The State of New Hampshire

Department of Environmental Services

Robert R. Scott, Commissioner

EMAIL ONLY

July 30, 2019

Lawrence Ufford, President

Trumbull-Nelson Construction Company, Inc.
19 Plaza Heights Road
West Lebanon, NH 03784

Subject Site: Hanover – Trumbull-Nelson Construction Company, Inc., 200 Lebanon Street,
DES Site #199509013 LUST Project #5950

High Resolution Subsurface Characterization Report prepared by

Pathways Consulting LLC dated May 31, 2019 (Activity #269680)

Dear Mr. Ufford:

The New Hampshire Department of Environmental Services (NHDES) has reviewed the subject report
and other information in our files regarding the petroleum hydrocarbons discharge discovered on
September 15, 1995 at the referenced site. NHDES approves the report as meeting the requirements
of a site investigation under Env-Or 606.01 and the work scope/budget approved by NHDES on
January 7, 2019. Based on our review of the current information and report conclusions and
recommendations, NHDES has the following comments:

 The subject high-resolution subsurface characterization (HRSC) activities identified a shallow

petroleum residuals plume related to the known Leaking Underground Storage Tank (LUST)
contents and a potential secondary groundwater hydrocarbons plume deeper in the natural
soil formation. It appears that the two plumes intersect and/or interact under the concrete floor
of the warehouse south of the LUST area. However, the secondary plume is characterized by
instrumentation that can detect a wide range of hydrocarbons (i.e. methane, many carbon-
containing compounds) that are not considered hazardous or have characteristics of
hazardous materials. Therefore, further investigation and characterization by sampling and
laboratory analyses of the secondary plume consisituents in the impact areas are not
Petroleum Reimbursement Fund Program (Fund) eligible for reimbursement.

 NHDES concurs with the recommendation to sample existing monitoring wells that are not
included in the current Groundwater Mangement Permit (GMP), specifically MW-2, MW-6,
MW-16 and MW-17. The groundwater samples from these wells should be analyzed for
Volatile Organic Compounds (VOCs) by EPA Method 8260C and for Polynuclear Aromatic
Hydrocarbons (PAHs) by EPA Method 8270, and methane, lead, and TPH. These monitoring
wells should be sampled in August 2019 and in November 2019 during the scheduled GMP
sampling event. Potentially, these wells can be added to the GMP by a future revision.

 NHDES also concurs with the recommendation to conduct a soil boring through the concrete
floor of the warehouse building at location OiHPT-30 (see Figure 3 of the subject submittal).
The boring should be drilled below the concrete floor into the underlying soils to a depth of 25
feet below floor grade. Soil samples will be collected every five feet of drill depth and screened
with a photoionization detector (PID) and flame-ionization detector (FID) to record field
measurements during drilling. Soil samples will be collected for laboratory analysis based on
highest readings above and below measured water table depth. The laboratory analysis shall
include: VOCs, PAHs, and total organic carbon (TOC).
www.des.nh.gov
PO Box 95, 29 Hazen Drive, Concord, NH 03302-0095
Telephone: (603) 271-3899 Fax: (603) 271-2181 TDD Access: Relay NH 1-800-735-2964
Lawrence Ufford
DES Site # 199509013
July 30, 2019
Page 2 of 2

This boring may be completed as a monitoring well based on the soils screening and its relation
to existing MW-17. A field decision will be made for a monitoring well after the boring is
advanced.

 Any further recommendations regarding additional soil borings and new monitoring wells are
related to investigation of the secondary hydrocarbon plume which appears to migrate from
upgardient on-site areas in the northeast and southeast. These investigations and data
collection efforts are not Fund-eligible under the LUST project. Also, the investigation of the
floor drain(s) and yard drainage is not Fund-eligibe but must be determined for the potential
discharge of regulated contaminants to groundwater.

Facility Compliance and Cost Reimbursement

A review of our files shows that Trumbull-Nelson Construction Company is eligible to be reimbursed
by the New Hampshire Petroleum Reimbursement Fund Program (Fund) for costs to implement
NHDES-required investigation and remediation related to the to the petroleum discharge discovered
on September 15, 1995.

To receive reimbursement from the Fund, all work must be pre-approved and conducted in accordance
with the New Hampshire Code of Administrative Rules Odb-400. Please direct your consultant to
submit a detailed work scope and budget for NHDES approval. The WSA is due within 30 days of
receipt of this letter. For additional assistance on the Fund reimbursement process and compliance
status of your facility, please contact Jennifer Marts, P.G., Petroleum Fund Management Section
Supervisor at (603) 271-2570 or by email at Jennifer.Marts@des.nh.gov.

Please do not hesitate to contact me if you have any questions regarding this letter.

Sincerely,
Waste Digitally signed by Waste
Management Division

Manageme
DN: cn=Waste Management
Division, o=Wasste, ou=ORCB,
email=michele.l.regan@des.nh.gov
Steven A. Croce, P.E.
nt Division
, c=US
Date: 2019.07.30 11:41:19 -04'00'
Oil Remediation and Compliance Bureau
Tel: (603) 271-2229
Fax: (603) 271-2181
Email: steven,croce@des.nh.gov

ec: Margaret Bastien, P.E., ORCB

Hanover Health Officer
Russell W. Rohloff, P.E., Pathways Consulting, LLC

Route/ec: Todd Piskovitz, P.G., ORCB