PERMANENT SOLUTION STATEMENT. Hydraulic Oil Release 68 Hopkinton Road Westborough, Massachusetts

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2 PERMANENT SOLUTION STATEMENT Hydraulic Oil Release 68 Hopkinton Road Westborough, Massachusetts Release Tracking Number: CHES Job No.: TABLE OF CONTENTS INTRODUCTION... 1 SITE SETTING... 2 RESPONSE ACTIONS... 2 RISK CHARACTERIZATION... 2 DATA USABILITY ASSESSMENT & REPRESENTATIVENESS EVALUATION... 4 CONCLUSION... 4 PUBLIC NOTIFICATION... 5 FIGURES Figure 1 Figure 2 Figure 3 Locus Map Aerial Photograph MA DEP Bureau of Waste Site Cleanup Phase 1 Site Assessment Map APPENDICES Appendix A DEP Transmittal Forms Appendix B Site Photographs Appendix C Uniform Hazardous Waste Manifest Appendix D Municipal Notification Letters.

3 Clean Harbors Environmental Services, Inc. 42 Longwater Drive P.O. Box 9149 Norwell, MA PERMANENT SOLUTION STATEMENT Hydraulic Oil Release 68 Hopkinton Road Westborough, Massachusetts DEP Release Tracking Number: CHES Job No.: INTRODUCTION On October 3, 2014 at approximately 2:30 PM, a release of an estimated 22 gallons of hydraulic oil occurred at the E.L. Harvey & Sons (E.L. Harvey) facility located at 68 Hopkinton Road in Westborough, Massachusetts (Figure 1). The release occurred when one of two hydraulic oil circulation valves on a trailer was inadvertently left open by a driver, which resulted in the overflow of hydraulic oil onto pavement surfaces at the facility as the truck traveled along the roadway while moving the trailer. The oil is used to run the hydraulic system and ram on the push-out trailer when the hydraulic lines from the tractor (truck) are connected. The oil was released to the asphalt pavement and reclaimed asphalt pavement (RAP) surfaces at the 68 Hopkinton, Westborough property, and the adjoining Wood Street, Hopkinton property that is also part of the E.L. Harvey facility. The release was confined to pavement and did not impact any nearby storm drains or other underground utilities. The release area is shown on the Aerial Photograph presented as Figure 2. In response to the release, E.L. Harvey spread absorbent materials (saw dust) and subcontracted a road sweeper service to contain and collect the released oil. E.L. Harvey also contracted Clean Harbors Environmental Services, Inc. (CHES) to direct the cleanup, dispose of the remedial waste and provide Licensed Site Professional (LSP) services for the release. Based on the results of the IRA, CHES has prepared this Permanent Solution Statement (PSS) to document the IRA and the resulting site conditions. Copies of the PSS Transmittal Form (BWSC104) and the Release Notification Form (BWSC103) for the release, to be submitted electronically, are presented in Appendix A.

4 Hydraulic Oil Release, 68 Hopkinton Road, Westborough - PSS RTN No.: Page 2 of 5 SITE SETTING The release occurred between Building 6 in Hopkinton and Building 5 in Westborough on the asphalt and RAP roadway surfaces. The area surrounding the facility is mixed residential/ industrial and the nearest residence is located approximately 250 feet south of the southern-most portion of the release area on Wood Street in Hopkinton. No utilities were identified within the release site. RESPONSE ACTIONS Upon discovery of the release at approximately 2:30 PM, E.L. Harvey personnel spread saw dust on the impacted pavement surfaces to absorb the released oil. The area of impact measured approximately 0.6 miles long by two to four inches wide between the origination location just north of Building 6 in Hopkinton, to the ending location just west of Building 5 in Westborough (see Figure 2). E.L. Harvey thereafter contracted CHES to respond and assist with the cleanup, dispose of the spent absorbent materials and provide Licensed Site Professional (LSP) services for the release. The hydraulic oil reservoirs on both the trailer and tractor were topped off with 22 gallons of hydraulic oil such that the release quantity was determined to be approximately 22 gallons. At the request of E.L. Harvey, CHES notified the Massachusetts Department of Environmental Protection (DEP) of the release of an estimated 22 gallons of hydraulic oil at approximately 3:10 PM. The DEP issued release tracking number (RTN) for the release and granted verbal approval to conduct IRA activities including the application and removal of absorbent materials to the release area, proper disposal of the spent absorbents and assessment of site conditions. The Hopkinton Fire Department (HFD) and Westborough Fire Department (WFD) were both notified of the release, but neither responded to the site. The saw dust and other loose materials on the surfaces were collected with a contracted sweeper and placed into a roll-off container staged at the site pending disposal. The entire release area was inspected after cleaning of the pavement surfaces and there was little or no staining, and there were no cracks or seams observed that could provide a migratory pathway for the released oil to impact the underlying soil or groundwater. Photographs taken after the cleanup on October 6 th are presented as Appendix B. On October 13, 2014, a total of approximately four tons of spent absorbents (sawdust) was transferred from the roll-off into a CHES vacuum truck (Guzzler) and transported to Clean Harbors of Braintree, Inc. in Braintree, Massachusetts for disposal under a Uniform Hazardous Waste Manifest (Manifest Tracking Number FLE). A copy of the manifest is included as Appendix C. RISK CHARACTERIZATION The Massachusetts Contingency Plan (MCP) requires that a level of No Significant Risk be achieved to satisfy the closure criteria for a Permanent Solution. To achieve a level of No Significant Risk, the response actions must restore the release area to background conditions or meet the applicable risk standards. Since no soil or groundwater was impacted, and the Clean Harbors Environmental Services, Inc.

5 Hydraulic Oil Release, 68 Hopkinton Road, Westborough - PSS RTN No.: Page 3 of 5 pavement surfaces were cleaned, the release site was restored to background conditions. Details of the risk characterization are presented below. Human and Environmental Receptors The release occurred at the E.L. Harvey facility located at 68 Hopkinton Road in Westborough. The site is located in a solid waste recycling facility that is bordered to the north and east by undeveloped land, the south by Route 90 and the west by Hopkinton Road and Wood Street. No schools or recreational facilities are located within 500 feet of the release, and the nearest residential property is located approximately 250 feet south of the release area on Wood Street in Hopkinton. Based on current and future use of the site as a recycling facility, potential human receptors would include adult workers at the facility. However, since the response actions conducted remediated the impacted pavement surfaces, no exposure to the released hydraulic oil currently exists at the site. According to the MassDEP Bureau of Waste Site Cleanup Phase 1 Site Assessment Map attached as Figure 3, the site is located both east and west of Piccadilly Brook, the closet surface water body and a Perennial Stream. Figure 3 and the Locus Map (Figure 1) are centered on the town line between Westborough and Hopkinton, and the site extends approximately 550 feet to the northwest and 900 feet to the south as shown on the aerial photograph (Figure 2). Additional water features (Freshwater Wetlands and FEMA 100yr Floodplain) associated with Piccadilly Brook are located within and closely adjacent to the site. In addition, certified and potential vernal pools are located inside one-half mile of the site. A Public Water Supply Zone II is located approximately 1,000 feet to the southeast of the site in Hopkinton. A second Public Water Supply Zone II is located approximately 1,800 feet northwest of the site in Westborough. A Medium Yield Aquifer is also located within 500 feet to the east of the site in Hopkinton. A portion of the site is located within an ACEC, and there a several protected open spaces located within one-half mile of the site. The closest is associated with Piccadilly Brook and is located only a few feet north and east of the site. None of these receptors were impacted by the release, and no other environmental receptors were identified within the release area. Soil and Groundwater Exposure Categories The MCP requires that the soil and groundwater at the site be categorized as potential exposure pathways. Three exposure categories (S-1, S-2, and S-3) are possible for soil and are determined by the accessibility of the soil and the frequency/intensity of site use by adults and children. The site soils are located below the pavement and are considered potentially accessible soil. Based on the high frequency and low intensity of site use by adults (children are not present), the site soils are categorized as S-3. However, the site soils were not impacted by the release. No other soil categories apply to the site. As with soil, three exposure categories exist for groundwater (GW-1, GW-2, and GW-3) and are based on groundwater as a potential exposure pathway via drinking water (GW-1), indoor air (GW-2), and surface water (GW-3). To determine the groundwater exposure category for the site, CHES conducted a review of the MassDEP Bureau of Waste Site Cleanup Phase 1 Site Assessment Map (Figure 3). As shown on Figure 3, the site is not located within a Zone 2, an Clean Harbors Environmental Services, Inc.

6 Hydraulic Oil Release, 68 Hopkinton Road, Westborough - PSS RTN No.: Page 4 of 5 Interim Wellhead Protection Area or any other drinking water source area. Additionally, no private drinking water wells are located within 500 feet of the site according to the water departments for both Westborough and Hopkinton. As such, groundwater category GW-1 does not apply to the site. Groundwater category GW-2 also does not apply to the site, because no portion of the release area is located within 30 feet of an occupied building. Groundwater category GW-3 does apply to the site, because all groundwater is considered a source for discharge to surface water. Groundwater was not impacted by the release. Risk to Human Health and the Environment Response actions completed at the site included the application of saw dust on the pavement surfaces to recover the released oil. Neither soil nor groundwater was impacted by the release. As such, the site was restored to pre-existing (background) conditions, and a Condition of No Significant Risk with respect to human health, public welfare and the environment has been achieved. Risk to Public Safety As defined in Section of the MCP, potential impacts to public safety must be characterized relative to the release. Following the release, E.L. Harvey personnel responded by collecting the released oil with absorbents, returning the site to a level of No Significant Risk. Although some oil staining remains present on the impacted pavement surfaces, it will likely fade with time. Inspection of the site indicated no hazards or other conditions associated with the release that posed a threat to public safety. All remedial waste resulting from the IRA has been removed from the site, and there are no uncontained materials or any other conditions attributable to the release remaining at the site that could pose a threat of physical harm or bodily injury to humans. As such, a condition of No Significant Risk has been achieved for the site with regard to public safety. DATA USABILITY ASSESSMENT AND REPRESENTATIVENESS EVALUATION Most of the components normally discussed in the representativeness evaluation and data usability assessment are not applicable to this release. During the response, the limits of the release were clearly defined by visual observations of hydraulic oil present on the pavement surfaces. As such, visual indications of oil guided the response. Once the pavement surfaces were cleaned, no further response was warranted and the response was concluded. Since there is no evidence that soil or groundwater was impacted by the release, no sampling or laboratory analysis was conducted. Following the response only a stain remained on the paved surfaces. CONCLUSION At approximately 2:30 PM on October 3, 2014, a release of approximately 22 gallons of hydraulic oil occurred at the E.L. Harvey facility located at 68 Hopkinton Road in Westborough, Massachusetts. The release occurred when one of two hydraulic oil circulation valves on a trailer was inadvertently left open by a driver, which resulted in the overflow of hydraulic oil onto pavement surfaces at the facility as the truck traveled along the roadway while moving the trailer. The oil is used to run the hydraulic system and ram on the push-out trailer when the Clean Harbors Environmental Services, Inc.

7 Hydraulic Oil Release, 68 Hopkinton Road, Westborough - PSS RTN No.: Page 5 of 5 hydraulic lines from the tractor (truck) are connected. The oil was released to the asphalt pavement and reclaimed asphalt pavement (RAP) surfaces at the 68 Hopkinton, Westborough property, and the adjoining Wood Street, Hopkinton property that is also part of the E.L. Harvey facility. Response actions conducted at the site included the application of saw dust to collect the released oil. No storm drains or other underground utilities were impacted by the release. A total of four tons of spent absorbents were generated during the response actions. At the completion of the response actions, no hydraulic oil remained on the pavement, and only staining remained that will fade over time. The impacted pavement was inspected and determined to be in good condition with no evidence of seams, cracks or damaged areas that could serve as pathways for the subsurface migration of released oil. As such, the site was restored to pre-existing (background) conditions. Therefore, a Permanent Solution with No Conditions has been achieved at the site, and no further response actions are required. PUBLIC NOTIFICATION As required by 310 CMR , written notification of this RAO and a copy of the Release Notification Form (BWSC103) have been forwarded to the Town Manager s Office and Board of Health for the Town of Westborough, and the Board of Selectmen s Office and Board of Health for the Town of Hopkinton. The release site is owned by E.L. Harvey, such that an Informational Notice to Property Owners (BWSC122) is not required. Copies of the public notification letters are presented as Appendix D. Clean Harbors Environmental Services, Inc.

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11 MassDEP Phase 1 Site Assessment Map Page 1 of 1 10/15/2014 Site Information: HYDRAULIS OIL RELEASE 68 HOPKINTON ROAD WESTBOROUGH, MA NAD83 UTM Meters: mN, mE (Zone: 19) October 15, 2014 MassDEP - Bureau of Waste Site Cleanup Phase 1 Site Assessment Map: 500 feet & 0.5 Mile Radii The information shown is the best available at the date of printing. However, it may be incomplete. The responsible party and LSP are ultimately responsible for ascertaining the true conditions surrounding the site. Metadata for data layers shown on this map can be found at: m 1000 ft

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26 Photograph 1: View of roadway pavement after cleanup at Building 6 at the E.L. Harvey, Westborough Facility facing southeast (photograph taken on October 6, 2014). Photograph 2: View of roadway pavement after cleanup at the E.L. Harvey, Westborough Facility facing northwest (photograph taken on October 6, 2014).

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