MASSACHUSETTS CONTINGENCY PLAN REMEDY OPERATION STATUS OPINION

Transcription

1 273 West Main Street, Norton, MA Tel: (508) Fax: (508) MASSACHUSETTS CONTINGENCY PLAN REMEDY OPERATION STATUS OPINION CITGO BULK STORAGE TERMINAL 385 QUINCY AVENUE BRAINTREE, MASSACHUSETTS MassDEP RTN , TIER 1B PERMIT # November 13, 2008 Prepared for: CITGO Petroleum Corporation 385 Quincy Avenue Braintree, Massachusetts Prepared by: Environmental Strategies & Management, Inc. 273 West Main Street Norton, MA ES&M Project No

2 RTN Page i CONTENTS 1.0 INTRODUCTION Background Purpose CURRENT SITE STATUS BELD Area BELD Area BELD Areas 3 and BELD RAM ACTIVITES CITGO Terminal Area I CITGO Terminal Area II (Off-Site Area) CITGO Terminal Area III Dunkin Donuts IRA LSP OPINION...8 FIGURES 1 Site Map CITGO Terminal Area I 2 Site Map CITGO Terminal Area II 3 Site Map CITGO Terminal Area III 4 Site Map BELD

3 RTN Page INTRODUCTION On behalf of CITGO Petroleum Corporation (CITGO), Environmental Strategies & Management, Inc. (ES&M) presents this Remedy Operation Status (ROS) Opinion for the CITGO Bulk Storage Terminal (the Terminal) located at 385 Quincy Avenue in Braintree, Massachusetts. This ROS Opinion is being submitted in accordance with the Massachusetts Contingency Plan (MCP), 310 CMR This ROS Opinion has been prepared to certify that all portions of the Terminal, and its associated off-site areas (collectively referred to as the Site ) now qualify for ROS. The Terminal site was first listed as a confirmed priority disposal site on January 15, The Site was classified as a Tier 1B Site on November 15, Extensions of the Tier 1B permit were granted by the Massachusetts Department of Environmental Protection (MassDEP) in February 2000, March 2002, October 2004, and November ES&M has provided CITGO with environmental services at the Terminal since 2001, and at the associated off-site areas since The various areas of the Site, as explained below, have either reached regulatory closure or are in Phase V of the MCP. The Licensed Site Professional (LSP) responsible for ensuring that Phase V activities conform with the applicable requirements and deadlines set forth in 310 CMR for the operation, maintenance, and monitoring of the Comprehensive Response Actions is Mr. Douglas Heely of ES&M (LSP #9632). 1.1 Background The Site, which is regulated under release transaction number (RTN) , includes the 60+ acre bulk petroleum storage facility, and portions of the Braintree Electric Light Department (BELD) facility located east of the Terminal. The area west of the Terminal, known as the Mala/Quirk area, was also previously considered part of the Terminal Site. For a variety of reasons, these areas of the Site have been reported separately. Hence, separate Phase reports have been submitted for each area. Figure 1 shows the western portion of the Terminal including the loading rack area (known as Area I), and Figure 2 shows the Mala/Quirk Area (Area II). Figure 3 shows the remainder of the Terminal (known as Area III). Figure 4 shows the off-site BELD property which is further divided into four different Areas (Areas 1, 2, 3 and 4) based on historical refinery impact and risk characterization. CITGO Terminal Area I is predominantly asphalt covered and consists of the Terminal office building and garage, and truck loading rack located along Quincy Avenue. The CITGO Terminal was first listed as a confirmed disposal site by the MassDEP as a result of a 1978 release of petroleum in the loading rack area near Quincy Avenue. Ongoing Phase V activities in Area I include operation of groundwater pumping and LNAPL recovery system, and seasonal operation of a soil vapor extraction system. Area II includes the Mala/Quirk properties west of the Terminal. Area II is predominantly paved, and currently houses a pre-owned automobile dealership owned

4 RTN Page 2 by Daniel Quirk. Groundwater extraction, LNAPL recovery, and soil vapor extraction systems operated at Area II between 2001 and 2003 to remediate petroleum impact related to the 1978 release at the loading rack. An A-3 RAO-P for Area II was filed with the MassDEP in June Area III comprises the tank storage portion of the facility, and includes a series of above ground petroleum storage tanks ranging in capacity from 2,000 gallons to 5 million gallons; several warehouse buildings; and a pier and loading dock along the Weymouth Fore River. The above ground tanks predominantly store gasoline, No. 2 fuel oil, low sulfur diesel, kerosene, and ethanol. Petroleum products, received by ocean tanker or barge, are stored in above ground storage tanks and are distributed by tanker trucks filled at the loading rack in Area I. LNAPL is periodically detected in several scattered Area III monitoring wells (i.e., extensive, contiguous plumes are not observed). Manual bailing is employed to recover LNAPL from these select wells. LNAPL recovery activities are performed on at least a quarterly basis in Area III at the Terminal. BELD Area 1 refers to an area that overlaps the BELD and CITGO properties south of the BELD utility switchyard, where tar-like material and viscous light non-aqueous phase liquid (LNAPL) were present. A soil removal program was completed to remove tar-like material that had seeped through the paved parking area. Ongoing remedial actions include operation of a mobile oil skimming system in addition to passive recovery in Area 1. Area 2 includes a portion of the CITGO Terminal west of the BELD switchyard, as well as BELD property west and south of the Potter 2 electric generating facility. An LNAPL plume was delineated on the western portion of Area 2, with intermittent LNAPL observed on the eastern portion. A total fluids, vacuum-assisted groundwater remediation and soil vapor extraction system is currently operational in Area 2. Areas 3 and 4 are located in the eastern part of BELD. A Condition of No Significant Risk for current site uses and activities has been achieved for these areas. A Class A-3 Partial Response Action Outcome (RAO-P) was filed in December 2007 for BELD Areas 3 and Purpose This ROS Opinion is being submitted in accordance with 310 CMR to certify that comprehensive remedial actions have been implemented to work towards a Permanent Solution at this large and complex Site, but that further operation and maintenance are required. As described in Section 1.1, the Site includes a number of areas with separate remedial systems and programs, each of which was designed for the purpose of achieving a Permanent Solution. Specifically, ROS applies since: a) Phase III and Phase IV Comprehensive Response Actions have been completed within all areas currently regulated under DEP Site Number ;

5 RTN Page 3 b) All of the remedial systems and programs were designed in accordance with 310 CMR to achieve a Permanent Solution; c) The remedial systems have been, and will continue to be, operated in accordance with the Phase V provisions of the MCP (310 CMR ) as well as with the Phase IV Remedy Implementation Plan(s) 1, as modified from time to time, and any applicable permits, approvals, and licenses; d) Each identified source of OHM has been eliminated or controlled in accordance with 310 CMR (5); e) There are no known Substantial Hazards at the Site; and f) Operational data are being reported, and will continue to be reported, every six months as described in 310 CMR Specific details of the sources of OHM, and systems and remedies in place at each section of the Site are described in Sections 2.1 through CURRENT SITE STATUS 2.1 BELD Area 1 A portable LNAPL skimming system has been installed in the portion of BELD Area 1 that lies within the CITGO Terminal boundary. The LNAPL observed in this portion of the Site is extremely viscous. The portable skimming unit uses a belt to pull the LNAPL out of the well, where it is scraped off of the belt and deposited into a 55 gallon drum with overfill protection and secondary containment. The skimming system is periodically moved between wells RW-A, RW-B, RW-C, RW-D, and HAND-12, based upon product thickness at each well. An oil absorbent sock is in place at collection well A-01 on the BELD portion of Area 1. Collection Well A-01 periodically contains viscous product. The sock is checked during monthly gauging events, and is replaced when it shows signs of saturation. 2.2 BELD Area 2 An LNAPL plume has been delineated on the western portion of Area 2 with intermittent LNAPL observed on the eastern portion. Additionally, LNAPL had infiltrated the storm water drainage system located east of the switchyard. Between January 2005 and May 2006, ES&M implemented comprehensive response actions that 1 As was previously mentioned, the Mala/Quirk, BELD and Terminal areas, which are all regulated under , have been reported separately over the years for a variety of reasons. Hence, each of these three areas has its own Phase reports that have been submitted under

6 RTN Page 4 included replacement of 230 feet of the storm drain system, and the construction of a groundwater treatment system in Area 2. The groundwater extraction/treatment system, and the soil vapor extraction system was first activated in March 2005 and is currently operational. Top loading, total fluids pumps driven by compressed air are deployed in seven recovery wells (RWT-1 through RWT-7) on the CITGO property, and within two recovery wells (RWB-9, and RWB-11) and two interceptor trench wells (ITW-1 and ITW-2) on the BELD property. These pumps extract groundwater and LNAPL to dual oil water separators (located on the Terminal side of Area 2) where LNAPL and groundwater are separated. Three granular activated carbon units (one 1,000-pound and two 500-pound units) then treat the extracted water prior to discharge to the Weymouth-Fore River under a Remediation General Permit issued by USEPA. The SVE system was first activated in Area 2 in July 2005, and is operated seasonally. Soil vapor is extracted from recovery wells RWT-1 through RWT-7 on the CITGO property near the BELD fence line. The extracted soil vapor was initially treated using a thermal oxidizer, but is currently treated through two 1,000-pound granular activated carbon units. To supplement the remedial system in Area 2, hand bailing is conducted routinely to recover LNAPL. Recovered LNAPL is emptied into the LNAPL storage tank at the Area 2 treatment system on the Terminal property. 2.3 BELD Areas 3 and 4 Area 3 refers to the eastern portion of the BELD property near the Weymouth-Fore River shoreline. Assessment activities indicated that Area 3 had asphalt-like material on the upland portion in overburden soils immediately above shallow bedrock. This asphalt-like material was also found on surface sediments within the inter-tidal basin of the Weymouth-Fore River. Asphalt-like material was excavated from the tidal flats and areas upgradient from the tidal flats in January In addition, petroleum-impacted soil was excavated from the upland area in May ES&M personnel occasionally inspect the area during low tide, and have collected small amounts of nuisance tar-like material. Any collected material is managed according to the Terminal s Soil Management Plan. In the spring of 2001, a 24-inch diameter, high pressure natural gas pipeline was installed across the eastern portion of the BELD property (Areas 3 and 4). The gas pipeline was installed under a Utility Release Abatement Measure (URAM) by Algonquin Gas Transmission Company/Duke Energy (Algonquin) to supply natural gas to a new electricity-generating power plant on the north side of the Weymouth-Fore River. Portions of this pipeline were installed transecting Areas 3 and 4, parallel to and within resource boundaries of the Weymouth-Fore River. As part of the Order of Conditions issued to Algonquin by the Braintree Conservation Commission, all pipeline trenches through Areas 3 and 4 were excavated to bedrock and backfilled around the pipe with an impervious flowable fill material. The purpose of the low permeability fill

7 RTN Page 5 material was to minimize possible migration of any petroleum into the Weymouth-Fore River from the upland portions of Area 3 and 4. All contaminated soil and asphalt-like material encountered during excavation and trenching was transported off-site to a licensed soil recycling or disposal facility under a MassDEP bill of lading. The pipeline installation and soil removal activities are summarized in a Utility Release Abatement Measure (URAM) Completion Report prepared by Coler and Colantonio, Inc. for Algonquin in May Based on a number of comprehensive response actions completed in Areas 3 and 4, a Condition of No Significant Risk for current site activities and uses was demonstrated. On December 20, 2007, ES&M submitted a Class A-3 RAO-P statement for this portion of the Site. 2.4 BELD RAM ACTIVITES In the fall of 2007, Braintree Electric began construction of a new power plant on their property, in the location of the former Potter 1 plant. In accordance with a comprehensive agreement between BELD and CITGO, soil and groundwater has been managed by ES&M during construction, as outlined in the Terminal s open-ended RAM Plan (ES&M, January 2004). Details of these activities are reported every six months in RAM Status reports. 2.5 CITGO Terminal Area I The Area I remediation system consists of a total-fluids recovery and treatment system, and a soil vapor extraction system that is also used to apply vacuum to several of the pumping wells. The goals of these systems are to eliminate migration of petroleum hydrocarbons from Area I, to recover LNAPL, and to reduce concentrations of petroleum hydrocarbons dissolved in groundwater and adsorbed to soil. The total-fluids system has been in operation since late The system currently consists of 13 recovery wells fitted with pneumatic total-fluids pumps (groundwater and LNAPL), and an interceptor trench recovery well (TR-1) equipped with a submersible electric pump for groundwater recovery. Recovered liquids are transferred to an oil/water separator located in the Terminal's garage building. Water is pumped from the separator through three activated carbon adsorbers (plumbed in series), and a low profile, shallow-tray air stripper. Treated water is discharged to the Weymouth-Fore River under the Terminal s NPDES permit. The SVE system was first activated during the fall of 2000 and is operated on a seasonal basis. The SVE system currently consists of 22 vacuum extraction wells 2 connected by above ground and sub-grade piping to a 3-hp vacuum blower with a moisture separator. Soil vapor is currently treated by two 2,000-pound vapor phase carbon adsorbers. 2 Thirteen of the extraction wells are connected to both the total fluids pumping and SVE systems.

8 RTN Page CITGO Terminal Area II (Off-Site Area) In 1996, ES&M completed a Phase II Comprehensive Site Assessment to evaluate Site conditions and define the extent of petroleum in the off site area west and north of the CITGO Terminal. The results of Phase II indicated that two properties west of the terminal required additional response actions under the MCP: the upper portion of the vacant lot referred to as the Mala property, and the adjoining former bank property, now owned by Daniel Quirk. The Phase II Report documented that concentrations of petroleum in soil and groundwater in the remaining off-site areas were below MCP Method 1 risk-based standards that were in effect at the time. Consequently, a Class A- 2 RAO-P statement was submitted to MassDEP in March 1997 to redefine the Site to include only the upper Mala and Quirk properties. During the summer and fall of 1997, ES&M completed a Phase III evaluation of remedial action alternatives for the redefined off-site area. Groundwater extraction, LNAPL recovery, and soil vapor extraction were selected as the preferred remedial action alternatives to be applied on the Quirk property. A similar remedial action alternative, but with application of higher vacuum to the extraction wells, was selected for the Mala property. The remedial system was installed in the late fall of 1998 and early winter of The system was activated in January 2001, following the execution of an access agreement between CITGO and Quirk to allow access to the Quirk property for system monitoring and maintenance. The groundwater extraction, LNAPL recovery, and soil vapor extraction systems operated in Area II between 2001 and 2003, and were extremely successful at eliminating LNAPL and reducing concentrations of petroleum in soil and groundwater. A Method 2 Risk Characterization and supporting documentation for a revised Class A- 3 Partial RAO were submitted to the MassDEP in October 2003 for a portion of the Quintree Mall property, and for the lower and mid Mala properties. This revised RAO-P was submitted so that AULs could be placed on these properties to ensure continued commercial use. An A-3 RAO-P for the remainder of the off-site area west of the Terminal was filed with the MassDEP in June of CITGO Terminal Area III In Area III, a monitoring and LNAPL bailing program has been implemented to address discrete and limited areas of LNAPL. Additionally, numerous soil excavations have been performed over many years under the open-ended RAM Plan. The thicknesses of LNAPL and concentrations of adsorbed and dissolved petroleum in soil and groundwater have been reduced across Area III since the remedial program was implemented. One of the discrete areas of LNAPL is in the vicinity of the Terminal s outfall separator located in the northern portion of Area III, adjacent to the Weymouth-Fore River. Investigatory activities have shown that small amounts of viscous oil are seeping into

9 RTN Page 7 the underground storm water piping located upgradient of the inlet to the separator. A July 2006 investigation of the pipeline revealed the presence of LNAPL from historical refinery operations in this area. Petroleum impacted soil and several hundred feet of historical piping were removed during the investigation, and a cement/grout mix was pumped into the excavation trench around the storm water piping. Subsequent inspections of the oil collection chamber within the separator has shown that while the infiltration has decreased, infiltration is continuing in a portion of the storm water piping upgradient of the inlet. The oil that infiltrates the piping is held within the first chamber of the separator, and is inspected and vacuumed out on a routine basis by Terminal operations staff. In 2006, CITGO contracted ES&M to conduct a comprehensive evaluation of the Terminal s storm water management system to recommend improvements and to maintain compliance with applicable regulatory requirements. As a result of this evaluation, CITGO has made several improvements to efficiently manage the flow of non-contact and contact water to the oil water separator. Currently, CITGO is replacing the oil water separator at the loading rack near Quincy Avenue, and is installing new piping between this oil water separator and the outfall separator. Several options are also being evaluated to eliminate the infiltration of oil into piping upgradient of the outfall separator. These include replacing or relining the piping, excavating additional impacted soil and recovering historical LNAPL in the vicinity of the piping, and implementing modifications to the outfall separator itself. At the present time, CITGO has implemented an inspection and control program that includes daily inspections of the main outfall separator and periodic skimming to remove LNAPL observed in the first chamber. Detailed observations are recorded on a monthly inspection report, including amounts of LNAPL recovered during skimming. 2.8 Dunkin Donuts IRA On December 27, 2007, air monitoring conducted by Clean Harbors indicated that volatile organic compounds were intruding into the indoor air of the Dunkin Donuts building located at 421 Quincy Avenue in Braintree, Massachusetts. On December 28, 2007, MassDEP received oral notification that vapor concentrations in the indoor air triggered a 2-hour reportable condition. MassDEP subsequently issued Release Tracking Number (RTN) to Dunkin Donuts. The CITGO Terminal was identified by MassDEP as a potential source of these vapors, and CITGO was deemed to be a Potentially Responsible Party (PRP) for this RTN. A Notice of Responsibility dated February 29, 2008 was subsequently issued to the CITGO Terminal. CITGO retained ES&M to conduct IRA assessment activities at the Dunkin Donuts property, and on neighboring properties. While CITGO is a PRP for the Dunkin Donuts release, IRA activities are being conducted under RTN , which has not been linked to RTN

10 RTN Page LSP OPINION The LSP for the Site, Mr. Douglas Heely, opines that all qualifications for achieving ROS status at the Site, as defined by RTN , have been met. Based on the preceding ROS Opinion and in accordance with 310 CMR (4), the deadline to achieve a Response Action Outcome no longer applies.

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