IMMEDIATE RESPONSE ACTION PLAN
FORMER ATHOL MGP SITE
51 ELECTRIC STREET
ATHOL, MASSACHUSETTS
RELEASE TRACKING NUMBER 1-2014353
(LINKED RELEASE TRACKING NUMBERS 1-2015163 AND 1-2015815)
Tier IB Permit Number W039233
November 2009
Prepared For:
40 Sylvan Road
Waltham, Massachusetts 02451-1120
Prepared By:
Innovative Engineering Solutions, Inc.
25 Spring Street
Walpole, Massachusetts 02081
(508) 668-0033
IMMEDIATE RESPONSE ACTION PLAN
FORMER ATHOL MGP SITE
51 ELECTRIC STREET
ATHOL, MASSACHUSETTS
RELEASE TRACKING NUMBER 1-2014353
(LINKED RELEASE TRACKING NUMBERS 1-2015163 AND 1-2015815)
Tier IB Permit Number W039233
November 2009
Prepared for:
National Grid
40 Sylvan Road
Waltham, Massachusetts 02451-1120
Prepared by:
Innovative Engineering Solutions, Inc.
25 Spring Street
Walpole, Massachusetts 02081
Richard K. Eby, P.G., L.S.P.
Senior Hydrogeologist
Joseph E. Higgins, P.E., L.S.P.
Project Manager and LSP of Record
License Number 7196
Immediate Response Action Plan
Former Athol MGP Site
51 Electric Street
Athol, Massachusetts
DEP Release Tracking Number: 1-2014353
(Linked Release Tracking Numbers 1-2015163 and 1-2015815)
Tier IB Permit Number W039233
Pursuant to the Massachusetts Contingency Plan (MCP, 310 CMR 40.0000), this Immediate Response
Action (IRA) Plan has been prepared by Innovative Engineering Solutions, Inc. (IESI) on behalf of
National Grid. This IRA Plan outlines the IRA activities to be conducted at the former manufactured gas
plant (MGP) site located at 51 Electric Street in Athol, Massachusetts. The purpose of the IRA is to
address the presence of MGP-related waste consisting of coal tar in the form of dense non-aqueous liquid
(DNAPL) that was detected in one monitoring well at the site. A site location map is provided as Figure
1; a site plan is provided as Figure 2.
The former Athol MGP site has been assigned Release Tracking Number (RTN) 1-2014353 by the
Massachusetts Department of Environmental Protection (MassDEP) and is currently classified as a Tier
IB disposal site (with a Tier I permit number of W039233).
On September 22, 2009, DNAPL (coal tar) was measured in one monitoring well (MW-205D) at a
thickness of 0.75 foot. Pursuant to the MCP (specifically 310 CMR 40.0313(1)), the presence of NAPL
at a thickness greater than ½ inch is considered a release requiring notification to the Massachusetts
Department of Environmental Protection (MassDEP) within 72 hours. As such, IESI, on behalf of
National Grid, verbally notified Mr. Ben Fish of the MassDEP on September 24, 2009 at approximately
4:30 pm of this “72-hour” notification condition. This notification occurred within the regulatory
deadline. .
At the time of verbal notification, the MassDEP did not issue a new RTN for the condition. Mr. Fish of
the MassDEP indicated that this condition did not represent a new release since it was related to former
MGP operations for which response actions are currently being conducted under RTN 1-2014353; as
such, a new RTN was not necessary. Mr. Fish also indicated that a Release Notification Form (RNF,
BWSC-103) was not required for this release.
Pursuant to the MCP (specifically 310 CMR 40.0412(2)), an IRA is required for sites where a release has
occurred which requires notification to the MassDEP under the “72-hour” notification provisions. As
such, an IRA is being initiated to address the DNAPL condition. The MCP requires that an IRA Plan be
submitted to the MassDEP within 60 days of notifying the MassDEP of the need to conduct an IRA. This
IRA Plan satisfies that regulatory requirement. The content of this IRA Plan has been structured to
address the specific information requirements set forth in 310 CMR 40.0424 (1)(a) through (j). A copy of
the IRA Transmittal Form (BWSC-105) that was submitted electronically to the MassDEP is included in
Appendix A.
310 CMR 40.0424(1)(a)
the name, address, telephone number and relationship to the site of the
person assuming responsibility for conducting the Immediate Response
Action;
The property is the location of a former MGP, for which National Grid is the Responsible Party.
AmeriGas is the current owner. The site location is shown on Figure 1. The contact person, address, and
telephone number for National Grid is:
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Name:
Brian Quillia
Title:
Lead Senior Environmental Engineer
Address:
National Grid
40 Sylvan Road
Waltham, Massachusetts 02451-1120
Telephone Number:
(781) 907-3655
This information is also provided on the IRA Transmittal Form (BWSC-105) that was submitted
electronically to the MassDEP; a copy of this form is included in Appendix A.
310 CMR 40.0424(1)(b)
a description of the release or threat of release, site conditions, and
surrounding receptors;
This section provides background information including regulatory status, site history, and a summary of
the site information that was presented in the Phase II Comprehensive Site Assessment (CSA) report, the
Phase III Remedial Action Plan (RAP), the Phase IV Remedial Implementation Plan (RIP), and the
Revised Phase IV RIP that were submitted to the DEP in August 2005, December 2005, August 2006,
and July 2008, respectively.
Description of Release
Soil and groundwater at the site have been impacted as the result of historic operations associated with the
former MGP. Comprehensive response actions are currently being conducted at the site under Phase IV
of the MCP process and in accordance with the Tier IB permit (Tier I Permit Number W039233). These
comprehensive response actions include, in part, the following components:
•
Implementing phased groundwater remediation initially to address groundwater conditions in the
downgradient portion of the site and then subsequently in the source area.
•
Excavation and off-site disposal of the source materials. Excavation will focus on removing the
most highly contaminated soils at the site which potentially act as a continuing source of
contamination to groundwater.
•
Capping remaining impacted soils at the MGP property.
•
Implementing an Activity and Use Limitation (AUL) to require maintenance of the cap and to limit
site activities, including restricting potential unauthorized excavation activities and residential uses.
•
Implementing a groundwater monitoring program to assess the effectiveness of the groundwater
remediation system.
The groundwater remediation system consists of an oxygen delivery system that introduces oxygen to the
subsurface through injection points in order to create oxygen delivery zones (or permeable treatment
“curtains”) and enhance in-situ aerobic biodegradation. The initial phase of the oxygen delivery system
was constructed in 2007 and involved installation of a downgradient line of oxygen injection points in
order to target the downgradient portion of the plume. This line of oxygen injection points consists of ten
sparge well clusters with 3 injection points in each cluster. Each sparge well cluster consists of three
separate sparge wells screened within the shallow, intermediate and deep groundwater zones,
respectively. The deep sparge wells are screened above the bedrock surface, the intermediate depth
sparge wells are screened at approximate depths of 60 feet to 70 feet below the ground surface, and the
shallow depth sparge wells are screened at an approximate depth of 30 feet below the ground surface.
The locations of the sparge well clusters are shown on Figure 2.
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The equipment for the oxygen delivery system is housed in a steel shipping container (see Figure 2). The
system uses atmospheric compressed air (generated by the compressor) passed through a molecular sieve
(the oxygen generator) to generate a high oxygen gas stream for injection into the subsurface. The
process control and manifold piping system is configured to allow for automatic cyclic operation and
oxygen injection into a group of four or five wells at a time. The system uses both compressed air and
oxygen for injection into the aquifer, but the duration of compressed air is limited and used primarily to
facilitate distribution of oxygen into the formation.
The initial phase of the CRA was constructed as described in the Phase IV – Remedy Implementation
Plan that was submitted to the MassDEP in August 2006. Remaining portions of the CRA, including
installation of additional oxygen injection lines, proposed soil excavation activities at the former MGP,
and additional investigation activities to further delineate the downgradient extent of MGP-related
compounds in groundwater are being conducted in a phased and sequential manner as described in the
Revised Phase IV – Remedy Implementation Plan that was submitted to the MassDEP in July 2008.
On September 22, 2009, DNAPL (coal tar) was measured in one monitoring well (MW-205D) at a
thickness of 0.75 foot. As indicated above, the presence of NAPL at a thickness greater than ½ inch is
considered a release requiring notification to the MassDEP within 72 hours. The MassDEP was notified
of this release on September 25, 2009 at approximately 4:30 pm of this “72-hour” notification condition,
which is within the regulatory deadline. At the time of verbal notification, the MassDEP did not issue a
new RTN for the condition (nor did they require submittal of a RNF for this release), since this condition
was related to former MGP operations for which response actions are currently being conducted under
RTN 1-2014353, and did not represent a new release.
Description of Site Conditions
For purposes of this discussion, the term “site” is generally consistent with the definition of the site as
presented in the Phase II CSA; specifically, the boundaries of the site extend from the former MGP
located on Electric Street in a westward direction towards the South Street Well and extending beneath
Miller’s River, as delimited by the boundaries of the deeper groundwater zone having constituents with
concentrations greater than MCP Method 1 GW-1 standards. We also use the term “former MGP” to
refer to the property located at 51 Electric Street where the MGP was formerly located.
The former MGP site is located at 51 Electric Street in Athol, Massachusetts. Latitude and longitude
coordinates for the site are approximately 42° 35' 25" north latitude and 72° 14’ 14” west longitude. The
Universal Transverse Mercator (UTM) coordinates for the site are approximately 4,719,002 meters North
and 726,753 meters East.
The former MGP occupies an area of approximately 5.8 acres, and is currently owned by AmeriGas,
which operates a propane distribution facility on the property. Aboveground storage tanks (ASTs) used to
store the propane are situated in the southern corner of the property. Three buildings used for various
purposes by AmeriGas are also located on the property. A chain link fence restricts access to the
property; however, the gates to Electric Street are generally kept open during normal weekday business
hours. With the exception of the driveway into the yard and parking areas along Electric Street, the
remainder of the site not occupied by buildings is unpaved. An inactive railroad spur is located adjacent
to Electric Street on the southeastern corner of the former MGP property.
Most of the former MGP property is relatively flat and approximately 10 feet to 20 feet lower in elevation
than Electric Street and properties to the southeast along Harrison Street. The area west of the former
MGP slopes gently to the west across Jones Street and towards the Miller’s River. MW-205D, the
monitoring well that contains the DNAPL, is located on the west side of Jones Street.
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Surrounding Receptors
The site is located in a primarily commercial and residential portion of Athol. The site is generally
bordered to the east by Electric Street, to the south by Harrison Street, to the north by South Street, and by
Miller’s River to the west. Residential properties are located to the west, north, and east of the site, and
commercial properties are located to the south and southwest. The nearest residences are located less
than 100 feet from the site. The site and nearby properties are serviced by municipal water and sewer.
No institutions as defined by 310 CMR 40.0006 were identified within 500 feet of the site. The
residential population within a one-half mile radius of the site is estimated at greater than 1,000 people.
Miller’s River is located approximately 1,000 feet west of the former MGP. Mill Brook is located
approximately 500 feet north of the former MGP and flows in a westerly direction and discharges into the
Miller’s River. Based upon Massachusetts Geographic Information System (GIS) mapping, the banks
alongside Miller’s River are an area designated as Natural Heritage and Endangered Species Program
(NHESP) Estimated Habitat of Rare Wildlife in Wetland Areas, of which a portion is located at the 500
foot distance radius from the former MGP property. Mill Brook is located within the 100 year floodplain.
The GIS map shows no other surface water bodies, including mapped wetlands, vernal pools, ponds,
lakes, rivers, Outstanding Resource Waters, and reservoirs located within 500 feet of the site. In addition,
there are no Areas of Critical Environmental Concern, Protected Open spaces, habitats for Species of
Special Concern or Threatened or Endangered Species within 500 feet of the site. The GIS map shows
that the former MGP is located within an area designated as Non-Potential Drinking Water Source Area,
and a High Yield Potential Drinking Water Source Area is located approximately within the boundaries of
the site. The release associated with the former MGP is located within the Zone II wellhead protection
for the South Street Well; also, portions of the disposal site are located within the Zone I wellhead
protection area for the South Street Well. The South Street Well is located approximately 800 feet
hydraulically downgradient of the former MGP. The South Street Well has been used as a back-up water
supply for the Town of Athol since May 2000, when the Town installed three new supply wells
(identified as the Tully Well Field) on the northwest side of town. Historically, petroleum related
constituents have been periodically detected in the South Street well.
For risk characterization under the MCP (310 CMR 40.0932), groundwater at the site would be
designated GW-3 since all groundwater is considered a potential source for surface water discharge and is
classified as GW-3 category. Since the groundwater is generally encountered at depths less than 15 feet
below the ground surface, the groundwater would also be categorized as GW-2 within 30 feet of an
occupied building. Since the site is located within the Zone II wellhead protection area for the public
water supply wells, and a portion of the site is within the Zone I of the South Street Well, the site
groundwater is also considered category GW-1.
The soils would conservatively be considered accessible since portions of the site are not paved. Children
are not present; adults work at the property. Also, intensity of use would be considered low, since only
passive activities would occur at the site. However, since abutting properties have residential uses, site
soils are considered category S-1 for risk characterization purposes.
310 CMR 40.0424(1)(c)
a description of any Immediate Response Actions undertaken to date at
the site;
Following detection of the presence of DNAPL in monitoring well MW-205D on September 22, 2009,
monitoring well MW-205D was pumped to remove DNAPL. A total of approximately 3 gallons of a
mixture of DNAPL and water were recovered from the well during the pumping. The recovered fluids
were placed in a 55-gallon drum and moved to the drum storage area at the National Grid facility on
Harrison Street. This drum (along with 2 other drums of purge water generated during well development
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activities) was subsequently transported off-site by Clean Harbors to their facility in Braintree,
Massachusetts on October 7, 2009. A copy of the uniform hazardous waste manifest is included in
Appendix B.
310 CMR 40.0424(1)(e)
the objective(s), specific plan(s) and proposed schedule for the
Immediate Response Action, including, as appropriate, plans and/or
sketches of the site and any proposed investigative and/or remedial
installations;
The objective of this IRA is to implement remedial response actions to address the presence of DNAPL
detected in monitoring well MW-205D and to evaluate DNAPL recovery rates. IRA activities will
involve installation and operation of a pump in monitoring well MW-205D to collect and remove DNAPL
from the well.
A bottom-loading pneumatic pump equipped with a double-check valve (QED Model LP1301) will be
installed in monitoring well MW-205D. The pump will be operated using a QED pneumatic controller
(Model L360) to adjust on-off cycles and the pumping rate. Fluids will be pumped from the bottom of
the monitoring well until the fluids run clear. The pumping duration and amount of fluids recovered
during each pumping event will be recorded; an estimate of the amount of DNAPL recovered will also be
recorded.
Liquids (DNAPL and water) recovered from the well will be discharged directly into a 55-gallon drum.
The pneumatic pump will remain in the well along with the tubing and fittings. To facilitate recovery
operations and accommodate recovery equipment, a flush mount two-foot by two-foot well vault will be
installed on monitoring well MW-205D. The pump controller, 55-gallon storage drum, and other
ancillary equipment will be located on a portable utility trailer. The trailer will also be equipped with a
gas-powered air compressor for operation of the pneumatic pump. The remediation waste will be
temporarily stored at the hazardous waste storage area at the National Grid facility located adjacent to the
former MGP at 20 Harrison Street in Athol, Massachusetts.
DNAPL recovery will be conducted periodically during regular site visits. Initially, DNAPL recovery
will be conducted approximately once per month. The frequency of DNAPL recovery visits will be
adjusted (i.e. increased or decreased), as necessary, depending on the amount of DNAPL detected in
MW-205D and on the rate of DNAPL recovery.
It is expected that the DNAPL recovery operations will eventually be incorporated into the ongoing
Operation, Maintenance and Monitoring (OMM) activities that are currently being undertaken at the site
under Phase IV of the MCP. Following revision of the OMM Plan to incorporate the DNAPL recovery
operations, we will submit an IRA Completion Report as additional IRA activities will no longer be
required.
310 CMR 40.0424(1)(f)
a statement as to whether Remediation Waste will be excavated,
collected, stored, treated, or re-used at the site;
Since implementation of this IRA will involve the removal of DNAPL from MW-205D, remediation
waste will be collected and stored as part of IRA activities. All IRA derived/generated waste will be
managed in accordance with the provisions of the MCP. Specifically, any fluids removed from
MW-205D as well as used personal protective equipment and disposable equipment (tubing, etc.)
generated as a result of the IRA activities will be containerized. As indicated above, this remediation
waste will be temporarily at the hazardous waste storage area at the National Grid facility located adjacent
to the former MGP at 20 Harrison Street in Athol, and will be transported off-site for disposal within 90
days of generation.
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310 CMR 40.0424(1)(g)
where appropriate, a proposed environmental monitoring plan, for
implementation during and/or after the Immediate Response Action;
As discussed above, response actions are ongoing at the site under Phase IV of the MCP in accordance
with the Revised Phase IV RIP, and include additional investigation activities, routine site monitoring
activities including quarterly groundwater monitoring as part of OMM, and continued implementation of
the selected remedy for the site. The proposed IRA activities will be conducted in accordance with DEP
procedures and will be consistent with the ongoing monitoring activities. Specifically, for this IRA, we
anticipate monitoring NAPL recovery rates during the removal of fluids from the well. Also, during the
field activities for this IRA, we will conduct routine ambient air monitoring prescribed by the site Health
and Safety Plan which was included in the Revised Phase IV RIP.
310 CMR 40.0424(1)(h)
a listing of federal, state, or local permits that will likely be needed to
conduct the Immediate Response Action;
No permits are anticipated for the additional investigation activities.
310 CMR 40.0424(1)(i)
except as exempted pursuant to 310 CMR 40.0411(2), the seal and
signature of the Licensed Site Professional who prepared the Immediate
Response Action Plan;
This information is also provided on the IRA Transmittal Form (BWSC-105) that was submitted
electronically to the MassDEP; a copy of this form is included in Appendix A.
310 CMR 40.0424(1)(j)
such other information as the Department may deem appropriate and
necessary, based on site specific conditions, in order to review and
evaluate the Immediate Response Action Plan in question;
As indicated above, the response actions for this site are currently being conducted under the provisions
of Tier 1B Permit W039233. Based on the results of supplemental investigation activities completed at
the site and the detection of DNAPL in monitoring well MW-205D, we reviewed the site Tier
Classification and Numerical Ranking System (NRS) scoresheet to determine whether recent findings
would result in a change in Tier Classification for the site. The original numerical ranking and tier
classification was completed in May 2003 and resulted in a disposal site score of 522 points and
classification as a Tier 1B site. A copy of the original tier classification and NRS scoresheet is attached in
Appendix C.
Our review of the NRS scoresheet based on current site information and as summarized below resulted in
an increase in the total score of 20 points, or a revised total score of 542 points. Since this revised total
score does not exceed the NRS cutoff score for a Tier 1A site of 550 points, the Tier Classification
remains unchanged and the site remains classified as a Tier 1B disposal site. A summary of the NRS
scoring revisions based on current information is provided below for each section of the NRS scoresheet.
Section I – Disposal Site Information
Section I of the NRS provides relevant site information for which there are no scores. There were
no changes to Section I of the NRS.
Section II – Exposure Pathways
Section II of the NRS contains information on exposure pathways at the site, and the original
NRS scoresheet had a total score of 215 points. There were no changes to Section II of the NRS
and the score for this section remains 215 points.
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Section III – Disposal Site Characteristics
Section III of the NRS contains information on disposal site characteristics, and the original NRS
scoresheet had a total score of 112 points. Based on the detection of NAPL (coal tar) in
monitoring well MW-205D (at a thickness of 9 inches), the toxicity score (Section III. A.)
increased from 45 points to 60 points. This revision results in a total score of 127 points for
Section III.
Section IV – Human Population and Land Uses
Section IV of the NRS contains information on human population and land use in the vicinity of
the site, and the original NRS scoresheet had a total score of a total score of 105 points. There
were no changes to Section II of the NRS and the score remains 105 points.
Section V – Ecological Population
Section V of the original NRS contains information on ecological receptors, and the original NRS
scoresheet had a total score of 90 points. It appears there was a transcription error on page 1 of
the original NRS, which had a total score of 110 points for this section; the supporting
documentation indicated a score of 90 points, which was the correct score and was used in
calculating the total score.
Based on the current delineation of impacted groundwater at the site, the area of impacted
groundwater extends beneath areas delineated on MassGIS mapping as a wetland area which
would increase the score for the resource area from 0 points to 30 points, and results in an overall
score of 100 points for Section V.A. (Environmental Resource Areas). In addition, based on
current MCP environmental toxicity values, Section V.B (Environmental Toxicity Score)
increased from 20 points to 25 points. These changes result in a total increase of 35 points for the
section, and a total section score of 125 points for Section V.
Section VI – Mitigating Disposal Site-Specific Conditions
As noted above, we scored Section V.A. of the NRS scoresheet (Environmental Resource Areas)
as 100 points, with 30 points assigned to the "Wetlands, Certified Vernal Pool, or Outstanding
Resource Water" resource (this is the point value that is assigned for the resource being on-site).
While in plan view, the boundaries of the disposal site appears to extend onto a wetland area;
however, in profile or cross-section view, the contamination in the wetland area is located at
depths greater than 90 feet below the ground surface. As such, it is not likely that the
contamination at depth will affect the wetland resource area. Therefore, in Section VI of the NRS
scoresheet we deducted 30 points for this resource score, which is consistent with a score for the
wetlands being located greater than 100 feet from the disposal site.
As indicated above, our review of the NRS scoresheet based on current site information and as
summarized above resulted in an increase in the total score of 20 points, or a revised total score of 542.
Since this revised total score does not exceed the NRS cutoff score for a Tier 1A site of 550 points, the
Tier Classification remains unchanged and the site remains classified as a Tier 1B disposal site.
Should any questions and/or additional comments arise regarding this IRA Plan, please do not hesitate to
contact Joseph E. Higgins, P.E., L.S.P of IESI at (508) 668-0033 (ext. 223).
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FIGURES
APPENDIX A
COPY OF THE IMMEDIATE RESPONSE ACTION (IRA) TRANSMITTAL FORM
(BWSC-105)
APPENDIX B
COPY OF THE UNIFORM HAZARDOUS WASTE MANIFEST
APPENDIX C
COPY OF THE 2003 NRS SCORESHEET