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Commonwealth of Massachusetts Department of Environmental Protection Northeast Regional Office Immediate Response Action Status Report #3 12 Cedar Road, 14 Cedar Road, and 14 Barnes Road Salem, Massachusetts RTN 3-38273 December 3, 2024 ---PAGE BREAK--- Marlborough Technology Park 100 Nickerson Road, Marlborough, MA 01752 Tel [PHONE REDACTED] Fax [PHONE REDACTED] tetratech.com December 3, 2024 Mr. Erik Johnson Commonwealth of Massachusetts Department of Environmental Protection Bureau of Waste Site Cleanup Northeast Regional Office 150 Presidential Way Woburn, MA 01801 Re: Immediate Response Action Status Report #3 12 Cedar Road, 14 Cedar Road, and 14 Barnes Road Salem, Massachusetts Release Tracking Number 3-38273 Dear Mr. Johnson: On behalf of our client, Prolerized New England Company, LLC (PNE), Tetra Tech, Inc. (Tetra Tech) is submitting this Immediate Response Action (IRA) Status Report #3 for the referenced parcels (the Site) identified by Release Tracking Number (RTN) 3-38273. The IRA Status Report is being submitted to document actions implemented for the referenced RTN since submission of IRA Status Report #2 on June 5, 2024. The release conditions which require implementation of an IRA is the presence of biphenyls (PCBs) and total chromium, at concentrations greater than 10 milligrams per kilogram (mg/kg) and 200 mg/kg, respectively, at a location within 500 feet of a residential property. This report was prepared in accordance with the requirements of the MCP for an IRA Status Report (310 CMR 40.0425) and is subject to the Licensed Site Professional (LSP) Statement of Limitations and Conditions in Appendix A. This report and the transmittal form BWSC-105 are being submitted electronically to MassDEP via eDEP. Please contact the undersigned if you have any questions regarding this report. Very truly yours, Raymond C. Johnson, P.G., L.S.P. Senior Vice President P:\165728\143-165728-23002\DOCS\REPORTS\INGEMI IRA SR\IRA SR #3\IRA SR#3_DECEMBER 2024.DOCX ---PAGE BREAK--- i TABLE OF CONTENTS 1.0 INTRODUCTION 1 2.0 STATUS OF IRA ACTIVITIES 1 2.1 Imminent Hazard Evaluation 2 2.2 Posting of Signage 2 2.3 Site Inspections 2 2.4 Upcoming Activities 2 3.0 SIGNIFICANT NEW SITE INFORMATION 2 4.0 MANAGEMENT OF REMEDIATION 2 5.0 CONCLUSION AND LSP OPINION 3 LIST OF FIGURES Figure 1 Locus Map LIST OF APPENDICES Appendix A LSP Statement of Limitations and Conditions ---PAGE BREAK--- Immediate Response Action Status Report #3 12 Cedar Road, 14 Cedar Road, and 14 Barnes Road Salem, Massachusetts Release Tracking Number 3-38273 1 1.0 INTRODUCTION This Immediate Response Action (IRA) Status Report #3 has been prepared by Tetra Tech, Inc. (Tetra Tech) on behalf of our client, Prolerized New England Company, LLC (PNE) in accordance with the requirements of the Massachusetts Contingency Plan (MCP) (310 CMR 40.0425). The IRA Status Report is being submitted for the property comprised of 12 Cedar Road, 14 Cedar Road, and 14 Barnes Road, in Salem, Massachusetts (the Site), identified by Release Tracking Number (RTN) 3-38273, to document activities conducted between June 1 and November 30, 2024. These properties are part of a larger MCP disposal site associated with RTN 3-38210, which includes portions of the properties at 9, Cedar Road, 15 Cedar Road, 16 Cedar Road, and 16 Barnes Road. This report documents IRA activities conducted since submission of IRA Status Report #3 on June 5, 2024. The location of the Site is shown on Figure 1. RTN 3-38273 was assigned based on verbal notification made on August 7, 2023 to MassDEP of a MCP “2-Hour” notification condition; specifically, the presence of biphenyls (PCBs) and total chromium, at concentrations greater than 10 milligrams per kilogram (mg/kg) and 200 mg/kg, respectively, at a location within 500 feet of a residential property. The verbal notification was made by Blackstone Environmental Solutions, LLC (BES) on behalf of JL Realty Trust, John M. Ingemi Realty Trust, and Barnes Road Trust (the Trustees). The Trustees own the properties discussed herein and have been identified by the Massachusetts Department of Environmental Protection (MassDEP), as Responsible Parties (RPs) for the MCP disposal site. Detailed information regarding the conditions at the Site, implementation and results of previous testing, and the release condition which resulted in the need to conduct an IRA were included in the IRA Plan submitted on October 6, 2023. IRA Status Reports #1 and #2 were submitted on December 5, 2023 and June 5, 2024, respectively. The IRA Plan and IRA Status Reports #1 and #2 were submitted by BES on behalf of the RPs/Trustees. This IRA Status Report describes actions implemented to date, and future activities anticipated to be performed, in relation to the release condition, and is subject to the Licensed Site Professional (LSP) Statement of Limitations and Conditions in Appendix A. 2.0 STATUS OF IRA ACTIVITIES Based on requirements issued by MassDEP when verbal notification of the release condition was made on August 7, 2023, and the requirements of the MCP, the IRA Plan submitted on October 6, 2023 included a description of the conditions at the disposal site, a discussion of the results of testing conducted by others and by BES, and the results an Imminent Hazard Evaluation (IHE). The IHE concluded that an Imminent Hazard (IH) condition did not exist at the disposal site for the conditions evaluated. On May 16, 2024, BES on behalf of the Trusts posted water signs stating, “Keep Out – Asbestos Contaminated Area” at eleven locations around the perimeter of 12 Cedar Road, 14 Cedar Road, 14 Barnes Road, and 16 Barnes Road, along with two “No Trespassing” signs at the street frontage along the southern boundary for 16 Barnes Road. ---PAGE BREAK--- Immediate Response Action Status Report #3 12 Cedar Road, 14 Cedar Road, and 14 Barnes Road Salem, Massachusetts Release Tracking Number 3-38273 2 The IRA activities conducted to date for the disposal site, and activities anticipated to be conducted, are summarized in the following sections. 2.1 IMMINENT HAZARD EVALUATION As discussed above, based on an IHE prepared for BES by O’Reilly, Talbot & Okun (OTO), it was concluded that an IH condition did not exist at the disposal site for the conditions evaluated. The IHE was submitted concurrently with the IRA Plan, and evaluated exposures to hypothetical trespassers. The conclusions of the IHE will continue to be evaluated as additional data is developed for the disposal site. 2.2 POSTING OF SIGNAGE On May 16, 2024, warning signs were posted as discussed above. The signage will be inspected quarterly and replaced if they are damaged or destroyed. 2.3 SITE INSPECTIONS Site inspections were conducted by Tetra Tech on behalf of PNE on August 1 and October 25, 2024 by viewing the subject parcels from adjacent public roadways to evaluate whether the warning signs were still in place. Multiple warning signs were observed on those dates, and no evidence of tampering with the signs was observed. Tetra Tech personnel also observed the properties from public roadways to look for evidence of high frequency or high intensity uses by unauthorized personnel. No evidence of such uses were observed on the dates noted above. 2.4 UPCOMING ACTIVITIES IRA activities anticipated to be implemented during the next six months include quarterly inspections of signage and to evaluate the disposal site for evidence of high frequency or high intensity uses by unauthorized persons. Supplemental soil sampling to further characterize conditions on the property will be implemented in the future, as part of MCP Phase II investigations. If data developed during the supplemental sampling is materially different from the results of the surficial sampling conducted to date, an evaluation will be made of whether the IHE needs to be updated or revised. 3.0 SIGNIFICANT NEW SITE INFORMATION No significant new Site information has been developed or provided to Tetra Tech since submission of the IRA Plan. 4.0 MANAGEMENT OF REMEDIATION WASTE No remediation waste has been generated during the period of this IRA Status Report. ---PAGE BREAK--- Immediate Response Action Status Report #3 12 Cedar Road, 14 Cedar Road, and 14 Barnes Road Salem, Massachusetts Release Tracking Number 3-38273 3 5.0 CONCLUSION AND LSP OPINION IRA activities for conditions related to RTN 3-38273 have been implemented for the period from June 1 to November 30, 2024. Conditions at the disposal site are currently stable and future activities will be conducted in accordance with the IRA Plan and the MCP. Additional sampling is planned as part of the MCP Phase II assessment of the Site, and the IHE will be revised if the results of that testing indicate conditions materially different from those characterized to date. ---PAGE BREAK--- N 0' 2000' Designed By: Project No.: Date: www.tetratech.com 6/24/2024 12:36:03 PM - P:\165728\143-165728-23002\CAD\SHEETFILES\ADDITIONAL LOT FIGURES_6.24.24\N-ZZ FIG 1 SITE LOCUS MAP.DWG - RANIERI, ALEX Bar Measures 1 inch Copyright: Tetra Tech Information obtained from USGS Map of Quadrangle dated 100 Nickerson Road Marlborough, Massachusetts 01752 Phone: (508) 786-2200 Fax: (508) 786-2201 Salem, Massachusetts 2021 Schnitzer Steel Industries Site Locus Map 143-25185-22005 June 24, 2024 AMR Figure 1 SITE 500 FEET 0.5 MILE Salem, Massachusetts 9,12,14,15 and 16 Cedar Road and 12 and 14 Barnes Road ---PAGE BREAK--- Appendix A LSP Statement of Limitations and Conditions ---PAGE BREAK--- 1 Statement of Limitations and Conditions Attachment to Opinion of Massachusetts Licensed Site Professional Tetra Tech, Inc. Name of Licensed Site Professional: Raymond C. Johnson LSP Registration Number: 6118 Date of Opinion: December 4, 2024 Client to Whom Opinion was Rendered: Prolerized New England Company, LLC Release Tracking Numbers: 3-38273 This Statement of Limitations and Conditions is an integral part of, and is incorporated by reference into, the Opinion of Massachusetts Licensed Site Professional referenced above. Limitations 1. Purpose of Opinion A. This Opinion is being provided in compliance with the requirements set forth in the Massachusetts Contingency Plan 310 CMR 40.0000 et seq. Specifically, the LSP has prepared this Opinion at the request of the Client identified above as part of an Immediate Response Action Status Report. This stated purpose has been a significant factor in determining the scope and level of services required to render this Opinion. B. Should the purpose for which this Opinion is to be used change, this Opinion shall no longer be valid. 2. General A. This Opinion was prepared for the sole and exclusive use of the Client, subject to the provisions of the MCP. No other party is entitled to rely in any way on the conclusions, observations, specifications, or data contained herein without the express written consent of Tetra Tech, Inc. and the LSP who rendered this opinion. Any use of this Opinion by anyone other than Client, or any use of this Opinion by Client or others for any purpose other than the stated purpose set forth above, without the LSP's review and the written authorization of Tetra Tech, Inc. and the LSP, shall be at the user's sole risk, and neither Tetra Tech, Inc. nor the LSP shall have any liability or responsibility therefore. B. This Opinion was prepared pursuant to an Agreement between Tetra Tech, Inc. and the Client referenced above which defines the scope of work and sets out agreements regarding waivers of consequential damages, limitations on liability, and other important conditions and restrictions pursuant to which the Opinion is rendered. All uses of the Opinion are subject to and deemed acceptance of the conditions and restrictions contained in such Agreement. A copy of the Agreement or relevant excerpts from the Agreement will be made available upon requests to any authorized person seeking to use the Opinion. 3. Scope of Services The observations and conclusions described in this Opinion are based solely on the Services provided pursuant to the Agreement with the Client and any approved additional services authorized by Client. Without limitation of any other applicable limitations or conditions, neither Tetra Tech, Inc. nor the LSP shall be liable ---PAGE BREAK--- 2 for the existence of any condition, the discovery of which would have required the performance of services not authorized under the Agreement. To the best of the knowledge and belief of Tetra Tech, Inc. and the LSP who signed this Opinion, no inquiry of an attorney-at-law having been made, no laws, regulations, orders, permits or approvals are applicable to the response actions to which this opinion relates except, if and to the extent applicable, M.G.L. c. 21A, Sections 19-19J, 309 CMR, M.G.L. c. 21 E and 310 CMR 40.0000. Accordingly, this opinion is not intended to and does not address compliance with any other laws, regulation, orders, permits or approvals. 4. Changed Circumstances The passage of time may result in changes in technology, economic conditions or regulatory standards, manifestations of latent conditions, or the occurrence of future events which would render this Opinion inaccurate or otherwise inapplicable. Neither Tetra Tech, Inc. nor the LSP shall be liable or responsible for the consequences of any such changed circumstances or conditions on the accuracy of this Opinion. 5. Additional Compensation Should Tetra Tech, Inc. or the LSP be required or requested to review or authorize others to use this Opinion after its date of submission, Tetra Tech, Inc. shall be entitled to additional compensation at then existing rates or such other terms as may be agreed upon between Tetra Tech, Inc. and the Client. Nothing herein contained shall be deemed to require Tetra Tech, Inc. or the LSP to undertake any such review or authorize others to use this Opinion. 6. Conclusions The conclusions stated in this Opinion are based upon: • Visual inspection of existing physical conditions; • Review and interpretation of site history and site usage information which was made available or obtained within the scope of work authorized by the Client; • Information provided by the Client; • Information and/or analyses for designated substances or parameters provided by an independent testing service or laboratory on a limited number of samples; and • A limited number of subsurface explorations made on dates indicated in documentation supporting this Opinion; upon which the LSP has relied and presumed accurate, and upon which the LSP is entitled to reasonably rely. The LSP was not authorized and did not attempt to independently verify the accuracy or completeness of information or materials received from the Client and/or from laboratories and other third parties during the performance of its services. Neither Tetra Tech, Inc. nor the LSP shall be liable for any condition, information, or conclusion, the discovery of which required information not available to the LSP or for independent investigation of information provided to the LSP by the Client and/or independent third parties. 7. This Opinion is rendered for the limited purpose stated above, and is not and should not be deemed to be an opinion concerning the compliance of any past or present owner or operator of the site with any federal, state or local law or regulation. No warranty or guarantee, whether express or implied, is made by this opinion, and any implied warranties of merchantability or fitness for a particular purpose are expressly disclaimed. Without limiting the generality of the foregoing, no warranty or guarantee is made that all contamination at a site or sources or contamination has been detected or identified, that any action or - recommended action will achieve all of its objectives, or that this Opinion or any action as to which this Opinion relates will be upheld by any audit conducted by the DEP or any other party. LSP_Limitations.doc ---PAGE BREAK--- Tetra Tech Marlborough Technology Park 100 Nickerson Road Marlborough, MA 01752 tetratech.com