Memorandum. Rian Amiton; City of Brockton Planning Department. John McRobbie and Thomas Biolsi; TRC Environmental Corporation

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1 TRC Wannalancit Mills 650 Suffolk Street Lowell, Massachusetts Main Fax Memorandum To: From: Subject: Rian Amiton; City of Brockton Planning Department John McRobbie and Thomas Biolsi; TRC Environmental Corporation Preliminary Evaluation of Potential Remediation Activities and Estimated Remedial Costs Corcoran Building 308 Montello Street Brockton, Massachusetts Date: February 8, 2012 CC: Matthew Robbins; TRC Environmental Corporation This memorandum was prepared by TRC Environmental Corporation (TRC) at the request of the City of Brockton (the City ) to present a preliminary evaluation of future assessment and remediation activities and costs which may be required at the Corcoran property located at 308 Montello Street in Brockton, Massachusetts (the Site ) during redevelopment. The following sections are included in this Memorandum: Site Description and Background, Past Environmental Investigations, Known and/or Potential Environmental Conditions, Recommended Additional Site Characterization Activities, Potential Remediation Activities, and Estimated Characterization and Remedial Costs. Please note that this preliminary evaluation was based upon existing and available data at the time of evaluation. If additional information becomes available in the future, the recommended additional characterization activities and potential remedial activities may change to reflect this new information. As such, the estimated characterization and remedial costs presented herein are intended to represent an order-of-magnitude cost for each characterization and remedial option and are to be used for relative comparison purposes only. Site Description and Background The Site consists of one rectangular-shaped acre lot located at 308 Montello Street between White Avenue and Bolton Place in Brockton, Massachusetts (see Figure 1 for a Site Location Map). The Site is developed with a three-story warehouse and a single-story office building, both of which are currently used by the Brockton School Department s facilities/custodial staff. The buildings were ENVIRONMENTAL ENERGY INFRASTRUCTURE

2 constructed in A concrete loading dock area is located on the west-central side of the warehouse building to the south of which is located a single-story three bay garage. Historically, the Site was occupied by residential structures and a lumber yard until at least In 1915, the current warehouse building was constructed and was occupied by the E.C. Hall Wholesale Grocer. The Corcoran Supply Company occupied the Site between approximately 1930 and During this time, the office building addition was constructed. The Site has been used by the School Department as an annex for the storage of school equipment and supplies since the early 1990s. Past Environmental Investigations Five environmental investigations have been conducted at the Site, and include: ASTM Phase I Environmental Site Assessment, Former Corcoran Supply Site, 308 and 0000 Montello Street, Brockton, MA, prepared by TRC Environmental Corporation, dated November ASTM Phase II Environmental Site Assessment, Former Corcoran Supply Site, 308 Montello Street, Brockton, MA, prepared by TRC Environmental Corporation, dated January ASTM Phase I Environmental Site Assessment, Corcoran Building, 308 Montello Street, Brockton, MA, prepared by TRC Environmental Corporation, dated July Pre-Renovation Investigative Survey Report For Hazardous Building Materials, Corcoran Supply Building, 308 Montello Street, Brockton, MA, prepared by TRC Environmental Corporation, dated September Limited Subsurface Investigation, Corcoran Site Parcel , 308 Montello Street, Brockton, MA, prepared by TRC Environmental Corporation, Draft dated February 2, Phase I Environmental Site Assessment Based on the findings of TRC s 2002 Phase I Environmental Site Assessment (ESA), two recognized environmental conditions (RECs) were identified in connection with the Site. Specifically, the following RECs were identified: The potential presence of one 200-gallon gasoline UST installed in the southern portion of the loading dock area in 1920; and The potential presence of one 1,000-gallon gasoline UST which was reportedly installed below the garage in the southern portion of the Site in The Phase I report also identified the presence of an 800-gallon vaulted aboveground storage tank (AST) containing No. 2 fuel oil located in the basement of the warehouse building. Due to access limitations, TRC was unable to evaluate the tank s condition. Based on assessment findings, TRC recommended: 1) decommissioning and/or removing the potential on-site USTs; 2) assessing subsurface environmental conditions at the Site related to the UST; and 3) assessment of subsurface conditions in the vicinity of the vaulted AST prior to redevelopment of the Site. Page 2 of 8

3 Phase II Environmental Site Assessment On April 8, 2003, a geophysical survey was conducted at the Site by Hager GeoScience, Inc. of Woburn, Massachusetts as part of a Phase II ESA. During the survey, ground-penetrating radar (GPR) techniques were used to search for evidence of subsurface anomalies historically reported and/or suspected below the Site. These areas included the Exterior Loading Dock Area and the Garage Area (Interior Loading Dock Area and main Garage Area). Survey results identified the following: Two suspect USTs on the southern and western portions of the Site as shown on the Site Plan provided as Figure 2. The location of a suspected 1,000-gallon gasoline UST was detected on the southern side of the Site within the Garage Area with the geophysical anomaly measuring approximately 7 x 5 feet. An anomaly measuring approximately 9 x 4 feet in size was identified on the western side of the Site within the Exterior Loading Dock Area which was attributed as being a reported 200-gallon gasoline UST. An additional buried object was identified adjacent to the Interior Loading Dock in the southwestern portion of the Site; however, due to Site constraints at the time of the geophysical survey, the size and nature of the buried object located could not be accurately measured. To date, no further action has been taken in regards to the January 2004 Phase II ESA report. It should be noted that during the 2002 Phase I ESA, TRC estimated that the vaulted AST was approximately 1,000 gallons in capacity. During Phase II assessment activities, TRC confirmed the tank s capacity to be 800 gallons. Phase I Environmental Site Assessment In July 2011, TRC conducted a second Phase I ESA for the Site and determined that the recommendations made in the original Phase I ESA had not yet been addressed. Based on the findings of the 2011 Phase I ESA, TRC concluded that the following REC existed in connection with the Site: The current storage of petroleum, the existence of out-of-service USTs, and the presence of an unknown buried object. Hazardous Building Materials Survey In August 2011, TRC conducted a hazardous building materials survey to evaluate the presence of asbestos-containing materials (ACM), lead-based paint (LBP) and other hazardous/regulated materials throughout the Site building that will require disposal prior to future building renovation activities. No exploratory demolition was conducted as part of the building survey. Based upon the results of the hazardous building materials inspection, ACM, LBP and additional hazardous/regulated materials were determined to be present in various building materials throughout the Site building. The results of the survey and estimated quantities of ACM and LBP are documented in the Pre-Renovation Investigative Survey Report For Hazardous Building Materials, dated September Page 3 of 8

4 Site Investigation On December 6, 2011, TRC oversaw the excavation of a test pit within the Interior Loading Dock Area in the southwestern portion of the Site building to determine the nature of the buried object Identified by the geophysical survey in Since the investigation was funded by an EPA Brownfields Hazardous Substance Assessment Grant through the City of Brockton, the portion of the REC identified in the 2011 Phase I ESA associated with petroleum (i.e., the current storage of petroleum and the existence of out-of-service petroleum USTs) was not able to be addressed. Test pit excavation activities resulted in the identification of a 6-inch diameter cast iron sewer drain line which transected the excavation from northeast to southwest at a depth of approximately 14 inches below grade. Final dimensions of the test pit excavation area measured approximately 8 feet by 7 feet by 1.5 feet deep. Groundwater was not encountered and no environmental sampling was conducted. During field screening activities, no stained soils were encountered and no VOCs were detected by the PID. During excavation activities on December 6, 2011, TRC also inspected and gauged three existing on- Site monitoring wells (MW-1 through MW-3) in preparation for potential groundwater sampling (contingent upon test pit results). Each of the wells appeared viable for sampling and in good overall condition. PID well mouth readings indicated 751 and 657 ppm/v in monitoring wells MW-1 and MW-2, respectively.. As requested by the City, groundwater samples were not collected or analyzed as part of TRC s investigation. The results of this field effort were documented in TRC s Draft Site Investigation Summary Letter Report, dated February 2, Known and/or Potential Environmental Conditions The following environmental conditions are either known to exist or have the potential to exist based on existing information and may impact redevelopment activities at the Site: Building Construction Materials & Hazardous/Regulated Items Confirmed presence of ACM on the interior and exterior of the Site building. Potential presence of additional ACM in the Site building in areas inaccessible to TRC during the August 2011 hazardous building materials survey. Confirmed presence of LBP on the interior and exterior of the Site building. Potential presence of polychlorinated biphenyls (PCBs) in building construction materials at the Site which may be subject to regulatory waste disposal requirements. Confirmed presence of additional hazardous/regulated materials within the Site building including universal waste fluorescent bulbs (potentially containing mercury), fluorescent light fixture ballasts (potentially containing PCBs), thermostats containing mercury ampoules, fire extinguishers containing waste chemical solid, air handling units (potentially containing PCB Page 4 of 8

5 capacitors and refrigerants), and other universal wastes such as used electronic devices (i.e., printed circuit boards, among others). Subsurface Conditions Potential soil and/or groundwater contamination and vapor intrusion issues within the Site building resulting from a potential release(s) associated with o an 800-gallon vaulted AST containing No. 2 fuel oil located in the basement of the warehouse building; o a 200-gallon gasoline UST located on the western side of the Site within the Exterior Loading Dock Area; o a 1,000-gallon gasoline UST located on the southern side of the Site within the Garage Area; Elevated concentrations of volatile organic vapors detected in the headspace of wells MW-1 and MW-2. Recommended Additional Characterization and Remediation Activities To better understand how the known or potential environmental conditions at the Site may impact redevelopment, TRC recommends the below additional site characterization and remediation activities: Management of Building Construction Materials & Hazardous/Regulated Items Should regulated building construction materials (i.e., ACM, LBP, or PCBs) and/or other hazardous items (as documented in the Pre-Renovation Investigative Survey Report For Hazardous Building Materials, dated September 2011) be disturbed during future renovation or demolition activities, these materials should be managed as regulated waste in accordance with applicable local, state, and federal regulations. Prior to the removal of these materials, abatement costing and abatement/compliance specifications should be prepared by a Massachusetts DOS certified Project Designer. Additional Site Characterization and Remedial Investigations Conduct an inspection and/or testing of the 800-gallon No. 2 fuel oil AST system located in the basement of the Site building to assess the structural integrity of the tank and estimate the system s remaining useful life. Should leaks be identified, repair the leaking components and retest the system to confirm the repairs were successful and no additional leaks are occurring; Decommission the suspected 200-gallon gasoline UST on the western side of the Site within the Exterior Loading Dock Area in accordance with MassDEP published guidance WSC-#96-402: Underground Storage Tank Closure Assessment Manual. Decommissioning activities should be conducted by a qualified tank removal contractor under the direction of a Massachusetts Licensed Site Professional (LSP); Page 5 of 8

6 Decommission the suspected 1,000-gallon gasoline UST located on the southern side of the Site within the Garage Area in accordance with MassDEP published guidance WSC-#96-402: Underground Storage Tank Closure Assessment Manual. Decommissioning activities should be conducted by a qualified tank removal contractor under the direction of a LSP; Redevelop the three existing on-site monitoring wells (MW-1 through MW-3) to remove fines and prepare the wells for groundwater sampling; Collect and analyze groundwater samples via EPA low-flow sampling method from three on- Site monitoring wells (MW-1 through MW-3) to assess groundwater quality beneath the Site. Samples should be submitted for volatile petroleum hydrocarbons (VPH) and extractable petroleum hydrocarbons (EPH) analyses; and Collect and analyze sub-slab soil gas samples from beneath the concrete floor of the Site building if the results of the groundwater samples are above the MCP Method 1 GW-2 cleanup standards. Soil gas results will be used to evaluate if a migration pathway for volatile organic vapors is present from groundwater to indoor air. Soil gas samples should be submitted for air phase hydrocarbon (APH) analysis. Estimated Characterization and Remedial Costs The following table summarizes the estimated costs related to additional Site characterization and potential remedial activities discussed herein. The costs do not include abatement or demolition costs of the existing on-site building, associated permitting, potential MCP-reporting obligations, or activities not discussed herein. Table 1: Estimated Characterization and Remedial Costs Summary Table Building Construction Materials & Hazardous/Regulated Items Activity Abatement Plans/Compliance Specifications Estimated Comments Comparison Cost $5,000-$10,000 Prepared by a Massachusetts DOS certified Project Designer prior to redevelopment activities in preparation for ACM, Lead, and OHM Abatement and OSHA safety compliance. Asbestos Abatement TBD Completed by a licensed asbestos removal contractor as part of redevelopment in accordance with applicable state and federal abatement/disposal regulations. Estimated cost based upon future use of Site building. Lead Abatement TBD Completed by a licensed lead removal contractor as part of redevelopment in accordance with applicable state and federal abatement/disposal regulations. Estimated cost based upon future use of Site building. Page 6 of 8

7 Table 1 (continued): Estimated Characterization and Remedial Costs Summary Table Building Construction Materials & Hazardous/Regulated Items Activity Additional Hazardous/Regulated Materials Abatement Additional Building Materials Sampling* Estimated Comparison Cost TBD Comments Remove additional hazardous/regulated materials from within the Site building as part of redevelopment and manage in accordance with applicable local, state, and federal regulations. < $5,000 TCLP Lead: Collect a representative composite building material sample(s) of the projected waste stream from the building for TCLP lead analysis prior to redevelopment activities to determine applicable waste disposal requirements. PCBs-In-Caulking: Perform bulk sample collection of exterior building caulking for PCB analysis prior to redevelopment activities to determine whether the material is regulated for disposal under EPA TSCA PCB standards. Notes: * - Assumes all PCB results will be identified at concentrations below 50ppm and no PCB abatement will be warranted. Should PCB results be identified at concentrations above 50ppm, additional characterization and preparation of an abatement and specification plan will be required and disposal of PCB-containing materials will be regulated under EPA TSCA PCB standards. TCLP Toxicity Characteristic Leachate Procedure TSCA Toxic Substance Control Act PCB Polychlorinated biphenyls TBD To be determined Table 2: Estimated Characterization and Remedial Costs Summary Table Site Characterization and Remedial Investigations Activity Estimated Comparison Cost Comments Additional Site Characterization and Potential Remediation Activities 800-gallon fuel oil AST Inspection/Testing $2,000 - $5,000 Although not required under regulation, as part of best management practice, TRC recommends removing the sand surrounding the AST and examining the removed sand, tank shell, and underlying surface for visual/olfactory evidence of leaks or spill. Should impacts to the sand be identified, TRC recommends managing and disposing the impacted media as regulated waste in accordance with applicable state and federal regulations. Page 7 of 8

8 Table 2 (continued): Estimated Characterization and Remedial Costs Summary Table Site Characterization and Remedial Investigations Estimated Activity Comments Comparison Cost 200-gallon gasoline UST $2,000 - $5,000 MassDEP regulations state that USTs which Decommissioning have been out of service for six months or more must be properly removed. The 200- gallon gasoline UST has been out of service for over six months, and therefore should be promptly removed in accordance with MassDEP guidance. Conduct confirmatory soil sampling and groundwater sampling as 1,000-gallon gasoline UST Decommissioning Monitoring Well Development and Groundwater Sampling warranted. $5,000 - $15,000 MassDEP regulations state that USTs which have been out of service for six months or more must be properly removed. The 1,000- gallon gasoline UST has been out of service for over six months, and therefore should be promptly removed in accordance with MassDEP guidance. Conduct confirmatory soil sampling and groundwater sampling as warranted. $5,000 To facilitate the sale and/or redevelopment of the Site, redevelop existing on-site wells (MW-1 through MW-3) to remove fines and prepare the wells for groundwater sampling. Complete one round of groundwater sampling via low-flow sampling methods at each of the wells. Samples to be submitted for VPH and EPH analyses. Vapor Intrusion Assessment $5,000 - $10,000 To facilitate the sale and/or redevelopment of the Site, collect and analyze sub-slab soil gas samples from beneath the concrete floor of the Site building if the results of the groundwater samples are above the MCP Method 1 GW-2 cleanup standards. The soil gas results will be used to evaluate if a migration pathway for volatile organic vapors is present from groundwater to indoor air. Soil gas samples should be submitted for APH analysis. The estimated characterization and remedial costs presented above are intended to represent an orderof-magnitude cost for each characterization and remedial option and are to be used for relative comparison purposes only and is not a price proposal by TRC to perform the work. Attachments: Figure 1 Site Location Map Figure 2 Site Plan Page 8 of 8

9 Site Location Approximate Site Location Brockton and Whitman 7.5-Minute USGSTopographic Quadrangle R:\Projects\GIS_2011\182985_Brockton\MXD\Fig1_Brockton_ mxd 0 1,000 2,000 Feet Massachusetts Site Location FIGURE 1 Wannalancit Mills 650 Suffolk Street Lowell, MA SITE LOCATION MAP PARCEL CORCORAN BUILDING 308 MONTELLO STREET BROCKTON, MASSACHUSETTS JUNE 2011

10 John Page Electrical Service (Commercial Office) 285 Montello St WHITE AVENUE Vacant City Owned Land (Parcel ) Warehouse 31 Perkins St Vacant Undeveloped City Owned Lot (297 Montello St) Approximate Location of Fuel Oil Fill and Vent Pipes Warehouse 41 Perkins St Approximate Location ofreported 200-gallon Gasoline UST Vacant Undeveloped City Owned Lot Approximate Location of Vaulted 800-Gallon No. 2 Fuel Oil Storage Tank BOLTON PLACE Approximate Location of Reported 1,000-gallon gasoline UST R A I L R O A D Parking Lot 24 Parkins St Residence MONTELLO STREET Vacant Storage/Commercial Space (Former Lumber Supply Company) 336 Montello St OVERVIEW MAP Historic MGP Facility 208 Montello St CRESCENT STREET Former Magic Chemical 121 Crescent St RTN: 4-47 MAIN STREET WHITE AVENUE MONTELLO STREET Residence Approximate Site Boundary Former Rail Line MassGIS 30cm Ortho Imagery, 2009 Active Rail Line Approximate Groundwater Flow Direction 0 50 Feet R:\Projects\GIS_2011\182985_Brockton\MXD\Fig2_Brockton_135074_ mxd Massachusetts Site Location FIGURE 2 SITE PLAN Wannalancit Mills 650 Suffolk Street Lowell, MA PARCEL CORCORAN BUILDING 308 MONTELLO STREET BROCKTON, MASSACHUSETTS JULY 2011