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24 May 200> Cyn Protect \Nmnher 201882-00-TlS Miassachusetts lDepartment of Envitritnmental Protection Bureaiu of Waste Site Cle anup Cental Regional Oflice 627 Main Stieet Athol, Mlassaebusetts 01608{) Attention; NMr. Nicholas .(Chitlds, Branch Clue- Emrtcgency Response Re:

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DeTar Mr. Chdtds: The purpose of this submittal is in pirovide the Massachusetts Department of Environmental lProtection [MADE P4 wtiths an Immediate Response Action [IRA] C ompletion and Response Action Outcome [RA () Statemnst Repor1 Pac kage tor the abov e referenc ed site [herein refer red to as D isposal Sire]. T his package has been pr epared by Cy Environnmental Serv ices [Cyn] oni behtalof the Potentially Responsible Party [P'RP] to maintain the site's compliance with the Massac husetits Contingency P lan [MSC P - 3 I0 CMAR 40 0000] and to close the site release file. lnformai on required for an IRA and RAG Statemsent Report as speci fled in 3/0 CAIR 40 0427 ta 30 CMI AR 40./036, are contatied itn this document as a whole. Copies or the [RA Completion [BWSC -1051 and RAO) Transmittal Foinms [BWSC->104[ are attached as Appendix A and Appendix B of this teport, respectiv ely T he originalI forms are provided as a separate attachment to thits report Refer to Figure I for the regional location of the site, Figutre 2 for the layout of the site, and Appendix C for photograph of the D isposal Site.

General Terms Cyn E nvironmientalI Services [C pn} is psroviding an IRA Completion and R(OA Report for the trelease ot an unsknow n quantity of nmber 2 fuel oil. whitch wsas disc overed and repot ed to the MADElP on I19 June 2003. The regi onal locatain of the Di/spos a!Sire or Properny'is showxn on the Site Locus Map as Figurec I.

Athol Medical Clinic / IRAC and RAO Report 1467 Main Street, Athol, Massachusetts 01331 Release Tracking Number: 2-148 15

24 May 2005

This document addresses the release of oils and/or hazardous materials [OHMs] associated with the site, which was issued Release Tracking Numbers 2-14815 by the MADEP and the PRP regulatory filing requirement for an IRA Completion / RAO Report. Further information on the release is outline throughout this report. For the purpose of this report and pursuant to the Massachusetts Contingency Plan [MCP' - 310 CMR 40.0000] the following terminology will be used: Property or Facility- is defined as the area immediately surrounding the limits of the Disposal Site. Site - means any building, structure, installation, equipment, piping or pipeline, well, pit, lagoon, impoundment, ditch, landfill, storage container, motor vehicle, rolling stock, aircraft, or any other place or area where OHMs has been deposited, stored, disposed, or placed. Disposal Site - means any building, structure, installation, equipment, piping or pipeline, well, pit, lagoon, impoundment, ditch, landfill, storage container, motor vehicle, rolling stock, aircraft, or any other place or area where an uncontrolled release of OHMs has come to be located as a result of any spilling, leaking, pouring, abandoning, emitting, emptying, discharging, injecting, dumping, discarding, or otherwise disposing of such OHMs. Release - means any spilling, leaking, pumping, pouring, emitting, emptying, discharging, injecting, escaping, leaching, dumping, or disposing into the environment. Environment - means waters, land, surface or subsurface strata, or ambient air of the Commonwealth of Massachusetts [COM]. Contaminated Media - means contaminated groundwater, sediment, soil, and/or surface waters. Release conditions were determined to have inpact a limited area of soil located adjacent to the existing building, and directly under the fill and vent lines of the tank. Information required for an IRA Completion and RAO Report is contained in this document as a whole. All opinions and conclusions made in this report are based solely upon information gathered on the property and disposal site, relative to response actions and assessment activities conducted.

PropertyDescription and Site Sen sitivity Currently, the site is operated as a medical clinic. Properties surrounding the site are primarily residential with commercial business located along Main Street. Refer to Appendix C for photographs of the Disposal Site. Based on information provided on a MADEP/GIS map [Figure 3 / Sheet A and B] and other informational sources, the release did not occurred within the geographical boundaries of an area classified as a Current or Potential Drinking Water Source. Thus, the release is subject to RCGW-2 Reportable Concentrations, and Method I GW-2 and GW-3 Risk Characterization Standards. Soils onsite are subject to RCS-I reportable concentrations [residential properties located within 500-feet of the disposal site] and Method I S-I Risk Characterization Standards.

Utilities Response actions found no evidence that the release impacted the interior of a utility structure. Natural Resource Areas within 500 feet of the DisposalSite - 310 CMR 40.0424 (1ff(b) Based on information derived from site reconnaissance, a USGS Topographic Quadrangle Map [Figure 1], the MADEP/GIS NRS Site Map [Figure 3], indicate no evidence that a Class A Surface Water Body is located within %2mile radius of the site. Additionally, 314 CMR 4.00 indicates that the Disposal Site is located within the Miller River Drainage Basin of the Connecticut River Drainage System. The Disposal Site is not located within a I-mile radius of a Natural Heritage & Endangered Species Areas.

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Athol Medical Clinic / IRAC and RAO Report 1467 Main Street, Athol, Massachusetts 01331 Release Tracking Number: 2-148 15

24 May 2005

Information collected from a MADEP/GIS Map shows that the Disposal Site is not located within the geographical boundaries of a Potentially Productive Aquifer, Zone II, or Interim Wellhead Protection Zone. Additionally, a review of this plan noted that the Disposal Site is located within 500-feet of a wetlands and a Classified Protected Open Space (Local/State/ FederavfTrustee), but not located within 500-feet of a: * * * *

Species of Special Concern, Threatened or Endangered Species Habitat; Area of Critical Environmental Concern; Certified Vernal Pool, or Outstanding Resource Water; and/or 100-feet of an area potentially containing a Fish Habitat

The property is provided with city water, and information provided by town officials revealed that there are no private wells located within 500-feet of the Disposal Site. The Disposal Site is located within 500-feet of a Public Water Supply Distribution Pipeline. Information obtained from the Town of Athol web-page derived a population density of 300-people within a 'A-mile radius of the Disposal Site. An inspection of the property, and miscellaneous reference sources, indicates that the Site is a classified institution. No other institutions were located within 500-feet of the Disposal Site [Residences are within 500-feet of the Disposal Site although this does not affect the groundwater classification].

Release History - 310 CMR 40.0330 As noted in the Notice of Noncompliance [dated 6 October 2003], the MADEP was contacted at 11:45-AM on 19 June 2003, that a sudden release of an unknown amount of number 2 fuel oil had occurred at the above noted site. The release was connected with a 275-gallon aboveground storage tank, which was located within the basement of the building, and occurred as a result of rainwater entering the fill pipe of the AST. The rainwater displaced the oil from the tank, and cause the soil located below the fill pipe to become contaminated. At the time that the release conditions were reported to the MADEP and the Athol Medical Clinic was advised to retain the services of an LSP and to conduct the appropriate response actions. Based on correspondence reviewed, no actions were taken to address this condition, or to provide the required regulatory submittals to the MADEP. As a result, the MADEP issued a Notice of Non-Compliance Letter to advise the PRP of their obligation under the Massachusetts Contingency Plan. This letter was followed by a Notice of Enforcement Conference Letter, which was dated 16 March 2004. To address these letters, the PRP retained the services of Cyn in April 2005 to prepare the required regulatory paperwork. Identification numbers assigned to the site release conditions include the Release Tracking Number 2-14815, and the Notice of Non-Compliance Number NON-CE-03-3146. A copy of the Notice of Responsibility and other MADEP documents are attached as Appendix D of this report. Site Reporting Conditions -310 CMR 40.0310 A review of the site conditions noted that the release triggered the following MCP Reporting criterion. *

310 CMR 40.03//I (3) - 2-hour reporting trigger: A release to the environment indicated by a release of a quantity of oil greater than the applicable reportable quantity [i.e., 10-gallons] and which occurred within a 24hour period;

A review of the MADEP web database recorded indicates that the site has not been cited for previous releases of oil and/or hazardous materials.

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A thol Medical Clinic / IRAC and RAO Report 1467 Main Street, Athol, Massachusetts 01331 Release Tracking Number: 2-14815

24 May 2005

Limits ofA pp roved Immediate Response Actions - 310 CMR 40.0411 At the time of notification, the MADEP advised that general response actions were required in the form of an IRA [in accordance with the 310 CMR 40.04 /0]. The requirements also included the need for employing or engaging a Licensed Site Professional [LSP] to manage, supervise, or actually perform necessary response actions leading to a level of No Significant Risk at the site. Based on information provided to Cyn, an LSP and response contractor was not retained to conduct response actions, or to define a scope to the Immediate Response Action program. Cyn was not retained to provide the required initial regulatory submittal [RNF and IRA Plan] until April 15, 2004 (submission date).

Scope of A mended IRA Measures - 310 CMR 40.0424 (3) Though the submission of the April 15 IRA Plan, Cyn requested that the IRA Plan be amended to allow the removal and disposal of an estimated 50-cubic yards of petroleum impacted soil. This program also outlined the removal of groundwater through physical or mechanical processes to facilitate the removal of the impacted soil, or to address the presence of impacted water. This water will be disposed of in accordance with the requirements of the MCP and in an appropriate method.

Interim Deadlines - 310 CMR 40.016 7 The Notice of Non-Compliance established 3 November 2003 as an interim submission deadline for the Release Notification Form and the Immediate Response Action Plan or Completion Statement. Lastly, the Notice of Enforcement Conference established a date of 30 March 2004 for the PRP to meet with the MADEP to discuss and reach an agreement on returning the site into compliance with the Massachusetts Contingency Plan.

Release Quantity Estimate The quantity of oil released is unknown at this time.

Revulatory Compliance Submittals The submission of this report will serve to address the sites missed regulatory filing deadlines, and bring the site back into compliance with the Massachusetts Contingency Plan. For this submittal, Cyn has attached copies of the IRA Transmittal Form [BWSC-l05] and RAO Transmittal Form [BWSC-104] as Appendix A and Appendix B, The initial Non-Compliance issue was addressed when Cyn was retained to submit an RNF and a respectively. combined IRA Plan/Status Report on 15 April 2004.

Limitsof Investigative Testing Available informtion indicates that a number 2 fuel oil release occurred at the site. Based on the nature of the release conditions, Cyn would analyze the collected media samples for residual concentrations of extractable petroleum hydrocarbons [EPHI], volatile petroleum hydrocarbons [VPH], select volatile organic compounds [BTEX (benzene, toluene, ethylbenzene, total xylenes), MTBE (methyl tertbutyl ether), and naphthalene], and select polynuclear aromatic hydrocarbons [2-methylnaphthalene, naphthalene, acenaphthene, and phenanthrene]. Refer to Appendix E for a copy of Cyns Quality Assurance and Quality Control Plan, and Standards Operational Procedures. To facilitate the disposal of impacted soils from the site, a representative soil sample was obtained and analyzed for residual concentrations of total petroleum hydrocarbons, volatile organic compounds, flash point, paint filter, pH, reactive cyanide, reactive sulfide, and total polychlorinated biphenyls. The results of this testing are attached as Appendix F of this report.

PreviouslyConducted Release Assessment and Response Measures - 310 CMR 40.0424 (1)c Prior to submitting the April 04 IRA Report, Cyn's Supervisor conducted a site inspection and noted that the fill and vent lines had been plugged to limit a further release of fuel oil tank. No actions have been taken to address and dispose of the impacted soils located below the lines.

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Athol Medical Clinic / IRAC and RAO Report 1467 Main Street, Athol, Massachusetts 01331 Release Tracking Number: 2-14815S

24 May 2005

Recently Conducted Release Assessment and Response Measures - 310 CMR 40.0424 (l1)(c) Following the submission of the April 04 IRA Plan Report package, Cyn has conducted the following response actions. *

12 April 2004: Cyns Field Chemist conducted an inspection to evaluate the site conditions [photos attached as Appendix C]. Screening of soil collected from the area under the two fill pipes recorded total organic vapor readings varying between 67.5-part per million by volume [ppm/v] and 156-ppm/v. This inspection detected an area of impacted soil 9-feet long and 8-feet wide [see Figure 2].

*

2/. 22. and 25 June 2004: Cyn personnel arrived onsite to commence with the excavation of petroleum-impacted soil. This soil was stockpiled on polyethylene sheeting within an adjacent lot. During the excavation program, Cyn Field Chemist collected and screened representative soil samples obtained from the response excavation. This screening program was used to direct the focus of the site response actions. Lastly, a sample of the impacted material was collected and submitted for laboratory analysis [used to arrange the disposal of impacted soils]. The results of this testing are attached as Appendix F to this report

*

2 and 6 Julv 2004: Cyn personnel continued removing petroleum-impacted soil. During the removal process, representative samples were obtained and screened for readings of total organic vapors using a photoionization detector. The results of these response actions created an excavation measuring approximately 20-feet long by 9feet wide, and varying between 20 and 40-inches deep. Water was observed within the excavation at a depth of 27inches below the existing grade. Readings recorded at the limits of the response excavation were noted to vary between less than 0.1-ppm/v and 47.8-ppm/v.

*

7 andS8Julv 2004: Cyn personnel obtained and placed hay bales around the limits of the response excavation.

*

12 Julv 2004: Cyn personnel used a vacuum truck to remove water from the response excavation. Because of a mechanical failure, no soil removal actions were conducted.

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19 .Julv' 2004: Cyn personnel used a vacuum truck to remove water from the response excavation. Upon the removal of the water from the excavation, Cyn personnel excavated and removed the impacted soil. During response actions, Cyns Field Chemist collected and screened representative soil samples obtained during the response actions.

*

22 July 2004: Cyns Field Chemist collected representative soil samples from the limits of the response excavation. These samples were obtained from each sidewall, with the obtained samples being prepared and submitted for laboratory analysis. The results of this testing [received on 28 July] are summarized in Table I, the laboratory report attached as Appendix G, and the sampling locations shown on Figure 4. A comparison of the individual results against the applicable Method I Risk Characterization Standards noted that each was below the applicable risk limit. Thus, it appeared that no further response actions would be required. Response actions had developed an excavation measuring 20-feet long by 9-feet wide, and 40-inches deep.

*

2 Aueust 2004: In preparation for the removal of the impacted soils from the site, Cyn personnel mobilized onsite and placed the impacted materials into the roll-off can. The impacted soil contained in the can was staged onsite in the event that further assessment measures encountered impacted soils.

*

9 August 2004: Cyns Field Chemist collected representative soils samples from the base of the response excavation, and from two additional soil-sampling points located near the edge of the wetlands. In addition, a water sample was collected from a point located between the response excavation and the edge of the wetlands. The results of the soil testing [received on 19 August] are summarized in Table 1, the laboratory report attached as Appendix H, and the sampling locations shown on Figure 4. A comparison of the individual results against the applicable Method I Risk Characterization Standards noted that each was below the applicable risk limit. Thus, it appeared that no further response actions would be required. It should be noted that no evidence of a petroleum release was present within the water sample.

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Athol Medical Clinic / IRAC and RAO Report 1467 Main Street, Athol, Massachusetts 01331 Release Tracking Number: 2-14815

24 May 2005

e2/ and 25 A pril 2005: Following the resolution of payment issues, Cyn personnel arrived onsite to remove the rolloff container, thirteen bags of miscellaneous trash, and 100-feet of flex hose from the site. In addition, personnel backfilled the response excavation level with the existing grade.

Soil Characterization A review of the soil removed during the response actions noted it to consist of Silty Sand with varying percentages of gravel and fines, and occasional cobbles / boulders. Soils of this consistency normally have a permeability factor in the range of 104 to 10~5 centimeters per second [cm/sec].

Groundwater Depth During response actions, the groundwater table was encountered at a depth approximately 27-inches below the exiting grade.

Integrity of Testing Results To validate the integrity of the analytical data, the laboratory report were reviewed to insure that the samples were analyzed within the required holding times, that the detection limits were below the most stringent and applicable risk based standard, and quality assurance/quality control parameters were within acceptable limits. For each of the samples, the surrogate recoveries were noted to be within the required and acceptable ranges, and were prepared and preserved as required by the applicable analytical method. Next, the field and/or trip blanks were reviewed for evidence of volatile contaminants (indication of cross-contamination issue]. No evidence of impurities was detected within the field blank. Lastly, confirmatory soil samples used to evaluate and document the integrity of the response excavation were extracted and/or analyzed within the applicable testing guidelines. Thus, the results would appear to accurately reflect and document the site residual release conditions.

Management of Rem ediation Waste - 310 CMR 40.0030 Wastes generated as part of Cyn's response actions were managed using the following paperwork: Petroleum Impacted Booms 1. 21 A pril 2005: 13 bags containing vactor hose, pad, trash, and ploy were removed from the site under Straight Billof-Lading number 14512. This material was transported to and disposed of at Cyn Oil Corporation located in Stoughton Massachusetts. 2.

25 April 2005: 100 feet of Flex Hose and three 10-foot section of PVC piping were removed from the site under Straight Bill-of-Lading number 16312. This material was transported to and disposed of at Cyn Oil Corporation located in Stoughton Massachusetts.

Petroleum Impacted Liquids 1. 12 July 2004: 1,560 gallons of petroleum impacted water was removed from the site under uniform hazardous waste manifest MA-Q-8272 17. This water was transported to and disposed of at Cyn Oil Corporation located in Stoughton Massachusetts. 2.

19 July 2004: 685 gallons of petroleum impacted water was removed from the site under uniform hazardous waste manifest MA-Q-827232. This water was transported to and disposed of at Cyn Oil Corporation located in Stoughton Massachusetts.

Oily Solids: 1. 29 Aporil 2005: Impacted soils generated as part of the site response actions were removed from the site using a Billof-Lading. This paperwork documented the removal and recycling of 22.64-tons [15.09-cubic yards] of impacted soil at the Aggregate Industries facility located in Stoughton, Massachusetts.

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Arhol Medical Clinic / IRAC and RAO Report 1467 Main Street, Athol, Massachusetts 01331 Release Tracking Number: 2-14815

24 May 2005

Refer to Appendix I for a copy of the previously noted disposal paperwork.

Critical Exposure Pathway Assessment - 310 CMR 40.0414 /40.0006 Pursuant to 310 CMR 40.0414 (3) and 310 CMR 40.0006 Cyn reviewed the site conditions for evidence of Critical Exposure Point Pathways. Critical Exposure Point Pathways are de fined as: 'a means by which oils and/or hazardous materials [OHMs] released at the disposal site are transported, or likely to be transported to human receptors via vapor phase emissions of measurable concentration(s) of OH Ms into the living or work space of a school, daycare, pre-school, or occupied residential dwelling. or 'ingestion, dermal absorption, or inhalation of measurable concentration(s) of OH Ms fromn a drinking water supply well(s) [public or private] located at or servicing a pre-schooL, daycare school, or occupied residential building'. No evidence of a Critical Exposure Point Pathway was detected during the completion of the site response actions.

Imminent Hazard Evaluation Cyn compared the reported site conditions against the Imminent Hazard criteria established in Section 40.0321 and Section 40.0950 of the MCP. Based on a review of the site release conditions, an Imminent Hazard Condition does not exist at the site.

Substantiaat Release Migration Assessment To determine whether a Condition of Substantial Release Migration exists, Cyn compared the site conditions against the criteria established under 310 CMR 40.0413. The results of this evaluation indicated no evidence that a Condition of Substantial Release Migration existed.

Release Conceptual Site Model A conceptual model of the release is provided as Figure 5 of this report. Product released from the tank fill impacted the underlying soils. To address the release, the fill and vent pipes were plugged and the underlying soils removed and disposed of. Confirmatory samples obtained from the limit of the response excavation indicated that the levels of impact had been reduced to levels under Method I standards. Lastly, testing of a groundwater sample recorded no evidence of the release. Based on this information, it appears the response actions have address the site release conditions and eliminated potential migration pathways and exposure points concerns. Media Impact Evaluaio,, - 310 CMR 40.0924 / 40.0925 An evaluation of the disposal site indicated that the release impacted the following: *

Soil: Site response actions removed and disposed of 22.64-tons [15.09.-cubic yards] of petroleum-impacted soil to an asphalt batching plant. Upon the removal of this material, confirmatory soil testing was conducted. The results of this testing are summarized in Table 1 of this report. The areas of residual impact will be addressed through the completion of a Method I Risk Characterization.

*

Groundwater: Testing of a groundwater sample detected no evidence of impact. Thus, groundwater will not be considered an impacted media.

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Athol Medical Clinic!/RAC and RAO Report 1467 Main Street, Aihol, Massachusetts 01331

24 May 2005

Release Tracking Number: 2-14815

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Solid Sur faces and Subsurface Utilities: No evidence of impact.

*

Sediment and Surface Water: No evidence of impact.

*

Interior A ir: No evidence of impact has been detected.

Soil Characterization - 310 CMR 40.0933 This assessment is based on Accessibility, and on the Frequency and Intensity of Use of these soils to for children and adults. A characterization of the soil in the area of the Disposal Site indicates: *

Frequency of Use: Since the release occurred at a residence, the frequency of use for adults and children would be considered High. This assessment is based on items 310 CMR 40.0933 (4)(a)(l)(b) (3 & 4) and 310 CMR 40.0933 (4)(a)(2);

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I *

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*

Intensity of Use: The Intensity of Use by adults and children will be considered High [310 CMR 40.0933

*

Accessibility: Soils covered by pavement are classified as Accessible [310 CMR 40.0933 (4)(c)(l)].

(4()I]

Based on the above criteria, the soils will be considered and subject to S-I soil standards.

Exposure Point Con cent rations. Soils - 310 CMR 40.0926 The exposure point for the soils is defined as the horizontal and vertical distribution of the contaminant in soil, for each applicable soil category. The exposure point concentration is calculated by using the arithmetic average of each site related OHMs for each exposure point [in each applicable soil category]. Any data represented as a "hot spot" must be addressed as a separate and distinct exposure point. Refer to Table 1 for a summary of the analytical results, which were collected during the completion of the site response actions. It should be noted that based on the conditions, the applicable Method I Risk based standard are S-. In general, site none applicable that and thedetermined sampling the hotspotresults evaluation of the residual sampling results exceeded an applicable Method I Risk Standard. As described above, the sampling points are classified as "Accessible" [S-I classified location]. In general, levels of residual petroleum impact were present within a majority of the analyzed soil samples. Based on this information, the limits of the Disposal Site - Soil Impact will be defined by those points showing a positive detection of petroleum impact [See Figure 4]. Cyn's risk assessment would evaluate the area of residual impact as individual and a combined exposure point concentration. As noted earlier all of the analytical results were below the applicable S-1 concentrations. Based on this information point will be calculated and used to none of the results are considered a "Hot Spot". Thus, a combined exposure represent the "Accessible" exposure zone. The data associated with each of these exposure zones, and the calculated exposure point concentrations are summarized in Table I of this report. A review of this table notes that each of the individual and combined exposure point concentrations are below the applicable Method I S-I risk standards.

Groundwater Characterization - 301 CMR 40.0932 Groundwater is categorized based on proximity to drinking water sources, proximity to structures, and surface water impact. A characterization of the groundwater in the area of the disposal site indicates:

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*

classified as a Current or The disposal site is not subject to GW-1 standards since it is not located within an area Potential Drinking Water Source area;

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Athol Medical Clinic / IRAC and RAO Report 1467 Main Street, Athol, Massachusetts 01331 Release Tracking Number: 2-148l5

24 May 2005

*

GW-2 Standards will be considered applicable, since the release did occurred within 30-feet of the an occupied building and the depth to the groundwater table may be less than 15-feet below the existing grade; and

*

As is the case for all disposal sites, groundwater at the disposal site is a potential source of discharge to surface water bodies and, therefore, is subject to GW-3 standards.

Exyposure Point Concentrations. Groundwater - 310 CMR 40.0926 Exposure point pathways are defined, without limitation, as ingestion, inhalation, and/or dermal absorption of the impacted media. To evaluate the groundwater conditions, a single groundwater sampling points was created between the excavation and the adjacent wetlands. A water sample obtained from this location was collected and analyzed for concentrations of EPH and VPH compounds. The results of the testing reported no evidence of petroleum impact above an applicable Method I Standard. Based on this information, it appears that the release did not have an impact on the underlying groundwater. Therefore, the computation of a contaminant exposure point concentration was not determined or calculated [assumed as background / non-detectable].

Indoor Air Evaluation - 310 CMR 40.0995 No evidence of an indoor air issue was encountered during the completion of the site response actions

Feasibility Assessment - 310 CMR 40.0860 Pursuant to Section 310 CMR 40.0860, a feasibility assessment was conducted and based on the following criteria: 1. Evaluating the feasibility of implementing a Permanent Solution; 2.

Evaluating the feasibility of reducing the concentrations of oil and/or hazardous materials in the environment to levels that achieve or approach background; and

3.

Evaluating the feasibility of reducing the concentrations of oil and/or hazardous materials in soils and groundwater at the disposal site to levels at or below applicable Upper Concentrations Limits.

The findings of the investigation and response actions have reduced the concentrations of contamination to levels under the applicable risk based standards. These residual concentrations indicate that background levels have not been obtained. Thus, pursuant to 310 CMR? 40.1020 (3), a Feasibility Assessment (Section 40.0860) must be completed to determine whether a Permanent or Temporary Solution, to the reported contaminants (i.e., residual concentrations), has been achieved at the Disposal Site. The feasibility of achieving a permanent solution or restoring background conditions at a Disposal Site is dependent upon any one of the following factors: a) b) c) d) e)

the technical feasibility; a cost-benefit analysis; the availability of trained and knowledgeable personnel; the availability of an approved off-site disposal location (i.e., Federally or State Approved); or the location of the source (i.e., off-site release).

An evaluation for achieving a Permanent Solution, or restoring background conditions, was completed using the technical feasibility and cost-benefit analysis procedures. According to 310 CMR? 40.0860 (S)(a), if existing technology or reasonable modification of technology cannot remediate the contaminant at the Disposal Site to the extent necessary to attain levels that approach of achieve background, the remedial action shall not be considered technologically feasible. According to 310 CMR? 40.0860 (4)(b) and (6)(a), if the incremental cost of conducting the remedial actions is substantial and disproportionate to the incremental benefit of risk reduction, environmental restoration, and monetary and non-pecuniary values, then the benefits of implementing the remedial action to achieve a Permanent Solution and to reduce the concentrations of the contaminants in question in the environment at the Disposal Site to levels which achieve or approach background, are not considered feasible.

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Athol Medical Clinic / IRAC and RAO Report 1467 Main Street, Athol, Massachusetts 01331 Release Tracking Number: 2-14815

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In this particular case, in order to attempt to approach or achieve background concentrations of the reported contaminants (assuming that background concentrations are analogous to non-detectable concentrations) additional remedial measures would be required. The confirmatory analytical results reported residual concentrations of petroleum constituents exist. Thus, the implementation of remedial actions contaminants insitu, or to excavate and dispose of them off-site. Additionally, inconvenienced during the completion of the response actions. However, since a been achieved at the site, the cost associated with initiating remedial actions concentrations, would not proportionally reduce the current Risk Characterization.

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would be required to treat the the site would be disturbed and Level of No Significant Risk has to reduce the reported residual

Currently, the site has achieved a Level of No Sigificant Risk without implementing an Activity and Use Limitation on the limits of the Disposal Site. Additionally, the primary source was eliminated, and the secondary source eliminated through removal and disposal of the impacted media. Lastly, response actions have reduced the levels of residual concentration to under Method I Risk Characterization Standards and Upper Concentration Limits. Thus, a permanent solution has been achieved, and additional remedial measures would not be required at the site to reduce the reported contaminant concentrations to background levels according to the provision provided in Section 40.0960 (4)(b) and 6(a).

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Response Action Outcome C'ategorizationDetermination- 310 CMR 40.1030 Pursuant to Section 310 CMR 40./030 (2) the specific category of Response Action Outcome applicable to a site or Disposal Site shall be established based on the following factors: 1. if site conditions pose No Significant Risk; 2. the elimination of a substantial hazard(s); 3.

a Level of No Significant Risk being achieved by remedial measures;

4.

the implementation of an Activity and Use Limitation(s) to maintain a Level of No Significant Risk; and/or that the

5.

remedial actions achieved background levels.

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has The findings of this investigation and remedial actions have satisfied items I trough 3. Thus, a permanent solution been achieved, and additional remedial measures would not be required at the site. Pursuant to 310 CMR 40.1036, a Class A-2 Response Action Outcome Statement applies to the Disposal Site since: 1. A Permanent Solution has been achieved;

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2.

The levels of oil and hazardous material in the environment have not been reduced to background; and

3.

One or more Activity and Use Limitations are not required to maintain a Level of No Significant Risk.

a Class A-2 Response Action Outcome has been achieved at a site when the source of (5), to 40.1/003 to 30 CMR Pursuant the contamination, which is likely result in an increase in the concentration of the contamination in an environmental media, is eliminated or controlled. In this case, the source was eliminated and the impacted media removed from the

site.

CYN Environmental Services 100 Tosca Drive, Stoughton, MA 02072

Cyn Project Number 20i882-0o-TS Page 10 of I l

Athol Medical Clinic / IRAC and RAO Report 1467 Main Street, Athol, Massachusetts 01331 Release Tracking Number: 2-14815

24 May 2005

Risk to Safety Evaluation - 310 CMR 40.0960 Pursuant to 3/0 CMR 40.0960, a Level of No Significant Risk to Safety exists or has been achieved if the conditions at the disposal site, which are related to a release of oil and/or hazardous materials, do not currently and will not in the foreseeable future pose a threat of physical harm or bodily injury to people. In this case, the source of the release was addressed and the impacted media were removed, and the excavated areas backfilled. Hence, a Level of No Significant Risk exists.

Conclusion In conclusion, a Class A-2 outcome has been achieved and no further action is required. To complete the PRPs investigative and MCP compliance obligations, Cyn has prepared a RAO Statement [Appendix A], which details that; a Class A-2 outcome has been achieved.

Certification The conclusions and recommendations provided herein are based solely upon the scope of work conducted and the availability of information at this time. Any additional information, which becomes available concerning the disposal site or the abutting properties, should be provided to Cyn Environmental Services so that we may evaluated whether there is a need to modify the conclusions and recommendations accordingly. Should you have any questions or require any further information relative to this submittal, please feel free to contact me. Sincerely, Cyn Environmental ervices

Philip D cBain, LSP Sr. Project Manager

Tables

I

Summary of Soil Testing Results

Figures

1 2 3 4 5

Site Locus Map General Site Layout Plan MADEP / GIS Map Soil Sampling Location Plan Conceptual Site Modeling Plan

Appendix

A B C D E F G H

Immediate Response Action Transmittal Form [BWSC-105], Photocopy Response Action Outcome Transmittal Form [BWSC-104], Photocopy Site Photograph MADEP Correspondence Standard Operational Procedures and QA/QC Plan Disposal Arrangement Paperwork and Testing Report July 2004 Laboratory Report - Soil Testing Services August 2004 Laboratory Report - Soil and Groundwater Testing Services Bill-of-Lading and Uniform Hazardous Waste Manifests-

I cc:

Athol Medical Clinic Cyn File

-

Athol, MA

CYN Environmental Services t00 Tosco Drive, Stoughton, MA 02072

Cyn Project Number 2018824O0-TS Page t t of It1

Table I.

Summary of Soil Testing Results

CYN Environmental Services

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f Registration of Hazardous Waste Site CLeanup Profesuionals by telephone at (617) 556-1091, ir in person or by mail at One Wintr Street,10th Floor, Bdston, Massaohusetts 02108.

Iaddresses

If you have any quastions, please contact this offce at the letterhead address or at (508) 792'/63. The Deartment reauests that vo nmr your LSP of this Notice. .All future correspondence comnmicationsiregarding te disposal site should referenceRTN: 2-14815.

I

Sincerely,

Juy1.203Sinae FSNCw

-

[NOMISSUED.ER]

I

nclosures .cc:

g

Section Chief Bureau of Waste Sitto Cleanup

AtholFireflepartmentPhil MoBain; LSP; CYN Environmenal, Inc.; 100 Tosca Dr., Stoughton, MA )2072 Database Entry 2-0014sl3- Atl0-nor

P. 010.

I

02/2S/04

l8. 2004

~

10:57AM

DEP-CERO

508 792 7621

12:10pm

No.2819

P. 011

P.6/f1

SUMMARV dI1UABLIfY UNDERCHATRI21E

IAs

mated Inthe Notce eof Raespo nsiiiy hccffmpanyln; als Sumnsy, the Depnemt has reast n to believe that you arn Potenially Responible Pmny ("PRP") with potwtial lifability under M.G. e,2IE, gtin 5,for tespwe a nan coats and damnaget te nummi retomnae ad y the rokosM n/or thrnt of release. The Dwptent bas idetified puu Ps t Pbeue It bellvs you Al inoe or rmsr of the ftlowing waegoies ofpmrsons made potendally liable by Subsedton 3(a): - any cwrem owne or operaor orf alte born orsa which ther is or has been a release or thre ofrtlnaof oil

3*

any person wo

a any

5:

nedworoperaeda ste ar thet dme bataidcus rnteral wes stored or disposeof,

peron who mranged

e uesaport, disposal, sinrge or trieane ofhazardous material1 nor atse;

* y person who rnspoted hazdus mariai to a tranhport, disposal, therm Isor has bemn arelease or ireat of release or such material; ad-

magse or tratment site hom which

- any peaon who othewse caused or is legal respousible for aresse or threat of release of all orhmnerdous For purposes of the MCP', you are considere * Rlesponsible Party ("RP") with actal liblky unt lr diapter 2II if you Nill riekes you (I) are entiiled to adeanse. under Section 5 oioter aplicable i' v,and (2)have reasonably meurred cleanup coats in anon equal to or greater than any applicable cap on ialty und etir M 5(d).

within

I

one of thes catgo

lls liability is "se,"meaning illis not based co lauf but solely ren your stames ascar -mer, operator, gnato, transpoter or dispose. It isalso jont and several/mning t eac person who fhils within one of ihesategonea may be bald liable for ali responsaractonwossncmdte atta~tegdless ofteeneiswnc fmanyoterhlable partie.

3

Scot. Sprovides a few naowly drtawn defenses to labilit, Including adefbne for releates and danages caused by an act

. of God, msot oftwr oren aerby sthird party other than an Sinployee, agent or person with whom the party hasn a ormafeal relationship (. Subsaelion 5(4)); a defenae for rtni n net of reidaisi propenty at whicthe miw er matmaint a ponnanunt

presidence

(sne Submeton 5()) and adeftane for ea~In pulie utilitIes and agenctes ofthec Commonawualth wichi own anght-of~way

thtunmitseessctionS)).

I

You may vohntarily undentake taonse ecdwionmder the MCP wthoul having yomr liability wr de riper 21- fotnafly uagudicated by the Dertmemr. Ifyou do not take the necessary response acdions, or fil to perform than Inan appropriate and timely manuner, the Deprtmi is ambronrd by ChapterI 2IBm pertebn the necessary work. pefomigthese aadons [f you ore asRP end you fhil to perfom necessary response aons at the uIte, yot may be hold liable fbr tp to the 3 ie l epneato ot nurdby the Dleparnt and sanctions may be imposed on you ftr Ibiluro to pedorm by the 14CP.

I ~response aeoerequrd . Reponise nelln cots iiclde,

I"T Z

n

so ov

em

ivor

without

lirmtatlon, die

cost

of direct houma-pant by Depatmen' employees marring for

peribrmed by prann other thanthe Depflrwn oris controsxpenenurrenyi h

de'ot, ie Departent may laciens o ad of yourpropertyin the Cormmonwealth imder MG.Le. 212, Siction I3. To recover this debt, the Commonwealth may foreclose on these Uian orthe Attormey General ray bring legal acton aginsl yoU.

I

In additi on to yourjmetu li iw for response taton cost. and damages to natural resources caused bythe relase, clvil aneriminal liabilily ma uo eiposedby a court of enmpetent Jurldction under M.O.L c. 225, Section I I, and civil ~~~adminilrmnya pEnalties mny bewaaeed by' the Dparent under MGL el. 2A Sectdon 26, (hr each via tion of Chapter 1B, the MCP or any or pemi Or approval Issued thermur If you are an RPY and you have roason to believe Ohat your perfomance of dhe neceauy responsa amtioa i beyond your tecmeal, finnocial or legal ability, you should promptly notify the Depstmn in writing of your inabilliy In accodace wilh Chapter 21B, Subsection 1(e and 330 CMR 4072. If you assert and demontats in compliance therewith that part rmring or paying for such response action isbeyond your ability, Suhsoedcn $(e) provides you with a limited defoense to an action t y the CoImonWealp for recver otwolo hreties heDeprtmnts rsposeactoncosts and 310 CMR 40.0172lprovides you wits limited defenistothe *Departmeta assnt of civil mdmnfrdredve pernulds.

a

-

5?

A~al Id. LUU4 IU:00AM

-

Ut -~u

t

0S/23/04

uu3 8 /2 il

12.:10pm

- 021

MrmtnOMNZY -

ELLEN RoY RZRtnnit

opvrnerBacratary

KERY HLt

oaz!rr w. GOLLEDGE rr

H

URGENT LEGAL MATTER: PROMPT ACTION NECESARY Athol Medical Clinic 1467 Main St. AtholMA 01331

*

R

ATTN: Julie Hockman,

OffEce Manager

I

.NOTICE

3 ~

RE: CRWSC - Ato! Athol Medical Clinic 14d7 Main St. -

-KRN:

2-14815'

NON-CB-03-3146

OF NONCOMPWLIANCE-

ThNTERI DEADLiBS MIL 6.21E,.310 CMR 40,0000 FAILURE TO SUBMIT A RELEASE NOTIFICATTON FORM WITH!6 DAYSl FAIURE TO StJMfT AN IRA PLAN WITHIN 60 DAYS.

I I

-/ I

COMMONWEALTH OF MASSACHIUSETTrS -EXECUImVE OFFICE OF ENVIRONMENTAL AFFAIRSDEPARTMENT OF ENVIRONMENTAL PRO'IECTION Central Regional Office. 411 Main Street, Worcester. MA OLGOS

5

if

A review of infonnation available to the Department demonstrates that you Ailed to comply with one or more laws, regulations, orders, licenses, permits, or spprovals enforced by theDepadent.Be advised that the regulations that generally set forth the requirements of providing notihcation and conducting Imrnediate Response Actions are coditled at Subparts C and D), of the Massachusetts Contingency Plan, 310 CMR 40.0333'and 310 CMR 40.0420, rea ectively. The Deparment has included with and specifically incorporated into this writing a NOTICE OF NONCOMPLIANCE SUMMARY, which includes: L. the elements and occurrence(s) of the noncompliance necessitating thin issuance of this Notice; and-

I

I

P. 002

2. the deadline(s) within which a return to compliance must be acl loved by:£. coming into compliance with the applicable requirements, or ii. subtmitting a written pmposai to the Department setting forth how and when coming ito compliance with the requirements will be achieved

I

Tb Is fnadn i* ans~ahl, toalferna. hmar. ca Aprathfcak 1 ADA cordiauoiwu-6I7-Sf5647.

U

Pulntad on n.cyed pape

33/2s/4 04 10:58AMl DEP-CERD CB OF NONCOMPLIK. JB

SDB 792 7621 NON-CB-O3-.L44.

iza

No.2819

po . aes

P.8/l

Page 2

An administradve penalty may be out of compliance with the requirements assessed for every day from now w that you remain Notwithstanding tis NON, the Dqiarmnent described in this Notice of Noncompliancee (NON). authority in orde to obtain fll compliance reserves tho tight to exercise the frI extent of Its legal wit limited to the assessmnt of civfl namnitrative all applicable legal requiremen s, including but not penalies, the cormmencement of a civil court(s) of competent jurisdiction, or tecommencement action in the of acriminal prosecutian in the court(s) competent jurisdiction.-of

mn ambiguity or confision concemning tis-Notice. Inresponding to this NON, please reference the NON numiber found on ihe first page document to ensure proper acknowledgement of this of your response. ThelwDepartmen requestsht.vo itbun Vour SP of this Notice.

October 6.2003

Nicholas J. Child Branch Chief, Emergency Response Bureau of Waste Site Clesiup

NJC/ EncL [C&WFNLET C&B/NON

cc:

J

James Moody, CDRO/BWSC Enfortement Coordinator Michael Maher, CERO Regional Enforcement Mary Gardner, CERO/BWSC Deputy ReglonalCoordinator Director Datgbase BEtry

0S/2'3/04

. ' DEP-CEHO 508 192 1821 04 10:59AM CB OF NONCOMPLOE SUMMARY NON-CE-03-$4

3! I, U

12:10pm

No. 2819

P. 10/l

Page 2

310 CMR 40.0420(7%t Reouirements. Approvals, and Time Lines for Conductine Imrnediate

7'

(7)Phcept as provided in 310 CMR 40.0420(8), and without regard to whether oral approval was given by the Department to conduct or initiate Response Ar-ions, Rhs and other peson~s conducting response actions shall submit t o the Deparment an Innnediate (a) within 60 days of providing oral notificaion to the Departmientbof -hose"2 Hour" or *72 Hlour" releases or threats of releases specified in-31C CMR 4O.0311 through 40.0314; *(b,) within 60 days of orally communicating to the Department kniowli dge.of a condition of Substantial Release Migration at a disposal site; (c) within 60 days of the date that the Deparitment issues a Notice of Responsibility indicating that they are an RP or PRP for a site at which an Immediate Response Action isrerenidpursuant to 310 CMR 40.0412; or (d) within a time pediod established bythe Department as an Iterim D~eadlino inaccordance with 310 CUR 40.0167. DESCRIPTION OF ACT OR OIfSION CONSTITUTING NONCOMPJJINC

.

Based on-lhe above ihformation, the due date for submitting adt IRA Plan to the Department was August 18, 2003. The Department has yet to receive an iRiA Plan for this rselease~as required by~l 30dR40.0420(7). DES CIPTION OF fQUIREMENTS NOT COMPLIED WITH

* 310 CMR 40,042,0(7%: Requirements. Aporovals. and Time Lines for Conduotine Immpediate

*

P. 004I

(8) Except as provided in 310 CMR. 40.0420(8), and without regard to whether oral approval wvas given by the Departmt to conduct or initiate Response Actions, RPs and other persons conducting response actions shall submfit to the Departnrent an Itnmediate Response Action Plan, within the earliest of the foillowing time periods: (a) wthin 60 days of providing oral notification to the Dleparment of those "2 Hour" or "72 Hour" releases or threats of releases specified in 310 CMRP 40.0311.through 40.0314; .0dy foal omnctn t h eatetIoLdeo (b) within 6 aso rlycmuiaigt h eatetkolieo condition of Substantial Pelease Migration at a disposal site; (c) with 60 days of the daze that the Depatment issues a Notice ofltessponuibility indicating That they are an RP or PRP for a site at which en Immediate Redponse Action is requied pursuant to 310 CMRP 40.0412; or(d) withntieperiod establishedby teDparnentuannerim eadline in accordance with 310 CMRt 40.0167.

0S/2S/04

*

-04

10:58AM

DEP-CERO

509 792 7621

12:10pm

No 2919

9. 9/li

NOTICE OF NONCOMPLIAlNCE SUMMARY NON-CE-03-Q4{

-

I U 3 I I 1 I I

3

Athol Medical Clinic l467 Main St. fDATE OF NONCOMPLIANCE

AMgust 18, 2003 DESCRIPTION OFRSEOQUIEMENTS NOT COMVPLIED WITH

310 CMR 40.333: How to Notify (1)

Two Hour and Seventv-Two Hour Notifications. Persona descrit ed in 310 CMR-

40.0331(1) shall:

~

~

(a). notify the Department of arelease orthreat of release specifieS in 310 CMR 40.0311 through 40.0314, inclusive, by calling a telephone number published by the Department and designated for that purpose and orally notifying die Department the informarion specified in 310 CMR 46.0334; and (b) within 60 days thereanter, submit a completed Release Notification Form, as described in 310 CMR 40.0371, to the Departrnent oeuce looated:n the DEP region in which the release or threat of release occurd. Where appropri ate, the Release Notification Fonn may be accompanied by a Response Action Ou tcome Statemnent,

as described in 310CMR 4.1000.

I

DESCRIPTION OF ACT OR OMWISSION CONSTITUTING-NONCOMPLIAJQS-

The Department of Environmental Protection (the Department) was nC tified on June 19, 2003, at 11:45 a.m., that a sudden release of an unb::own amount of No. 2 (il occurred at the above-reftrenced property. Specifically, the release occurred from the fill pipe of two, two ansventy-five (275 gation abovegroundsoag tanls(ASTn) kocatedinde

Ihundred I

I

ASTa, tebydisplacing an unknown amount of oil frmthe AST, and releasing the oil from the fdll pipes to the soil.

I

P. 006

Based on the above information, the due date for submitting an RNF to tice Department Was August 18, 2003. The Department has yet to reoeive a Release Notification form for-this release, as required by310 CMR 40.0333(1)(b);

03/2s/e4

12i10pm

P. 01S8

LOCATION: Central Regional Office 627 Main Street Worcester, MA DATE:

March 30, 2004

TIME:;

10:00 am.

The purpose of the enforcement conference is to provide you with the opportunity to reach a negotiated agreement with the Department to return to compliance and pay a civil administrative penalty as appropriate. The Department believes that pror apt resolution of this enforcement case in a manner that ensures your 'expeditious return to compliance and resolves all penalty issues is beneficial and consistent with the Department's environmental protection goals.. The enforcement conference will provide you with the opportunity to dis';uss the alleged violations and your return to compliance and/or penalty conditions of a final enforcement document.. Prompt settlement may also decrease the resources you and the Department might expend on protracted litigation of the issues. If you either do not attend the enforcement conference or do not reach a negotiated settlement, then the Department will initiate appropriate enforcement acti ons and you will have limited, if any, further opportunity to reach a negotiated settlement of this case. Please contact Kevin W. Daoust at (508) 767-2815 to confirm your attendance at the Enforcement Conference or if you have any questions. Sincerely,

Date:

MazyDG'td Deputy Regional Director Bureau of Waste Site Cleantp

Enclosure Cc:

Robert Brown, Chief Regional Counsel DEP CERO James Moody, Regional Enforcement Coordinator, DEP CERO

I

~03/2L/04

12:10pm P. 014I

Attachment I DEPARTMENT 0OF ENVIRONMENTAL PROTECTION Policy Statement SETTLING CIVIL ADMINISTRATIVE PENAL TY CASES The Department's goal Is to encourage settlements In a ppropriate enforcement cases as early in the administrative penalty process as possible (iLe.,conducting pre-Issuance enforcement negotiation meetinigs leading to a consent order with penalty). The Department believes that by encouraging earlysettlements that meet the Department's environmental jrotection goals, it will maximize limited resources and benefit the environment through early -compliance. Early settlement allows violators to save the potentially great costs resulting from adjudication of the ease and provides them witha an opportunity to have more input into the compliance condition;s. Early settlement provides the violator with a greater opportunity to settle with more favorable terms and conditions, where later settlement, :f any, with the Department may result in less flexible conditions depending ona the circumstances of the case. The Department will continue to allow violators to pres ent new factual information concerning the alleged violations at any point in the settlement process.

0//4.12110pm P. 01E

Attachment 2 Athol Medical Clinic Violations

Violation 1 FACTS: The Department of Environmental Protection (the Department) w as notified on June 19, 2003, at 11:45 a.m., that a sudden release of an unknown amount of No'. 2 oil occurred at the above-referenced property. Specifically, the release occurred from the fill pipe of two, two hundred and seventy-five (275) gallon aboveground storage tanks (A.STs) located inside. According to information available to the Department, rainwater entere d the fill pipes of theASTs, thereby displacing an unknown amount of oil from the AST, and re leasing the oil from the fill pipes to the soil. Based on the above information, the due date for submitting an RNF to the Department was August 18, 2003. The Department has yet to receive.a Release Notification form for this release, as required by 310 CMR 40.0333(1)(b). On October 6, 2003, the Department issued a Notice of Noncompliance (NON-CE-033146) to Athol Medical Clinic, requesting the submittal of the RNF and IFA Plan by November 3, 2003. Athol Medical Clinic has not complied with NON-CE-03-3 146 to date. LAW: 310 CMvR 40.333: How to Notify (I) Two Hour and Seventy-Two Hour Notifications. Persons desc:-ibed in 310 CMR 40.0331(1) shall: (a) notify the Department of a release or threat of release specified in 310 CMIR 40.0311 through 40.03 14, inclusive, by calling a telephone number published by the Department and designated for that purpose and orally niotifying the Department the information specified in 31l0:CMR 40.0334; and (b) within 60 days thereafter, submit a completed Release Noti:ication Form, as described in 310 CMR 40.0371, to the Department office 1Iccated in the DEP region in which the release or threat of release occurred. where appropriate, the Release Notification Form may be accompanied by a Respconse Action Outcome Statement, as described in 310 CMR 40.1000. VIOLATION: -Athol Medical Clinic failed to comply with NON-CE-03-3: 46 by failing to submit an RNF within established Interim Deadlines.

APPENDIX E StandardOperationalProcedures & Quality Assurance / Quality Control Plan

CYN Environmental Services

Standard Operation Procedures ISOP'sl IDrilling Procedures (if required) a)

Overburden:

Test borings are accomplished by using a truck-mounted rig vehicle set-up with both hollow stem augers and flush jointed casing. Drilling operations will be completed using the procedures outlined in WSC-3 10-91 "Standard Reference for Monitoring Wells", Section 3.3 - 2.2. Hollow stem augers will be advanced to the groundwater table or contaminated media to allow the collection of soil samples and to allow the documentation of the subsurface conditions. If required, drilling operations will be converted to flush jointed casing to minimize potential contaminant transference whibh would occur during auger operations. The casing will be advance into or through the zone of contamination to allow the installation of the proposed monitoring well or define the limits of the soil contamination. The casing will be advanced using a 300-pound weight dropping a distance of 24-inches. Drilling fluids generated during the cleaning of the interior annular casing space will be containerized on-site for treatment or disposal considerations. A FRAC tank will be used to allow the separation of the suspended soil from the drilling fluid. Representative samples of these solids and fluids will be collected and analyzed to determine if treatment or disposal actions are required towards this material. The collected soil and fluid will be containerized and disposed of as contaminant conditions dictate. Refer to Section V and VI of this SOP for information regarding soil sampling and decontamination procedures, respectively. The soil test borings drilled to the bottom of the aquifer [deep wells] will be located in area of greatest known or suspected contamination as determine by the Phase II Investigation. These borings will be extended to the bottom of the aquifer [lower permeability strata] or until refusal is encountered with the flush jointed casing. The bottom of the aquifer will be determined by field personnel during the drilling operations by identifying and confirming the presence of a less permeable material than the overlying strata; i.e., clay, silt, glacial till or bedrock. Based on the present site conditions, the installation of deep test borings does not appear to be required. b)

Bedrock Coring:

The installation of bedrock monitoring wells are currently not proposed in this investigation study. If contaminant conditions are detected which require the installation of bedrock monitoring wells, then the procedures outlined in WSC-310-91 "Standard Reference for Monitoring Wells", Section 3.6 will be followed. The installation of the test borings will be completed in a manner to ensure that contaminants from upper laying locations will not migrate down to the underlying bedrock aquifer, if present. IISoil Samplin2 Probes The soil sampling probes will be completed using a 3-inch diameter, hand operated, bucket auger. To complete this task, a coring machine will be used to allow an egress for the bucket auger. The auger will be advanced through the soil to obtain a representative soil sample from the soil/water interface. This sample will be placed in a glass jar, screened for total organic vapor readings, and submitted for laboratory analyses. The constituent analyzed for will include volatile organic compounds, total petroleum hydrocarbons, and polynuclear aromatic hydrocarbons. After the sampling collection, the hole will be backfilled with the excavated soils, and the concrete surface seal installed. Refer to Section V of this SOP for information regarding the sampling equipment decontamination procedures.

CYN Environmental Services 100 Tosca Ddiver, Stoughton, MA. 02072

Page I or 9

Ill

Monitoring Well Installation (if reauired) a)

Overburden:

The monitoring wells will be constructed with a 0.5 foot long sediment trap-attached to a 10 foot long section of threaded 2 inch diameter, 0.010 inch slotted schedule 40 polyvinyl chloride [PVCI wellpoint. The wellpoint and sediment trap will be extended to the ground surface by a solid 2 inch diameter threaded PVC riser pipe. Following the installation of the sediment trap, wellpoint and riser pipe, a clean sand filter will be placed around the sediment trap and wellpoint to approximately I foot above the slotted wellpoint section. A one foot thick bentonite seal is then placed above the silica sand filter. The remainder of the annular space is filled with native soil to within a foot of ground surface. At this point a gate box is installed flush to the ground surface and a concrete seal incorporated. All PVC connections are completed without the use of glues to prevent contamination. After installing each monitoring well, the well is developed using one of the procedures outline in Section 4.5 of the DEP policy WSC-310-9l "Standard Reference for Monitoring Wells". Due to the anticipated depth of the overburden wells, it appears that an over-pumping technique will be employed to develop these monitoring wells. Fluids evacuated during the well production will be stored in a container. Samples from the container will be collected to determine the disposal protocol. b)

Deep Wells:

Based on the existing information, deep monitoring wells have not been proposed to be installed at the Disposal Site. However, if conditions generated by the Phase II Investigation, or the schedule remedial measures require, then deep monitoring wells will be installed using the following protocol. These monitoring wells will be screened at the bottom of the overburden aquifer to sample for the chlorinated organic compounds detected on the site. These deep monitoring wells will be constructed of a 0.5 foot long sediment trap attached to a 5 or 10 foot long section of threaded 2 inch diameter, 0.0 10 inch slotted schedule 40 polyvinyl chloride [PVC] welipoint. The wellpoint and sediment trap will be extended to the ground surface by a solid 2 inch diameter threaded PVC riser pipe. Following the installation of the sediment trap, wellpoint and riser pipe, a clean sand filter will be placed around the sediment trap and wellpoint to approximately 1 foot above the slotted wellpoint section. A one foot thick bentonite seal is then placed above the silica sand filter. The remainder of the annular space is filled with concrete grout to within a foot of ground surface. At this point a gate box is installed flush to the ground surface and a concrete seal incorporated. All PVC connections are completed without the use of glues to prevent contamination. After the installation of each monitoring well, the well is developed using one of the procedures outline in Section 4.5 of the DEP policy WSC-310-91 "Standard Reference for Monitoring Wells". Due to the unknown depth of the deep wells, it appears that a mechanical surging technique with over-pumping will be employed to develop these monitoring wells. Fluids evacuated during the well production will be containerized and laboratory analyzed to determine the appropriate and applicable disposal method, if required. IV Groundwater Samnlina Prior to the initiation of the groundwater sampling collection, an initial site reconnaissance is performed. The procedures involve the inspection of each monitoring well to ensure that the protective casing is intact and that no apparent vandalism has occurred since the monitoring well was constructed.

CYN Environmental Services 100 Tosca Driver, Stoughton, MA. 02072

Page 2of 9

Once the protective cover is removed, a check of the well headspace is performed using a photoionization detector for total organic vapors (TOys). This instrument is calibrated to benzene in accordance to the Massachusetts Department Environmental Protection and manufacturing requirements. In addition, static water levels are measured along with the total well depth. These values are used to determine the volume of water bailed prior to sample collection; in addition, a check is made with the drilling records to ensure that the migration of fines into the well screen has not occurred. Upon the completion of the reconnaissance program, water samples are obtained from each monitoring well. Prior to purging and sampling the well, a clean bailer and product-water interface probe will be used to check for the presence of light or deep non-aqueous phase liquid [U.DPAPL] or a petroleum sheen. Additionally, a sample will be collected from the monitoring well to document the pH, conductivity and temperature of the groundwater. After checking for a UJDNAPL layer, a volume of water equivalent to three times the standing water in the well is evacuated (with a freshly decontaminated submersible pump or bailer) and allowed to stabilize. After the water level stabilizes, the sampling equipment will be used to collect the require samples for laboratory analysis. Prior to purging and sampling the next location, the submersible pump or bailer will be cleaned in a five step process. First, the equipment will be cleaned with a brush and tap water, next an alconox solution will be used to clean the equipment, followed by a methyl alcohol bath, distilled water rinsing, and finally air drying. Upon commencement of the purging and sampling at the next location, new product transfer tubing or rope will be used to ensure against cross contamination. Each sample is placed in a sample contains and labeled with identification which includes the job name and number, date, time, sample's name, sampling identification, preservative and analysis to be conducted. All samples are placed in a cooler, chilled to approximately 4 degrees Centigrade and shipped immediately to a Commonwealth of Massachusetts, Department of Environmental Protection certified laboratory. All meters used during the groundwater sampling program [photoionization meter and probes] are calibrated in accordance with the manufactures specifications to ensure the validity of the collected date. This calibration program will be completed prior to the arrival at the site. V

Soil SampnlinE Soil samples are collected in accordance with ASTM D-1586, "Penetration Test and Split Barrel Sampling of Soils". Standard Penetration Tests (SPT) are performed in all test boring locations. A continuous sampling method will be completed in one exploration location to supply additional information on the subsurface lithology conditions and contaminant characteristics. Soil samples are collected at five (5) foot intervals or at changes in the subsurface conditions. Soil sampling operations will be converted to a continuous sampling methodology based upon elevated TOV readings so that the zone of soil contamination may be defined. Split-spoon soil samples are collected by using a split-spoon sampler, inserted into the hollow stem auger, and then driving it through undisturbed soil (by means of 30 inch blow from a 140 pound hammer). These soil samples are placed in precleaned glass jars and capped immediately to prevent any loss of volatile organic compound or oxidation. A layer of aluminum foil is place between the jar opening and the screw cap to provide a tight seal. Soil samples obtained from the split spoon sampler during the test boring program will be analyzed with a direct reading photoionization detector (HNU or Microtip) for concentrations of total organic vapors. As required by the MADEP protocol [jar headspace], the collected soil samples are warmed to room temperature (70 degrees Fahrenheit) prior to screening. Soil samples chosen for laboratory analyses are selected as the 'worst case' based upon field screening using the photoionization meter or due to particular or atypical color or odor. The selected soil samples are analyzed for concentrations of total petroleum hydrocarbons, polynuclear aromatic hydrocarbons and/or volatile organic

CYN Environmental Services 100 Toscn Driver, Stoughton, MA. 02072

Page 3 of 9

compounds. The orientation of this testing is based on previously existing analytical data and the conditions detected during the exploration program. Revisions to this analytical program may be required based on the detected subsurface conditions. Overburden sampling will continue until background levels, as recorded by the field screening or TOVs are obtained or refusal is encountered during the test boring program. Samples selected for analysis are placed in the appropriate sample contained and labeled with identification which includes the job name and number, date, time, sample's name, sampling identification, preservative and analysis to be conducted. All samples are placed in a cooler, chilled to approximately 4 degrees Centigrade and shipped immediately to a Commonwealth of Massachusetts, Department of Environmental Protection certified laboratory. Soil samples selected for physical property analysis will be stored/preserved in accordance with the procedures outlinedin ASTM D-4220-89 "Standard Practice for Preserving and Transporting Samples." Cyn's Site Health and Safety Protocol require that these samples be screened for TOV readings or analyzed for the contaminants detected at the site. Samples submitted for gradation analysis will be completed using the procedures outlined in ASTM D422 "Standard Method for Particle Size Analysis for Soils". VI Decontamination Procedures Prior to the start of the exploration program, the drilling contractor will completely clean and decontaminate all equipment to be used at the site. This will ensure that contaminants are not transferred to the site from a previously completed location. Between each exploration location, the equipment used during the drilling event will be transferred to a centralized location for decontamination. The following will serve as the minimum standard for the drilling process: 1. 2. 3. 4.

Portable water rinse and brushing Soapy water cleaning Steam cleaning Portable water rinse and air drying

.All fluids produced by this process will be containerized for off-site disposal. To confirm the integrity of the portable water source used by this decontamination process, a sample of the water will be collected from the location and analyzed for the items listed during the Phase II Investigation. During soil sampling, the drilling contractor will supply two to three split-spoon samplers to ensure the integrity of the collected soil samples. This will reduce delays produced during the decontamination of the sampler after each sampling event. Cyn will require that the split spoon samplers are decontaminated using the following process: 1. 2. 3. 4. 5.

Portable water rinse and brushing Soapy water cleaning Portable water rinse Distilled water rinse Air drying

Prior to purging and sampling the next location, the submersible pump or bailer will be cleaned in a five step process. This process will include: 1. Portable water rinse and brushing 2. Soapy water cleaning [alconox solution] CYN Environmental Services 100 Tosca Driver, Stoughton, MA. 02072

Page 4 orfg

3. 4.

Distilled water rinse Air drying

Upon commencement of the purging and sampling at the next location, new product transfer tubing or rope will be used to ensure against cross contamination

VII Hydraulic Conductivity Testing [Slug Testing, if requiredi Hydraulic conductivity testing will be conducted on select monitoring wells. Hydraulic conductivity is the rate at which water passes through a permeable medium under unit gradient and the value is generally given in units of cubic feet [volume] per square foot[area[ per day [time] or simplified as feet per day [ft/day]. The hydraulic conductivity is calculated by removing a volume or slug of groundwater from a well and recording the rate of recharge of groundwater to the well. To accurately record this rate, a pressure transducer and data logger are used during the performance of the slug test. The transducer measures pressure differences and the data logger records and stores the measurements at specific timer increments. Manual calculations convert the recorded pressure differences into actual groundwater fluctuation depths. The ratio of recorded changes in water depth (h/h 0 ) are computed and plotted versus time (t) on send-logarithmic graph paper. Data from the graph is incorporated in an equation to cbmpute the hydraulic conductivity of the aquifer surrounding the well tested. A potential groundwater flow rate will be calculated in units of fl/day using the following relationship. V

=

K (dh/dl)/n Where:

= flow rate (ft/day) K =average hydraulic conductivity (ft/day) dh/dl = hydraulic gradient (ft/ft) n = porosity of the soil

y

Transmissivity is rate which groundwater is transmitted through a unit width of an aquifer under a unit hydraulic gradient and the value is generally given in units of cubic feet [volume] per day [time] per foot [saturate thickness] or simplified square foot per day [ft2/day]. In order to evaluate additional site specific aquifer flow properties, the hydraulic conductivity value obtained from the monitoring well is multiplied by the saturated thickness of the aquifer to obtain the transmissivity of the aquifer. The saturated thickness of the aquifer is measured from the top of the groundwater surface to the bottom of the aquifer. VIII

Total Organic Vapor Screening Procedures The following are recommended procedures for conduction analytical screening of petroleumcontaminates soils utilizing a portable photoionization detector (PID) or flame ionization detector (FID). 1. Half-fill two clean glass jars with the sample to he analyzed. Quickly cover each open top with one or two sheets of clean aluminum foil and subsequently apply screw caps to tightly seal the jars. Sixteen ounce (16-oz) (approximately 500 ml) soil or "miason" type jars are preferred; jars less than 8 ounces (approximately 250 ml total capacity may to be used.

CYN Environmental Services 100 Tosca Driver, Stoughton, MA. 02072

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2.

Allow headspace development for a least 10 minutes. Vigorously shake jars for 15 seconds both at the beginning and end of the headspace development period. Where ambient temperature are below 32 degrees Fahrenheit (0 degrees Celsius), headspace development should be within a heated vehicle or building.

3.

Subsequently to headspace development, remove screw lid/expose foil seal. Quickly puncture foil seal with instrument sampling probe, to a point about one-half of the headspace depth. Exercise care to avoid uptake of water droplets or soil particles. As an alternative, syringe withdrawal of a headspace sample with subsequent injection to instrument probe, or septum-fitted inlet is acceptable contingent upon verification of methodology accuracy using a test gas standard.

4.

Following probe insertion through foil seal and/or sample injection to the probe, record highest meter response as the jar headspace concentrations. Using foil seal/probe instrument method, maximum response should occur between 2 and 5 seconds. Erratic meter response may occur at high organic vapor concentrations or conditions or elevated headspace moisture, in which case headspace data should be discounted.

5.

The headspace screening data from both jars samples should be recorded and compared; replicate values should be consistent to plus or minus 20%.

6.

PID and FID filed instruments shall be operated and calibrated to yield "total organic vapors" in parts per million (v/v) as benzene. This variation in the MADEP protocol and procedures is required to properly evaluate the horizontal and vertical limits of the release, and to provide field critical information to terminate the boring, place the monitoring well, and evaluate Site Health and Safety procedures. The PID instrument is operated with a 10.0 eV (+/-) lamp source. Operation, maintenance, and calibration shall be performed in accordance with the manufacturer's specifications. For jar headspace analysis, instrument calibration shall be checked/adjusted no less than once every 10 analyses, or daily, whichever is greater.

7.

Instrument with digital (LED/LCD) display may not be able to discern maximum headspace response unless equipped with a "maximum hold" feature or strip-chart recorder

generally,

Deviations, departures and/or additions to the above procedures will be considered on a case-by-case basis by the MADEP on-scene coordinator or project manager. In such cases, compelling technical justification may be presented and documented by the methodology proponent. IX -Disposal Soil SamplinR To comply with off-site disposal requirements, a representative soil sample will be collected from the excavated soils at a frequency of one per every 500-cubic yards. This soil sample will be laboratory analyzed for concentrations of RCRA 8 total metals, paint filter test, pH, flash point, reactive cyanide and sulfide, and polychlorinated biphenyls. In addition, a soil sample will be laboratory analyzed for total petroleum hydrocarbons at a frequency of one per every one-hundred cubic yards. The results of this testing will be compared to the limits provided within the contract documents to determine whether off- or on-site disposal is required. Selection of soil samples for laboratory analysis will be based on field screening results, olfactory, and/or visual indications. Samples selected for analysis are placed in the appropriate sample container and labeled with identification which includes the job name and number, date, time, sample's name, sampling identification, preservative, and analysis to be conducted. All samples are placed in a cooler, chilled to approximately 4 degrees Centigrade and shipped immediately to the analytical laboratory.

CYN Environmental Services 100 Tosca Driver, Stoughton, MA. 02072

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Ouality Assurance/Ouality Control IOA/OC1 Plan I

Introduction All information pertinent to field activities including sampling will be recorded in a) a field logbook; and b) sample labels or tags. The purpose of the document control is to assure that all documents for a specific project are accounted for when the project is completed. -Accountable documents include items such as logbook, field data records, correspondence, sample tags or labels, chain-of-custody records, analytical records and/or photographs.

II

Field Loebook All information pertinent to a field activity will be entered in a bound book with consecutively numbered pages. Entries in the logbook will include the following 1. Date and time of entry 2. Name and Address of field contractor 3. Type of process producing waste[if known] 4. Description of sample 5. Number and size of sample collected 6. Date and time of sample collection 7. Reference maps, sketches, photo's 8. Any field measurements

9. Purpose of sampling 10. 11. 12. 13. 14. 15.

Producer of waste and address [if known] Types of waste [sludge, wastewater, etc.] Waste component and concentration Description of sampling location Collector's sample ID number and/or name Field observations

III Chain-of-Custody [COCl Procedures Samples submitted to the analytical laboratory will be accompanied by a Cyn Chain-of-Custody form completed by Cyn personnel. Each sample will be logged on this COG form with the appropriate data. A copy of the COG is attached to the end of this QA/QC protocol. A sample is in someone's "custody" if: * * e *

A.

it it it it

is one's actual possession; or is in one's view, after being in one's physical possession; or is in one's physical possession and then is locked up so that no one can tamper with it; or is kept in a secure area, restricted to authorize personnel only.

Samnyle Collection.Handlinp and Identification The number of persons involved in the collection and handling of samples will be kept to a minimum. One member of the sampling team is to be appointed field custodian. Samples are turned over to the field custodian by the team member who collected the samples. The field custodian documents each transaction and the sample remains in his/her custody until it is shipped to the laboratory. Each sample is identified by affixing a pressure sensitive gummed labels on the container(s) as described in Section IV of this plan. The sample container should then be placed in a transportation case [i.e., cooler], along with the chain-ofcustody record. The transportation case will be sealed or locked. The transportation case will be capable of controlling the temperature of the interior [i.e., ice packages, insulation].

CYN Environmental Services 100 Tosca Driver, Stoughton, MA. 02072

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B.

Transfer of Custodv and Shipment When the samples are transferred, the transferee will sign and record the date and time on the COG record. Custody transfer made to a sample custodian in the field should account for every sample, although it may be transferred as a group. Every person who takes custody must fill in the appropriate section of the COG record. The field custodian will be responsible for properly packaging and dispatching samples to the appropriate laboratory. This responsibility includes filling out, dating, and signing the appropriate portion of the COG. The COG will include the following sampling collection information: * * * * * *

Sampling location as specific as possible Sampling date and time Sampling equipment , collection, and decontamination procedures Sampling container description Field filtration/preservative procedures Sample collector's name, title, and affiliation

All packages sent to the laboratory will be accompanied by the COG record and other pertinent information and forms. A copy of these forms will be retained by Cyn and placed in the Job File as permanent record of procedure. In addition, a copy of the completed COG record will appear in the final report submitted to the client or other governing body. Cyn will use the laboratory carrier service for all project sampling deliveries. In the event of samples mailed to the laboratory, mailed package can be registered with return receipt request. For packages sent by common carrier [such as Federal Express, Express Mail], receipts will be retained until the package has been received by the laboratory. Samples will be packed so as not to break during transit, and will be sealed or locked so that any tampering can be readily detected. C.

Sample Collection and Preservation Samples plus appropriate duplications, field blanks, trip blanks will be collected and preserved in accordance with procedures defined in 40 CFR 136. Samples requiring preservation shall be treated at the time collection; holing times begin at this time.

D.

Sample Disposal Unless otherwise instructed, all samples will be disposed of upon expiration of their holding time or thirty days after submittal of the Report to the MADEP, whichever is longer. Samples will be disposed of in an environmentally responsible manner.

CYN Environmental Services T0O Tosca Driver, Stoughton, MA. 02072

Page

8 of9

IV Samle Labels Each sample will be sealed immediately after it is collected and labeled using a waterproof ink. Labels are filled out prior to collection to minimize handling of sample containers. Labels are firmly affixed to the sample containers.

V

Quality Control Prior to sampling, rinsate from the cleaning of a sampling bailer(s) shall be collected and analyzed for volatile organic compounds in accordance with EPA Method 8240. This will ensure some control over what constituents, if any are being introduced to the well by sampling equipment. In addition, laboratory spike, trip and equipment samples will be performed as required.

QA/QC procedures and laboratory qualification from the laboratory will be used by Cyn. If deemed necessary, periodic duplicate samples shall be collected and sent to the laboratory for analysis.

CYN Environmental Services 100 Tosca Driver, Stoughton, MA. 02072

Page 9 of 9

APPENDIX F Disposal Arrangement Pap envork And Testing Report

CYN Environmental Services

CY ED VIRORGE GIRL

Fax Correspondence iiFax

Number: 781-341-2440

SEGYICES

19 April 2005 Mr. Bill Reinhardt Aggregate Industries, Inc. 1101 Turnpike Street Stoughton, MA 02072 RE:

Soil DisposalLetter, TrackingNumber 2-14815 Athoi Medical Clinic - Number 2 Fuel Oil Release 1467 Main Street, Atho, Massachusetts 01331

Dear Mr. Reinhardt: Cyn Environmental Services (Cyn) has prepared this letter to outline the reason for the delay in disposal of petroleum-impacted soil associated with the above referenced site. Initially, Cyn provided you with a completed BOL, analytical results, and the facility prequalification form in 13 July 2004. While response actions were completed in August 2004, unforeseen circumstances limited the removal of the roll-off container containing the impacted soils. With these conditions being resolved, Cyn is requesting approval to transport and dispose of the impacted soils at your Stoughton Facility. For you convenience, I have attached a copy of the July 2004 package. It is my opinion that the attached results accurately reflect the soils contained within the roll-off container. Should you have any questions relative to this submittal, please contact the undersigned at your convenience. Sincerely, Cyn Environmental Services

Philip D. McBain, LSP Senior Project Manager

P.O. BOX 0119 - 100 TOSCA DRIVE - STOUGHTON, MA 02072-0119 TELEPHONE 781-341-1777 - FAX 781-341 -6246 1-800-242-5818 in, MA - 1-800-622-6365 outside MA

100 Tosca Drive, PO Box 119 Stoughton, MA 02072, Phone Number 781-341-1777.

FaxTanImUallia

To:

Bill Reinhardt

From:

Fax:

781-341-2440

Pages: 15 [counting cover page]

Phone: 781-341-5500 Re:

Bill of Lading / Athol Medical Clinic

0 Urgent

0 For Review

Philip McBain

Date:

13 July 2004

CC:

File

0 Please Comment

* Please Reply

0 Please Recycle

Comments: Please review and contact me with approval or questions. Would like to arrange for the disposal of material sometime this week or next.

Thanks, Phil McBain

Privileged and Confidential information. If transmission problems occur, please contact Cyn at 781-341-1777, Ext 133.

Page I of 3 AGGREGATE INDUSTRIES 1101 TURNPIKE STREET, STOUGHTON, MA 02072 PHONE (781) 341-5500,.. FAX (781) 341-2440 SOIL RECYCLING SUBMITTAL Site Information: Name: Athol Medical Clinic Street: 1467 Main Street _Athol, City/Town:

Contact: Phone No: State/Zip:

Generator Information: Name: Same Cityrown:

Contact: Phone No: State/Zip:

Consultant Information: Name: Cyn Environmental Services Street: 100 Tosca Drive Stogton City/Town:

Contact: Phone No: State/Zip:

Street:

______

Estimated Soil Quantity

Tons,

Jose Amparo 978-249-9736 MA 01331

Matt Murphy 781-341-1777 Massachusetts 02072 100

Cubic Yards

NOTE: Water displaced oil out of AST. Soil below fill connection impacted by released oil Soil Contaminants (gasoline, diesel fuel, motor oil, etc)

Number 2 Fuel Oil

Analyses Performed (check all that apply) X TPH, X VOCs, _X Flash, _XpH, _X Cd, _X_ As, X PCBs,X Cr, TCLP (metals), if required based on total levels __All the above tests were performed Other

Laboratory Analytical Data Attached Screening Data Attached

No

_X Reactivity (S,CN), XIHg,

Yes ,

Instrument Used and Constituent Found:

Page 2 of 3 Description/Source of Release X_ Other, Describe, Including date of release Water entered AST and displaced oil out of fill line, impacting soils below the fill connection. __UST,

Soil Description Physical Description (sand, gravel, silt, etc.) Coarse to fine sand with 20-30% c-f gravel. Classification Method:

Visual and Unified Soils Classification System

Check if the following materials are present: None __construction debris vegetation matter

ash

___clay

__

___coal

other deleterious materials (list)

___________________

Soil Characterization Methodology Sampling Method: Grab, X_ Composite _Biased samples (e.g. headspace screening, visually contaminated) Contaminant of Concern: Number 2 Fuel Oil Related Compounds Site History ( Current Use

___

Past Use

check if extra sheets attached ) Medical Clinic Medical Clinic

I, the generator, having used due diligence determined that these is no reason to suspect or believe that the petroleum contaminated soil has been impacted by any release of oil or hazardous materials other than that of the known source or I have identified that additional oil and hazardous materials that are suspected or known to be present in the soil, in addition to those associated with the known release, including any anthropogenetic contaminants. I, the generator, realize that due diligence shall consist of a search of information and records reasonably available to the generator of the contaminated soil sufficient to make the determination. Such records and information may include, but are not limited t, those of the generators, location of generation (i.e. facility if not the generator), the Department's Bureau of Waste Site Cleanup, and the municipality (i.e. Board of Health, Fire Department) within which the site is located.

X Si

eof Generator

Generator

-

Jose Amparo Printed Name

C

1J/2 ate Page 3 of 3

A site diagram is required indicating any major structures or roads, excavation areas and stockpile locations. All sampling locations must be noted. X

Check if diagram attached

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~Massachusetts Department of Environmental Protection

BWSC-O1 2A

Bureau of Waste Site Cleanup

Ii

Release Tracking Number*

BILL OF LADING Pursuant to 310 CMR 40.0030

2

-

14815

A. OCAIONOF SITE OR DISPOSAL SITE WHERE REMEDIATION WASTE WAS GENERATED: lase Name (optional) Street:

Athol Merlical ('linic

1467 Main Street

Ciztrown:

AthoI,

l.ocation Aid:

MA

AlEI-

Zip Code:

42..

04..

DaeProffGeneration

/

/__

_

Additional Release Tracking Numbers Associated with this Bill of Lading

I I

47-3 5-75"N / 71-1 ?'-S8"W

*

Not Applicable

Note: If Bill or Lading Isthe result of a Limited Removat Action (LRA) taken prior to Notification, a Release Tracking Number Is not needed.

B PESONCONDUCTING RESPONSE ACTIONS ASSOCIATED WITH BILL OF LADING Athol Medical Clinic Naeof organization: Name of Contact: Jose Amparo Title: Owner

I IC. I(check I .PRP Street:

1467 Main Street Athol

City/Town: Telephone:

State:

Q78-74Q-Q73%

Ext.:

01331

ZipCode:

MA

______

RELATIONSHIP TO RELEASE OR THREAT OF RELEASE OF PERSON CONDUCTING RESPONSE ACTIONS ASSOCIATED WITH BILL OF LADING

one/specify)

RP

o

Specify (circle one):

Owner

Operator

Generator

Transporter

Other RP:

Specify (circle one):

Owner

Operator

Generator

Transporter

Other PRP:

______________

___________

Fiduciary/Secured Lender

oAgency/Public Utility on a Right of Way

In Other-Person:

If an owner and/or operator is not conducting the response action associated with the Bill of Lading, provide on a attachment the name, contact person, address and telephone number, including any area code and extension, for each, if known.

ID. I

TRANSPORTER/COMMON CARRIER INFORMATION:

Transporter/Common Carrier Name:Cyn Environmental

Contact Person: Matt Murphy 100 Tosca Drive Street: City/Town: Stoughton Telephone: 781-341-1777

Title: State:

E

Ext.:

Sipervisor

Zip Code:027

MA

______

E. RECEIVING FACILITY/TEMPORARY STORAGE LOCATION: Aoreote lnuinctriec

Operator/Facility Name:

Contact Person: Street:

Bill Reinhardt

Environmental Manager

Title:

I1101 Turnpike Street

City/Town: Telephone:

State:

Stnughtnn 781-341-5500U

Type of Facility

(check one)

U U

[1

Asphalt Batch/Cold Mix

Asphalt Batch/-ot Mix Thermal Processing

Division of Hazardous

Waste/Class APermit:

Ext.:

02072

Zip Code:

______

E C

0

I] Incineration 0 Temporary Storage 0 Other:

Landfill/Disposal

Landfill/Daily Cover Landfill/Structure Fill

____________________

Division of Solid Waste

S-01-029

Management Permit #:

Actual/Anticipated Period of Temporary Storage (specify dates if applicable): Reason for Temporary Storage (if applicable):

Revised 10/1/93

MkA

Not Applicable

____ / _____

/

_

to ___/

EPA Identification #: ____ /

MAD-981213531

Not Applicable

Not A pplicaible

Thisform

is printed on recycledpaper

Page

1of 2

Massachusetts Department of Environmental Protection Bureau of Waste Site Cleanup

BWSC-012A Release Tracking Number

2W-D1481

BILL OF LADING Pursuant to 310 CMR 40.0030 E. RECEIVING FACILITY/TEMPORARY STORAGE LOCATION (continued):

Not Applicable

Temporary Storage Address

State:

City/Town:

Zip Code:

-

__

-

____

F. DESCRIPTION OF REMEDIATION WASTE:

(check all that apply) Contaminated Media (check all that apply): C]Contaminated

I

Debris (circle all that apply):

oiL

Other:

Engineered Impoundments

Jet Fuel

Containers

Drums

Not Applicable Diesel Fuel

100

#2Ol

4Oil

150

Tons:

I]Transportation Accident

oUnderground Storage Tank Immediate

Response Actions Associated with Bill of Lading (circle one): Utility-Related Abatement Measures Other (specify):

Not Applicable

Other:

Tank Bottoms/Sludges

Waste Oil

#~6Oil

Other:

Cubic Yards:

Contaminant Source (check one/specify):

_____

Vegetation/Organic Materials

Non-aqueous Phase Liquids

Gasoline

Type of Contamination (circle all that apply):

Other:

Nnt Annlienhle

Other:

CINon-hazardous Uncontainerized Waste (circle all that apply): CiNon-hazardous Containerized Waste (circle all that apply):

Estimate Volume of Materials

Surface Water

Demolition/Construction Waste

Inorganic Absorbant Materials

Kerosene

Groundwater

Response Actions

Limited Removal Actions (LRA)

Other:________

Water entering AST

*Other:

Release Abatement Measures Comprehensive Response Action

___________________

Remediation Waste Characterization Support Documentation attached:

USite

History Information

U

Sampling and Analytical Method and Procedures

ILaboratory Data

5Field Screening Data

If supporting documentation is not appended, provide an attachment stating the date and in connection with what document such information was previously submitted to DEP

G. LICENSED SITE PROFESSIONAL (LSP) OPINION: Name of Organization: Cyn Environmental Services Philip D. McBain LSP Name: Telephone:

781

341

-

-

1777. Ext.-

Title

Senior Project Manager1/ LSP

133

I have personally examined and am familiar with the information contained on and submitted with this form. Based on this information, it is my Opinion that the testing and assessment actions undertaken were adequate to characterize the Remediation Waste, in accordance with 310 CMR 40.0030, and that the facility or location can accept remediation wastes with the characteristics described in this submittal. Ilam aware that significant penalties including, but not limited to, possible fines and imprisonment may result if I willfully submit information which I know to be false, inaccurate, or materially incomplete. Seal:

Signature: Date:

See Attached Replacement Opinion

______/______/_____

Licensed Number.

5121

H. CERTIFICATION OF PERSON CONDUCTING RESPONSE ACTIONS ASSOCIATED WITH THIS BILL OF LADING: I certify under penalties of law that!I have personally examined and anmfamiliar with the information contained in this submittal, including any. and all documents accompanying this certification, and that, based on my inquiry of' those individuals immediately responsible for obtaining the information, the material information contained herein is, to the best of my knowledge and belief, true, accurate and complete. Iam aware that there are significant penalties, including, but not limited topossible fines and imprisonment, for willfully submitting false, inaccurate, or

Name of Person (print):

Revised 10/1/93

Tnse A mparo

Thisform

isprinted on recyclespaper

Page 2 of 2

USE LSP Replacement Opinion V with the following BWSC Form:

O

Bill of Lading (BWSC-012A) LSP Replacement Opinion V

I attest under the pains and penalties of perjury that I have personally examined and am familiar with this submittal including any and all documents accompanying this submittal. In my professional opinion and judgment based upon application of (i) the standard of care in 309 CMR 4.02 (1) (ii) the application provision of 309 CMR 4.02 (2) and (3), and (iii) the provisions of 309. CMR 3.03 (5). to the best of my knowledge, information and belief, the assessment actions undertaken to characterize the Remediation Waste which is (are) the subject of this of acceptance at the facility identified in this submittal comply with the application provision of 310 CMR 40.O000, and such facility is permitted to accept Remediation Waste having the characteristics described in this submittal. I am aware that significant penalties may result, including, but not limited to, possible fines and imprisonment, if submit information which I know to be false, inaccurate or materially incomplete. *Release Tracking Number:

___ -

2-14815

LSP Name:

Philip D Mcein

Title: Senior Pmject Mnager /ITSP'

LSP Organization:

Cyni Environmental Services

Date:

781-341-1777 Ext 133

Telephone/Ext.: Signature:-

.4~

Seal:

/3

2oo

'

iF

Massachusetts Department of Environmental Protection Bureau of Waste Site Cleanup --

-

BWSC-012B Release Tracking Number

BILL OF LADINQpursuant to 310 CMR 4O.0030)

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LOG SHEET

[2l-

OF

L LOAD INFORMATION: LOAD 1: Signature of Transporter Representative: Date of Shipment:

Receiving Facility/Temporary Storage Representative:

Time of Shipment (circle one) am/pm /

/

___

_

Truck/Tractor Registration:

Trailer Registration (if any):

I

Date of Receipt:

Time of Receipt:

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one) am/pm

Load Size (cu. yds./tons):

LOAD 2: Signature of Transporter Representative: Date of Shipmet:

:ime

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Truck/Tractor Registration:

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Trailer Registration (if any):

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Truck/Tractor Registration:

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I(circle ILoad Size (cu. ydsitons):

one) am/pm ________

Receiving Facility/Temporary Storage Representative:

of Shipment (circle one) am/pm

/

Date of Receipt:

___

LOAD 3: Signature of Transporter Representative: Date of Sbipnent:

________

Receiving Facility/Temporary Storage Representative:

of Shipment (circle one) am/pm

/

/_

14815

_

Trailer Registration (if any):

IDate

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Time of Receipt: _

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one) ant/pm

Size (cu. ydsitons):

_________

LOAD 4: Signature of Transporter Representative:

Receiving Facility/Temporary Storage Representative:

Date of Shipmet:

Date of Receipt:

:ime

of Shipment (circle one) am/pm

I

Truck/Tractor Registration:

Time of Shipment (circle one) am/pm /

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_

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Time of Receipt:

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(circle one) am/pm Load Size (cu. ydsitons):

__________

Receiving Facility/Temporary Storage Representative:

Time of Shipment (circle one) am/pm /

Facility/Temporary Storage Representative:

Trailer Registration (if any):

LOAD 6: Signature of Transporter Representative:

__

________

Date of Receipt:

_

_______________________________

Date of Shipment:

(circle one) nm/pm Load Size (cu. yds./tons):

IReceiving

LOADS5 Signature of Transporter Representative:

__

/_

Trailer Registration (if any): ____________________________

Date of Shipment:

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Time of Receipt:

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Date of Receipt:

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Time of Receipt: _

Trailer Registration (if any): ___________________________

I(circle ILoad

one) am/pm

Size (cu. yds./tons):

________

LOAD 7: Signature of Transporter Representative:

Receiving Facility/Temporary Storage Representative:

Date of Shipment:

Date of Receipt:

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Time of Shipment (circle one) am/ pm

Truck/Tractor Registration:

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Time of Receipt:

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Trailer Registration (if any):

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HiJ. LOG SHEET VOLUME INFORMATION: Total Volume This Page (cu. yds./tons): Total Carried Forward (cu. yds./tons): Total Carried Forward and This Page (cu. yds.Itons): 10/1l/93

Thisform is printed on recycled paper

Page I of I

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I II 7Massachusetts Department of Environmental Protection Bureau of Waste Site CleanupI

IIJ.

BILL OF LADIN~pursuant to 310 CMR 40.0030) SUMMARY SHEET_____OF____

SUMMARY OF SHIPMENT:

DATE OF SHIPMENT:1

DATE OF RECEIPT:

SUMMARY SHEET OF SHIPPED: BILL OF LADING TOTAL SHIPPED (only of different):

I

NUMBER OF LOADS Sil

eWSC-012C Release Tracking Number

2- 14815

Massachusetts Department of Environmental Protection Bureau of Waste Site Cleanup -

BWSC-012C Release Tracking Number

-

BILL OF LADIN~pursuant to 310 CMR 40.0030) SUMMARY SHEET

[J

41

L. ACKNOWLEDGEMENT OF RECEIPT OF REMEDIATION WASTE AT RECEIVING FACILITY OR TEMPORARY STORAGE LOCATION: Receiving Facility/Temporary Location Representative (Print):

Aggregate Industries / Bill Rienihardt

Signature: ____________________________________

Title: Date:

Environmental Manager _____/

_____/

___

M. ACKNOWLEDGEMENT OF SHIPMENT AND RECEIPT OF REMEDIATION WASTE BY PERSON CONDUCTING RESPONSE ACTIONS ASSOCIATED WITH THIS BILL OF LADING: I certify under penalty of law that I personally examined and am familiar with the information contained inthis submittal, including any and all documents accompanying this certification, and that, based on my inquiry of those individuals immediately responsible for obtaining the information, the material information contained herein is, to my knowledge and belief, true, accurate and complete. I am aware that there are significant penalties, including, but not limited to, possible fines and imprisonment, for willfully submitting false, inaccurate, or incomplete information.

C. VT~J

gipnnenire

Name of Person (print):

Ujy'hifomiprneonrccepaePae2f2 i 10/ Rc~c 3/93 evsed

2 2 c--

Date:

07

/ /2.-

/ O-

Jose Amparo

This form is printed on recycled paper

Page 2 of 2

EIIBIUEI1TRL SERV1ICES Client: Date: Project Manager: Job #

Athol Medical Clinic 1467 Main St. Athol, MA 7/2/04 Phil McBain 201-882-00-TS Sample Information

Laboratory ID Number 2043138

Sample ID Number Soil disposal

-

1

Analysis Aggregate Parameters

-Massachusetts certification number: M-MA904 P.O. BOX 0119

+

1771 WASHINGTON STREET - STOUGHTON, MA 02072-0119 TELEPHONE 781-341-5108 - 1-800-899-1038 - FAX 781-344-3318

/

Cyn Environmental Services Analytical Laboratory

Eli VIROmE'IIE iRL. SERV ICE S

Customer: Athol Medical Clinic Location: Athol, MA Lab Number: 2043138 Sample ID: Sail disposal - 1 Sampled By: Sylvia Kirsch Sample Matrix: Soil

Job Number: Waste Code: Sample Date: Receipt Date: Analysis Date: Report Date:

201 -882-00-TS NA 06/25/04

06/28 /0 4 07/01/04 07/02/04

Inorpanics Method EPA 1010 EPA 9095 EPA 9045 SWS46 7.2 SW846 7.2

Analyte Flashpoint Paint Filter pH Reactive Cyanide Reactive Sulfide

Result

RL

>140 Pass 6.2 ND ND

140 5 5

NA S.U. mg/Kg mg/Kg

Result

RL

Units

ND 4,300

0,5 170

mg/Kg

Result

RL

Unrits

120 30 5 5 ND 810 ND ND

3 7 3 2 3 15 1 3

mg/Kg mg/Kg mg/Kg mg/Kg mg/Kg mg/Kg mg/Kg mg/Kg

0.3

0.3

mg/L

Orqjanics Method EPA 600/4-8-04 5 EPA 8100M

Analyte Total PCBs Total Petroleum Hydrocarbons

mg/Kg

Metals Method

Analyte

EDXRF EDXRF EDXRF EDXRF EDXRF EDXRF EDXRF EDXRF

Total Total Total Total Total Total Total Total

Lead Chromium Arsenic Cadmium Mercury Barium Selenium Silver

TCLP/EDXRF

TCLP Lead

NA = Not Applicable ND = Not Detected above Reporting Limit (RL).

Metals tested by energy dispersive x-ray fluorescence spectrometry.

Submitted By:

Approved By:

ministratoremplae\18a C:\Winnt\Priles P.O. BOX 0119'* 1771 WASHINGTON STREET - STOUGHTON, MA 02072-0119 TELEPHONE 781-341-5108 * 1-800-899-1038 - FAX 781-344-3318

2.-

Cyn Environmental Services Analytical Laboratory Customer: Location: Lab Number: Sample ID: Sampled By: Sample Matrix:

EDYVIBRO RfiE 11181l SEA VICES

Job Number: Data File: Sample Date: Receipt Date: Analysis Date: Report Date:

Athol Medical Clinic Athol, MA 2043138 Soil disposal - 1 Sylvia Kirsch Soil

201-882-00-TS V28572.D 06/25/04 06/28/04 06/30/04 07/07/04

Orgianics Date Extracted: 06/25/04 Dilution Factor: Sample Preservation: Methanol

Container Condition: Satisfactory % Moisture: 18.3% Soil Weight (g): 15.2 Method EPA 5035/8260 EPA 5035/8260 EPA 5035/8260 EPA 5035/8260 EPA 5035/8260 EPA 5035/8260 EPA 5035/8260 EPA 5035/8260 EPA 5035/8260 EPA 5035/8260 EPA 5035/8260 EPA 5035/8260 EPA 5035/8260 EPA 5035/8260 EPA 5035/8260 EPA 5035/8260 EPA 5035/8260 EPA 5035/8260 EPA 5035/8260 EPA 5035/8260 EPA 5035/8260 EPA 5035/8260 EPA 5035/8260 EPA 5035/8260 EPA 5035/8260 EPA 5035/8260 EPA 5035/8260 EPA 5035/8260 EPA 5035/8260 EPA 5035/8260 EPA 5035/8260 EPA 5035/8260 EPA 5035/8260 EPA 5035/8260 EPA 5035/8260 EPA 5035/8260

Result

Analyte Acetone Benzene Bromobenzene Bro mochloro me th ane Bromodichloromethane Bromoform Bromomethane 2-Butanone (MEK) n-Butylbenzene sec-Butylbenzene tert-Butylbenzene Carbon tetrachloride Carbon Disulfide Chlorobenzene Chloroethane Chloroform Chloromnethane 2-Chlorototuene 4-Chlorotoluene 1,2-Dibromo-3-chloropropane Dibromochloromethane 1,2-Dibromoethane (EDB) Dibromomethane 1,2-Dichlorobenzene 1,3-Dichlorobenzene 1 ,4-Dichlorobenzene Dichiorodifluoromethane 1,1 -Dichloroethane 1,2-Dichloroethane 1,1-Dichloroethene cis-1,2-Dichloroethene trans-i,2-Dichloroethene 1,2-Dichloropropane 1,3-Dichloropropane 2,2-Dichloropropane 1,1-Dichloropropene

RL

U!nits

1400 300 300 300 300 300 600 1400 300 300 300 300 300 300 600 300 600 300 300 300 300 300 300 300 300 300 600 300 300 300 300 300 300 300 300 300

ug/Kg ug/Kg ug/Kg ug/Kg ug/Kg ug/Kg ugKg ug/Kg ug/Kg ug/Kg ug/Kg ug/Kg ug/Kg ug/K(g ug/Kg ug/Kg ug/Kg ug/K~g ug/Kg ug/Kg ug/Kg ug/Kg ug/Kg ug/Kg ug/Kg ug/Kg ug/Kg ug/Kg ug/Kg ug/Kg ug/Kg ug/Kg ug/Kg ug/Kg ug/Kg ug/Kg

3 P.O. BOX

0119 - 1771 WASHINGTON STREET - STOUGHTON,

MA

02072-0119

TELEPHONE 781-341 -5108 * 1-800-899-1038 * FAX 781-344-3318

Cyn Environmental Services Analytical Laboratory Job Number: Waste Code: Sample Date: Receipt Date: Analysis Date: Report Date:

Customer: Athol Medical Clinic Location: Athol, MA Lab Number: 2043138 Sample ID: Soil disposal - 1 Sampled By: Sylvia Kirsch Sample Matrix: Soil

* ERV IREnTAL

201-882-00-TS V28572.D

06/25/04 06/28/04

06/30/04 07/07/04

Organics Date Extracted: 06/25/04 Dilution Factor: 1 Sample Preservation: Methanol

Container Condition: Satisfactory % Moisture: 18.3% Soil Weight (g): 15.2 Method EPA 5035/8260 EPA 5035/8260 EPA 5035/8260 EPA 503518260 EPA 5035/8260 EPA 5035/8260 EPA 5035/8260 EPA 5035/8260 EPA 5035/8260 EPA 5035/8260 EPA 5035/8260 EPA 5035/8260 EPA 5035/8260 EPA 5035/8260 EPA 5035/8260 EPA 5035/8260 EPA 5035/8260 EPA 5035/8260 EPA 503518260 EPA 5035/8260 EPA 5035/8260 EPA 5035/8260 EPA 5035/8260 EPA 5035/8260 EPA 5035/8260 EPA 5035/8260 EPA 5035/8260 EPA 5035/8260

EPA EPA EPA EPA

50 35/8260 5035/8260 5035/8260 503 5/82 60

Result

Analyte cis-1,3-Dichloropropene trans-i,3-Dichioropropene Ethylbenzene Hex ach lorob uta dilen e 2-Hexanone lsopropylbenzene 4-isopropyitoluene Methyl tert-butyl ether (MTBE) 4-Methyl-2-pentanone (MIBK) Methylene chloride Naphthalene n-Propylbenzene Styrene 1,2,3-Trichloropropane 1,1,1,2-Tetrachloroethane 1,1,2,2-Tetrachloroethane Tetrachioroethene (PCE) Toluene 1,.2,3-Trichlorobenzene 1,2,4-Trichlorobenzene 1,1,1-Trichloroethane 1,1,2-Trichloroethane Trichioroethene (TCE) Trichlorofl uoromethane 1,2,4-Trimethylbenzene 1,3,5-Trimethylbenzene Vinyl chloride Total Xylenes

Surroaates Dibromofl uoromethane 1,2-Dichloroethane-d4 Totuene-d8 4-B romnof luo robe nzene

Result 97% 96% 77% 91%

RL

its

300 300 300 300 1400 300 300 300 1400 300 300 300 300 300 300 300 300 300 300 300 300 300 300 600 300 300 600 600

ug/Kg

ug/Kg ug/Kg ug/Kg ug/Kg ugKg ug/Kg ug/Kg ug/Kg ug/Kg ug/Kg ug/Kg ug/Kg ug/Kg ug/Kg ug/Kg ug/Kg ug/Kg ug/Kg ug/Kg ug/Kg ug/Kg ug/Kg ug/Kg ug/Kg ug/Kg ug/Kg ug/Kg

Recovery Limits 70-130 70-1 30 70-1 30 70-130

ND = Not Detected above Reporting Limit (RL).

Approved By:

Submitted By:

P.O. BOX 0119 - 1771 WASHINGTON STREET - STOUGHTON, MA

02072-0119

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TELEPHONE 781-341-5108 - 1-800-899-1038 - FAX 781-344-3318

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EOYIIROOiEGIITALI

Fax Correspondence iiFax

Number: 781-341-2440

SERBV ICE S

27 April 2005 Mr. Bill Reinhardt Aggregate Industries, Inc. 1101 Turnpike Street Stoughton, MA 02072 RE:

Soil DisposalLetter, Tracking Number 2-14815 Athrot Medical Clinic - Number 2 Fuel Oil Release 1467 Main Street, Athol, Massachusetts 01331

Dear Mr. Reinhardt: Cyn Environmental Services (Cyn) has prepared this letter to confirm that the release, which occurred at the above noted location consisted of Number 2 fuel oil. The source of the Methylene Chloride, which was reported within the testing results is unknown but may be a laboratory contaminant. Should you have any questions relative to this submittal, please contact the undersigned at your convenience. Sincerely, Cyn Environmental Services

Philip D. McBain, LSP Senior Project Manager

P.O. BOX 0119 - 100 TOSCA DRIVE - STOUGHTON. MA 02072-0119 TELEPHONE 781-341-1777 - FAX 781-341-6246 1-800-242-5818 in MA - 1-800-622-6365 outside MA

01/07/2004 08:58 FAX

17213443318

WASHINGYON-STREET

' TSO

@j002/006I

EN IN VI OE AIU I SER VICE S Client:

Athol Medical Clinic 1467 Main St. Athol, MA

Date:

712104

Project Manager: Job #

Phil Mc~aini 201-882-00-Ts Sample Information

Laboratory ID Number 2043138

Sample ID Number Soil disposal

-

1

Analysis Aggregate Parameters

Massevchusetts certification number: M-MA904 P.O. BOX

0119 -1771

WASH(NGTON STREET'- STOUGHTON, MAC0272-OI1G

TELEPHONE 781-MI1-IC 5 + 1-60-991038.- FAX( 71-344-3316

/

07/01/2004 08:56 FAX

17813443318

WASTTN-STREET

+

T&D

@j003/0068

Cyn Environmental Services Analytical Laboratory Customer: Location: Lab Number Sample ID: Sampled By: Sample Matrix:

SES YIlC ES

Athol Medical Clinic Athol, MA . 2043138 Soil disposal -i1 Sylvia Kirsch Soill

Job Number Wante Code: Sample Date: Recuipt Date: Anal3 sis Date: Rerort Date:

201 -882.-0O-TS NA 06/25/04 06/28/0 4 07/01/04 07/02/04

Inorpanics Method

Analyte

EPA 1010 EPA 9095

EPA 9045 SWS46 7.2 SW846 7.2

Flashpoint Paint Filter pH Reactive Cyanide Reactive Sulfide

Result

RL

>140

14C

Pass 6.2 ND -

NA

5S 5

mg/Kg mg/Kg

Result

RL

Units

ND

0.5 170

mg/Kg

ND

Oroanics Method

Anlalye

EPA 600/4-8-045 EPA 810DM

Total PCBs Total Petroleum Hydrocarbons

4,300

mg/Kg

Metals Method EDXRF

EDXRF EDXRF EDXRF

Analyte

Result

RL

Units

Total Lead Total Chromium Total Arsenic

120 30 5S 5 ND

mg/Kg

610

3 7 -3 2 3 15

ND ND

1 3

0.3

0.3

EDXRF EDXRF ED XR F EDXRF

Total Total Total Total Total

TCLP/EDXRF

TCLP Lead

Cadmium Mercu-y Baium Selenium Siver

mg/Kg mg/Kg

mg/Kg mg/Kg mg/Kg mg/Kg mg/Kg mg/L

NA = Not Applicable ND = Not Detected above Reporting Limit (RL).

Metals tested by energy dispersive x-ray fluorescence spectrometry.

Submitted By: P.O Ois BO

Approved By: 1 WA*N~N~ETS-JUGH1ON, MA 02072-0119 TELEPHONE 781-341-5101 * 1-E0-Hl9O-103O + FAX 781'344-3318

2-

01/01/2004 08:51 FAX

11813443318

gASHINGTON-STREET

+

TSD

@004/006

.Cyn Environmental Services Analytical Laboratory A | Customer Location: Lab Number; Sample ID: Sampled By: Sample Matrix:

[NYI ROGWnl1 TR1L

E

[[ES

Athol Medical Clinic Alhol, MA 2043138 Soil disposal - 1 Sylva Kirsch Soil

Job Nu nbqr Data Filie: Sample Date: Receipt Date: AnalysiS Date: Report Date:

201-882-00-TS V28572.0 06/25/04 06/28/04 08/20/04 07/07/04

Oruanics Container Condidon: Satisfactory % Moisture: 1.3% Soil Weight (g): 15.2 Method

EPA 5035/8260 EPA 5035/8260 EPA 5035/8260 EPA 5035/8260 EPA 5035/8260 EPA 5035/8260 EPA 5035/8260 EPA 5035/8280 EPA 5035/8260 EPA 6035/80 EPA 503518260 EPA 5035/8260 EPA 5035/8280 EPA 5035/8260 EPA 5035/8260 EPA 5035/8260 EPA 5035/8260 EPA 5035/8260 EPA 5035/8260 EPA 5038/8260 EPA 5035/8260 EPA 5035/8260 EPA 5035/8280 EPA 5035/8260 EPA 5035/6260 EPA 6035/8260 EPA 5035/8260 EPA 5035/8260 EPA 5035/B260 EPA 5035/8280 EPA 5035/8260 EPA 5035/8260 EPA 5035/8260 EPA 5035/8260 EPA 5035/8280 EPA 5035/8260

P.O. BOX

0119 - 1771

Analyte Acetone Benzene Rromnobenzene Bromochioromethane Brmonldclromethane Bromoformn Brmomethaene 2-flutanone (MEK) n-Butylbenzene sec- utylbenzene lert-Butylbenzene Carbon tebrdchoulde

Crbon Disulfide Chlorobenzeneo. Chlorceihane Chlorofonnm Chlornmethane 2-Ch lortolue ne

4-Chlorotoluene 1,2-Dlbromio-3-chtoroprgpane Dibromodloqomethane 1,2-Dibromoethane (EDB) Di brom-omnethane. 1,2-Dichlorabenzene 1.3-Dichlorobenzene 1.4-Dlchobenzene Dichlorodlfluoromethane 1,1-Dichloroethane I,2-Didloroethane 1,1-Dlchloroethene cis-1,.2-Dichloroethene lrans-1,2-Olchloroelhene 1.2-Dlchloropropane 1.3-ODilorpropane 2,2-aidlioropropane 1,1l-Diclropropene

WASHINGTON SThEET - STOUGHTON, MA 02072-v11g

Date Extacted: 00/25/04 Dllution Fiactor 1 Sample Presernation: Methanol

Result

RL

Units

.1400 300 300 300 300 300 600 1400 * 300 300 300 300 300 300 600 300 800 300 300 300 300 300 ~300 300 300 300 600 300 300 300 300 300 300 300 300 200

ug/Kg ug/Kg ug/Kg

ug/Kg ug/Kg

ug/Kg

ug/Kg ug/Kg

ug/Kgo ug/Kg ug/K~g ug/Kg

ug/Kg

ug/Kg ug/Kg

ug/Kg ug/Kg

ug/Kg ug/Kg ug/Kg ug

ug/Kg

g g

TELEPHONE 7O1-341-510i * 1-00-69-1038 - FAX 7B1-344-3318

.3

I

07/07/2004 08:57 FAX

17813443318

WASHINGTON--STREET

T&Dj005/008 16

Cyn Environmental Services Analytical Laboratory

cy ii

Customer. Athol Medical Clinic Location! Ath, MA Lab Number 2043138 Sample ID: Soil disposal - 1I Sampled By: Sylvia Kirsch Sample Matrix: Soili

EFIYIROOFI1ENTIII SERVICES

Job Number: Waste (:ode: Sample Jate: Receipt 2ate: Analysi Jate: Report isle:

201-802-00-TS V28572.D 06/25/04

06/28/04 06/30/04 07/07/04

Organics Container Condition: Satsfactory % Moisture: 16.3% Soil Weight (9J: 15.2 Method

Anaivte

EPA 5035/8260 EPA 5035/8260 EPA 5030/820 EPA 5035/8260 EPA 5035/8260 EPA 5035/6260 EPA 5035/6260 EPA 5035/8260 EPA 5035/8260 EPA 5035/8260 EPA 5035/8260 EPA 5035/680 EPA 5035/8260 EPA 503ti/8280 EPA 5035/80 EPA 5035/8260 EPA 5035/8260 EPA 5035/8260 EPA 5035/8260 EPA 5035/8260 EPA 5035/8280 EPA 5035/8260 EPA 5035/8260 EPA 5035u/80 EPA 5035/6260 EPA 5035/8280 EPA 5035/8260 EPA 5035/8260

1,2,3-Trdhlarobenzene 1.2,4-Tridilomobenzene 1,1,1-Trlihoroeihane 1,1,2-Trlihoroethane Trlchloraethene (TCE) Trdhlorofluoromethiane 1.2.4-Trirnethytbenzene 1.3,5-Timethylbenzone Vinyl chloride Total Xylenes

EPA EPA EPA EPA

Surroates Dibrvnmofluvrgnmelhane 1,.2-Dichloroethane44 Toluene46B 4-B rom~oluorobenzene

5035/620 50350/8260 5035/8260 5035/8260

Date Exin

c: 06/25/04

Dilution Fictor: 1 Sample Preservation: Methanol Result

Un!;it~s -

cis-1.3a-Dichloropropene trns-1,.3-Didchloropropene Ethylbenzene Hexadcroutadiene 2-Hanone lsopropytbenlzeneC 4-tsopropylleluwee Methy4 tart-butyl ether (MTBE) 4-Meihyl-2-penlanonie (MIBK) Methlylene chloride Naphthalene ni-Propylbenzene Styrene 1,2,3-Trdhlormpropanie 1,1,.1,2-Telrachloroethane 1.1.,2-Tetrlroethano. Tetrachlcoothens (PCE) -

300 300 300 300 1400 300 300 300 1400 300 300 300 300 300 300 300 300 300 300 300 300 300 300 600 300 300 600 800

Toluene

ug/Kg ug/Kg

ug/Kcg ug/Kg ug/Kg

ug/Kg ug/Kg ug/Kg ug/KDate:

Woratory

Ire

or

Dave Dickinson P.O. BOX 0119- 1771 WASHINGTON STREET - STOUGHTON, MA 02072-0119

TELEPHONE 781-341-5108 - 1-80(-899-1038 - FAX 781-344-3318

2-

Cyn Environmental Services Analytical Laboratory Customer: 1467 Main St. Location: Athol, MA Lab Number: 2043524 Sample ID: Camp 1I Sampled By: Chris McKenna Sample Matrix: Sail

EGiI ROG IlEGITA . SERVI[ES

Job Number: 20276600SP Batch ID: ES0413 Sample Date: 07/22/04 Receipt Date: 07/22/04 Analysis Date: 07/27/04 Report Date: 07/28/04

ExtraCtable Petroleum Hvdrocarbons by MADEP EPH 04-1 Sample Temperature: Received @ 4'C0 Container Condition: Satisfactory Percent Moisture: 13.1 Frac. Column Lot #: 01 24603 Method

Analyte

GO/F ID GC/F ID

C9-C18 Aliphatics 019-C36 Aliphatics C11-C22 Aromatics C11-C22 Aromatics*t 2-Methylnaphthalene Acenaphthene Naphthalene Phenanthrene

GC/F ID GO/F ID GC/MS GC/MS GC/MS GC/MS Method

Surrogate

GC/F ID

2-Bromonaphthalene 2-Fluorobiphenyl Chl orooctadeca ne Orthoterphenyl

GC/FID GO/FID GC/F ID

Date Extracted: 07/22/04 AROC ALl Dilution Factor: 1 1 Extraction Method: EPA 3546 Result

RL

Units

ND ND ND ND ND ND ND ND

23 23 23 23 0.2 0.2 0.2 0.2

mg/Kg

Result

AR

_Units

93 115 93 121

40- 140 40- 140 40-1 40 40-1 40

mg/Kg mg/Kg mg/Kg mg/Kg mg/Kg mg/Kg mg/Kg

AR = Acceptance Range RL = Method Reporting Limit ND = Not Detected Comments: *Unadjusted, Concentrations based on dry weight.

Submitted By:

P8 '3iflf'R

rsC--t

Approved By: IS~ RNIN

Wti'lIid

&i

ON, MA 02072-0119 TELEPHONE 781-341-5108 - 1-800-899-103

+

FAX 781 -344-3318

S

Cyn Environmental Services Analytical Laboratory cy0 *

RTRL IInYA

E !~v~

Customer: Athol Medical Clinic Location: Athol, M~A Lab Number: 2043524 Sample ID: Comp i Sampled By: Chris McKenna Sample Matrix: Soil

Job Number: Data File: Sample Date: Receipt Date: Analysis Date: Report Date:

20276600SP V28656.D 0 7/22/04 07/22/04 07/26/04 07/27/04

Volatile Petroleum Hydrocarbons Sample Temperature: Container Condition: Percent Moisture: Extraction Weight(g): Method

Received @ 4* C Satisfactory 13.1% 18.3 Analvte

MADEP-VPH-04-1 .1 MADEP-VPH-04-1 .1 MAD EP-VPH-04-1 .1 MADEP-VPH-04-1 .1 MADEP-VPH-04-1 .1 MADEP-VPH-04-1 .1 MADEP-VPH-04-1 .1 MADEP-VPH-04-1 .1 MADEP-VPH-04-1 .1 MADEP-VPH-04-1 .1 MADEP-VPH-04-1 .1 Method

C5-C8 Aliphatics C9-C12 Aliphatics C9-C10 Aromatics C5-C8 Aliphatics* C9-C12 Aliphatics* Benzene Ethylbenzene Methyl tert-Butyl Ether Naphthalene Toluene Xylene (total) Surrogate

MADEP-VPH-04-1 .1

2,5-Dibromotoluene

Date Extracted: 07/22/04 Dilution Factor: 1 Sample Preservation: 1:1 Methanol Covering Sample Result

RL

Units

ND ND ND ND ND ND ND ND ND ND

2.4 2.4 2.4 2.4 2.4 0.24 0.24 0.09 0.24 0.47 0.47

mg/Kg mg/Kg mg/Kg mg/Kg mg/Kg mg/Kg mg/Kg mg/Kg mg/Kg mg/Kg mg/Kg

Result

AR

Units

122

70-1 30

%/

ND

AR = Acceptance Range RL = Method Reporting Limit ND = Not Detected Comments: * =

Unadjusted

Submitted By:

A~

C:\VPH-fcomnputer\Fina Data\3524-3529VPH.xis

Approved By:

(2,4km

P.O. BOX 0119 - 1771 WASHINGTON STREET - STOUGHTON, MA 02072-0119 TELEPHONE 781 - ~4I-5I08

A

*

1-800-899-1038- FAX 781-344-3318

Cyn Environmental Services Analytical Laboratory SEY RD

Customer: Locatidn: Lab Number: Sample ID: Sampled By: Sample Matrix:

D10EDIRL

1467 Main St. Athol, MA 2043525 Camp 2 Chris McKenna Soil

Job Number: 20276600SP Batch ID: ESO413 Sample Date: 07/22/04 Receipt Date: 07/22/04 Analysis Date: 07/27/04 Report Date: 07/28/04

Extractable Petroleum Hydrocarbons by MADEP EPH 04-1 Sample Temperature: Received @ 4C Container Condition: Satisfactory Percent Moisture: 20.7 Frac. Column Lot #: 0124603 Method

Analyte

GC/FID

C9-C18 Aliphatics C19-C36 Aliphatics C11-C22 Aromatics C11-C22 Aromatics* 2-Methyl naphthalene Acenaphthene Naphthalene Phenanth rene

GC/F ID GC/F ID GC/FID GC/MS GC/MS GC/MS GO/MS

Surrogate

Method GC/F ID GC/FID

2-Bromonaphthalene 2-Fl uorobiphenyl Chlorooctadecane Orthoterphenyl

GC/FID GC/FID

Date Extracted: 07/22/04 ARO ALl Dilution Factor: 1 1 Extraction Method: EPA 3546 Result

RL

Units

170

25

mg/Kg

96 39 39 ND ND ND ND

25 25 25 0.3 0.3 0.3 0.3

mg/Kg mg/Kg mg/Kg

Result

AR

85 98 70 96

40- 140 40- 140 40-1 40 40-1 40

mg/Kg mg/Kg

mg/Kg mg/Kg _Units

AR = Acceptance Range RL = Method Reporting Limit ND = Not Detected Comments: *Unadjusted, Concentrations based on dry weight.

Submitted By:

zi

t

Approved By:

/ pW P.OBOX0119fY

11

A

YHIGTON STET + STOGHTON, MA 02072-0119

TELEPHONE 781-341-5108 - 1-800-899-1038+*FAX 781-344-3318

Cyn Environmental Services Analytical Laboratory

EllYVI ROifEGIARL

SE[R VIt ES

Customer: Athol Medical Clinic Location: Athol, MA Lab Number: 2043525 Sample ID: Comp 2 Sampled By: Chris McKenna Sample Matrix: Soil

Job Number: Data File: Sample Date: Receipt Date: Analysis Date: Report Date:

20276600SP V286 57. D 07/22/04 07/22/04 07/26/04 07/27/04

Volatile Petroleum Hydrocarbons Sample Temperature: Container Condition: Percent Moisture: Extraction Weight(g): Method

Received @ 4* C Satisfactory 20.7% 23.2 Analyte

MADEP-VPH-04-1 MADEP-VPH-04-1 MADEP-VPH-04-1 MADEP-VPH-04-1 MADEP-VPH-04-1 MADEP-VPH-04-1 MADEP-VPH-04-1 MADEP-VPH-04-1 MADEP-VPH-04-1 MADEP-VPH-04-1 MADEP-VPH-04-1

.1 .1 .1 .1 .1 .1 .1 .1 .1 .1 .1

Method

C5-C8 Aliphatics C9-C12 Aliphatics 09-Ci0 Aromatics C5-C8 Aliphatics* CS-Cl12 Aliphatics* Benzene Ethylbenzene Methyl tert-Butyl Ether Naphthalene Toluene Xylene (total) Surrogate

MADEP-VPH-04-1 .1

2,5-Dibromotoluene

Date Extracted: 07/22/04 Dilution Factor: 1 Sample Preservation: 1:1 Methanol Covering Sample Result

RL

Ujnits

ND ND ND ND ND ND ND

2.0 2.0 2.0 2.0 2.0

ND

0.20 0.20 0.08 0.20 0.41 0.41

mg/Kg mg/Kg mg/Kg mg/Kg mg/Kg mg/Kg mg/Kg mg/Kg mg/Kg mg/Kg mg/Kg

Result

AR

Units

121

70-130

ND ND ND

AR = Acceptance Range RL = Method Reporting Limit ND = Not Detected Comments: * = Unadjusted

Submitted By:

t~

&

Approved By:

C:\vPH\fComputer\FinaI Data\3524-3529vPH.xIs P.O. BOX 0119 - 1771 WASHINGTON STREET - STOUGHTON. MA 02072-0119 TELEPHONE 781-341-5108 - 1-800-899-1038 - FAX 781-344-3318

Cyn Environmentai Services Analytical Laboratory Customer: 1467 Main St. Location: Athol, MA Lab Number: 2043526 Sample ID: Comp 3 Sampled By: Chris McKenna Sample Matrix: Soil

[HE VIODE DIA

Job Number: 20276600SF Batch ID: ES0413 Sample Date: 07/22/04 Receipt Date: 07/22/04 Analysis Date: 07/27/04 Report Date: 07/2 8/0 4

Extractable Petroleum Hydrocarbons by MADEP EPH 04-1 Sample Temperature: Received @ 4*C Container Condition: Satisfactory Percent Moisture: 14.9 Frac. Column Lot #: 0124603

Date Extracted: 07/22/04 ARO ALl Dilution Factor: 1 1 Extraction Method: EPA 3546

Method

Result

GC/FID GO/FID GC/FID GC/FID GC/MS GC/MS GC/MS

GC/MS Method GC/FID GC/FID GC/FID GC/F ID

Analyte C9-C18 Aliphatics C19-C36 Aliphatics C11-C22 Aromatics C1 1-C22 Aromnatics* 2-Methylnaphthalene Acenaphthene Na phthalene Phenanthrene Surrogate 2-Bromonaphthalene 2-Fluorobiphenyl Chlorooctadecane Orthoterphenyl

R RL4

Units

990 360 360 360 ND ND ND ND

24 24 24 02 0.2 0.2 0.2

mg/Kg

Result

AR

104 106 63 78

40-140 40-1 40 40-1 40 40-140

mg/Kg

mg/Kg mg/Kg mg/Kg mg/Kg mg/Kg mg/Kg Units

AR = Acceptance Range RL = Method Reporting Limit ND = Not Detected Comments: *Unadjusted, Concentrations based on dry weight.

Submitted By: Pu BX019*171WAHNGT!ITEE-rSTU

Approved By: TON, MA 02072-0119 TELEPHONE 781-341 -5108 - 1-800-899-1038 - FAX 781 -344-3318

7

Cyn Environmental Services Analytical Laboratory Customer: Location: Lab Number: Sample ID: Sampled By: Sample Matrix:

SESRYIC ES

Athol Medical Clinic Athol, MA 2043526 Camp 3 Chris McKenna Soil

Job Number: Data File: Sample Date: Receipt Date: Analysis Date: Report Date:

20276600SP V28658.D 07/22/04 07/22/04 07/26/04 07/27/04

Volatile Petroleum Hydrocarbons Sample Temperature: Container Condition: Percent Moisture: Extraction Weight(g): Method MADEP-VPH-04-1 MADEP-VPH-04-1 MADEP-VPH-04-1 MADEP-VPH-04-1 MADEP-VPH-04-1 MADEP-VPH-04-1 MADEP-VPH-04-1 MADEP-VPH-04-1 MADEP-VPH-04-1 MADEP-VPH-04-1 MADEP-VPH-04-1

Received @ 40 C Satisfactory 14.9% 20.8 Analyte

.1 .1 .1 .1 .1 .1 .1 .1 .1 .1 .1

Method MADEP-VPH-04-1 .1

C5-C8 Aliphatics C9-C12 Aliphatics C9-C10 Aromatics C5-C8 Aliphatics* 09-Cl12 Aliphatics* Benzene Ethylbenzene Methyl tert-Butyl Ether Naphthalene Toluene Xylene (total) Surrogate 2,5-Dibromotoluene

Date Extracted: 07/22/04 Dilution Factor: 1 Sample Preservation: 1:1 Methanol Covering Sample Result

RL

Units

ND 20 2.3 ND 22 ND ND ND ND ND ND

2.1 2.1 2.1 2.1 2.1 0.21 0.21 0.08 0.21 0.42 0.42

mg/Kg mg/Kg mg/Kg mg/Kg mg/Kg mg/Kg mg/Kg mg/Kg mg/Kg mg/Kg mg/Kg

Result

AR

Units

102

70- 130

AR = Acceptance Range RL = Method Reporting Limit ND = Not Detected Comments: * =

Unadjusted

Submitted By: ~ C:\vPH\fComputer\inal Data\3524-3529vPH.xls

Approved By:

P.O. BOX 0119 - 1771 WASHINGTON STREET - STOUIGHTON, MA 02072-0119 TELEPHONE 781-341-5108

I-800-899-1038 1 - FAX 781-344-3318

Cyn Environmental Services Analytical Laboratory

IEDAf~GR

SEYIE

Customer: Location: Lab Number: Sample ID:

1467 Main St. Athol, MA 2043527 Comp 4

Sampled By: Chris McKenna Sample Matrix: Soil

Job Number: 20276600SP Batch ID: ES0413 Sample Date: 07/22/04 Receipt Date: 07/22/04 Analysis Date: 07/27/04 Report Date: 07/28/04

ExtraCtable Petroleum Hydrocarbons by MADEP EPH 04-1 Sample Temperature: Received @ 4C Container Condition: Satisfactory Percent Moisture: 22.0 Frac. Column Lot #: 0124603

Date Extracted: 07/2 2/04 ARO ALl Dilution Factor: 1 1 Extraction Method: EPA 3546

Method

Result

RL

Units

440 160 180 180 ND ND ND 0.9

26 26 26 26 0.3 0.3 0.3 0.3

mg/Kg

Result

AR

Units

90

40-140 40- 140 40- 140 40- 140

GC/FID GC/FID GC/FID GC/FID GC/MS GC/MS GC/MS GC/MS

Analyte C9-C18 Aliphatics C19-C36 Aliphatics C11 -C22 Aromatics C11-C22 Aromatics* 2-Methylna phthalene Acenaphthene Naphthalene Phenanthrene

Method GC/FID GC/FID GC/FID GC/FID

Surrogate 2-Bromonaphthalene 2-Fl uorobiphenyl Chlo rooctadecane

Orthoterphenyl

99 53 73

mg/Kg mg/Kg mg/Kg mg/Kg mg/Kg mg/Kg

mg/Kg

AR = Acceptance Range RL = Method Reporting Limit ND = Not Detected Comments: *Unadjusted, Concentrations based on dry weight.

Submitted By:

zZ~21~,

-

Approved By:

C:\Winnt\ProfesAdministaorTemplate\324.3527EPH P.O. BOX 0119 + 1771 WASHINGTON STREET + STOUGHTON, MA 02072-0119 TELEPHONE 781-341-.5108 * 1-800-899-1038

+

FAX 781-344-3318

7%

Cyn Environmental Services Analytical Laboratory Customer: Athol Medical Clinic Location: Athol, MA Lab Number: 2043527 Sample ID: Comp 4 Sampled By: Chris McKenna Sample Matrix: Soil

SERYICE S

Job Number: Data File: Sample Date: Receipt Date: Analysis Date: Report Date:

20276600SP V28659.D 07/22/04 07/22/04 07127104 07/27/04

Volatile Petroleum Hydrocarbons Sample Temperature: Container Condition: Percent Moisture: Extraction Weight(g): Method MADEP-VPH-04-1 MADEP-VPH-04-1 MADEP-VPH-04-1 MADEP-VPH-04-1 MADEP-VPH-04-1 MADEP-VPH-04-1 MADEP-VPH-04-1 MADEP-VPH-04-1 MADEP-VPH-04-1 MADEP-VPH-04-1 MADEP-VPH-04-1

Received

@ 4"

C

Satisfactory 22.0% 19.2 Analyte

.1 .1 .1 .1 .1 .1 .1 .1 .1 .1 .1

Method MADEP-VPH-04-1 .1

05-CS Aliphatics C9-C12 Aliphatics 09-C 10 Aromatics C5-CS Aliphatics* C9-C12 Aliphatics* Benzene Ethylbenzene Methyl tert-Butyl Ether Naphthalene Toluene Xylene (total) Surrogate 2,5-Dibromotoluene

Date Extracted: 07/22/04 Dilution Factor: 1 Sample Preservation: 1:1 Methanol Covering Sample Result

RL

Units

ND 4.2 ND ND 4.2 ND ND ND ND ND ND

2.5 2.5 2.5 2.5 2.5 0.25 0.25 0.10 0.25 0.50 0.50

mg/Kg mg/Kg mg/Kg mg/Kg mg/Kg mg/Kg mg/Kg mg/Kg mg/Kg mg/Kg mg/Kg

Result

AR

Units

112

70-130

AR = Acceptance Range RL = Method Reporting Limit ND = Not Detected Comments: * =

Unadjusted

Submitted By:

A~~

4~

C:\vPH-\Computer\Final Data\3524-3529vPH xis

Approved By:

P.O. BOX 0119 - 1771 WAsHINGTON STREET - sTOUGHTON, MA 02072-0119 TELEPHONE 781-341-5108 - 1-800-899-1038 - FAX 781-344-3318

/0

Cyn Environmental Services Analytical Laboratory

SEABV

Customer: Athol Medical Clinic Location: Athol, MA Lab Number: 2043528 Sample ID: Field Blank Sampled By: Chris McKenna Sample Matrix: Soil

I C~Ff_ ES

Job Number: Data File: Sample Date: Receipt Date: Analysis Date: Report Date:

20276600SP V28654.D 07/22/04 07/22/04 07126/04 07/27/04

Volatile Petroleum Hydrocarbons Sample Temperature: Container Condition: Percent Moisture: Extraction Weight(g): Method MADEP-VPH--04-1 MADEP-VPH-04-1 MADEP-VPH-04-1 MADEP-VPH-04-1 MADEP-VPH-04-1 MADEP-VPH-04-1 MADEP-VPH-04-1 MADEP-VPH-04-1 MADEP-VPH-04-1 MADEP-VPH-04-1 MADEP-VPH-04-1

Received @ 4" C Satisfactory 0.0% 15.0 Analyte

.1 .1 .1 .1 .1 .1 .1 .1 .1 .1 .1

Method MADEP-VPH-04-1 .1

C5-C8 Aliphatics C9-C12 Aliphatics C9-C10 Aromatics C5-C8 Aliphatics* C9--C1 2 Aliphatics* Benzene Ethylbenzene Methyl tert-Butyl Ether Naphthalene Toluene Xylene (total) Surrogate 2,5-Dibromotoluene

Date Extracted: 07/22/04 Dilution Factor: 1 Sample Preservation: 1:1 Methanol Covering Sample

Result

RL

Units

ND ND ND ND ND ND ND ND ND ND ND

2.5 2.5 2.5 2.5 2.5 0.25 0.25 0.10 0.25 0.50 0.50

mg/Kg mg/Kg mg/Kg mg/Kg mg/Kg mg/Kg mg/Kg mg/Kg mg/Kg mg/Kg mg/Kg

Result

AR

Units

122

70-1 30

AR = Acceptance Range RL = Method Reporting Limit ND = Not Detected Comments: * =

Unadjusted

Submitted By:__

Approved By:

C:\vPH4computer\Final Data\352435S29vPHxls P.O. BOX 0119 - 1771 WASHINGTON STREET * STOUJGHTON, MA 02072-0119 TELEPHONE 781- 341-5108

e

1-800-899-1038 - FAX 781-344-3318

/

Cyn Environmental Services Analytical Laboratory

EIlYI ROOUEI1RLR . SE[RVICES$

Customer: Location: Lab Number: Sample ID: Sampled By: Sample Matrix:

Athol Medical Clinic Athol, MA 2043529 Trip Blank Chris McKenna Soil

Job Number: Data File: Sample Date: Receipt Date: Analysis Date: Report Date:

20276600SP V28655.D 07/22/04 07/22/04 07/26/04 07/27/04

Volatile Petroleum Hydrocarbons Sample Temperature: Container Condition: Percent Moisture: Extraction Weight(g): Method MADEP-VPH-04-1 .1 MADEP-VPH-04-1 .1 MADEP-VPH-04-1 .1 MADEP-VPH-04-1 .1 MADEP-VPH-04-1 .1 MADEP-VPH-04-1 .1 MADEP-VPH-04-1 .1 MADEP-VPH-04-1 .1 MADEP-VPH-04-1 .1 MADEP-VPH-04--1.1 MADEP-VPH-04-1 .1 Method MADEP-VPH-04-1 .1

Received @ 4* C Satisfactory 0.0% 15.0 Analyte C5-C8 Aliphatics C9-C12 Aliphatics C9-C10 Aromatics C5-C8 Aiiphatics* C9-C12 Aliphatics* Benzene Ethylbenzene Methyl tert-Butyl Ether Naphthalene Toluene Xylente (total) Surrogate 2,5-Dibromotoluene

Date Extracted: 07/22/04 Dilution Factor: 1 Sample Preservation: 1:1 Methanol Covering Sample

Result

RL

_Units

ND ND ND ND ND ND ND ND ND ND ND

2.5 2.5 2.5 2.5 2.5 0.25 0.25 0.10 0.25 0.50 0.50

mg/Kg mg/Kg mg/Kg mg/Kg mg/Kg mg/Kg mg/Kg mg/Kg mg/Kg mg/Kg mg/Kg

Result

AR

Units

117

70- 130

AR = Acceptance Range RL = Method Reporting Limit ND = Not Detected Comments: *

= Unadjusted

Submitted By:

A ~Z -

Approved By:

Vt

C:\vPH\Computer\Final Data\3524-3529vPH.xIs P.O. BOX 0119 - 1771 WASHINGTON STREET.- STOUGHTON, MA 02072-0119 TELEPHONE 781-341-5108

*

1-800-899-1038 - FAX 781-344-3318

/2-

Cyn Environmental Services Analytical Laboratory

EDYVINRO IIl EO1ARL SERVICES

Quality Control Report EXTRACTABLE PETROLEUM HYDROCARBONS (EPH) By MADEP EPH 04-1

Sample ID: Soil Method Blank Lab Number: ESO41 3BLK Batch ID: ESO413 Extract Date: 07/12/04 Method

Analyte

GC/F ID GO/F ID GC/FiD GC/MS GO/MS GO/MS GC/MS

C9-C18 Aliphatics 019-036 Aliphatics 011-C22 Aromatics 2-Methylnaphthalene Acenaphthylene Acenaphthene Anthracene Benzo(a)anthracene Benzo(a)pyrene Benzo(b)fl uora nthene Benzo(g,h,i)perylene Be nzo(k)fluoranthene Chrysene Dibenz(a h)anth racene Fluoranthene Fluorene Indeno(1 ,2,3-cd)pyrene Naphthalene Phena nthrene Pyrene

GO/MS GO/MS GC/MS GO/MS GO/MS GO/MS GO/MS GO/MS

GC/MS GO/MS GO/MS GC/MS GO/MS Method

Surrogate

GC/FID

2-B romonaphthalene 2-Fluorobiphenyl Chlorooctadecane Orthoterphenyl

GO/F ID GO/F ID GO/F ID

Extraction Method: EPA 3546 Frac. Column Lot #: 0124603 Percent Moisture: 0.0% Extraction Weight: 10 gins Result

RL

Units

ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND

20 20 20 0.2 0.2 0.2 0.2 0.2 0.2 0.2 0.2 0.2 0.2 0.2 0.2 0.2 0.2 0.2 0.2 0.2

mg/Kg mg/Kg mg/Kg

Result

AR

Units

69 81 52 69

40-140 40-140 40-140 40-1 40

mg/Kg mg/Kg mg/Kg

mg/Kg mg/Kg mg/Kg mg/Kg mg/Kg mg/Kg mg/Kg

mg/Kg mg/Kg mg/Kg mg/Kg mg/Kg mg/Kg

mg/Kg

RL = Reporting Limit AR = Acceptance Range ND = Not Detected Submitted By

:_

PEN~f$*9m~gg~tV9rS

__

NY

Approved By:

Th4 r 8GHTON, MA 02072-0119 TELEPHONE 781-341-5108 - 1-800-899-1038 - FAX 781-344-3318

'-3

Cyn Environmentai Services Analytical Laboratory Quality Control Report

EDYVI RO Ai HIEf ITA 1. ERVuIrC

U L II I

I I, L U

-EXTRACTABLE PETROLEUM HYDROCARBONS (EPH) By MADEP EPH 04-1

Sample BD: Soil Range LCS Lab Number: ESO413LCS Batch ID: ESO413 Extract Date: 07/12/04 Method

Extraction Method: EPA 3546 Frac. Column Lot #: 0124603 Percent Moisture: 0.0% Extraction Weight: 10 gins

AnaMe

GO/FIDB GO/FIDB GO/FIDB GO/FIDB GO/FIDB GC/FIDB GC/FIDB GC/FIDB GC/FIDB GO/FIDB GC/FIDB GO/FIDB GC/FIDB GO/FIDB GO/FID GO/FIDB GO/FIDB GO/FIDB GO/FIDB GO/FIDB GO/FIDB GO/FIDB GO/FIDB GO/FIDB GO/FIDB GC/FIDB GO/FIDB GO/FIDB GC/FIDB GO/FIDB GC/FIDB

Naphthalene 2-Methy~lnaphthalene Acenaphthylene Acenaphthene Fluorene Phenanthrene Anthracene Fluoranthene Pyrene Benzo(a)anthracene Chrysene Benzo(b)fiuoranthene Benzo(k)fluoranthene Benzo(a)pyrene tndeno(1,2,3-od)pyrene Dibenz(a, h)anthracene Benzo(ghiperylene Non ane Decane Dodecane Tetradecane Hexadecane Octadecane Nonadecane Eicosane Docsane

Tetracosane Hexacosane Octacosane Tricontane Hexatriacontane

Method

Surrogate

GO/FIDB GO/FIDB GC/FIDB GC/FIDB

2-Bromonaphthalene 2-Fluorobiphenyl Chlorcoctadecane Orthoterphenyl

IResult

AR

42 44 49 50 48 52 46 54 54 53 56 53 55 52 45 45 44 46 42 46 51 55 66 55 58 60 59 59 56 55 43

40-140 40-140 40-14 0 40-140 40-14 0 40-140 40-140 40-140 40-140 40-140 40-140 40-1 40 40-1 40 40-1 40 40-140 40-140 40-14 0 40-140 40-140 40-140 40-1 40 40-140 40-140 40-140 40-140 40-140 40-140 40-140 40-140 40-140 40-140

Result

AR

65 77 51 61

40-140 40-140 40-140 40-140

Unijts

%Naphthatene Breakthrough =