ATTACHMENT BWSC-105 EVERETT STREET AT MASSACHUSETTS AVENUE CAMBRIDGE, MASSACHUSETTS RTN 3-26434 D. DESCRIPTION OF RESPONSE ACTIONS 14. Removal of Drums, Tanks or Containers: a. Describe Quantity and Amount: 303 55-Gallon Drums and 1 85-Gallon Drum of drill cuttings, drill wash water, and purge water (investigation derived wastes), one (1) approximately 20-Ton Roll-Off of excavated soil generated from the installation of the Retail Strip dewatering treatment system infiltration trench, one (1) approximately 3-Ton Roll-Off of excavated soil generated from the installation of soil vapor monitoring wells in Everett Street, Massachusetts Avenue and Chauncy Street, one (1) approximately 16.6-Ton Roll-off and one (1) approximately 18.2-Ton Roll-off of vacuum extracted soil generated from the utility clearance for bioremediation injection wells above the water table in Massachusetts Avenue, one (1) 1-cy box of hazardous soil generated from the installation of bioremediation injection wells in Massachusetts Avenue, and three (3) approximately 1-cy boxes of excavated soil generated from the modifications to the Zero Chauncy Street SVS. b. Receiving Facility Drums: Roll-Offs: Boxes: Ross Incineration Services, Grafton, OH Pollution Control Industries, East Chicago, IN Clean Harbors of Connecticut, Inc., Bristol, CT Clean Harbors Environmental Services, Cleveland, OH Clean Harbors Environmental Services, Kimball, NE Aggregate Recycling Corporation, Eliot, ME Taunton Landfill, Taunton, MA Clean Harbors Environmental Services, Kimball, NE Note: IRA activities, which have included SVS installation, operation, and monitoring at several buildings and sealing and patching of the basement slab at 3 to 5 Everett Street have not generated Remediation Waste. The IRA Status Reports previously submitted to MassDEP summarized management of Remediation Waste, Remedial Wastewater and/or Remedial Additives that were generated as part of site investigation, Phase IV and RAM activities. The management of these wastes was summarized in the IRA Status Reports for completeness but was
also documented in the associated Phase II, Phase IV and RAM Status and/or Completion Reports. The following is a summary of Phase IV, RAM, and investigatory remediation waste management previously summarized in IRA Status Reports: Observation well installation generated soil cuttings. Soil cuttings from above the water table were placed in cubic yard-sized packs and temporarily stored on-site until they were shipped off-site for disposal in two roll-off containers. Soil cuttings from below the water table were placed in one cubic yard-sized pack, and temporarily stored on-site until it was shipped off-site for disposal as hazardous waste. Observation well installation and sampling generated purge water. Purge water was treated and discharged using the treatment and infiltration system located at the Retail Strip. Excess Phase IV injection solution was either treated and discharged using the treatment and infiltration system located at the Retail Strip or drummed for disposal (two drums of excess injection solution were transported to Clean Harbors in Kimball, Nebraska on 20 October 2010). Excess water from the bioremediation performed in Massachusetts Avenue was discharged into horizontal wells below the Massachusetts Avenue sidewalk with no treatment because it did not contain concentrations of contaminants above RCGW-2 standards. Soil and asphalt excavated from the Retail Strip parking lot were temporarily stored in three roll-off containers and shipped off-site for disposal as hazardous waste. Drums of used carbon and bag filters from the GCTS were removed on 20 October and 14 December 2010. The drums were transported to Clean Harbors in Kimball, Nebraksa and Ross Incineration Services in Grafton, Ohio, respectively. Copies of the Uniform Hazardous Waste Manifests and Non-Hazardous Waste Manifests for waste removal were previously submitted to MassDEP as attachments to previous IRA, Phase IV, and RAM Status or Completion Reports. Following submission of this IRA Completion Report, Remediation Waste will be managed as a Phase IV activity.remediation waste generated from future assessment activities will be containerized for future offsite disposition or in the case of purge water, treated and discharged using the treatment and infiltration system located at the Retail Strip. Additionally, future granular activated carbon from the treatment of water and vapors will be transported off-site for disposal or regeneration, as necessary. 16. Other Response Actions: Installation of subslab ventilation/depressurization systems and air exchange units.
F. PERSON UNDERTAKING IRA 2. Complete Name of Organization: President and Fellows of Harvard College Acting by and through Harvard Law School and University Operations Services H. REQUIRED ATTACHMENT AND SUBMITTALS: 2. The Response Actions on which this opinion is based were subject to approval by the Massachusetts Department of Environmental Protection and the terms of a Tier IC Permit. Approval has been granted by MassDEP for the installation and operation of six (6) subslab ventilation/depressurization systems (SVS), which are located at Story Hall, Dane Hall, and Wyeth Hall (now demolished) on the Harvard campus, at the Retail Strip building at 1607-1613 Massachusetts Avenue, at Zero Chauncy Street, and at 1600 Massachusetts Avenue. MassDEP has also granted approval for various configurations of indoor air exchange units at various times and places. Remedial monitoring reports for the systems at Story Hall, Dane Hall, and the Retail Strip are prepared every six months concurrent with IRA Status Reports, pursuant to the MCP (310 CMR 40.0006). The system at Wyeth Hall was shut down in May 2007, and is therefore no longer a subject of ongoing remedial monitoring reports. The systems at Zero Chauncy Street and 1600 Massachusetts Avenue have been reported on monthly. a. Harvard Campus: Oral approval was granted on 30 November 2006 to conduct an Imminent Hazard Evaluation; 1 and 2 December 2006 for assessment only IRA activities; 15 December 2006 for the installation of two subslab ventilation/depressurization systems at buildings located on the Harvard campus; 28 August 2007 for installation of a subslab ventilation/depressurization system (SVS) and extraction points for two possible systems at buildings located on the Harvard campus; for the shutdown of SVS at Story Hall on 8 May 2009; and for the shutdown of SVS at Dane Hall on 30 June 2010. b. Retail Strip: Oral approval was granted on 19 November 2007 for the installation of the subslab ventilation/depressurization system (SVS) in the basement of the Retail Strip where Crimson Cleaners formerly operated a dry cleaning business. MassDEP approval for startup was granted on 8 January 2008. After the system began operation, it was determined that expanding to include a dewatering component would increase the system s effectiveness. Approval was granted on 12 February 2008 for the installation and operation of a treatment and re-infiltration system to manage groundwater associated with the IRA activities at the former Crimson Cleaners. Two indoor air exchange units were also installed on 21 May 2008 in the portion of the Retail Strip occupied by the former clothing store. The units were shut down on 2 September 2008 when the former tenant vacated the clothing store space. On 23 September 2008, the indoor air exchange units were repositioned and turned back on so that two units were operating in the basement below the former clothing store, and three units were operating in the basement of the former dry cleaner. These units were temporarily shut down from 15 May to 21 May 2009 during
mechanical systems repair activities. Additionally, on 16 June 2009, one indoor air exchange unit was removed from the basement below the former clothing store and one indoor air exchange unit was removed from the basement of the former dry cleaner for use at other areas of the Site. Currently, one indoor air exchange unit in the basement below the former clothing store and two indoor air exchange units in the basement of the former dry cleaner continue to be in use. Following soil vapor sampling from horizontal soil vapor wells installed on 31 December 2008 through the eastern and western foundation walls of the Retail Strip, three of the wells (H1, H2, and H3) were connected to the Retail Strip SVS on 7 April 2009, and two of the wells (H4 and H5) were connected to the Retail Strip SVS on 13 April 2009. Geosyntec monitored total VOC concentrations at these extraction wells between 11 March and 12 May 2009 with a MiniRAE photoionization detector (PID). Haley & Aldrich continues to monitor influent, mid-carbon, and effluent discharges from the SVS with a GC-FID on a quarterly basis. The Retail Strip SVS was temporarily shut down for rebound testing on 20 July 2009 following oral approval from Kathy Cahill of MassDEP on 16 July 2009. Indoor air sampling was performed on 3 August 2009, two weeks following the shutdown, to evaluate impacts to indoor air. Indoor air results showed that no Imminent Hazard was present, but based on the rebound concentrations the system was restarted on 12 August 2009. RAM activities associated with the 10 February 2010 RAM Plan Retail Strip Sewer Lateral Remediation were initiated in February 2010. Concurrent with these activities, certain extraction wells were temporarily turned off and on, as noted on the OM&M logs. On 2 March 2010, the dewatering component of the SVS and all vertical extraction wells were shutdown, per oral approval by MassDEP on 2 March 2010. Select horizontal extraction wells currently remain open. c. Zero Chauncy Street: Per discussions with MassDEP on 4 March 2008, Haley and Aldrich installed indoor air exchange units at two garden level apartments at Zero Chauncy Street. An SVS was installed at Zero Chauncy Street following verbal MassDEP approval of the 26 June 2008 Addendum/IRA Plan Summary of Work and Request for Approval of SVS Design and Further Work at Zero Chauncy Street. The SVS began operation on 17 July 2008. The air exchange units in Apartments B-2 and B- 3 at Zero Chauncy Street were shut down on 7 August 2008. In order to enhance the SVS performance, the 2-hp blower in the existing SVS was replaced with a 3-hp blower on 24 September 2008. Two indoor air exchange units were reinstalled in Apartment B-3 on 16 June 2009. IRA Plan Addendum #2 - Zero Chauncy Street was submitted to MassDEP on 22 June 2009. MassDEP granted conditional approval of the plan in its letter dated 2 July 2009. In response, a letter was submitted to MassDEP on 15 July 2009 to request an extension to applicable deadlines. The request was approved by MassDEP in a letter dated 23 July 2009. The IRA activities outlined in the Addendum were performed during July and August 2009 after the approval, and included the expansion of the SVS with perforated vacuum piping connected to two new extraction lines and sealing cracks in the floors and walls with concrete
sealant. The two indoor air exchange units were shut down on 30 July 2009 after connection of the SVS modifications (a few days prior to the end of construction) to allow for sampling on 5 August 2009. In addition, RAM activities relating to the 7 July 2009 RAM Plan for a bioremediation pilot test have been completed at Zero Chauncy Street. A RAM Completion Report, dated 4 November 2009, was submitted to MassDEP on 6 November 2009. d. 1600 Massachusetts Avenue: Haley & Aldrich installed an indoor air exchange unit for the ground floor apartment (Unit 101) at 1600 Massachusetts Avenue on 21 March 2008. An SVS was installed at 1600 Massachusetts Avenue following verbal MassDEP approval of the 30 April 2008 Addendum/IRA Plan Summary of Work and Request for Approval of SVS Design and Further Work at 1600 Massachusetts Avenue. The SVS began operation on 21 May 2008. The air exchange unit in Unit 101 at 1600 Massachusetts Avenue was shut down on 4 June 2008. 6. LSP Opinion: Deborah H. Gevalt is the LSP for the project. The LSP seal and signature are provided on the attached Transmittal Form BWSC-105. The attached Remedial Monitoring Report (RMR) contains material facts, data, and other information that support the LSP Opinion that, to the best of the LSP s knowledge, information and belief, the response actions that are the subject of this submittal (i) are being implemented in accordance with the applicable provisions of M.G.L.c.21E and 310 CMR 40.0000, (ii) are appropriate and reasonable to accomplish the purposes of such response action as set forth in the applicable provisions of M.G.L.c.21E and 310 CMR 40.0000, and (iii) comply with the identified provisions of all orders, permits, and approvals identified in this submittal. G:\30118\211 DLA Piper\MCP\RMRs\2011 09 29 RMRs\2011-0923-BWSC105 Attachment-D2.docx