SUBJECT: Additional Corrective Action Work Plan
←
→
Page content transcription
If your browser does not render page correctly, please read the page content below
April 2, 2021
Mr. Alan Cubberley
Rocky Mountain Oil Company
PO Box 1224
Minneapolis, Minnesota 55440
Delivered via email: acubberley@circlek.com
SUBJECT: Additional Corrective Action Work Plan
Holiday Station Store #267, 1700 10th Avenue South, Great Falls, Montana
MDEQ Facility I.D. No. 07-08065; Leak ID #2597; WP ID# 34276
Circle K #2746276
Tetra Tech Project No.: 117-8153011.1
Dear Mr. Cubberley:
Tetra Tech, Inc. (Tetra Tech) has prepared this work plan for additional corrective action at
former Holiday Station Store #267, 1700 10th Avenue South, Great Falls, Montana (Figures 1 and
2). This work plan was prepared in accordance with Additional Corrective Action Work Plan
letter dated February 23, 2021 from Mr. Donnie McCurry of the Montana Department of
Environmental Quality (MDEQ) 1.
The MDEQ work plan request includes the following: Submit a Standardized Generic
Applications Corrective Action Work Plan (WP) AC-07 to DEQ by April 9, 2021. The WP is
expected to include the following scope of work:
• Discuss ongoing WP tasks and results with DEQ's project manager; submit written
agreed-upon WP modifications as required to complete the WP objectives.
• Restart and operate AS/SVE systems including routine operation and maintenance
activities at least quarterly through March 31, 2022.
• Assess the condition of facility monitoring wells. Be prepared to make minor repairs, as
needed. Measure the total depth of each well and compare the measured depth to the
installation depth.
• Conduct one round of groundwater monitoring at the facility during high groundwater
conditions.
• Analyze groundwater samples for petroleum constituents as required by the Montana
Tier 1 Risk-Based Corrective Action Guidance for Petroleum Releases.
• Dispose of purge water in accordance with DEQ guidance.
• Validate all laboratory analytical data using DEQ’s Data Validation Summary Form
(DVSF).
• Prepare a Release Closure Plan (RCP); discuss results with DEQ’s project manager.
DEQ expects the RCP to cover the Release investigation, cleanup, and monitoring
information. Use the RCP format.
• Prepare and submit a Generic Applications Report (AR-07) detailing the results of the
1
MDEQ, 2021. Additional Corrective Action Work Plan Required for the Petroleum Release Former Holiday Station Store #267, 1700 10th
Avenue South, Great Falls, Cascade County, Montana; Facility ID #07-08065 (TID 18686); Release 2597, Work Plan 34276. Helena, Montana.
February 23.
Tetra Tech
7100 Commercial Avenue, suite 4, Billings, MT 59101
Tel 406.248.9161 Fax 406.248.9282 www.tetratech.com
Additional Corrective Action Work Plan
Holiday Station Store #267, Great Falls, Montana
Rocky Mountain Oil Company
April 2, 2021
AS/SVE system operation and the groundwater monitoring. The Report is expected to
include all the content outlined in the Report format and the following:
o Maps, tables and boring/well logs are expected to conform to the examples in the
Remedial Investigation Guidance.
o Tabulate cumulative groundwater data.
o Append laboratory analytical data and field data.
o Append the DVSF and RCP.
SCOPE OF WORK
Task 1 - Groundwater Monitoring
Tetra Tech will conduct one groundwater monitoring event at the facility site. This groundwater
monitoring event will be conducted in May 2021. We will measure groundwater levels and
collect groundwater samples from 21 monitor wells (GHB-3s, GHB-4s, GHB-7s, GHB-8s, GHB-
9s, GHB-44s, GHB-45s, GHB-46s, GHB-47s, HGF-2sA, HGF-3s, HGF-4s, HGF-5s, HGF-6s,
HGF-9s, HGF-15s, HGF-16s, HGF-17s, HGF-18s, HGF-19s, WET-2, and WET-3; Figure 2). In
addition, we will collect fluid levels on the following wells: GHB-48s, GHB-49s, GHB-50s, GHB-
51s, GHB-52s, GHB-56s, GHB-57s, GHB-58s, WET-4, WET-5, WET-6, and WET-7.
Groundwater samples will be collected from these monitor wells using the methods detailed
below:
Depth to groundwater will be measured in each monitor well (Figure 2) using an electronic
oil/water level interface device. The device will be decontaminated between wells using a
Liquinox® soap solution, a deionized water rinse, and a final deionized water rinse.
One groundwater sample will be collected from each monitor well listed above using a
peristaltic pump and disposable polyethylene tubing. The “GHB” and “WET” wells have 1-
inch casing diameters which requires a narrow sampling device such as the peristaltic
pump. Samples will be collected using low flow method. Field parameters including
dissolved oxygen, oxidation-reduction potential, pH, specific conductivity, turbidity, and
temperature will be recorded during purging. Purged groundwater will not be collected.
One duplicate sample will be collected from a well with presumed petroleum hydrocarbon
impacts. Also, a trip blank will accompany the sample cooler during sampling and
shipment. The duplicate and trip blank samples will be analyzed for the same constituents
as the natural samples.
The groundwater samples will be preserved according to laboratory method, placed in ice
filled coolers and transported to Energy Laboratories or Pace Analytical Services, Inc. in
Billings, Montana for analysis of volatile petroleum hydrocarbons (VPH) using the
Massachusetts Department of Environmental Protection (MDEP) methods, ethylene
dibromide (EDB) using EPA Method 8011, and 1,2-dichloroehtane using EPA Method
8260.
Task 2 – SVE System Operation and Maintenance
Tetra Tech will re-start the SVE system. The electrical power must be re-stored by contacting
Northwestern Energy and have the service re-connected. We will check the vacuum and air
velocity in all SVE lines to ensure that they are not plugged. The SVE system will be checked
monthly for 12 months to determine the operational status. Also, during each monthly visit, we will
collect air velocity, vacuum, and volatile organic data using a photoionization detector (PID) or
flame ionization detector (FID) on each SVE line and SVE exhaust.
2
Additional Corrective Action Work Plan
Holiday Station Store #267, Great Falls, Montana
Rocky Mountain Oil Company
April 2, 2021
Task 3 – Reporting
Tetra Tech will prepare an AR-07 additional corrective action report after the completion of the
groundwater sampling and following receipt of analytical data describing work activities and
presenting laboratory analytical results. The report will provide conclusions regarding the
direction of groundwater flow and magnitude of petroleum hydrocarbon impacted soil and
groundwater, summary of all groundwater level and analytical data, summary of all soil data, the
completed data validation summary form, the release closure plan, the SVE system re-start
operation data, and recommendations for further work, if warranted.
An additional brief report will be prepared after the completion of the monthly SVE system
operation for a period of 12 months. This report will include the SVE system monthly operation
data.
SCHEDULE AND BUDGET
Tetra Tech will schedule this work within three business days upon receiving formal
authorization by Rocky Mountain Oil Company, MDEQ, and the obligation letter from the
Montana Petroleum Tank Release Compensation Board (MPTRCB). The work described above
will be conducted on a unit cost basis per attached cost estimate (Attachment A). This site is
eligible for reimbursement through the MPTRCB. During invoicing Tetra Tech will prepare the
MPTRCB Claim for Reimbursement for Rocky Mountain Oil Company to receive reimbursement.
AUTHORIZATION
This work will be conducted in accordance with the terms and conditions of the Master
Consulting Services Agreement between Rocky Mountain Oil Company and Tetra Tech, Inc.
dated March 28, 2017. This work plan may be accepted by signing the attached Work
Authorization #6 (Attachment B) and returning a copy to our Billings office. If you have
questions or comments regarding this work plan, please call us at (406) 248-9161. For your
convenience we have forwarded a copy of this work plan to Mr. Donnie McCurry (MDEQ).
We appreciate the continuing opportunity to provide Circle K with consulting services and look
forward to hearing from you. Please call if you have any questions or comments regarding this
work plan.
Sincerely,
Tetra Tech, Inc.
Paul E. Lemire Jeffrey R. Rice
Senior Hydrogeologist Senior Project Manager
PEL/JRR/ba
N:\TYPING\PROPOSAL\2021 Proposals\Env\Holiday 267 Work Plan\Holiday 267 March 2021 ACA Work Plan.docx
cc: Donnie McCurry-MDEQ, Helena dmccurry@mt.gov
3
FIGURES
/ Llf..99'
0
:Bank
/
-Mount Olivet
\
�•TH AVE
I
/ I ;------
II
I
I
'
-
I
3°j'J7 /
REFERENCE: ., I 0
U.S.G.S': Northeast and Southeast Great Falls Quadrangles, Cascade County, Montana -,...,..--7, .. }
7.5 minute series (Topographic), 1965, Revised 1994. ,-,;'SS
SS
SS
SS
SS
HGF-5s
SS
GHB-57s HGF-4s
SS
SS
GHB-51s
HGF-18s
HGF-19s
SS
WET-5 WET-2
WET-6 WET-4 WET-3
GHB-47s
SS
GHB-48s GHB-49s GHB-50s
SS GHB-56s (ALLEY) GHB-54s
SS
MW-11 SS SS SS SS SS SS GHB-44sSS GHB-45s GHB-46s SS SS SS
MW-10 SS SS SS SS SS SS SS SS SS
GHB-52s
NG NG NG NG NG NG NG NG NG NG NG NG NG NG NG NG NG NG NG NG NG
NG HGF-6s
SS
WET-7 GHB-9s
SS
GHB-55s
GHB-58s
NG
NG
SS
MW-9
SS
NG
SS
NG
HGF-16s GHB-7s
HGF-15s
SS
HGF-17s
(NORTH)
MW-5 MW-4
SS
NG
HGF-7s
TTV-1
MW-8
GHB-8s
NG
(BUILDING)
MW-3
MW-2
W
W
SD
MW-7
W
W
W
(SOUTH)
GHB-3s GHB-4s
SD
MW-6 MW-1 HGF-9s
W
W
W
SD SD SD SD SD SD SD SD SD SD SD SD SD SD SD SD SD SD SD SD SD SD
SD
W W W W W W W W W W W W W W W W W W W W W W
SD
W
W W W W
SD
W W W W W W W W W W W W W W W W W
W
W
SD
W
W
SD
W W W W W W W W W W W W W W W W W W W W W
W
W
HGF-3d
HGF-3S
HGF-2s-A
HGF-15s
W
HGF-2d
TTV
W
W
NG
SD
SS
W
W
HGF-14d
NG
SS SS SS SS SS SS SS SS SS SS SS SS SS SS SS SS SS SS SS SS SS SS
NG NG NG NG NG NG NG NG NG NG NG NG NG NG NG NG NG NG NG NG NG NGYou can also read
