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| Debris Behind the Former Automotive Repair Garage, Lot O-32 |
Before its purchase by Mr. Roberts, Lot O-32 was used as a vehicle repair shop, landscaping and gravel business, and unofficial dumping site. Between 1957 and 1967, it was “used by the Air Force for a terminal very high-frequency omni-directional range (TVOR) facility, a type of short-range radio navigation system for aircraft”, according to a report dated October 25, 2021, by O’Reilly, Talbot & Okun. This company performed a limited subsurface assessment of the site as the town prepared for possible development of the parcel.
Findings by this firm prompted a “Release Notification Form” filing with the Massachusetts Department of Environmental Protection (MA DEP) regarding volatile organic compounds (VOCs) found at one of the soil boring sites. Although soil sample borings B-1 through B-8 and B-10 were not concerning, sample B-9 showed compounds compatible with a release of gasoline.
MA DEP has defined Lot O-32, or portions thereof, as a waste disposal site under MA General Law Chapter 21E, also known as the MA Superfund law, and the MA Contingency Plan, 310 CMR 40. Further assessment by the town is required and a report must be submitted to MA DEP by January 23, 2023.
This is the second time Shutesbury has filed with the MA DEP due to contamination found at this site. Approximately 10 years ago the town was required to notify the Department of a finding of polychlorinated biphenyls (PCBs) from a groundwater sample in a well adjacent to a drum located behind the former garage building on Lot O-32. That notice was retracted five weeks later.
Between 2010 and 2012, Lot O-32 was poked and prodded several times by a handful of environmental assessment companies as the town sought to determine whether the site was contaminated. Here is a timeline of contamination-related activities involving the site and the investigations leading up to the discovery of PCBs behind the dilapidated garage, the reporting of such to MA DEP, and the subsequent retraction.
Note: The late Larry Kelley of Amherst reported at length on these issues 10 years ago on his blog, Only in the Republic of Amherst. The photos presented in this post are from his blog, which I encourage readers to peruse.
1995: The U.S. Military Cleans Up a Messy Legacy
In 1995, contamination from the underground storage tank (UST) installed by the military prompted a Formerly Used Defense Sites Program (FUDS) cleanup of Lot O-32 by the U.S. Army Corps of Engineers on behalf of the Department of Defense. During cleanup, the Corps removed the UST (page 6) and 100 tons of gasoline-contaminated soil from the former TVOR location.
2010: First Looks by Fuss & O’Neill and O’Reilly, Talbot & Okun
In the summer of 2010, civil and environmental engineering firm Fuss & O’Neill performed an Environmental Transaction Screen for the Town Of Shutesbury. A report dated December 29, 2010 (obtainable through the Shutesbury Town Clerk’s office), updated a July 24, 2010 Transaction Screen with “additional information provided…by the Town of Shutesbury.”
The purpose of the screen was to identify potential environmental conditions (PECs) affecting Lot O-32. A representative from Fuss & O’Neill walked the lot with the Town Administrator (TA), noting a debris pile and two empty drums behind the garage. The representative was denied access to the interior of the garage and was unable to make any judgments by merely peering through a window. Evidence of historical dumping was observed and the TA reported that 13 dumpsters filled with waste were removed from the site before the town purchased the property.
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| Unseen by Fuss & O'Neill, Inside the Garage: Open Floor Drain |
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| Cracked Cement Flooring |
The TA noted that two underground storage tanks were removed from the site in 2004: one held home heating oil for the former residence and the other stored gasoline and was located near the garage. Shutesbury’s Fire Chief provided information for the fuel oil UST removal, which showed no evidence of leakage. The firm noted that it did not review any documentation for the gasoline UST removal.
The report characterized the presence of dumping, i.e., the empty drums, as the only PEC and “recommended further evaluation”. The ongoing UST gasoline release cleanup activities (enter Release Tracking Number = 1-16996 in the search boxes ) at the nearby Fire Station were identified as an “environmental concern” for Lot O-32, based on the proximity of the two parcels.
The Fuss & O’Neill report made no reference to the TVOR military facility.
During the summer of 2010, the town also commissioned a study (page 123) by geotechnical engineering and environmental consultancy firm O’Reilly, Talbot & Okun (OTO). The purpose of the study was to identify geographical conditions that may impact the construction of a new library.
OTO reported encountering groundwater in three of four soil borings at depths of three, seven, and fifteen feet below the ground surface. Though this was not considered a major issue for the finished building, the firm recommended using water-control methods during construction.
One issue concerned the site's high silt and fine sand levels, which could contribute to building footing instability. They suggested excavating another six inches in depth and providing crushed stone on which to place the footings. Dewatering sumps during construction were also recommended.
2012: Cold Springs Environmental Consultants Weigh in
In 2012, Shutesbury hired Cold Springs Environmental Consultants (CSEC) for further assessment of the environmental conditions noted in the Fuss & O’Neill report on Lot O-32. The town had previously worked with CSEC during the Fire Station contamination issue.
During due diligence inspections carried out in December 2011 and January 2012 and described in a report dated April 26, 2012, CSEC noted several Recognized Environmental Conditions (RECs) on the site:
The locations of the removed heating oil and gasoline tanks;
An open floor drain with an unknown terminus exiting a wall in the garage building;
A debris pile behind the garage that included a 55-gallon drum containing debris and petroleum;
A pile of debris southwest of the garage;
Scattered debris such as abandoned vehicles along a dirt road extending south;
The site’s proximity to the Shutesbury Department of Public Works and Fire Department.
Again, there was no mention of the former military installation.
During the month of December, CSEC supervised the installation of four monitoring wells and obtained groundwater samples from each:
GP-1, placed near the former gas UST;
GP-2, near the debris pile behind the garage;
GP-3, near the floor drain line terminus; and
GP-4, at the site of the former fuel oil UST.
All four samples were tested for Volatile Organic Compounds (VOCs). Sample GP-1 was also tested for Volatile Petroleum Hydrocarbons (VPHs). Samples GP-2, GP-3, and GP-4 were also tested for Extractable Petroleum Hydrocarbons (EPHs). All results were below legally reportable concentrations.
Two soil samples, at depths of 12 to 14 inches, were obtained from a test pit at the garage floor drain terminus (FD-S-1 and FD-S-2). A surface soil sample from beneath the drum in the debris pile behind the garage was also collected (DR-1). No reportable levels for VOCs or EPHs were detected in any of the samples. However, based on the finding of PCBs in the petroleum remaining in the drum, Sample DR-1 was also tested for PCBs. Analysis showed 39.9 ppb PCBs; MA DEP reportable levels are 2,000 ppb.
The lab test finding of PCBs in Sample DR-1 prompted additional soil and groundwater testing on April 10, 2012.
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| Drum Located Behind Garage Building |
Three triangulated soil samples were taken from the area beneath the petroleum-containing drum:
DR-1
DR-2
DR-3
Another soil sample, FDT-1-20”, was taken near the garage floor drain terminus at a depth of 20 inches.
Levels of PCBs in all four soil samples were below the laboratory detection threshold of <22.6 to <27.9 ppb.
Monitoring wells GP-2 (near the drum) and GP-3 (near the floor drain terminus) were also retested. Because the test wells were located in an area of residential drinking water wells, a strict standard of no more than .50 ppb was applied. PCB levels in GP-2 were recorded as .544 ppb, above the Reportable Concentration. GP-3 levels were found to be .425 ppb, just under the reportable limit.
In accordance with 310 CMR 40, CSEC notified MA DEP within 72 hours of notifying the town of the results. A DEP official approved an Immediate Response Action which required sampling of private drinking water wells within 500 feet of the affected well site–including Lot O-32’s monitoring wells. The soil beneath the contaminated drum was to be tested at a depth of two to three feet.
Additional sampling was carried out under the Immediate Response Action Plan. According to a CSEC report dated May 30, 2012, new samples taken from all four test wells were tested for PCBs and found to be below “the laboratory detection limits of 0.206 to 0.233 parts per billion” and thus well below the reportable limit of .50 ppb. Laboratory filtered and unfiltered samples from each well were tested.
The company’s president attributed this outcome to the prior samples taken from GP-2 and GP-3 containing soil sediment, to which PCBs tend to adhere. In his opinion, this was the cause of the previous high readings, not because of the presence of PCBs in the groundwater. Apparently, town officials questioned this result, to which the contractor replied that “it happens with sediment sometimes.”
The soil from the area beneath the removed drum was retested as well. The new results were less than 30.90 ppb, the laboratory reporting limit, compared with the prior results of 39.90 ppb. The report stipulated that the soil bore sample was retrieved from a depth of 20 inches, rather than the two to three feet stated in the report of April 26. The reason given for this discrepancy was that “PCB levels in soil do not increase with depth based on the laboratory analytical data”.
The May 30 report advises the town that, based on the new data, the prior Release Notification to MA DEP may be retracted by filing the appropriate documents by June 24, 2012. The TA submitted the Release Notification & Notification Retraction Form on May 30, 2012.
In early June, test results from surrounding wells were delivered to the town. The most significant finding involved elevated salt levels in many drinking water wells–particularly the Shutesbury Department of Public Works (DPW).
Next, I’ll take a look at the most recent environmental issue found on Lot O-32 and how it may affect the taxpayers of Shutesbury.
