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HomeMy WebLinkAboutMiscellaneous - Weston Solutions, Incr-• v-3 se WESTON SOLUTIONS, INC. ri �j r - I Yaf M A fl SOLUTIONS �S W% N T( Or NORTH APJLK, BOi'7D OF HEALTH FEB -9 - 'u n Lj PHASE INITIAL SITE INVESTIGATION REPORT BUILDING 48 AREA MERRIMACK VALLEY WORKS NORTH ANDOVER, MASSACHUSETTS Prepared for: LUCENT TECHNOLOGOIES, INC. 2101 West Chesterfield Blvd. Springfield, Missouri 65807 Prepared by: WESTON SOLUTIONS, INC. One Wall Street Manchester, New Hampshire 03101-1501 February 2004 W.O. No. 11621.039.001 U TABLE OF CONTENTS n Lj Section Page n 1. INTRODUCTION..........................................................................................................1-1 2. GENERAL DISPOSAL SITE INFORMATION [310 CMR 40.0483(1)(a) AND (b)]............................................................................... 2-1 3. DISPOSAL SITE HISTORY 1310 CMR 40.0483(1)(c)] .............................................3 -1 3.1 OWNER/OPERATOR AND OPERATIONS HISTORY ................................... 3-1 3.2 RELEASE HISTORY.......................................................................................... 3-4 3.3 OIL AND/OR HAZARDOUS MATERIAL USE AND STORAGE HISTORY......................................................................................... 3-5 3.4 WASTE MANAGEMENT HISTORY................................................................ 3-5 3.5 ENVIRONMENTAL PERMITS AND COMPLIANCE HISTORY .................. 3-6 4. SUBSURFACE INVESTIGATIONS AND SITE HYDROGEOLOGICAL CHARACTERISTICS [310 CMR 40.0483(1)(d)].......................................................4-1 4.1 PREVIOUS INVESTIGATIONS........................................................................4-1 4.1.1 VHB —Limited Subsurface Investigation ................................................ 4-1 4.1.2 Roux — Preliminary Assessment.............................................................. 4-2 4.2 SITE HYDROGEOLOGIC CONDITIONS........................................................ 4-4 5. NATURE AND EXTENT OF OIL AND/OR HAZARDOUS MATERIAL 1310 CMR 40.0483(1)(e)]...............................................................................................5-1 5.1 INDOOR AIR AND SOIL GAS.......................................................................... 5-1 5.2 SOIL RESULTS.................................................................................................0 5-4 5.3 GROUNDWATER RESULTS............................................................................ 5-4 5.4 PRELIMINARY SITE CONCEPTUAL MODEL.......................0...................... 5-7 I..j 6. MIGRATION PATHWAY AND EXPOSURE POTENTIAL n1310 CMR 40.0483(1)(f]................................................................................................ 6-1 L_, 6.1 AIR....................................................................................................................... 6-1 6.2 SOIL.....................................................................................................................6-1 F) �, 6.3 GROUNDWATER.............................................................................................. 6-1 6.4 SURFACE WATER............................................................................................ 6-2 r...} 7. EVALUATION FOR IMMEDIATE RESPONSE ACTIONS [310 CMR 40.0483(1)(g)]............................................................................................... 7-1 n G:\PROJECTS\11621039\BUILDING_48\PHASE I\TOC.DOC 11 5 FEBRUARY 2004 n G TABLE OF CONTENTS (concluded) Section Page 8. CONCLUSIONS [310 CMR 40.0483(h)]..................................................................... 8-1 9. REFERENCES...............................................................................................................9-1 APPENDIX A 10 SEPTEMBER 2003 RELEASE NOTIFICATION FORM AND 21 OCTOBER 2003 NOTICE OF RESPONSIBILITY LETTER APPENDIX B MASSACHUSETTS DEPARTMENT OF ENVIRONMENTAL PROTECTION/MASSACHUSETTS GEOGRAPHIC INFORMATION SYSTEM SITE SCORING MAP APPENDIX C FLOOR PLAN OF BUILDING 48 APPENDIX D MAP, BORING LOGS, WELL COMPLETION LOG, RELEVANT TEXT SECTIONS FROM THE VHB REPORT, AND A SUMMARY TABLE OF THE LABORATORY RESULTS APPENDIX E SUMMARY TABLES AND MAPS FROM ROUX ASSOCIATES, INC. APPENDIX F SUBSTANTIAL RELEASE MIGRATION EVALUATION BY ROUX ASSOCIATES, INC. G:\PROJECTS\11621039\BUILDING_48\PHASE I\TOC.DOC 111 5 FEBRUARY 2004 n I u n LIST OF FIGURES n` L Title Page Figure 1 Disposal Site Locus Map Building 48 Area................................................................. 2-2 Figure 2 Site Plan Building 48 Area........................................................................................... 2-3 Figure 3 1980 Aerial Photograph Building 48 Area................................................................... 3-3 Figure 4 Concentrations of Chlorinated VOCs Detected in Groundwater July 2003 ................. 4-3 Figure 5 Water Level Elevations and Generalized Groundwater Flow Direction in the ShallowOverburden..................................................................................................... 4-6 LIST OF TABLES Title Page Table 1 Summary of Chemical Storage Areas Building 48, Merrimack Valley Works............ 3-2 Table 2 Indoor Air Sampling Results Building 48, Merrimack Valley Works ......................... 5-1 n Table 3 Volatile Organic Compounds Detected in Groundwater and Soil Vapor Building 48, MerrimackValley Works............................................................................................. 5-2 F) Table 4 Risk Evaluation Exposure Assumptions Building 48, Merrimack Valley Works........ 5-3 u n Table 5 Summary of Soil Analytical Results from VHB Building 48 Area, Merrimack Valley Works............................................................................................. 5-5 n L Table 6 Summary of Groundwater Analytical Results from VHB and Roux Building 48 Area, nMerrimack Valley Works............................................................................................. 5-6 L n; L �I GAPROJECTS\111210391BUILDING_48\PHASE I\TOC.DOC iV 5 FEBRUARY 2004 U LIST OF ACRONYMS CDM Camp Dresser & McKee cis-1,2-DCE cis-1,2-dichloroethene 1, l -DCA 1,.1-dichloroethane 1, l -DCE 1, l -dichloroethene EPH Extractable Petroleum Hydrocarbons ft feet ft2 square feet HI Hazard Indices ILCR Incremental Lifetime Cancer Risks Lucent Lucent Technologies, Inc. MCP Massachusetts Contingency Plan MDEP Massachusetts Department of Environmental Protection MVW Merrimack Valley Works NOR Notice of Responsibility OHM Oil and/or Hazardous Material Ozzy Ozzy Properties, Inc. PCE tetrachloroethene PPA Potentially Productive Aquifer RC Reportable Concentrations RCRA Resource Conservation and Recovery Act RNF Release Notification Form Roux Roux Associates, Inc. RTNs Release Tracking Numbers SRM Substantial Release Migration 1,1,1 -TCA 1,1,1 -trichloroethane TCE trichloroethene trans-1,2-DCE trans-1,2-dichloroethene USGS U.S. Geological Survey's UST underground storage tank VHB Vanasse Hangen Brustlin, Inc. VOCs volatile organic compounds WESTON® Weston Solutions, Inc. G:\PROJECTS\11621039\BUILDING_48\PHASE I\LIST OF ACRONYMS.DOC V 5 FEBRUARY 2004 SECTION 1 INTRODUCTION 1. INTRODUCTION Weston Solutions, Inc. (WESTON®) has prepared this Phase I — Initial Site Investigation Report on behalf of Lucent Technologies, Inc. (Lucent) for the Building 48 area of the Merrimack Valley Works (MVW) in North Andover, Massachusetts. The MVW is located at 1600 Osgood Street in North Andover and was formerly owned by Lucent. The current owner of the MVW is 1600 Osgood Street, LLC, a wholly-owned subsidiary of Ozzy Properties, Inc. (Ozzy). The MVW is a confirmed Disposal Site, where investigation and remedial activities have been conducted site -wide since 1986 under Release Tracking Numbers (RTNs) 3-0174 and 3-21863. This Phase I — Initial Site Investigation Report; however, pertains only to that limited portion of the MVW known as Building 48, as well as its immediately -surrounding area, where a 120 -day reportable condition not associated with either of the other two RTNs was identified in May 2003. Specifically, during due diligence activities conducted in anticipation of a potential sale of the MVW, several volatile organic compounds (VOCs) were detected in groundwater adjacent to Building 48 at concentrations that exceeded their applicable Massachusetts Contingency Plan (MCP) Reportable Concentrations (RC) for groundwater. Consequently, Lucent submitted a Release Notification Form (RNF) to the Massachusetts Department of Environmental Protection (MDEP) on 10 September 2003 to report this release pursuant to MCP 310 CMR 40.0315. In response to the RNF, the MDEP assigned RTN 3-23204 to the release, as indicated in a 21 October 2003 Notice of Responsibility (NOR) sent to Lucent. Copies of the 10 September 2003 RNF and the 21 October 2003 NOR are presented in Appendix A. This Phase I — Initial Site Investigation Report has been prepared in accordance with the requirements and format set forth in the MCP at 310 CMR 40.0480. Accordingly, the remainder of this Phase I — Initial Site Investigation Report is divided into the following sections: ■ Section 2: General Disposal Site Information ■ Section 3: Disposal Site History ■ Section 4: Subsurface Investigations and Site Hydrogeological Characteristics ■ Section 5: Nature and Extent of Oil and/or Hazardous Material ■ Section 6: Migration Pathways and Exposure Potential ■ Section 7: Evaluation for Immediate Response Actions ■ Section 8: Conclusions ■ Section 9: References G:\PROJECTS\11621039\BUILDING_48\PHASE I\PHASELDOC 1-1 6 FEBRUARY 2004 L SECTION 2 GENERAL DISPOSAL SITE INFORMATION [310 CMR 40.0483(1)(a) AND (b)] n it u F1 2. GENERAL DISPOSAL SITE INFORMATION n [310 CMR 40.0483(1)(a) AND (b)] Li As stated in the previous section, the Disposal Site that is the subject of this report n� (RTN 3-23204) is located within Lucent's MVW at 1600 Osgood Street in North Andover, U Massachusetts. The latitude and longitude of the approximate center of the Disposal Site are n „ LJ 42043'57" North and 71007'13" West, respectively, and the Universal Transverse Mercator coordinates for the center of the Disposal Site are North — 4733063 and East — 0326523. A Disposal Site Locus Map, showing a 500 -foot and %2 -mile radii from the approximate boundaries of the Disposal Site, is provided in Figure 1. The location of the Disposal Site in relation to the rest of the MVW is shown in Figure 2. Building 48 is currently unoccupied, although the adjacent Building 49 is used on a limited basis by Lucent for the storage of wastes. The Disposal Site is located near the northwest corner of the 168 -acre Lucent MVW (Figure 2). Land use surrounding the Disposal Site is industrial. Beyond the MVW lie mainly industrial and u commercial properties, although a few residential properties are also present near the far n northeastern corner of the facility, more than 2,500 feet (ft) from the Disposal Site. Other I I� residential properties exist within %2 mile of the Disposal Site, but most are located on the opposite side of the Merrimack River (see Figure 1). Based on the U.S. Geological Survey's u (USGS) Topographic Map for the Lawrence, Massachusetts Quadrangle (USGS, 1987) and Ell observations of the area around the MVW, it has been estimated that approximately 500 people live within a %2 -mile radius of the Disposal Site. There are no Institutions (as defined in the u MCP) within 500 ft of the Disposal Site. ,n A small, unnamed intermittent stream is located approximately 100 ft northwest of the Disposal Site. The unnamed stream flows northward and discharges to the Merrimack River, which is located approximately 450 ft from the Disposal Site. In addition, a Potentially `J Productive Aquifer (PPA) is located less than 100 ft east of the Disposal Site; however, the nearby portion of the PPA is classified as a Non -Potential Drinking Water Source Area due to the overlying industrial land use (Appendix B). Other portions of the PPA are not considered W; ONE G:\PROJECTS\11621039\BUILDING_48\PHASE I\PHASELDOC 2-1 6 FEBRUARY 2004 LJ u -; ... ., t 1 l � [,/ ` 11 I� t J/,fl fl • :" , j/r ""'�::1 �`' � J^'' • ; t'� -----� r :. } �^ { ^�,\ ,,l• ! �.l • -, x.'11 i. t � • . ; • � �\ '�',''� � +pyo C +� '�� ,w'� r ;° �; `.,% 7. w "`666 • jy� `1I yy 4 i ••Y �r ! • i• Vit\ • ��' ��/ �ij •'�� A ' i ``•\ I. �.:;-�`A�\�_�,~ ' � `� .' - 4 111 L Aral t • �� f. �!, / t \ \` i l ✓Vii.'; 1 ,; \ ,� v� 7 r ^' A1IVR;E UIrvCPAL' r NOTE: GRAPHIC SCALE MAP FROM DELORME XMAP 4.0 SOFTWARE - 1400 700 0 700 1400 MASSACHUSETTS, CONNECTICUT, & RHODE ISLAND TOPOQUAD CD APPROXIMATE SCALE IN FEET DISPOSAL SITE LOCUS MAP BUILDING 48 AREA MANCHESTER • NEW HAMPSHIRE MERRIMACK VALLEY WORKS DRAWN DATE DES. ENG. DATE W.O. NO. LUCENT TECHNOLOGIES A.J.M. DEC. 2003 11621.039.001 NORTH ANDOVER, MA. CHECKED DATE APPROVED DATE FIGURE NO. J.J.S. DEC. 2003 1 0 N G) O O v G7 m m M\Design�D-)LUGEt�JLDING 4tl\JASE 1�rYl 1 AND�:.191, FIG 2, 14/2004`3:1 :49 PM, murrot, V_j � � � � ED v c v z G) N D A 2s z G7 D 8. r c 0 m co Z c v m z 0 0 I w Z O 0 r- 0 0 G7 m N 4 c M X v C- cn D ; D � r o in Z 0 Zmr. gzD Z 2 fes/! o U mo $ =1> rZ rn'v N Z +n m m--lT` Z7< -D O;Ui OW C7 -u -o, =D a � N 0 r D y Z r Nom on o w DZ y0 �� -� -n MO X C-)G)o K gm D V) m N M DN N m z o N 0-v = � yv -0oD i r- K:* ZNO X IM Fol CD �v C) ca 5c 0 0 v z c� v y z G) D rn� D v a c F v z G) V O N DC Z ; �m wo c� v 8 ry p Ln r c� y vm Ln D (n 1-10 D Wa) 2N .P0 z zM �v Q �� -0 > D v rn m D vZ vv v ;o v W M,(D C-4 v d ❑ — -� Val N Zr D 2� W Z D O N U mo $ =1> rZ 3 �<ND �0 -D O;Ui Sc> v �mr-<_X a � co -n 0 Z �i on MM K^v �� -� -n MO D �D KCS K gm 0m DN 0-v 8 yv -0oD u m co r- K:* ZNO IM v Fol CD �v C) ca 5c 0 0 v z c� v y z G) D rn� D v a c F v z G) V O N DC Z ; �m wo c� v 8 ry p Ln r c� y vm Ln D (n 1-10 D Wa) 2N .P0 z zM �v Q �� -0 > D v rn m D vZ vv v ;o v W M,(D C-4 v d ❑ — -� Val 9 Lj Non -Potential Drinking Water Source Areas, as they are overlain by open space. Only Non -Potential Drinking Water Source Areas are located within 500 ft of the Disposal Site. A k copy of the MDEP/Massachusetts Geographic Information System Site Scoring Map for the to n Disposal Site, showing the location of the PPA and the Merrimack River is provided in I I Appendix B. n G G:\PROJECTS\11621039\BUILDING_48\PHASE I\PHASELDOC 2-4 6 FEBRUARY 2004 1 SECTION 3 DISPOSAL SITE HISTORY [310 CMR 40.0483(1)(c)] n u L► 3. DISPOSAL SITE HISTORY [310 CMR 40.0483(1)(c)] 3.1 OWNER/OPERATOR AND OPERATIONS HISTORY The Disposal Site and the entire MVW are currently owned by 1600 Osgood Street, LLC, a wholly-owned subsidiary of Ozzy, which purchased the facility from Lucent in September 2003. L Lucent retained environmental responsibility for the property and is the Responsible Party under the MCP. The facility had been owned and operated by Lucent and its corporate predecessors (e.g., AT&T, Western Electric Co.) since 1953, when construction of the MVW on farmland and undeveloped woodlands was initiated [Camp Dresser & McKee (CDM), 2003]. u As shown in Figure 2, the Disposal Site comprises two separate buildings (Buildings 48 and 49) L and the surrounding open areas. Building 48 is a single -story, high -bay building of cinder -block construction with a metal roof. The foundation is standard concrete slab on grade. According to engineering drawings provided by Lucent, the building was initially constructed in 1986 and occupied approximately 7,000 square feet (ft). A 5,000 ft2 extension was added onto the north fn side of the building in 1987, increasing the total area of the building to approximately 12,000 ft2. i.a A single loading dock is located at the south end of the building. Building 48 is currently unoccupied, but had historically been used for the storage of chemicals n purchased in less -than -bulk quantities (e.g., in drums). The interior of the building had been Li divided up into distinct rooms to segregate the various chemicals based on their physical n properties. Each room was completed with a 12 -inch -high poured concrete containment wall on v all sides. There were no penetrations of the concrete floor or containment walls within any of the r materials storage rooms. The floor plan of Building 48 (including the expansion) is shown on a u construction plan dated October 1987 provided in Appendix C. The various chemical storage r rooms and their approximate sizes are summarized in Table 1. In approximately 1994, the concrete containment walls were removed from the doorways to facilitate convenient foot traffic, and Building 48 was converted into an assembly area for telecommunications equipment. According to Lucent representatives, no hazardous materials or chemicals have been used in Building 48 since 1994 (Makovitch, 2003). n U G:\PROJECTS\11621039\BUILDING_48\PHASE I\PHASEI.DOC 3-1 6 FEBRUARY 2004 C Table 1 Summary of Chemical Storage Areas Building 48, Merrimack Valley Works Storage Area Approximate Area in Square Feet (ft) Halogenated Compounds 1,300 ft2 Inorganics 200 ft2 Oxidizers 200 ft2 Poisons 200 ft2 Acids 1,400 ft2 Caustics 1,400 ft2 Combustibles 1,200 ft2 Flammables 1,800 ft2 Dispensing Area 300 ft2 Staging Area 1,000 ft2 Office, hallways, bathrooms, and utility rooms 3,000 ft2 Total Building 48 12,000 ft2 Building 49 is a single -story structure of steel beam construction with a metal roof. The foundation is standard concrete slab on grade. The southern half of the building is an open pole -barn, but the northern half has concrete -block walls and is finished as office space. The office space is currently unoccupied. Based on engineering drawings provided by Lucent, the building was initially constructed in 1986 along with Building 48 and occupies approximately 7,000 ft2. Building 49 has always been used for the short-term storage of hazardous waste prior to removal for off-site disposal. The concrete slab floor of Building 49 is completely surrounded by a poured concrete containment wall several feet high. A series of three floor drains collect runoff from spills and direct them to a concrete holding tank. Other than the three floor drains, there are no other penetrations of the concrete slab or the containment wall and all concrete was observed to be in excellent condition with no cracks, staining, or spalling noted. Prior to the construction of Buildings 48 and 49, the area had been used as an interim storage area for drums containing waste solvents. This area was commonly referred to by facility personnel as the `Barrel Pad" (CDM, 1986). A 1980 aerial photograph of the area is presented as Figure 3 and clearly shows the presence of a large number of drums stored on a paved area. G:\PROJECTS\11621039\BUILDING_48\PHASE I\PHASELDOC 3-2 6 FEBRUARY 2004 r CInterviews with Lucent employees have indicated that although the Barrel Pad was paved with asphalt concrete, there were no berms, curbs, or other containment structures, consistent with construction practices and regulations at the time the former Barrel Pad area was constructed and nn operated. f+ `-' An underground storage tank (UST) containing waste solvents was formerly located to the south of Building 48 (see Figure 2). Based on North Andover Fire Department records, the waste flammable tank was a 3,000 -gallon steel tank that was installed in 1971. Although discussions r with Lucent representatives indicated that the waste flammable tank was removed in the mid-1980s, coincident with the removal of other storage tanks at the facility, and that no "significant" soil or groundwater contamination was noted at that time, no written record of the tank removal could be located [Vanasse Hangen Brustlin, Inc. (VHB), 2003a; Makovitch, 2003]. 3.2 RELEASE HISTORY It is believed, based on data collected to date, that one or more releases had occurred which impacted environmental media at the Disposal Site. The condition that resulted in the issuance of RTN 3-23204 was first detected in May 2003, during due diligence activities conducted by VHB at the Disposal Site in anticipation of a potential sale of the MVW. During these activities, tetrachloroethene (PCE), trichloroethene (TCE), and 1,1,1 -trichloroethane (1,1,1 -TCA) were detected in groundwater from monitoring well VHB-MW-4 at concentrations exceeding their respective MCP RC in RCGW-2 groundwater. U Subsequent soil and groundwater sampling at the Disposal Site by Roux Associates, Inc. (Roux) has confirmed the presence of the three compounds at concentrations exceeding applicable RCs ti U as well as the presence of other constituents, some of which also exceeded applicable RCs. The magnitude and distribution of these constituents is being addressed under RTN 3-23204, and are discussed in Section 5 of this report. The exact source(s) of the constituents released at the Disposal Site is not clear, although these constituents were most likely released from the former waste flammable tank, or from the former Barrel Pad. Compounds such as those found in the groundwater are known to have been stored in the waste flammable tank and at the former Barrel Pad (CDM, 2003). G:\PROJECTS\11621039\BUILDING_48\PHASE I\PHASELDOC 3-4 6 FEBRUARY 2004 1 i V . J 3.3 OIL AND/OR HAZARDOUS MATERIAL USE AND STORAGE HISTORY Extensive manufacturing of telecommunications equipment (including extensive plating operations) historically took place at the MVW. Given the historical use of the Disposal Site for the storage of raw materials and waste products from this manufacturing process, it is likely that a wide variety of Oil and/or Hazardous Material (OHM) were present at one time or another. , Existing facility documentation (e.g., CDM, 2003) indicates that OHM used historically in the r + manufacturing operations includes ammonia, sodium hypochlorite, sodium hydroxide, caustic soda, isopropyl alcohol, solder, solder paste and flux, copper, cyanide, chromium, lead, various r acids, and solvents such as PCE, TCE, 1,1,1 -TCA, toluene, acetone, varsol, and methylene chloride. Dates of use and/or quantities used for OHM are not available; however, it is likely that , these OHMs were stored at the Disposal Site from the 1950s through the 1990s when extensive manufacturing at the MVW ceased. Chlorinated solvent usage at the MVW was phased out in 1992 (Makovitch, 2003). , N 3.4 WASTE MANAGEMENT HISTORY No wastes are currently generated or stored at Building 48. Building 49 is still used for the r ` storage of small quantities of waste materials prior to off-site disposal. These wastes include b solder, flux, cleaners, and isopropyl alcohol. r " Historically, Building 49 was used to store various quantities of hazardous waste materials from r , manufacturing processes in other parts of the MVW. No records are available with regard to the exact types and/or quantities of materials stored at Building 49, but it can be assumed that the wastes would have included spent solvents, solder, flux, and cleaners. Prior to construction of Building 49, these same waste materials were presumable stored in the former Barrel Pad, likely r 1 in approximately the same quantities. The other waste streams generated by manufacturing activities at the MVW including acid/alkali, cyanide, ammonia, chromium, and copper solutions were treated at the facility's wastewater treatment plant. W. The waste flammable tank was reportedly used to store larger volumes of used solvents prior to off-site disposal. The spent solvents were not segregated in any way prior to disposal and likely rti G:\PROJECTS\11621039\BUILDING-48\PHASE I\PHASELDOC 3-5 6 FEBRUARY 2004 4 C Cincluded PCE, TCE, 1,1,1 -TCA, varsol, toluene, methylene chloride, and acetone, all of which were know to have been used at the MVW. 3.5 ENVIRONMENTAL PERMITS AND COMPLIANCE HISTORY No permits have been issued specifically for the Disposal Site or for current on-site facilities (i.e., within the Disposal Site), other than a permit for connection to the Greater Lawrence Sanitary District (No. W008811). However, several facility -wide permits applied to activities historically conducted at the Disposal Site (Makovitch, 2003): Wastewater generated at the MVW was historically discharged to the u Merrimack River after treatment at the facility's wastewater treatment plant. This discharge was conducted in accordance with joint National Pollution Discharge Elimination System permit MA0001261 (federal)/352 (state). U ■ According to facility personnel, Lucent once maintained a Resource Conservation and Recovery Act (RCRA) treatment, storage, and disposal facility permit for the MVW; however, this permit was rescinded at Lucent's request sometime in the late 1980s or early 1990s when Lucent became aware that it did not need the permit. I� Hazardous waste formerly generated at the MVW was managed in accordance with the facility's RCRA Large Quantity Generator Permit (U.S. Environmental Protection n Agency ID# MAD001005370). ``J ■ Discharges of airstreams from the MVW were permitted under the facility's Major CPA (MBR -95 -IND -028), which was recently rescinded at Lucent's request. L Prior to obtaining the Major CPA, Lucent and its predecessors maintained permits for several individual carbon absorbers. A separate air discharge permit is maintained for rZ the Building 51 Groundwater Treatment System (MBR -89 -IND -268). ■ Air discharges from the boilers that are used to heat the facility are operated under MDEP Permit: NOx RACT ECP No.MBR-94-COM-052. ■ Storage of virgin and waste solvents in storage tanks was permitted under the facility's permit with the local fire department (ID # 09210). ■ Two Tier I permits have been issued for the site by MDEP under the MCP. The Tier I Permit for RTNs 3-0174 was first issued in November 1986 and several extensions have since been issued. This Disposal Site is currently in Phase V under the MCP. The Tier I permit for RTN 3-21863 was issued in June 2003. This Disposal Site is currently in Phase II under the MCP. No Notice of Violations has been issued for either of these sites by MDEP. G:\PROJECTS\11621039\BUILDING_48\PHASE I\PHASEIAOC 3-6 6 FEBRUARY 2004 r I.J ■ A Groundwater Withdrawal Permit was issued by the MDEP for three groundwater production wells located at the northeast corner of the MVW used to supply process water to the facility (Groundwater Withdrawal Permit No. 9P-3-13-210.01). Two of the three production wells have been decommissioned. The third well still exists but is no longer being used. ■ Lucent also maintains a permit from the Town of North Andover for solid waste dumpsters (Dumpster Permit No. 244-2D) and from the MDEP for recycling of solder (Recycling Permit No. W016580). G:\PROJECTS\11621039\BUILDING 48\PHASE I\PHASELDOC 3-7 6 FEBRUARY 2004 1-' SECTION 4 SUBSURFACE INVESTIGATIONS AND SITE HYDROGEOLOGICAL CHARACTERISTICS [310 CMR 40.0483(1)(d)] 4. SUBSURFACE INVESTIGATIONS AND SITE HYDROGEOLOGICAL CHARACTERISTICS [310 CMR 40.0483(1)(d)] As part of subsurface investigations conducted in response to the Lucent's "site -wide" RTN (3-0174) and other site investigation activities, 87 monitoring wells have been installed at the MVW from 1986 through the present. Several of the monitoring wells installed in the 1980s are located in the vicinity of the Disposal Site and were sampled as part of Disposal Site investigations. These monitoring wells include: MW -5S, MW -5D, MW -6S, MW -6D, MW -10S, and MW -1 OD. Wells with the suffix "S" are wells located in the shallow overburden, while wells with the suffix "D" are located in the deep overburden. Copies of boring logs and monitoring well completion reports for these wells have previously been submitted to MDEP by CDM within the Phase I and Phase II reports for RTN 3-0174. 4.1 PREVIOUS INVESTIGATIONS 4.1.1 VHB — Limited Subsurface Investigation In May 2003, VHB drilled a number of soil borings and installed several groundwater monitoring wells at the MVW in support of a property transfer investigation performed for Ozzy (VHB, 2003b). As part of this investigation, VHB advanced four direct -push soil borings (1312-1 through B12-4) in the vicinity of the former waste flammable tank just south of Building 48, and another five soil borings (B 16-1 through B 16-4) in the vicinity of the former Barrel Pad. Continuous soil sampling was performed to depths of 10 to 25 ft in each of the nine borings. All samples were screened in the field for VOCs using a photo -ionization detector. Selected samples were submitted to an analytical laboratory for testing based on the results of the headspace screening and visual characteristics. Laboratory testing of the soil samples included cyanide, ammonia, VOCs, metals, and Extractable Petroleum Hydrocarbons (EPH). A map showing the locations of the soil borings, boring logs, relevant text sections from the VHB report, and a summary table of the laboratory results are presented in Appendix D. In addition to the soil sampling, VHB installed, developed and sampled one shallow groundwater monitoring well (VHB-MW-4) in the vicinity of the waste flammable tank. The groundwater G:\PROJECTS\11621039\BUILDING_48\PHASE I\PHASELDOC 4-1 6 FEBRUARY 2004 91 I M sample was analyzed for various forms of cyanide, metals, VOCs, EPH, and volatile petroleum ; , hydrocarbons. A map showing the locations of the monitoring well, well completion log, relevant text sections from the VHB report, and a summary table of the laboratory results are - presented in Appendix D. The results of the analytical testing of the groundwater sample from VHB-MW-4 indicated that concentrations of PCE, TCE, and 1,1,1-TCE all exceeded the MCP RCGW-2 RC. This was the initial data that resulted in the reporting of this Disposal Site to MDEP. 4.1.2 Roux — Preliminary Assessment I, , W As a follow-up to the VHB investigation, Roux performed additional investigations in the ,1 Building 48 area to evaluate the potential for a Substantial Release Migration (SRM) condition to exist (Roux, 2003). As part of the investigation, Roux installed an additional five groundwater monitoring wells and sampled the new wells plus seven existing monitoring wells including VHB-MW-4. Roux also collected soil gas from beneath the slab and an indoor air sample at Building 48. No indoor air sampling was performed in Building 49. L1 The results of the groundwater sampling confirmed the findings by VHB that an area of groundwater containing various solvents at concentrations exceeding the MCP RCGW-2 RC exists in the vicinity of Building 48. The estimated area of groundwater exceeding the MCP RCGW-2 standards is shown on Figure 4, along with the concentrations observed in each monitoring well. The plume appears to originate in the vicinity of the waste solvent tank. The , groundwater contamination appears to be confined to the shallow portion of the saturated zone based on laboratory groundwater quality results from MW -63D, which is a deep overburden well installed adjacent to VHB-MW-4. Field headspace screening of soil samples collected during the drilling of MW -63D suggest that the contamination is limited to the upper 25 to 30 ft of the � J overburden. Groundwater elevation data from MW -63D and VHB-MW-4 indicates that there is an upward hydraulic gradient, which would tend to retard the downward migration of dissolved contaminants. Roux used the observed concentrations of contaminants in groundwater to calculate the potential impacts to nearby surface water bodies (Merrimack River) as part of a SRM Evaluation. G:\PROJECTS\11621039\BUILDING-48\PHASE I\PHASELDOC 4-2 6 FEBRUARY 2004 M:\Design�DWG�LUCENT BUILDING 48 E ASE 1�♦ HU�O.dwg,�ut1, 2/4 004 2:41:09 PM, m� t, 1:1 n D ; z �m v n = rn m C— D z < L c0 O N 00 �rm � � r -,MM 6z> o Df rn' Z Z D G) r m�T� _N < w N 002 = r o o O Nzpm J 0 D ;u 0 Dr--< n 0* Z7 D O NNN m :3D rn m = N z z o W = � M C - i C ; 1-. _ ; r i L )C -- i [--i C=Z I- w s L' _; C I L i - —J C __ � L � E- � 1 C C � M:\Design\DWG\LUCENT\BUILDING 48\PHASE 1 FIG 4.dwg, FIG 4, 2/4/2004 3:16:44 PM, murrot, 1:1 w O 0 0 C/) z�m Om 0m o TC -4 F0 ZM Zr D N 000oo z CC) CD F— Fn o��� m �o v z M lo ;o,n r v r Co rrz rr C z v O Z p n zm O tng z r.I � r �� �� N 0 n ® o D fT1 �.� D �� �N G7 zr fel D f Tl f Tl �'� cn z z m0 o Z /I� /I�'� Ni M>8 N K c� Z G�<(� * I D Iv I I j v D Ooz D o 0 f nn I mm � cn Cw 0 r� II � U): m w Ki rnDn ^' � 0 D D Ft II CZ_m ; I v �I D Iv O0DZ� �'rn0N N vc-PO1ODto Q)N2� D m O -I D v 5 w W I v Z v I O Z O m� D r �� I ZZZ vZZ ICS v Z m m �(<jnnn UI N O Z (� t� m m / i i v p vvl <v�� .. C mDD .N I i jn�mm CD t, •N 10 F— cn 00 G�N2 C7 (A zN. m `LDS N ovovo °' �''v� I vl �� <-I nn m O O$ cn INN00000�o^�' t0 o O O ZVOi� mDD C10 -) cn v v rn � z m 101, II II II II II II II Svc Zc�,�r� ppr ���zm — O -� I I rvN gg 1 r-.- rD MM 00\ \ �n o vn rrn?pO� \ \ �rn oo=Oc�MV cv mm0vr-mm N r- 0m>Mr^Mzomm XN MMD m N p Z rn M v rn \ oOz o�� r D < A ocnn n �v \� Iv Iv'i jmm pN rn y 0Dc�i N 0* D o r- O m to vNN \� « ��M D _\�1 vvvvvvv ZZvn Z\� Ove D O (Onv N \� (n E5 m "AO rn rn O v n v rn a ; O m Z = N lz m O (� m N zip Z= -I> ZO D0 CmMm(n !/ in � � .Z7 ; $ - > M D m rZ <<v_iD �. fTl O D(7� to O Om�v X M C: � O Z D � �� � M r� C _ < Dov r �z s � O0 �Zrn I n G7K3 M �l - 0D 00 mm w N ��7C) >Z� • 0 �� 'ro�� 5; co MOO 0 o ODr N0Om z > r"D KCK o L"' Cr1 Z O D�� �rn �M zmn Z C(n; • Oar DNS D m N 0y zoo v z g M 0 C7 D m m N� > -p 0:* o O > z co Z N 67 C) v lv m mm I Iv Iv'i vv.j � N rnDn I W D I D I D Iv I « n ov�ovo� `p0 O S m O co p oWw J J J<\ I �l V\ I nNmmO vv.j � v v j � 'o mDc�i "K) c D I D Iv v n N m zzzzzzz co p oWw c� O O N O 0 0 � 00 DOO N (T CT CT �+ U1 N 000000UiO 00000001 0000000 000000 �' �nnn �nNmm vv.j � Dal i I man I" ; D I m rn � I N m zzzzzzz vvvvvvv rn gcn �nnn �nNmm vv.j :. N m m vvl i I 008 N � D I m o � I N W O O �� N m ZZ Z'-+C�NZ �nnn �nNmm vv.j I I .. I v v I i I r0*1DD N � v I m v � I o N m ZZ Z'-+C�NZ vvvvcn v rn gcn �nnn Nmm Ivlvj vv.j jmm v i I m mDD N � ao $$ov000 m v � I t0 m rn vzcoz vcnv rn gcn vvvvvvv �nnn Nmm Ivlvj mDD .N v i I m � 0 rn v � ao $$ov000 m � C1 Iv Iv.l mDD .N v i I m � C1 t0 m zz�zz� vvwvv�^' IIS Imm m D n N � D v � C1 I m Ln v zzzzzzz vvvvvvv n LJ n F L.1 Based on very conservative assumptions regarding groundwater flow conditions and fate and transport parameters, Roux concluded that there is no risk to the Merrimack River from the contamination at Building 48 and that a SRM condition does not exist at the Disposal Site. The soil gas and indoor air results indicated that VOCs are migrating from the groundwater through the soil gas and into Building 48. Roux performed a limited risk evaluation and concluded that the observed concentrations in indoor air did not represent an Imminent Hazard, even if the building were to be occupied. In any event, because Building 48 is currently unoccupied, there is no human health exposure at this time. A complete description of the work performed by Roux is contained in their 28 July 2003 Preliminary Assessment — Building 48 Area Letter Report, which was provided to MDEP along with the initial NOR. Summary tables presenting the data collected by Roux and maps showing the locations of the samples are included in Appendix E. 4.2 SITE HYDROGEOLOGIC CONDITIONS Based on the USGS Lawrence, Massachusetts topographic map (see Figure 1), the Disposal Site is located in a relatively flat area at an elevation of approximately 49 ft above National Geodetic Vertical Datum. Portions of the Disposal Site are covered by asphalt roadways or buildings with an approximate 6 -inch concrete floor. The remaining portions are landscaped or undeveloped areas. Based on soil boring and monitoring well logs provided by Roux and VHB, the soil underlying the Disposal Area consists of fine to coarse-grained sand and silt. Weathered bedrock was encountered below the sand and silt overburden at a depth of approximately 78 ft at monitoring well MW -63D. Based upon previous groundwater investigations completed at the facility, there are three groundwater zones at the Disposal Site. The first is overburden groundwater contained within the interspersed layers of sand and silt. Below the overburden groundwater zone is the bedrock groundwater zone. Previous investigations performed at the facility have identified a buried channel of sand and gravel deposits within the overburden groundwater zone. This buried channel feature is located far to the east of the Disposal Site and is not considered a factor in this G:\PROJECTS\11621039\BUILDING_48\PHASE 1\PHASELDOC 4-4 6 FEBRUARY 2004 E investigation. Previous groundwater investigations have concluded that there is hydraulic communication between the various groundwater zones at the facility. Groundwater exists within the overburden at the site under unconfined conditions. Water level data collected on 10 July 2003 indicated that groundwater is present at a depth ranging from 14 to 23 ft below grade. The general groundwater flow direction is to the north-northwest, toward the Merrimack River. Figure 5 is a groundwater contour map prepared by Roux as part of their Preliminary Investigation. A comparison of water levels in VHB-MW-4 and MW -63D (a shallow and deep overburden monitoring well cluster located near the presumed source area), indicates a strong upward vertical hydraulic gradient is present within the overburden. Water level data from other nearby monitoring well couplets (MW-5S/D, MW-6S/D, and MW-IOS/D) also show a strong upward vertical gradient. Studies performed at other areas of the MVW indicate an upward gradient within the overburden, as well as from the underlying bedrock up into the overburden. All of these observations are consistent with the regional groundwater flow regime, as groundwater moves upward as it discharges to the Merrimack River, which is the regional groundwater discharge point. G:\PROJECTS\11621039\BUILDING 48\PHASE I\PHASELDOC 4-5 6 FEBRUARY 2004 C- L-3 L-.3 L -j L---] C-7 L -3i M:\Design\DWG\LUCENT\BUILDING 48\ HASE 1\hIG 2 AND 5.dwg, FIG 5, 2/4/2004 3:18:42 PM, murrot, 1:1 01 I ON ■ i N r m m -<0 m D Z m D2�Wm ZDP>m r*i o n DD 'vim comm ACo r ° -- Z mAZ r M v m II AZz G7 ..mr- M 0 D -<Z m fT1 Z C) O r * Z mm0 O� mzm C 0 D <ZiN D m; > �zZ C OZD � m r^zo 0-9 0 m v 2:* oz r m m m r o gm m 0 �*(n o N p 0 D m ° z W�r- °30 AD* (0 —I y =mo z Z me O <mz <(n m Zv m m D ■ i N -" Z zr O D2�Wm ZDP>m n DD 'vim comm ;0[ D my ;u C- -<<ND �O NOm �m 0 o K -u m (gym OD ..mr- M 0 oz -<Z m DKa0 rn m K, N r mm m mO O Dw f r� m; > 2 0 < m m 0m >N N° m 0-9 0 D 0 -v 0 D Nz W n vi cZi m 0 m % 0 55 m Cf) .� s m D �M m Gi z K N A C- > �M> Z o z _>M z A m z N r mm c� Z0 f o o > 2 0 < m m oZD o�0 N° m r V) � < �M< W n =0r r C my �D Z r o N p 0 D D cN/>o-< 0 (0 —I y =mo O <mz <(n CNx c m V)m m CO rl Z (J1 o C O 0 m z A m zK 01 N q� 0 co �� OZ 40 40) I 4 � N N I W F- N � O L4 1 ON i m �V1 Cn r— 8 M 0 0 M M _ 8 00 F n Z r, Sm g m Cf) .� m D �M z K N mD m m z oo �D z SECTION 5 NATURE AND EXTENT OF OIL AND/OR HAZARDOUS MATERIAL [310 CMR 40.0483(1)(e)] N n Li n Li F1 Li F-1 Li n r� i� 5. NATURE AND EXTENT OF OIL AND/OR HAZARDOUS MATERIAL [310 CMR 40.0483(1)(e)] This section provides information on the nature and extent of contamination as determined by this Phase I — Initial Site Investigation. Separate discussions are provided in the subsections that follow regarding the nature and extent of contamination that has been identified in indoor air and soil gas (Subsection 5.1); soil (Subsection 5.2) and groundwater (Subsection 5.3). A Preliminary Conceptual Site Model is provided as Subsection 5.4. 5.1 INDOOR AIR AND SOIL GAS Roux collected one soil gas sample from beneath Building 48 and one indoor air sample from within the building. The results of the indoor air sample are presented in Table 2. Table 2 Indoor Air Sampling Results Building 48, Merrimack Valley Works VOCs Detected Within Indoor Air of Building 48 (Sample B-3) Compound Detected Concentration (pg/m3) Concentration (ppbv) 1,1,1 -TCA 17.9 3.29 2-butanone 2.63 0.891 Acetone 27.3 11.5 Chloromethane 1.46 0.706 ethyl alcohol 33.4 17.7 isopropyl alcohol 7.42 3.02 methylene chloride 8.38 2.41 para/meta-xylene 3.38 0.780 PCE 16.6 2.45 Toluene 4.90 1.30 TCE 32.6 6.07 Trichlorofluoromethane 3.00 0.535 Notes: pg/m3 = microgram per cubic meter ppbv = parts per billion by volume G:\PROJECTS\11621039\BUILDING_48\PHASE I\PHASELDOC 5-1 6 FEBRUARY 2004 All 12 of these VOCs were also detected in soil vapor beneath Building 48, with only one — methylene chloride — detected at a higher concentration in indoor air. This suggests a subsurface source (e.g., groundwater) for most of these VOCs, rather than an indoor source (e.g., residual effects from the historical storage of chemicals in this building). In addition to the 12 VOCs detected in both indoor air and soil vapor, there were 16 additional VOCs detected in the soil vapor sample that were not detected in the indoor air sample. These additional VOCs include both chlorinated VOCs [such as 1, 1 -dichloroethane (1,1 -DCA), cis- and trans -1,2- dichloroethene (cis- and trans-1,2-DCE), and vinyl chloride] and non -chlorinated VOCs (such as benzene and methyl tertiary butyl ether). As indicated in Table 3, the majority of the VOCs detected in the soil vapor sample were not detected in groundwater from the waste flammable tank area south of Building 48, suggesting that these compounds may be related to the former Barrel Pad. Table 3 Volatile Organic Compounds Detected in Groundwater and Soil Vapor Building 48, Merrimack Valley Works Groundwater (VHB-MW-4) Soil Vapor (B-3/SG) 1, 1 -dichloroethene Acetone Isopropyl alcohol cis-1,2-dichloroethene Benzene Methylene chloride Ethylbenzene 2-butanone Methyl tert butyl ether Tetrachloroethene Chloroethane Propylene Toluene Chloroform Tetrachloroethene 1,1,1 -trichloroethane Chloromethane Toluene Trichloroethene Cyclohexane 1,1,1 -trichloroethane m/p-xylene 1, 1 -dichloroethane Trichloroethene o -xylene 1, 1 -dichloroethene trichlorofluoromethane cis-1,2-dichloroethene 1, 1,2-trichloro- 1,2,2-trifluoroethane trans-1,2-dichloroethene 1,2,4-trimethylbenzene Ethyl alcohol Vinyl chloride Ethylbenzene m/p-xylene n -hexane o -xylene G:\PROJECTS\11621039\BUILDING_48\PHASE I\PHASELDOC 5-2 6 FEBRUARY 2004 n Ll n n u As mentioned previously, Roux evaluated the indoor air data to determine the potential to represent an Imminent Hazard and/or long-term human health risk. Table 4 summarizes the assumptions used to calculate the cumulative Incremental Lifetime Cancer Risks (ILCRs) and Hazard Indices (HI) calculated for 5 -year (Imminent Hazard) and 25 -year exposure scenarios, n respectively. n n I u n �i M u n Li F, Lj n Li F LJ n IJ Table 4 Risk Evaluation Exposure Assumptions Building 48, Merrimack Valley Works Potential Human Health Risk Calculation Assumptions and Results Parameter Units Imminent Hazard Evaluation 25 -Year Exposure Scenario Receptor N/A Site Adult Worker Site Adult Worker Exposure duration Hours per day 8 8 Exposure frequency Days per year 240 240 Lifetime exposure Years 5 25 Adult weight Kilograms 70 70 Based upon the assumptions listed above and using other standard default values obtained from MDEP guidance, Integrated Risk Information Services, Health Effects Assessment Summary Tables, and National Center for Environmental Assessment, Roux calculated a cumulative HI of 3E-1 and a cumulative ILCR of 2E-6 for the 5 -year exposure duration. These values are both below the benchmarks considered to represent an Imminent Hazard. Therefore, an Imminent Hazard would not exist if Building 48 were to be occupied by site workers in the future under the previously stated assumptions. The HI and ILCR for the 25 -year worker exposure scenario were calculated to be 3E-1 and 8E-6, respectively, both below the benchmarks considered to represent a condition of significant risk to human health. Additional details regarding this analysis can be found in Roux's Preliminary Assessment — Building 48 Area Letter Report (Roux, 2003). G:\PROJECTS\11621039\BUILDING_48\PHASE I\PHASEI.DOC 5-3 6 FEBRUARY 2004 r 5.2 SOIL RESULTS As described in Section 4, soil samples were collected by VHB from nine geoprobe borings drilled within the two suspected source areas in an effort to characterize subsurface soil conditions at the site. The results of the soil analyses are summarized in Table 5. Soil samples collected from the four borings drilled near the waste flammable tank location all contained concentrations of PCE and TCE that exceeded the MCP RCS -1 RC but did not exceed the MCP RCS -2. Reporting category RCS -2 is the applicable standard for this site based on the industrial use of the facility and the groundwater classification (GW -3). Soil samples from the five borings drilled in the vicinity of the former Barrel Pad did not contain concentrations of any compounds that exceeded the MCP RCS -1 RC. Additional sampling of soils from beneath Building 48 should be performed to investigate the possibility that soils in that area have been impacted by activities associated with the former Barrel Pad. 5.3 GROUNDWATER RESULTS I L_ I r• r, As discussed in Section 4, groundwater samples were collected from monitoring wells in the vicinity of the Disposal Site by both VHB and Roux and were analyzed for VOCs, cyanide, metals, and ammonia. The results are summarized in Table 6. Chlorinated VOCs were detected r in all five of the new monitoring wells, and in four of the seven existing wells sampled, with l J some concentrations exceeding MCP Method 1 GW -2 and GW -3 standards. The highest VOC concentrations were detected at VHB-MW-4, the well closest to the former waste solvent UST. Concentrations of PCE and TCE detected at this well exceed both MCP Method 1 GW -2 and GW -3 standards, while the detected concentrations of 1,1,1 -TCA and 1,1-DCE exceed MCP Method 1 GW -2 standards. Non -chlorinated VOCs were also detected in groundwater in the Building 48 area. Existing well VHB-MW-4, for example, contained relatively insignificant (i.e., compared to Method 1 standards) concentrations of ethylbenzene, toluene, and xylene isomers. The presence of these compounds at this well is consistent with the reported historical usage of the waste solvent UST for storage of flammable wastes. GAPROJECTS\11621039\BUILDING_48\PHASE I\PHASELDOC 5-4 6 FEBRUARY 2004 N N O C m C V o - d E `y N a nE w c= CIo in $ `u o d > 0 o m o-mE� ==E8� 0 CO E o v U _0 a° n m x m o o n i o ani w O U N -a) rn�oa E v co c rn y o c c m ! c °c U N Q) C N al O � N N U a c u E N a) O In Q Z I f/1 Z S s O N N ❑ ❑ ❑ ❑ N N ❑ 0) co U0 ❑ co ❑ ❑ ❑ co ❑ ❑ ❑ ❑ y� O hN ❑ ap n ❑ ❑ ❑ M m N N Z Z Z Z rn o Z m y Z Z Z Z Z Z Z Z O 0O O O O Z N e Z Z Z M NI I I to Z w Z-tn - N v I l l l i t l l l t l t mN o o Z N Z Z Z Z Z N r O, ' M O N I I I I I I I I I I l l l t l l ❑❑❑❑ O❑ 0 0 0 000 I I I I I I m n )n Z Z Z Z Z Z Z Z Z Z Z Z 1O N M 0 N I I I I I m o h I I I I I I I I I 1 1 Z Z Z Z Z Z Z Z Z Z o M ❑❑❑❑ 0 0 0 0 ❑ 0 0 0 0 n � Z Z Z Z Z Z Z Z Z Z Z Z Z Z lel � O N. N I I I I I I I I I I I I I I 1 1 <. ?❑❑ 0 0 0000 0 0 0 000 o o Z Z Z Z Z Z Z Z Z Z Z Z Z Z Z N o M O N N I I I O o N❑ O M o O o❑❑❑ au u? ,� Z ❑❑ O (n ❑ m❑ e 0 to M m y) Z ri o Z )n Z (a Z Z Z N m o c+i Z o Z Z Z o Z o Z m o o N Gr of N Z Z m u v) 0 c n N N I t° `O M m 4 w m O M m m. N w O 0000000 m h Z Z Z (o o o Z Z a .- o Z Z Z Z Z Z Z Z I I I I I I N H U NO M U o o c C o m 0 o 0 0 o o 0 0 oN m 0 O M p O N N O N N M 10 a) O a) o 0 a) a) o 0 0 o c o c o o o c c M N O O O O o o o O O O O O 0 0 0 0 0 0 )O O O. O O •- N N N C C C C N m N N a m Q T d � C N N a a Lc cU N m y y G O C O c C N a) 1. �. C O y N L C L N c m L E L d o a) n c y c a ai ai S' E c E E E N L U N c a) m y o o O �, o m _a E E y Q m N ,., U Z` E E •E .E E a y .c L n >` H o cV n L n F- H T ao M N c U U m m E E E a) a] h •C N N L O y C o U p o N u) (n U U m l�0 a) �? y? L Q Q m U U U J Z (n (n F- N y m N d M N E F •- H U c N d Z C — d Q) L U U U LL U N O = N EL o a a o N W W « c E i U o O N N O C m C V o - d E `y N a nE w c= CIo in $ `u o d > 0 o m o-mE� ==E8� 0 CO E o v U _0 a° n m x m o o n i o ani w O U N -a) rn�oa E v co c rn y o c c m ! c °c U N Q) C N al O � N N U a c u E N a) O In Q Z I f/1 Z S s % 9§22 z z C-4 /)] „ ,,,,,,,,,,,,,, §/22)[222)22 ®� ,,,,,,,,,,,,, §§2232)22222 §§ J „ 00 \\) 22)|§72222 „ s■ `a. °„ §/22§2222292 $[J. as o C,§- �� �����,,,,,,,,, 2222\/222§22 i§J . ()] 22222§222222 22k22222)222 2f] „ ,,,,,,,,,,,,„ 2d§ /2kk/))\2229 „ ,,,,,,,,,,,,,, . .. .�� �))„ ,,,,,,,,,,,,,, 2222222222)9 yg9222222222 \� ,, ,,,,,,,,,,,,,, �\® „ ,,,,,,/,,,,,,, \ o0, 0Z 29;- $�� 2> 22 2k2222229222\2 _%[ §222;§ ®SS•aS22|;SB \ ! E. ± k $$E �� _ ifs ! k \\j//)}�@ !|§!� ! § § - \k /�j /!y!§k=@7\§-�` m _-))§Af\k{ )- �- a 3& kla)06a!!2U)U) =;l71 '00 § / !; % n Li Trichlorofluoromethane (i.e., Freon) was detected at a trace concentration at existing well L MW -6S. `-' The groundwater VOC data from the four new shallow overburden wells, in conjunction with n those from the existing wells in the area of Building 48, provide a general approximation of the `i aerial extent of VOC contamination in the Building 48 area. As shown in Figure 4, no n chlorinated VOCs,were detected at existing wells MW75S and MW -6S, indicating that the lateral extent of the Building 48 shallow overburden VOC plume does not extend to these wells. The r? four new shallow overburden wells, in turn, provide a general understanding of the extent of the Li VOC plume, while existing well MW- IOS provides upgradient delineation. Of note are the VOC rl concentrations at MW -60S, which - for most VOCs - are second only to those detected at u VHB-MW-4. The presence of such concentrations at MW -60S is consistent with the n north-northwest flow of groundwater in the shallow overburden (towards the Merrimack River). The data suggest that the VOC plume likely extends beyond the property boundary; however, all n VOC concentrations at the fence line (and elsewhere, other than at VHB-MW-4) are well below u MCP Method 1 GW -3 standards. n The monitoring well network in the Building 48 area also provides vertical delineation of the extent of VOCs in groundwater beneath the Building 48 area. Volatile organic compounds were Li detected in three of the four deep overburden wells (MW -6D, MW -IOD, and MW -63D), although at concentrations up to 1,000 times lower than those detected in the overlying LJ overburden. It is not clear whether the VOCs found in the deep overburden are related to. the Building 48 area or are related to other, upgradient releases at the site (Building; 70/71 is being L' addressed under RTN 3-0174). 5.4 PRELIMINARY SITE CONCEPTUAL MODEL WESTON has developed a Preliminary Site Conceptual Model based on the data collected thus far, as presented in this report. Two potential source areas exist at the site including the 3,000 -gallon underground waste flammable storage tank and the former Barrel Pad waste storage area. rd LJ G:\PROJECTS\11621039\BUILDING_48\PHASE I\PHASELDOC 5-7 6 FEBRUARY 2004 U Waste Flammable Underground Storage Tank Available records for the waste flammable tank indicate it was installed in 1971. Discussions r with Lucent representatives indicated that the waste flammable tank was removed in the mid-1980s and that no "significant" soil or groundwater contamination was noted at that time; however, no written record of the tank removal could be located. The results of laboratory analyses on soil samples from the vicinity of the tank suggest that there is no residual soil contamination in this area. The use of geophysics in an effort to locate the tank r or tank grave is recommended to confirm that the borings were drilled in the exact location of the tank; and therefore, the soil samples collected are truly representative of the conditions there. r L J Groundwater in the vicinity of the tank contains levels of VOCs, specifically TCE, 1,1,1 -TCA, r and PCE exceeding the MCP GW -3 groundwater standards. Monitoring wells just upgradient of this area do not contain appreciable concentrations of VOCs, suggesting that the tank is the source of these compounds. The area of groundwater contamination emanating from the tank , location extends to the north-northwest towards the Merrimack River. The groundwater contamination does not extend in the direction of the small intermittent stream located to the , northwest of the Disposal Area. Based on the observed concentrations, it is likely that the VOC plume extends off-site. Given the depth to groundwater in this area (14 to 23 ft below grade) human exposure to groundwater is unlikely. Vapor migration into indoor air from groundwater and soil gas has occurred at Building 48, which is the only building located within the perceived extent of the plume. Building 48 is currently not occupied and a risk evaluation performed by Roux has confirmed that observed concentrations in indoor air do not pose a risk to human health even if Building 48 were to become occupied. Resampling of indoor air during likely worst-case conditions is recommended to confirm the initial sampling results and associated risk assessment conclusions. Worst-case conditions are considered to be winter time, when the surrounding ground surface is frozen (restricting the migration of soil gas to the ambient air), the building is heated (resulting in a chimney effect which can draw in the largest volume of soil gas from beneath the floor slab), and the windows are closed (minimizing the degree of ventilation). G:\PROJECTS\11621039\BUILDING-48\PHASE I\PHASELDOC 5-8 6 FEBRUARY 2004 n n U M U n Li Former Barrel Pad Area The former Barrel Pad was a paved area used to store drums of hazardous waste materials prior to the construction of Building 49. It is possible that there may have been releases to the soil in the vicinity of the former Barrel Pad, although no documentation of any releases was found. A portion of the former Barrel Pad extends beneath the present footprint of Building 48. Soil samples from areas of the Barrel Pad outside of Building 48 did not contain concentrations of any compounds that exceeded the applicable MCP RC. The results of indoor air and soil gas sampling suggest that there may be soil and/or groundwater contamination associated with the portion of the Barrel Pad that extended beneath Building 48; however, additional investigation would be prudent in that area. G:\PROJECTS\11621039\BUILDING_48\PHASE I\PHASELDOC 5-9 6 FEBRUARY 2004 E SECTION 6 MIGRATION PATHWAY AND EXPOSURE POTENTIAL 6. MIGRATION PATHWAY AND EXPOSURE POTENTIAL [310 CMR 40.0483(1)(f)] This section describes and evaluates the known and potential contaminant migration pathways, exposure points and potential receptors (human and environmental) to OHM migrating along the following pathways: ■ Air (including soil vapor) ■ Soil ■ Groundwater ■ Surface water 6.1 AIR As described previously, VOCs have been identified in an indoor air sample: collected from inside Building 48. Building 48 is currently unoccupied, and it is the only building within the boundaries of the mapped VOCs plume related to this Disposal Site. Volatile organic compounds were also identified in soil gas and groundwater beneath Building 48. These data indicate that VOCs released in the vicinity of the waste flammable tank have migrated via groundwater and are partitioning to soil gas and migrating to indoor air in Building 48. Because: Building 48 is presently unoccupied, there is no current risk to human health as a result of this pathway. 6.2 SOIL To date, concentrations of VOCs, ammonia, and metals above the MCP RC have not been found at the Disposal Site. It is possible that soil contamination related to the waste flammable tank and/or the former Barrel Pad could exist at the site. Additional investigation is needed to confirm that soil is not a concern, but based on existing data there are no human health or ecological risks associated with site soils. 6.3 GROUNDWATER Several VOCs have been detected in groundwater beneath the Disposal Site and extend to the north-northwest towards the Merrimack River. Concentrations of TCE and PCE were found G:\PROJECTS\11621039\BUILDING 48\PHASE I\PHASELDOC 6-1 6 FEBRUARY 2004 exceeding MCP Method 1 Standards for GW -3 groundwater. Although, the MCP Method 1 Standards for GW -2 do not currently apply to the groundwater beneath the Disposal Site because ` Building 48 is not occupied, it is likely that this condition will change in the future. Concentrations of TCE, PCE, vinyl chloride, 1,1,1 -TCA, and 1,1-DCE all exceed the GW -2 standards in the vicinity of Building 48. Direct measurement of VOC concentrations in indoor air will be made during the Phase II investigation to assess the potential risk to future Building 48 ' workers. Since groundwater is located 14 to 23 ft below grade and it is not used as a drinking water source , , in any capacity, facility workers are not exposed to groundwater via ingestion or dermal contact. L This depth to groundwater also eliminates future construction workers as a potential future , receptor. Groundwater is flowing towards the Merrimack River. An SRM Evaluation that was performed by Roux calculates the potential impacts to the Merrimack River. Based on very conservative assumptions regarding groundwater flow conditions and fate and transport parameters, Roux concluded that there is no risk to the Merrimack River from the contamination at Building 48 and that a SRM condition does not exist at the Disposal Site. This evaluation was presented in their Preliminary Assessment — Building 48 Area Letter Report (Roux, 2003) that was provided to MDEP previously. 6.4 SURFACE WATER The Merrimack River is located approximately 450 ft north of Building 48. Monitoring well MW -60S is located about 500 ft up -gradient of the Merrimack River and ' contained concentrations of several VOCs, but all were well below their corresponding MCP Method 1 GW -3 standard. This is consistent with the results of the SRM Evaluation preformed by Roux during the Preliminary Assessment. Human exposure pathways to OHM in the Merrimack River include ingestion (fish) and dermal contact (swimming). Receptors include ` humans associated with recreational use and biological communities in the river. No impacts to human health or the environment related to surface water are believed to result from VOCs ' migrating from the Disposal Site. G:\PROJECTS\11621039\BUILDING_48\PHASE I\PHASELDOC 6-2 6 FEBRUARY 2004 ` SECTION 7 EVALUATION FOR IMMEDIATE RESPONSE ACTIONS [310 CMR 40.0483(1)(g)] n n G 7. EVALUATION FOR IMMEDIATE RESPONSE ACTIONS [310 CMR 40.0483(1)(g)] In accordance with the MCP (3 10 CMR 40.0412) the Disposal Site does not meet the following requirements for conducting Immediate Response Actions: n ■ A release of oil and/or hazardous material has not occurred which requires Li notification to the Department under the "Two Hour" notification provisions of 310 CMR 40.0311 or 40.0312. .L A release or threat of release of oil and/or hazardous material has not occurred which requires notification to the Department under the 72 Hour" notification provisions of r1 310 CMR 40.0313 or 40.0314. v ■ A condition of SRM has not been identified. n Li Immediate or accelerated response actions are not necessary to prevent, eliminate, or minimize damage to health, safety, public welfare, or the environment. WESTON has concluded that the site does not meet any of the requirements for a 2 -hour notification as required under 310 CMR 40.0311 or 40.0312. Specifically, WESTON evaluated whether the VOCs observed in indoor air could pose an Imminent Hazard as defined at MCP 310 CMR 40.0321 and 40.0950. WESTON concluded that current conditions at the site do Lj not pose an Imminent Hazard to human health because Building 48 is currently unoccupied and a preliminary risk evaluation performed by Roux indicated that all the individual estimated ILCRs are below IE -5 and the estimated HI are below ten (310 CMR 40.0995). Therefore, the conditions at the site do not pose an Imminent Hazard. WESTON also concluded that the site does not meet any of the requirements for a 72 -hour notification provided at 310 CMR 40.0313 or 40.0314 since: r ■ No Non Aqueous Phase Liquid has been observed at the site. LI ■ Findings in the vicinity of the former waste flammable were not obtained as part of a closure assessment. G:\PROJECTS\11621039\BUILDING 48\PHASE I\PHASELDOC 7-1 6 FEBRUARY 2004 ■ The Disposal Site is not in a Zone I of a public water supply or within 500 ft of a private supply. ■ Although there are VOCs greater than 5 milligrams per liter in groundwater, there is not a school or occupied residential structure in the vicinity of the Disposal Site. With respect to the conclusion that the release does not represent a SRM, WESTON considered the definition of SRM set forth at MCP 310 CMR 40.0006. An SRM includes, "releases to groundwater that have been or are within one year likely to be detected in a surface water body, wetland, or public water supply reservoir." WESTON reviewed an evaluation performed by Roux, who considered data collected from MW -60S located about 500 ft upgradient of the Merrimack River. Based on a series of calculations using conservative assumptions for groundwater flow as well as fate and transport mechanisms, Roux concluded that an SRM condition does not exist at the site. The SRM Evaluation preformed by Roux is included in Appendix F. As a result of the considerations described above, WESTON concluded that immediate or accelerated response actions are not necessary to prevent, eliminate, or minimize damage to health, safety, public welfare, or the environment at this site. G:\PROJECTS\11621039\BUILDING_48\PHASE I\PHASELDOC 7-2 6 FEBRUARY 2004 SECTION 8 CONCLUSIONS [310 CMR 40.0483(h)] n u n 8. CONCLUSIONS [310 CMR 40.0483(h)] n Release Tracking Number 3-23204 was triggered by the detection of TCE and PCE in n groundwater at shallow overburden monitoring well VHB-MW-4 in May 2:003 and again in July, 2003 at concentrations that exceeded the applicable MCP RC. Subsequent Initial Site n Investigation Activities were conducted to develop preliminary information regarding the source IU and extent of VOCs at the Disposal Site, and to guide determinations on required and appropriate n further response actions. Key findings regarding the source and extent of VOCs at the LJ Disposal Site developed through implementation of Initial Site Investigation Activities are r1 summarized below. 1. Concentrations of TCE and PCE detected in groundwater at VHB-MW-4 have n exceeded the applicable RC (RCGW-2) and the relevant MCP Method 1 (GW -3) .LJ groundwater standards. n 2. Several other VOCs, including 1,1,1 -TCA, cis-1,2-DCE, l,l-DCE, 1,1 -DCA, L, trichloroflouromethane, vinyl chloride, toluene, ethylbenzene, and xylene have been detected in groundwater in the vicinity of Building 48, but at concentrations below their applicable RC and relevant Method 1 standards. 3. Soil samples collected from the vicinity of the waste flammable tank and the former n Barrel Pad did not contain concentrations of VOCs, metals, or petroleum LJ hydrocarbons exceeding applicable RC. Low concentrations of VOCs and petroleum hydrocarbons were found, but below the RC and relevant Method 1 standards. n u 2 4. The source of the VOCs in groundwater appear to be related to a waste flammable underground storage tank that had been located just south of Building 48. The 3,000 gallon steel tank was installed in 1971, and is believed to have been removed in the late 1980's; but no documentation could be found to verify the tank removal. 5. A second potential source of the VOCs in groundwater is a former Barrel Pad that had existed at the Building 48 location prior to construction of that building in 1986. The former Barrel Pad was an asphalt -paved area that was used to store drums of hazardous wastes prior to off-site disposal. 6. Volatile organic compounds were identified in soil gas beneath Building 48 and indoor air from within Building 48. Building 48 is currently unoccupied. A preliminary risk evaluation was performed by Roux to assess potential risks to human health via inhalation of indoor air should Building 48 be reoccupied in the future. That evaluation concluded there would be no risk to human health based on an 8 -hour work day exposure. G:\PROJECTS\11621039\BUILDING 48\PHASE I\PHASELDOC 8-1 6 FEBRUARY 2004 n 7. Groundwater exists under unconfined conditions at a depth of between 14 and 23 ft below grade. Groundwater flow is to the north-northwest towards the Merrimack River, which is the regional groundwater discharge area. 8. The estimated horizontal extent of the dissolved VOC plume in groundwater is shown on Figure 4. The lateral extent of the plume is well defined by existing monitoring wells. Additional monitoring wells are needed to confirm the longitudinal extent of the plume. 9. Deep overburden monitoring well MW -63D, located within the presumed source area . of the VOC plume, contained only very low concentrations of VOCs. Water level data from the shallow and deep overburden well pair in this area (VHB-MW-4 and MW -63D) confirm that there is a strong upward vertical hydraulic gradient. An upward vertical gradient is consistent with the location of the site within the groundwater discharge zone associated with the Merrimack River. A strong upward vertical gradient was also observed at all other monitoring well couplets in the vicinity of Building 48 (MW-5S/D, MW-6S/D, and MW- IOS/D). Field headspace screening of soil samples collected during drilling of the monitoring wells show a substantial drop in concentration after penetrating 15 to 20 ft below the water table. The water quality data, combined with the water level data, suggest that the VOC contamination is not migrating into the deep overburden, but rather staying within the top 20 ft of the saturated zone. 10. Roux associates conducted an evaluation to determine if VOCs in groundwater constituted a condition of SRM under the MCP. The evaluation involved estimating the mass of VOCs potentially discharging into the Merrimack River based on , observed concentrations in groundwater and on groundwater flow conditions. Roux concluded that it was very unlikely that an SRM condition existed at the site, largely due to the size and discharge of the Merrimack River. Outcome of the Initial Site Investigation Activities (310 CMR 40.0486) Based on the results of the Initial Site Investigation Activities, Comprehensive. Response Actions are necessary at the Disposal Site since the requirements of a Class A or B Response Action Outcome have not been met pursuant to the provisions of 310 CMR 40.1000. In accordance with 310 CMR 40.0486; therefore, Tier Classification of the Disposal Site was undertaken. Based on the scoring of the Disposal Site using the MCP Numerical Ranking System (MCP 310 CMR 40.1500), the Building 48 Area Disposal Site is being classified as a Tier II Disposal Site. G:\PROJECTS\11621039\BUILDING_48\PHASE I\PHASELDOC 8-2 6 FEBRUARY 2004 `'` f 11 U 7) Furthermore, the following recommendations for future response actions ("Conceptual Scope of Work") are being made, pursuant to 310 CMR 40.0510(1)(e)(2): 1. Additional groundwater monitoring wells will be installed to define the downgradient extent of the VOC plume. Consideration will be given to installing monitoring wells through the floor of Building 48 in an effort to document groundwater quality beneath the building. n 2. Sampling of unsaturated soils beneath Building 48 will be conducted within the footprint of the former Barrel Pad, to further evaluate whether these soils may be r, contributing to the VOCs observed in indoor air. . `-' 3. Further indoor air sampling will be conducted to better characterize the levels of VOCs and to provide additional data to be used as a basis; for a detailed risk assessment (see below). n 4. A Method 2 Risk Characterization will be performed to determine whether MCP groundwater standards for those constituents currently exceeding the MCP Li Method 1 GW -3 standards apply, given site-specific conditions. Specifically, n pursuant to 310 CMR 40.0982, site-specific information may be used to modify the MCP Method 1 GW -3 groundwater standards that are protective of potential discharges of OHM to surface water, or to demonstrate that such standards are not applicable at the Disposal Site. The Risk Characterization will also assess the risk to potential site workers as a result of VOCs in indoor air. It is estimated that implementation of these activities will cost in the range of $55,000. G:\PROJECTS\11621039\BUILDING_48\PHASE I\PHASELDOC 8-3 6 FEBRUARY 2004 Vj SECTION 9 REFERENCES n `Li n �' 9. REFERENCES Camp Dresser & McKee, 1986. Phase II Hydrogeologic Investigation at the AT&T Merrimack Valley Works, North Andover, MA. Camp Dresser & McKee, 2003. Phase I Environmental Site Assessment, Lucent Technologies, Merrimack Valley Works, North Andover, MA. I17 Makovitch, A., 2003 Earth Tech, Inc. Telephone conversation with James Soukup, Weston Solutions, Inc., November 20, 2003. Massachusetts Department of Environmental Protection BWSC Waste Site Scoring Map, December 12, 2003. Roux Associates, Inc., 2003. Preliminary Assessment - Building 48 Area Letter Report, July 28, 2003. USGS, Topographic Map, Lawrence, Massachusetts, Quadrangle 1987. u n Vanasse Hangen Brustlin, Inc., 2003a. ASTM Phase I Environmental Site Assessment, f Lucent Technologies/Bell Labs Innovations, 1600 Osgood Street, North Andover, '-' Massachusetts. I ' Vanasse Hangen Brustlin, Inc., 2003b. ASTM Phase II Limited Subsurface Investigation, v Lucent Technologies/Bell Labs Innovations, 1600 Osgood Street, North Andover, F, Massachusetts. Li n L� F Lj Ell G:\PROJECTS\11621039\BUILDING_48\PHASE I\PHASELDOC 9-1 6 FEBRUARY 2004 n LJ APPENDIX A 10 SEPTEMBER 2003 RELEASE NOTIFICATION FORM AND 21 OCTOBER 2003 NOTICE OF RESPONSIBILITY LETTER COMMONWEALTH OF MASSACHUSETTS EXECUTIVE OFFICE OF ENVIRONMENTAL AFFAIRS DEPARTMENT OF ENVIRONMENTAL PROTECTION ONE WINTER STREET, BOSTON, MA 02108 617-292-5600 �J1@1dVci MITT ROMNEY Governor 1_ ' O L T q 7 2003 KERRY HEAL ' O @ n Lieutenant Go or NO V U Lucent Technologies inc. r--� 2101 W. Chesterfield Blvd., Suite C100-110 Springfield, MO 65807-8672 u Attention: Mr. Gregory Vierkant LJ ELLEN ROY HERZFELDER Secretary ROBERT W. GOLLEDGE, Jr. Commissioner October 21, 2003 RE: North Andover 1600 Osgood Street RTN 3-23204 NOTICE OF RESPONSIBILITY PER M.G.L. c.21 E & 310 CNIR 40.00009 the MCP r� tJ THIS IS AN IMPORTANT NOTICE. FAILURE TO TAKE ADEQUATE ACTION IN RESPONSE TO THIS NOTICE COULD RESULT IN SERIOUS LEGAL n CONSEQUENCES. k-, Dear Mr. Vierkant: Information contained in a Release Notification Form (RNF) submitted to the Department of Environmental Protection (the Department or DEP) on September 11, 2003 and submitted by Lucent Technologies Inc. indicates that there is or has been a release of oil and/or hazardous material at the above -referenced property which exceeds a 120 day" reporting threshold (310.CMR 40.0315) and which requires one or more response actions. r-� Based on this information, the Department has reason to believe that the subject property or portion(s) thereof is a disposal site as defined in the Massachusetts Oil and ," Hazardous Material Release Prevention and Response Act, M.G.L. c. 21 E, and the n Massachusetts Contingency Plan, 310 CMR 40.0000 (the MCP). The assessment and cleanup of disposal sites is governed by.M.G.L. c. 21 E and the MCP. n The purpose of this notice is to inform you of your.legal responsibilities under state law for assessing and/or remediation of the subject release. For purposes of this notice, the terms and phrases used herein shall have the meaning ascribed to there by the MCP n This information is available in alternate formal. Call Aprel McCabe, ADA Coordinator at 1-617-556-1171. TDD Scrvkv -1-500-298.2207. U DEP on the World Wide Web: httpjlwww.mass.gov/dep j1 Printed on ReCyded Paper n . Lucent Technologies Inc. Page -2- n U unless the text clearly indicates otherwise: r) STATUTORY LIABILITIES n The Department has reason to believe that you (as used in this letter, "you" refers to Lucent Technologies Inc.) are a Potentially Responsible Party (a PRP) with liability `J under M.G.L. c. 21 E, § 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: ot hazardous. material to or ata site; any person who transported hazardous material to a transport, disposal, storage or treatment site from which there its 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. f7 This liability is "strict", meaning it is not based on fault, but solely on your status as I i 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, n regardless of the existence of any other liable parties. u The MCP requires responsible parties to take necessary response actions at n, properties where there is or has been a release or threat of release of oil and/or Ld 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. 21 E n 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 sanctions which may be imposed for failure to perform r response actions under the MCP. U 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 j LJ 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 ori cost liability, see 310 CMR 40:1200.) n The Department may also assess interest on costs incurred at the rade of twelve w` 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 n the debt, the Commonwealth may foreclose on these liens or the Attorney General may L, 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 F, Lj Lucent Technologies Inc. u Page -3- L, natural resources caused by the release. Civil and criminal liability may also be imposed under M.G.L. c. 21 E, § 11, and civil administrative penalties may be imposed under r) M.G.L. c. 21 A, § 16 for each violation of M.G.L. c. 21 E, the MCP, or any order, permit or approval issued thereunder. . The subject site shall not be deemed to have had all the necessary Bind required n response actions taken unless and until all substantial hazards presented by the site have been eliminated and a level of No Significant Risk exists or has been achieved in compliance with M.G.L. c. 21 E and the MCP. In addition, the MCP requires persons undertaking response actions at disposal sites to perform Immediate Response Actions (IRAs) in response to "sudden releases", Imminent Hazards and Substantiall Release Migration. Such persons must continue to evaluate the need for IRAs and notify the Department immediately if such a need exists. r-rIt is important to note that you must dispose of any Remediation Waste generated . I at the subject location in accordance with 310 CMR 40.0030 including, without limitation, L_J contaminated soil and/or debris. Any Bill of Lading accompanying such waste must bear F) 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. Ld The Department encourages parties with liabilities under M.G.L. c. 21 E to take L' prompt action in response to releases and threats of release of oil and/or hazardous F) 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. If you have any questions relative to this notice, you should contact Paegan Deering at the letterhead address or (617) 654-6660. All future communications regarding this release must reference the Release Tracking Number (RTN) 3-23204 contained in the subject block of this letter. Ve tr yours M 4., t -Colny B C b LJ Bureau of Waste S ' e p cc: North Andover Health Department, by electronic mail LJ James L. Soukup, Weston Solutions Inc. by electronic mail DEP data base NOR/file n n U n 6 - — — -- V b../ V .............���������� Lucent Technologies Ben Labs Innovations Lucent Technologies Inc. 2101 West Chesterfield Blvd. Springfield, Mo 65807-8672 September 10, 2003 Via UPS Ovemi t Letter Massachusetts Dept. of Environmental Protection Bureau of Waste Site Cleanup One Winter Street Boston, MA 02108 Re: 1600 Osgood, North Andover Dear: Please find enclosed a completed Release Notification. Form BWSC-1.03 for a recently discovered release at the above referenced property. This release was identified on May 21, 2003 during due diligence activities conducted by the buyer. Additional investigation and delineation activities were conducted by Roux Associates. You will find enclosed an investigation report as prepared by Roux Associates entitled, "Preliminary Assessment- Building 48 Area, Lucent Technologies Inc., Merrimack Valley Works, North Andover, MA" dated July 28, 2003. The report provides additional information beyond that provided in the form Should you have any questions you may contact me at the above address and phone number. Sincerely, -Wry P. Vierkant Lucent Technologies Inc Enclosures Cc: James Soukup, Weston Solutions Inc. Ralph McMurry, Hill Betts & Nash r� u LJ n �-n Massachusetts Department of Environmental Protection BWSC-103 Bureau of Waste Site Cleanup Release Tracking Number RELEASE NOTIFICATION & NOTIFICATION RETRACTION FORM Ptxsuant to 310 CMR 40.0335 and 310 CMR 40.0371 (Subpar) C) If assigned by DEP A RELEASE OR THREAT OF RELEASE LOCATION: Street: 1600 Osgood Location Aid: North Andover 01845 Ctty/l'own: ZIP Code:--------�...----..._. B. THIS FORM IS BEING USED TO: (check—one) [✓� Submit a Release Notification (complete ah sections of this form). n Submit a Retraction of a Previously Reported Notift cation of a Release or Threat of Release (complete Sections. A, 8, E. F and G of this form). You MUST attach the suppoAiling documentation required by 310 CMR 40.0335. C. INFORMATION DESCRIBING THE RELEASE OR THREAT OF RELEASE (TOR): Date and time you obtained knowledge oithe Release or TOR. Date: 05-21-03 Tkne: _._._.__.._.. Specify �� AM L� PM The date you obtained knowledge Is always required. The time you obtained knowledge Is not required If reporting holy 120 Day Conditions. IF KNOWN, record date and time raise so or TOR occurred, Date: Time: Specify, n AM .1 PM [ j Check here U you prevfouety provided an Oral NodIcation to DEP (2 Hour and 72 Hour Reporting Condkkm only). Provide date and time of Oral Notification. Date: Time: Specify. [—� AM ❑ PM Check al Notification Thresholds that appy to the Release or Threat of Release: (for more information see 310 CMR 40.0310 - 40.0315) 2 HOUR REPORTING CONDITIONS 72 HOUR REPORTING CONDITIONS 120 DAY REPORTING CONDRIONS [ -] Sudden Release 0 Subsurface Non Aqueous Phase Liquid Release of Hazardous Materk*s) to Sol or (NAPL) Equal to or Greater Crap 112 Groundwater Exoseding Reportable Ll Threat of sudden Release Inch Concentration(a) . [ 1 OR Sheen on Surface Water � Underground Storage Tank (UST) E Release of Ol to Soil Exceeding Reportable Release Concentration(s) and Affecting More Cyan 2 Cubic L] Poses imminent Hazard Yards Threat of UST Release Could Pose Innmirent Hazard.n Release of Oi to Groundwater Exceeding Reportable Release to Groundwater near Concentrabon(s) �] Release Detected In Private Wel ❑ W assn Spy Subsurface Non -Aqueous Phase Liquld (NAPL) [ ] Release to Storm Drain LJ Release b Groundwater near Equal to or Greater than 1/8 Inch and Less than 112 U Sanitary Sewer Release Scholl or Residence inch (Imminent Hazard Only) List below the Ole or Hazardous Materials that exceed Ciel- Reportable Concentration or Reportable Quantity by the greatest amount. 0 necessary, attach a IM of additional 01 and Hazardous Materiel substances subjed to reporting. Name and Quantiles of Osis (0) and Hazardous Materials (HM) Released: Repodable Concentrations O or HM Released O HM CAS #. Amount or Units Exceeded, U Applicable (check one) (If known). Concentration (RCS -1, RGS-2, RCGW -1, RCGW -2) Ptd a .127-18-4 5,500 ug/L RCGW-2 TCE n R .079-01-6. 46,000 ug/L RCGW-2 1,1,1 -TCA © 071-55-6 11,000 ug/L RCGW-2 D. ADDITIONAL INVOLVED PARTIES: Check here V attaching names and addresses of owners of properties affected by Use Release or Threat of Release. other than an owner who Is submitting this Release NotUicatlon (required). Check here If attaching Licensed Site Professional (LSP) name and address (opbonA. You may write In names and addresses on the bottom of the second page of this form. Revised 3!1195 Supersedes Fort BWSC-003 Page 1 of 2 Do Not After This Form Massachusetts Department of Environmental Protection BWSC-103 Bureau of Waste Site Cleanup Release rra&kVNumber -�� RELEASE NOTIFICATION & NOTIFICATION RETRACTION FORM Pursuant to 310 .CMR 40.0335 and 310 CMR 40.0371 (Subpart C) 1f assigned by DEP E. PERSON REQUIRED TO NOTIFY: Name ofOrgan(zation: -Lucent Technologies Inc. NameofContact Gregory Vierkant Title: Project Manger EH&S Street: -_2101 W. Chesterfield Blvd., Ste. C1007110 cky/Town: Springfield MO ZIP Code: 65807-8672 -------------- - State: —------------ --.. 417-882-2211`" 417-882-2167 Telephone: Ext.: FAX: (opibnaq ------ F. RELATIONSHIP OF PERSON REQUIRED TO NOTIFY TO RELEASE OR THREAT OF RELEASE: (check one) [✓] RP or PRP Specify: 9/ Owner of Operator O Generator O Transporter Other RP or PRP:---- Fldudary, Secured Lender or Municipakywkh Exempt Status (as defined by M.G.L. c. 21E, s. 2) Agency or Public Ud ty on a Right of Way (as defined by M.G.L. c. 21E, s. 5(0) Any Person Otherwise Required to Notify Specify Relationship: --____-- ------.------_-- ..... G. CERTIFICATION OF PERSON REQUIRED TO NOTIFY: I Gr_ec�o I V ierkant attest under Brae pains and penalties of perjury (1) that I have persom* examined and an fambar with the Information contained in this submittal, including any and at documents accompanying this transmittal form, (il) that, based on my Inquiry of those IndMduais Immediately responsible for obtaining Me information, the material information contained in this submittal is, to the best of my knowledge and belief, true, accurate and complete, and (10) that I am fully authorized to make this attestation on behalf of the entity legally responsbla for thio subrrgtial.the person or entity on whose behalf this submittal Is made amus aware that flu" are significant penalties, including, but not lrrtited to. parable flnea r imprison t fo submitting false. inaccurate. or Incomplete Information. ay Title: Project Manager, EH&S (signature) For: Lucent Technologies Inc. Date: September 10, 2003 - (print name of person or entity recorded in Section E) — Enter address of the person providing certification, If different from address recorded In Section E: Street: CWTown:------------- _....._---._ _ State: ZIP Code: --_--- -- ... Telephone: ------•------•------- Ext.:. FAX:(oQ6oneQ YOU MUST COMPLETE ALL RELEVANT SECTIONS OF THIS FORM OR DEP MAY RETURN THE DOCUMENT AS INCOMPLETE. IF YOU SUBMIT AN INCOMPLETE FORM. YOU MAY BE PENALIZED FOR MISSING A REQUIRED DEADLINE. LSP Contact Information: ,Tames L. Soukup Weston Solutions Inc. 1 Wall Street Manchester, NH 03101-1501 . Phone. (603) 656-5400, Ext. 5480 Fax: (603) 656-5401 LSP #: 5888 tit Revised 3/1195 Supercedes Form BWSC-003 Page 2 of 2 Do Not Alter This Foran APPENDIX B MASSACHUSETTS DEPARTMENT OF ENVIRONMENTAL PROTECTION/MASSACHUSETTS GEOGRAPHIC: INFORMATION SYSTEM SITE SCORING MAP -� MA DEP - Bureau of Waste Site Cleanup aITE NAME: Site Scoring Map: 500 feet & 0.5 Mile Radii WIN Building 48 Tarr *vmmaftn w,o.nenec etilo M..n*Wra r'j600 Osgood Street 6 M bel arsrsre it t -r: jr� JORTH ANDOVER, MA 01845 orc•mv pkaae.etixbto 113 L �24357n 710713ew Site LEocation acts mwm �..rr ri..,ei�oJre.�j$.n..e.■w+zd+n•2Ku PLEASANT ALLEYS" \ ; l CAMPBELL STREET • . • ) J �t + b m s i 9SIMONE SMfEUTSNE �►',It .� STREET HILL STREE va N B RY NUE ,SELL ~ PITM STREET I AMES T T 133 110 ° yoF :� : , ' Jr \:: / °o�bb CIO o - IPA s aA S I -S0,4 ROAD 125 40 B9y cGyET SNF 1 1 ) to -ter r T Roads: isnited Access. Divided, Major Hoed, Comectot Street, Track.'Id EPA Sob Source Aquifer,:FEMA 100 -year floodplain _- eourdsies: Town. Coma .DFP Pubk Water Supplies: Grourd,Surface,Non Comrttu ity iU Q — RV-; Tran; R v+er'"; Pgelne; Aquedilct Approved Z.Z- NAPA Surface Water Supply Zone A ®® j8e4ns: fAm. Sub: Streams: Am.. d, kW.*ht. t. Man Made Siwre, D. ' Da y: Water Features Rt>Fc Slafece Wever Supply ... aj� Wetlands: FmshAa t,NHESP VVuowdsHabitat ....... fbteMi* Pmdtwth a Agtifars: Nied6nHigh Yeld' Pirctected Open Space: ACEC ............................. d Non Fbtentid Drnkig Water Soums Area: NbmN* Yield �® D Awmitted Sold Waste FwAties; Cerbfed Ul nW flools». S ` CALE 1:15000 0 112 v2 KWMOM' �� December 12, 2003 APPENDIX C FLOOR PLAN OF BUILDING 48 r r f APPENDIX D MAP, BORING LOGS, WELL COMPLETION LOG, RELEVANT TEXT SECTIONS FROM THE VHB REPORT, AND A SUMMARY TABLE OF THE LABORATORY RESULTS n W 7rM Vanasse Hangen Bnutlin, Inc. r ,-4 AOC 11: Former 10,000 -gallon No. 6 Fuel Oil UST VFIB directed the advancement of four geoprobe soil borings, B11-1 through 4 (refer to Figure 2a), in the area of the Former 10,000 -gallon No. 6 Fuel Oil UST. Soil conditions in the area of this former UST generally encountered consisted of asphalt for 0 to 0.5 feet {1 followed by brown fine to medium non-native sand from 0.5 to 10 feet. Groundwater was encountered at 8 to 10 feet bgs. A gray stained clayey sand encountered at 10 to 11 feet was observed to have a sheen. A slight petroleum odor was observed in borings B11- I'r 2 and B11-3. However, PID jar headspace results indicated only minor detections of VOCs around 2-3 ppm. Concrete refusal in all four borings was encounter at a layer of concrete at 11 feet bgs. Three samples for EPH where collected from borings 1311-1, B11-2, and 1311-3 at approximately 10 to 11 feet and submitted for laboratory analysis. AOC 12: Former 3,000 -gallon Waste Flammable UST VHB directed the advancement of four geoprobe soil borings, B12-1 through 4 in the area of the Former 3,000 -gallon Waste Flammable UST (see Figure 2a). Soil conditions in the area of this former UST generally consisted of asphalt for 0 to 0.5 feet followed by brown silty fine sand from 0.5 to 25 feet bgs. Groundwater was encountered at 10 to 12 feet bgs. VHB noted a solvent odor within borings B12-1, B12-3, and B12-4. A sheen was observed by VHB within B12-1. White and bright blue crystals were encountered within boring B12-1 from 3 to 5 feet bgs. ra- u_. s Vertical Extent rt Headspace results (refer to table below) for the four borings indicated the highest result of 566 ppm was the highest reading in AOC 12. This reading occurred at B12-1 between 10 to 12.5 feet bgs. However, headspace results averaged over 500 ppm for soils within 7 Soil Investigation \\Mawalr\ev\1483U\dies\relrirh\Lixinii I'luro II Irtresiip ion npm FI.\AL ,w r L gravel from the 4.5 feet to 15 feet bgs at the bottom of the tank. Water within the tank was encountered at 7 feet bgs, and an ammonia odor was encountered in saturated soils within the tank. 1310-3 was advanced through the bottom of the tank and to a depth of 19 feet bgs. Soils beneath the tank consisted of a wet dark brown silty sand with a strong ammonia odor. Jar headspace results were non -detect per instrument detection limits with the exception of the sample beneath the tank from 17 to 19 feet bgs which had a result of 113 ppm. VHB collected samples for ammonia, total cyanide and physiological cyanide from 1310-3 from 13 to 15 feet bgs and 17 to 19 feet bgs as well as for VOCs at 17 to 19 feet bgs for laboratory analysis. u Soil boring B10-1, advanced to the north of the etchant/spent etchant UST, generally encounter tan silty sand which was dry to 17 feet bgs. VHB did not encounter any visual and olfactory evidence of OHM within this boring. Jar headspace results were non -detect per instrument detection limits for soil samples collected from B10-1: VHB collected a I1 v sample from 1310-1 from 17 to 19 feet bgs for physiological cyanide, total cyanide, and LA ammonia for laboratory analysis. r ,-4 AOC 11: Former 10,000 -gallon No. 6 Fuel Oil UST VFIB directed the advancement of four geoprobe soil borings, B11-1 through 4 (refer to Figure 2a), in the area of the Former 10,000 -gallon No. 6 Fuel Oil UST. Soil conditions in the area of this former UST generally encountered consisted of asphalt for 0 to 0.5 feet {1 followed by brown fine to medium non-native sand from 0.5 to 10 feet. Groundwater was encountered at 8 to 10 feet bgs. A gray stained clayey sand encountered at 10 to 11 feet was observed to have a sheen. A slight petroleum odor was observed in borings B11- I'r 2 and B11-3. However, PID jar headspace results indicated only minor detections of VOCs around 2-3 ppm. Concrete refusal in all four borings was encounter at a layer of concrete at 11 feet bgs. Three samples for EPH where collected from borings 1311-1, B11-2, and 1311-3 at approximately 10 to 11 feet and submitted for laboratory analysis. AOC 12: Former 3,000 -gallon Waste Flammable UST VHB directed the advancement of four geoprobe soil borings, B12-1 through 4 in the area of the Former 3,000 -gallon Waste Flammable UST (see Figure 2a). Soil conditions in the area of this former UST generally consisted of asphalt for 0 to 0.5 feet followed by brown silty fine sand from 0.5 to 25 feet bgs. Groundwater was encountered at 10 to 12 feet bgs. VHB noted a solvent odor within borings B12-1, B12-3, and B12-4. A sheen was observed by VHB within B12-1. White and bright blue crystals were encountered within boring B12-1 from 3 to 5 feet bgs. ra- u_. s Vertical Extent rt Headspace results (refer to table below) for the four borings indicated the highest result of 566 ppm was the highest reading in AOC 12. This reading occurred at B12-1 between 10 to 12.5 feet bgs. However, headspace results averaged over 500 ppm for soils within 7 Soil Investigation \\Mawalr\ev\1483U\dies\relrirh\Lixinii I'luro II Irtresiip ion npm FI.\AL ,w r L n VKB F1 LAI A M Vanasse Hangen Brustlin, Inc. B12-1 between 5 and 17.5 feet bgs. Headspace readings decreased to 9.2 ppm VOCs at 20 to 25 bgs at B12-1 (groundwater is approximately 12-13 feet bsg in this area. A similar vertical extent, however slightly lower headspace results were encountered with B12-4 with decreasing concentrations corresponding to increasing depth below the groundwater interface. Jar headspace results from B12-3 indicated VOC concentrations increased from 367 ppm at or near the groundwater interface to approximately 560.ppm from the groundwater interface at approximately 12.5 to 17.5 feet bgs. Results decreased to 228 ppm at 17.5 to 20 feet bgs within B12-3. Further samples below 20 feet bgs within B12-3 were not collected. Horizontal Extent Headspace results indicate that the horizontal of the release appears to at a maximum along a south to north axis at B12-1 with a decrease to the south towards B12-4 and a slightly lower decrease to the north towards B12-3. Along a west to east axis, the horizontal extent of this release appears to be again at a maximum at B12-1, which decrease to the east towards B12-2. Based on an inferred groundwater flow direction to the northwest, these results are consistent with downgradient migration of contaminants. VHB was unable to install borings in the area directly west of boring B12-1 because of underground utilities, therefore the western extent of this release has not been fully investigated. However, borings B16-1 and B16-5 within neighboring AOC -16 appears to have been impacted by the release at B12-1 as indicated by headspace results from this area. AOC -16 is located to the west and northwest of AOC -12. AOC 12/AOC 16: Jar Headspace Screening Results for VOCs Boring ID: De th Interval (ft) B12-1 B12-2 B12-3 B12-4 B16-1 B16-5 0-2.5 - 0 - 4.2 0.3 5.4 2.5-5.0 45 5.2 46.9 41 13 564 5.0-7.5 565 15.5 62.4 341 26 385 7.5-10.0 .565 15 293 433 30 98 10.0-12.5 566 - 367 157 - 29 12.5-15.0 564 - 563 135 - 4 15.0-17.5 146 - - - - - 17.5-20.0 9.2 - - - i - i - Notes: All results displayed in ppm (parts per million) "-" indicates depth interval not sampled Samples were collected for laboratory analysis from boring B12-1 from -2.5 to 5 feet bgs, 7.5 to 10 feet bgs, B10-4 from 7.5 to 10 feet bgs, as well as from B12-3 from 10 to 12 feet bgs for VOCs. Samples from B12-1 from 7.5 to 10 feet bgs, B104 from 7.5 to 10 feet bgs and B12-3 from 10 to. 12 feet bgs were submitted for laboratory analysis of EPH. Based on the presence of blue crystals within boring B12-1 from 2.5- 5 feet bgs, VHB segregated the blue crystals from the soil component of this sample and submitted the crystal component Soil Investigation \\\1a�atr\� \Od,1,W\dnas\rcF+nrL\Lunmt ftlw 11 ln-iptinn rep+rt FINALAm f� ►M Vanasse Hangen Brustlin, Inc. for analysis of total and physiologically available cyanide and the soil fraction for analysis of total and physiological cyanide, VOCs, 13 PP metals and EPH. 4� AOC 14 Two 175,000 -gallon ASTs to VHB advanced one soil boring in the area of two 175,000 -gallon No. 6 oil ASTs. This 1� boring was installed beneath a gravel covered liner within a containment basin u surrounding one of the ASTs. 'A liner was observed within both of the No. 6 oil AST containment basins. L Initially, VHB intended to utilize a Vacuum excavation truck to excavate gravel which existed at an unknown depth over the underlying liner, and then advance a hand auger soil boring beneath the liner. However, based on field conditions, it was possible to excavate the gravel by hand, exposing the underlying liner for inspection in 5 areas within the containment basins for the No. 6 oil ASTs. Four of the five areas excavated n consisted of a gravel layer on top of the liner which was heavily stained with No. 6 oil, and in places the No. 6 oil had hardened into a pavement like layer on top of the gravel. rr The gravel varied in depth over the liner averaging approximately 6" in depth. Water was observed above the liner in several of the areas excavated. v The liner consisted of an approximate 10 mil weight polyethylene sheeting. The liner was observed to be intact in areas visible to VHB. The liner appeared to contain water _a collected in the dike area. Because of the light weight of the plastic liner, after several n unsuccessful attempts VHB delayed sampling beneath the liner, except for one dry area not viably impacted with petroleum, until a suitable method for patching the liner could v be agreed to by all parties. VHB collected this one hand augered soil sample at B14-3 for -7 0.5 to 1.5 feet below grade surface. Based on visual and olfactory inspection, and screening by the headspace method for VOCs, VHB did not encounter evidence of OHM within this sample. In order to seal the areas of the liner which were disturbed during gravel excavation and attempted boring advancement, a layer of bentonite was placed over these followed by a t`7 layer of polyethylene sheeting, with was overlain by a layer of gravel. �i AOC 15 Filled Land Area 1 VHB directed the installation of seven test pits in the Filled Land Area (refer to Figure 3). Test pits were installed using a backhoe operated by Cyn Environmental of Stoughton, MA. Soil conditions in the Filled Land Area generally consisted of tan silty sand with �-t broken asphalt, concrete and landscaping debris from 0 to 6 feet bgs followed by gray i clay from 6 to 7 feet followed by light tan sand and silt from 7 to 10 feet bgs. Groundwater was not encountered to a depth of 10 feet bgs. VHB did not observe any w 9 Soil Investigation �''�\\\I.In'.Ilf�l'\'\Ir:,l,1J��IN'A�R'FN.II��Ll1.Y•III IIlIv'II 111.'.��Ilh.11lilll fv1I 1I'I\A I.Am' - - I I.. �L J n VHB n Vanasse Hangen Brustlin, Inc. visual or olfactory evidence of contamination. Headspace results were all non -detect per instrument detection limits. VHB collected samples for 13 PP Metals from test pits TP -15- 1 from 5 to 6 feet bgs, TP -15-5 from 9 to 10 feet bgs, and TP -15-7 from 6 to 7 feet bgs. AOC 16: Former Barrel Pad Hazardous Material Storage Area `-' VHB directed the advancement of four geoprobe soil borings, B16-1 through 4 in the area I� of the Former Barrel Pad Hazardous Materials Storage Area. Soil conditions in the area of " this former barrel pad generally consisted of asphalt for 0 to 0.5 feet followed by brown L' silty fine sand from 0.5 to 10 feet bgs and a dark brown clayey peat from 10 to 15 feet bgs. Groundwater was encountered at approximately 9' feet bgs. VHB observed a solvent y odor and sheen within B16-5 from 5 to 10 feet, and a solvent odor within B16-1 from 5 to 10 feet bgs. Headspace results for these borings are discussed above. The observed n evidence of solvent impacts is likely the result of downgradient migration of 4 f. contaminants from the Former 3,000 gallon Waste Flammable Tank within ACC 12. VHB observed a black silty sand within B16-4 from 3 to 5 feet bgs, and collected samples for EPH and 13 PP Metals from this depth interval. MCP Standards The results of the soil laboratory analyses were compared to the MCP Reportable Concentrations for soil category RCS -2 to help assess regulatory compliance issues for the Site. The MCP establishes reportable concentration limits for contaminants above which further response actions are required under the MCP process. The reporting standards r-� are based on uses of the Property and the surrounding properties and are divided into u two reporting standards commercial/ industrial and residential. Based on a review of the Site and surrounding area, the Site is not located with 500 feet of a residential area. Soil reporting RCS -2 was determined to apply to the Site since the RCS -1 criteria (i.e., located within 500 feet of a residential area) were not met. RCS -2 Soil Reporting Standards are most commonly applicable at commercial/industrial properties with no residential abutters. f ' Soil Analytical Results n A summary of all soil analytical results is included in Table 1. Although the commercial/ industrial standards are applicable to the Site, VHB also compared to f7 residential standards (which are not applicable) for comparisons sake and for soil management purposes during redevelopment activities. Locations of the soil borings are shown on Figure 2a and 2b. As shown in Table 1, all compounds analyzed were below applicable RCS -2 standards. ,L_ `-� 10 Soil Investigation V....w4.\ua I41 Wrn-.�rrl.rtl•�Lun•m l'ha..•II lnvnug.iliun ni—I FINAL - f `1 VIII? Vanasse Flangen Brustlin, Inc. t� n eliminate or control the source of OHM to indoor air of the facility in order to achieve a Class A RAO. n Restrictions on this area with respect to intrusive redevelopment activities are a likely outcome of the MCP response actions. Attached in Appendix E are copies of selected information from Roux's Phase I LSI Report. For a detailed review of the PWB Shop r RTN #3-21863 Phase I LSI the complete copy of the original report should be reviewed. This document is a publicly available document on file with the MADEP Northeast Region. A0C#12 Former Waste Flammable UST F Investigation L d Introduction ``' Section 2.0 and Section 3.0 of this Report document concentrations of VOCs in soil u and groundwater in the area of the former waste flammable UST (AOC# 12) that were first identified during a subsurface investigation conducted by VHB. Based on v the detection of VOC concentrations in groundwater above applicable RCGW-2 Standards and Method 1 Cleanup Standards (see Table below), Roux Associates installed six soil borings, five of which were completed as monitoring wells and collected a soil vapor samples and an indoor air sample from Building 48 located i immediately downgradient of the former waste solvent UST location to further investigate the nature and extent of this release. This work was completed during 1� July 2003. This Section discusses the preliminary results of Roux Associates' i� investigations (see Appendix F for preliminary Roux Associates Reports, Data Tables and Figures). f'? Roux Associates' July 2003 Preliminary Assessment of the Building 48 Area (within u AOC 12) included the advancement of six soil borings, four of which were completed as shallow overburden monitoring wells (MW -59S, 60S, 61S, 64S). -One soil boring was completed as a deep overburden monitoring well (MW -63D). A sixth borehole (SB -62) was refused at 16 feet below grade. Roux Associates conducted field head space screening on soil samples but did not detect readings above 50 ppm with the exception of MW -63D collocated at VHB-MW-4; therefore, no soil samples were i submitted for laboratory analysis. Roux Associates collected groundwater samples from the five newly installed monitoring wells and seven existing monitoring wells (VHB-MW-4, MW -05S, 05D, 06D, 06S, 10D, and 10S) in the area of AOC #12. i� Roux also conducted a groundwater elevation survey to establish the horizontal and vertical location of existing and newly installed wells, as well as groundwater `= elevations within the wells. This established the localized groundwater flow direction _ within this area. Lj 19- Environmental Reports Conducted by Others n Phase 11 Investigation report FINAL.doc W1 n VHB i ( n u� Vanasse Hangen Brustlin, Inc. One soil gas and one indoor air sample was collected from Building 4& Samples were collected with Summa canisters and analyzed for VOCs using EPA Method TO - 15. Results of soil screening by the jar headspace method for results of VOCs using an PID detected a maximum results of 159 ppm within soil boring MW -63D at a depth interval of 20 to 22 feet bgs which was below the surface of the groundwater table (see soil borings within Appendix F). This headspace result from MW -63D was consistent with VHB's soil screening results from adjacent VHB-MW-4. Soil samples were not collected from this interval, however adjacent monitoring well VHB-MW-4 is screened across this same depth interval. The results of the groundwater elevation survey are displayed on Roux's Figure "Groundwater Elevation and Generalized Groundwater Flow in Shallow Overburden Wells" contained in Appendix F. Referring to this figure, groundwater flow within AOC 12 is to the north-northwest towards the Merrimack River. Monitoring locations and groundwater analytical results are depicted in Roux Associates' figure, "Concentrations of Chlorinated VOCs Detected in Groundwater", included in Appendix F. As depicted in this figure, and shown in the table below, five VOC compounds were detected above MCP Method -1 GW-2/GW-3 Standards: [Note: Method 1 standards are provided for reference only and are not necessarily the cleanup standards that will be applied to the Site. Furthermore, groundwater in the vicinity of AOC -12 is not classified GW -2 since there are no occupied buildings within 30 feet of any of the monitoring wells. However, since the depth to groundwater at wells VHB-4, MW -10S, MW -64S and MW -5S is less than 15 -feet bgs, Method 1 GW -2 standards are presented for discussion purposes only.] Roux Associates VOC Groundwater Results in AOC 12 area Well ID MW- 10S * MW -64S VHB-MW-4 *(1) VHB-MW-4 * (1) MCP MCP MCP GW -2 GW -3 UCL Date 7/10/03 7/10/03 7/10/03 5/12/03 1,1-DCE <1.0 28 300 <250 1 50,000 100,000 TCE 2 2,100 84,000 46,000 300 20,000 100,000 1,1,1 -TCA <2.0 1,100 18,000 11,000 4,000 50,000 100,000 VC 16 20 <400 <500 2 40,000 5,000 PCE 65 420 5,900 5,500 3,000 5,000 50,000 Notes: 20 Environmental Reports Conducted by Others n \\,'�tawatr\ev\08.;1\docs\reports\ Lucent Phase 11 Investigation report FINAL.doc T E �- � w...W.. - i O 0 W v i Fri D oz V� CO Fq I / � b b i O 0 W v i Fri D oz V� CO Fq I / � i i i i - i I I / i O 0 W v i Fri D oz V� CO Fq I / � ELI A.. 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T L acLu r 7 TE X L ` y O d U O d T;, (n (n000� O >Hrl—WH QO U W U) N .y c (0 Ein =a o u U N N N CZD _U W a E a 2,5 y O C U C Cl (D d 0 r E m o 0 .CL �mcLn a ccQ co E`0 a E C C U O r fn GI to U CD c � T Q G C az m0 F) U n VHB Soil Boring'Repor Site Data: Lucent Technologies n1600 Osgood Street `—' North Andover, Massachusetts n u Driller: TDS Drill Rig: Geoprobe n Technique: Vibratory Push Date: 5/1/2002 Weather: Rainy - 50s F1 Li n Lj r� y n Li n n n Li n LIJ n u L� Project f Boring #: B12.1 Boring Depth 25' Depth to Ground Water 10' VHB Representative Jessica Fox 0-5' - 60/60 0-3" - Asphalt. 0-2.5' _ 3"-2'9" - Light brown silty fine sand, gravel, brick. Solvent odor. 2.5-5' 45 2'9"-3'- Intact asphalt. 3'-5' - Medium brown silty fine sand. White and bright blue crystals. Solvent 15-10' I I - I 60/60 I I Brown/tan silty fine sand. Strong solvent odor. Ir 7 n I ccc Wet at 10'. Tan/orange silty fine sand. Strong solvent odor. Sheen. Tan/orange silty fine sand. Strong solvent odor. Sheen. Gray fine sand. No odor. VHB Site Data: Lucent Technologies 1600 Osgood Street North Andover, Massachusetts Driller: TDS Drill Rig: Geoprobe Technique: Vibratory Push Date: 5/1/2002 Weather: Rainy - 50s tt B12-2 Boring Depth 11' Depth to Ground Water - VHB Representative Jessica Fox Aept6 Sero le # : P .. Blow Countsl: Recovery PID Field Glass6catiA on nd Remarks " �o<n PM 0-5' - 54/60 Dark brown fine sand fill. Trace coal. 0-2.5' 0 2.5-5' 5.2 5-10' - 60/60 Brown fine sand fill. 5-7.5' 15.5 7.5-10' 15 Concrete. 8/12 - Concrete refusal at 11'. Groundwater not encountered. Soil Boring Report Site Data: Lucent Technologies 11600 Osgood Street North Andover, Massachusetts Driller: TDS Drill Rig: Geoprobe Technique: Vibratory Push Date• 5/1/2002 B12-3 Boring Depth 20' Depth to Ground Water 12' VHB Representative Jessica Fox Weather: Rainy - 50s pepth Sample # Blow Counts: Recovery inn :PID , p F �e1d Glass�ficat�on And Remarks 0-3" - Asphalt. 0-5' - 42/60 3"-3'6" - Brown silty fine sand. Some gravel. Slight solvent odor. 0-2.5' - 2.5-5' 46.9 Light brown silty fine sand, orange streaks. Strong solvent odor. 5-10' - 60/60 5-7.5' 62.4 7.5-10' 293 Brown/orange fine sand. Strong solvent odor. Wet at 12 feet. 10-15' - 60/60 10-12.5' 367 12.5-15' 563 Light brown fine sand 15-20' - 60/60 15-17.5' 558 Light brown coarse sand 17.5-20' 228 VHB , n.fa- Lucent Technologies 1600 Osgood Street North Andover, Massachusetts Driller: TDS Drill Rig: Geoprobe Technique: Vibratory Push Date: 5/1/2002 Weather: Rainv - 50s Project # Boring #: B12-4 Boring Depth 15' Depth to Ground Water 10' VHB Representative Jessica Fox Recovery,YID ss�GradonAnd:Remarkc4 Depth .:Sample# 111ow:Counts :: Field Cla :::..........:............... mlin 1' 0-5' - 48/60 0-6" - Asphalt. 0-2.5' 4 2 6"-1' - Orange coarse sand. 2.5-5' 41 1'-4'- Brown silty fine sand. Gravel. 4'-4'6" - Light brown silty fine sand. 5-10' - 60/60 5-7'- Dark brown silty fine sand. Solvent odor. 5-7.5' 341 7'-77" - Rock fragments. 7.5-10' 433 7'2"-10'- Brown silty fine sand. Organic matter. Sovlent odor. Wet at 10'. Brown silt. Solvent odor. 10-15' - 60/60 10-12.5' 157 12.5-15' 135 I Soil Boling Report ite Data: [it Technologies Osgood Street i Andover, Massachusetts Driller: TDS Drill Rig: Geoprobe Technique: Vibratory Push Date: 5/1/2002 Weather: Rainy - 50s B16-1 Boring Depth 10' Depth to Ground Water 9' VBB Representative Jessica Fox Recovery PID FW Cl ArimbonAndReinarl�s Depth Sample # ; Blow Counts on ....._.................. . 0-5' 39/60 0-4" - Asphalt - 0-2.5' 0.3 4"-1'1" - Silty brown fine sand with some gravel. 2.5-5' 13 T-I'l"-2'- Silty gravel and rock fragments, some fine sand. 2'-3'3" - Light brown silty fine sand. Gray/medium brown silty fine sand, solvent odor. 5-10' 60/60 5-7.5' 26 Wet at 9'. 7.5-10' 30 l V VHB n Cite Data: U E Lucent Technologies 1600 Osgood Street North Andover, Massachusetts n Driller: TDS u Drill Rig: Geoprobe Technique: Vibratory Push Date: 5/1/2002 I Weather: Rainy - 50s B16-2 Boring Depth 10' Depth to Ground Water 9' VHB Representative Jessica Fox Recovery Depth Sample inn ..dRfieIdCassfcerk Blow Counts : 0-5,.._ .... - 48/60 0-2" -Asphalt 0-2.5' 1 0 2"-9" - Silty dark brown sand and gravel. No odor. 2.5-5' 2.7 9"-1'- Silty gravel. No odor. 1'-5' - Brown silt, some gravel. No odor. Light brown silty fine sand. No odor. 5-10' - 60/60 5-7.5' 2.8 Wet at 9'. 7.5-10' - I ,foil Boring Report Cin nata. [it Technologies Osgood Street i Andover, Massachusetts Driller: TDS Drill Rig: Geoprobe Technique: Vibratory Push Date: 5/l/2002 Weather Rainy - 50s rroject ff Boring ��� B16-3 Boring Depth 10' Depth to Ground Water 9' VHB Representative Jessica Fox Depth Sample.ii Blow Counts Rernvery PID F�e1d C1a sricabon And Remarks. in P 0-3" - Asphalt. o -s' 48/60 3"-3'- Medium brown silt, some gravel. No odor. 0-2.5' 0.4 3'-4'- Gray/tan silty fine sand. No odor. 2s -s' 0.5 Tan silty fine sand.. No odor. s-10' 60/60 Wet at 9 feet. 5-7.5' 0.3 7.5-10' - Soil Boring Report it, -main! nt Technologies Osgood Street i Andover, Massachusetts Driller: TDS Drill Rig: Geoprobe Technique: Vibratory Push Date: 5/l/2002 Weather: Rainy - 50s ;F 7 B16-4 Boring Depth 10' Depth to Ground Water 9' VHB Representative Jessica Fox Pep th Sample Blow Counts Recovery porn PID P F geld Class�ficabon Aud Remarks 0-5' - 44/60 0-5" - Asphalt. 2-3' 1 1.6 5"-2'- Brown silty gravel. 3-5' 0.2 2'-3'- Black silty fine sand. Sample collected for EPH and Metals. 3-3'8" - Gray silty fine sand. 5-10' - 38/60 Brown silty fine sand, some gravel. No odors. No staining. 5-7.5' 0.3 Wet at 9 feet. 7.5-10' 0.5 L Soil Boeing Report life nata: nt Technologies Osgood Street i Andover, Massachusetts Driller: TDS Drill Rig: Geoprobe Technique: Vibratory Push Date: 5/1/2002 B16-5 Boring Depth 15' Depth to Ground Water 9' VHB Representative Jessica Fox Weather: Rainy - 50s Depth Sample# Blow Counts Recovery. inn P.ID PM Fre1d C1ass�fication; W Remarks .: 0-5' - 60/60 0-3" - Asphalt. 0-2.5' 5.4 3"-9" - Brown silty gravel. 2.5-5' 564 9"-5'- Olive silty fine sand. Solvent odor. Sheen. 5-10' - 60/60 Oliveltan silty fine sand. Solvent odor. Sheen. 5-7.5' 385 7.5-10' 98 10-15' 60/60 10'-10'8" - Olive silty fine sand. 10-12.5' 29 10'8"-11' - Dark brown peat. Organic matter. 12.5-15' 4 11'-11'6" - Gray silt 11'6"-15'- Dark brown clayey eat. Organic matter, wood. MLMOrMg nitoWell Diagram Project Name: Ozzy Properties Project No. 833400 Date: 6 -May -03 Location: 1600 Osgood Street Contractor: TDS Drilling Well No. VHB-MW-4 Li North Andover, MA Engineer: Jessica Fox GW Depth: 13 ft bgs Elevation: { fop of Surface Li basing 44. F1 Fop of PVC Riser n L n -hickness of 3entonite Seal F, L' 'op Of Sand n u n op of Well Screen u 1, iLJ n i� n n Dttom of 'ell Screen n apth of Borehole I U `I U r f lU 7/14/2003 Top of PVC is 2.5 inches" below the ground Natural Material to a depth of 3 feet below the ground 2" PVC Schedule 40 riser pipe .25 feet to 3 feet Bentonite Seal elevation 3 feet - 4 feet Top of 2" PVC 10 -Slot well screen riser pipe at 5 feet Groundwater located at 13 feet Filter Sand surrounding the Slotted well screen: 4 - 25 feet Bottom of well located at 25 feet bgs Vanasse Hangen Brustlin, Inc. mw diagram, xis APPENDIX E SUMMARY TABLES AND MAPS FROM ROUX ASSOCIATES, INC. F L' yr lJ r r u U E 3 V CJ 3 r e 0 ao O t a b r v 3 � N � 3 N M � V � � a r � aXi E N v C v N N O O. N � �3>g yy T O � •N X O .� o L w X y 1 r L y A K 3 O.L T L L N= G�> a UE =u d s -0 c �L 3 c o U U II $ F II E Table 2 Water Level Information Building 48 Area July 10, 2003 Well ID Well Type Depth to Water (feet) Depth to Bottom (feet) Measuring Point Elevation (feet above msl) Groundwater Elevation (feet above msl) MW -5S Shallow Overburden 13.98 23.12 31.40 17.42 MW -6S Shallow Overburden 27.50 37.10 39.80 12.30 MW -10S Shallow Overburden 12.90 18.48 33.03 20.13 MW -59S Shallow Overburden 17.97 27.03 33.55 15.58 MW -60S Shallow Overburden 22.51 29.78 35.39 12.88 MW -61S Shallow Overburden 20.76 28.80 37.90 17.14 MW -64S Shallow Overburden 14.68 23.82 33.32 18.64 VHB-MW-4 Shallow Overburden 14.15 22.06 33.29 19.14 MW -6D Deep Overburden 28.36 NM 39.48 11.12 MW -101) Deep Overburden 20.21 78.41 33.16 12.95 MW -63D Deep Overburden 21.08 75.20. 33.18 12.10 MW -5D Bedrock 15.71 NM 31.19 15.48 NM = not measured (depth greater than 100 feet) , ms1= mean seal level ROUX ASSOCIATES, INC. LUC77007M03.173M i >o H m m 8 a (n �' O D 4yy7 1 A ° x m p am7y ° av 0 O g W O p OA n z A a r Z Q < I I 2 A A w� N; —i :j O G) m c zn �O A z A Z O . r czi m z o m � o F °z z a z z a z M f z Ln m c Ln r O 8 Ci a U _a:�, K rnK� 8 a (n �' O D C n. f 0 ° av 0 Dz Z A 0 x Z. 00 n z A a r Z Q < o � 0 m M N i o ("N —i :j O G) � zn �O Z a U _a:�, K rnK� � (n �' D n. f 0 C7 I> Cf) cj� m J !� U) z fTl m D z Q 41 ao I I COO ► cn .,� , � >cK / rn m n co cn oo `� Aooyv rn wv,c�cn Nva w mvvN ys- r X m y r It A p A myAZ w9vo "Igr AF�*Ao CCF ?.gZvg mpN m6O O CxO oO zz 0f PO p,N p�� ,AV09 O O ➢0 000 m NuZO -u m 2 O8m 0X m1AO(; ;Nvr m 50 cgij 0 p\Z $-4 ZO ANA m AZ�a� �0oor� CME A O•'v I rA Anl0+1 A Nam O A�D_•1 _A A� i�z teo �Ai°zny� my OLDz O D �Omr}, DmyZO O�Z Z� cmi i mm �,� � i Z01 -I icy 0z-1 A O('�O A p�pZPC 0 AA m� i pot M io ;0o� v� ooc2 m� A LO Z I 1p r+7• �n>S c,�iviZQ zm OW. R1 Zfz 0000 ;0 m y z m oy�; r" z O A ° O Q 0 ; vy 3 C. WASTEWATER TREATMENT P LD -1 )0 NSJ�„ MW -4D NS MW -4S NS SANDI BED I SAID MW -108' a PCE CCE N CIS-1,2-DCE VC BLDG TCA I.I-D,1-DCA 1,1,1 -TCA 1,1-DCE MW -4D NS MW -4S NS SANDI BED I SAID ND j 2 65 T8xz,, M ND NO MVV' -1 GS ND `Er? 3,000 -GALL VIABLE L101-1llJ V E SOLVENT UST I--&AW—n ' TCE -CE 10 N CIS -1,2-0 VC DEEP OVERBURDEN MONITORING WELL 1,1,1 -TCA 1], 1,1 -DCA FENCE 1,1-DCE ND j 2 65 T8xz,, M ND NO MVV' -1 GS ND `Er? 3,000 -GALL VIABLE L101-1llJ V E SOLVENT UST I--&AW—n ' Prepared For. 1,1 -DCA N SHALLOW OVERBURDEN MONITORING WELL DEEP OVERBURDEN MONITORING WELL N BEDROCK MONITORING WELL 3r--w--x-- FENCE • --- STREAM . RAILROAD TRACKS xr .. NS x -- MW -9S NS LEGEND NOTES: 1. BASE MAP DERIVED FROM CDM DRAWING TITLED "SITE PLAN" (FIGURE 2 OF CDM -S PHASE IV REMEDY IMPLEMENTATION PLAN, JANUARY 2001). 2. LOCATIONS OF FORMER PWB PTTs AND TRENCHES BASED ON CDM DRAWING TITLED "SAMPLING LOCATIONS AND RESULTS IN FORMER PRINTED WIRING BOARD SHOP- (FIGURE 1-1 OF CDM'S PHASE I ENVIRONMENTAL ASSESSMENT REPORT, MAY 8, 2002 DRAFT). 3. LOCATIONS OF FORMER WASTE SOLVENT UST, FORMER CHEMICAL STORAGE AST AND SPILL PIT, AND WASTEWATER PIPING AND UTILITY CORRIDOR APPROXIMATED BASED ON WESTERN ELECTRIC COMPANY DRAWING TITLED "OUTSIDE UNDERGROUND PIPING", DRAWING NO. 222-5-505 (DATE OF. LAST REVISION 6/16/80). 4. LOCATION AND SIZE OF THE MERRIMACK RIVER ARE APPROXIMATE. 5. LOCATION OF FORMER FURNACE PIT BASED ON WESTERN ELECTRIC COMPANY DRAWINGS TITLED "STRUCTURAL - CONCRETE, LOWER FLOOR", SHEET 4, DRAWING NO. 195-47143 (DATE OF LAST REVISION 3/23/56). 6. APPROXIMATE LOCATION OF FORMER DEGREASER IDENTIFIED BY EARTH TECH/FACILITY PERSONNEL. 7. LOCATION OF FORMER 3,000 -GALLON FLAMMABLE LIQUID WASTE/WASTE SOLVENT UST BASED ON AT&T TECHNOLOGIES, INC. DRAWING TITLED "SERVICE PIPING', DRAWING NO. 222- 1673-508 (DATE OF LAST REVISION 5/19/87) AND INFORMATION PRODIVED TO ROUX ASSOCIATES BY VHB. 8. LOCATION OF FORMER BARREL PAD BASED ON APRIL 1, 1980 AERIAL PHOTOGRAPH. Title: CONCENTRATIONS OF CHLUKINA i tU VUcs VHB-I DETECTED IN GROUNDWATER PCE JULY 2003 TCE MERRIMACK VALLEY WORKS CIS -1,2 -DCI NORTH ANDOVER, MASSACHUSETTS VC 1,1,1 -TCA Prepared For. 1,1 -DCA 1,1-DCE NS = NOT :ROUX ASSOCIATES, IF t9 LUCENT TECHNOLOGIES :ompiled by: AG Dote: 7/22/03 1 FIGURE 'repared by: RF/CRS Scale: AS SHOWN 'roject Mgr LM Office: MA 3 ile No: WC0717303 Project: 77007MO3 WASTEWATER TREATMENT F ` SAND BE i �c EE BLDLi 50 NG f r i BLDG 51 vHB-MW-a'` 19.14 FORMER 3,000 -GAL FLAMMABLE LIQUID VtiASIE. SOLVENT U . NG BLDG 34 MW NG MW-60S LOCATION AND DESIGNATION OF SHALLOW 12,88 OVERBURDEN MONITORING WELL ---MEASURED WATER—LEVEL ELEVATION, IN FEET ABOVE MEAN SEA LEVEL (NG=NOT GAUGED) mw 14 UNE OF EQUAL WATER—LEVEL ELEVATION, IN FEET GENERALIZED GROUNDWATER FLOW DIRECTION NOTES: 1. BASE MAP DERIVED FROM CDM DRAWING TITLED 'SITE PLAN' (FIGURE 2 OF CDM'S PHASE N REMEDY IMPLEMENTATION PLAN, JANUARY 2001). 2. LOCATIONS OF FORMER PWB PITS AND TRENCHES BASED ON CDM DRAWING TITLED 'SAMPLING LOCATIONS AND RESULTS IN FORMER PRINTED WIRING BOARD SHOP' (FIGURE 1-1 OF CDM'S PHASE I ENVIRONMENTAL ASSESSMENT REPORT, MAY 8, 2002 DRAFT). 3. LOCATIONS OF FORMER WASTE SOLVENT UST, FORMER CHEMICAL STORAGE AST AND SPILL PIT, AND WASTEWATER PIPING AND UTILITY CORRIDOR APPROXIMATED BASED ON WESTERN ELECTRIC COMPANY DRAWING TITLED "OUTSIDE UNDERGROUND PIPING', DRAWING NO. 222-5-505 (DATE OF LAST REVISION 6/16/80). 4. LOCATION AND SIZE OF THE MERRIMACK RIVER ARE APPROXIMATE. 5. LOCATION OF FORMER FURNACE PIT BASED ON WESTERN ELECTRIC COMPANY DRAWINGS TTTLED "STRUCTURAL'— CONCRETE, LOWER FLOOR", SHEET 4, DRAWING NO. 195-47143 (DATE OF LAST REVISION 3/23/56). 6. APPROXIMATE LOCATION OF FORMER DEGREASER IDENTIFIED BY EARTH TECH/FACILITY PERSONNEL 7. LOCATION OF FORMER 3,000—GALLON FLAMMABLE LIQUID WASTE/WASTE SOLVENT UST BASED ON AT&T TECHNOLOGIES. INC. DRAWING TITLED "SERVICE PIPING", DRAWING NO. 222— 1673-508 (DATE OF LAST REVISION 5/19/87) AND INFORMATION PRODIVED TO ROUX ASSOCIATES BY VHB. 8. LOCATION 'OF FORMER BARREL BASED PAD ON APRIL 1, 1980 AERIAL PHOTOGRAPH. Title: WATER LEVEL ELEVATIONS AND GENERALIZED GROUNDWATER FLOW DIRECTION IN THE SHALLOW OVERBURDEN MERRIMACK VALLEY WORKS NORTH ANDOVER, MASSACHUSETTS Prepared For. ROUX ASSOCIATES, II £mnamna,to/ com wkq d Managemar LUCENT TECHNOLOGIES :ompiled by: AG Date: 7/22/03 FIGURE 'repared by: RF/CRS Scale: AS SHOWN 'roject Mgr. LM Office: MA 4 le No: L000717304 Project: 77007MO3 APPENDIX F SUBSTANTIAL RELEASE MIGRATION EVALUATION r BY ROUX ASSOCIATES, INC. L n Mr. Greg Vierkant L July 28, 2003 Page 6 downward, and the general absence of confining layers beneath the source area (see log for MW -63D in Attachment A). Concentrations of the parent compounds (PCE, TCE, and TCA) were highest at MW -63D, located in the source area, while concentrations of daughter products (cis-1,2-DCE, vinyl chloride, 1,1-dichloroethane [DCA] and 1,1-DCE) were generally lowest at MW -63D. LThe PCE and TCE concentrations detected at VHB-MW-4 were the only concentrations detected in the Building 48 area that exceed Method 1 GW -3 standards. Method 1 GW -2 n standards, on the other hand, were exceeded at eight of the 11 wells. However, only the L, Method 1 GW -2 exceedances at MW -10S, MW -64S, and VHB-MW-4 are highlighted in Table 1 and Figure 3, since these were the only wells with exceedances at which the n depth to water was less than 15 feet, and which were not deep overburden wells. The depth to water beneath the Building 48 area varies considerably, ranging from 12.9 feet at MW -10S to 27.5 feet at MW -6S (Table 2). The water table is present at depths nshallower than 15 feet at MW -5S, MW -10S, MW -64S, and VHB-MW-4, all located IL, south and west of Building 48; consequently, Method 1 GW -2 standards are potentially relevant (i.e., as a contingency in case occupied buildings are present near these wells in n the future) only at those four wells. (It is recognized that wells MW -10S and VHB-MW- 1 4 are located greater than 30 feet from buildings, and that there are in fact no occupied buildings in this area; however, these exceedances are highlighted for future land use r' considerations.) Based upon the depths to water in the five monitoring wells surrounding Building 48 (MW -5S, MW -59S, MW -60S, MW -61S and .MW -64S; see Figure 2 and Table 2), surface topography, and building construction, depth to water beneath n Building 48 and a portion of Building 49 is likely greater than 15 feet. However, based on the VOC concentrations detected at MW -60S, which are significantly higher than Method 1 GW -2 standards, there is still a strong potential for VOC vapor migration into in indoor air of Building 48. to 2.2. Evaluation of Potential Surface Water Impacts Given the proximity of the Merrimack River to the Building 48 VOC plume, Roux Associates evaluated whether a Condition of Substantial Release Migration (SRM) exists n at the Site. Pursuant to 310 CMR 40. 0006, a Condition of SRM exists for "releases to the groundwater that have been or are within one year likely to be detected in a surface Lj water body, wetland, or public water supply reservoir." To evaluate the potential for a detectable VOC impact to the Merrimack River associated with the migrating Building 48 groundwater VOC plume, Roux Associates completed a series of conservative calculations to estimate potential VOC concentrations in the Merrimack River. Potential river VOC concentrations were based upon the volume of groundwater discharging into the river, the concentration of TCE detected upgradient of the river, and the volume of river water with which the TCE will mix. TCE was selected for these calculations as it is the VOC present in highest concentration in groundwater. The actual volume of river water in which the TCE will mix is less than the total volume F; ROUX ASSOCIATES, INC. - LUC77007M03.173/LR r; u Mr. Greg Vierkant July 28, 2003 Page 7 of river flow volume and is related to the velocity of the river and the size of the river (Fischer, 1973): F1 Lj QX = v H or f� where v river flow velocity; ii H = river depth; and, Q = mixing distance. Mixing distance (a) is related to dispersion as well as river flow velocity and the length of the river reach potentially intercepted by the plume: Ell Q = (D y/v) vz where D = dispersion coefficient; u y = length of the river reach potentially intercepted by the plume; and v = river flow velocity. n Data collected by the USGS in the vicinity of the Site since 1938 indicates an average river flow velocity of 2.67 feet per second (ft/sec) (USGS, 2003), while a review of the n site groundwater data indicates a length of potential impact of 360 feet. The depth of the Lj Merrimack River reach in the vicinity of the Site is unknown, but was conservablely assumed to average 5 feet. It should be noted that the average depth of the Merrimack n River at the USGS gauging station located approximately 9.5 miles southeast of the Site L' (Station ID 01100000) ranged from approximately 10 to 20 feet since 1938 (USGS, 2003). Based upon these parameters the mixing distance was calculated to be 10.5 feet n or about 49 times less than the river width (approximated to be 516 feet) in the vicinity of '-' Building 48. Based upon the calculated mixing distance and assumed depth of the river, a mixing river flow was estimated to be approximately 127 cubic feet per second (ft3/sec) or about 123 times less than the average river discharge observed by the USGS since 1938 at the USGS gauging station in (15,569 ft3/sec). Groundwater discharge, and mass loading to the river was based upon site specific information gathered in the vicinity of Building 48 as summarized below: r • Hydraulic conductivity (K) equal to 6 feet per day (ft/day); Li • Groundwater gradient (i) equal to 0.0248 (unitless); F1 • Saturated thickness (B) equal to 40 feet; and • Groundwater WE concentration equal to 8,800 gg/L, based upon the /> concentration observed in monitoring well MW -60S, which is the furthest downgradient well within the Building 48 VOC plume (approximately 420 feet upgradient of the Merrimack River). n ROUX ASSOCIATES, INC. LUC77007M03.173/LR n Mr. Greg Vierkant July 28, 2003 Page 8 h L� Using the results of the river calculations and the groundwater parameters and f "1 assumptions noted above, Roux Associates estimated the a TCE concentration for the IL, Merrimack River by dividing the mass flux into the river (i.e., TCE concentration multiplied by the groundwater flux into the river) by the river mixing flow. Using this approach and the stated assumptions, the estimated TCE concentration in the Merrimack River attributable to VOC migration from the Building 48 area, assuming no attenuation between the river and MW -60S was estimated to be 1.7 µg/L which is below the 2 µg/L n reporting limit for TCE identified by Resource Laboratories in the laboratory report for Li' the groundwater samples collected by Roux Associates and analyzed undiluted for VOCs using EPA Method 8260B [Attachment C]. Although the 1.7 µg/L calculated TCE concentration is likely detectable, albeit below the reporting limit, actual TCE levels in the Merrimack River are likely non-detectable due to. the conservative nature of the assumptions used by Roux Associates in the river calculations, including the following: n L • No TCE attenuation in groundwater between MW -60S and the river — A 90% reduction in TCE concentration is observed between source area well VHB-MW- 4 (84,000 µg/L) and the downgradient well MW -60S (8,800 µg/L) used in the feet 1 river calculations. These two wells are 312 feet apart while MW -60S is 400 from the Merrimack River. Accordingly, it is reasonable to expect much lower concentrations of TCE in groundwater immediately adjacent to the river. n 0 • Uniform TCE concentration with depth — The mass of TCE discharging into the river was based upon the assumption that 8,800 µg/L observed in MW -60S represented the concentration within the entire 40 foot saturated thickness. As discussed earlier (Section 2.1), TCE concentrations at depth were much lower than those used in the calculations. u Mixing into only 5 feet of river water — USGS data indicates that the Merrimack River averages 10 to 20 feet deep. Mixing into less water (i.e., depth) than �r actually exists would result in less dilution and higher concentrations. Alternatively, using a river depth of 10 feet (rather than the 5 -foot depth used in . the calculations) would result in a lower calculated TCE river concentration significantly lower than the method detection limit. Degradation, volatilization, and partitioning to sediments within the riverbed were • ignored. These factors would reduce the concentration within the river after discharge from groundwater. The approach described above over -predicts the actual impact to the river, and it can j therefore be concluded that a Condition of SRM does not exist at the Site. A spreadsheet detailing these calculations is provided as Attachment D. f LUC77007M03.173ILR ROUX ASSOCIATES, INC. [ k ( « ) \ § :\\ co \ ] co /§ ]co § ° in E ) . t . . . _ }\)j /0;¢ 0 �2E® . § 7k/ . 2§!k . \\\1 / C LL \} \ �0 t!%�t= - //f==LO . 227_( 04 CD | -CD EEEE -- @;e 2 m , ) ƒR\2 - ;f . )\E\ .E)cEE \ In \} }�� \\� § \\ \ \ k ° \ \ 04 \ \ / . f x Da x .c E fEx EE 9 1 )k\)) ~ ; � . t ; ; 2 ; ; 42 \ \ > _ } ) zk ƒ\ EE E'E \\ LO CD 0 CD CD 0 co a �.2c o00 X22 ��� a°2 �_=G >�_= • >| ) k 2 ƒ > - _ a ; \ ƒ . cm § ! _ ■` ) � { J { _ ƒ \ \ } « § _ \ _ § ) � ) \ ) (Ic ° . c ; ® x k� 2� 7\ )�}� j\/£3 § ) / - §\ )x �o o k£wk \ 2 ;} (\ \0 ®| k/ __&; {\$/\ ) a \ .2 a. 3. J, 3! / LU =o mT kE(D d w e w2 =o w� aJ ( « ) \ SOLUTIONS „ in r, WO is mm ® PRINTED ON RECYCLED PAPER i Weston Solutions, Inc. Suite 2 West 43 Constitution Drive Bedford, New Hampshire 03110 603-656-5400 • Fax 603-656-5401 • • ® www.westonsolutions.com The Trusted Integrator for Sustainable Solutions Y Office of Data Entry Massachusetts Department of Environmental Bureau of Waste Site Cleanup Northeast Regional Office 205B Lowell Street Wilmington, MA 01887 Re: Phase V — Inspection and Monitoring Report Former Merrimack Valley Works North Andover, Massachusetts MassDEP RTN: 3-00174 Dear Sir/Ms.: CrT 1 TM --r I H ANDOVER HEALTH DEPARTMENT / b DO C:>5 U -4 8 October 2009 Work Order No. 11621.039.001 Weston Solutions, Inc. (WESTO^ is submitting the attached Phase V — Inspection and Monitoring Report on behalf of Lucent Technologies, Inc. for the areas associated with RTN 3-00174 of the Merrimack Valley Works in North Andover, Massachusetts. This submittal includes: ■ Comprehensive Response Action Transmittal Form (BWSC-108). ■ Remedial Monitoring Reports (BWSC-108A and BWSC-108B) for four remediation systems in operation at this site. ■ Phase V — Inspection and Monitoring Report (includes a CD with the full document including Appendices). By copy of this letter, the attached document has been submitted to the Selectman's Office and the Board of Health for the City of North Andover, Massachusetts. If you have any questions or comments regarding this submittal, please do not hesitate to contact me at (603) 656-5412. Very truly yours, )MVSTON SOLUTIONS, OLUTI NS, INC. Frederick R. s, P. . Project Man FRS:kmc cc: G. Fisher, Alcatel -Lucent Ellen Keller, Ozzy Properties F. Lilley, Golder Associates Board of Health, Town of North Andover Selectman's Office, Town of North Andover an employee -owned company GAPROJECTS\11621039\0&M_and_Monitoring\O&M_Rcports\Apri106-DecOSReport\cover letter.docz ti« s�