SCANNED 289 Great Road D Suite 105 Geosyntec c consultants PH 978-263-9588 FAX 978-263-9594 www.geosyntec.com JU 2 4 22 June 2009 I/f File No. TR0076 Ms. Rodene Lamkin Commonwealth of Massachusetts OFF/cc Department of Environmental Protection Northeast Regional Office 205B Lowell Street Wilmington, MA 01887 Subject: General Electric Company West Lynn Facility, 40 Federal Street, Lynn, MA Release Tracking Number: RTN 3-0361 Initial Response to Notice of Audit Findings (NOAF) Dated May 22, 2009 Dear Ms. Lamkin: On behalf of the General Electric Company (GE), Geosyntec Consultants, Inc. (Geosyntec) has prepared this initial response to a Notice of Audit Findings (NOAF) dated May 22, 2009 for the GE West Lynn Site located at 40 Federal Street in Lynn, Massachusetts (RTN 3-0361) (the "Site"). This initial response provides data on conditions at the Site that are contained in documents submitted previously to the Massachusetts Department of Environmental Protection (MassDEP) that were not referenced as documents reviewed and considered in the Audit that was recently conducted. Documents submitted to the MassDEP between 1995 and 2003 not referenced in the NOAF include over 40 documents listed in Table 1, including the Phase II Comprehensive Site Assessment Report for the GE West Lynn Facility (the "Phase II Report"; Beak, 1998b) which presents a compilation of the results of comprehensive soil, groundwater, soil gas and indoor air investigations at the Site and addresses the issues raised in the NOAF. We think it is very important to discuss this information and the actions specified in the NOAF with you before we prepare and submit a formal Audit Follow-Up Plan. This letter presents the specific items that the NOAF requests be addressed in the Audit Follow-Up Plan and describes existing data that addresses each of the items. The specific data referenced in the NOAF for items 1 and 2 as discussed below were identified by GE and GE's consultants at the time of their collection and additional data were collected to evaluate more fully potential exposure pathways. An extensive soil gas and groundwater investigation program was implemented between 1992 and 1997 to address potential exposure pathways and the results of these investigations are presented in the Phase II Report. In addition, an indoor air, soil gas and groundwater monitoring program was developed to confirm that no changes were occurring in conditions at the Site which could impact the potential exposure pathways. This monitoring program was established in the TR0076 NOAF Response Letter 2009-06-22.doc engineers I scientists I innovators
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SCANNED289 Great RoadD Suite 105Geosyntec c
consultants PH 978-263-9588FAX 978-263-9594
www.geosyntec.com
JU 2 4 22 June 2009
I/f File No. TR0076Ms. Rodene LamkinCommonwealth of Massachusetts OFF/ccDepartment of Environmental ProtectionNortheast Regional Office205B Lowell StreetWilmington, MA 01887
Subject: General Electric Company West Lynn Facility, 40 Federal Street, Lynn, MA ReleaseTracking Number: RTN 3-0361Initial Response to Notice of Audit Findings (NOAF) Dated May 22, 2009
Dear Ms. Lamkin:
On behalf of the General Electric Company (GE), Geosyntec Consultants, Inc. (Geosyntec) has preparedthis initial response to a Notice of Audit Findings (NOAF) dated May 22, 2009 for the GE West LynnSite located at 40 Federal Street in Lynn, Massachusetts (RTN 3-0361) (the "Site"). This initialresponse provides data on conditions at the Site that are contained in documents submitted previously tothe Massachusetts Department of Environmental Protection (MassDEP) that were not referenced asdocuments reviewed and considered in the Audit that was recently conducted. Documents submitted tothe MassDEP between 1995 and 2003 not referenced in the NOAF include over 40 documents listed inTable 1, including the Phase II Comprehensive Site Assessment Report for the GE West Lynn Facility(the "Phase II Report"; Beak, 1998b) which presents a compilation of the results of comprehensive soil,groundwater, soil gas and indoor air investigations at the Site and addresses the issues raised in theNOAF. We think it is very important to discuss this information and the actions specified in the NOAFwith you before we prepare and submit a formal Audit Follow-Up Plan.
This letter presents the specific items that the NOAF requests be addressed in the Audit Follow-Up Planand describes existing data that addresses each of the items.
The specific data referenced in the NOAF for items 1 and 2 as discussed below were identified by GEand GE's consultants at the time of their collection and additional data were collected to evaluate morefully potential exposure pathways. An extensive soil gas and groundwater investigation program wasimplemented between 1992 and 1997 to address potential exposure pathways and the results of theseinvestigations are presented in the Phase II Report. In addition, an indoor air, soil gas and groundwatermonitoring program was developed to confirm that no changes were occurring in conditions at the Sitewhich could impact the potential exposure pathways. This monitoring program was established in the
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mid-1990s and continues to this day. The results of this monitoring program are presented in semi-annual monitoring reports provided to the MassDEP. We believe that the overall Site data presented inthe Phase II Report provides an assessment of all probable exposure pathways and that the on-goingmonitoring of groundwater, soil gas and indoor air conducted on an annual or semi-annual basisprovides assurance that there are no changes in conditions at the Site that would impact possibleexposure pathways and that there is no direct evidence to indicate that there are likely to be CriticalExposure Pathways (CEPs) related to the Site.
As described in the Phase II Report, a site conceptual model was developed based on an evaluation ofall available site data. This model includes the following key components: 1) TCE was released to thesubsurface on the GE Facility (the portion of the Site owned by GE) and this TCE migrated down to andbelow the water table; 2) as groundwater moved off the Facility property, precipitation that infiltratedinto the soil and reached the water table overlaid groundwater containing TCE and a layer of cleangroundwater formed above the impacted groundwater; 3) the thickness of this "clean water lens"increased as the groundwater moved further from the Facility; 4) the clean water lens prevents migrationof TCE from the deeper groundwater into the soil gas; and 5) the exposure pathway from groundwater tosoil gas to indoor air is not complete in areas where the clean water lens is present. Data to support theexistence of the clean water lens at the Site is presented in the Phase II report. Figure 5.5 and 5.6 of thePhase II Report shows cross-sections and TCE concentration data from different depth intervalsconsistent with the clean water lens. A copy of Figure 5.5 from the Phase II Report along with otherrelevant figures from the Phase II Report previously submitted to MassDEP are included inAttachment A.
The concept of a clean water lens is supported by several sources including a paper written by NancyFitzpatrick and John Fitzgerald of the MassDEP in 2002 (Fitzpatrick, 2002) and the New JerseyDepartment of Environmental Protection Vapor Intrusion Guidance (NJDEP, 2005). A copy of theFitzpatrick paper and excerpts from the NJDEP Guidance are presented in Attachment B.
Specific issues that were identified in the NOAF for follow-up in an Audit Follow-up Plan are listed initalics below, and our discussion of existing data that addresses each of these issues is set forth belowfor your consideration.
NOAF Item ]a - TP-C30 located south of the GE West Lynn facility at the corner of South Street andSouth Common Street contained 630 u2/L TCE at a depth of 20' bcs in 1995.
NOAF Item lb - TP-C27 located south of the GE facility on Summer Street near the corner of SouthStreet contained 670 uZ/L TCE at 20' bzs in 1995.
NOAF Item Ic - TP-C26 located south of the GE facilitv on South Street contained 690 uZ/L TCE at 16'bzs in 1995
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NOAF Item Id - TP-C33 located on Neptune Street Ct. near the corner of South Street, south of the GEfacility contained 680 uz/L TCE at a depth of 15' bzs in 1995.
Response: The temporary groundwater probes referred to in the four items above are all located to thesouth of the Facility and the information regarding the significance of the data from these locations arediscussed below.
The objective of the temporary probe investigation program conducted in 1995 that included TP-C30,TP-C27, TP-C26 and TP-C33 was to characterize fully the lateral extent and ultimate fate of volatileorganic compounds (VOCs) in groundwater associated with the Site. With this objective in mind, theseprobes were installed below the water table and, therefore, do not reflect VOC concentrations that havethe potential to off gas into soil gas. The objective of the temporary probe investigation was not toevaluate the potential for vapor intrusion because an extensive soil gas survey had been conducted in1992 to evaluate the potential exposure pathways associated with VOCs off-gassing from shallowgroundwater to soil gas in this area.
The soil gas survey conducted in 1992 included the collection of soil gas samples in the vicinity oftemporary probes TP-C30, TP-C27, TP-C26 and TP-C33. The locations of the temporary probes areshown on Figure 1.11 from the Phase I Report. Samples from soil gas probes SG-72, SG-75, SG-95and SG-100 had low and/or non-detectable concentrations of TCE of <1 ppbv, 67 ppbv, <1 ppbv, and <1ppbv, respectively. These data are shown on Figure H-2a from the Phase II Report.
In addition to this soil gas data, groundwater data are available from a set of nested monitoring wells(BCL-204S, I and D) located in close proximity to the location of TP-C30. The location of this well isshown on Figure 6 from the most recent Semi-Annual Remedial Monitoring Report Quarters 3 and 4,2008 (the "Monitoring Report Q3 and Q4, 2008"; Geosyntec, 2009). Data from the different depthwells in this well nest are shown in Figure 11 and Table E-2 from Appendix E of the Monitoring ReportQ3 and Q4, 2008. A copy of Figure 6, 11 and Table E-2 from the Monitoring Report Q3 and Q4, 2008along with other relevant tables and figures from this report are included in Attachment C. The shallowwell at BCL-204S is screened between 8 and 13 feet below ground surface (ft bgs), which is shallowerthan the sampling depths of elevated concentrations at temporary probes TP-C30, TP-C27, TP-C26 andTP-C33 as shown in Figure 5.5 from the Phase II Report. The temporal data for BCL-204S shown inFigure 6 from the Monitoring Report Q3 and Q4, 2008 show that the concentrations of TCE declinedsignificantly in 1996 and 1997, presumably as a result of the operation of additional groundwaterextraction wells along the southern boundary of the West Lynn Facility which was initiated severalyears earlier. The concentration of TCE in the shallow groundwater at BCL-204S has remained belowthe current GW-2 standard of 30 pg/L since the fall of 1997.
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Indoor air monitoring was also conducted in 1992 in a daycare (Gregg House) located between TP-30and the Facility. The location of the Gregg House and the results of indoor air monitoring at thislocation are shown on Figure 5.9 of the Phase II Report. TCE was not detected in the indoor air samplecollected from Gregg House in 1992.
The soil gas data from 1992 showed a maximum concentration of TCE in soil gas in the vicinity of thelocation of TP-C30, TP-C27, TP-C26 and TP-C33 of 67 ppbv. Groundwater monitoring data fromBCL-204S show that the concentrations of TCE in shallow groundwater have decreased significantlysince the early 1990s and are below the current GW-2 standard. Based on these soil gas andgroundwater data, we believe that the existing data demonstrate that the vapor intrusion pathway is notcomplete in the vicinity of TP-C30, TP-C27, TP-C26 and TP-C33.
NOAF Item le - TP-D35 located on Woodman Street west of the GE facility contained the elevatedconcentration of 4400 ueIL TCE at 12' bzs in 1995.
Response: The 1995 groundwater sample from TP-D35 was collected from below the water table, andresults from this sample do not reflect VOC concentrations that have the potential to off gas into soil gasat this location. Additionally, an extensive soil gas survey was conducted in 1992 that included thecollection of soil gas samples in the vicinity of temporary probe TP-D35. The location of TP-D35 isshown on Figure 1.11 from the Phase II Report. Data from analysis of samples collected in 1992 fromsoil gas probes SG-35 located slightly north of TP-D35 and SG-33 located to the east of TP-D35 (closerto the Site) both showed concentrations of TCE in soil gas <1 ppbv. These data are shown on Figure H-2a from the Phase II Report. Additional soil gas data was collected in 1997 at a location (SGP-14)slightly to the south west of TP-D35 as shown on Figure H-2b from the Phase II Report and showed 48ppbv of TCE.
In addition to these soil gas data, groundwater data are available from shallow monitoring wells (BCL-201S and BCL202) located to the east and to the west of the location of TP-D35. The locations of thesewells are shown on Figure 6 from the most recent Monitoring Report Q3 and Q4, 2008. Unlike the TP-D35 sample that was collected below the water table, these wells (BCL-201S and BCL202) are screenedacross the water table between 4 and 9 ft bgs and 6 and 21 ft bgs respectively. These wells have beensampled on a regular basis since 1994 and data from analysis of these samples are shown in Figure 11and in Table E-2 from the Monitoring Report Q3 and Q4, 2008. The maximum concentration of TCEdetected in groundwater samples from BCL-201 S was 11 pg/L in 1994 and only trace concentrations(i.e., <5 pg/L) have been detected since that time. Only trace concentrations (i.e., <5 pg/L) have beendetected in samples from BCL-202.
The soil gas data from 1992 and 1997 showed a maximum concentration of TCE in soil gas in thevicinity of the location of TP-D35 of 48 ppbv. Groundwater monitoring data from BCL-201S and BCL-
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202, which has been collected on a regular basis since 1994, show that the concentrations of TCE inshallow groundwater are well below the current GW-2 standard of 30 gg/L. We believe that the existingdata demonstrate that the vapor intrusion pathway is not complete in the vicinity of TP-D35.
NOAF Item If - SG-2 7 located at the corner of Spencer and Woodman Streets revealed a hijzh level ofTCE at 3882 ppbv in soil vapor in 1992.
Response: Soil gas probe SG-27 was part of the extensive soil gas survey conducted in 1992. Thelocation of SG-27 and data from analysis of soil gas from this location can be seen on Figure H-2a andin Table H-10 in Appendix H from the Phase II Report. Indoor air monitoring was also conducted in1992 in the residence closest to SG-27 at #50 Spencer Street. The location of the residence at #50Spencer Street and the results of indoor air monitoring at this location can be seen on Figure 5.9 of thePhase II Report. The indoor air sample collected in 1992 from #50 Spencer Street showed a traceconcentration (0.66 ppbv) of TCE. This was reported as a trace or estimated concentration as it wasbelow the reporting limit for the analytical method used to conduct the analysis. Indoor air monitoringwas also conducted in the Italian American (ITAM) building located on the east side of Spencer Streetdirectly across from #50 Spencer Street on the same side of Spencer Street as the Facility. The locationof the ITAM building and data from indoor air monitoring in the ITAM building up to 1997 are shownon Figure 5.9 of the Phase 2 Report. The results of all indoor air monitoring in the ITAM building areshown in the attached Table 2. TCE was detected in the indoor air samples from the ITAM building in1994 at a concentration of 0.69 ppbv and 2.4 ppbv in the duplicate sample. TCE was also detected inthe ambient air sample in 1994 at a concentration of 0.23 ppbv. The concentrations of TCE were non-detect (i.e., <0.19 ppbv) in 1995, 1996, 1997, 1998 and 1999 and non-detect (<0.31 ppbv) in 2003,2004, 2005, 2007, and 2008. In 2006, TCE was detected in the indoor air at concentrations of 0.56 ppbvbut was also detected in the ambient air sample at a concentration of 0.47 ppbv. In 2009, TCE wasdetected in the indoor air at concentrations of 0.23 ppbv but was also detected in the ambient air sampleat a concentration of 0.18 ppbv.
Using the 1992 indoor air results from #50 Spencer Street and the ITAM building and the 1992 soil gasresults at SG-27, it is possible to calculate an empirical, site-specific attenuation factor for TCE vaporintrusion into these buildings by dividing the observed indoor air concentration by the detected soil gasconcentration. At #50 Spencer Street, the empirical attenuation factor would be the estimatedconcentration in the residence of 0.66 ppb divided by the measured concentration in the soil gas probeadjacent to the residence of 3,882 ppbv or 1.7 x 10-t Note that this empirical attenuation factor assumesthat 100% of the TCE detected in indoor air resulted from subsurface vapor intrusion; however, theindoor air results for PCE and 1,1,1-TCA indicate that interior or "background" sources of VOCs alsowere present in this building because these constituents were not detected in soil gas near the building.Accordingly, the actual soil gas to indoor air attenuation factor could be even lower. At the ITAMbuilding, TCE was not detected in indoor air in 1992, which is the time when soil gas data is also
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available near this building; however, we can estimate a conservative attenuation factor for the ITAM bydividing the TCE reporting limit for the indoor air sample (0.47 ppbv) by the soil gas concentration atSG-27. The resulting empirical attenuation factor for the ITAM building would be 1.2 x 104; becausethis empirical attenuation factor is based on a reporting limit and not a detected concentration itrepresents a conservative, upper-bound range of soil gas to indoor air attenuation at the ITAM building.
Following the soil gas survey conducted in 1992, additional soil gas points were installed in the vicinityof SG-27 including: SGP-1, SGP-3, SGP-5 and SGP-6 installed in between February and May 1994.The locations of these soil gas probes and data from analysis of soil gas samples from these locationsobtained between 1994 and 1997 can be seen on Figure H-2b and Table H-10 in Appendix H of thePhase II Report. Soil gas samples have been collected from SGP-1 and SGP-5 on a regular basis (atleast twice per year) since 1997. Data from the analysis of samples from these locations are shown inFigure 7 and Table F-2 from the Monitoring Report Q3 and Q4, 2008. Since 2002, concentrations ofTCE in soil gas samples from soil gas probes SGP-1 and SGP-5 have had a maximum concentration of620 ppbv and 660 ppbv, significantly less than the concentration measured in SG-27 in 1992 of 3,882ppbv.
In response to the presence of TCE in soil gas at the site, a soil vapor extraction (SVE) system wasinstalled at a location approximately 80 feet south of the corner of Spencer Street and Woodman Streetand operated in 1994, 1997 and in 2001. Figure 12 from the Monitoring Report Q3 and Q4, 2008 showsthe periods of time when the SVE system was operated and the impact of the operation of the SVEsystem on the concentration of volatile organic compounds (VOCs) in soil gas probes in the immediatevicinity of the SVE system. The data show significant reductions in VOC concentrations followingoperation of the SVE system in 1997 and 2001.
Ongoing monitoring of soil gas from soil gas probes in the vicinity of SG-27, including SGP-1 andSGP-5, shows significantly lower concentrations than were reported in 1992 at SG-27. Using the site-specific, empirical attenuation factors discussed above that were calculated based on 1992 soil gas andindoor air results, we can calculate potential vapor intrusion-related indoor air concentrations associatedwith recent TCE concentrations detected in soil gas at SGP-i and SGP-5 by multiplying the soil gasconcentrations by the empirical attenuation factors. Using the maximum TCE concentrations that havebeen detected at SGP-1 and SGP-5 since 2002 and the empirical attenuation factors, resulting vaporintrusion-related indoor air concentrations for TCE would range from 0.07 to 0.11 ppbv. To provide aneven more conservative estimate of potential indoor air concentrations, we considered the TCEattenuation factor that MassDEP used to calculate the MCP Method 1 GW-2 standard for TCE of 7.53 x104 (MassDEP, 2008). Using this "GW-2 attenuation factor", potential vapor intrusion-related indoorair concentrations associated with TCE detected at SGP-1 and SGP-5 would range from 0.47 to 0.50ppbv. Regardless of which attenuation factor is used (i.e., site-specific empirical or MassDEP GW-2),
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potential indoor air concentrations associated with recent soil gas concentrations in the vicinity of SG-27 are well below the risk-based concentration of 2.6 ppbv for TCE presented in MassDEP's Draft 2008Indoor Air Threshold Values document. Based on the available data discussed above, recentconcentrations of TCE detected in soil gas samples in the vicinity of SG-27 are not believed to result insignificant vapor intrusion into buildings in the area. Accordingly, additional assessment ofgroundwater, soil vapor, and potentially indoor air in this area is not warranted.
NOAF Item 2 - Room B-101 of the Drewicz School was found to contain .41 ovbv TCE in indoor air in1992. This value now exceeds the MassDEP draft threshold value of.15 vpbv which is indicative of aCEP that must be evaluated. A determination of whether recent indoor air data exists for the DrewiczSchool; and if not, indoor air monitoring is recommended to determine whether a CEP exists.
Response: Figure 5.9 from the Phase II Report presents the highest concentrations of TCE,tetrachloroethene (PCE) and 1,1,1 -trichloroethane (1,1,1 -TCA) from analysis of indoor air samples fromany of the rooms of Drewicz School where indoor air samples were collected in 1992, 1994, 1995, 1996and 1997. Table K-I and K-2 of Appendix K from the Phase II Report present the results from analysisof ambient air and indoor air samples from the eight locations sampled within the Drewicz School in1992 (rooms 107, 101, B101, H-2, H-4, the boiler room, the cafeteria, and crawl space) and the resultsof monitoring in the boiler room and cafeteria in 1994, 1995, 1996 and 1997. Additional data frommonitoring in the Drewicz School in 1998, 1999, 2000, 2001 and 2002 are presented in the 1998, 1999,2000, and 2001 Annual Indoor Air Quality Monitoring in the West Lynn Community prepared byEnvironmental Health & Engineering, Inc. and in the Monitoring Report QI and Q2, 2002 prepared byGeosyntec. The results of analysis of all the indoor air sampling conducted in the Drewicz School areshown in the attached Table 3. TCE was detected at trace concentrations in the samples collected fromrooms 107 and 101 on the first floor and H-4, B-101 and the boiler room in the basement in 1992 butwas not detected in any of the subsequent samples from the Drewicz School in 1994, 1995, and 1996 atdetection limits of 0.71, 0.38, and 0.19 ppbv respectively. Three samples were collected in the cafeteriain 1997, two were non-detect at less than 0.19 ppbv and one reported a trace concentration of 0.15 ppbv.Two samples were collected in the boiler room in 1997 and both were non-detect for TCE at less than0.19 ppbv. TCE was not detected in indoor air samples from the school in 1998, 1999, 2001 ahd 2002.In 2000, TCE was detected in the school cafeteria at a concentration of 0.35 ppbv but it was alsodetected in the ambient air sample at a concentration of 0.22 ppbv, therefore the detection of TCE in theschool is attributable to background sources.
Soil gas data from the vicinity of the Drewicz School has been collected during several phases of theinvestigation program. Soil gas samples were obtained from seven locations on the public streetsaround the Drewicz School in 1992. The soil gas sampling locations (SG-51, SG-52, SG-53, SG-54,SG-66, SG-60, and SG-62) and the results of analysis are presented in Figure H-2a of the Phase IIReport. The concentrations of TCE reported in samples from all of these locations were <1 ppbv with
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the exception of SG-62, located at the intersection of Western Avenue and Holland Street, whichreported a concentration of 43 ppbv. Soil gas samples were also collected in 1997 from SGP-15 locatedat the corner of Hood and Holland Streets. The location of SGP-15 and the results of analysis arepresented in Figure H-2b of the Phase II Report. The concentrations of TCE in two soil gas samplescollected from SGP-15 in 1997 were 2.3 and 3.9 ppbv.
Page 6 of the NOAF states that "indoor air monitoring conducted in 1995 reported 1.5 ppbv in the boilerroom". The 1.5 ppbv detected in the boiler room in 1995 was PCE and not TCE and the presence ofPCE in the boiler room is attributable to sources other than migration from soil vapor as discussed in areport submitted to MassDEP in January 1998 titled Preliminary Evaluation of Potential Sources ofTetrachloroethene in Indoor Air at the Drewicz School (BEAK, 1998a)
TCE was detected at a trace level (0.41 ppbv) in the Drewicz School in 1992 but TCE has not beendetected at concentrations above the reporting limit for the analytical method used to conduct theanalysis in samples of indoor air from the School other than in 2000 when it was also detected inambient air. The soil gas data from 1992 and 1997 showed a maximum concentration between theFacility and the Drewicz School (SG-66 sampled in 1992 and SGP-15 sampled in 1997) of 3.9 ppbv ofTCE. We believe that the existing data demonstrate that the vapor intrusion pathway is not complete inthe vicinity of the Drewicz School and a Critical Exposure Pathway does not exist at the School.
NOAF Item 3 - The 1992 indoor air data for two residences indicates that a CEP may be present. In1992, 1.2 ppbv TCE was detected in #88 Spencer Street and .99 ppbv TCE was found at #58 WaterhillStreet. Since 2003, lower levels of TCE (between .24 and .53 ppbv) have been detected in the tworesidences. A comparison to the ambient air monitoring results indicates that the data is sometimesconsistent with ambient levels and can be attributed to ambient conditions. TCE levels are consistentyabove the MassDEP draft threshold value of. 15 pybv TCE and it is not clear whether a CEP now existsin the two residences. If a CEP is present, the feasibility of installinz a mitigation system must beevaluated.
Response: Results of indoor air monitoring at #88 Spencer Street and #58 Waterhill Street obtainedbetween 2002 and 2008 are presented in previous Semi-Annual Monitoring Reports and are compiled inthe attached Table 4 and Figure 1. Recent sampling conducted in March 2009 not previously submittedto the MassDEP are also presented in Table 4 and shown in Figure 1. TCE was not detected in indoorair from either residence or the ambient air sample in 2002, 2003, 2004 or 2007. Figure 1 shows thedetection limits for analysis of TCE in the air samples as open symbols on the chart. As shown inFigure 1, TCE was detected in both residences in 2005 but at concentrations below that reported in theambient air sample collected at the same time. In 2006, TCE was detected in a sample of indoor airfrom #58 Waterhill Street at 0.53 ppbv but a similar concentration (0.47 ppbv) was detected in theambient air sample collected at the same time. It is reasonable to conclude that the TCE detected in
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samples from the residences in 2005 and 2006 are due to an outside source. In 2008, TCE was detectedin a sample of indoor air from #88 Spencer Street at a concentration of 0.24 ppbv. In 2009, TCE wasdetected in the ambient air sample (0.18 ppbv) but was not detected in either residence. Theconcentration of TCE detected at #88 Spencer Street in 2008 is consistent with concentrations detectedin ambient air in 2005, 2006 and 2009 and not considered attributable to chemicals at the Site. Webelieve that the existing data indicate that a Critical Exposure Pathway does not exists in either of theresidential buildings where monitoring has been conducted in the vicinity of the Site. Indoor airmonitoring has been and continues to be conducted to evaluate if there is a CEP for these residences. Itshould also be noted that the residences at #58 Waterhill Street and #88 Spencer Street were selected forongoing monitoring after 1992 because they were the locations with the highest detected concentrationsof TCE detected in indoor air in the survey conducted in 1992; however, as discussed above, other linesof evidence available for these buildings indicate that the presence of TCE in indoor air samples fromthese residences is not associated with subsurface vapor intrusion.
We think it is very important to discuss this information and the actions specified in the NOAF with youbefore we prepare and submit a formal Audit Follow-Up Plan. We would appreciate the opportunity tomeet with you to discuss information regarding the Site and appropriate follow-up actions. If you haveany questions or would like additional information, please do not hesitate to call Doug Larson at978-206-5774.
Sincerely,
GEOSYNTEC CONSULTANTS, INC
Dou . rson, Ph.D., P.E., LSPPrincipal
Thomas A. Krug, M.Sc. P. Eng.Associate
Copies to: Mr. John Uruskyj, General Electric CompanyLynn Board of Health, moconnoribci.lynn.ma.us
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REFERENCES
Beak Consultants Limited (BEAK). 1998a. Preliminary Evaluation of Potential Sources ofTetrachloroethene in Indoor Air at the Drewicz School. January 1998.
Beak Consultants Limited (BEAK). 1998b. Phase II Comprehensive Site Assessment Report for theGE West Lynn Facility. Lynn, MA. February 1998.
Commonwealth of Massachusetts Executive Office of Energy & Environmental Affairs Department ofEnvironmental Protection (MassDEP). 2009. Notice of Audit Findings. Letter to Mr. John Uruskyj ofGeneral Electric Company. 22 May 2009.
Commonwealth of Massachusetts Department of Environmental Protection (MassDEP). 2008b.Massachusetts Contingency Plan (MCP) Numerical Standards Development Spreadsheets -Development of MCP Risk-Based Levels for Soil and Groundwater; MCP GW2 alpha.xls. February2008. http://www.mass.gov/dep/service/compliance/riskasmt.htm
Fitzpatrick, N.A. and Fitzgerald J.J.. 2002. An Evaluation of Vapor Intrusion Into Building through aStudy of Field Data. Soil and Sediment Contamination. 11(4): 603-623.
Geosyntec Consultants (Geosyntec). 2009. Semi-Annual Remedial Monitoring Report - Quarter 3 and4, 2008, West Lynn Site. January 2009
New Jersey Department of Environmental Protection (NJDEP). 2005. Vapor Intrusion Guidance.October 2005.
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TABLES
Geosyntec Consultants
Table 1: Documents Submitted to MassDEP Between 1995 and 2003 Not Referenced in theMay 22, 2009 Notice of Audit Findings
Document Title Date AuthorQuarterly Remedial Monitoring Report CalendarQuarter December 1994 to February 1995 GE West Feb-95 BEAK ConsultantsLynn FacilityResults of Supplemental Phase II Sampling Activities Jul-95 BEAK Consultantsfor the GE West Lynn FacilityCombined Quarterly Remedial Monitoring Report:Groundwater and Soil Gas Monitoring CalendarQuarter June to August 1995/Groundwater Treatment Aug-95 BEAK ConsultantsSystem Product Only Recovery System MonthlyMonitoring Calendar Quarter May to July 1995,Summer Quarter 1995Installation of Supplemental Monitoring Wells, Oct-95 BEAK ConsultantsPiezometers at the GE West Lynn FacilityResults of a Soil Boring Program at the GE West Oct-95 BEAK ConsultantsLynn FacilityInstallation of Monitoring Wells, Piezometers andSoil Gas Probes in the Area Adjacent to the GE West Oct-95 BEAK ConsultantsLynn Facility
Combined Quarterly Remedial Monitoring Report, Feb-97 BEAK ConsultantsWinter Quarter 1997Results of Shallow Soil Sampling in the Plant IIIArea at the GE West Lynn Facility, Lynn, MA Apr-97 BEAK Consultants
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Document Title Date AuthorResults of a Soil Gas Survey Conducted at the GE Apr-97 BEAK ConsultantsWest Lynn Facility, Lynn, MA
1997 Annual Indoor Air Quality Monitoring In the Nov-97 Environmental HealthWest Lynn Community and EngineeringAdditional Phase II Comprehensive Site Assessment Dec-97 BEAK ConsultantsActivities for the GE West Lynn SitePreliminary Evaluation of Potential Sources ofTetrachloroethene in Indoor Air at the Drewicz Jan-98 BEAK ConsultantsSchoolPhase II Comprehensive Site Assessment Report for Feb-98 BEAK Consultantsthe GE West Lynn Facility, Lynn, MA1998 Annual Indoor Air Quality Monitoring In The Sep-98 Environmental HealthWest Lynn Community and Engineering
2000 Annual Indoor Air Quality Monitoring in the rn-00 Environmental HealthLynn Community MADEP Case No. 3-0361 01-Jun-00 and EngineeringCombined Semi-Annual Remedial MonitoringReport, Quarter 1 and Quarter 2, 2000, West Lynn 27-Jul-00 GeoSyntec ConsultantsFacilityLetter to DEP - Re: Case 3-0361 Risk AssessmentAddendum to the Phase II Comprehensive Site 29-Aug-00 GeoSyntec ConsultantsAssessment ReportLetter to DEP - Re: Case 3-0361, West Lynn Facility,40 Federal Street, Lynn, MA. Results of 30-Aug-00 GeoSyntec ConsultantsSupplemental Soil Sampling I
Page 2 of 3TR0076/NOAF Response Table I Documents.doex.
2009.06.18
Geosyntec Consultants
Page 3 of 3TR0076/NOAF Response Table I Documents.docx
Document Title Date Author
Activity and Use Limitation (AUL) for the West 01-Sep-00 GeoSyntec ConsultantsLynn Facility
Remedial Action Plan for the West Lynn Site, Lynn, 06-Sep-00 GeoSyntec ConsultantsMA
Response Action Outcome (RAO) Statement for the 08-Sep-00 GeoSyntec ConsultantsGeneral Electric West Lynn Site
Combined Semi-Annual Remedial MonitoringReport, Quarter 3 and Quarter 4, 2000, West Lynn 29-Jan-01 GeoSyntec ConsultantsSite
2001 Annual Indoor Air Quality Monitoring In The 07-May-01 Environmental HealthLynn Community MADEP Case No. 3-0361 and Engineering
Combined Semi-Annual Remedial MonitoringReport Quarter 1 and Quarter 2, 2001 West Lynn Site 31-Jul-01 GeoSyntec Consultants(40 Federal Street)Combined Semi-Annual Remedial MonitoringReport Quarter 3 and Quarter 4, 2001 West Lynn Site 31-Jan-02 GeoSyntec Consultants(40 Federal Street)Combined Semi-Annual Remedial MonitoringReport Quarter 1 and Quarter 2, 2002 West Lynn Site 31-Jul-02 GeoSyntec Consultants(40 Federal Street)Combined Semi-Annual Remedial MonitoringReport Quarter 3 and Quarter 4, 2002 West Lynn Site 31-Jan-03 GeoSyntec Consultants(40 Federal Street)
2009.06.18
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TABLE K2: VOCs IN ON- AND OFF-SITE AMBIENT AIR SAMPLESGE West Lynn Facility, Lynn, MA (4 of 4)
Notes:
All concentrations are in units of parts per billion (ppb) by volume.<2.0 - compound was not detected. The associated value is the detection or quantitation limitUt - trace- Indicates concentration slightly below limit of detectionJ - estimated valueU - analyte was not detected; the associated value is the detection limitBlank spaces indicate that the associated compounds were not analyzed for.
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