear of
Building #2 and were closed in-place in August 1991 in accordance with applicable state
and federal regulation. The third UST (2,500 gallons) was located to the north, beneath
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Building #1 and was closed in-place in February 1991 in accordance with applicable state
and federal regulation.
Because the USTs were located beneath the facility, in-place
closure was approved by the Worcester Fire Department. The USTs were closed by
General Chemical Corp. in accordance with 527 CMR 9.00. According to BODYCOTE, the
USTs were emptied of product, cleaned, and filled with concrete slurry.
An on-line database search conducted by CAPACCIO did not reveal reported petroleum
releases at BODYCOTE other than RTN #2-12660, which is associated with a release at
the former 5,000-gallon and 8,000-gallon USTs, currently under Remedy Operating Status
and RTN #2-14062, which is associated with a release of lead and chlorinated hydrocarbon
compounds and is currently in Phase IV of the MCP. BODYCOTE reports that there have
been no other significant releases at the facility.
3.2.2
Lead Use
Lead was used by BODYCOTE for localized heat treatment of steel parts. Heat treating
was performed using 15-inch-diameter, 24-inch-deep pots filled with molten lead. The
molten lead was covered with a layer of charcoal that contained heat and splatter. Referred
to by BODYCOTE as the Lead Line, this method was used by BODYCOTE on an asneeded basis from approximately 1985 to 1991 at which time the activity was discontinued.
The Lead Line, which BODYCOTE reported to last operate, had one lead pot and was
removed in 1993. According to BODYCOTE, lead heat treating was used more commonly
in the 1950’s to 1970’s. The location and number of Lead Lines, if any, that may have been
operated by Greenman Steel, New England Metallurgical, and Lindberg Heat Treating up
to 1985 are not known. BODYCOTE’s former Lead Line was located in Building #2 as
shown on Figure 2.
BODYCOTE has no documented information regarding disposal
practices of the lead/charcoal waste. However, BODYCOTE reported that unused empty
lead pots where stored outside behind the 284 Grove Street facility when no longer
needed.
3.2.3
Chlorinated Hydrocarbon Use
Two former parts vapor degreasers were located at the 284 Grove Street BODYCOTE
facility. One was located in Building #1 and the other located in Building #2; locations of
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the former vapor degreasers are shown on Figure 2. Hazardous waste manifests obtained
from BODYCOTE from the early 1980’s indicated the use of Trichloroethene (TCE) in the
former vapor degreaser located in Building #1.
This vapor degreaser was reportedly
located above ground on the facility concrete floor. Solvent was added directly to the vapor
degreaser from portable containers. This vapor degreaser was removed in 1986 and a
new one installed at the eastern corner of Building #2 in 1988. The new vapor degreaser
was larger and located in a concrete-lined pit. Solvent was supplied via a 200- to 300gallon AST located outside at the eastern corner of Building #2. The AST was located in a
berm made of a concrete slab and 2-feet-high cinderblock walls that was filled via a fill pipe
accessible from Brookfield Street.
According to BODYCOTE, this degreaser utilized
tetrachloroethene, similarly called perchloroethene (PCE), from 1986 to 1989; 1,1,1trichloroethane (TCA) was used from 1989 to 1995. Use of this degreaser was terminated
and it was removed in approximately 1995. Spent solvents from both degreasers was
reportedly contained and transported off-site as a hazardous waste by a licensed
transporter.
3.3
Environmental Permits and Compliance
BODYCOTE reports that the following permits are held for the 284 and 280 Grove Street
facilities:

Air Emissions: Limited Plans Approval;

Small Quantity Generator of hazardous waste: #MAD046130720;

Storm Water Discharge (General Multi-Sector): #MAR05B316;
According to BODYCOTE, there has been one notice of non-compliance or violation issued
in the last five years for environmental operating permits. In the spring of 2000, MADEP
issued a non-compliance for opacity in air emissions from quench oil smoke. MADEP
determined that an air permit was not required for the emission. MADEP and BODYCOTE
determined maintenance procedures to reduce opacity, which BODYCOTE has since
implemented. Four violations relative to Waste Site Clean Up at the property were issued
by MADEP in the last five years. MADEP conducted an audit inspection of RTN 2-12660
on February 14, 2002 and September 21, 2004. The audits focused on the IRA and ROS,
respectively, performed at the Site. The violations, which were identified and corrected
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according to MADEP’s Notice of Audit Finding, was maintenance of the groundwater
remediation system and inspection logbook for the Site. MADEP required no further action.
In response to a request for an extension for report submittal relating to RTN 2-14062, on
May 5, 2005, the MADEP issued an NON for failure to submit the required Phase II –
Comprehensive Site Assessment Report and Phase III – Remedial Action Plan.
In
response to this NON, BODYCOTE submitted an incomplete Phase II and Phase III in
December 2005. The MADEP subsequently issued an NON on March 10, 2006, citing
deficiencies in the Phase II and Phase III report. A Revised Phase II and Phase III report
was submitted to the MADEP in July 2006.
4.0
IDENTIFICATION OF APPLICABLE SOIL AND GROUNDWATER CATEGORIES
4.1
Overview
As presented in 310 CMR 40.0930, groundwater and soil categories have been developed
to characterize groundwater and soil in the Commonwealth of Massachusetts. Standards
for each of these categories were established for comparison to concentrations of OHM
present in soil and groundwater. The results of this comparison are used to determine
whether these concentrations require response actions, or if they indicate a condition of No
Significant Risk.
4.2
Identification of Applicable Groundwater Category
Groundwater is classified as one of three categories defined in the MCP; GW-1, GW-2, and
GW-3. Category GW-1 is for groundwater located within any one of the following areas:

Zone II Water Supply Well Head Protection Area;

Interim Water Supply Well Head Protection Area;

Zone A of a Class A surface water body;

Less than 500 feet from a private water supply well that was in use at the time of
release notification;

Potentially Productive Aquifer;

Greater than 500 feet from a public water system distribution pipeline; and,

Within an area designated by a municipality for the protection of groundwater quality
to ensure its availability for use as a source of potable water supply.
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If none of the GW-1 criteria are satisfied, then groundwater is category GW-2, if it is located
within 30 feet of an occupied building or structure, and the average annual depth is 15 feet
or less. Groundwater that is neither category GW-1 or GW-2, is category GW-3 by default.
Groundwater categories were defined at the Site using information from MADEP’s
Geographic Information Mapping System (GIS) of environmental resources.
Groundwater categories were defined at the Site using information from MADEP’s
Geographic Information Mapping System (GIS) of environmental resources. The Site is
located within an MADEP-designated medium-yield non-potential drinking water source
area. Groundwater located on Site within 30 feet of an occupied structure would be
classified as GW-2 since the average annual depth to groundwater is less than 15 feet
below grade.
Groundwater is also category GW-3 by default.
4.3
Identification of Applicable Soil Category
Three categories of soil have been identified by MADEP to determine the applicability of
standards for the characterization of risk for individual compounds. These designations
are S-1, S-2, and S-3, and are based upon the site, receptor and exposure information in
conjunction with specific criteria for exposure potential to groups of individuals as
identified in 310 CMR 40.0933. The three soil category descriptions reference potential
for exposure to that soil. Category S-1 soils are associated with the highest potential for
exposure, with S-3 soils having the lowest. The potential for exposure is determined by
evaluating the frequency of use of the site, intensity of use of the site, and accessibility
of site soil by children and adults. The evaluation of these criteria for children and adults
is performed independently and the soil category with the lowest number from these two
evaluations is designated for the entire site or for a specified volume of soil on the site.

Frequency of use by adults is high, because adults work on-site on a continuing
basis. Children are not present.

Intensity of use is low, because routine site activities are passive and do not disturb
soil and because impacted soil is located beneath asphalt pavement or the
BODYCOTE facility.
Therefore, the soil exposure category is S-3. However, S-1 Soil Standards will be utilized
in the following risk characterization to evaluate the status of achieving No Significant Risk
without the need for an Activity and Use Limitation.
5.0
SUBSURFACE INVESTIGATION
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The following subsurface activities were conducted to fulfill MCP requirements for either
this RTN (2-15735), for RTN 2-12660 and/or RTN 2-14062:

A total of eighteen monitoring wells have been completed at the Site;

A total of 50 soil borings have been completed at the Site; and,

Quarterly groundwater gauging and sampling.
A Site Plan showing the soil boring locations (S-1 through S-45 as well as B-1, B-2, B-3, B4, and B-5/MW-6) is included as Figure 2.
A detailed summary of the subsurface
investigation relating to petroleum hydrocarbons is discussed below. Note that LPH and
the associated volatile petroleum hydrocarbons (VPH) and extractable petroleum
hydrocarbons (EPH) in and around the east end of the property are being addressed under
response actions conducted under RTN 2-12660.
5.1
Groundwater Gauging
Weekly manual groundwater gauging and LPH recovery has been conducted from
monitoring well MW-9, attached in Table 1. From November 3, 2005 through April 12,
2006, the amount of LPH recorded in monitoring well MW-9 ranged from 0.02 foot on
January 11, 2006 to 1.66 feet on March 1, 2006. Through April 12, 2006, a total of
approximately 8 gallons of LPH has been manually recovered from the well. Based on the
gauging data, there appears to be a correlation between the amount of LPH recorded in the
monitoring well and the depth to water. The thickness of LPH appears to increase as depth
to water increases. This trend will continue to be evaluated.
Based on these data, the overall groundwater flow direction is to the east/southeast, which
is consistent with previous data. A Groundwater Data Map of the April 3, 2006 data is
included as Figure 4.
5.2
Soil Sampling
During the Phase I investigation, lead, VPH, EPH, polyaromatic hydrocarbon
compounds (PAHs) and volatile organic compounds (VOCs) compounds in soil were
detected at concentrations exceeding the MADEP RCS-2 Reportable Concentrations.
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Between September 2002 and October 2005, CAPACCIO supervised the installation of
an additional 21 soil borings and 4 monitoring wells. Additionally, 6 soil samples were
collected during RAM activities completed from September 2003 through April 2004.
Boring logs and Well Completion Reports were submitted in the Revised Phase II and
Phase III submitted to the MADEP in July 2006 under RTN 2-14062. In reference to
these logs, the sediments encountered typically consisted of medium to fine sand with
varying amounts of silt, gravel and fill material. Continuous soil samples were collected
for field screening purposes utilizing a photoionization detector (PID). PID readings are
indicated on the boring logs.
5.2.1
Soil Analytical Data - VPH
In May 2004, a soil sample collected from soil boring S-27, located toward the front of the
facility, indicated a concentration of the C9-C10 VPH carbon chain range that exceeded the
applicable MADEP Method 1 Soil Standards at a depth of 7 to 10 feet below grade. VPH
and EPH data is summarized in Table 2. Between September 2002 and September 2005,
additional soil samples were collected and analyzed for VPH via the MADEP Method. In
reference to Table 2, no other VPH compounds exceeded the applicable MADEP Method 1
Soil Standards. None of the targeted compounds included in the VPH analysis have been
detected in any of the soil samples.
5.2.2 Soil Analytical Data - EPH
In September 2002, soil samples collected from soil borings S-6 and S-9, located on the
northern side of the facility, indicated concentrations of the C9-C18 and C19-C36 EPH carbon
chain ranges, respectively, that exceeded the applicable MADEP Method 1 Soil Standards
at depths of 9 and 10 feet below grade, respectively. Additionally, soil boring S-16, located
at the front of the facility along Grove Street, indicated concentrations of each of the EPH
carbon chain ranges that exceeded the applicable MADEP Method 1 Soil Standards at a
depth of 9 feet below grade. VPH and EPH data is summarized in Table 2. Between
October 2003 and September 2005, additional soil samples were collected and analyzed
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for EPH via the MADEP Method. In reference to Table 2, the C9-C18 Aliphatic and C11-C22
Aromatic carbon chain ranges were recorded at concentrations exceeding the applicable
MADEP Method 1 Soil Standards in soil boring S-29. The C19-C36 EPH carbon chain range
was recorded at concentrations exceeding the applicable MADEP Method 1 Soil Standards
in soil borings S-22, S-23, S-29, and S-33 and in soil samples collected from Area #1A and
Area #2B. Targeted compound analytical data is included in Table 3. In reference to this
table, none of the targeted compounds included in the EPH analysis have been detected in
any of the soil samples at concentrations exceeding the applicable MADEP Method 1 Soil
Standards.
5.3
Groundwater Sampling
During the Phase I investigation, lead, VPH, EPH and VOC compounds were detected in
groundwater at concentrations exceeding the applicable MADEP Method 1 Groundwater
Reportable Concentration. Since completion of the Phase I Report, quarterly groundwater
samples have been collected from selected and accessible monitoring points and
monitoring wells. Prior to sampling, a minimum of three well volumes of groundwater was
purged from the wells and purged groundwater was screened in the field for pH,
temperature, conductivity and dissolved oxygen.
The groundwater samples were
submitted to either Alpha Analytical Laboratories (Certification #M-MA086) or R.I. Analytical
Laboratories (Certification #MA-RI015) and analyzed for VPH and EPH with target
compounds via MADEP methods and/or volatile organics via either EPA Method 8260 or
8010. A summary of the VPH and EPH analytical data is presented in Table 4. Laboratory
analytical reports were submitted along with previously submitted Phase and ROS Status
Reports under RTN 2-12660 and/or RTN 2-14062.
5.3.1
Groundwater Analytical Data – VPH
VPH and EPH data is summarized in Table 3. In reference to Table 3, VPH compounds
exceeded the applicable MADEP Method 1 Groundwater Standard in monitoring wells MW4 (C9-C12 Aliphatics in July 2001 and April 2002 only), MW-6 (C9-C12 Aliphatics in April
2006), MW-8 (C5-C8 Aliphatics in June 2006), MW-9 (each of the VPH carbon chain ranges
from Januarh 2005 through April 2006), MW-S11 (each of the VPH carbon chain ranges in
April 2005), MW-12 (C9-C12 Aliphatics and C9-C10 Aromatics in April 2006) and monitoring
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point S-2 (C5-C8 Aliphatics and C9-C12 Aliphatics in October 2002). None of the targeted
compounds included in the VPH analysis have been detected in any of the monitoring
wells.
5.3.2
Groundwater Analytical Data – EPH
VPH and EPH data is summarized in Table 3. In reference to Table 3, EPH compounds
exceeded the applicable MADEP Method 1 Groundwater Standard in monitoring wells MW1 (each of the EPH carbon chain ranges on varying dates), MW-3 (C19-C36 Aliphatics in
October 2001 only), MW-4 (C9-C18 Aliphatics only on varying dates), MW-6 (C9-C18
Aliphatics only in January and April 2006), MW-9 (each of the EPH carbon chain ranges on
varying dates) and monitoring point S-2 (each of the EPH carbon chain ranges in October
2002).
5.4
Migration Pathways
Given the nature of the compounds present at the Site, the potential exists for migration of
OHM via air, soil, groundwater, and surface water. A discussion of each potential migration
pathway relative to the Site follows.
5.4.1
Air
Migration pathways for petroleum hydrocarbon compound vapors to enter ambient or
indoor air are present at the Site. Impacted groundwater from petroleum hydrocarbons is
present adjacent to and beneath the Site and located less than 10 feet below the ground
surface.
In order to determine if there is impact to indoor air from the subsurface
conditions, on May 11, 2006, three indoor air samples were collected from the facility. One
sample was collected from the southeastern rear of the facility, in the vicinity of MW-S11
and the former degreaser, one sample was collected from the center of the facility, in the
vicinity of S-14 and one sample was collected from the western side of the facility in the
vicinity of S-15 and the former degreaser. The samples were collected in accordance with
MADEP protocol over a 24-hour period. Each of the three samples was analyzed for
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volatile organic compounds via Method TO15. The analytical data is presented in the
revised Phase II and Phase III report, submitted to the MADEP in July 2006 under RTN 214062. In reference to this data, benzene, TCA and toluene were detected, however, at
concentrations significantly below the MADEP-established indoor air background
concentrations.
A pathway exists for petroleum hydrocarbon vapors to migrate into, and potentially impact
air quality, in the culvert or other subsurface utilities along Brookfield Streets. Migration of
petroleum under RTN 2-12660 to the underground culvert had occurred in the past through
a weep hole and was abated during IRA activities.
Significant impact to air inside the
underground culvert has not occurred by evidence of safe oxygen levels and safe lower
explosive limits measured in the culvert. The underground culvert is not an occupied
structure. As part of IRA activities being conducted under this RTN, utilities adjacent to the
Site are routinely screened. To date, no actionable levels have been detected.
5.4.2
Soil
Soil impacted with petroleum has been identified at the Site. These compounds are not
particularly mobile in soil. Therefore, soil is not considered a potential migration pathway.
5.4.3
Groundwater
Hydrocarbon-impacted groundwater has been identified on-site and is considered a
migration pathway. However, there are no reported private water supply wells within 500
feet of the Property and the Site is not located within or near a public water supply wellhead
protection area. Therefore, no exposure pathways to groundwater are present.
5.4.4
Surface Water
Although the Mill Brook Culvert is underground, water in the culvert is considered
surface water because it conveys surface water from Indian Lake to Salisbury Pond.
The underground culvert receives surface water runoff from the Site and can receive
groundwater via 4-inch-diameter weep holes in the wall to the culvert. A surface water
migration pathway is present but there is no exposure pathway. The culvert discharges
to Salisbury Pond, which, according to the WDPH, is not used for swimming, boating, or
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fishing.
Posted signs at the pond indicate that these activities are not permitted.
However, the pond does support a fish habitat.
There is no evidence of contamination from the Site to water in the underground culvert.
LPH from the Site had discharged to the underground culvert through the weep holes
and this pathway has been abated by blocking the holes and by operating a groundwater
interception trench as part of ROS activities under RTN 2-12660.
5.5
Exposure Assessment
The identification of potential human and environmental receptors is based upon a
comparison of the physical Site characteristics with the current and reasonably
foreseeable uses of the Site. There are no known documented impacts or exposures of
OHM to human receptors at or in the immediate vicinity of the Site. To date, there have
been no known complaints to the Site owner from neighboring residential Property
owners relative to compounds detected at the site. There has been no documented offsite impact to air or surface water from the site.
5.5.1
Current and Reasonably Foreseeable Site Conditions
Currently, the Property is maintained as a heat treating facility. Based on the Property
location and history, reasonably foreseeable site conditions are expected to remain
commercial or industrial.
However, to determine the level of risk for the most
conservative assumption, residential use of the Site will be evaluated. No foreseeable
uses or exposures at the Site have been excluded from this assessment at this time
through an Activity and Use Limitation (AUL) or by any temporary risk reduction
measure.
6.0
EVALUATION FOR IMMEDIATE RESPONSE ACTIONS
Per the MCP, the following conditions require Immediate Response Actions (IRAs):

Sites where a release or threat of release of OHM has occurred which requires 2-hour
notification;
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
Sites where a release or threat of release of OHM has occurred which requires 72-hour
notification;

Sites where a condition of Substantial Release Migration has been identified;

Any other site where the Department determines that immediate or accelerated
response actions are necessary to prevent, eliminate, or minimize damage to health,
safety, public welfare or the environment.
The presence of LPH measured at monitoring well MW-9, by definition, constitutes a
condition requiring IRAs.
6.1
Critical Exposure Pathway
The MCP defines Critical Exposure Pathways (CEPs) as those routes by which OHM
released at a Site are transported, or likely transported, to human receptors by 1) vapor
emissions of measurable concentrations into the living or working space of a pre-school,
daycare, school, or occupied residential dwelling; or 2) ingestion, dermal absorption or
inhalation of measurable concentrations of OHM from drinking water supply wells located at
and serving a pre-school, daycare, school, or occupied residential dwelling.
CAPACCIO has determined that a CEP is not present at the Site. There are no public or
private drinking water supply wells located in the area for a groundwater pathway to exist.
The closest residential dwelling to the Site is located approximately 300 feet to the
southeast and is located potentially downgradient of the Site.
The concentrations of
petroleum hydrocarbon compounds have been delineated to below the Method 1 GW-2
and GW-3 water quality standards and therefore not expected to result in a measurable
concentration to indoor air in the residential dwelling.
7.0
TIER CLASSIFICATION
A Tier Classification has been completed for the Site. In accordance with Subpart E of the
MCP, the Tier Classification consists of the following:

Completion of a Phase I report;

Completion of a Numerical Ranking Scoresheet;
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
Review of site conditions with Tier I Inclusionary Criteria; and

Preparation of a Tier Classification submittal.
The Tier Classification submittal includes the following documents:

Tier Classification form;

Licensed Site Professional (LSP) Tier Classification Opinion which includes this Phase I
report, NRS score sheet, and an opinion as to whether the site should classified as Tier
I or Tier II;

Certification of the submittal regarding the technical, financial and legal ability to
proceed with response actions at the site; and

Certification of the Tier Classification submittal itself;
Site conditions were reviewed relative to Tier I Inclusionary criteria as defined in the MCP
and conditions at the Site do not meet any of the criteria.
The NRS score was calculated at 262. This score classifies the Site as Tier II. The score
sheet is included as Appendix B.
The NRS score is based in part on the following conditions specific to the Site:

The Site is located in a Non-Potential Drinking Source medium yield aquifer where the
population density in this area of Worcester is greater than 4,400 people per square
mile. A score of zero was assessed for the “aquifer” portion of the NRS score sheet,
Part IV.B., in accordance with MADEP’s September 4, 1997 NRS Guidance Manual.

Greater than 12 inches of LPH measured at monitoring well MW-9 resulted in an OHM
human health toxicity score of 65 in Part III.A. of the NRS score sheet.
8.0
SUMMARY/CONCLUSIONS
A release of petroleum hydrocarbon compounds is present at the BODYCOTE property
located at 284 Grove Street in Worcester, MA. The following is a summary of findings
relating to the Phase I investigation:
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
Extractable and volatile petroleum hydrocarbons were present in soil and groundwater
beneath the property. LPH is present in the sidewalk area along Brookfield Street in
the vicinity of monitoring well MW-9. Potential source(s) of LPH are being reviewed by
CAPACCIO; and,

The Site scored 262 points under the MCP numerical ranking score sheet which
classifies it as Tier II.
9.0
PHASE I COMPLETION STATEMENT
This Phase 1 Report and Tier Classification were completed to investigate a release of lead
and chlorinated hydrocarbon compounds at BODYCOTE’s 284 Grove Street, Worcester,
MA facility. This investigation was completed in accordance with MCP, 310 CMR 40.0480.
Based on the results of the Phase I investigation, continued response actions are required;
a conceptual Phase II Scope of Work is provided below in Section 10.0.
10.0
CONCEPTUAL PHASE II SCOPE OF WORK
A conceptual Phase II scope of work is therefore presented for the purpose of fulfilling the
Tier Classification submittal. Phase II activities are anticipated to include the following:

Sampling and analysis of soil, groundwater, and LPH gauging to define the nature and
extent of petroleum product at the Site. The investigation will include consideration of
all potential on-site and off-site petroleum sources.

Collection of additional Phase II data in accordance with 310 CMR 40.0830 which may
be applicable to the Site.

Documentation of findings in a Phase II report in accordance with 310 CMR 40.0835.
It is estimated that the above conceptual scope of work will cost between $10,000 and
$15,000 depending on findings. In accordance with the MCP, a Phase II - Comprehensive
Site Assessment Report and, if necessary, a Phase III - Remedial Action Plan will be
submitted to the MADEP by May 5, 2008.
11.0
LIMITATIONS
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This Phase I Report is based solely on the scope of work conducted and sources referred
to in this report. The data presented in this report were collected and analyzed using
generally accepted industry methods and practices at the time the report was generated.
This report represents the conditions, locations, and materials that were observed at the
time the field work was conducted. No inferences regarding other conditions, locations, or
materials, at a later date or earlier time may be made based on the contents of the report.
This report was prepared for the sole use of BODYCOTE. CAPACCIO acknowledges and
agrees that this report may be conveyed to BODYCOTE’s attorney, lender, title insurer, and
regulatory agencies associated with the subject property. This report has been prepared in
accordance with the terms and conditions set forth in our Additional Services Letter
Agreement dated July 7, 2005. No other warranty, expressed or implied, is made.
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