September 21, 2004 GeoInsight Project

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GeoInsight, Inc. GeoInsight, Inc. GeoInsight, Inc. 75 Gilcreast Road, Suite 210 319 Littleton Road, Suite 105 Corporate Ten Center Londonderry, NH 03053-3566 Westford, MA 01886 1781 Highland Avenue, Suite 207 TEL 603-434-3116 TEL 978-692-1114 Cheshire, CT 06410 FAX 603-432-2445 FAX 978-692-1115 TEL 203-271-8036 www.geoinsightinc.com FAX 203-271-8038 September 21, 2004 GeoInsight Project 3871-000 Richard Packard Massachusetts Department of Environmental Protection Southeast Regional Office Bureau of Waste Site Cleanup 20 Riverside Drive Lakeville, Massachusetts Re: Proposed IRA Cleanup Activities Leisure Shores Beach DEP RTN 4-17786 Barge B120 Spill Buzzards Bay, Massachusetts Dear Mr. Packard: GeoInsight, Inc. (GeoInsight) prepared this letter to present proposed additional cleanup activities planned at Leisure Shores Beach in Mattapoisett, Massachusetts. Refer to Figure 1 for the approximate location of Leisure Shores Beach. These cleanup activities will be conducted as part of response actions proposed in the September 15, 2003 Immediate Response Action (IRA) Plan (as modified) to remove residual oil on the shoreline associated with the release from Bouchard Barge No. 120 (B120). GeoInsight, as the Licensed Site Professional (LSP) under the Massachusetts Contingency Plan (MCP), prepared this letter on behalf of Bouchard Transportation Company, Inc. 1.0 IRODUCTION The Leisure Shores Beach is a portion of shoreline segment W1F-02 (Brandt Island West) and this segment is periodically inspected for the presence of surficial and buried oil as part of IRA response actions proposed in the September 15, 2004 IRA Plan. Discrete patches of oil, primarily in the form of small (approximately 1-inch diameter or smaller) tarballs, have been encountered at this segment and cleanup activities were conducted on April 1, April 8, April 16, May 17, and August 10, 2004 to remove the detected oil. Refer to IRA Status Reports dated February 10 and September 16, 2004 for additional information regarding these inspection and cleanup activities. Environmental Solutions at Work

GeoInsight, INC. In September 2004, oil was encountered in the lower intertidal zone at the Leisure Shores Beach in an area bounded by a rock groin to the west (with a small stream crossing the groin), and a smaller groin to the east, near a grill in the shape of a torpedo. The oil consisted primarily of small particles ranging in size from approximately 1 millimeter (mm) to 7 mm in diameter. These small particles were found as either discrete particles in the subtidal sediment, adhered to small rocks or shells, or floating on the water surface in trenches excavated by the inspection team. Initial evaluation indicated that the oil distribution appeared to be discontinuous, with some areas of the beach containing oil particles and other areas apparently free of oil particles. In response to the detection of oil in this area, GeoInsight and ERIX, Inc. (ERIX) excavated a series of trenches aligned on a grid pattern to delineate the extent of oiling. Figure 2 shows the approximate location of the trenches and includes a row and column numbering system to identify individual trench locations. Visual observations for each trench location are summarized in Table 1. A total of 113 trenches were manually excavated within the intertidal zone in the area of concern. In general, the oiling was found to be discontinuous, with oil encountered in approximately 40 percent of the trenches. The observed oiling conditions primarily consisted of small pinhead to pepper flake size particles, measuring approximately 1mm to 2mm in diameter. These small oil particles were observed floating on the water surface within the trench and were often surrounded by a rainbow sheen. Slightly larger oil particles, termed globules, measured 5mm to 7mm in diameter and were found in a smaller proportion of the oiled trenches. The number of oil particles observed in the individual trenches was generally low, ranging from 1 to 6 oil particles per trench. 2.0 PROPOSED CLEANUP ACTIVITIES The small size of the oil particles and the limited number of particles encountered during this investigation indicates that the total volume of B120 oil in this area is relatively small. Due to the small size of the observed particles and the discontinuous nature of the oil distribution, GeoInsight proposes to conduct the cleanup activities initially using oil absorbent materials. Based upon the outcome of the initial absorbent cleanup activities, other cleanup strategies will be evaluated and implemented, if necessary. The initial cleanup activities will consist of digging and turning over the beach sediment using rakes and shovels to expose residual oil. Shoreline sediment will not be removed from the Leisure Shores Beach during this cleanup operation. Oil absorbent pads or sweep (rolls of oil absorbent material) will then be placed in areas of observed oil to remove the small oil particles. Oil absorbent pads will also be placed in trenches where oil particles are observed on the water surface to remove floating oil particles. Rocks and shells with observed oil will also be wiped with absorbent material. September 21, 2004 Page 2 GeoInsight Project 3871-000

GeoInsight, INC. 3.0 SCHEDULE Because the oil observed is present primarily in the lower portion of the lower intertidal zone, cleanup and post-cleanup inspection activities must be conducted at low tide. GeoInsight proposes to initiate cleanup activities on Thursday, September 23, 2004, with September 24, 2004 available if additional cleanup is required. An initial post-cleanup inspection, consisting of trenching and test-pitting using hand tools, will be conducted on Monday, September 27, 2004. Additional cleanup, using the methodology described above, will be conducted on Tuesday, September 28, 2004, if required, with a post-cleanup inspection on Thursday, September 30, 2004. GeoInsight will evaluate alternative cleanup strategies, in consultation with the Massachusetts Department of Environmental Protection, if the September 30, 2004 inspection indicates that additional cleanup activities are necessary. Please feel free to call Kevin Trainer at (978) 692-1114 if you have any questions or if you would like to discuss this project. Sincerely, GEOINSIGHT, INC. Kevin D. Trainer, P.G., C.P.G., L.S.P. Senior Project Geologist Richard J. Wozmak, P.E., P.H., L.S.P. Principal Attachments: Figure 1 Site Locus Figure 2 Trench Excavation Locations Table 1 Leisure Shores Trench Locations and Descriptions cc: Victor Corso, Bouchard Transportation Company, Inc. Andrew Davis, LeBoeuf, Lamb, Greene & MacRae LLP September 21, 2004 Page 3 GeoInsight Project 3871-000

SITE LOCUS SOURCE: USGS Marion and Sconticut Neck Quadrangles N TITLE: PROJECT: Bouchard B120 Oil Spill Buzzards Bay, Massachusetts LOCATION: Leisure Shores Mattapoisett, Massachusetts SITE LOCUS COOUR IERVAL: DRAWN: CHECKED: APPROVED: FIGURE: 3 meters KDT KDT RJW SCALE: DATE: FILE NO.: PROJECT NO: AS SHOWN 9/16/04 Figure 1- Leisure Shores 3871-000 1

201918171615141312 11 10 9 8 7 6 5 4 3 2 A B C D E F 1 LEGEND OILED TRENCH UNOILED TRENCH 0 50 100 APPROXIMATE SCALE (feet) NORTH TITLE: DESIGNED: SCALE: DRAWN: DATE: CHECKED: FILE: PROJECT: B120 OIL SPILL LOCATION: Leisure Shores Beach Mattapoisett, Massachusetts TRENCH EXCAVATION LOCATIONS APPROVED: KDT KDT/LAC LAC KDT PROJECT #: As Shown 9/17/04 3871LS 3871-000 FIGURE #: 2

Row A (Approximately 30' south of high tide/ wrack line) East Row Endpoint: 41 37.719 N 70 49.426' W West Row Endpoint: 41 37.714' N 70 49.467' W TABLE 1 Trench # Length (feet) Depth (inches) Field Team Observation Coordinates North Coordinates West 1 2.5' 3" 1 pinhead-size fleck of oil encircled with sheen floating in 41 37.719' N 70 49.426' W water within trench 2 1.5' 2" 2 pinhead-size flecks of oil encircled with sheen (2mm 41 37.719' N 70 49.429' W diameter) 3 2' 3" 2 pinhead-size flecks of oil (one encircled with sheen and one with a 3"-long rainbow sheen streamer) floating in water within trench. 1 globule (5mm diameter) encircled with a sheen (0.5" diameter) floating in water within trench. Rainbow tint apparent in an area of soil along the border of the trench (1 square inch area) 41 37.719' N 70 49.433' W 4 2' 4" No evidence of oil in trench or spoils pile 5 2' 5" No evidence of oil in trench or spoils pile 6 2' 5" No evidence of oil in trench or spoils pile 7 1.5' 5" No evidence of oil in trench or spoils pile 8 2' 5" No evidence of oil in trench or spoils pile 9 1.5' 4" 1 pinhead-size fleck of oil with associated rainbow sheen streamer (1" long) 41 37.718' N 70 49.412' W 10 2' 4" No evidence of oil in trench or spoils pile 11 1.5' 4" 1 pinhead-size fleck of oil encircled with sheen (<1cm 41 37.716' N 70 49.446' W diameter) 12 2.5' 4" No evidence of oil in trench or spoils pile 13 2.5' 3" No evidence of oil in trench or spoils pile 14 1.5' 2" No evidence of oil in trench or spoils pile 15 2' 3" 2 pinhead-size flecks of oil encircled with sheen 41 37.714' N 70 49.451' W (<1"diameter) 16 2.5' 3" No evidence of oil in trench or spoils pile 17 2.5' 3" 1 pinhead-size fleck of oil encircled with sheen (0.5" 41 37.717' N 70 49.458' W diameter) 18 2' 2" No evidence of oil in trench or spoils pile 19 2' 3" No evidence of oil in trench or spoils pile 20 2.5' 2" Several streamers of sheen<1" long) 41 37.714' N 70 49.461' W Notes: 1. : Not Taken (if no evidence of oil observed by inspection team). 2. Length and Depth are approximate values. 3. Trenches are adjacent approximately 5 to 8 feet apart. Trench 1 is the eastern-most trench. 3871-000/ MCP IRA Leisure Shores 9-04 Page 1 of 6

Row B (Approximately 40' south of high tide/ wrack line) East Row Endpoint: 41 37.719 N 70 49.424' W West Row Endpoint: 41 37.706' N 70 49.452' W TABLE 1 Trench # Length Depth Field Team Observation Coordinates Coordinates West (feet) (inches) North 1 2' 2" 7 pinhead-size flecks of oil each encircled with sheen (up to 0.5" 41 37.719' N 70 49.425' W diameter) 2 2' 2" Trace sheening (1" diameter) 41 37.719' N 70 49.427' W 3 3.5' 2" 3 pinhead-size flecks of oil, each encircled with sheen (1cm- 2" 41 37.718' N 70 49.430' W diameter) and one oil streamer, 4 3.5' 2" 3 pinhead-size flecks of oil encircled with sheen area (4.5"x3" 41 37.716' N 70 49.433' W diameter) 5 3.5' 2" No evidence of oil in trench or spoils pile 6 2' 2" No evidence of oil in trench or spoils pile 7 3' 2" No evidence of oil in trench or spoils pile 8 3.5' 2" No evidence of oil in trench or spoils pile 9 4' 3" No evidence of oil in trench or spoils pile 10 4' 3" No evidence of oil in trench or spoils pile 11 4' 3" No evidence of oil in trench or spoils pile 12 4' 3" 4 pinhead-size flecks of oil and 1 globule (5mm) encircled with 41 37.716' N 70 49.445' W sheen (0.5" diameter) 13 3' 2" 1 pinhead-size fleck of oil encircled with sheen (1cm diameter) 41 37.713' N 70 49.445' W 14 3.5' 2" No evidence of oil in trench or spoils pile 15 4' 2" No evidence of oil in trench or spoils pile 16 4' 2" No evidence of oil in trench or spoils pile 17 4' 2" 1 pinhead-size fleck of oil with associated rainbow sheen streamer 41 37.710' N 70 49.452' W Notes: 1. : Not Taken (if no evidence of oil observed by inspection team). 2. Length and Depth are approximate values. 3. Trenches are adjacent approximately 5 to 8 feet apart. Trench 1 is the eastern-most trench. 3871-000/ MCP IRA Leisure Shores 9-04 Page 2 of 6

TABLE 1 Row C (Approximately 50' south of high tide/ wrack line) East Row Endpoint: 41 37.716' N 70 49.425' W West Row Endpoint: 41 37.706' N 70 49.452' W Trench # Length (feet) Depth (inches) Field Team Observation Coordinates North Coordinates West 1 3' 2" No evidence of oil in trench or spoils pile- slight flooding in trench due to incoming tide 2 2.5' 2" Trace sheening (1" diameter) 41 37.716' N 70 49.427' W 3 2.5' 2" 1 fleck (5mm diameter) with associated rainbow sheen streamer, and 41 37.713' N 70 49.431' W several pinhead-size flecks of oil encircled with sheen (1cm to 2" diameter) 4 2' 2" 4 pinhead-size flecks of oil each encircled with sheen (up to 3cm 41 37.714' N 70 49.432' W diameter) 5 2' 2" 4 pinhead-size flecks of oil each encircled with sheen (1cm diameter) 41 37.714' N 70 49.433' W 6 2' 2" 3 pinhead-size flecks of oil each encircled with sheen (2cm diameter) 41 37.714' N 70 49.433' W 7 2' 2" No evidence of oil in trench or spoils pile 8 2' 2" 1 pinhead-size fleck of oil encircled with sheen (1cm diameter) floating in 41 37.712' N 70 49.435' W water within trench 9 2' 2" No evidence of oil in trench or spoils pile 10 1.5' 2" No evidence of oil in trench or spoils pile 11 1.5' 2" No evidence of oil in trench or spoils pile 12 2' 2" 1 fleck of oil (5mm) encircled with sheen (1cm diameter) floating in 41 37.710' N 70 49.440' W water within trench 13 3.5' 2" 1 pinhead-size fleck of oil encircled with sheen (1cm diameter) floating in 41 37.711' N 70 49.442' W water within trench 14 4' 2" No evidence of oil in trench or spoils pile 15 4' 2" Trace sheening (0.5" diameter) 41 37.710' N 70 49.447' W 16 3' 2" 3 pinhead-size flecks of oil and 3 globules (7mm diameter) each encircled with sheen (up to 1"diameter) 41 37.709' N 70 49.447' W 17 2' 2" 3 pinhead-size flecks of oil each encircled with sheen (1cm diameter) 41 37.708' N 70 49.446' W 18 3' 2" 3 pinhead-size flecks of oil each encircled with sheen (1" diameter) 41 37.707' N 70 49.451' W 19 4' 2" 4 pinhead-size flecks of oil each encircled with sheen (1cm diameter) 41 37.708' N 70 49.453' W 20 2' 3" No evidence of oil in trench or spoils pile 41 37.706' N 70 49.452' W Notes: 1. : Not Taken (if no evidence of oil observed by inspection team). 2. Length and Depth are approximate values. 3. Trenches are adjacent approximately 5 to 8 feet apart. Trench 1 is the eastern-most trench. 3871-000/ MCP IRA Leisure Shores 9-04 Page 3 of 6

Row D (Approximately 60' south of high tide/ wrack line) East Row Endpoint: 41 37.715' N 70 49.426' W West Row Endpoint: 41 37.704' N 70 49.452' W TABLE 1 Trench # Length (feet) Depth (inches) Field Team Observation Coordinates North Coordinates West 1 1' 2" No evidence of oil in trench or spoils pile- slight flooding in trench 2 1' 2" No evidence of oil in trench or spoils pile 3 1-2' 1-2" Area of 5 adjacent and parallel trenches (labeled 3a - 3e) where sediment sample LS-OS-S01 was taken by GeoInsight with MADEP on 8/31/04. Trenches 3a- 3e are approximateky 0.5'- 1' apart. See associated descriptions below. The eastern-most trench is 3a 41 37.714' N 70 49.432' W 3a No evidence of oil in trench or spoils pile 3b Several pinhead and few globules (up to 5mm diameter) each 41 37.714' N 70 49.432' W encircled with sheen (up to 1cm diameter) floating in water within trench 3c Several pinhead and few globules of oil (up to 5mm diameter) each 41 37.714' N 70 49.432' W encircled with sheen (up to 1cm diameter) floating in water within trench 3d 50% cover of floating globules of oil and associated sheening 41 37.714' N 70 49.432' W 3e 50% cover of floating globules of oil and associated sheening 41 37.714' N 70 49.432' W 4 3.5' 2" 1 pinhead-size fleck of oil encircled with sheen (1cm diameter) 41 37.710' N 70 49.434' W. 5 3.5' 1" 1 pinhead-size fleck of oil with associated rainbow sheen streamer (4"x1"). Some sheen is organic 41 37.709' N 70 49.440' W 6 3.5' 1" No evidence of oil in trench or spoils pile- slight flooding in trench 7 3.5' 1" No evidence of oil in trench or spoils pile- slight flooding in trench 8 3.5' 2" 2 pinhead-size flecks of oil encircled with sheen (1cm diameter) 41 37.699' N 70 49.435' W 9 3.5' 1" No evidence of oil in trench or spoils pile 10 3.5' 1" No evidence of oil in trench or spoils pile- slight flooding in trench 11 3.5' 1" No evidence of oil in trench or spoils pile- slight flooding in trench 12 3.5' 1" 2 pinhead-size flecks of oil each encircled with sheen (up to 2cm 41 37.709' N 70 49.440' W diameter) - slight flooding in trench 13 3.5' 1" Trace sheen (<5mm diameter) 41 37.709' N 70 49.442' W 14 3.5' 1" No evidence of oil in trench or spoils pile- slight flooding in trench 15 3.5' 1" 4 globules of oil each encircled with slight sheen (5mm diameter) 41 37.707' N 70 49.444 W 16 5' 2" 1 B120 tar patty in sand within trench hardened and slightly plastic (0.5" diameter)- slight flooding in trench 41 37.706' N 70 49.444 W 17 5' 2" No evidence of oil in trench or spoils pile- slight flooding in trench 18 5' 2" No evidence of oil in trench or spoils pile 19 5' 2" No evidence of oil in trench or spoils pile- slight flooding in trench Notes: 1. : Not Taken (if no evidence of oil observed by inspection team). 2. Length and Depth are approximate values. 3. Trenches are adjacent approximately 5 to 8 feet apart. Trench 1 is the eastern-most trench. 3871-000/ MCP IRA Leisure Shores 9-04 Page 4 of 6

Row E (Approximately 70' south of high tide/ wrack line) East Row Endpoint: 41 37.713' N 70 49.425' W West Row Endpoint: Not Recorded TABLE 1 Trench # Length Depth Field Team Observation Coordinates Coordinates West (feet) (inches) North 1 1' 2" No evidence of oil in trench or spoils pile 2 1' 2" No evidence of oil in trench or spoils pile 3 1' 2" No evidence of oil in trench or spoils pile 4 1' 2" No evidence of oil in trench or spoils pile 5 1.5' 2" Trace sheening (12" diameter) 41 37.711' N 70 49.428' W 6 1.5' 2" No evidence of oil in trench or spoils pile 7 1' 2" No evidence of oil in trench or spoils pile 8 1' 2" No evidence of oil in trench or spoils pile 9 1.5' 2" No evidence of oil in trench or spoils pile 10 1.5' 2" No evidence of oil in trench or spoils pile- slight flooding in trench 11 1.5' 2" 1 pinhead-size fleck of oil with associated rainbow sheen streamer 41 37.708' N 70 49.438' W 12 1.5' 2" 1 pinhead-size fleck of oil encircled with sheen (1cm diameter) 41 37.706' N 70 49.440' W 13 2' 2" 5 pinhead-size flecks of oil each encircled with sheen (up to 1cm 41 37.706' N 70 49.442' W diameter) 14 2.5' 2" 6 pinhead-size flecks of oil each encircled with sheen (up to 1cm 41 37.709' N 70 49.444' W diameter) 15 3' 2" 3 pinhead-size flecks of oil each encircled with sheen (up to 2cm 41 37.704' N 70 49.447' W diameter) 16 2' 2" 1 pinhead-size fleck of oil encircled with sheen (5mm diameter) 41 37.703' N 70 49.448' W 17 2' 2" No evidence of oil in trench or spoils pile 18 2' 2" No evidence of oil in trench or spoils pile 19 2' 2" No evidence of oil in trench or spoils pile Notes: 1. : Not Taken (if no evidence of oil observed by inspection team). 2. Length and Depth are approximate values. 3. Trenches are adjacent approximately 5 to 8 feet apart. Trench 1 is the eastern-most trench. 3871-000/ MCP IRA Leisure Shores 9-04 Page 5 of 6

TABLE 1 Row F (Approximately 80' south of high tide/ wrack line) East Row Endpoint: 41 37.713' N 70 49.421' W West Row Endpoint: 41 37.699' N 70 49.453' W Trench # Length Depth Field Team Observation Coordinates North Coordinates West (feet) (inches) 1 2' 3" No evidence of oil in trench or spoils pile 2 2' 3" No evidence of oil in trench or spoils pile 3 2' 3" 1fleck of oil (5mm diameter) with associated rainbow sheen streamer floting in water 4 2.5' 3" No evidence of oil in trench or spoils pile 5 2' 3" No evidence of oil in trench or spoils pile 6 2.5' 3" No evidence of oil in trench or spoils pile 7 2' 3" No evidence of oil in trench or spoils pile- slight flooding in trench 8 1.5" 2" No evidence of oil in trench or spoils pile- flooded trench due to incoming tide. Black algae spot on gravel and shells 9 2' 3" No evidence of oil in trench or spoils pile- slight flooding in trench 10 2' 3" No evidence of oil in trench or spoils pile- slight flooding in trench 11 2' 3" No evidence of oil in trench or spoils pile- slight flooding in trench 12 2' 3" No evidence of oil in trench or spoils pile- slight flooding in trench 13 2' 3" No evidence of oil in trench or spoils pile- slight flooding in trench 14 2' 3" No evidence of oil in trench or spoils pile- slight flooding in trench 15 2' 3" No evidence of oil in trench or spoils pile- slight flooding in trench 16 2' 3" No evidence of oil in trench or spoils pile- slight flooding in trench 17 1.5' 3" No evidence of oil in trench or spoils pile- slight flooding in trench 18 2' 3" 3 pinhead- size flecks encircled by rainbow sheens (4cm x 2cm) 41 37.697' N 70 49.453' W 3871-000/ MCP IRA Leisure Shores 9-04 Page 6 of 6