General Chemical Draft Plan

Charles D. Baker Kathleen A.
Theoharides
Governor Secretary
Karyn E. Polito Martin Suuberg

Lieutenant Governor Commissioner
Draft Immediate Response Action Plan
Tank Farm/Loading Rack Area Remediation
Former General Chemical Corporation Site

133-135 Leland Street
Framingham, Massachusetts
RTN 3-0019174
Prepared by:
Massachusetts Department of Environmental Protection
Bureau of Waste Site Cleanup
Northeast Regional Office
205B Lowell Street
Wilmington, Massachusetts 01887
January 2020
This information is available in alternate format. Contact Michelle Waters-Ekanem, Director of Diversity/Civil Rights at 617-292-5751.
TTY# MassRelay Service 1-800-439-2370
MassDEP Website: www.mass.gov/dep
Printed on Recycled Paper
General Chemical Corporation Site IRA Plan
RTN 3-0019174
January 2020
Table of Contents
1.0 INTRODUCTION .............................................................................................................................. 1
2.0 BACKGROUND................................................................................................................................. 1
2.1 HISTORICAL SITE OPERATIONS ........................................................................................................ 2
2.2 SIGNIFICANT NEW INFORMATION .................................................................................................... 2
3.0 IMMEDIATE RESPONSE ACTION PLAN (310 CMR 40.0424) ................................................ 3
3.1 PERSON ASSUMING RESPONSIBILITY FOR CONDUCTING THE IRA .................................................. 3
3.2 DESCRIPTION OF RELEASE, SITE CONDITIONS, AND SURROUNDING RECEPTORS ........................... 4
3.2.1 Release Description and Associated Notifications.................................................................. 4
3.2.2 Site Conditions ........................................................................................................................ 5
3.2.3 Potenial Receptors .................................................................................................................. 5
3.2.4 Completed Investigations ........................................................................................................ 7
3.3 DESCRIPTION OF ANY IMMEDIATE RESPONSE ACTIONS UNDERTAKEN TO DATE AT THE SITE ...... 7
3.3.1 January 1995 PCE Release ..................................................................................................... 7
3.3.2 January 2000 CEP .................................................................................................................. 8
3.4 THE REASON WHY AN IMMEDIATE RESPONSE ACTION IS REQUIRED ............................................. 8
3.5 OBJECTIVES, SPECIFIC PLANS, AND PROPOSED SCHEDULE FOR IMMEDIATE RESPONSE ACTION ... 9
3.5.1 Objectives ................................................................................................................................ 9
3.5.2 Specific Plans .......................................................................................................................... 9
3.5.3 Proposed Schedule ................................................................................................................ 14
3.6 REMEDIATION WASTE STATEMENT ............................................................................................... 14
3.7 PROPOSED ENVIRONMENTAL MONITORING .................................................................................. 14
3.8 LISTING OF FEDERAL, STATE, OR LOCAL PERMITS REQUIRED TO CONDUCT IRA ........................ 16
4.0 PUBLIC INVOLVEMENT ............................................................................................................. 16
5.0 REFERENCES ................................................................................................................................. 17
FIGURES
1. Site Location Map
2. Aerial Map
3. GCC Facility Map
4. ERH Electrode Site Plan
5. ERH Electrode Cross Sections
6. ERH Temperature Monitoring Point Cross Section
7. ERH Vacuum Monitoring Point Cross Section
8. ERH Hydraulic Management Well Cross Section
9. ERH Process Flow Diagram
10. Photographs of Mobile Lab
APPENDIX - TRS Group, Inc. – In Situ Thermal Remediation Services Proposal – May 9,
2019
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General Chemical Corporation Site IRA Plan
RTN 3-0019174
January 2020
1.0 Introduction
The Massachusetts Department of Environmental Protection (MassDEP) has prepared this Draft
Immediate Response Action (IRA) Plan for the General Chemical facility, located at 133-135 Leland
Street in Framingham. The purpose of this plan is to provide details of a proposed project to
remediate portions of the facility – the former tank farm and loading rack areas - that have been
heavily contaminated by historic spills of chemical solvents. A key element of this project is the
installation and operation of an Electrical Resistance Heating (ERH) system to boil the groundwater
and vaporize the chemical solvents in these areas. The vaporized chemicals will then be vacuumed
from the ground and trapped in an activated carbon filter.
The specific areas that will be treated were selected because they contain high levels of chlorinated
solvent contaminants, such as Tetrachloroethylene (PCE) and Trichloroethylene (TCE). It is
estimated that approximately 40% of all such chlorinated contaminants on the General Chemical
facility property will be removed from the environment as a result of this treatment effort. Additional
areas of the site will be addressed as funding becomes available.
A brief summary of former site operations, current conditions, and needed remedies is provided in
Section 2.0. The proposed IRA is presented in Section 3.0, pursuant to 310 CMR 40.0424(1) of the
Massachusetts Contingency Plan (MCP). Additional information pertaining to public involvement
activities associated with this IRA Plan are presented in Section 4.0.
2.0 Background
The former General Chemical facility property is located at Latitude 42 o16'23"N, Longitude
71o24'00"W; UTM coordinates 302,000m E, 4,682,400m N. It is bounded by Leland Street to the
northwest, a residential area to the north, the Woodrow Wilson Elementary School to the
east/southeast, and an undeveloped wetland to the south/southwest. There are residential areas in all
directions within one-quarter mile of the Site. Refer to Figures 1 and 2 for a site location map and an
aerial map, respectively.
Contamination from the General Chemical facility has migrated beyond the property boundaries and
impacted surrounding areas. These impacted areas are considered part of the General Chemical
“disposal site”, which, for identification purposes, has been assigned Release Tracking Number
(RTN) 3-0019174 by MassDEP.
The currently known boundaries of the General Chemical Disposal Site include the former facility
property and
 a portion of the downgradient CSX railroad property;
 vacant former residential properties (owned by General Chemical or other associated entities)
at 91, 91A, 119, and 125 Leland Street;
 a portion of the property occupied by the Woodrow Wilson Elementary School;
 a portion of the property at 155 Leland Street;
 a portion of the Century Estates Condominium property;
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General Chemical Corp
RTN 3-0019174 – IRA Plan
January 2020
 a portion of the downgradient Massachusetts Water Resource Authority (MWRA) property on

which the Sudbury Aqueduct is located, extending from Leland Street in the Town of
Framingham to a gatehouse (Station 112+00) west of Coolidge Street in the Town of
Sherborn;
 land and wetlands to the south of the General Chemical property owned by Exelon, of which
only a portion is developed and occupied by an electrical substation;
 land and wetlands to the southeast of the General Chemical property owned by Exelon, which
includes an unnamed drainage ditch on the Exelon property to its discharge point with Course
Brook; and
 Course Brook from the Exelon property in Framingham to Coolidge Street in Sherborn.
2.1 Historic Site Operations

The General Chemical property was originally an oil terminal dating back to the 1920’s, then began
operations in the 1960’s through the 1970’s as a halogenated solvent reclamation, recycling, and
distribution center. Over time, the facility underwent upgrades as hazardous waste management
requirements and regulations evolved. Upgrades to the General Chemical facility included
aboveground storage tank (AST) removals, underground storage tank (UST) removals and drainage
improvements. General Chemical became a licensed Hazardous Waste Treatment, Storage, and
Disposal Facility in 1986 and ceased operations in March 2012.
At the time of the facility’s closure in 2012, physical structures at the site included three buildings
(still in existence), seventeen ASTs, six settling vessels, associated piping, and a concrete wall
secondary containment structure for the tank farm. Hazardous Waste Storage Buildings No. 1 and
No. 2 were used exclusively for the storage and transfer of regulated hazardous and non-hazardous
waste. The Warehouse building was used for solvent recycling, empty drum storage, and as a
laboratory. Figure 3 provides a General Chemical facility map depicting notable features prior to
shut-down.
Additional details pertaining to site operations and history are provided in a Phase II Comprehensive
Site Assessment Report, which was completed by Groundwater and Environmental Services, Inc.
(GES) on March 2, 2015. This and other MCP reports submitted to MassDEP for the GCC site are
available at https://eeaonline.eea.state.ma.us/EEA/fileviewer/Rtn.aspx?rtn=3-0019174.
2.2 Disposal Site Contamination

Semi-annual groundwater and surface water sampling was most recently performed by APTIM
Environmental & Infrastructure, Inc. (APTIM), a state contractor, in May/June 2019 and December
2019/January 2020. Semi-annual sampling has been performed periodically at the Site since 1999 in
order to document the concentrations of contaminants of concern in groundwater and surface water,
and to look for significant changes in contaminant concentrations and/or extent of contamination.
The results of the sampling have shown a relatively stable contaminant plume extending from the
General Chemical facility to the south to the area of the Exelon Substation. Shallow contaminated
groundwater discharges to an unnamed ditch located southwest of the facility. The contamination
extends via surface water flow to the southeast, where the ditch discharges into Course Brook, which
then flows east toward Sherborn and Natick.
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2.3 Source Area Concerns

Site characterization data obtained to date have identified the existence of heavily contaminated areas
on portions of the former General Chemical facility. These locations function as “source areas” of
the soluble chlorinated solvent contaminants that are migrating from the site in the groundwater.
This migration will continue for decades unless steps are taken to remediate these source areas.
Disposal Site conditions indicate that actions are needed to mitigate the continuing discharge of
contaminants from the former facility property. As such, and in accordance with 310 CMR
40.0412(4) of the MCP, MassDEP has determined that one or more IRAs are needed in these source
areas, with the objective of removing as much mass of contaminants as possible using available
funding.
After an evaluation of alternatives, MassDEP has determined that the best remedial strategy to
accomplish this objective is the use of in-situ thermal technology, in which the contaminants of most
concern below the ground surface are vaporized, captured, and removed from the site. The initial
effort, which is the subject of this plan, is to begin on the most upgradient portions of the site, to
ensure that residual contaminants at the site will not flow into and re-contaminate treated areas.
The contractor selected to undertake this thermal treatment project is the TRS Group, Inc. (TRS), as a
sub-contractor to MassDEP prime contractor APTIM, who will install and operate an ERH system.
TRS has extensive qualifications and experience in projects of this nature, including thermal
remediation projects implemented at many public and private sites. These sites include large
Department of Defense sites and a significant number of sites regulated by the USEPA. TRS also has
experience working on sites next to schools and residential areas.
3.0 Immediate Response Action Plan (310 CMR 40.0424)

The following subsections provide details with regards to the proposed IRA, as specified in 310 CMR
40.0424.
3.1 Person Conducting the IRA
General Chemical has been identified as a Potentially Responsible Party for the disposal site.
However, MassDEP will be conducting the IRA detailed in this plan through its contractor APTIM
and sub-contractor TRS. The name, address, and telephone number of the specific MassDEP
organizational unit conducting the IRA is as follows:
The Commonwealth of Massachusetts
Department of Environmental Protection – Northeast Region
Bureau of Waste Site Cleanup
205B Lowell Street
Wilmington, Massachusetts 01887
978-694-3200
Point of Contact: Stephen Johnson, Deputy Regional Director/Bureau of Waste Site Cleanup;
Phone Number: 978-694-3350; Email: Stephen.Johnson@mass.gov
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3.2 Description of Disposal Site and Potential Contaminant Receptors

3.2.1 Historic Spills at the Site
According to the May 2000 Interim Comprehensive Assessment Report II (GZA 2000),
approximately 50 recorded spills of oil and/or hazardous materials occurred at the GCC facility from
1983 through 2000. The MassDEP spills database has records of approximately 34 of these spills; the
rest were reportedly below MCP notification thresholds. A majority of the releases were the result of
surficial spills, overfilling of tanks, and above-ground piping ruptures. The MassDEP-documented
releases ranged from 5 to 200 gallons in volume and consisted mainly of halogenated compounds
(e.g., chlorinated solvents) and waste oil. All documented releases were reportedly contained and
cleaned up without significantly impacting the environment. Although no documentation exists prior
to 1983, it is speculated that chlorinated solvent and petroleum product spills seeped into the ground
during the 1960’s and 1970’s before impervious containment and asphalt pavement were in use at the
property.
3.2.2 Regulation of the Site by MassDEP

Environmental investigations were initiated at the General Chemical Site in the 1990’s, primarily in
accordance with 310 CMR 30.000, the Massachusetts Hazardous Waste Regulations. After 1999,
investigative and remedial work was regulated under both 310 CMR 30.000 and the MCP. Starting
in 2012, the regulatory oversight mechanism employed at this site by MassDEP shifted exclusively to
the MCP.
Prior to 2000, sampling performed by Weston & Sampson Engineering, Inc. on behalf of the
Massachusetts Water Resources Authority (MWRA) within Course Brook and the adjacent Sudbury
Aqueduct to the south had identified dissolved chlorinated solvent concentrations within samples
from both locations. Additionally, GZA GeoEnvironmental, Inc., on behalf of General Chemical, had
performed multiple indoor air sampling events at the 91 and 91A Leland Street residences from July
1997 through October 1999 to evaluate vapor concentrations and associated human health risks.
On January 18, 2000, MassDEP was notified that 13 µg/m 3 of TCE was detected within the indoor air
of 91 Leland Street. On January 24, 2000, MassDEP sent a letter to Mr. Roy Swartz of General
Chemical indicating that both the discharge of contaminated groundwater to the surface water of
Course Brook, as well as the identification of elevated chlorinated volatile organic compounds
(CVOCs) within indoor air vapors at 91 Leland Street constituted a Condition of Substantial Release
Migration under the MCP. Furthermore, the indoor air concentrations within the 91 Leland Street
residence represented a Critical Exposure Pathway and would require IRAs. The indoor air was also
impacted by cis-1,2-Dichloroethylene (cis-1,2-DCE), 1,1,1-Trichloroethane (1,1,1-TCA), and
toluene. The Substantial Release Migration represented a 72-hour reportable condition. Release
Tracking Number (RTN) 3-19174 was assigned to the disposal site, and the General Chemical was
listed as a Potentially Responsible Party.
Other reporting conditions have been identified at properties that are currently part of the General
Chemical disposal site. The other reportable conditions were assigned their own RTNs, and included
RTN 3-14860 (the Woodrow Wilson Elementary School), RTN 3-28186 (155 Leland Street), and
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January 2020
RTN 3-29233 (91 Leland Street). These RTNs have all been linked to and are now managed under
RTN 3-19174, the parent RTN for the General Chemical disposal site. Additional detail pertaining to
each RTN can be found in Section 6.0 of the March 2015 Phase II Comprehensive Site Assessment
(GES).
3.2.3 Site Conditions

The groundwater at the General Chemical site has been impacted by CVOCs due to historical
operations at the Site. The primary chlorinated solvents detected in groundwater at the site include:
TCE, PCE, 1,1,1-TCA, methylene chloride and 1,4-dioxane, plus CVOC breakdown products such as
cis-1,2-DCE. Impacted shallow groundwater migrates off the property to the southwest and
discharges to a drainage ditch that runs southeast and flows into Course Brook. Additionally, shallow
groundwater is seeping into the MWRA Sudbury Aqueduct located to the south of the property;
ultimately discharging into Course Brook via a weir in Sherborn. Contamination in the deeper
groundwater migrates off property to the southwest, but the plume flow direction shifts to the
southeast.
Soil at the General Chemical property is highly contaminated from historic spills. Indoor air was also
impacted at nearby residences that have since been acquired by General Chemical or associated
entities, and abandoned. A detailed description of the Nature and Extent of contamination is provided
in Section 8.0 of the March 2015 Phase II Comprehensive Site Assessment (GES).
3.2.4 Potential Receptors
Human Receptors
No institutions such as nursing homes or daycare facilities are located within 500 feet of the GCC
site. However, the Woodrow Wilson Elementary School is located on abutting property east of the
General Chemical site and has several monitoring wells on the property. Historically, low to non-
detectable concentrations of CVOCs have been detected in these monitoring wells. Former
downgradient residential properties located at 91, 91A, 119, and 125 Leland Street were previously
acquired by General Chemical or related entities and are vacant, and no longer used for residential
purposes. Therefore, there are no current residential receptors immediately downgradient from the
General Chemical facility.
The closest occupied residential property to the site is 155 Leland Street located north of the General
Chemical facility; this property is being evaluated as part of the General Chemical disposal site. The
closest downgradient or cross-gradient occupied residential areas to the General Chemical site
include the Century Estates Condominiums, which is also being evaluated as part of the General
Chemical disposal site. Other single-family residences located further to the southwest along Leland
Street are not currently considered part of the General Chemical disposal site.
Drinking Water
Framingham
The General Chemical site is not located within a Potentially Productive Aquifer, Zone II of a public
water supply well, Zone A of a Class A surface water supply, Interim Wellhead Protection Area, or a
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USEPA Sole Source Aquifer. The GCC site is also not located in Framingham’s Groundwater
Protection Overlay District. The GCC property and surrounding areas are supplied with potable
water by the MWRA.
Sherborn
All downgradient properties in Sherborn are serviced by private drinking water wells that are
typically installed into the bedrock at varying depths ranging from 100 to 600 feet below grade.
Based on a review of the well database for the Town of Sherborn on the MassDEP website, and
communications with the Town of Sherborn, the nearest private drinking water wells are located in
the vicinity of Coolidge Street and Meadowbrook Road. These wells were tested in 2012 and 2015
and no contamination above drinking water standards was identified. Another testing round was
recently completed on January 15th and January 17th, 2020. The results are expected to be available
in February 2020.
Natick
The Natick Water Department maintains and operates eleven public water supply sources which
supply drinking water to the town. None of these sources are in the vicinity of the GCC site or areas
along Course Brook extending into Sherborn or Natick. According to the Natick Water Department
and a review of the MassDEP private water supply database, private wells are not used as a source of
drinking water in Natick.
Sudbury Aqueduct
The Sudbury Aqueduct is buried below grade on the parcels abutting the GCC property downgradient
and to the east-southeast toward Sherborn. The Sudbury Aqueduct is considered a secondary back-up
drinking water supply conduit by the MWRA.
Environmental Receptors
The most significant environmental receptors in the vicinity of the GCC facility are the downgradient
wetlands, an unnamed ditch, and Course Brook. The unnamed ditch passes through the Exelon
property and travels southeast to its confluence with Course Brook, which is located approximately
1,800 feet southeast of the GCC facility property boundary and extends into Sherborn. Course Brook
is a tributary to water bodies further downstream in the drainage basin that are designated Class B,
which signifies they are a habitat for fish, other aquatic life, and wildlife, supporting reproduction,
migration, growth and other critical functions, and suitable for primary and secondary contact
recreation. Class B waters shall have consistently good aesthetic value, and should be free from
floating, suspended and settleable solids in concentrations and combinations that would impair
compatible use or that would cause aesthetically objectionable conditions.
The GCC site is not located within an Area of Critical Environmental Concern, Estimated Habitat of
Rare Wetlands Wildlife, or state, federal, or municipal Protected Open Space, and there are no
Certified Vernal Pools located on Site. The MassDEP Priority Resource Map depicts “potential”
vernal pools near the drainage ditch confluence with Course Brook. No other sensitive
environmental receptors have been identified. Together, the drainage ditch and Course Brook
constitute the primary discharge feature in the area.
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Agricultural Receptors
Given the agricultural use of the properties along Course Brook in Sherborn, the potential exists for
use of water for irrigation purposes both from irrigation wells or intakes in surface water
impoundments near and along Course Brook. Class B surface water bodies like Course Brook are
suitable for irrigation and other agricultural uses and for compatible cooling and process uses. Based
on a review of the MassDEP private well database and discussion with the Sherborn Board of Health,
there are no known irrigation wells on the properties through which Course Brook traverses within
the area of the GCC Site. However, based on discussions with local property owners, irrigation water
is used from Course Brook directly, and from irrigation ponds. Animals such as horses and cows are
expected to use water from Course Brook.
3.2.5 Completed Investigations

Comprehensive environmental assessment activities were initiated at the GCC Site in the 1990’s and
have continued through present day. Assessment activities have been performed on behalf of the
General Chemical Corporation, the United States Environmental Protection Agency, and MassDEP.
Assessment information, including continued development of the Conceptual Site Model were
documented in numerous submittals, including:
 May 2000 – Interim Comprehensive Assessment Report (GZA)
 February 1, 2001 – Imminent Hazard Evaluation (GZA)
 December 14, 2001 – Supplemental Assessment Plan and Stabilization Measure (GZA)
 July 8, 2002 – Immediate Response Action Completion Report (Vertex)
 December 2008 – Comprehensive Assessment Report (CDW)
 September 2009 – Remedy Evaluation Report (FS Engineers)
 October 2011 – Remedy Implementation Plan (FS Engineers)
 May 31, 2013 – Data Gap Action Plan Report (GES)
 March 2, 2015 – Phase II Comprehensive Site Assessment (GES)
 February 15, 2016 – Draft Phase III Remedial Action Plan (GES)
Additional details pertaining to previously performed remedial investigations at the General
Chemical Site are provided in Section 6.2 of the March 2015 Phase II Comprehensive Site
Assessment (GES).
3.3 Description of Any Immediate Response Actions Undertaken to Date at the Site
3.3.1 January 1995 PCE Release

An IRA was completed by GCC on January 9, 1995 to contain and remediate a 10-15 gallon release
of PCE at the Site (RTN 3-12043). The release was contained on the pavement of the truck loading
area at the facility and cleaned up using Speedi-Dri absorbent. An IRA Plan was submitted
simultaneously with the Class A-1 Response Action Outcome Statement on March 28, 1995 by
ERM-New England, Inc.
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3.3.2 January 2000 Critical Exposure Pathway

In February 2000, GZA GeoEnvironmental, Inc. (GZA) submitted an IRA Plan for the Site on behalf
of General Chemical. The IRA Plan indicated that total VOC concentrations greater than 5 mg/1 were
detected in groundwater samples collected within 30 feet of the then occupied dwelling at 91 Leland
Street. GZA concluded that this represented a 72-hour Substantial Release Migration reporting
condition and a Critical Exposure Pathway may have existed with respect to potential vapor phase
emissions to indoor air at 91 Leland Street, warranting an IRA.
GZA submitted an IRA Plan and conducted response actions, which consisted of the installation of a
false floor in the basement of 91 Leland Street, the extraction of vapors beneath the floor, and the
discharge of the vapors to the outside of the building. GZA also continued air monitoring activities
within the building.
Following the original IRA Plan, GZA submitted the following reports to MassDEP associated with
this incident:
 Final Installation Report, January 11, 2001
 IRA Status Reports, May, October and December 2000 and July 2001
These reports detailed the venting system installation and on-going air monitoring activities
conducted within 91 Leland Street. GZA also submitted a report entitled Evaluation of Critical
Exposure Pathways at 91 and 91A Leland Street on November 11, 2001. This report provided
venting system operational data, air monitoring data, and a risk evaluation.
According to the IRA Completion Report dated July 8, 2002, an evaluation of the potential for a
Critical Exposure Pathway to have existed at the 91 Leland Street building was completed in 2001.
This evaluation included ten indoor and outdoor sampling events. Based on the results, GZA
concluded that a Critical Exposure Pathway did not exist within the building due to the fact that
indoor air sampling data demonstrated that the organic compounds detected were the result of sources
other than contaminated groundwater. Therefore, GZA concluded a Critical Exposure Pathway did
not exist.
Residents of the 91 Leland Street property vacated the building on May 10, 2002. The crawl space
venting system was shut down at that time and the building secured. General Chemical Corporation
currently owns the 91 Leland Street property and reportedly has no plans to utilize the building.
3.4 The Reason Why an Immediate Response Action is Required

Contaminant conditions exist at this site, including a significant area containing dense non-aqueous
phase liquid solvent, with no measures in place to control migration. Immediate actions are needed
to mitigate the continued migration of contaminants from the former facility via groundwater flow to
surface waters and downgradient properties. As such, and in accordance with 310 CMR 40.0412(4)
of the MCP, MassDEP has determined that one or more IRAs are needed in these source areas on the
General Chemical facility, with the objective of removing as much mass of contaminants as possible
using available funding.
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3.5 Objectives, Specific Plans, and Proposed Schedule for Immediate Response Action
The following sections summarize the objectives, specific plans, and proposed schedule of the IRA
for the General Chemical site.
3.5.1 Objective and Approach
The objective of this IRA is to remove as much mass of CVOCs as possible with available funding
using an ERH thermal treatment process. Based upon an analysis of site characterization data
collected to date, approximately 40% of the total mass of CVOC contamination on the General
Chemical property is located in the upgradient areas targeted for treatment in this IRA. The ERH
system is expected to recover about 95% of the mass of chlorinated solvents in these treatment areas.
The two areas targeted for remediation are identified as Thermal Treatment Areas 1 and 2. A map
showing the targeted thermal treatment areas is included as Figure 4.
ERH is an in-situ thermal treatment technology that uses the resistance of soil for the transmission of
electrical current to generate heat. Metallic probes are inserted into the ground to serve as electrodes.
Voltage is then applied to these electrodes to induce the flow of electricity below the ground surface
between the electrodes. The soil present between the electrodes impedes the flow of this electricity,
creating resistance, which generates heat.
The voltage/amperage of electricity delivered to the electrodes is controlled to produce the desired
amount of temperature rise. The objective for this project is to ensure a temperature just high enough
to boil and steam-strip the chlorinated solvents of most concern (e.g., PCE, TCE). These vaporized
contaminants are then vacuum-extracted from the vadose zone and passed through an activated
carbon filter, where they are trapped. Once the filter is saturated, it is shipped off site to a location
where it is regenerated.
A complication at the General Chemical site is the presence of oil contamination in the treatment
areas. While oil is also an environmental contaminant, it is less toxic and substantially less volatile
and mobile than the chlorinated solvents. Because the activated carbon filters are expensive, it is not
desirable to saturate them with oil. Rather, it will be important to maintain temperatures in the
treatment areas just high enough to vaporize most of the chlorinated solvents, but low enough to
minimize the vaporization of oil. This is expected to be a dynamic and iterative process, where the
voltage applied to the various electrodes is adjusted in response to ground temperature data and the
chemical composition of the vapor-phase emissions.
3.5.2 Specific Plans

A standard ERH remedial system has been developed by TRS for this site, as described below.
Additional design details and specifications will be developed after receipt of public comments on
this plan, and upon installation of the system, based upon encountered site conditions.
The specific anticipated sequence of events associated with the IRA consists of: review of public
comments, pre-construction permitting, site preparation, treatment system installation, treatment
system startup and operation, and treatment system shutdown and removal.
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3.5.2.1 System Location and Design

The two separate treatment areas that are the subject of this IRA are presented in Figure 4. Treatment
Area 1 is an approximately 1,500 square-foot area north-centrally located in the vicinity of the former
loading rack. The vertical treatment zone in Treatment Area 1 is anticipated to be the top 10 ft of
subsurface soil.
The second treatment area is an approximately 3,250 square-foot area located along the northern
property boundary, southeast of Thermal Treatment Area 1, in the vicinity of the former tank farm.
The vertical treatment zone in Treatment Area 2 is split into five separate grid areas with targeted
depths ranging from 15-30 ft.
The total treatment volume of Treatment Area 1 is 560 cubic yards, and for Treatment Area 2 is
2,300 cubic yards. The average CVOC concentration determined for soils in Area 1 was 3,393
mg/kg, which is based on the summation of the average concentrations of CVOCs detected in soils
from the 0-10 foot depth interval. The average soil concentration of CVOCs in Area 2 is 674 mg/kg,
which is based upon the summation of the average concentrations of CVOCs detected within soils
within the target areas. Based on the above information it is estimated that 3,546 pounds of CVOCs
are present within Treatment Area 1 and 4,643 pounds are present within Treatment Area 2.
The ERH system will consist of 27 electrodes and co-located vapor-recovery wells, spaced
approximately 16 feet apart, as presented in Figure 4. Electrode depth will vary based upon the
designated treatment zones, to a maximum depth of 30 feet in portions of Treatment Area 2.
Electricity from a 480-volt, 1,400 amp power drop will be applied to the electrodes to increase
temperatures in the treatment areas. The amount of voltage applied to each individual electrode will
vary to create ground temperatures in the range of 90 to 100⁰C. The heating will continue for
approximately 14 weeks or until 760,000 kilowatt hours (kWh) of electrical energy has been applied
to the subsurface.
A 40-horsepower vapor recovery blower will be used to create a negative pressure in the vadose zone
in the treatment areas, and induce the flow of steam and vaporized contaminants into the 27 vapor
recovery wells, at a flowrate of approximately 510 standard cubic feet per minute (scfm). The
steam/vapor will flow into a condenser. Liquid water exiting the condenser will be directed to an
oil/water separator, and then to an aqueous-phase activated carbon treatment system. The treated
condensate water will then be discharged to the sewer or other permitted location.
The vapor stream exiting the condenser will contain elevated concentrations of CVOCs and other
volatile oil and hazardous materials, and will be piped into 2 in-series filters that each contain 10,000
pounds of granular activated carbon (GAC). The treated vapor stream will then be discharged into
the ambient air. Once spent, the 10,000 pound GAC filters will be shipped to an off-site location for
regeneration. It is anticipated that 80,000 pounds of GAC will be needed to treat vapor emissions
during this project.
The concentration and chemistry of recovered vapors will be regularly monitored by MassDEP
personnel to evaluate, adjust, and fine-tune system operations, to meet the remedial objective.
Subsurface vapor migration and ambient air quality will be continually monitored and evaluated by
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MassDEP, to ensure protection of public health, including at the nearby Woodrow Wilson
Elementary School.
A process flow diagram of the proposed treatment train is provided in Figure 9. Additional
information on the TRS Group, the ERH process, and proposed remedial system are presented in “In-
Situ Thermal Remediation Services Proposal” in Appendix 1.
3.5.2.2 Permitting
Prior to mobilization, MassDEP and associated contractor(s) will obtain necessary permits for the
implementation of the IRA treatment systems. Required permits potentially include Building,
Electrical, and Road Opening Permits that will be obtained through the City of Framingham. In
addition, either a wastewater discharge/sewer-entry permit will be obtained from MWRA/city of
Framingham, or a National Pollution Discharge Elimination System (NPDES) or Remediation
General Permit (RGP) will be obtained from EPA.
3.5.2.3 Site Preparation

Site preparation activities include the following:
 Underground utilities will be located and marked-out using Dig Safe and site records. In
addition, a ground-penetrating radar survey will be performed by a contractor prior to
subsurface installations to identify any potential unknown buried utilities or structures in the
treatment areas.
 A contractor will install a 1400 amp, 480-volt power drop that will be used to power a 700
kW power control unit.
 20 existing PVC monitoring wells in and near the ERH treatment area will be grouted by a
drilling contractor. The abandonment of these wells in this manner is necessitated by the high
temperatures that will be created by the ERH system in and near the treatment areas, which
will melt the PVC piping.
 The existing metal fence along the northerly property boundary will be replaced with a vinyl
clad coated chain link fence for voltage mitigation purposes
3.5.2.4 Treatment System Installation

The ERH system components will be installed by TRS, working as a subcontractor to APTIM, the
prime state-funded contractor for this project. The installation work will be overseen by MassDEP
and APTIM. ERH equipment, consisting of a total of 27 subsurface electrodes/vapor recovery wells
spaced about 16 feet apart will be installed in the two treatment areas by a licensed drilling company.
A detail map showing the construction of a typical electrode is included as Figure 5, though
adjustments may need to be made in the field during installation based upon conditions encountered.
Each electrode will be installed using 12-inch O.D. drill tooling and will have a co-located, stainless
steel vapor recovery screen installed within each electrode borehole. Once an electrode is installed to
its target depth, the 12-inch diameter borehole will be backfilled with a permeable backfill material
that includes zero-valent iron (ZVI). The ZVI reacts with CVOCs to produce conductive chloride
ions that reduce the local resistance, preferentially concentrating current flow in areas with the
11
January 2020
highest CVOC levels. The power supply cable to each electrode will be grouted in place at the
ground surface. All drilling spoils will be consolidated in roll-off containers and/or drums for off-site
disposal.
Four temperature monitoring points and three vacuum monitoring points will be installed
simultaneously during the electrode installation event. Detail maps showing the structure of each
temperature and vacuum monitoring point are included as Figures 6 and 7, respectively. Temperature
monitoring points will be installed using a minimum of 4-inch O.D. drill tooling, and will consist of
an iron riser pipe set in grout within the borehole annulus. Each temperature monitoring point will
have five temperature sensors installed vertically at even intervals to provide vertical temperature
profile data during the treatment operation.
The three vacuum monitoring points will be installed around the treatment zone periphery to measure
negative pressures in the vadose zone beneath the ground surface. Vapor monitoring point installation
depth will be determined during the final ERH installation. The points will consist of 0.5-inch
diameter CPVC 0.040 well slot screen surrounded by a sand backfill within the borehole annulus.
Vacuum points will not be advanced deeper than the water table. All drilling spoils will be
consolidated in drums or roll-off containers for off-site disposal
Two contingency hydraulic management wells will be installed immediately upgradient of ERH
Treatment Areas 1 and 2 as a precautionary measure. Operation of the hydraulic management system
will only be initiated if the groundwater velocity entering the treatment zones is higher than
anticipated (i.e., greater than 1 foot/day), because the cooler groundwater will reduce temperatures in
the treatment zone, reduce the effectiveness of thermal treatment on the contaminants of concern, and
lessen the capture of mobilized VOCs. A hydraulic management well detail is provided in Figure 8.
Final locations will be determined during the installation phase of the project based upon the property
access agreement.
During the electrode installation, piping and connections associated with the water and wastewater
connections will be installed by a contractor.
Once subsurface ERH infrastructure is installed in each treatment area, remaining surface
installations will be performed. The 1400-ampere, 460-volt power drop and 700 kW power control
unit will be connected to the aboveground ERH electrical network. The ground surface of the
treatment area will be covered by a cap, insulating the ground and preventing a shock-hazard to foot-
traffic.
The process vapor and liquid treatment systems will then be installed. The vapor-phase treatment
system is illustrated in Figure 9, and relies on two in-series 10,000-pound GAC vessels to adsorb
extracted vapor-phase CVOCs. A condenser will be installed upstream of the GAC vessels. A single
40-horsepower blower with noise enclosure, capable of a total capacity of up to 800 scfm, will be
installed following the condenser to push the contaminated vapor through the two GAC vessels.
The liquid-phase treatment system is also illustrated in Figure 9. Although LNAPL and DNAPL are
not anticipated, an oil/water separator will be installed upstream of the aqueous phase GAC filter as a
12
January 2020
precaution. Similar to the vapor-phase treatment system, two in-series lead/lag 200-pound liquid
phase GAC vessels will be incorporated into the liquid treatment process.
In order to monitor the potential for the subsurface migration of contaminated vapors, 3 soil vapor
monitoring wells will be installed at the site between the areas targeted for remediation and the
neighboring residence/Woodrow Wilson Elementary School.
Electrical and process instrumentation will be installed, and remote communication telemetry control
infrastructure will be connected.
3.5.2.5 System Operation and Monitoring

Once all infrastructure is installed and has been tested accordingly, electrical power will slowly be
increased to the electrodes until subsurface treatment area target temperatures are reached. The ERH
system is designed to deliver 760,000 kilowatt hours (kWh) of electrical energy to the subsurface
over a 14-week period of operation, with an average operating power of 333 kWh. Contractor and
MassDEP personnel will be on site during system start-up and optimization. Once the system is in
steady-state operation, it will be monitored 24/7 remotely, with on-site inspections at least 2 days per
week. Liquid discharge monitoring will be conducted in accordance with the associated MWRA or
NPDES/RGP permit. Vapor-phase monitoring will be conducted hourly during startup with a PID
meter and on-site Gas Chromatograph, decreasing to daily when steady-state conditions are achieved,
and then 2 to 4 times a week during longer term operation. Remediation waste will be characterized
and managed appropriately.
IRA Status Reports will be generated as necessary during the remediation process and pursuant to
310 CMR 40.0425.
3.5.2.6 Termination, Demobilization and Final Reporting

After 14 weeks (or 760,000 kWh), the transmission of electrical current to the site electrodes will be
terminated. The vapor recovery system will continue to run for a minimum of 5 days, during which
time the concentrations of off-gassing vapors will be monitored. If significant emissions of CVOC
vapors continue to be observed after the 5-day period, MassDEP may elect to continue to operate the
vapor recovery system until such time as continued operation is not removing a significant mass of
contaminants.
After termination of the vapor recovery system, the soil gas vapor wells will be monitored on at least
a daily basis, until such time as it can be concluded that subsurface vapor migration is not of
significant concern. If such a migration pathway is noted, the vapor recovery system will be
reactivated.
Once a decision is made by MassDEP that vapor migration is not a concern, the ERH system will be
deactivated and removed. All above grade temporary structures, piping, and equipment will be
removed from the Site. Electrodes will be abandoned in-place by grouting the top three feet of each
electrode and grouting the entire casing for each vapor recovery point, temperature monitoring point,
and hydraulic management well. All investigation-derived waste will be characterized and managed
appropriately. The electrical utility connection will be terminated, as will any other municipal system
13
January 2020
connections that were associated with the remedial system. A final IRA Completion Report will be
prepared by MassDEP consistent with 310 CMR 40.0427.
3.5.3 Proposed Schedule

Given the proximity of the disposal site to the adjacent Woodrow Wilson Elementary School, efforts
have been made to sequence the ERH system operations during the summer when use of the school is
at a minimum. The general ERH remedial activities sequence is as follows:
 ERH system design and permitting: January 6, 2020 to April 3, 2020

 Site preparation, including materials mobilization: March 2 to March 13, 2020
 Subsurface installation: March 16 to April 17, 2020
 ERH surface construction: April 20 to May 22, 2020
 ERH equipment mobilization and construction: May 25 to June 5, 2020
 System shakedown and start-up testing: June 8 to June 19, 2020
 ERH system operations: June 22 to September 25, 2020
 Demobilization: September 28 to October 23, 2020
3.6 Remediation Waste Statement

Remediation Waste and Remedial Wastewater will be generated as part of this IRA. Contaminated
soil will be generated during the electrode installation process and other subsurface drilling and
excavation activities, and will be containerized and tested for off-site disposal as a Remediation
Waste or Hazardous Waste.
Extracted groundwater and condensed steam will be treated onsite, with effluent discharged to either
the municipal sewer system as regulated by an MWRA/City of Framingham discharge permit or to
the unnamed brook via a NPDES/RGP permit from the USEPA. The monitoring of the wastewater
discharge will be conducted by MassDEP in accordance with permit requirements.
The spent GAC filters used to treat the recovered vapor and wastewater discharge will be removed
from the site and brought to a regeneration facility.
3.7 Proposed Environmental Monitoring

A robust monitoring program is necessary to optimize system operations and ensure protection of the
surrounding populations, including the adjacent Woodrow Wilson Elementary School. This is
especially true during startup operations, while system components and operations are being adjusted,
corrected, and fine-tuned. As such, MassDEP will deploy its mobile laboratory to the site during this
critical time period, in order to immediately detect and address any potential exposure issues that
could arise.
The MassDEP mobile lab is a 27.5 foot long vehicle with two on-board generators, internet
connectivity via a dual modem wireless router, a 10 meter weather mast that transmits wind direction
and other meteorological data real-time to an on-board receiver/laptop PC, and various support
systems and equipment for gas chromatographs and other analytical testing instruments. Photographs
of the mobile laboratory are included as Figure 10.
14
January 2020
3.7.1 Startup
Perimeter air monitoring will be conducted continuously during system startup using four AreaRAE
monitors at the perimeter of the work area. Each monitor is equipped with a 400 cc/minute pump that
continuously samples air, for analysis by 4 sensors, including a photoionization detector (PID) to
detect volatile organic compounds. Readings are transmitted real-time by radio frequency to a
receiver located in the MassDEP mobile lab. Data from the receiver is wired to a laptop PC that
continuously displays concentration readings, which are updated every 2 seconds. Exceeding a
programmed action level for each sensor produces a visible and audible alarm. Data readings for
each sensor are recorded and logged independently on each AreaRAE unit as well as in the laptop PC
program.
In addition to the AreaRAE monitors, portable hand-held real-time meters will also be used to test
additional downwind areas and to test for additional chemical contaminants.
To complement and enhance continuous real-time analytical screening operations, grab samples of air
will be obtained in 0.5-L Kynar sampling bags at least twice per hour in downwind locations and/or
at or within sensitive receptors such as the Woodrow Wilson Elementary School. These samples will
be immediately analyzed on-site in the mobile lab on two Inficon HAPSITE Gas Chromatographs
with Mass Spectrometers (GC/MS) for VOCs, using a testing method calibrated to detect and
quantify 36 common organic compounds at a Reporting Limit of 0.2 ppbV (200 parts-per-trillion) for
most chlorinated solvent VOCs. Each unit is calibrated and operated consistent with the MassDEP
Compendium of Analytical Methods, including the daily analysis of a calibration check standard at a
concentration of 5.9 ppbV.
In addition to ambient air, soil vapor monitoring wells will be tested at least hourly with a PID meter,
and periodically by GC/MS.
3.7.2 Steady-State/Longer Term Operations
Once sufficient data is obtained to demonstrate satisfactory ERH operations and the lack of off-
property air and soil vapor impacts, the mobile lab will be demobilized. However, MassDEP
personnel will continue to deploy to the site on a daily basis for at least the first 5 days of operations,
to test vapor monitoring wells with a PID meter, and obtain ambient or indoor air samples in 0.5-L air
sampling bags for transport to the MassDEP laboratory in Wilmington, for analysis on the HAPSITE
GC/MS unit the same or next day.
For longer term operations (through week 14), MassDEP personnel will deploy to the site 2 to 4 days
per week, to test air and soil gas with a PID meter, and obtain samples of outdoor and/or indoor air
for transport to the MassDEP laboratory in Wilmington for same or next day analysis.
3.7.3 Remedial Air Emissions

Samples of the vapors entering and leaving the lead/lag 10,000 pound GAC filters will be analyzed
by MassDEP on a frequent basis during ERH system startup, with both a PID meter and GC/MS, to
15
January 2020
ensure adequate VOC removal, and to correlate PID readings to Target Analyte concentrations
reported from the GC/MS analysis. If a reasonable correlation is established, longer-term
monitoring of GAC filter effluent will be conducted primarily with a PID meter, with only periodic
split-sample analysis via GC/MS.
In addition to ensuring safe levels of air emissions, the chemistry of influent vapors to the 10,000
pound GAC filters will also be evaluated to determine whether significant concentrations of
petroleum hydrocarbons are being liberated from the treatment zone, which may necessitate
adjustment to electrode voltages and treatment zone temperatures, to prevent saturation of the GAC
filter by oil contaminants, and preserve capacity for the CVOC contaminants of primary interest and
concern.
3.7.4 Remedial Wastewater
Samples of the aqueous wastewater stream entering and exiting the liquid-phase GAC filter will be
collected by MassDEP during the first 5 days of operation, for headspace analysis on the MassDEP
HAPSITE GC/MS instruments. Subsequent longer-term sampling will be at a less frequent basis,
depending upon the initial data sets.
Samples will also be taken by MassDEP personnel for analysis by a certified laboratory by EPA
Method 8260 or other method specified in the sewer or Remediation General Permit (RGP).
3.8 Listing of Federal, State, or Local Permits required to Conduct IRA

The following permits are or may be required to conduct the proposed IRA:
 Building Permit – City of Framingham
 Electrical Permit – City of Framingham
 Water Connection Permit – City of Framingham
 Sewer Entry Permit – City of Framingham and/or MWRA
 NPDES or RGP – US EPA
3.9 Name of LSP who Prepared IRA Plan

This plan has been prepared and the IRA will be directly overseen by MassDEP personnel. In
accordance with 310 CMR 40.0411(2) of the MCP, a Licensed Site Professional is therefore not
required.
4.0 Public Involvement

On July 30, 2012, General Chemical received a petition from residents in Framingham,
Massachusetts. The petition requested that the General Chemical disposal site be designated as a
Public Involvement Plan site, as required under Section 14(a) of Massachusetts General Laws chapter
21E and 310 CMR 40.1400 of the MCP. A Draft Public Involvement Plan was submitted to
MassDEP on March 21, 2013. A public meeting was held on April 4, 2013 to present the PIP process
and requirements. A Revised Final PIP, dated June 18, 2013, was subsequently issued for this site.
Given the interest that has been expressed by the public, a public meeting will be held on February 6,
2020 from 7:00 to 9:00 PM at the Woodrow Wilson Elementary School to present this IRA Plan, and
16
January 2020
provide interested parties an opportunity to comment, prior to project finalization and

implementation.
5.0 References
APTIM. 2018. Focused Remedy Evaluation – General Chemical Corporation Site. Correspondence.
Aptim Environmental & Infrastructure, Inc. March 12, 2018.
ERM. 1995. Supporting Documentation for Response Action Outcome (RAO) Statement, Release
Tracking Number 3-12043. ERM-New England, Inc. March 29, 1995.
GES. 2011. Remedy Implementation Plan, General Chemical Corporation, 133-135 Leland Street,
Framingham, Massachusetts, Groundwater & Environmental Services, Inc., September 28, 2011.
GES. 2012. Data Gap Action Plan, General Chemical Corporation, 133-135 Leland Street,
Framingham, Massachusetts, Groundwater & Environmental Services, Inc., January 20, 2012.
GES. 2013. Data Gap Action Plan Report, General Chemical Corporation, 133-135 Leland Street,
Framingham, Massachusetts, Groundwater & Environmental Services, Inc., May 31, 2013.
GES. 2015. Phase II Comprehensive Site Assessment, General Chemical Site 133-135 Leland Street,
Framingham, Massachusetts. Groundwater & Environmental Services, Inc., March 2, 2015.
GES. 2016. DRAFT Phase III Remedial Action Plan. General Chemical Corporation, 133-135
Leland Street, Framingham, Massachusetts. Groundwater & Environmental Services, Inc., February
15, 2016.
GZA. 2000. Interim Comprehensive Assessment Report II, General Chemical Corporation, 133-135
Leland Street, Framingham, Massachusetts, GZA GeoEnvironmental, Inc., May 2000.
GZA. 2001. Imminent Hazard Evaluation, General Chemical Corporation, 133-135 Leland Street,
Framingham, Massachusetts, GZA GeoEnvironmental, Inc., February 1, 2001.
GZA. 2001. Supplemental Assessment Plan, General Chemical Corporation, 133-135 Leland Street,
Framingham, Massachusetts, GZA GeoEnvironmental, Inc., December 14, 2001.
MassDEP. 2014. Massachusetts Contingency Plan, 310 CMR 40.0000, Massachusetts Department of
Environmental Protection, April 2014.
TRS Group. 2019. In Situ Thermal Remediation Services, General Chemical Site 133-135 Leland
Street, Framingham, Massachusetts. TRS Group, May 9, 2019.
USGS. 1987. Framingham Massachusetts 7.5 Minute Series Quadrangle Map, United States Geologic
Survey.
Vertex. 2002. Immediate Response Action Completion Report, General Chemical Corporation, 91
Leland Street, Framingham, Massachusetts. Vertex Engineering Services, July 8, 2002.
17
FIGURES
M:\Graphics\1600-Westford\Misc\General Chemical\General Chemical Framingham\General Chemical Framingham SLM.dwg, Layout1, 2/6/2015 1:07:46 PM, WShea
TM
STUDY AREA
SS
APPROXIMATE
2
Legend
Sampling Locations
Monitoring Well
Monitoring Well, Destroyed
Piezometer
Piezometer, Destroyed
Injection Well
Recovery Well
Former Recovery Well, Destroyed

Garage Loading
Rack MIP Boring
Loading Former Loading Dock Soil Boring
Pad
Surface Soil
Loading Rack Waste
Solvent Aqueduct
Storage Clean Surface Water
Solvent
Storage Water Well
Loading Rack Fuel Oil
Storage GCC Facility Property
Loading Former Septic Tank
Dock Former Storage and Handling Areas (Approximate)
Former Virgin Rail Road Tracks
Warehouse Solvent
Former Still Roads
Storage
1st Floor
Basement Sump Access Road
Drainage Brook (Approximate)
Former Tank
GCC GCC 1st Floor
Production Area
Buildings
Fence
Vessels Parcel Boundary
Parcel Division
Former Septic Virgin & Cleaned
Leach Field Solvent Storage Right of Way
Virgin Wetlands (Surveyed)

Chemicals Water
Tank
Note:
Historical solvent storage and handling features obtained
Fuel Oil & Detention
Basin from multiple sources. There are no chemical storage tanks
Virgin
Solvent remaining on the GCC facility property following the 2012
Storage RCRA closure activities.
Groundwater & Environmental Services, Inc.

GCC
Figure 10. Photographs of Mobile Lab
APPENDIX
General Chemical Site

In Situ Thermal
Remediation Services

General Chemical Site
133‐135 Leland Street
Framingham,
Massachusetts

DATE
May 9, 2019

Submitted to:
APTIM

Table of Contents
EXECUTIVE SUMMARY 2
GENERAL INFORMATION ABOUT TRS 2
SECTION 1 ‐ PROJECT BACKGROUND 3
SECTION 2 ‐ TECHNICAL APPROACH 3
2.1 TARGET TEMPERATURE FOR IN SITU THERMAL REMEDIATION 3
2.2 ELECTRICAL RESISTANCE AND THERMAL CONDUCTION HEATING 4
2.3 ELECTRICAL RESISTANCE HEATING TECHNOLOGY DESCRIPTION 5
2.4 VOLATILE ORGANIC COMPOUND MASS ESTIMATE 6
2.5 ELECTRICAL RESISTANCE HEATING CONCEPTUAL DESIGN 6
2.6 HYDRAULIC MANAGEMENT 10
2.7 PROCESS VAPOR TREATMENT 10
2.8 PROCESS LIQUID TREATMENT 10
SECTION 3 ‐ DESCRIPTION OF WORK 12
3.1 DESIGN, PERMITS AND PLANS 12
3.2 MATERIALS MOBILIZATION 13
3.3 SUBSURFACE INSTALLATION 14
3.4 SURFACE INSTALLATION AND START‐UP 14
3.5 SYSTEM OPERATIONS, MONITORING AND REPORTING 15
3.6 DEMOBILIZATION AND FINAL REPORTING 16
SECTION 4 ‐ SCHEDULE 17
SECTION 5 ‐ SAFETY, TRAINING, QUALITY AND BEST PRACTICES 17
SECTION 6 ‐ TRS PROJECT EXPERIENCE 18
SECTION 7 ‐ TRS PROJECT TEAM 19
SECTION 8 ‐ CONTRACTING 20
SECTION 9 ‐ PRICING 21

LIST OF TABLES
TABLE 1: BOILING TEMPERATURES OF PRIMARY SITE VOCS 3
TABLE 2: ERH DESIGN PARAMETERS AND ENGINEERING MODEL INPUT 7
TABLE 3: ERH MODEL OUTPUT 7
TABLE 4: ERH SYSTEM COMPONENTS 10

LIST OF FIGURES
FIGURE 1: ERH UNIFORM HEATING AND CONDUCTION HEATING PROFILE 4
FIGURE 2: UNIFORM HEATING OF ERH AND TCH SUPERHEATING SCHEMATICS 4
FIGURE 3: ERH REMEDIATION PROCESS 5
FIGURE 4: ERH ELECTRODE SITE PLAN 8
FIGURE 5: ERH ELECTRODE CROSS SECTIONS 9
FIGURE 6: ERH PROCESS FLOW DIAGRAM 11
FIGURE 7: PROJECT TEAM ORGANIZATION 19

LIST OF APPENDICES
ATTACHMENT A – PROJECT SUMMARIES
ATTACHMENT B – COST SUMMARY
MA.FRA.1460 PT Aptim 2019-05-09 acf 1

Executive Summary
TRS Group, Inc. (TRS) proposes to use our standard fixed price in situ thermal remediation (ISTR) for the removal
of chlorinated volatile organic compounds (VOCs) in soil at the Former General Chemical Corporation property
(the Site) located at 133 to 135 Leland Street in Framingham, Massachusetts. TRS is prepared to begin this
project immediately upon award and notice‐to‐proceed.
Our team of employee‐owners, dedicated to safety, offers Aptim
Environmental and Infrastructure, Inc. (APTIM) and the Why TRS?
Massachusetts Department of Environmental Protection
(MassDEP) a best‐value, robust technical approach, which
 Vast experience with ISTR
provides certainty for successful project completion.
 Excellent safety record with an EMR
The most important elements that TRS brings to this project are: of 0.83
 Our attention to health and safety, training, quality and  Abundance of local New England staff
best practices to support the project

 Our company of employee‐owners who work  Five ERH remediations successfully
cooperatively and collaboratively with our clients completed in New England

 Our experience implementing electrical resistance  Project team with >30 years of
heating (ERH) and mitigating risks and vapor exposure collective ISTR experience
to people
General Information about TRS
TRS is an employee‐owned company, which has fostered an easy to work with, collaborative culture. Employee
ownership provides a strong incentive for our people to work productively with great attention to our clients’
needs and desires. Our employee‐owners bring great ideas to projects every day because they know that cost‐
effective, high quality work is the key to their long‐term success. We consistently hear from our customers that
our staff is the best they have experienced; that our people are extraordinarily conscientious and hardworking;
and that they work cooperatively to solve problems.
Further, we strongly believe that health and safety is the most important thing that we do. Experience and
safety are inseparable when working with complex electrical systems. It is critical that we protect not only our
people, but also all others associated with our projects.
TRS has completed five ERH remediation projects in New England and nine projects with APTIM. Our extensive
project experience has allowed our staff to master the use of ISTR in complex geologies consisting of a
combination of unconsolidated soils (sand, silt and clay) and many other complex stratigraphies and lithologies.
Our staff of fifty‐five full‐time, highly experienced professionals collectively have hundreds of years of
experience in the in situ remediation industry. All our staff work solely on ISTR, with an average of over ten years
of ISTR experience. Eighty percent of our staff hold technical degrees in science and engineering disciplines;
twenty‐five percent are licensed professional engineers or geologists; and fifteen percent also hold advanced
degrees in science, engineering or business management, including master and doctoral degrees. Our
engineering staff holds degrees in seven different engineering disciplines.
The foundation of our business is built on trust with our customers, trust that has grown into repeat business.
Our customers value that we will work with them collaboratively to solve the challenges inherent in situ
remediation, with eighty percent of our customers returning to TRS for our services. Over the last few years TRS
has grown dramatically by providing honest and accurate designs and pricing.

Section 1 ‐ Project Background
The General Chemical Corporation Site was originally used as a fuel oil storage facility throughout the 1940s to
1960s. Historical petroleum releases resulted in the thin sporadic occurrences of light non‐aqueous phase liquid
(LNAPL) in a few monitoring wells and low concentrations of benzene, toluene, ethylbenzene, and xylenes and
total petroleum hydrocarbons (TPH) observed in soil and groundwater samples.
In the late 1960s to 1970s, the site operated as an industrial solvent recycler, which is responsible for a dense
non‐aqueous phase liquid (DNAPL) release, resulting in relatively high concentrations of tetrachloroethene
(PCE), trichloroethene (TCE), and 1,1,1‐trichloroethane (1,1,1‐TCA), and their breakdown products. Despite the
presence of petroleum hydrocarbons, primarily diesel range TPH, the chlorinated VOCs are detected from
samples collected from Site groundwater at concentrations greater than the Massachusetts Contingency Plan
groundwater standards and require remediation.
APTIM and MassDEP selected ISTR as the technology to reduce chlorinated VOC concentrations in groundwater
and soil at the Site. During ISTR, the subsurface is heated to temperatures where VOCs are removed via steam
stripping and distillation. ISTR is highly effective at VOC mass reduction and occurs in all soil types, regardless of
the permeability. The main overall remediation goal for the ISTR is chlorinated VOC mass removal.
Section 2 ‐ Technical Approach
TRS has developed an ISTR technical approach that is aligned with MassDEP and APTIM remedial goals for this
Site. The following subsections describe key elements of the TRS ISTR technical approach and conceptual
electrical resistance heating (ERH) design.
2.1 Target Temperature for In Situ Thermal Remediation
The primary VOCs at this site are tetrachloroethene, trichloroethene, and 1,1,1‐trichloroethane. The boiling
point of TCE is 87 degrees Celsius (°C) at an atmosphere of pressure, which is less than the boiling point of water
(100°C at an atmosphere). When a VOC is immersed in water, the combined boiling point is depressed as
described by Dalton’s Law of Partial Pressures. Dalton’s Law includes the boiling temperature of NAPLs in
contact with moist soil. Consequently, the VOC/water interface will boil when the vapor pressure of the VOC
plus the vapor pressure of water are equal to the ambient pressure. As described in Table 1, the boiling
temperature of TCE when in contact with water is 73°C, which is lower than the boiling point of pure TCE.
Table 1: Boiling Temperatures of Primary Site VOCs
Boiling Temperature in Boiling Temperature in
Compound
Contact with Air Contact with Water
Pure Water 100°C 100°C
Tetrachloroethene 121°C 88°C
Trichloroethene 87°C 73°C
1,1,1‐Trichloroethane 74°C 65°C
Once subsurface heating starts, the boiling points of VOC/water mixtures are reached in the following order:
separate phase NAPL in contact with water or soil moisture, followed by dissolved VOCs, and finally,
uncontaminated groundwater. This order is advantageous for remediation because contaminated water will boil
off before uncontaminated water, reducing the time and energy required to complete treatment.

2.2 Electrical Resistance and Thermal Conduction Heating
During ERH, the entire soil volume is heated uniformly such that all parts of the treatment zone achieve a similar
and sufficient amount of thermal treatment. Uniform treatment occurs because the fast‐flowing current in the
soils is responsible for the heating rather than the rate‐limited thermal conductivity of the soil. With thermal
conduction heating (TCH), the heat is generated at the heater well and it must be pushed out into the formation
by a temperature gradient. The rate of heat spread is quite slow due to the low thermal diffusivity of the soil.
This effect has been demonstrated well in sand‐box studies using infrared imaging, as illustrated in the figures
below.

Figure 1: ERH Uniform Heating (left) and Conduction Heating (right) Profile

The sandbox studies were identical in shape, size and construction and each had the same amount and type of
soil (Figure 1). One study simulated ERH, while the other simulated TCH, with identical element or heater well
spacing and operating at the exact same power. As the figures show, the ERH system quickly delivered its power
uniformly throughout the entire sandbox, while the conductive heating system could only heat the soil around
the heater well in the same time frame. This is because the rate of heat propagation in soil is limited by thermal
diffusivity to an average of less than 1 inch per day.
The uniform heating provided by ERH results in important advantages for a site with an overlying building and
co‐mingled TCE and petroleum hydrocarbon contamination as found at the Site. The ERH and TCH schematics
below provide another depiction than the actual data above.
200 to 400˚C
20-30°C
20 to 30˚C
95-105°C
73 to 105˚C
ERH TCH
Figure 2: Uniform Heating of ERH and TCH Superheating Schematics

To create temperatures in the subsurface that can volatilize TCE, or other volatile organic compounds (VOCs),
and to conduct the heat front several feet away from the TCH heater well, it is necessary to establish a
temperature gradient that exceeds 100°C within the region from the heater well to the remediation (boiling)

region. During TCH, the subsurface can be divided into a superheated region (>100°C) near the TCH heater wells
(Figure 2), a remediation region where active boiling is occurring (73°C, for TCE, to 100+°C), and an unheated,
untreated region (20 to 30°C). A TCH remediation is successful when the remediation regions overlap, and VOC
mass reduction occurs throughout the entire treatment volume.
When using TCH, subsurface temperatures typically exceed the target temperature within a significant amount
of the targeted treatment volume, approximately 15 to 30%. A side effect of superheating is the volatilization of
VOCs that are not site contaminants of concern (COC), such as higher boiling compounds like diesel, which is
present at the Site. The uniform ERH temperature can effectively volatilize site COCs, such as TCE, and avoid a
significant amount of petroleum hydrocarbon volatilization in comparison to a TCH remediation approach.
2.3 Electrical Resistance Heating Technology Description
ERH is an in situ thermal technology that uses the resistance of soil to generate heat in the subsurface and
reduce VOC concentrations in groundwater and soil. The subsurface can be heated to the boiling point of water.
Groundwater and soil moisture are converted to steam and, as a result, VOCs are removed via steam stripping
and distillation.
ERH uses commonly available electricity and delivers it to the subsurface through electrodes. TRS can install the
electrodes vertically to any depth, at angles or horizontally underneath operating facilities and surface
structures, and in the presence of buried utilities. The technology is equally effective in soil and most bedrock,
and in the vadose and saturated zones. ERH passes an electrical current through the soil, rock, and groundwater
that requires treatment. The principal current path is the thin layer of water immediately adjacent to the soil or
rock grains. Relatively little current is carried by the water in the soil pores. The electrical current warms the
subsurface and then boils a portion of the moisture into steam (Figure 3). This in situ steam generation occurs in
all soil types, regardless of permeability, even in very low permeability clay and rock. Sedimentary rock usually
has significant primary porosity and the rock grains generally have the thin film of water required for ERH.
The subsurface electrical energy evaporates the target contaminants and provides steam as a carrier gas to
sweep VOCs to the vapor recovery wells. After condensing the steam and cooling the extracted air to ambient
conditions, TRS treats the VOC vapor using conventional methods, such as granular activated carbon or thermal
oxidizers (Figure 3).
Figure 3: ERH Remediation Process (not site‐specific)

A unique feature of the TRS system is our patented electrode design. The conductive, permeable backfill in the
TRS electrode includes zero valent iron (ZVI). The reductive dehalogenation process that takes place at the
electrode backfill is the same as that produced by an iron‐filing remediation wall. The ZVI reacts with the
chlorinated VOCs to produce conductive chloride ions that reduce the local resistance. This process begins
immediately after installing the electrodes. The conductive ions have time to diffuse outward from the
electrodes during the interval between electrode installation and start‐up. This diffusion occurs in all soil types,
regardless of permeability; however, because the ZVI reacts with the contamination itself, the TRS ERH process
automatically adapts to direct more energy where it will do the most good, into the most‐contaminated depth
intervals.
Although volatilization will be the primary removal mechanism for chlorinated VOCs at the Site, TRS has
documented on several sites that a significant fraction of the VOCs will be degraded in place by other in situ
processes, such as hydrolysis of 1,1,1‐TCA, conversion of total organic carbon (TOC) to dissolved organic carbon
(DOC), abiotic reactions with soil mineralogy, mass transfer of DNAPL and sorbed contaminants to aqueous
phase contaminants, and enhanced biodegradation.
Heat accelerates most chemical reactions including the breakdown of the COCs and the breakdown of naturally
occurring materials such as soil humus or TOC. PCE, TCE, cis‐1,2‐dichloroethene (cis‐1,2‐DCE), and vinyl chloride
(VC) are degraded by anaerobic microbes through the following pathway:
PCE → TCE → cis‐1,2‐DCE → VC → ethene
Thermophilic (heat‐loving) bacteria are an important contributor in the first two steps of the above chain. For
this reason, slight increases in TCE during implementation of an ERH remediation should be anticipated;
however, any TCE increases would be insignificant in comparison to the PCE decreases. Each of the daughter
products of the breakdown products (TCE, cis‐1,2‐DCE, and VC) have lower boiling points than PCE and will be
volatilized along with the PCE.
When the subsurface is heated, much of the naturally distributed TOC that is in the soil exists as long chain
humic and fulvic acids break apart into smaller compounds with increased water solubility. Thus, heating speeds
the conversion of TOC into dissolved organic carbon (DOC). This conversion makes the organic carbon
bioavailable, creating an in situ electron donor, or “bug food,” for microbial growth and accelerates the Site
bioremediation activity.
In the months and years after ERH treatment is complete, the heat will slowly spread away from the treatment
region to the surrounding soil and increase the rate of bioremediation. The DOC concentrations will slowly
return to baseline levels as the microbes grow.
2.4 Volatile Organic Compound Mass Estimate
Initially, TRS provided our own VOC mass estimate based on select data provided by MassDEP. After working
with APTIM and MassDEP project team members over the last month, TRS recognizes the comprehensive
historic and recent data and existing conceptual site model available to our team. As a result, TRS used the
APTIM VOC mass estimate based upon average analytical concentrations with further area subdivision in our
site‐specific ERH modeling and conceptual design (Section 2.5 below).
2.5 Electrical Resistance Heating Conceptual Design
TRS uses a proprietary series of engineering and cost computer models during the design of its ERH systems. This
model has been calibrated, refined and adjusted for accuracy based on in‐house research and development and
empirical data collected from over 150 operating ERH projects performed over 20 years. Some typical data input
into the model for this project include the data shown in Table 2 below.

Table 2: ERH Design Parameters and Engineering Model Input
Site Parameter ERH Model Input
Total Treatment Area 4,750 ft2
Target Treatment Volume 2,700 yd3
Area 1: 10 ft
Area 2A: 15 ft
Area 2B: 15 ft
Target Treatment Depth
Area 2C: 20 ft
Area 2D: 25 ft
Area 2E: 30 ft
1,1,1‐trichloroethane,
methylene chloride,
Primary Contaminants of Concern tetrachloroethene, trichloroethene,
(and breakdown products including
cis‐1,2‐dichloroethene)
Soil Type Fill material, sand, silt‐fine sand, till
Groundwater Elevation 7 ft bgs (conservative estimate)

During ERH system construction, TRS will fine‐tune the cable design by performing single electrode resistance
testing (SERT) at the electrodes. TRS uses this data to determine the actual resistivity values of soil across the
Site, including the variability in resistivity with respect to depth and spatial location. We incorporate this data
into the final model and adjust the electrode target voltage values appropriately to account for variability to
assure optimal thermal treatment. TRS will never ask for a change order based on variable soil resistivities.
Key design components of the TRS ERH engineering model output for the conceptual project design are
summarized below in Table 3.
Table 3: ERH Model Output
ERH System Component ERH Model Output
Electrodes 27
Electrode Spacing 16 feet
Vapor recovery flow 510 scfm
Temperature Monitoring Points 4 (5 sensors each)
Power Drop Requirement 480 volts, 1400 amps
760,000 kWh (additional 80,000 kWh for
Total Energy including Equipment
surface equipment)
VOC Mass Estimate 8,189 pounds
Steam Production 70 scfm
Average Operating Power 333 kilowatts
Days of Operation 86 ‐ 115 days

The site‐specific ERH system is designed to deliver 760,000 kilowatt hours (kWh) of electrical energy to the
subsurface, efficiently using 27 electrode locations in ERH treatment areas 1 and 2. The locations of the vertical
bored electrodes are described in Figure 4. Detailed cross sections for the electrodes are shown in Figure 5. Each
electrode will have a co‐located vapor recovery screen within the electrode borehole.


Figure 4: ERH Electrode Site Plan


Figure 5: ERH Electrode Cross Sections
The TRS ERH system will consist of the primary system components identified in Table 4.


Table 4: ERH System Components
Primary System Component Quantity
700 kW power control unit 1
Monitoring, control, and data
1
acquisition system
Remote access and control system 1
Electrodes 27
Temperature monitoring points 4
27, co‐located with
Vapor recovery wells
electrodes
Hydraulic management wells 2
Oil and water separator 1
Steam condenser 1
40‐hp vapor recovery blower 1
Liquid phase granular activated
2
carbon vessels (200 lbs each)
Vapor phase granular activated
2
carbon vessels (10,000 lbs each)
2.6 Hydraulic Management
Typically, TRS recommends the use of a hydraulic management system when groundwater flow velocities are
greater than a foot per day (ft/d). Although the Site groundwater flow velocity is less than that, TRS will install
two hydraulic management wells immediately downgradient of ERH Treatment Areas 1 and 2 as a precautionary
measure. Operation of the hydraulic management system will only be initiated if elevated temperatures and
groundwater VOC concentrations are detected outside of the ERH treatment volume.
2.7 Process Vapor Treatment
The process flow diagram describes the conceptual treatment of extracted steam, soil vapor and groundwater
with TRS‐owned process liquid and vapor equipment (Figure 6). TRS recommends using granular activated
carbon for process vapor treatment. As requested by MassDEP, TRS evaluated the use of the TRS‐owned steam
regenerative granular activated carbon (SRGAC) unit for process vapor treatment. Although the SRGAC unit
would be effective at treating the site VOCs, it would add approximately $308,000 to TRS project costs.
2.8 Process Liquid Treatment
TRS will install an oil and water separator at the Site. Although LNAPL and DNAPL is not anticipated, TRS
recognizes there is significant VOC mass present. Based on our experiences at similar sites, TRS will install and
operate this unit to prevent unplanned shutdowns and unexpected costs associated with potentially processing
LNAPL and DNAPL directly in the steam condenser.

Additionally, TRS recommends using granular activated carbon for process liquid treatment, as indicated in
Figure 6.

Figure 6: ERH Process Flow Diagram

Section 3 ‐ Description of Work
TRS and APTIM have developed a scope of work to help prevent unnecessary markupsThis scope of work split is
described in the subsections below.
3.1 Design, Permits and Plans
This section describes the ERH design, permitting and planning tasks and the corresponding responsible
company.
TRS tasks:
 Attend project kick‐off and pre‐construction meetings with APTIM and MassDEP personnel and other
relevant parties, as determined by APTIM after project award
 Prepare and submit a project schedule and proposed invoice schedule to APTIM within a week after
project award
 Organize and conduct bi‐weekly conference calls with APTIM to discuss design progress and
developments
 Prepare design drawings for APTIM review. The ERH design package will including the following:
o ERH technology description
o Design criteria and assumptions
o Design drawings, including
 Electrode layout
 Process equipment layout
 Vapor recovery and piping layout
 Security system and fencing drawings
 Process and instrumentation diagram
 ERH electrode construction details
 Hydraulic management well details
 Temperature monitoring point construction details
 Electrical single line diagram
o ERH‐specific Health & Safety Plan within four weeks of project award
o Project Work Plan within four weeks of project award, detailing at a minimum:
 Site description
 Project organization and responsibilities
 ERH treatment process description
 Technical approach
 Project schedule
 Sequence of work
 Description of ERH components and equipment

 Mobilization and Site preparation
 Subsurface installation tasks
 Waste management
 Surface installation tasks
 Start‐up and shake‐down
 Site operations and maintenance
 Demobilization and Site restoration
 Reporting
o Prepare final drawings and plans following APTIM reviews, if needed
 Prepare a material takeoff
APTIM Tasks:
 Review and provide comments on all plans and design drawings
 Obtain permits for water and air discharge
 Install a 1400‐ampere, 480‐volt power drop and connect ERH equipment to it
 Provide water and sewer connections
 Facilitate submittals and access agreements with the property owners
 Serve as the client interface
3.2 Materials Mobilization
This section describes the mobilization of all materials that will be procured and delivered to the Site in
preparation of the installation activities.
TRS Tasks:
 TRS will place orders for all items required for subsurface installation activities. This task includes
procurement time and expenses to secure the following items:
o Electrode conductive plate elements
o Conductive backfill materials
o Stainless steel well screens for vapor recovery
o Hydraulic management well pumps
o Cable electrode heads
o Resistive temperature detectors
o Drip tubes and solenoids
o Vapor recovery system hose, piping and connective fittings
o Temperature monitoring point casing materials
o Emergency eye wash station, restroom facilities and trash disposal
 Provide all surface cable for above‐ground electrodes and transformers
 Provide all chlorinated polyvinyl chloride piping for the vapor conveyance system

 Provide instrumentation for process piping controls and monitoring
 Provide communication control boxes and all communication wire for transmission of data to the TRS
data acquisition system
 Provide a fork lift or crane to remove deliveries from truck
3.3 Subsurface Installation
This section describes the ERH subsurface installation task and the corresponding responsible company.
TRS tasks:
 Call for a utility marking service prior to performing any subsurface work activities
 Perform a ground penetrating radar survey with a private locate company to identify any potential
buried utilities not identified by the utility marking service
 Survey in the location of all electrodes
 Perform all concrete coring activities
 Procure a local drilling subcontractor to install electrodes with co‐located vapor recovery, hydraulic
management wells and temperature monitoring points
 Supervise and manage all drilling activities. TRS assumes boring logs and/or geologic logging is not
required for drilling activities and all drilling will be performed in Level D personal protective
equipment.
 Provide all specialty, conductive backfill materials used in electrode construction
 Manage the collection of drilling spoils to support waste disposal by Aptim
APTIM tasks:
 Abandon any existing polyvinyl chloride monitoring wells and any other wells located within 20 feet of
the ERH treatment volume
 Provide roll‐off containers for storage of drilling spoils
 Transport and offsite disposal of drilling spoils and other investigation derived wastes
 Perform waste characterization and manifest preparation of the wastes generated during drilling
activities. TRS estimates that 30 tons of contaminated soil cuttings will be generated from drilling
activities.
3.4 Surface Installation and Start‐up
The section provides a detailed description of ERH surface installation and start‐up tasks and the corresponding
responsible company.
TRS tasks:
 Perform SERT testing on ERH electrodes to finalize ERH electrode cable design
 Provide surface insulation
 Provide a custom‐built power control unit (PCU) with operating system for remote telemetry
 Provide wireless internet connection for remote data communication

 Provide and install an internal security system. TRS will provide the security sensors and security
monitoring system on a rental basis for the project. The security will be interlocked to the TRS PCU to
prevent contact with voltage should unauthorized access occur into the treatment area.
 Install TRS‐owned, custom built steam condenser including a heat exchanger, separator tanks and
cooling water recirculation system
 Install a 40‐HP vapor recovery blower with noise enclosure and capable of a total capacity of up to 800
standard cubic feet per minute
 Provide an oil and water separator
 Provide two 200‐lb Liquid Granular Activated Carbon (LGAC) vessels, each filled with carbon
 Provide transformers to regulate voltage
 Provide a crane to off‐load equipment from trucks and stage the equipment, as it arrives
 Provide cable infrastructure for the electrodes (note that TRS cables, controls and other above‐ground
items are rented equipment owned by TRS)
 Provide the piping and fittings necessary to connect the vapor recovery wells to the inlet of the steam
condenser and to connect between our steam condenser, vapor recovery blowers, and vapor treatment
systems
 Flow measuring devices and vacuum gauges. Please note, flow cannot accurately be determined in
pipes or other locations containing steam.
 Provide and install a temperature monitoring system, interlock wiring between all system components,
and a remote monitoring system
 Provide secondary containment for the steam condensers, oil water separator and LGAC vessels
 Complete electrical connections downstream of the PCUs, including power connections to the
condensers, cooling towers, and vapor recovery blowers and to the transformers and electrodes
 Perform proprietary ERH system startup procedures
 Verify performance of the data acquisition system
 Perform ERH system security and safety interlock system functionality testing
 Perform ERH system voltage safety checks within 50 feet of an electrode
 Conduct ERH system safety training with APTIM, MassDEP and any other site personnel, as required
APTIM tasks:
 Provide three (a lead, lag, and backup) 10,000‐lb vapor phase granular activated carbon (VGAC) vessels,
each filled with carbon
 Replace the metal sheeting fence for the adjacent property along the northern site boundary. This
replacement is applicable to the metal portion of the fence within 50 feet of the ERH treatment area.
3.5 System Operations, Monitoring and Reporting
The ERH operations, monitoring, and reporting task breakdown for this project is provided below.
TRS tasks:
 Operate TRS equipment listed above
 Conduct oversight and monitoring of the heating, vapor recovery, temperature monitoring and safety
systems

 On‐site checks, including electrode current surveys and voltage surveys
 Perform maintenance on ERH equipment and various components
 Prepare weekly operational status reports provided in electronic format weekly. Reports include
temperature, power, energy, and condensate rates along with recommendations for confirmatory
sampling and system optimization.
 Provide response to any ERH system alarms or emergency response
 Replace spent LGAC, as necessary
 Transfer any recovered LNAPL recovered from oil water separator to 55‐gallon drums
 Provide APTIM with standard operating procedures and training to perform safe sampling at the Site
after the performance objectives are achieved
APTIM tasks:
 Replace spent VGAC as necessary and arrange for off‐site regeneration of the spent VGAC.
Approximately 80,000 pounds of VGAC is estimated to support ERH operations.
 Hire confirmatory soil sampling drilling subcontractor for the verification sampling efforts
 Perform condensate sampling of the ERH treatment system
 Perform vapor sampling of the ERH vapor treatment systems
 Pay for electricity used during the ERH remediation
3.6 Demobilization and Final Reporting
This section describes the ERH system demobilization and final reporting tasks and the responsible party.
TRS Tasks:
 Remove all above grade temporary structures, piping, and equipment that TRS placed at the site. TRS
provides TRS‐owned equipment and cable as rented items to the project and maintains ownership of
these items at project completion.
 Continue vapor recovery for 5 days after the cessation of heating, if desired
 Abandon all electrodes by grouting the upper three feet of the electrodes and grouting the entire casing
for the vapor recovery screens, temperature monitoring points and hydraulic management wells
 Prepare and submit a final report and include the following topics:
o Site background
o Site parameters
o Project objectives
o ERH design approach
o ERH system construction description
o Energy delivery and usage summaries
o Temperature profiles at various points during operation
o Mass removal estimates
o ERH performance results
APTIM tasks:

 Disposal of VGAC, LGAC, and LNAPL
 Terminate connection at electrical utility and disconnect from PCU
Section 4 ‐ Schedule
The schedule for implementing the ERH remediation includes the notice to proceed on approximately June 3,
2019. TRS is committed to performing ERH system operations during the summer of 2020, as requested by
MassDEP. The completion date for the project is October 2, 2020.
The general sequence of the ERH remediation activities includes the following:
 Notice to proceed: June 3, 2019
 ERH system design and permitting: June 3 to July 8, 2019
 Site preparation and materials mobilization: July 8 to July 26, 2019
 Subsurface installation: July 29 to August 23, 2019
 ERH surface construction: August 26 to September 27, 2019
 ERH equipment mobilization and construction: May 4 to May 15, 2020
 System shakedown and start‐up testing: May 18 to May 29, 2020
 ERH system operations: June 1 to September 4, 2020
 Demobilization: September 7 to October 2, 2020
Section 5 ‐ Safety, Training, Quality and Best Practices
The TRS Quality Assurance program helps ensure that TRS provides outstanding value. During the design, build
and operations process, TRS conducts internal reviews to make sure our that our ERH systems will meet or
exceed the project requirements.
Further, TRS is committed to its Behavioral Based Health and Safety Program (BBS), protecting the health and
safety of all participants during hazardous waste/hazardous substance site work. The BBS program complies
with U.S. Department of Labor, Occupational Safety and Health Administration regulations under 29 CFR
1910.120. Its primary purpose is to provide the safest workplace possible for all persons working on or coming in
contact with a TRS site. BBS objectives focus on reducing incidents (personal injury, property damage, lost time,
etc.) and near misses, improving the safety at our worksites, and improving processes and procedures.
Safety is the most important part of TRS’s business, superseding quality control, scheduling, site operations, cost
control, and employee relations. TRS has an excellent safety record, with an EMR of 0.83.
Each TRS employee‐owner is responsible for actively participating in TRS’s BBS Program and preventing incidents
Additionally,the employee‐owner has the implicit right and obligation to stop work if any unsafe action or
situation is encountered. Every supervisor is required to take all necessary actions to prevent incidents through
training, enforcement of safety rules and site specific guidelines, and any other means necessary. Each
employee‐owner is held accountable for learning to perform work in a safe manner and understanding the site‐
specific health and safety guidelines. Satisfactory safety performance is considered a condition of employment.

Section 6 ‐ TRS Project Experience
TRS has extensive ISTR project experience. We have performed ERH remediation on some of the largest and
most complex projects in the world, including ten completed projects at US Environmental Protection Agency
(EPA) Superfund sites with four ongoing Superfund projects. Additionally, TRS has successfully cleaned dozens of
sites that were of similar size, depth interval and treatment volume as this site, as well as many that were larger,
more complex geologic units and deeper heating. Further, we have applied ERH on sites with similar or more
difficult hydrogeology, including low permeability clays (as low as 10‐8 cm/sec) and silts, sands, gravels, large
rocks, glacial till and bedrock, and groundwater flow velocities as high as 20 feet per day in subsurface paleo
channels.

We have applied ERH in areas as large as three acres with treatment depth intervals as deep as 130 ft bgs and
with treatment volumes larger than 100,000 cubic yards. We have applied ERH at sites with depths to
groundwater as shallow as 1‐2 ft bgs and as deep as 60 ft bgs. The TRS ISTR equipment fleet includes enough
capacity to execute 18 to 20 ERH projects simultaneously and includes: custom‐built PCUs, steam condensers,
vacuum blower packages, a steam regenerated granular activated carbon system, thermal oxidizers with acid
scrubbers, and a variety of system accessories.

Our fully integrated team has performed over 150 ERH projects under the supervision of some of the
environmental remediation industry’s most demanding clients, including the DOD, DOE, USACE, EPA and many
Fortune 500 companies. We have created and implemented programs for source area delineation, sample
collection and analyses, air monitoring, hot soil and groundwater sampling, health and safety, and QA/QC that
meet the standards of each of these groups. Having worked under and adopted the EPA Triad management
system, we are also experienced in developing near real time site data sets using multiple lines of evidence for
presentation to project stakeholders.

The table below is a summary of our company and project history and experience.

Number of
ERH Projects Number of Number of Full
ERH Guaranteed ERH Number of
Years in Completed & Full Time Time Staff/
projects in Projects ERH Projects
Business Ongoing in Staff in EPA Degrees/PE or
U.S. Completed & with APTIM
USEPA Region 1 Region 1 PG
Ongoing
19 >150 42 / 6 9 5 / 1 5 55 / 43 / 15

Recently, TRS completed two ERH remediations with chlorinated VOC remedial goals within the presence of
petroleum hydrocarbons. One project in the state of Washington was completed for the USACE Seattle District.
ERH was performed at the Tacoma Well 12A Superfund Site for the remediation of chlorinated VOCs. LNAPL was
present during the remediation, although it did not have a remedial goal.

Another project was in Asheville, North Carolina and concluded a few months ago. Similar to the Washington
site, there was a chlorinated VOC remedial goal of 95% TCE reduction. The site contained a significant amount of
diesel with a 15‐foot thick smear zone across one acre. Even with the heavy impact of diesel, the ERH system
achieved a 97% reduction of TCE in soil and a 99% reduction of TCE in groundwater.

Project summaries are provided in Attachment A. Additionally, contact information is provided below.

Tacoma, Washington Project:
 Tamzen Macbeth, CDM Smith, macbethtw@cdmsmith.com, (208) 904‐0238

 Kira Lynch, USEPA, Region 10, lynch.kira@epa.gov, (206) 553‐2144
Asheville, North Carolina Project:
 Susan Avritt, Wood Group, susan.avritt@woodplc.com, (828) 252‐8130
 Craig Zeller, USEA Region 4, zeller.craig@epa.gov, (404) 273‐7072
Section 7 ‐ TRS Project Team
TRS employee‐owners consist of 55 full‐time, highly experienced professionals who collectively have hundreds of
years of experience in the in situ thermal remediation industry. Many of our staff in the early 1990s started their
careers in the in situ air movement remediation business, including the design, construction and operations of
soil vapor extraction, air sparging and multi‐phase extraction remedial systems. In the late 1990s we combined
in situ thermal remediation with our in situ air movement expertise to launch ISTR in the commercial
marketplace. All our staff work solely on ISTR, with an average of over ten years of experience. Only TRS
employees operate our field equipment. We consistently hear from our customers that our employee‐owners
and the projects they complete are the best they have experienced. They also tell us our staff are conscientious
and hardworking individuals who work collaboratively with them to solve remediation challenges at their sites.

TRS has prepared a qualified local team to support this ERH remediation. The team and its organization are
described in Figure 7 and paragraphs below.
MassDEP
APTIM
TRS Group
Greg Knight, Robert Poulin
Emily Crownover, Ph.D.
Safety and Senior Project
Lead Engineer
Quality Manager Manager
Sean Fournier
QSAT Team Staff Engineer
Project Manager
Local Driller
ERH Operations
System Specialist

Figure 7: Project Team Organization

Robert (Bob) Poulin, TRS Senior Project Manager, will be our primary point of contact. Bob is located in Hollis,
New Hampshire, and has been a full‐time TRS employee for ten years, working exclusively with ISTR

remediation. He has managed several dozen ERH remediation projects and has made significant contributions to
the design, construction and operational improvements that TRS employs today. Bob has managed 15 ERH
projects in EPA Regions 1 and 2 and has recently managed our ERH remediation project at an EPA Superfund site
in Sparta, New Jersey. Bob brings staff and subcontractor supervision experience and the ability to navigate the
regulatory requirements for all aspects of a remediation project.

Sean Fournier, TRS Project Manager, directly reports to Bob and will support this project at the Site. Sean is
located in Templeton, Massachusetts and will manage the day to day activities. He has managed ten ISTR
remediation projects, two in Massachusetts. He offers the project team a tremendous amount of hands‐on
construction and project management experience.

Emily Crownover, Ph.D., TRS Lead Engineer, will support Bob and will lead the design for this project. Emily is
located in St. Louis, Missouri. Emily has advanced within TRS from a Research and Development Engineer to
Senior Lead Engineer, managing staff within our engineering department. Her work on numerous ERH projects
has included the design of ERH systems and on‐site roles as a project engineer and project manager.

Greg Knight, TRS Safety and Quality Manager, manages the TRS health and behavior‐based safety programs. He
provides training programs to ensure TRS ERH projects remain safe, addressing client‐specific safety
requirements. Greg has worked in the TRS operations group for 14 years and has intimate experience with all
aspects of TRS field operations. Additionally, Greg manages our QSAT team (quality, safety, assets and training).

The ISTR and remediation experience for the primary project team members are described below.

Project Team Member Years of Remediation Experience Years at ISTR Experience
Robert Poulin 19 10
Sean Fournier 27 8
Emily Crownover, Ph.D. 11 5
Greg Knight 22 14

Our proposed project team has performed most of our ERH remediation projects located in the eastern portion
of the United States. Additionally, TRS also has four operations employee‐owners living less than two hours from
the site.

TRS uses standard project management controls to track the project schedule and progress, while looking
forward to important critical path items. Additionally, the QSAT team plays an important role in assuring that
work is performed on schedule and in a safe and technically competent manner.
Section 8 ‐ Contracting
The conract for the ERH remediation will be between APTIM and TRS. The contract terms have not been finalized
and may affect TRS pricing. Given our experience working with APTIM on other ERH remediations, a quick
resolution of contract terms is anticipated.
The contract will be a standard fixed price remediation contract based on the assumptions provided in this
proposal. TRS will continue to operate until the design remediation energy (760,000 kWh) has been input to the
subsurface or the remediation system has operated for 96 days, whichever occurs first. If MassDEP and APTIM
requests TRS continue to operate the ERH system for continued mass reduction beyond the design remedation
energy or design schedule, a weekly rate of $27,400 is applicable.

Any applicable state taxes will be added to each TRS invoice as the ERH remediation has been priced assuming
all work is Massachusetts sales tax exempt. Additionally, TRS has assumed prevailing wage rates are not required
for this project.
Our pricing includes the assumption that others do not delay TRS’ work. In the event TRS’ equipment is on‐site
while others delay system installation and construction tasks, startup activities, operations, or demobilization, an
equipment standby rate of $3,400 per day will apply. If TRS is required to work at a reduced pace (e.g. limit ERH
power application), then the equipment standby rate will be applied pro rata in proportion to the limitation.
Because of the volatility in the commodity markets, the terms of this proposal and pricing are valid for 30 days
from the date of this proposal. In the event of a prolonged delay, price adjustments may be required.
The proposal is based on payment terms of net 30 days from the date of our approved invoice. TRS assumes the
contract for this project will be awarded all at once and that notice to proceed (NTP) will be provided for the
entire project. If the client elects to issue NTP for individual task items, TRS will add 5% to each task item.
Section 9 ‐ Pricing
Total compensation to TRS for work activities described in this proposal is $1,199,000. The pricing for this project
is described in the Cost Summary, provided in Attachment B.
Payment for the Materials Mobilization task is due prior to starting field work. TRS will coordinate with APTIM to
schedule the invoice for this task to allow for complete invoice processing on a convenient schedule. Other than
the Materials Mobilization task, TRS will invoice monthly on a percent complete basis.

Attachment A
ERH Remediation of
CVOC’s at Well 12A
Superfund Site
-Tacoma, Washington
Project Objectives:
 90% Reduction of COC soil
concentrations in vadose
and saturated zones
Site Characteristics:
 3 Treatment areas
totaling 27,900 yd³
 Vadose & saturated zone:
sand, silt, clayey silt,
glacial till, gravel
 568mg/kg CVOC baseline
ERH Site Overview concentration
 Integrated Multi-phase
Goal: 90% Reduction extraction system
Post- ERH: 94.5%
reduction, 22,307 lb  Estimated 409lb of mass
mass removal  Electrode field under
active facility and
roadway
Operations:
 Total run time: 117 days
 4,025,919 kWh applied
 Maximum Temp: 96.8°C
Results:
 22,307lb mass removed
 94.5% reduction of COC’s
CVOC monitoring well concentrations pre- & post-ERH
Contact TRS Group: For more information

Mark Kluger and other project examples,
VP Sales & Marketing please visit:
302-655-6651 www.thermalrs.com
ERH Remediation at
Complex Superfund Site
- North Carolina
Fixed- Price Remediation

Goal: 95% reduction of TCE in
soil, groundwater, and LNAPL
from baseline concentrations
Site Characteristics
• Treatment volume: 51,583 yd³
• Water table to bedrock
• Variable electrode depth and
thickness based on bedrock
ERH Equipment Compound refusal
60,000
• 16,523 µg/L TCE baseline
*Site Average 95.4% Operations
Concentration Reduction
Total VOC Groundwater Concentration (µg/L)
50,000
• Total run time: 159 days
40,000 • Avg temp: 104°C
• 8,842,536 kWh applied
30,000 • 7,550 lb CVOC removed
20,000 Results
10,000
• Exceeded RAO of 95%
reduction TCE in soil,
0 groundwater and LNAPL
• Removed 14,000 gallons of
MW-31
MW-28
MW-29
MW-32
MW-2
MW-30
MW-26A
MW-24
fuel oil from subsurface

MW-31A
MW-27
MW-25
MW-23
MW-3
Pre-ERH
MW-23A
MW-25A
MW-30A
MW-26
Post-ERH
MW-29A
MW-24A
MW-28A
Average
TCE monitoring well concentrations pre- & post-ERH
Contact TRS Group: For more information

Mark Kluger and other project examples,
VP Sales & Marketing please visit:
302-655-6651 www.thermalrs.com
Attachment B
General Chemical Corporation Remediation Parameters
www.thermalrs.com
Area 2A‐2E
Treatment Volume: Area 1 Avg 19 ft TTZ
Electrical Resistance Heating Treatment Area: 4,750 sq. ft 1,500 3,250
Average Target Shallow Extent of Heating: 1 ft 1 1
Average Target Deep Extent of Heating: 17.7 ft 10 19 (weighted average)
Typical Depth to Groundwater: 7 ft
Treatment Volume: 2,900 cu. yd 800 2,200
Is a New Insulating Surface Cap Required? yes, 100% coverage
Subsurface Components:
Number of Electrodes: 27 8 19
Electrode Boring Diameter (in.): 12.0 12.0
Average Distance Between Electrodes: 16 ft 16 16
Avg. Total Depth of Electrodes: 18.8 ft 16 20 (weighted average)
Avg. Depth to Top of Electrode Conductive Zone: 2 ft 2 2
Number of Co‐located Vapor Recovery Wells: 27 8 19
Number of Temperature Monitoring Points: 4 (avg. 5 sensors each)
Number of Hydraulic Management Wells: 2
Contaminant Information:
Average Clean‐up Percent: 95%
Client‐provided VOC Mass Estimate: 8,189 lb
Vapor Recovery and Condensate Streams:
Vapor Recovery Air Flow Rate: 510 scfm
Vapor Treatment Method: carbon
Assumed Activated Carbon Required: 80,000 lb
Condensate Production Rate: 0.3 gpm
Electrical Information:
Power Control Unit (PCU) Capacity: 700 kW
Average Electrical Heating Power Input: 333 kW
Total Heating Treatment Time: 86 ‐ 115 days
Bid Energy (kWh): 760,000 An additional 80,000 kWh is used by surface equipment.
The above remediation parameters are estimated +/‐ 20%. Final parameters will be determined during system design.
Best and Final Standard Fixed Price for General Chemical Corporation
Price Charged by TRS Group Price
Design, Work Plan, HASP, Permit Assistance: $75,000
Materials Mobilization: $140,000
Subsurface Installation: $190,000
Surface Installation and Start‐up: $274,000
Remediation System Operation: $381,000
Demobilization and Final Report: $139,000
Total TRS Price $1,199,000
TRS invoices monthly on a percent complete basis. TRS pricing is based on net 30‐day payment terms. Add 1% for net 60 days. TRS
requires payment for materials mobilization prior to starting field work. The above price is valid for 30 days from 05/09/2019.
Prepared for Jim Collins, 617.589.4008, james.collins@aptim.com
P1460 prepared by E. Crownover on 05/09/2019

General Chemical Draft Plan

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General Chemical Draft Plan

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Charles D. Baker Kathleen A.

Karyn E. Polito Martin Suuberg

Draft Immediate Response Action Plan

Tank Farm/Loading Rack Area Remediation

Former General Chemical Corporation Site

 a portion of the downgradient Massachusetts Water Resource Authority (MWRA) property on

2.1 Historic Site Operations

2.2 Disposal Site Contamination

2.3 Source Area Concerns

3.0 Immediate Response Action Plan (310 CMR 40.0424)

3.2 Description of Disposal Site and Potential Contaminant Receptors

3.2.2 Regulation of the Site by MassDEP

3.2.3 Site Conditions

3.2.5 Completed Investigations

3.3.1 January 1995 PCE Release

3.3.2 January 2000 Critical Exposure Pathway

3.4 The Reason Why an Immediate Response Action is Required

3.5.2 Specific Plans

3.5.2.1 System Location and Design

3.5.2.3 Site Preparation

3.5.2.4 Treatment System Installation

3.5.2.5 System Operation and Monitoring

3.5.2.6 Termination, Demobilization and Final Reporting

3.5.3 Proposed Schedule

 ERH system design and permitting: January 6, 2020 to April 3, 2020

3.6 Remediation Waste Statement

3.7 Proposed Environmental Monitoring

3.7.2 Steady-State/Longer Term Operations

3.7.3 Remedial Air Emissions

3.8 Listing of Federal, State, or Local Permits required to Conduct IRA

3.9 Name of LSP who Prepared IRA Plan

4.0 Public Involvement

provide interested parties an opportunity to comment, prior to project finalization and

Former Recovery Well, Destroyed

Virgin Wetlands (Surveyed)

Groundwater & Environmental Services, Inc.

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CVOC monitoring well concentrations pre- & post-ERH

Contact TRS Group: For more information

Fixed- Price Remediation

fuel oil from subsurface

TCE monitoring well concentrations pre- & post-ERH