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Home My WebLink AboutMiscellaneous - 49 BRENTWOOD CIRCLE 4/30/2018 le 49 BRENTWOOD CIRCLE 210/063.0-00311-0000,0 h, cJew av' Massachusetts Electric Company 1101 Turnpike Street Nlc.n chusetts Elec� North Andover,Massachusetts 01845 October 31, 1994 Ms. Mitra Khadem Commonwealth of Massachusetts Department of Environmental Protection Northeast Regional Office 10 Commerce Way Woburn, MA 01801 RE: Transformer,E48 Brent-W6bd-Circle North Andover RTN 3-6003 _ Response to Audit Finding Dear Ms. Khadem: Attached is a letter re repared b Ransom Environmental Consultants, Inc. on port p p Y behalf of Massachusetts Electric Company addressing the deficiency found during e the audit of the above referenced site. On September 15, 1994 excavating and soil sampling activities were conducted at the site as specified In your July 29, 1994 Notice of Audit Findings. Laboratory chemical analysis results indicated that the concentration of polychlorinated biphenyls (PCBs) remaining in the soil was below detection levels in all five samples collected from the perimeter of the former excavation. This Ino supports information su orts the conclusions in the RAO Statement prepared by Ransom and submitted by MECO to DEP on February 28, 1994. Should you have any questions regarding any of the enclosed information, please feel free to contact me at (508) 683-9511 . Sincerely, Ll� IF Maureen Breen, P.E. cc: L. J. Rounds P. R. Marshall BOH, North Andover, Attn: Sandra Starr A New England Electric System company amsom- Consulting Engineering Environmental Hydrogeology Consultants,Inc. Applied Sciences October 28, 1994 Project 93094 Ms. Maureen A. Breen Massachusetts Electric Company 1101 Turnpike Street North Andover, Massachusetts 01845 RE: Supplemental Soil Sampling Mineral Oil Dielectric Fluid Release . Pad-Mounted Transformer 39 Brentwood Circle North Andover, Massachusetts Release Date: July 21, 1993 MA DEP Release Tracking No. 3-6003 Dear Maureen: Ransom Environmental Consultants, Inc. (Ransom) has prepared this letter for Massachusetts Electric Company (MECO) and New England Power Service Company (NEPSCO) summarizing the soil sampling activities performed at the release site on September 15, 1994. The transformer is located on the north side of Brentwood Circle, adjacent to the east side of the residential property at 39 Brentwood Circle, in North Andover, Massachusetts. A sketch of the spill area is provided as Figure 1. Emergency response actions were performed on July 21-22, 1993 following the release of approximately 15 gallons of mineral oil dielectric fluid (MODF) from a 25 kVA pad-mounted transformer. Ransom transmitted a letter summarizing the response actions and the response action outcome (RAO) for the release site to the appropriate MECO and NEPSCO contacts on January 27, 1994. This letter was revised and resubmitted on February 22, 1994. Additional soil sampling activities were performed at the release site as required by the Massachusetts Department of Environmental Protection (MA DEP). The purpose of the sampling and subsequent laboratory chemical analysis was to confirm the absence of polychlorinated biphenyls (PCBs) and petroleum hydrocarbons at the limits of the excavation performed on July 21 and 22, 1993. Upon transmittal of this document to MA DEP, the certification attached to MA DEP's notice of audit findings letter must be signed and included with this letter. SOIL SAMPLING ACTIVITIES Ransom and MECO personnel visited the release site on September 15, 1994 to perform the excavation and sampling activities. Ransom observed that the new 25-kvA transformer installed to replace the previous transformer was smaller and that the concrete pad had been replaced Brawn's Wharf 45 Knollwood Road 90 Washington Valley Road Printed on Recycled Paper Newburyport,MA01950 Elmsford,NY 10523 Bedminster,N)07921 Tel (508)465-1822 Tel (914)345-2116 Tel (908)719-8947 Fax(508)465-2986 Fax(914)345-2123 Fax(908)781-1489 Maureen A. Breen Massachusetts Electric Company with a fiberglass box pad. The limits of the previous excavation were clearly marked by a slight depression in the ground and the presence of new grass. Prior to excavation activities, MECO personnel determined whether it was possible to de-energize the transformer without interrupting customer service. MECO determined this would not be possible and decided to perform the excavation with the transformer active. Excavation along the sides of the transformer at the limits of the previous excavation was performed using hand shovels and a small backhoe. Due to access limitations along the west and south sides of the transformer, MECO decided to excavate soil by hand on those sides. MECO excavated along the south side of the transformer to the bottom of the fiberglass box pad at a depth of approximately 3.5 feet below grade. MECO excavated at the former edge of the excavation to the level of the primary and secondary electric lines which feed into and out of the transformer. It was at this location, adjacent to the feed lines, that the sample 93094-E-SS1 was collected during the original cleanup activities. Petroleum hydrocarbons were detected during analysis of this sample at a concentration of 660 parts per million (ppm). Ransom collected a composite sample from the area adjacent to the lines which was designated as 93094-E-SS2. Along the remaining three sides, MECO excavated along the edge of the previous excavation to the depths of the original samples. Ransom determined that the excavation was at the limits of the former work, since it proceeded along the edges of the polyethylene sheeting which had been placed in the excavation during the initial response. During the excavation, Ransom collected composite soil samples from the east, west, and north sides of the excavation (designated as samples 93094-B-SS2, 93094-C-SS2, and 93094-D-SS2, respectively) in similar locations as the original sampling. Ransom also collected an additional composite sample from the southeast corner of the former excavation at a depth of approximately 5.0 feet below grade, in the area adjacent to and below the electrical lines. This sample was designated 93094-A-SS2 and was collected to represent the original sample 93094-A-SS1, which was collected at a depth of approximately 4.5 to 5.0 feet from beneath the electrical lines. Following the excavations, MECO backfilled the trenches with the excavated soil. After backfilling, MECO spread loam and seeded the area. LABORATORY CHEMICAL ANALYSIS RESULTS The five soil samples were submitted to Pace, Inc. (Pace) of Hampton, New Hampshire, and were analyzed for petroleum hydrocarbons by ASTM Method D3328-78, a gas chromatography method, and PCBs by United States Environmental Protection Agency (U.S. EPA) Method 8080. As shown in Table 1, petroleum hydrocarbons were detected in two of the composite soil samples collected from the excavation at concentrations of 17 ppm (93094-B-SS2) and 21 ppm (93094-D-SS2) and were identified by Pace as "indeterminate" lubricating oil, not MODF. The laboratory assigns an "indeterminate" identification when the sample chromatogram differs significantly from the reference chromatogram for the commercial products. Petroleum Ransom Project 93094 Page 2 er-rtn.ltr October 28, 1994 Maureen A. Breen Massachusetts Electric Company hydrocarbons were not detected above method detection limits in the remaining three composite samples. PCBs were not detected above the method detection limit-of 1.0 ppm in any of the five composite soil samples. Laboratory analysis data sheets are included as Attachment A. CONCLUSION Based on the results of soil sample chemical analyses, it is Ransom's opinion that soils remaining at the site have not been impacted by PCBs. With regard to petroleum hydrocarbon impacts, the initial cleanup approached background conditions and soil sample petroleum hydrocarbon concentrations were, again, below the MCP Method 1 S-1/GW-1 soil standard. As a result, this information supports the conclusions in the RAO Statement prepared by Ransom and submitted to MECO and NEPSCO on February 22, 1994. Should you have any questions regarding the emergency response actions that were performed at this spill site, please do not hesitate to contact us. Sincerely, RANSOM ENVIRONMENTAL CONSULTANTS, INC. Wayne C. Schanck Project Hydrogeologist _ l.J Allen R. Walker, P.E., LSP Senior Engineer WCS/TJS/ARW:sh Attachments E Ransom Project 93094 Page 3 er-rtn.ltr October 28, 1994 TABLE 1: SUMMARY OF SOIL SAMPLE CHEMICAL ANALYSIS RESULTS Supplemental Soil Sampling Mineral Oil Dielectric Fluid Release Pad-Mounted Transformer 39 Brentwood Circle North Andover, Massachusetts Sample Sample Sample Location PCBs Petroleum Hydrocarbons Designation Depth (feet) Concentration Concentration Laboratory (ppm) (ppm) Identification 93094-A-SS2 5.0 South Wall BDL(1) BDL(7) NA 93094-B-SS2 5.0 East Wall, bottom BDL(1) 17 Indeterminate Lubricating Oil 93094-C-SS2 4.5 West Wall,bottom BDL(1) BDL(7) NA 93094-D-SS2 6.0 North Wall, BDL(1) 21 Indeterminate bottom Lubricating Oil 93094-E-SS2 3.5 South Wall, BDL(1) Trace Indeterminate adjacent to lines Lubricating Oil NOTES: 1. Soil samples were collected by Ransom Environmental Consultants,Inc. on September 15, 1994, and were analyzed by Pace, Inc. of Hampton,New Hampshire. 2. Samples were analyzed for petroleum hydrocarbons by ASTM Method D3328-78, a gas chromatography method, and polychlorinated biphenyls (PCBs)by U.S. EPA Method 8080. 3. BDL = Below Detection Limit, with detection limit in parentheses. 4. Trace denotes compound detected but not quantifiable below method detection limits. 5. NA = Not Applicable. 4 Ransom Project 93094 Page 1 of 1 chem-rtn.tbl October 28, 1994 k APPROXIMATE LIMITS WOODED o OF ORIGINAL AREA a EXCAVATED AREA � N TO.39 BRENTWOOD gRgF --- -SS2 ---� WOODED AREA 1p WOODED f AREA I y- ( TRANSFORMER AND PAD ?i 0 ��E-_SS2— --A-� > NET `— --� 0 80X TREES NET SOIL SAMPLE BOX LOCATION AND DESIGNATION BRENTWOOD CIRCLE LEGEND: NOTES: _----_ APPROXIMATE LIMITS OF EXCAVATION ON JULY 21-22, 1993. 1. FIGURE BASED ON OBSERVATIONS AND APPROXIMATE LIMITS OF EXCAVATION MEASUREMENTS MADE BY RANSOM ENVIRON— ON SEPTEMBER 15, 1994. MENTAL CONSULTANTS, INC. ON JULY 21 AND 22, 1993 AND ON SEPTEMBER 15, 1994. 0 5 10 2. NET BOX=NEW ENGLAND TELEPHONE JUNCTION BOX APPROXIMATE SCALE in FEET 1'=5' MARMEnvironmental Consultants, Inc. SITE PLAN PREPARED FOR: SITE: MASSACHUSETTS ELECTRIC 39 BRENTWOOD CIRCLE DATE: OCTOBER 1994 COMPANY PROJECT: 93094 NORTH ANDOVER, MASSACHUSETTS NORTH ANDOVER. MASSACHUSETTS FIGURE: 1 93094-11 ATTACHMENT A Laboratory Analysis Data Sheets Supplemental Soil Sampling Mineral Oil Dielectric Fluid Release Pad-Mounted Transformer 39 Brentwood Circle North Andover, Massachusetts Release Date: July 21, 1993 MA DEP Release Tracking No. 3-6003 4 Ransom Environmental Consultants, Inc. Project 93094 N C O R P O R A T E Dace. REPORT OF LABORATORY ANALYSIS T4E ASSURANCE OF DUALITY October 3, 1994 Mr. Wayne Schanck Ransom Environmental Consultants Brown's Wharf Newburyport, MA 01950 RE: PACE Lab Number: 41554 P.O. Number: 93094 Project ID: 93094 Project Manager: Lillian Pepin Sample Receipt Date: September 15, 1994 Mass. Lab Certification #: NH00022 Dear Mr. Schanck: Please find enclosed the following information: • Technical Narrative • Sample Condition Receipt Report • Sample Table • Results • Chain-of-Custody Should you have any questions concerning this report please contact the project manager listed above. Partial reproduction of this document is prohibited; the final page of this report is so marked. The following signature indicates technical review and acceptance of the data. Sincerely, PACE New England, Inc. Authorized Signature Date P.O.Box 2130 An Equal Opportunity Employer 1 Lafayette Road Hampton,NH 03842 TEL•603.926.7777 FAX:603.926.7939 0000001 I N C O R P O R A T E D ce. REPORT OF LABORATORY ANALYSIS THE ASSURANCE OF QUALITY TECHNICAL NARRATIVE Laboratory Number: 41554 Samples were received in acceptable condition, with the exceptions noted on the sample receipt condition report. All samples were prepared and analyzed within the holding times specified in the referenced methods. Instruments and equipment used to generate sample data are calibrated to ensure that the accuracy and reproducibility of results are consistent with the data- user's quality requirements. Calibration procedures are derived from the appropriate USEPA methods and are detailed in specific laboratory Standard Operating Procedures. Procedures include initial calibration bracketing the working range, system performance checks, and continuing calibration verification at frequencies specified by the individual methods. Blank contamination was not observed at levels affecting the analytical results. Matrix effects, as monitored by matrix spike recovery, unusual physical properties and/or surrogate analyte recovery, were not apparent. Accuracy and precision as monitored by laboratory control sample analyses were within laboratory acceptance limits. Reference materials are obtained neat or in solution from reputable suppliers who certify them to be acceptable for use as primary calibration materials. As an additional control, these materials are checked with independent reference materials obtained from EPA or NIST when available. Preparation, use and storage of secondary dilutions of reference materials are in accordance with individual methods. Standard solutions are discarded before method specific holding times have been exceeded or sooner if degradation is observed. P.O.Box 2130 An Equal Opportunity Employer 1 Lafayette Road Hampton,NH 03842 TEL:603-926.7711 FAX:603.926.7939 0000002 PACE INCORPORATED NEW ENGLAND REGION LAB# 41554 SAMPLE RECEIPT CONDITION REPORT PAGE _t of_� Tel. (603) 926-7777 COOLER of FAX (603) 926-7939 COC# �C� SDG# CLIENT 1 lvl ` I(� DATE/TIME RECEIVED IS Qq �� LIMS ENTRY BY DELIVERED BY Q TRANSCRIPTION REVIEW BY RECEIVED BY LIMS REVIEW BY V °L L51(Y NA YES EXCEPTION COMMENT RESOLUTION 1. CUSTODY SEALS PRESENT/INTACT D", ❑ ❑ 2. CHAIN OF CUSTODY PRESENT IN THIS COOLER ❑ CR"' ❑ 3. CHAIN OF CUSTODY SIGNED ❑ I' ❑ 4. CHAIN OF CUSTODY MATCHES SAMPLES ❑ ly ❑ 5. SAMPLES RECEIVED AT 20- 6° C ❑ ❑ 6. VOLATILES FREE OF HEAD SPACE C�e ❑ ❑ 7. TRIP BLANK PRESENT IN THIS COOLER Ir ❑ ❑ B.. PROPER SAMPLE CONTAINERS AND VOLUME ❑ Ir ❑ 9. SAMPLES WITHIN HOLD TIME ❑ 01 ❑ 10. SAMPLES PROPERLY PRESERVED ❑ 11. ANALYTICAL PROGRAMS (circle one) COMMERCIAL CLP EPA-CLP NYASP NJ ISRA NEESA AFCEE Other 12. NUMBER OF PACE FILTRATIONS: 13. CORRECTIVE ACTIONS REPORT# Log-in Notes: CLIENT AUTHORIZATION SIGNATURE DATE 0000003 SAMPLE TABLE CLIENT ID. MATRIX PACE # PARAMETERS 93094-A-SS2 SOLID 41554-001 PCBS PETROLEUM HYDROCARBONS BY GC 93094-B-SS2 SOLID 41554-002 PCBS PETROLEUM HYDROCARBONS BY GC 93094-C-SS2 SOLID 41554-003 PCBS PETROLEUM HYDROCARBONS BY GC 93094-D-SS2 SOLID 41554-004 PCBS PETROLEUM HYDROCARBONS BY GC 93094-E-SS2 SOLID 41554-005 PCBS PETROLEUM HYDROCARBONS BY GC pace.C O R P O R A T E D tNE ASSURANCE 01 OUI1171 0000004 Laboratory number: 41554-001 Sample Designation: 93094-A-SS2 Date Extracted: 09/20/94 Date Analyzed: 09/21/94 Matrix: SOLID Results are expressed on a dry (103 degrees C) basis. Moisture content was 5 elevating the reporting limits by a factor of 1.05 PCBIS CONCENTRATION REPORTING LIMIT (ug/g) (ug/g) PCB-1242 BDL 1 PCB-1254 BDL 1 PCB-1221 BDL 1 PCB-1232 BDL 1 PCB-1248 BDL 1 PCB-1260 BDL 1 PCB-1016 BDL 1 METHOD REFERENCE: EPA SW 846, 3rd Edition METHODS 3550 AND 8080 BDL = Below reporting limit pace. coAPoaarEo TN! ASSUN/NCC,Of DUALITY 0000005 Laboratory number: 41554-001 Sample Designation: 93094-A-SS2 Date Extracted: 09/20/94 Date Analyzed: 09/21/94 Matrix: SOLID Results are expressed on a dry (103 degrees C) basis. Moisture content was 5 t, elevating the reporting limits by a factor of 1.04 REPORTING HYDROCARBON TYPE CONCENTRATION LIMIT (mg/kg) (mg/kg) Light Products BDL 3 Heavy Products BDL 7 METHOD REFERENCE: EPA SW 846, 3rd Edition. METHOD 8100 (MODIFIED) and ASTM D 3328-78 BDL = Below reporting limit Samples are compared to the following common commercial products in an effort to assess identity: gasoline, mineral spirits, kerosene, diesel/#2 fuel oil, #6 fuel oil, hydraulic oil, lubricating oil, mineral oil dielectric fluid (MODF) . Probable - Denotes similarity between chromatograms and one or more commercial materials. Indeterminate - Indicates that significant difference exists between sample and commercial products. a c¢. !I- IN C O R P O R 4 T E 0 IMC ASSURANCE Of OUAj1T1 0000006 PACE INCORPORATED SPB-5: 3Om X 0 . 25MM ID: 2UL INJECT, SCALE 2000 - 140,000 Page 1 Sample Name = 41554-1 PHC S RANSOM MODF 9/30 Report No = 9 . 01 Instrument = GCO9 Subseq/Sample/Bottle= 1/ 8/ 8 Sequence File: /DATA/GC09/SEQUENCE/G90920.SEQ V3 . 300 Method File /DATA/GC09/METHOD/C ALIB222CCA.MTHGti Result File /DATA/GC09/RESULT/G9S16840.RES t. Run Time 55.02 Minutes Injected on 0100 21Sep1994 Report Time 1136 21Sep1994 Run Status Signal0uerload SpecialInteg Timed Events Time Events Logic Value EuentUpdate 1 1.810 SumPeaks EuentOn -1 True 1 K . 400 2 5.210 SumPeaks EuentOff -1 True 3 5.650 ResetBl NoLogic -1 True 4 5.770 SumPeaks EuentOn -1 True 5 15.350 SumPeaks EuentOff -1 True 6 15.430 ResetBL NoLogic -1 True 7 15.630 SumPeaks EuentOn -1 True 8 16.200 SumPeaks EuentOff -1 True 9 16.480 ResetBL NoLogic -1 True 10 19.920 ResetBl NoLogic -1 True 11 20.100 SumPeaks EuentOn -1 True 12 48.010 ResetBL NoLogic -1 True 13 55.000 SumPeaks EuentOff -1 False Dil-Fact 100.00% Sample Amt: 0.0000 Standard Amt: 1.0000 Pk# RT IO-tm Factor Area Code UG/ML Name 1 3.30 #4.03 45670176 FF 0.0000 SOLVENT PEAK 1 15.40 15.00 96874 FF 16.8544 2FBIPHENYL 3(4/ 3 7 . 7 8 3 3 37.78 #35.63 720064 FF 90.5072 HEAVY PRODUCTS � amu � g3a u 4 0000007 Laboratory number: 41554-002 Sample Designation: 93094-B-SS2 Date Extracted: 09/20/94 Date Analyzed: 09/21/94 Matrix: SOLID Results are expressed on a dry (103 degrees C) basis. Moisture content was 8 t, elevating the reporting limits by a factor of 1.09 PCBES CONCENTRATION REPORTING LIMIT (ug/g) (ug/g) PCB-1242 BDL 1 PCB-1254 BDL 1 PCB-1221 BDL 1 PCB-1232 BDL 1 PCB-1248 BDL 1 PCB-1260 BDL 1 PCB-1016 BDL 1 METHOD REFERENCE: EPA SW 846, 3rd Edition METHODS 3550 AND 8080 BDL = Below reporting limit pace. coevooAteo 1AE ASSUAAACE Of OUAE17V 0000008 Laboratory number: 41554-002 Sample Designation: 93094-B-SS2 Date Extracted: 09/20/94 Date Analyzed: 09/21/94 Matrix: SOLID Results are expressed on a dry (103 degrees C) basis. Moisture content was 8 %-, elevating the reporting limits by a factor of 1.08 REPORTING HYDROCARBON TYPE. CONCENTRATION LIMIT (mg/kg) (mg/kg) Light Products BDL 4 Indeterminate Lubricating Oil 17 7 METHOD REFERENCE: EPA SW 846, 3rd Edition. METHOD 8100 (MODIFIED) and ASTM D 3328-78 BDL = Below reporting limit Samples are compared to the following common commercial products in an effort to assess identity: gasoline, mineral spirits, kerosene, diesel/#2 fuel oil, #6 fuel oil, hydraulic oil, lubricating oil, mineral oil dielectric fluid (MODF) . Probable - Denotes similarity between chromatograms and one or more commercial materials. Indeterminate - Indicates that significant difference exists between sample and commercial products. i I �I i I I CQ. I N C O R P O R A T E D THE ASSURAkCi Of oUA117V 0000009 PACE INCORPORATED SPB-5; 3Om X 0 . 25MM ID; 2UL INJECT, SCALE 2000 — 140,000 Page 1 Sample Name = 41554-2 PHC S RANSOM MODF 9/30 Report No a 10 . 04 Instrument = GCO9 Subseq/Sample/Bottle= 1/ 9/ 9 Sequence File: /DATA/GC09/SEQUENCE/G90920.SEQ 3 . 300 Method File a /DATA/GC09/METHOD/CALIB222CCA.MTH ( I Result File s /DATA/GC09/RESULT/G9S1684I.RES lC P Run Time n 55.02 Minutes Injected on 0205 21Sep1994 Report Time : 1655 26Sep1994 Run Status a EndOffBaseline Signal0uerload SpecialInteg Timed Euents Time Events Logic Value EuentUpdate 15 , 367 1 1.810 SumPeaks EuentOn -1 True 1 5.210 SumPeaks EventOff -1 True 3 5.650 ResetBL NoLogic -1 True 4 5.770 SumPeaks EuentOn -1 True 5 15.350 SumPeaks EventOff -1 True 6 15.430 ResetBl NoLogic -1 True 7 15.630 SumPeaks EuentOn -1 True 8 16.200 SumPeaks EventOff -1 True 9 16.480 ResetBL NoLogic -1 True 10 19.920 ResetBL NoLogic -1 True 11 20.100 SumPeaks EuentOn -1 True 11 48.010 ResetBL NoLogic -1 True 13 55.000 SumPeaks EuentOff -1 False Dil-Fact 100.00% Sample Amt: 0.0000 Standard Amt: 1.0000 Pk# RT ID-tm Factor Area Code UG/ML Name 36 . 817 1 3.30 #4.03 46184344 FF 0.0000 SOLVENT PEAK 1 15.37 15.00 127870 FF 22.2411 2FBIPHEHYL y LA 3 36,82 #35.63 5419528 FF 681.1984 HEAVY PRODUCTS S� lgsa� � oL4 0000010 Laboratory number: 41554-003 Sample Designation: 93094-C-SS2 Date Extracted: 09/20/94 Date Analyzed: 09/21/94 Matrix: SOLID Results are expressed on a dry (103 degrees C) basis. Moisture content was 3 1., elevating the reporting limits by a factor of 1.03 PCBFS CONCENTRATION REPORTING LIMIT (ug/g) (ug/g) PCB-1242 BDL 1 PCB-1254 BDL 1 PCB-1221 BDL 1 PCB-1232 BDL 1 PCB-1248 BDL 1 PCB-1260 BDL 1 PCB-1016 BDL 1 METHOD REFERENCE: EPA SW 846, 3rd Edition METHODS 3550 AND 8080 BDL = Below reporting limit pace.C O N P O N R T F N THE ASSUR-CE UI UUR1111 0000011 0 Laboratory number: 41554-003 Sample Designation: 93094-C-SS2 Date Extracted: 09/20/94 Date Analyzed: 09/21/94 Matrix: SOLID Results are expressed on a dry (103 degrees C) basis. Moisture content was 3 %-, elevating the reporting limits by a factor of 1.03 REPORTING HYDROCARBON TYPE CONCENTRATION LIMIT (mg/kg) (mg/kg) Light Products BDL 3 Heavy Products BDL 7 METHOD REFERENCE: EPA SW 846, 3rd Edition. METHOD 8100 (MODIFIED) and ASTM D 3328-78 BDL = Below reporting limit Samples are compared to the following common commercial products in an effort to assess identity: gasoline, mineral spirits, kerosene, diesel/#2 fuel oil, #6 fuel oil, hydraulic oil, lubricating oil, mineral oil dielectric fluid (MODF) . Probable - Denotes similarity between chromatograms and one or more commercial materials. Indeterminate - Indicates that significant difference exists between sample and commercial products. race. I N C O fl P O fl A T f D THE ASSURANCE-01 DUALITY 0000072 PACE INCORPORATED SPB-5, 30m X 0 . 25MM ID, 2LIL INJECT, SCALE 2000 — 140,000 Page 1 Sample Name = 41554-3 PHC S RANSOM MODF 9/30 Report No a 11 .01 Instrument = GC09 Subseq/Sample/Bottle= 1/ 10/ 10 Sequence File: /DATA/GC09/SEQUENCE/G90910.SEQ �t I 3 . 2- 0 Method File : /DATA/GC09/METHOD/CALIB212CCA,MTH `1 I Result File : /DATA/GC09/RESULT/G9S16842.RES Run Time : 55.02 Minutes Injected on 0309 11Sep1994 Report Time : 1139 21Sep1994 Run Status : EndOffBaseline SignalOuerload SpecialInteg Timed Events Time Events Logic Value EuentUpdate 15 . 350 1 1.810 SumPeaks EventOn -1 True 2 5.110 SumPeaks EuentOff -1 True 3 5.650 ResetBL NoLogic -1 True 4 5.770 SumPeaks EuentOn -1 True 5 15.350 SumPeaks EuentOff -1 True 6 15.430 ResetBL NoLogic -1 True 7 15.630 SumPeaks EuentOn -1 True 8 16.200 SumPeaks EuentOff -1 True 9 16.480 ResetBL NoLogic -1 True 10 19.920 ResetBL NoLogic -1 True 11 20.100 SumPeaks EventOn -1 True 12 48.010 ResetBL NoLogic -1 True 13 55.000 SumPeaks EventOff -1 False Oil-Fact : 100.00X Sample Amt: 0.0000 Standard Amt: 1.0000 Pk# RT IO-tm Factor Area Code UG/ML Name 37 . 150 1 3.25 #4.03 45885960 FF 0.0000 SOLVENT PEAK 1 15.35 15.00 157528 FF 27.4072 2FBIPHENYL5-5-% 3 37.15 #35.63 1724794 FF 216.7950 HEAVY PRODUCTS 0000013 II Laboratory number: 41554-004 Sample Designation: 93094-D-SS2 Date Extracted: 09/20/94 Date Analyzed: 09/21/94 Matrix: SOLID Results are expressed on a dry (103 degrees C) basis. Moisture content was 12 t, elevating the reporting limits by a factor of 1.13 PCB'S CONCENTRATION REPORTING LIMIT (ug/g) (ug/g) PCB-1242 BDL 1 PCB-1254 BDL 1 PCB-1221 BDL 1 PCB-1232 BDL 1 PCB-1248 BDL 1 PCB-1260 BDL 1 PCB-1016 BDL 1 METHOD REFERENCE: EPA SW 846, 3rd Edition METHODS 3550 AND 8080 BDL = Below reporting limit a ce., � PLt-F D A A D A A T F D iee asun.xeor Auutr 0000014 Laboratory number: 41554-004 Sample Designation: 93094-D-SS2 Date Extracted: 09/20/94 Date Analyzed: 09/21/94 Matrix: SOLID Results are expressed on a dry (103 degrees C) basis. Moisture content was 12 %, elevating the reporting limits by a factor of 1.13 REPORTING HYDROCARBON TYPE CONCENTRATION LIMIT (mg/kg) (mg/kg) Light Products BDL 4 Indeterminate Lubricating Oil 21 8 METHOD REFERENCE: EPA SW 846, 3rd Edition. METHOD 8100 (MODIFIED) and ASTM D 3328-78 BDL = Below reporting limit Samples are compared to the following common commercial products in an effort to assess identity: gasoline, mineral spirits, kerosene, diesel/#2 fuel oil, #6 fuel oil, hydraulic oil, lubricating oil, mineral oil dielectric fluid (MODF) . Probable - Denotes similarity between chromatograms and one or more commercial materials. Indeterminate - Indicates that significant difference exists between sample and commercial products. pace., L O R P O R R i F D TN[ ASSURANCE DF UU1111T 0000015 PACE INCORPORATED SPB-5; 3Om X 0 . 25MM ID; 2UL INJECT, SCALE 2000 — 140,000 Page 1 Sample Name = 41554-4 PHC S RANSOM MODF 9/30 Report No z 13 . 01 Instrument = GCO9 Subseq/Sample/Bottle= 1/ 12/ 12 Sequence File: /DATA/GC09/SEQUENCE/G90920.SEQ \ 3 , 300 Method File /DATA/GC09/METHOD/CALI8222CCA.MTN \ 1 1 Result File /DATA/GC09/RESULT/G9S16844.RES (DA IGI� Run Time 55.02 Minutes Injected on 0519 21Sep1994 Report Time 1140 21Sepl994 Run Status EndOffBaseline Signal0uerload SpecialInteg Timed Events Time Events Logic Value EuentUpdate 15 . 350 1 1.810 SumPeaks EuentOn -1 True 2 5.210 SumPeaks EuentOff -1 True 3 5.650 ResetBL Nologic -1 True 4 5.770 SumPeaks EuentOn -1 True 5 15.350 SumPeaks EuentOff -1 True 6 15.430 ResetBL Nologic -1 True 7 15.630 SumPeaks EuentOn -1 True 8 16.200 SumPeaks EuentOff -1 True 9 16.480 ResetBL Nologic -1 True 10 19.920 ResetBL Nologic -1 True 11 20.100 SumPeaks EuentOn -1 True 11 48.010 ResetBL Nologic -1 True 13 55.000 SumPeaks EuentOff -1 False Oil-Fact 100.00% Sample Amt: 0.0000 Standard Amt: 1.0000, 34 . 183 ``— Pk# RT ID-tm Factor Area Code UG/ML Name :r .03 466 4 30. 3 1 # 64456 FF 0.0000 SOLVENT PEAK 2 15.35 15.00 194369 FF 33.8169 2FBIPHENYL toe 3 34.18 #35.63 5948488 FF 747.6851 HEAVY PRODUCTS 5gg8�Ae)? C)q 0000016 Laboratory number: 41554-005 Sample Designation: 93094-E-SS2 Date Extracted: 09/20/94 Date Analyzed: 09/21/94 Matrix: SOLID Results are expressed on a dry (103 degrees C) basis. Moisture content was 1 elevating the reporting limits by a factor of 1.01 PCB'S CONCENTRATION REPORTING LIMIT (ug/g) (ug/g) PCB-1242 BDL 1 PCB-1254 BDL 1 PCB-1221 BDL 1 PCB-1232 BDL 1 PCB-1248 BDL 1 PCB-1260 BDL 1 PCB-1016 BDL 1 METHOD REFERENCE: EPA SW 846, 3rd Edition METHODS 3550 AND 8080 BDL = Below reporting limit pace.O O P P 0 8 A T f D THI ASSURANCE OF OUAL11V 0000017 Laboratory number: 41554-005 Sample Designation: 93094-E-SS2 Date Extracted: 09/20/94 Date Analyzed: 09/21/94 Matrix: SOLID Results are expressed on a dry (103 degrees C) basis. Moisture content was 1 %, elevating the reporting limits by a factor of 1.01 REPORTING HYDROCARBON TYPE CONCENTRATION LIMIT (mg/kg) (mg/kg) Light Products BDL 3 Indeterminate Lubricating Oil TRACE 7 METHOD REFERENCE: EPA SW 846, 3rd Edition. METHOD 8100 (MODIFIED) and ASTM D 3328-78 BDL = Below reporting limit Samples are compared to the following common commercial products in an effort to assess identity: gasoline, mineral spirits, kerosene, diesel/#2 fuel oil, #6 fuel oil, hydraulic oil, lubricating oil, mineral oil dielectric fluid (MODF) . Probable - Denotes similarity between chromatograms and one or more commercial materials. Indeterminate - Indicates that significant difference exists between sample and commercial products. "TRACE" denotes probable presence below listed detection limit. pace. C O F P O N A T E O INE ASSURANCE 01 0UAE1it 0000018 h PACE INCORPORATED SPB-5; 3Om X 0 . 25MM ID; 2UL INJECT, SCALE 2000 — 140,000 Page 1 Sample Name : 41554-5 PHC S RANSOM MODF 9/30 Report No : 14. 01 Instrument = GCO9 Subseq/Sample/Bottle= 1/ 13/ 13 Sequence File: /DATA/GC09/SEQUENCE/G90920.SEQ \\C1� i 3 . 267 Method File /DATA/GC09/METHOD/CALIB221CCA.MTH �, n Result File /DATA/GC09/RESULT/G9S16845.RES Run Time 55.02 Minutes Injected on 0624 21Sep1994 Report Time 1141 21Sep1994 Run Status EndOffBaseline SignalOuerload SpecialInteg Timed Euents Time Events Logic Value EuentUpdate 15 . 3 5 0 1 1.B10 SumPeaks EventOn -1 True 1 5.210 SumPeaks EventOff -1 True 3 5.650 ResetBL NoLogic -1 True 4 5.770 SumPeaks EuentOn -1 True 5 15.350 SumPeaks EuentOff -1 True 6 15.430 ResetBL NoLogic -1 True 7 15.630 SumPeaks EuentOn -1 True 8 16.200 SumPeaks EuentOff -1 True 9 16.480 ResetBL NoLogic -1 True 10 19.920 ResetBL NoLogic -1 True 11 20.100 SumPeaks EuentOn -1 True 11 48.010 ResetBL NoLogic -1 True 13 55.000 SumPeaks EuentOff -1 False i Dil-Fact 100.00% Sample Amt: 0.0000 Standard Amt: 1.0000 Pk# RT ID-tm Factor Area Code UG/ML Name q 1 3.27 #4.03 45820424 FF 0.0000 SOLVENT PEAK SS 37 . 783 2 15.35 15.00 194485 FF 33.8371 1FBIPHENYL � 3 37.78 #35.63 2739600 FF 344.3494 HEAVY PRODUCTS X 39G,00 LL a�c��-� �j� goy = i ► R I �..0 c 0000019 • 2F SOIL PESTICIDE SURROGATE RECOVERY Client: RANSOM ENVIRONMENTAL CONSULTANTS Lab No. : 41554 Project: 93094 Level: Soil CLIENT I S1 I S2 JOTHER ITOTI SAMPLE NO. (DBC)# (TCX)#1 JOUTI 93094-A-SS2 1 90 1 92 1 0 1 93094-B-SS2 1 82 1 82 I 1 0 1 93094-C-SS2 1 90 1 93 1 1 0 93094-D-SS2 1 67 I 75 1 1 0 93094-E-SS2 1 93 1 94 1 ( 0 IB-P4038C 1 94 1 93 I 0 QC LIMITS S1 (DBC) = Dibutyl Chlorendate 20 - 150 S2 (TCX) = Tetrachloro-m-xylene 20 - 150 # Column to be used to flag recovery values with an asterisk * Values outside of designated QC limits D Surrogates diluted out I loCQ® I N L O N P O N 4 T f D iNE ASSUR ANCI pR pUA lI1T 0000020 Laboratory number: B-P4038C Sample Designation: LABORATORY BLANK Date Analyzed: 09/21/94 Matrix: SOLID PCB'S CONCENTRATION DETECTION LIMIT (ug/g) (ug/g) PCB-1242 BDL 1.0 PCB-1254 BDL 1.0 PCB-1221 BDL 1.0 PCB-1232 BDL 1.0 PCB-1248 BDL 1.0 PCB-1260 BDL 1.0 PCB-1016 BDL 1.0 METHOD REFERENCE: EPA SW846, 3RD EDITION METHODS 3550 AND 8080 BDL = Below detection limit pace.C O H i 0 H A T E D INI ASS UAA MCF DI OUA1111 000002'1 PCB'S MATRIX SPIKE RECOVERY Laboratory Number: LS-P4038 Sample Designation: LABORATORY CONTROL SAMPLE Date Analyzed 09/15/94 Matrix: SOLID ug/g IN ug/g ug/g %REC- COMPOUND SAMPLE SPIKE FOUND OVERY AR-1254 0 5.04 4.91 97 METHOD REFERENCE: EPA SW846, 3RD EDITION METHODS 3550 AND 8080 pace.O O N P O N A T E D IN( Ass URANCI of a U a IIIT 0000022 QUALITY CONTROL DATA PETROLEUM HYDROCARBONS BY IR BLANK DATA Laboratory Number: B-H1064A Sample Designation: METHOD BLANK Date Analyzed: 09/20/94 Matrix: SOLID COMPOUND CONCENTRATION DETECTION LIMIT mg/kg mg/kg LIGHT PRODUCTS BDL 3 HEAVY PRODUCTS BDL 6 MATRIX SPIKE RECOVERY Laboratory Number: LS-H1064 Sample Designation: LABORATORY CONTROL SAMPLE Date Analyzed 09/20/94 Matrix: SOLID mg/kg mg/kg mg/kg % COMPOUND SAMPLE SPIKE FOUND RECOVERY DIESEL 0 34 19.6 58 METHOD REFERENCE: METHOD 8100 (MODIFIED) AND ASTM D 3328-78 Ce. pi2-L O N Y O H A T E O lx[ RSSURNNCE Of OU1111 0000023 Ransom Environmental Consultants, Inc., Brown's Wharf CHAIN OF CUSTODY (COC) o Newburyport, Massachusetts 01950 508/465-1822 Page of Project: 410 OP /CZ�5,L - C >`�: C. J,'rLE Lab: Pia - a Chain of Custody# /-3)c>9 Address: Ts'laN�w,�r) c cF'c%.c v, vi�;�%-�� r�if _ Lab Contact: r r' N /011/7 ,A) Sampled By: W4yove. Project#: 73 U I Y Lab Phone#: S (gy p_,) �1�✓✓ ? ? ?? Chemical Analyses Requested Cortmenls Date Time W-Water G-Grab Number of Field Field Filter Sample Identification Sampled Sampled Containers Preserve L-Liquid C-Com• G' pestle `L n •11 S-Solid W-Wipe J ? n /200 > C & 1 01A s/,?,t //So 923-f- C- 5SL 1 09-1- E—S5Z vl,5'/'1y 10gQ e fished b : , Date: t. Time: Received b .� Y (,� ;t ,,r �i •i +S', `l G✓ Y Date: Time: 5 elinquished W. Date: Time: Received by: Date' Time: Relin uished b : �� _ q Y Date: Time: Received by: Date: Time: Please include standard 0A10C DnrnimPntntinn• v;,N -- tr •* Commonwealth of Massachusetts Executive Office of Environmental Affairs Department of Environmental Protection Metro Boston/Northeast Regional Office William F. Weld Governor Trudy S.Coxe Secretary,EOEA (�Q/� Thomas B. powers JUL 2 vQ 199`T Ailing Commissioner CERTIFIED MAIL: Mass Electric Co. RE : NORTH ANDOVER 1101 Turnpike Street Mass Electric Co-Transformer North Andover, MP_ 01845 V9`B—rd ntwood-Circle RTN-3-6003 ATTN: Ms . Maureen Breene : NOTICE OF AUDIT FINDINGS INTERIM DEADLINE This is an important notice Promptly respond to any requests contained herein Failure to respond to any such requests could result in serious legal consequences. On June 3 ,1994 the Massachusetts Department of Environmental Protection issued a Notice of Audit informing you that the Department was conducting an audit of certain activities related to the disposal site referenced above pursuant to 310 CMR 40 . 1100 . That audit is now complete . The purpose of this notice is to explain the results of the audit . The scope of this audit included the following activities : * a Notice of Audit, issued on June 3 , 1994 ; * a site visit conducted on June 8, 1994 ; * a review of the documents in the Department ' s files . SUMMARY OF RESPONSE ACTIONS On July 21, 1993 , approximately 15 gallons of mineral oil dielectric fluid (MODF) was released from a 25kVA pad-mounted transformer. The transformer is located on the north side of 10 Commerce Way • Woburn, Massachusetts 01801 0 FAX(617)932-7615 9 Telephone(617)932-7600 Mass Electric Co. Page 3 1) Deficiency A sample of MODF was only tested by a Clor-n-Oil test kit which is a screening method to determine the approximate PCB levels in the oil . Due to the location of the transformer in a residential area and the low Method 1 cleanup standards for PCBs (the MCP S-1, S-2 , and S-3 Standards are 2 mg/kg) , it is essential to verify the levels of PCBs by laboratory analyses . Steps to correct deficiency: Soil samples should be collected along the perimeter of the former excavation and the area that detected the highest TPH levels during the July 1993 sampling, and analyzed for PCBs by EPA method 8080 . If the average PCB levels are above 2 mg/l, then the submitted risk characterization and RAO must be revised. You must respond in writing to the Department (to the attention of Mitra Khadem) within 30 days of the date of this Notice, indicating: (1) that you have taken the specified steps and corrected the deficiency, or (2) the date by which you anticipate completing the actions necessary to correct the identified deficiency, or (3) a rational as to why the deficiency does not exist . This response must include appropriate evidence and documention of your actions as specified for the deficiency. Failure to address the deficiency identified above by the Department, by the Interim Deadline established herein, may subject you and your officers and employees to enforcement action by the Department . The Department may conduct a follow-up audit to determine whether the required actions have been taken and the deficiency corrected. If the Department finds that the deficiency have not been addressed, then the Department may issue a Notice of Noncompliance (NON) , Notice of Intent to Assess a Civil Administrative Penalty (PAN) , administrative enforcement order, Notice of Responsibility (NOR) , Notice of Intent to take Response Action (NORA) or Unilateral Order; as appropriate . You may also be subject to cost recovery under 310 CMR 40 . 1200 for failure to perform response actions at the disposal site . A copy of this notice has been sent to the Licensed Site Professional (LSP) Allen R. Walker, Ransom for your disposal site . You may consult with the LSP when preparing a response to this notice . Note, however, that you, not your LSP, are obligated to respond to this Notice and remedy the deficiencies . Note that any submittal to the Department made in response to this notice must include the certification provided in Attachment 1 signed by an authorized individual as specified in 310 CMR 40 . 0009 . 3 1 Mass Electric Co. Page 4 This audit does not preclude future audits of past, current, or future response actions or activities at the site or inspections to confirm compliance with applicable requirements of other laws or regulations enforced by the Department . These findings do not in any way constitute a release from liability under M.G.L. c . 21E, the MCP, or any other law, regulation, or requirement . No portion of this Notice shall be construed to relieve any person from an obligation for Response Action Costs or damages related to a site or disposal site for which that person is liable under M.G.L. c . 21E or from any obligation for any administrative, civil or criminal penalty, fine, settlement, or other damages . No portion of this Notice shall be construed to limit the Department ' s authority to take or arrange, or to require any Responsible Party or Potentially Responsible Party to perform, any response action authorized by M.G.L. c . 21E which the Department deems necessary to protect health, safety, public welfare or the environment . If you have any questions regarding this notice or any requirements contained in it please contact Mitra Khadem or Jack Duggan at 617-932-7600 . Please reference the Release Tracking Number in any correspondence regarding the site . Very truly yours, Kk Cl Mitra Khadem Environmental Anal st 1 Patricia M. Donahue Chief, Compliance/Audits Bureau of Waste Site Cleanup CC: Ransom Environmental Consultants, Inc . , Brown Wharf Newburyport, MA 01950 , Attn: Allen R. Walker DEP/NERD/Data Entry/Files DEP/Boston/BWSC, c/o Larissa Drennen DEP/Boston, Steve Winslow BOH, 120 Main Street, North Andover, 01854 , Attn: Sandra Starr Town Hall, 120 Main Street, North Andover, 01854 , Attn: James Gordon 4 . 1 ATTACHMENT 1 CERTIFICATION OF SUBMITTAL (310 CMR 40 . 0009) This certification must be included with your response to the a Request for Information I certify under the penalties of law that I have personally examined and am familiar with the information contained in this submittal, including any and all documents accompanying this certification, and that, based on my inquiry of those individuals immediately responsible for obtaining the information, the material information contained herein is, to the best of my knowledge and belief, true, accurate and complete . I am aware that there are significant penalties, including, but not limited to, possible fines and imprisonment, for wilfully submitting false, inaccurate or incomplete information. Name (Print) : Position or title : Signature : Date : i DimKARENELSON ttor ,� a Town Of 120 Main Street, 01845 NORTH ANDOVER (508) 682-6483 BUILDING ;'•=:;;;e::•�� CONSERVATION ,ee4CNUgp4 DIVISION OF HEALTH PLANNING PLANNING & COMMUNITY DEVELOPMENT FILE 0 January 11, 1994 Mr. Scott Sayers, Environmental Analyst Mr. Roger Chu, Emergency Resp. Section Branch Chief DEP Northeast Region 10 Commerce Way Woburn MA 01801 RE: Spill—at=49 Brentwood=C rcle=Nort-h=Andover Dear Sirs: I recently received (from our Health Agent) a copy of the letter to Ms. Lori Rowds of Mass Electric pertaining to a spill of transformer oil on the above property. Please be advised that this property is within the watershed to North Andover' s sole source of public drinking water. Furthermore, this site may be within 100 ' of a wetland which is a tributary to the water supply. With this in mind, I would appreciate it if you would forward copies of any future correspondence to the Conservation Office. I am particularly interested in specific remediation measures such as soil removal. Also, how much material was spilled and where on the property was it released? Any alteration of land or discharges in this area are likely within the jurisdiction of the Conservation Commission and/or Planning Board and I would like to better inform them of this incident. Sincerely, Richard P. Doucette Conservation Administrator Town of North Andover MA CC : `North Andover Board of Health' North Andover Fire Department North Andover Division of Public Works Ms. Lori J. Rowds, Mass Electric b 1<v Commonwealth of Massachusetts Executive Office of Environmental Affairs Department of Environmental Protection Metro Boston/Northeast Regional Office William F. Weld Governor DEC 2 7 1993 Daniel S.Greenbaum Commissioner URGENT LEGAL MATTER: PROMPT ACTION NECESSARY CERTIFIED MAIL: RETURN RECEIPT REOUESTED Massachusetts Electric Company RE:NORTH ANDOVER 25 Research Drive f-49 'Brentwood Circle Westborough, MA 01582-0005 `RTN #3-0006003 NOTICE OF RESPONSIBILITY & INTERIM DEADLINE (S) ; M.G.L. c. 21E & 310 CMR 40. 0000 Attention: . Ms. Lori J.. :Rowds . Dear Madam: The Department of Environmental Protection (the Department or DEP) has determined that there is or has been a release of oil and/or hazardous material at the above-referenced property. The DEP received notification on July 21, 1993 that a release of transformer oil occurred at the subject property. . Based upon the information available, the Department has reason to believe that the subject property or portions) thereof is a disposal site as defined in the Massachusetts Oil and Hazardous Material Release Prevention and Response Act, M.G.L. c. 21E, and the Massachusetts Contingency Plan, 310 CMR 40. 0000 (the MCP) and that all the necessary and required response actions have not been taken such that a level of level of No Significant Risk exists or has been achieved in compliance with M.G.L. c. 21E and the MCP. The purpose of this notice is to inform you of your legal responsibilities under state law and to provide you with an Interim Deadline for assessing and/or remediating the subject release or threat of release pursuant to the MCP. For purposes of this notice, the terms and phrases used herein shall have the meaning ascribed to them by the MCP unless the text clearly indicates otherwise. 10 Commerce Way • Woburn,Massachusetts 01801 • FAX(617)935-6393 • Telephone(617)935-2160 ' E u Massachusetts Electric Company Page 2 STATUTORY LIABILITIES The following is provided to advise you of your statutory liabilities for completing response actions at the subject site. It is a summary of the liability provisions from M.G.L. c. 21E. Please refer to the statute for a complete description of the liability provisions. The Department has reason to believe that you (as used in this letter, "you" refers to Massachusetts Electric Company are a Potentially Responsible Party (a PRP) with liability under M.G.L. c. 21E, § 5, for response action costs. Section 5 makes the following parties liable to the Commonwealth of Massachusetts: current owners or operators of a site from or at which there is or has been a release/threat of release of oil or hazardous material; any person who owned or operated a site at the time hazardous material was stored or disposed of; any person who arranged for the transport, disposal, storage or treatment of hazardous material to or at a site; any person who transported hazardous material to a transport, disposal, storage or treatment site from which there is or has been a release/threat of release of such material; and any person who otherwise caused or is legally responsible for a release/threat of release of oil or hazardous material at a site. This liability is "strict" , meaning it is not based on fault, but solely on your status as an owner, operator, generator, transporter or disposer. It is also joint and several, meaning that you may be liable for all response action costs incurred at the site, regardless of the existence of any other liable parties. The MCP requires responsible parties to take necessary response actions at properties where there is or has been a release or threat of release of oil and/or hazardous material. If you do not take the necessary response actions, or fail to_ perform them in an appropriate and timely manner, the Department is authorized by M.G.L. c. 21E to have the work performed by its contractors. By taking such actions, you can avoid liability for response action costs incurred by the Department and its contractors in performing these actions, and any sanctions which may be imposed for failure to perform response actions under the MCP. You may be liable for up to three (3) times all response action costs incurred by the Department. Response action costs include, without limitation, the cost of direct hours spent by Department employees arranging for response actions or overseeing work performed by persons other than the Department or their contractors, expenses incurred by the Department in support of those direct hours, and payments to the Department' s contractors. (For more detail on cost liability, see 310 CMR 40. 1200. ) Massachusetts Electric Company Page 3 The Department may also assess interest on costs incurred at the rate of twelve percent (12%) , compounded annually. To secure payment of this debt, the Commonwealth may place liens on all of your property in the Commonwealth. To recover the debt, the Commonwealth may foreclose on these liens or the Attorney General may bring legal action against you. In addition to your liability for up to three (3) times all response action costs incurred by the Department, you may also be liable to the Commonwealth for damages to natural resources caused by the release. Civil and criminal liability. may also be imposed under M.G.L. c. 21E, S 11, and civil administrative penalties may be imposed under M.G.L. c. 21A, S 16 for each violation of M.G.L. c. 21E, the MCP, or any order, permit or approval issued thereunder. NECESSARY RESPONSE ACTIONS The Department has determined that an IRA, including, but not limited to soil removal and the collection and analysis confirmatory samples is necessary at the subject site to respond to the aforementioned release of transformer oil. You must employ or engage a Licensed Site Professional (LSP) to manage, supervise or actually perform the necessary response actions at the subject site. In addition, the MCP requires persons undertaking response actions at a disposal site to submit to the Department a Response Action Outcome Statement (RAO) prepared by an LSP in accordance with 310 CMR 40. 1000 upon determining that a level of No Significant Risk already exists or has been achieved at a disposal site or portion thereof. [You may obtain a. list of the names and addresses of these licensed professionals from the Board of Registration of Hazardous Waste Site Cleanup Professionals at (617) 556-1145. ] INTERIM DEADLINE(S) FOR COMPLIANCE WITH THE MCP Revisions to the Massachusetts Contingency Plan became effective on October 1, 1993 . Information available to the Department indicates that all of the response actions necessary to achieve a level of No Significant Risk at the subject site were not taken and/or completed as of October 1, 1993 . Therefore, additional response actions must now be conducted in accordance with M.G.L. c. 21E and the revised MCP, 310 CMR 40. 0000. Massachusetts Electric Company P Y Page 4 The MCP allows the Department to establishand enforce reasonable Interim Deadlines consistent with M.G.L. c. 21E in order to establish timeframes for responsible parties to perform response actions at disposal sites for which notification of a release/threat of release was received prior to October 1, 1993 , and for which additional response actions pursuant to the MCP are required after October 1, 1993 . In light of this, you are hereby notified that, at a minimum, the necessary response actions at the subject site must be conducted within the following Interim Deadlines: (1. ) Within -one year of the date of the issuance of this letter, you must either: (A. ) submit to the Department a Response Action Outcome Statement (e.g. , after completion of an Immediate Response Action [IRA] or Release Abatement Measure [RAM] ) for the subject site pursuant. to 310 CMR 40. 1000; or (B. ) classify the subject site as either a Tier I or Tier II disposal site in accordance with 310 CMR 40. 0500. (2. ) Within 30 (Thirty) days of the date of the issuance of this letter, you must notify the Department in writing acknowledging that you have been notified of and understand your obligation to undertake the response actions at the subject site pursuant to the timeframes established herein and in accordance with 310 CMR 40. 0000 . If you fail to voluntarily undertake the response action(s) necessary at the subject site within the Interim Deadline(s) established herein, the Department may perform the such response actions and seek to recover the Department's costs and may initiate other appropriate enforcement actions to ensure that such response actions are conducted. The Department' s decision to establish one or more Interim Deadlines in accordance with 310 CMR 40. 0167 is not subject to M.G.L. c. 30A or any other law governing adjudicatory proceedings. It is important to note that you must dispose of any Remediation Waste generated at the subject location in accordance with 310 CMR 40. 0030 including, without limitation, contaminated soil and/or debris. Any Bill of Lading accompanying such waste must bear the seal and signature of an LSP or, if the response action is performed under the direct supervision of the Department, the signature of an authorized representative of the Department. The Department encourages parties with liabilities under M.G.L. c. 21E to take prompt action in response to releases and threats of release of oil and/or hazardous material. By taking prompt action, you may significantly lower your assessment and cleanup costs and avoid the imposition of, or reduce the amount of; certain permit and annual compliance fees for response actions payable under 310 CMR 4 . 00. Massachusetts Electric Company Page 4 If you have any questions relative to this notice, you should contact Scott Sayers at the letterhead address or (617) 935-2160. All future communications regarding this release must reference the Release Tracking Number (RTN #3-0006003) contained in the subject block of this letter. Very truly yours,, Scott Sayers Environmental Analyst Roger Chu Branch Chief Emergency Response Section RC/SS/ram cc: Division of Response and remediation Board of Health Fire Department Data Entry/File r i k4 ®14- TE-'T A+ EX TEuT of FILL 35 Sia,o T� U �El/GT/ T,eUST 07- I3,8E,t/TCJoo ¢o � ExPnN si opt �`: � A�(/ODUE,e MASS. (b 900 35 45' ..... ...i: 36' DisFosA� DECEit�IBE,� ¢, /97� 9005.F. f000 GAI , tv �ro.SE/'f/ J-cc �/,PBs1l,ALGO AMK 19 1//LL 2QAD Pzo�cnsa � I iUO. .PFs�D/�C/�, �l9SS. h 4 ac-aeM GAP,. bu)EL. 22�• fro' 3Co, E i I oo' r �j - �' c`R9+rij/ �Y!: 'Q- Z: M t 0•110IO Q R.. W YF— o°a�-�-�-��a�� _'_ �-- -� _'c�'�i'�"+f•-t?�l/a.'c'r"L�C'�LAtSt'sL.�.S�iL` 4bSON'T ION uj 7. In 15Co,`7.�, 1 0,•- - li5l, X54-7, Fi�J�Sf� GASJ 155,�� FT G AU.Ot-1 ii log 1Ol • --:17A-NX i I «: d �3.C?o �wA :U sAub op- 4eMa PC)5A � 6��-'"f EEM �" !1�✓�..'IL r�Clc; CvE'��I �CA�A k..w:.iw+*.Y+,.,: Ae&-,4 Pit '*3 APOA= 900 Za --r. AtY AiN r , .( r �q ��rt 1 t p Y r�g t[ , I j �z"•. G��,IG'�t.`� � # 32" :5PtuPrAT'!0!1 - 15 +4 M. M L] k�- •�.+•-..,.wcww:-a.wa+.�a+n.�r,m-w...rKwr+�».�,�.�wx.a..w.u+wea./vin,�+atiwi.�a*..rs+wtoaa-�._�._._,w..w eves�w...nw.� .+mew.wea�e4ss.ee.r....w.o+.:.,._•,.r.�.+rwa�-•�-w- a.. w.s....+ao�.o�r.e'�: TO: NORTH ANDOVER, MASS 19 BOARD OF HEALTH FROM: DESIGN ENGINEER Re: Soil Absorption Sewage System Inspection This is to certify that I have inspected the construction of the said disposal system at Z B , FIV 7`W<3 a D �=�fZ North Andover, Mass. SITE LOCATION The grades and construction are as specified in my plans and specifications dated 19 . N OF A14S � J S H•. G s— f� r A der San arian 1 Nn. 454 o A OF C'/STAR ' F►.��S��NAL SAS°\ . I rv.W6 gr->u Qra r-", j TR V sT I TE. 6 -ib -76 137.4b I COTJ 44,04 ii' Amp i to > t8 1� QST PIT 10 �, � �° �aao G4L ' 1V 41;' 4-FtEOZOOtj Fm qAM i cl cr cc joseph j. barbagallo, r.s. I westward circle no. reading mass. ---� 074 k ti•----- -- -- -- • � ►-�-E � r:lwc r�-=�r -rte s r M-r=- --- -_� ��-- - -- ar M1 u. *P-soil- Gv.--CQ. V' WAS"r-O AFASTIMAD BP,�ie boy l�.gSORPTi� AlLRA E - - - - -- X------- --- ----- --> Li ►211 1AA 5 I tcl o ��y�/ g Si 0 y