1.0 title and approval page · phase i esa trc 2015 site visit . work plan for mercury assessment...

RFA# 16092 Miller Industries, Lisbon, ME

Rev. 1 Date: 12/11/2017

Approval Page

1.0 TITLE AND APPROVAL PAGE

Document Title: Site Specific Quality Assurance Project Plan Miller Industries, 300 Lisbon Street, Lisbon, Maine John K. Cressey, CG, PG, Beacon Environmental Consultants, LLC Preparer’s Name and Organizational Affiliation P.O. Box 2154, Windham, Maine 04062 (207) 376-5001 Preparer’s Address and Telephone Number 11/December/2017 Preparation Date:

Beacon Project Manager: John K. Cressey, CG, PG/Beacon Environmental Consultants, LLC

Beacon Project QA Officer: Nicole D. Cressey/Beacon Environmental Consultants, LLC

MEDEP Project Manager: Danielle Obery/MEDEP


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BEACON ENVIRONMENTAL CONSULTANTS, LLC

TABLE OF CONTENTS

1.0 TITLE AND APPROVAL PAGE ................................................................................................ 1

2.0 PROJECT ORGANIZATION AND RESPONSIBILITY FLOW CHART ............................. 3

3.0 SCOPE OF WORK........................................................................................................................ 5 3.1 Project Description and Background .................................................................................. 5 3.2 Data Quality Objectives .................................................................................................... 11 3.3 Conceptual Site Model ...................................................................................................... 13 3.4 Sampling Plan ................................................................................................................... 14

3.5.1 Dig Safe Clearance and Site Health & Safety Plan ............................................. 14 3.5.2 Field Screening—Soil Samples ........................................................................... 14 3.5.3 Soil Boring Exploration ....................................................................................... 14 3.5.4 Groundwater Sampling ........................................................................................ 15 3.5.5 Sample Management ............................................................................................ 15 3.5.6 Equipment Decontamination and Management of Investigation Derived Waste

(IDW) ................................................................................................................... 15 3.5.7 Historic Preservation (Section 106) Activity Review .......................................... 15 3.5.8 Reporting ............................................................................................................. 15

TABLES

Table 2-1: Project Personnel Responsibilities Table 3-1: Summary of Previous Investigations Table 3-2: Summary of Data Quality Objectives Table 3-3: Site Conceptual Model Summary Table 3-4: Summary of Site Investigation Table 3-5: Project Sampling SOPs Reference Table Table 3-6: Field Quality Control Samples Table 3-7 Sampling and Analysis Methods Requirements

FIGURES Figure 2-1: Project Organization Chart Figure 3-1: Site Location Map Figure 3-2: Site Plan


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2.0 PROJECT ORGANIZATION AND RESPONSIBILITY FLOW CHART This section provides a brief description of how the site investigation at Miller Industries property located at 300 Lisbon Street in Lisbon, Maine will be organized, including identification of the key project personnel, their responsibilities, and a flow chart showing the project chain of command. Figure 2-1 is a Project Organization Chart depicting the agencies and companies involved with this project. Table 2-1 describes each participant’s role in this project.

TABLE 2-1 PROJECT PERSONNEL RESPONSIBILITIES

NAME TITLE ORGANIZATIONAL AFFILIATION RESPONSIBILITIES

Danielle Obery Brownfields Project Manager

Maine Department of Environmental Protection (MEDEP)

Administers Brownfields 128(a) Grant. Approves tasks for the MEDEP and Provides technical oversight.

James Byrne Project Officer United States Environmental Protection Agency (USEPA)

Provides overall management of MEDEP’s Brownfields 128(a) Grant, reviews and approves deliverables.

John Cressey Brownfields Project Manager/ Task Manager

Beacon Environmental Consultants LLC

Provides overall technical and project direction for Beacon.

Nicole Cressey QA Officer Beacon Provides project quality assurance oversight.

John Cressey Field Lead Beacon Day-to-day technical lead in charge of field work; coordinates and conducts data collection; participates in data interpretation and preparation of deliverables; communicates and coordinates with subcontractors.

Field Staff Scientists/Geologists Beacon Conducts field activities with oversight from Project Manager/Task Manager; oversee subcontractor field activities; communicates and coordinates with Project Manager.


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Figure 2-1: Project Organization Chart

Beacon John K. Cressey, CG, PG

Brownfields Project Manager /Task Manager

Subcontractors Alpha Analytical Laboratory (Alpha)

Beacon Nicole Cressey

QA Officer

USEPA James Byrne

USEPA Project Officer

Beacon Various Staff

-Scientists -Geologists

MEDEP Danielle Obery

Brownfields Project Manager


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3.0 SCOPE OF WORK This Site Specific Quality Assurance Project Plan (SSQAPP) presents the sampling strategy, design, sample locations, analytical methods, and schedule for the site remediation at the Miller Industries property located at 300 Lisbon Street in Lisbon, Maine (the Site). The quality assurance/quality control (QA/QC) requirements contained in the original QAPP will be followed relative to sample collection, handling and analysis of samples including chain of custody, data management and documentation, data validation, and data usability assessments. Field and lab Standard Operating Procedures (SOPs) are included in the QAPP. 3.1 PROJECT DESCRIPTION AND BACKGROUND The Site is located at 300 Lisbon Street in the Town of Lisbon, Androscoggin County, Maine. According to information obtained from the Town of Lisbon Tax Assessor, the Site is identified on Assessor’s Map U-13 as Lots 34, 35, 42, and 43, which are approximately 1.3 acres, 1.3 acres, 2.2 acres, and 1.8 acres in size, respectively. Lot 34 is currently owned by Miller Realty Co., and Lots 35, 42, and 43 are currently owned by Miller Industries, Inc. Site History According to the Phase I ESA completed by TRC, documentation did not exist regarding the property’s usage prior to 1953. From 1953 through 1998 portions of the property were developed with mill structures for the manufacturing of blankets including:

• Lot 34: o Filtration Building o Clarifier

• Lot 35: o Parking lot

• Lot 42: o Weave Building o Due to clarity issues, the date(s) the substation was on-Site is uncertain

• Lot 43: o Main Mill Building (and Dye House) o Boiler Room o Machine Shop o Water Tower

The structures were demolished between 2005 and 2008 and the property is currently vacant.

Previous Investigations Table 3-1 describes the type of investigation, date, and contractor.

Table 3-1: Summary of Previous Investigations Type of

Investigation Contractor Conducting

Investigation Date of

Investigation Field Work Completed

Work Plan Sevee & Maher (SME) 2003 Site visit

Addendum to SME 2003 Site visit


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Work Plan

Findings Report SME 2004 Mercury assessment of building

Findings Report SME 2004 Post Demolition Assessment

Work Plan SME 2004 Site Visit

Site Assessment SME 2005 UST Removal and excavation

Findings Report SME 2005 Post Demolition Assessment

Work Plan SME 2005 Site Visit

Hazardous Waste Closure

SME 2005 Site Visit

Field Analysis Results for Monitoring of Oil

SME 2007 Groundwater sampling

Construction Documentation of Demolition Activities

SME 2009 Post Demolition Assessment

Hazardous Waste Closure

SME 2009 Site Visit

DEC SME 2012 Site Visit

Work Plan Wright Pierce 2015 Site Visit

Phase I ESA TRC 2015 Site visit

Work Plan for Mercury Assessment of Water Treatment Plant, SME, July 2003 In July 2003, SME submitted a work plan for the mercury assessment of the water treatment plant, which purpose was to:

“…outline a mercury assessment at the former water treatment plant (WTP) at Miller Industries' Mill Street Mill in Lisbon, Maine. The TP is identified in a June 2, 2003 letter from the Maine Department of Environmental Protection (MDEP) to Miller Industries, which noted concerns with building and soil contamination. The objective of the mercury assessment at the WTP will be to characterize the site conditions as related to mercury presence. The information gathered from the mercury assessment will be used to determine the nature and extent of future investigations and any remediation that may be necessary at the WTP.”


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Addendum to Work Plan for Mercury Assessment of Water Treatment Plant, SME, November 2003 In November 2003, SME modified the (aforementioned) July 2003 Work Plan approved by the MEDEP. The modifications included:

“…the clean-up of the mercury containing surfaces, investigation of any pipelines from the water treatment plant to the Sabattus River, and sediment sampling of all discharge points.”

Findings Report for Mercury Assessment of Water Treatment Plant, SME, June 2004 In June 2004, SME presented their results of the mercury assessment investigation at the Mill Street WTP. At the time of the report:

“…SME does not recommend the need for additional remediation work on the first floor due to the absence of direct exposure and risk to human health or the environment from the relatively low concentrations of mercury detected… …It is anticipated that approximately 1,000 square feet of the basement floor will require the TechXtract® process, generating approximately two to three drums of mercury containing waste liquid… …It is anticipated that the entire 2,300 square feet of the sub-basement concrete floor will require the TechXtract® process, generating approximately four to five drums or mercury containing waste liquid…”

Findings Report for Weave Building, Post-Demolition Investigation, SME, June 2004 In June 2004, SME recommended no further action on the first floor upper level, in areas of buried metals and pipe, or in the inert landfill. However: SME recommended:

A three foot by three foot area in the east room of the basement be remediated; an estimated four to five drums of soil was anticipated to be produced. Once the proposed remedial actions have been completed, Environ personnel will begin backfilling and grading the Weave Building foundation area. The backfill will consist of soil and inert debris (e.g. clean concrete and brick), and be brought to grade with the surrounding access road along the north and east sides. The backfill grade will be gradually sloped in a southward direction.

Work Plan for Handling, Sampling, and Analysis of Oil-Containing Soils During Tank Removal and Post Demolition Investigations, SME, July 2004 In July 2004, SME submitted a Work Plan addressing the sampling, analysis, and management of potential oil-containing soil that may be encountered during the removal of the four 15,000-gallon abandoned fuel oil tanks (see P-784-2004) and the investigation and removal of the surrounding building foundation(s) at the Mill Street Mill. Site Assessment, SME, March 2005


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In March 2005, SME completed a Site Assessment focusing on the excavation and removal of the four abandoned USTs, the (potential) extent of oil leakage, and the excavation and removal of oil-containing soils, pipes, and concrete. As of the date of the report, SME concluded that the tasks remaining for completion included:

“…the removal and disposal of stockpiled soil-coated concrete debris to a licensed facility with approval of the MDEP, the thawing out and final pumping of remaining oil and water stored in the on-site frac tank, and the establishment of a monitoring plan complete with monitoring wells to identify if further migration of the No. 6 oil is occurring through the subsurface…”

Findings Report for White Room, Post-Demolition Investigation, SME, April 2005 In April 2005, SME recommended no further action on the second floor level, on the Maintenance Garage area, or on the first floor level. In addition:

“Following the completion of all post-demolition investigations and identified remedial actions, Environ personnel started the process of backfilling and grading activities within the White Building area. The backfill consists primarily of soil and inert debris (e.g., clean concrete and brick), and will be gradually sloped and brought to grade with the surrounding access road along the north and east sides. The area will be top-soiled, seeded, and returned to green space in the Spring of 2005.”

Work Plan for Monitoring of Oil Migration, SME, April 2005 In April 2005, SME submitted a letter which,

“…serves as a Work Plan for a proposed boring program to identify oil within the subsurface soils and shallow groundwater at the Mill Street Textile Mill, owner my Miller Industries, Inc. of Lisbon Falls, Maine. The objective of this proposed program is to identify the migration of and residual heavy fuel oil or diesel range organic (DRO) compounds through the soils and groundwater after the site assessment and oil remediation activities were completed in February of 2005.”

Findings Report for Main Mill Building, Post-Demolition Investigation, SME, September 2005 In September 2005, SME recommended no further action on the Main Mill first floor, Main Mill basement, or in the Main Mill Dye House Pit area. In addition:

“Following the completion of all post-demolition investigations and identified remedial actions, Environ personnel proceeded with backfilling and grading activities within the Main Mill area. The backfill consists primarily of clean sandy gravel soil and small quantities of inert debris (e.g., clean concrete and brick), to be gradually sloped and brought to grade with the other canal wall adjacent to the Sabattus River. The area will be top soiled, seeded, and returned to green space in September of 2005.”

SME also submitted weekly updates to MEDEP during Post Demolition Investigations (of Weave Building, White Room, Main Mill Building, etc.) to report progress of the demolition process.


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Proposed Mercury Remediation Letter, SME, December 2005 In December 2005:

“As a remedial measure, SME proposed the excavation and removal of sediments in the vicinity of the outfall pipe… The excavation would require the use of an excavator to dredge the sediment from the river, a screen to filter out large cobbles and rocks, and a dewatering tank. The excavation activities would be scheduled during the summer months of July-August when the water level within the river is at its lowest, exposing as much of the sediment along the riverbank and the outfall pipe as possible.”

Facility Hazardous Waste Closure, Mill Street Textile Mill, SME, January 2006 In January 2006, SME submitted a Facility Hazardous Waste Closure report, stating,

“As a result of the reconnaissance visits, post-demolition investigations, and cleanup/remediation efforts completed by contracted companies, Sevee & Maher Engineers, Inc. hereby certifies in accordance with the regulations for hazardous waste closure certification under Chapter 851 of the MDEP Rules, that there are no known remaining hazardous wastes at the Mill Street Mill facility located at 15-19 Mill Street in Lisbon Center, Maine.”

Field Analysis Results for Monitoring of Oil Completed on May 17, 2007, SME, May 2007 In May 2007, results of the final round for the two bi-annual sampling periods were submitted to MEDEP. SME states,

“The objective of the program was to identify the migration of any residual heavy oil or diesel fuel through the soils and groundwater after the site assessment and oil remediation activities were completed in February 2005. Based on SME’s observations of the former Mill Street Textile Mill’s monitoring wells for the past two years, there is no evidence of heavy oil or diesel migration through the soils and groundwater. SME requests on behalf of Miller Industries, that no further monitoring events are necessary for the oil remediation project at the Mill Street Mill.”

Construction Documentation for Mercury Remediation and Demolition Project, Filtration Building, SME, November 2009 In November 2009, SME concluded:

“The remediation of the mercury-impacted concrete flooring in the Miller Industries Mill Street Mill Filtration Building and the demolition of the Filtration Building and the Pump House were completed in accordance with the plan as approved by MEDEP in Augusta 2008. The hazards of potential exposure to mercury from the Filtration Building have been eliminated by the remedial action completed in the summer of 2008. A minimum 1- inch of the concrete flooring in the basement and sub-basement of the Filtration Building where mercury had been previously detected was removed and


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transported to a licensed facility for proper disposal of hazardous waste. The Filtration Building was then demolished and the area restored to green space. The river intake Pump House was also demolished and the bank of the Sabattus River stabilized with riprap. At this time, SME recommends no further action for the former Filtration Building at the 10 Mill Street property in Lisbon Center, Maine.”

Facility Hazardous Waste Closure, Filtration Building, SME, November 2009 In November 2009, SME submitted a Facility Hazardous Waste Closure report, stating,

“As a result of the reconnaissance visits, post-demolition investigations, and cleanup/remediation efforts completed by contracted companies, Sevee & Maher Engineers, Inc. hereby certifies in accordance with the regulations for hazardous waste closure certification under Chapter 851 of the MEDEP Rules, that there are no known remaining hazardous wastes at Filtration Building - Mill Street Mill facility located at 10 Mill Street in Lisbon Center, Maine, with the exception of remnant sediment containing mercury completed in September 2009. At this time, SME recommends no further action for removal of sediments containing mercury in the Sabattus River. If the water levels in the Sabattus River drop as a results of proposed removal of the Mill Street Dam, the potential for exposure to the remaining mercury impacted sediments may be re-assessed, if warranted.”

Declaration of Environmental Covenant Revisions Letter, SME, August 2012 In August 2012, SME was asked to update the Draft Declaration of Environmental Covenant (DEC) to include: The location of the property lines; The Right of Way for Mill Street; The location of the existing water main which crosses the Sabattus River; The location of the remaining pockets of sediment containing mercury; and Where the thread of the river (i.e. the deepest channel portions) is located. During TRC’s file review with the MEDEP, TRC spoke with Ms. Pam Green, Project Manager with the MEDEP. Ms. Green stated that the MEDEP did not have a finalized DEC on file, meaning, as sampling and/or remediation activities are still being conducted on-Site, a finalized DEC has not yet been completed/submitted. Sampling and Analytical Work Plan for Sabattus River Mill Street Mill and Dam, Wright-Pierce, February 2015

In February 2015, Wright-Pierce developed a Sampling and Analytical Work Plan which covered:

• Resampling and analyzing of the Sabattus River Sediments Beneath Clay berm; and • Sampling and Analyzing the North Upstream Dam Sediments, North Shoreline

Sediments, and Sediments within North Side Impoundment.


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Phase I Environmental Site Assessment, TRC, October 2015 TRC prepared a Phase I ESA for the MEDEP dated October 2015 for the purpose of identifying recognized environmental conditions (RECs) as defined by the ASTM E 1527-13 standard associated with the Site. This Phase I ESA identified the following RECs and other environmental findings, which do not rise to the level of a REC:

• REC #1: Historical Site Use – Based on the Site’s known use as a mill for at least 75 years, the possibility exists for historically poor housekeeping practices and the potential for undocumented/un-remediated historical releases to have impacted surface and subsurface conditions at the Site, which constitutes a REC in connection with the Site.

• REC #2: Historical & Current Contaminant Assessment(s) and/or Remediation(s) – Historical and current documented releases to soil and river sediment at the Site, specifically, contamination in conjunction with the four former underground storage tanks (USTs), contamination in conjunction with the former Filtration Building, and remediation activities Site-wide, constitutes a REC in connection with the Site.

3.2 DATA QUALITY OBJECTIVES Data Quality Objectives (DQOs) are qualitative and quantitative statements that specify the quality and quantity of data needed to support decisions during site assessments. DQOs are developed by considering the purpose of collecting the data and the intended use of the data. The objective of this investigation is to determine whether impacts to the property exist. Data will be compared to MEDEP and USEPA risk-based standards and screening criteria to evaluate potential risk to human health and the environment. Based on this comparison and the proposed uses of the Site, a plan will be developed to remediate and/or manage any contamination discovered on the Site. A summary of data quality objectives that have been developed to meet the goals of this Site investigation are provided in Table 3-2. Data quality assessments are discussed in Section 9 of the QAPP.


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TABLE 3-2 SUMMARY OF DATA QUALITY OBJECTIVES

MATRIX PARAMETER METHODS STATE OR FEDERAL

STANDARD ANALYTICAL

LEVEL 1 DATA EVALUATION

TIER2 INTENDED DATA USE 3

Field Parameters Soils Total VOCs

Total Mercury Handheld PID Meter Handheld Lumex

None Level I NA FS, HS, ID

Off-Site Laboratory Analysis Subsurface Soils

EPH VPH RCRA 8 Metals PCBs VOCs

Massachusetts Method EPH Massachusetts Method VPH USEPA Method 6010C USEPA Method 8082 USEPA Method 8260C

MEDEP Petroleum Guidelines MEDEP Petroleum Guidelines MEDEP Hazardous Guidelines MEDEP Hazardous Guidelines MEDEP Hazardous Guidelines

Level II Modified Tier I ID, CC, IR, FA, HS, FS

Surface Soils EPH VPH RCRA 8 Metals PCBs VOCs




Groundwater EPH VPH RCRA 8 Metals PCBs VOCs




NOTES: 1) Analytical levels (USEPA, October 1988) Level I, on-site field screening and measurements, use one point calibration. Level II analyses using standard laboratory QA/QC, including duplicate analyses, suitable calibration

standards, sample preparation equipment, and operator training. 2) Tier levels for Region I, EPA-New England Data Validation Functional Guidelines for Evaluating Environmental Analyses (USEPA 1996). Modified Tier 1 is described in Section 17.2 of the Project QAPP. 3) Data Intended End Use is project-specific and may include: (EA) determine need for emergency action; (ID) identify waste material/contaminants; (CC) determine quantity and levels of contamination; (IR) identify

impacted targets/receptors; (SS) develop site score; (FA) document need for further action or no further action; (HS) health & safety; (FS) field screening. 4) MECDC Petroleum Guidelines = Remediation Guidelines for Petroleum Contaminated Sites in Maine, December 1, 2014


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Beacon has reviewed the Practical Quantitation Limits (PQLs) for the COCs and has determined that the laboratory can meet these limits. 3.3 CONCEPTUAL SITE MODEL Site Familiarity Beacon has reviewed the ASTM-compliant Phase I ESA completed by TRC, which included Site history research and reconnaissance to identify potential Contaminants of Concern (COCs) and to serve as the basis for proposed investigations. The Scope of Work served as the basis for development of our conceptual model for the Site. Table 3-3 provides a summary of key Conceptual Site Model Elements. Site Geology and Hydrogeology According to the United States Geological Survey topographic map, Lisbon Falls North Quadrangle dated 2014, the Site topographic elevation is approximately 140 feet above mean sea level, and local topography slopes towards the Sabattus River through the center of the Site. The topographic downward slope observed at the Site during the Site reconnaissance is generally towards the Sabattus River. According to the Significant Sand and Gravel Aquifer Map for the Lisbon Falls North, Maine Quadrangle, dated 1999, the Site is located within a Significant Sand and Gravel Aquifer which has moderate to no or low potential yield. This aquifer includes areas underlain by till, marine deposits, eolian deposits, alluvium, swamps, thin glacial sand and gravel deposits, or bedrock. Yields in surficial deposits are generally less than 10 gallons per minute in a properly constructed well. A copy of the Lisbon Falls North, Maine Quadrangle Significant Sand and Gravel Aquifer map has been included in Appendix C. Based on local topography and the Significant Sand and Gravel Aquifer Map for Lisbon Falls North, Maine Quadrangle, the assumed direction of shallow groundwater flow is anticipated to be towards the Sabattus River. However, a subsurface investigation would be required to assess actual groundwater flow direction. Sampling Objective As described in the Phase I ESA report and shown on the Site Plan, four areas of concern (AOCs) have been identified at the Site. Beacon will contact DigSafe to identify utilities in the area. The work described below focuses on identifying threats to the Site from former activities at the Site. AOC 1 – Former Substation A substation was located on the northeastern portion of the Site. Therefore, EPH, VPH, PCBs, and the 8 RCRA metals are considered COCs in surficial and subsurface soils and EPH, VPH, and 8 RCRA metals in groundwater in this area as well and assessment of the extent of petroleum using current analytical methods remains a data gap. AOC 2 – Former Boiler Room and Machine Shop


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The southeastern portion of the property was used occupied by the boiler room and the machine shop. EPH, VPH, VOCs and the 8 RCRA metals would be COCs within the former excavations and downgradient thereof in soil and/or groundwater. Assessment of these areas using current analytical methods and their extent remains a data gap. AOC 3 – Former Filtration Building A waste water treatment facility was formerly located in the southwest corner of the Site. Therefore, EPH, VPH, and the 8 RCRA metals are considered a COC for surficial soil, subsurface soils and groundwater in the southwest portion of the Site and assessment of the former facility as a source remains a data gap. AOC 4 – Northwest Portion of the property Past usage of the property as a mill may have impacted this portion of the property. EPH, VPH and RCRA 8 Metals, are therefore considered COCs for this AOC. 3.4 SAMPLING PLAN Based on the findings of the recent Phase I ESA, a sampling program has been developed to investigate potential soil contamination at the Site and to attempt to delineate potential source areas. A summary of the investigation, including sampling locations, media to be sampled and analytical program is included in Table 3-4; sampling locations will be dependent upon field sampling results. See Figure 3-2 for the sampling plan. These sampling locations will serve to detect potential contamination from historic onsite operations or releases. Standard operating procedures for this project are listed in Table 3-5, and are included in the Project QAPP. Field quality control samples to be collected for this project are described in Table 3-6. Table 3-7 presents the sample analysis requirements, including analyses to be performed, required sample volumes, containers, and preservation, and maximum holding times. Refer to Section 11 of the Project QAPP for field document control procedures. The scope of work to meet the objectives of the sampling plan is detailed below. 3.5.1 Dig Safe Clearance and Site Health & Safety Plan Beacon will pre-mark investigation locations and contact Dig Safe for utility clearance. A Site-specific health & safety plan (HASP) will be developed for the proposed Site investigation. Additionally, Beacon will subcontract with Digsmart of Maine to complete onsite utility locating. 3.5.2 Field Screening—Soil Samples Soil samples will be field screened for Total Organic Vapors (TOVs) using a PID and for Mercury using a Lumex RA915 meter. During field screening, results will be considered “elevated” if they are above 100 parts per million (ppm) for TOVs and above 85 ppm for Mercury. 3.5.3 Soil Boring Exploration Soil sampling will be completed in accordance with SOP 27 as required by the MEDEP’s soil sampling guidelines. Soils will be field screened with a PID in accordance with SOP 15 in the


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Project QAPP and with a Lumex for Mercury. Table 3-3 provides a summary of the proposed sampling program by media and analytes. 3.5.4 Groundwater Sampling Groundwater sampling will be completed via temporary 1” PVC wells. Once the well has been installed, it will be purged for up to 15 minutes with a peristaltic pump and tubing (in accordance with SOP #02) in an effort to develop and remove silt from within the wells prior to sampling. The wells will be sampled immediately following development. Once monitoring wells have been developed, a modified low-flow purge and sampling procedure will be conducted in general accordance with SOP #02 (See Table 3-5), but with the following modifications to that SOP:

• Measurements of temperature and ORP/Eh will not be used as indicators of stabilization.

• A reasonable effort will be made to achieve groundwater level stabilization. Table 3-3 provides a summary of the proposed sampling program by media and analytes.

3.5.5 Sample Management Samples will be collected and managed as described in the associated SOPs referenced above. Sample preservation requirements are listed in Table 3-7. 3.5.6 Equipment Decontamination and Management of Investigation Derived Waste (IDW) Powdered alconox will be used as a decontamination agent. Decontamination procedures are described in SOP 13. IDW will be managed as follows:

• Any excess soil generated during sampling will be backfilled. If free product is encountered, it will be contained for off-site disposal. 3.5.7 Historic Preservation (Section 106) Activity Review The activities and tasks proposed in this QAP do not have the potential to cause “effects” on historic properties (as defined in Section 106), if historic properties are present. Additional review under Section 106 - Protection of Historic Properties is not required. 3.5.8 Reporting

A report will be completed as described in the Project QAPP. The report will include the following items: 1. Tabulated analytical results (analytes exceeding regulatory standards will be in

bold face type). 2. A map documenting sampling locations and location of Site features. 3. A discussion of deviations from the approved QAPP and the effect on data

usability, if any.


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4. Recommendations for additional work, if necessary and justifications based upon data quality objectives and the conceptual site model.


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TABLE 3-3 SITE CONCEPTUAL MODEL SUMMARY

POSSIBLE SOURCE AREAS

AOC 1 – Former Substation AOC 2 – Former Boiler Room and Machine Shop AOC 3 – Former Filtration Building AOC 4 – Northwest Portion of the Property

CONTAMINANTS OF CONCERN

AOC 1 • Volatile Petroleum Hydrocarbons (VPH) • Extractable Petroleum Hydrocarbons (EPH) • Polychlorinated Biphenyls (PCBs) • 8 Resource Conservation and Recovery Act (RCRA) Metals

AOC 2 • EPH • VPH • 8 RCRA Metals • Volatile Organic Compounds (VOCs)

AOC 3 • VPH • EPH • 8 RCRA Metals

AOC 4 • EPH • VPH • 8 RCRA Metals

POTENTIAL MEDIA AFFECTED Soil and Groundwater

POTENTIAL EXPOSURE ROUTES

Exposure pathways for contamination in soil/sludge: • Direct contact for site workers • Inhalation of fugitive emissions (dust) during site use Exposure pathways for contamination in groundwater • Direct contact for site workers

POTENTIAL MIGRATION PATHWAYS

Migration pathways for contaminants: • Groundwater transport (if impacted).

RECEPTORS For soil and groundwater, potential receptors include site workers during excavation.

For soil, potential receptors include future site occupants if impacted surficial soil is discovered.


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TABLE 3-4 SUMMARY OF SITE INVESTIGATION

AOC

SAMPLE LOCATION/ SOURCE AREA (1)

TASK/MEDIA SAMPLE IDS

DEPTH OF SAMPLE

ANALYTICAL PARAMETER

NUMBER OF LAB SAMPLES(2)

NUMBER OF DUPLICATES RATIONALE FIELD ANALYSES/

OBSERVATIONS

AOC 1 Former Substation

Subsurface Soil SB-4, SB-5

Greatest observed contamination or groundwater interface

EPH VPH PCBs 8 RCRA Metals

2 1

To assess subsurface soil conditions associated with the former Substation

PID Field-Screening, Lumex Screening Visual Observations

Surficial Soil SB-4, SB-5 0-2’


2 0

To assess surface soil conditions associated with the former Substation

Groundwater MW-4 Screened interval


1 1

To assess groundwater conditions associated with former Substation

AOC 2 Former Boiler Room and Machine Shop

Subsurface Soil SB-6, SB-7, SB-8


VPH EPH 8 RCRA Metals VOCs

3 1

To assess subsurface soil conditions associated with former boiler room

PID Readings Lumex Readings Visual Observations

Surficial Soil SB-6, SB-7, SB-8 0-2’


3 0

To assess surface soil conditions associated with the former boiler room

Groundwater MW-6, MW-8

Screened interval


2 1

To assess groundwater conditions associated with former boiler room

AOC 3 Former Filtration Building Subsurface Soil SB-9, SB-

10, SB-11


VPH EPH 8 RCRA Metals

3 0

To assess subsurface soil conditions associated with former filtration building



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TABLE 3-4 SUMMARY OF SITE INVESTIGATION

AOC

SAMPLE LOCATION/ SOURCE AREA (1)

TASK/MEDIA SAMPLE IDS

DEPTH OF SAMPLE

ANALYTICAL PARAMETER

NUMBER OF LAB SAMPLES(2)

NUMBER OF DUPLICATES RATIONALE FIELD ANALYSES/

OBSERVATIONS



3 0

To assess surface soil conditions associated with former filtration building

Groundwater MW-9, MW-11

Screened interval


2 0

To assess groundwater conditions associated with former filtration building

AOC-4 Northwest Portion of the Site

Subsurface Soil SB-1, SB-2, SB-3



3 0

To assess subsurface soil conditions associated with the northwest portion of the Site




3 0

To assess surface soil conditions associated with the northwest portion of the Site

Groundwater MW-2 Screened interval


1 0

To assess groundwater conditions associated with the northwest portion of the Site

Site-wide Industrial Activities Surficial Soil

SS-1, SS-2, SS-3, SS-4, SS-5, SS-6, SS-7, SS-8, SS-9

0-2’ EPH 8 RCRA Metals 9 0

To assess the potential for soil impacts due to past site use



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TABLE 3-5 PROJECT SAMPLING SOPS REFERENCE TABLE

SOP REFERENCE NUMBER TITLE, REVISION DATE AND/OR NUMBER

ORIGINATING ORGANIZATION

SOP #02 RWM-DR-002 Groundwater Sample Collection for Site Investigation and Assessment Monitoring, Revision 00, March 25, 2009

MEDEP

SOP #06 RWM-DR-006 Protocol for Collecting Soil Samples, Revision 06, April 3, 2009 MEDEP

SOP #09 RWM-DR-012 Chain of Custody Protocol, Revision 04, April 3, 2009 MEDEP SOP #10 RWM-DR-013 Documentation of Field Activities and Development of a

Trip Report, Revision 03, April 3, 2009 MEDEP

SOP #13 RWM-DR-017 Equipment Decontamination Protocol, Revision 03, March 23, 2009

MEDEP

SOP #15 RWM-DR-019 Protocol for the Use of Portable Vapor Monitors, Revision 02, April 3, 2009

MEDEP

SOP #23 E1903-11 Standard Practice for Environmental Site Assessments: Phase II Environmental Site Assessment Process, July 2011

ASTM

SOP #27 Compendium of Field Testing of Soil Samples for Gasoline and Fuel Oil, October 25, 2012

MEDEP


Rev. 1 Date: 12/11/2017


TABLE 3-6 FIELD QUALITY CONTROL SAMPLES

QC SAMPLE FREQUENCY ACCEPTANCE CRITERIA CORRECTIVE ACTION

Soil: field duplicate

1 per 20 samples collected, per media (minimum of one/event)

Per USEPA data evaluation guidelines for comparison of field duplicates

Compare for resampling or reanalysis

Soil equipment rinse blank

One per non-dedicated piece of equipment that comes in contact with sample medium per sampling event

No compounds detected

Qualify results or resample if cross contamination is suspected

VOC/VPH Trip Blank

1 per cooler containing VOC/VPH samples

No compounds detected

Qualify results or resample if cross contamination is suspected


Rev. 1 Date: 12/11/2017


Table 3-7 Sampling and Analysis Methods Requirements

Medium/Matrix Analytical Parameter

Sampling SOP

Lab SOP Number of Samples Analytical Method

Sample Volume

Containers (Number, size and type)

Preservation Requirements (chemical, temperature)

Maximum Holding Time (preparation/ analysis)

Soil MA VPH SOP #06 2120 See Table 3-4 MA VPH 15 g 40 mL glass vial Methanol, 4°C 14 days to extraction; 40 days to analysis

MA EPH SOP #06 2119 See Table 3-4 MADEP EPH

30 g Amber glass w/ Teflon screw top

4°C Extracted within 7 days analyzed within 40 days

VOCs SOP #06 2108 See Table 3-4 8260 15 g 40 mL glass vial Methanol, 4°C 14 days to extraction; 40 days to analysis

RCRA 8 Metals SOP #06 2144 See Table 3-4 6010C 30 g Amber glass w/ Teflon screw top

4ºC Extracted within 7 days analyzed within 40 days

PCBs SOP #06 2129 See Table 3-4 8082 30 g Amber glass w/ Teflon screw top

4ºC Extracted within 7 days analyzed within 40 days

Groundwater VOCs SOP #02 2108 See Table 3-4 8260 40 mL 3 x 40 mL glass vials

HCl 14 days to extraction; 40 days to analysis

MA EPH SOP #02 2119 See Table 3-4 MADEP EPH

1L Amber glass w/ Teflon screw top


MA VPH SOP #02 2120 See Table 3-4 MA VPH 40 mL 3 x 40 mL glass vials


RCRA 8 Metals SOP #02 2144 See Table 3-4 6010 C 150 mL 1 x 150 mL plastic bottle

HNO3 Extracted within 7 days analyzed within 40 days

FIGURE 3-1: SITE LOCATION MAP Project No. BE-083

Drawing Not To Scale

Source: Esri, DigitalGlobe, GeoEye, Earthstar Geographics, CNES/Airbus DS,USDA, USGS, AeroGRID, IGN, and the GIS User Community

Former #2 AST

Former Boiler RoomFormer Machine Shop

Former Substation

Former Filtration Building

Former Clarifier

Proposed Sample Locations Miller Industries Mill St., Lisbon 0 50 100 150 20025

Feet

EPH, VPH, RCRA 8 MetalsEPH, VPH, PCBs, RCRA 8 Metals

EPH, VPH, RCRA 8 MetalsEPH, VPH, 8260, RCRA 8 Metals

Surficial Soil Sample Location(EPH, RCRA 8 Metals)

Surficial Soil Sample and Boring Sample Location

SS-1

SS-2SS-3 SS-4

SS-5

SB-1

SB-2/MW-2

SB-3

SB-4

SB-5/MW-5

SB-6/MW-6

SB-7

SS-6

SS-7

SB-8/MW-8SB-9/MW-9SB-10

SB-11/MW-11

SS-8

SS-9

Figure 3-2

1.0 title and approval page · phase i esa trc 2015 site visit . work plan for mercury assessment...

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