tinted St«M
Environmental Protection
Agency
0*fic«ol
EPA/BOD/R01-85/014
Stptamber 1985
Superfund
Record of Decision:
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TECHNICAL REPORT DATA
(Heat fwrf ImtntctioHS OH the rtvent bt/on completing)
1. RIPORT NO.
EPVROD/R01-8 5/01 4
«. TITLI ANO SUSTITtl
SUPERFUND RECORD OF DECISION
Cannon/Plymouth, MA
7. AUTHOR(S)
12. SPONSORING AOINCV NAMI ANO ADO
U.S. Environmental Protect ioi
401 M Street, S.W.
Washington, D.C. 20460
RISS
i Agency
B. REPORT OATI
fiopt-omhor 30. 1985
s. PIRPORMING ORGANIZATION CODE
S. PIRPORMING ORGANIZATION RIPORT NO.
id. PRodRAMTLlBlNT N6.
11. CONTRACT AlRANT NO.
13. TYPE OP RIPORT AND PIRIOO COVERED
Final POD RAjv-irt-
14. SPONSORING AOINCV COOE~
800/00
IS. SUPPLIMINTARV NOTI8
IS. ASS'T'R' Acf
The Cannon Engineering Corporation (CEC) Plymouth Site is located in Cordage Park, a
business and industrial park bordering Plymouth Harbor, in Plymouth, Massachusetts. The
site consists of 2.5 acres which includes three above ground storage tanks, two of which
are estimated to have nominal storage capacities in excess of 250,000 gallons each, and
one which has an estimated 500,000 gallon capacity. The tanks were originally used for
the storage of 16 marine fuel oil and bunker C oil. In 1976, CEC rented one tank for
the reported storage of waste oil and later rented a second tank. Allegedly, CEC used
the tanks to store hazardous wastes. In 1979, CEC was licensed by the Massachusetts
Department of Environmental Quality Engineering (DEQE) to store motor oils, industrial
oils and emulsions, solvents, laquers, organic chemicals, inorganic chemicals, cyanide
and plating waste, clay and filter media containing chemicals, plating sludge, oily
solids and pesticides. Potential problems observed at the site included slow leakage at
the bottom seams of one of the tanks; adequacy of earthen dikes surrounding the tanks;
odor complaints; and leaks from tank side valves. The principal contaminants of concern
identified in the soil during the RI included polynuclear aromatic hydrocarbons (PAH) ,
pesticides, and lead. Surface water samples collected from seeps along the tidal stream
and shore contained iron, selenium, lead, manganese and silver. PAHs, lead, and
pesticides were detected in sediment samples collected from the tidal stream. Low
(See Attached Sheet)
17. Kl V WORDS ANO OOCUMINT ANALYSIS
I. DESCRIPTORS
O.IOINTIrlERS/OPEN ENDED TERMS
Record of Decision
Cannon/Plymouth, MA
Contaminated Media: gw, sediments, soil, sw
Key contaminants: polynuclear aromatic
hydrocarbons (PAH) , pesticides, lead,
heavy metals
IS. DISTRIBUTION STATIMINT
IS. SECURITY CLASS (This Rtporti
None
20. siCURITV CLASS miupafti
None
c. COSATi Field/Group
21. NO. Of PAGES
76
22. PRICE
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._-~_._-_....-' -'. ...
INSTRUCTIONS
1.
lllIIORT NW8I11
lmerllh' I:'A reporl number II il a"..,. 011 tbe ccmr of tbe publkation.
LlAV. 8LANIC
IIICI"'NTI ~.ON.-II
....... for lilt by tail report .......t.
TlTL. AND,"TITU '
TidlIMuId ~t, dearly a~ brieR~ t~ subjKt !:0YCrIIC of the rqIOft,' aad br "i"f'l;ay~'" ",omilWnlly. S.II IUhl iI 10.' . if U".... 11\ !Ift\;lli.'r
.,.. or ."'..subordinate It to..... title. WIleD a report II 1IftII8nd...- thaft c- .,utu.., rqtr;Illhe prift\;lry iii"". a~ "'''11111\'
...... ... ..... ..btidl for tMlpICiftc Iide, ,
....-T DATI ,
&'- ...... .... C8IrJ a dill iDdica... at IIIIt 1D0tnla aad ,car. IndiI...lc the l<;ui~ un y;hil:h il "'..~ ",'~I~ {e-,K,. "'I' "I ;ISUI', "'I' "1'
.".".,..,. 0/,..,.,."". '~,J.
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I.
...
..
..
..IIPOIII8NG ORGANIZATION COOl
a.... MIIIk.
AU1'MOIICIJ
(;he ...) in !:o)II-uonal order (Iolut R. OM. I, Rolw" Doc-, C"(',),
.....
""POIII8NG ORGANIZATION II.PORT....II
....",.rClllllilll OIJIIIiIItioII ... to...... Ihis number.
""~NG ORGANIZATION NAIll AND ADDiI..
(;he -. ""'1. city. ....., and ZIP code. Lisl no more than IWO ,,"I. of an urpnilaliunal hiIaf\'hy,
Li.~1 aUlhur'. afliliallo" if il "iIT~r. bum Ih~ ""rfurmi", ,"pm-
'7.
&
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,.. MDCIIIAIIILIMINT..--11
U. die........ "''''''1 numbe. IIftder which tile report Will prepared. Subordinal~ num~r' mOl)' be i","lu"~'" in p;ar~'''lh......,.
n. CCIIITIIAc:TI8I1MT---II
.... OOIItrIet or put IlUlllber under which report wal prcpuccI.
,1. IM80IUNG AGINCY NAIll AND ADDII..
.... ZIP codI.
,1. n.. D' llUOIIT AND ..IIIDD COYIIIID
18dk:a.. intailll RaIL ek.. ... if appticable. clatll comedo
,... 8ICJII8DIIING AGIaIICY COD'
I...rt applOpriate code.
,.. ~_NTAIIY NOTa
Ea*lIIforlllldon 801 incIucled ebawbere but u.ful. IUCh as:
To lie ,.blilMd in. Su,...... SuppleIll8ftU. .te.
',.. AIIT1IACT
IIICIud8 a brief (2fJ() wordJ 01' I",) factuallUllllII8ry of tile lIIOI1 """irkant inforlllillillli \'onIOlln\,,11II 'h,' r"l'url, 1111". "'I"NI ,."..101"""
IIpIIIcaaI bibliopapla, or literalure .....,. mention it here,
Prepared in ~'OOfICration Wllh. "r...........".. "I. ''n....,..I~'" OIl ""..1""'11'" ..f.
''7. ICIY WOIIDI AND DDCUMlNT ANAL YIII
(a) DESCRIPTORS. Select f.om tbe ThesaUIUI of I::npneerillfl and ~:imlilk T~Jln~ the pruper aUlh"n/.." I\'.nl' I"all~nllfy .11\' In;Iiur
C08C8pt of I'" ...ueh and are auff'icitDU, apecitic and prailc to be ....-d iI~ Incll.'" entriesl"ur ~lalutuntl,
(b) IDENnl'lERS AND OPEN.ENDED TERMS - U. identiflen for prO~1 RiI~ '. ...ocIe nam..... \,qulp-nl d\''''j:nOl'uu, o:h:, U..: "ro:n'
88dad terms written in cIotcriptor form for tbOllsubj8cU for wIUcII no cIc~riptot ~Ailt..
(e)COSAn HELD GROUP .1:iIIcI and .................. to be iakm 1'lOIII the 1965 ('051\11 Suh~\'1 ('al~'J!I'" I.i~t. ~in",' the ma.
jority of cIoaamIntlln _Itidlaciplinuy ill nahUt. the Primary fillclJ(;roup a",lIII:nlhJ will 1M: ,,,,,ulic' di"lplinl:. am 1)1' hum:!"
....... or ty.. of pbpicl1 objecl. ne appIication(s) Will. CIOIHCI'crent:ed wilh "'",'UnWar, I Ie'Id/C ;'11111' OI"IfIIIIIWllh 'h:al "'1111'111111"
dlelldmarY postiqCl). .
1& DllTRI8UTI0N ITAT"NT
Denote ..leuabililr 10 the public or limilalion for reasons olh~. than 'iI:\'uril, fot ...a:ampl~ "K\'I\'OI": 1:..1011'11\'(1." f 'II\' OI..!' OI'OIi......III)' ,,,
tile public. with addle.. and pnl:c.
11. II" IlCUIIITV CLAlllFlCATION
DO NOT aubmit ,lauiracd reports to the Naliona' Tel:hnicallnformation wnK:C,
2'1. ......11 DF 'AOII
........ Ihe tow nu~be' of ,..... includilll this onc and unnumbered '-':'. bul CJll:lud~ dl\trlbutiun It'l. II OIn"
II. IIRICI
In.. the price let by the National rechnica1lnfonnation s.:rvk.~ or th\,' Government Prinlinr oml:\,', if knuwn.
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. ~... ... -~.".' _..~ ....~.. .-. -.'.'" . '. .
~~......_--._._- ...-.-..-.-
EPA/ROD/ROl-85/014
Cannon/Plymouth, MA
16.
ABSTRACT (continued)
p
levels of pesticides and some metals were also detected in harbor
sediments. Ground water samples did not exhibit analytical indications of
organic chemical contamination however, low levels of some metals were
detected.
'-.,
It has been determined that selection of the cost-effective remedial
alternative would best be served by generating supplemental information and
deferring selection of the final remedial alternative. The ROD for
CEC-Plymouth Site will be amended following evaluation" of the new data. The
ROD amendment will specify the remedial measures deemed appropriate to
address contamination remaining at the site. The tasks necessary to
generate supplemental information necessary for further remedial analysis
are: removal and offsite disposal of tanks no. 1, 2, and 3 and associated
piping; supplemental sampling of s011, ground water, surface water and
sediments, and assessment of the floodplains. Total capital cost for this
portion of the remedial decision is estimated to be between $350,000 and
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. . ..- - .
-
~....._._.... . .--
RECORD OF DECISION
REMEDIAL ALTERNATIVE SELECTION
SITE:
Cannon's Engineering corporation (CEC)-Plymouth Site
LOCATION:
Plymouth, Massachusetts
DOCUMENTS REVIEWED
I am basing my decision primarily on the following documents and
information describing the analysis of cost-effectiveness of remedial
~
alternatives for the CEC-Plymouth site:
1.
Remedial Investigation (RI); CEC-Plymouth site (1985).
prepared for the U.S. Environmental Protection Agency (EPA)
by NUS corporation, pittsburgh, pennsylvania (3une, 1985).
2.
Feasibility Study (FS); CEC-Plymouth site (1985).
prepared
for the EPA by NUS corporation, pittsburgh, pennsylvania
(June, 1985).
3.
Wetlands Assessment; CEc-p1ymouth Site (1985).
prepared
for the EPA by NUS Corporation, Pittshurgh, pennsylvania
(August, 1985).
Briefings by Waste Management Division technical staff
4 .
on the advisability of remedial alternatives proposed in FS.
5.
Community Relations Responsiveness Summary (attached).
6.
policy on Floodplains and wetlands Assessments for CERCLA
actions.
U.S. Environmental protection ~gency memorandum.
Hedeman, W., and G. Lucero.
August, 1985.
7.
protection of wetlands:
Executive order 119QO.
1977.
8.
protection of Floodplains:
Executive order 11988.
1977.
9.
Briefing, recommendations, and advice by Office of
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." ..... -.-..; .-''''''' ''''~.__.n -,~._.
-~.. . .-. . .
DESCRIPTION OF SELECTED REMEDY
Based on my review of the above materials, I have determined that
tank removal and appropriate off-site disposal is a necessary part
of any of the feasible alternatives.
Further, in order to provide
additional information on the impact of the remedial actions on the
floodplain, I have determined that additiooal study is needed. There-
fore, I have determined that an operable unit should be implemented
at this site, to include the following actions:
o Tank removal including associated pipework, foundation, and
subsequent appropriate off-site disposal (tanks, piping to
solid waste facilitY1 contaminated material, if any, to an
approved RCRA hazardous waste facility).
o Additional surface and subsurface sampling of bermed areas,
area of tank foundation, and other on-site locations to confirm
pattern of contaminant distribution.
o Groundwater sampling at high and low tide, surface water sam-
pIing (tidal stream, harbor), and sediment sampling (tidal stream,
harbor shoreline).
o Floodplains Assessment consistent with Floodplains Management
Executive Order 11988 to classify the study area, review relevant.
floodplain standards and siting implications, compare the
remedial alternatives relative to floodplains issues and assess
the effects of onsite remedial actions on public health, welfare
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..~ ..~_.,....-_.~..- - . ....-
o Following evaluation of existing and newly generated information
(Floodplains Assessment, Sampling Data) the CEC-Plymouth ROD
will be amended to address any further remediation of existing
site contaminants.
D~CLARATIONS
Consistent with the Comprehensive Environmental Response, Compen-
sation, and Liability Act of 1980 (CERCLA), and the National Con-
tingency Plan (NCP) (40 C.F.R. part 300), I have determined that at
the CEC-Plymouth Site, tank dismantling and off-site disposal, and
other measures as described above, comprise a necessary operable unit
which will be a part of any further cost-effective remedial actions
at the site.
The State of Massachusetts has been consulted on the content of
the selected remedy.
I have also determined that the action being taken is appropriate
when balanced against the availability of Trust Fund monies for u~e
at other sites.
~..
<:..- ~- i -- 3u I 19'?~
~V~ -
I\.;'"~ . - "
f J-,."J' . "
. .,. ,. . .'1'
. v', . ~.....~---',
Michael R. Deland
Regional Administrator
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'_..M~- --".~.':' -.--. -. .. ..... ."
,j1'\'ltO St..~
. ...... 4'
~.., -- .,..
\SJ
"", ~.r
4, PAO'C;.c,
UNITID STATES INVIRONMENTAL PROTECTION AGF.NCY
R~GIC'N I
J. F. KENNEDV FECER..\. al :'-DING. BOSTON MASSA:::HUSET'S 02203
RECORD OF DECISION
SUMMARY OF REMEDIAL ALTFRNATIVE SELECTION
SITE: Cannon's Engineering Corporation (CEC) - Plymouth Site
LOCATION: Plymouth, Massachuse~ts
SUMMARY:
The attached document represents the Summary of Remedial
Alternative Selection for the CEC-Plymouth Record of
Decision which was signed by the EPA Region I, Regional
Administrator on September 30, 1985.
This document
sUMmarizes the discussions, briefing, and reports
submitted to the Regional Administrator relating to
the technica~, regulatory~ and policy issues relevant
to remedial action selection at the CEC-Plymouth site.
The discussions, briefings, and reports summarized
in this document were the basis for the decision signed
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-.'.,-...----- ...._..
SUMMARY OF REMEDIAL ALTERNATIVE SELECTION
SITE LOCATION AND DESCRIPTION
The Cannon's Engineering Corporation (CEC) Plymouth site consists
of 2.5 acres locateo in Cordage Park, a husiness ano industrial
park bordering Plymouth Harbor, in Plymouth, Massachusetts.
The
site area is bordered by a tidal stream on the southeast perimeter,
'~
a warehouse on the southwest perimeter, a fish processing plant
on the northwest perimeter, and Plymouth Harhor on the northeast
perimeter.
Because the site is located directly adjacent to
nearby industries, there are individuals who work in direct
proximity to the site.
In addition, a retail complex which is a
.
component of Cordage Park is located approximately 1000' from the
site (see figure 1-1: location map).
The study area consists of 2.5 acres which includeR three ahove
ground storage tanks, two of which are estimated to have nominal
storage cap~cities in excess of 250,000 gallons each, and one which
has an estimated 500,000 gallon capacity.
Each storage tank is
surrounded by an earthen berm (see figure 1-2: site map). °The site
lies on an area which is comprised surficially of "made land,"
consisting of fill material transporteo to the site.
The f ill
material contains silty sands and sands containing rock, hrick, or
slag.
This fill mater.ia1 varies in thickness from one to nine feet
to
and overlies a peat deposit (north and northeastern portions of the
site) .
The upper geologic unit at the site consists of unstratified
sand and gravel which is approximately twenty-two feet thick.
Beneath that layer °is a fine grained sano which overlies a layer
/
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;.............. ---'.._--~-"'''..'-'
~
."'PUOOLI LOCAflOll
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.
LOCATION MAP
CANNON ENGINEERING CORPORATION
PLYMOUTH SITE, PLYMOUTH, MA
. SCALE: I" = 2000'
rn~~
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.N._-''''----'''---'_.~~ ~
I ,
I I
I ,
I I
I ,
, I
I I
I I
, .,
VANNIC. ,.C.
.~
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.
.
II
C
..
~
I
I : I
: I
II
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.
;
"
ay 'YO 1X!1T1I88 nA1\lMI
. 8YAMO ... AIIIA
J» ImIIWIY
. ... TAlI.
. .-Till Ull
---- NOPeRTT U.
--D-- .AI.
--1-- .WIIt
. II- FI.CI
- -0- - ITOltll "'''"0&.1
- -.- - IIWIIt IIMMOL.I
IYOit a.. CaMC!T!II. lallT!.. TA".I
TA.. 110. I C lOUT" )
.10, 000 IALL.D.1
TA.. 180. . C calfTltAL )
110. 000 8ALLA*1
TA.. .0. 1 (IIOItTtl)
100,000 MLLOIII
..
SITE MAP
CANNON ENGINEERING CORPORATION
PLYMOUTH SITE, PLYMOUTH. MA
NOT TO SCAL.E
PLY.1IOUTtI
....I0Il
FIGURE 1-2
etjOOd~
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:.._....,... ..... ~.~ -_. -. ..
of silty clay the continuity of which has not been demonstrated
conclusively.
This layer is believed to form an aquit~rd, which
creates two surficial aquifers underlying the site.
Groundwater. flow is generally toward the harbor and ~idal
stream, and is influenced by tidal action especially adjacent to
the ha rbor.
There is a tidal stream adjacent to the site which
empties into Plymouth Harbor.
Much of the site has been determined to lie within a coastal
floodplain as determined by a review of Federal Emergency Manage-
ment Agency (FEMA) information.
,)
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. """ .. .-. -..
. ----_.._.._J.4""
----~----_. - ............-..~. ..-.... ,.,...-.
SITE HISTORY
The storage tanks were constructed in the 1920's for the Plymouth
Cordage Company.
The Emhart Company bought the property in 1956
and sold it in 1958 to the Columbian Rope Company.
The present
owner is the Salt water Trust, which obtained ownership in 1969
from the Columbian Rope Company through its subsidiary, the
. Cordage Park Company.
The tanks were originally used for the storage.of" 16 marine
fuel oil and bunker C oil that was off loaded to the tanks from
barges.
Sometime in 1974, this practice was discontinued.
In
1976, CEC rented one tank under a verbal agreement with the Cordage
Park Company for the reported storage of waste oil and later rented
a second tank.
The third tank was intended to be utilized by CEC
however their operations were terminated before the tank was made
operational.
Allegedly, CEC used the tanks to store hazardous
wastes.
In 1979, CEC was licensed by the Massachusetts Department
of Environmental Quality Engineering (DEQE) to store motor oils,
industrial oils and emulsions, solvents, lacquers, organic chemicals,
inorganic chemicals, cyanide and plating waste, clay and filter media
containing chemicals, plating sludge, oily solids, and pesticides.
While in operation, CEC was in the business of transporting
hazardous wastes, storing hazardous wastes at its facilities in
Plymouth and West Yarmouth, and incinerating hazardous waste at its
"
Bridgewater'facility.
On June 9, 1980, CEC complied with a DEQE request and reported
types and classes of wastes in storage at its Plymouth Site.
reported that Tank Nos. land 2 (Southern and Central tanks)
CEC
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'.. ..._~~ ------.......-...-
_.~ --.-..-... -
.- . -. . - ~.
contained 6,000 barrels (250,000 gallons) each of Class "B" material
(water with bridged-in polar solvents and organic chemicals) and
that Tank No.3, which had a 12,000 barrel capacity, was empty
after having just been cleaned, repaired, and tested.
On June 12, 1980, the DEOE issued an Order of Revocation,
alleging that CEC had filed false reports and had transferred
hazardous waste to persons or firms n~t licensed to handle haz-
ardous waste.
In its Order of Revocation, DEOE ordered that
CEC's Massachusetts hazardous waste license be revoked and or-
dered CEC to close all of its facilities immediately.
plied with the order.
CEC COIiI-
On June 18, 1980, DEQE summarized its observations of potential
problems noted during numerous site visits in an internal memorandu~.
Potential problems included slow leakage at the bottom seams of I
of the tanks: permeability of earthen dikes surrounding tanks and,
thus, co~cern for their adequacy~ odor complaints: and leaks f~om
tank side valves.
On August 18, 1980, DEQE made a site visit in response to an
odor complaint.
It was noted that the southernmost tan~ (tank 00.
1 )
was leaking from several seams.
A small pool of waste material was
visible on the ground surface.
It was also no~ed that the manway to
the central tank (tank no. 2) was open and was the cause of odor
\i
problems in the area.
On March 24, 1981, the DEQE made a site visit and noted that
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~- .... -- _... .... - ---."-. ...... .~,~.......__..,
the central tank (tank no. 2) had a minor leak at one of the seams
but that no waste was observed reaching the ground surface.
A site inspection was conducted by the Field Investigation
Team (FIT) from Ecology and Environment, Inc., on July 19, 1982.
p,..
~eport was issued on July 27, 19R2.
The following conditions were
noted: the seams of tank no. 1 were leaking~ the seams of tank no.
2 were .weeping"~ several spills of a tarry substance were observed
around tank no. l~ and levels of organic vapors in the air exceeded
1,000 ppm near leaks in tank no. 1 as indicated by an organic vapor
analyzer (OVA).
DEOE conducted six site visits betwen July 20, lQ82, and August
13, 1982, to inve?tigate leaks reported by the FIT and to inspect
subsequent repairs by CEC.
After several unsuccessful attempts to
effect repairs, the DEOE contacted Jetline Services, Inc. to have
contaminated surface water at the base of the southern tank
(tank no. 1) removed and the leak-contained.
On October 15, 1982, the DEOE contracted with Jetline ~ervices,
Inc., for the cleanup of the CEC sites at Bridgewater and Plymouth.
The general scope of work of the contract called for" ... the
removal of hazardous material from the site(s) and proper off-site
disposal thereof.
The object of the project was the removal of
bulk and drummed hazardouS wastes and soils contaminated by
leaked and/or spilled hazardous wastes and the cleaning and decon-
tamination of vessels and appurtenances on the site(s)." Later in
the month, the estimated volume and PCB-content of each tank was
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"..... -- ~ -" '-. .
determined by Jetline Services, Inc., a~d the OBOE.
The southern
tank (tank no. 1) was estimated to contain approximately 221,000
gallons of product, 73,000 gallons of water, and no sludge.
~o
PCR's were detected.
The central tank (tank no. 2) cont~inen
approximately 204,000 gallons of product with 82 pprn PCA, 71,000
gallons of water with 71 pp~ PCR. and ~,ono gallons of slurlge
wi~h 77 ppm PCH (all quantities estimated).
Negotiations were initiated in Augu~t, 19R3 between Salt Water
Trust (owner of the property) and EPA which resulted in a consent
agreement where Salt Water Trust agreed to conduct the removal of
wastes from one of the two full tanks on site: and EPA contracted
t~ have contents re~overl from th~ second tank, with the third tMnk
being empty.
On September 22, 19ij3, Jetline services, Inc., under contract
to S"'Il t Wat.er Trust, hegAn pumpi ng wastes from Tank # 1.
Drainage
of the Tank 12 was cOMpleted in January 1984 by EPA contractors.
Roth tanks were steam-cleaned after they were emptied.
Ha~tes
were hauled to a hazardous waste disposal facility in Niagara
Falls.
Contractors to Salt Water Tru~t cleaned connecting
piping and removed residual sludge froM th~ central tank during
the summer of 1985.
The site was ranked according to the Hazard Ranking System (HRS)
\)
and WAS proposed for inclusion on the National Priority List (NPL)
in December, 1982: at which time CEC-Plymouth hecame eligihle for
Supp.rfund remedial actio~.
The CEC-Plymouth Site WAS included on
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. _....._~..-~
.. -.-. .. -- .
the NPL as a final site as was published in the Federal Register
in Septemher lq~3.
On July 5, 1984, NUS Corporation, EPA's Remeoial Planning
Office (REMPO), hegan sa~pling soils and surface waters at the
CEC-Plymouth Site.
FroM July 19 until July 26, subsurface soil
samples were collected froM the well ~oreholes and sediment samples
were collected froM the stream ano the intertidal zone.
The instal-
lation of five monito~ing wells was completeo on July 31, 19A4.
REMPO collected the final surface water and groundwater saMples in
e~rly August 19A4.
NtiS conducted a wetlands ~econnaissance in
July 19R5, and summarized literature and field observations in a
Wp.tlands Assp.ssm@nt in August, 19~5.
Ii
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.'~-"'---",,_,:,_-.-.....~. .-.__. -..
CURRENT SITE STATUS
During the time period that the storage tanks contained hazardous
waste, one set of hazards consisted primarily of the potential
for fire and explosion, the potential for tank failure and subsequent
release of hazardous materials to the surrounding environment
which may have ultimately included Plymouth Harbor, air releases of
volatile contaminants, and releases to the environment resulting
from leakage and poor housekeeping.
Soil contamination from
leakage and poor housekeeping are problems which still persist
subsequent to the emptying of tank contents.
The RI characterized soil, groundwater, surface water and
sediments from areas on and adjacent to the site.
Table 1 presents
a summary of the contaminants found on-site and off-site, and pre-
sents the range of concentrations found and the number of sample~ in
which the contaminants were detected.
Shallow soil samples were
collected at 0.5', 2', and 6'.
Subsurface samples collected during
monitoring well installation from split spoon samples were taken at
geologic interfaces.
Surface water samples were collected from the
tidal stream, Plymouth Harbor adjacent to the shoreline, and seeps
from the adjacent tidal stream and harbor shoreline.
Groundwater
samples were collected from five monitoring well.s installed during
the course of the RI.
Sediment samples were collected from the
surface water sample locations.
\)
In summary, the principal contaminants of concern identified
in the soil during the RI included polynuclear aromatic hydrocarbons
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TAIlE 1
CONTAIMANTS FOUND A8O\IE DET£CT1ON lIMITS II 11tE VARIOUS NEDIA
CANNON E~ERINO CQRPORATIOf8 PlYMOUTH SITE
PlYMOUTH. MASSACHUSETTS
~
~
Contamlnlnt
Sh.11ow 50111
. ualka'
OraeRlel - Volet" FrICtIon
"V
86V
75-01-2
108-88-3
IMthyien. chlofld'
toluene
.8-130 13)
Oralnlel - SemI-VoIet'" Friction
Acid btr8Ct8Mn
65A 108-85-2
phenOl
610 (1)
88..ne.tf11 EJdr8Ct8IIIH
18 83-32-8 ec""""'" .80-12.000 (2)
388 208-"-0 ........... ..0-18.000 (10)
558 81-20-3 nepMh8l8nI 1..-2.800 (2)
818 117-81-7 1II1(2-ethytblql)phth8l8t. IlOO-13.000 (.)
188 "-7.-2 dI-n-llutyl phIt\8I8t. 510 (1)
728 M-H-3 b8N0(.)entllrlC81I8
738 10-32-1 b8N0(.)pyNn8 850-1.800 (I)
7.8 201-18-2 b8IIZO(b)ftuorenth8n8 2..00-..800 (2)
751 207-01-1 blnlClC')ftuorlftthine 20200-..000 (2)
788 311-01-1 cIIryMn8 1.100-8.200 (I).
778 201-.-1 ~ 1.200-1.100 (2)
7. 120-12-7 IfttInCIftI
101 11-73-7 ........ 1.110-1.100 (3)
818 81-01-1 ph8n8nt""'" .30-32,000 18)..
Me 121-00-0 pyr8M ..0-8.100 18)
Sublurtec. SoIII
'ualka'
SurfIC. Wit.
'uall'
Sedlm.nll
'ualka'
1.521 11)
11-1.500 15)
2.820-3.0.012)
1.200-2,300 121
. 2,320-2.82012)
7.220 11)
3.520-6.360 12)
2.900-..180 121
7.580-12."012)
,-
Qroundwl'er
IUnconlln.d Aqulf.r)
'ualll
Groundwalef
(Conflnl" A'IUllu,)
-------
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t
.
,
~
I
,
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f
TAIU 1
CONTAl8NMTS fOUIID AMM 0£rECT10N IJIIrTS .. THE VARIOUS MEDIA
PAGE 1WO
Ground...er Groundwater
Shellow SolI. Sub.urfece Soli. Surfece W..er Sedlmen.. (Unconfined Aqulf.,1 (Confined Aqullur)
ru ~ Contemln.nt lualkat 1 uaJllat luant 1 ualkat luant 11111111
.....tckIft
3IP 30l-IO-2 ........ 5.Z5-78.8 (3) 5.74-473.8 (Z)
IZP 10-21-3 4,4'-DI)T 110- 10.000 (4) 8.3-10.48 (Z) 10- 100.56 12)
MP 72-14-1 4.4'-000 120 C1I 8.88 II) 10.2- 135.62 14)
t5P 111-21-7 ....uI1... I 3.11 (11 3.Z7 (I)
86P 115-21-7 ""111'... . 8.57 (II
t7P .1031-07-8 encIo.uI1- .ulle'. 4.37 (I) 35.1-1.170 (4)
lIP 71-20-1 8IIdrIn 8.15 (I)
lOOP 71-44-1 188p18ChIor 130 (11 10.tI-17.4 (21 30.76 (11
10IP 1024-17-3 188p18ChIor 8fIOIIId8 3.7 CII
10ZP 311-84-1 8IpM-IHC 510 (1) Z.5Z-8.470 (31
I03P 311-"-7 118t8-1ftC 2.35 (1) 1.4Z7 (11
I04P 311-." ""'e-BHC 2.80-7.48 (4) 21.51-2.808 (3)
105P 11-""1 IIftIm8-1HC 5.21-28.4 (Z)
ti:
-------
"
TAILE 1
CQNTMIiWRS FOUND MIM DET£C11C* lMTS . mE vARIOUS MEOlA
pAGE ~
GroundWII.r Groundw8ter
Shllow SoIII Sub,urtIC' 50111 Surfac. W.,er S.dlm.nll IUnconfined Aqull.rl IConlln.d Aqulle'l
~ WJ!2. Con'amlnlnl Imlll'a' 'maika' lua'" Imalka' luall' 11'0/1)
InonI8ftlcl
Iron 2,200-23.000 (30) '.400-nOOO 181 6.HUOO C81 2,800-8.400 161 53-4.710 'C31
I8Id 2.1-'.700 (30) II-54 18) 28- '80 (4) 32-470 181
menpne,. 23-'80 (30) "-280 (8) 20-400 (8) 2'-64 16) 300-720141 40 III
,.lInIum U I') 4-830 15) '8 C'I
,DYer '8- 170 (5)
NoI..:
I ) NumII8r of OCCurNftC8'
. """'1 report8d for d1ry18M - b8nzoCI)8ntttr8c8M
.. R.,unl reporI8d for pMnandnM and enlhrac8M
-------
(PAH), pesticioes, and lead.
The distribution of the PAH's did
not follow any di~tinct pattern although the highest concentration
was found near the south tank (tank 1).
Similarly, pesticides
were distributed through the 2.5 acre stuoy area in an apparently
random fashion hoth ve~tically and horizontally, being identified
only infrequently in surficial ~oils on-site.
Lead was found at
concentrations of 250 - 1700 mg/kg primarily in surf.ace soil~
(0"-6") inside the tanks' hp.rms.
Surface water samples did not show any analytical indication of
organic chemical contamination.
Samples collected from seeps along
the tidal stream and shore dio contain iron, selenium, lead,
manganese ano ~ilver.
PAH'S, leao, and pesticides ~ere also
detecteo in sediment samples collected from the tidal stream.
Low
levels of pesticides and some metals were also detected in harhor
sediments. .
Groundwater samples did not exhibit analytical indications
of organic chemical contamination however, low levels of some
metals were detected.
Bxisting information suggests that the
groundwater has not heen significantly impacted by prior or pre~ent
site conditions.
A summary of sample locations and sample types are presented in
Tahle 2, Figure 3, respectively.
\,
-------
I'
-
TABLE
2
SAMPliNG AND CHEMICAL ANALYSES DATA BASE
CANNONS ENGINEERING CORPORATION PLYMOUTH SITE
PLYMOUTH. MASSACHUSETTS
Media Sampled Sampler Oate
Ambient air NUS 3/84
Surface soil NUS 7/5/84
Sample locations
Three locations
Sample Nos. 75386. 75387. 75390
Boring No. 1-9 onslte (9-background)
Three depths each location - 0-0.5'. .
2.0'. 6.0' plus one duplicate at
each depth
CP-SO-001 - CP-SO-027
Subsurface soli
. NUS
7/19-27/84
MW-1A. 2A. 3. 4. 5 (background) onsite
CP-SS-001 - CP-SS-006
Surface water
NUS
7/5/84
Two locations with one duplicate and
one blank
CP-SW-OOO - CP-SW-002
\.
Surface water
NUS
812/84
Five locations with one duplicate
CP-SW-101, CP-SW-102. CP-SW-003 -
CP-SW-005A
Sediments
NUS
7/26/84
Five locations with one duplicate
CP-SO-001 - CP-SO-005
Groundwater
(Unconfined aquifer).
NUS
811- 2/84
MW-2. 3. 4, 5 (background) on site
with one blank
CP-MW-OOO. CP-MW-002 -
CP-MW-005
r.rOllnrlwAtAr
P-III~
O//OA
. ."U 1
/ "
I
~
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.
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!
laboratory AnaIY:>ls
Volatile organics
HSl organics
HSl Task I and II inor!Jilnics
Ammonia. f:yanide. sulfide
HSl organics
HSl Task I and II inorg..nif:s
HSl organics
HSl Task I ami II inorganics
HSl organics
HSl Task I and II inoryanks
Cyanide
HSL organics
HSl Task I and II inorganics
Cyanide
HSl organics
HSL Task I and II inorual\lf:s
-------
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, f,. :-~~...; .._-~, ...----"----';'-';;-'->"1'---6 .-.r~'I'~-s. "......--,,'
'. ."'~.~-:z...:-.__..'.._-.. 0"";:'''
", - . '''y/''''~~~!';~'-='':!'':':':':''':''_>:'''''~'' '" 0......
' , ,L.. ., :/'t>.-tU1"--" .:; :-\~~~~~~:~>~'~ ......- ---'
... ,. I. ", '.... 'r 5:g:11i: . .", - ,--
... , . I " .:':.,.... '"', ~ . _. ... . \.( ,.- --. -- - -.... ..~
.. 'I( , ',;. ': f1:"-:_~ :, ""'-";"j '::::,,{ ---- .
, ." fill I.. '~-:::,'l.7 ,,:.t,~ ,', ~ '
. .' . . \' '=-" 0' ~", ". .-.. . J' n:= .
~i ~ ", " P'. .! ,r:.: '",:..- 1/:,1' .-...
)' '~ ~\I, "':."-~ - --. '1,""; " /.' ,,'./,,',
. , '. ,,~ - ----.-_:.-!.:, I! ~'''''-'''- - -~.;.<...././;
'... 8-4 J"~- -- L"::.:--'. - ...- --"'~...." -----." -
! ; " ':::'~~.:-...---~ ':':'rl~" ---=-"........;;.' ..~~~.-..........~-'
'~' ,/ '..-----._-':--..._-.., ,~"."...,\",~ ' .-
. I \ "I '-- -----::':"~'i."'-_... ,..".;::,~.....-.,. ......
ItIftP ',:t: \ ,:', ",.~ ".,,";, "~'" ...-.
~' I '- , ~er.: ,'It'? 'I,' , ".". j:i=:-
"j, fill . /' _~r :,"t.-/ :=..\;;F:,,~\ \;'.'\'" . ...
, .~ I ' ..-',4_"" """. ,". .-:: ""
..."=:", tal ~ ---....~-:.~ ~..!,..'\ :t:~.:.:,~:.~ ,~;:-.
"' -- ., " , ,.,. .. ..., .. '~'. / \ .
"', \ ! ,. ! / : I ,,\~~ ;;::..:.~~:- ~'.' I \
..,. ~s ',..t.,.",........:.' \'N'~, ~';/J,~-+-
.. .......... I ..... "."... ......~....'" ~
.~ ""'-'" , ~ .,,..~~~, '" ";$"
1 ~-:'\ r, J -'-\.-"'e I ~...~_a.:::i:'::'i"
I I '~~~~. ~~~
} \, ' '... ~ ..... 1......;':--
. . , / '-, ... .....::.:.."".-""
., , ~....., '...... ,....-...~., .....
. '~ ' C,_""F c.. '----- - ''of ...
t ,. --, --~ --..
" I ~~' o,;;.~~-----:::---
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/ ,/ ,'----- -------
fS~ ..,(,: ..-- ,:r.:=, ---,----
. ~.. ......:4---
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,~'I
!B
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LUlU
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: ::S=:';L-.rT
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SAMPLE LOCATIONS
CANNON ENGINEERING CORPORATION PLYMOUTH, 51 n, ,(\-MOUTH. MA
.,/
,
1". '''':'f. ""0"
'6....~ -
seAl f. IN n.l. T
:-.
... "".t 'I
L--_,-
--
'-.
:'
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FIG'
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10
.
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RISK ASSESSMENT
/'
\
"
Migration Pathways
The current principal migr.ation pathway for this site appears to
be surface water runoff of surficial conta~inant~.
Site con-
, taminants could be physically transported offsite by surface water
runoff during storm or tidal events.
T~e adjacent tidal str.eam,
Plymouth Harnor, and possihly adjacent industrial property would
be' the ultimate receptors of this ",igration pathway.
The site is,
however, relatively flat with a shallow slope of about three percent
toward Plymouth Harbor.
The sit.e is also heavily vegetated, which
will tend to minimize erosion processes.
It is felt that storms of
unusual intensity and duration (such as the lOa-year flood) would
be required for significant offsite transport of site related
matedals.
(
It has been determined from a review of FEMA information that
much of the site lies within a coastal floodplAin.
The tank hp.rl11s
represent the highest site elevations.
If these soi1 berms were
re~oved, it is possible that the mater.ial inside the berms could
become inundated during a Major flood/storm event.
Such an event
could possihly result in transport of surface mAterials offsitp to
the tidal stream, ~lymouth Harbor or to neighboring properties.
Air sampling wa~ conducted as a.part of the RI.
However, t.he
data generated does not provide a definitive assessment of ambient
air quality.
The airrsam~ling results when considered in conjunction
with the ohservation that virtually no volatile organics were found
,in surface soil samples, suqgest that an air route for exposure to
-------
;,-~~...-.iJ""",--,,,,,, -.-.. .....~ .......
volatile organics is currently extremely unlikely.
Previous air-
releases were reported during the time hazardous Materials were
stored in the tanks.
~ecause of the vegetated nature of the
site, exposure to airhorne contaminnted soil p~rticles under
current conditions is also considered unlikely.
However, dis-
r~~tion of the soil cover in conjunction with turbulent air
flow could result in airborne contaminants which are sorbed
onto part iClilates.
Analysis of groundwater samples from site monitoring wells
indicates that groundwater i~ not a significant pathwny for
'migration of organic contamination.
Several inorganic species
wer.e detecte~ in groundwater but these consisted primarily of
iron and mang~nese.
However, groundwater does not appear to be
a major pathway for the transport of heavy metals.
In summary, the PAHs, lead, and pesticides present in site soils
are relatively immohile.
Offsite migr.ation via surface runoff is
possible under severe storm situations but this route does not ap-
p.ar to he a routine ~echanism for transport of contaminated
material to the tidal stream or harbor at this site.
Major flood
events such as those which are compar.ahle to the lOO-year flood
.
or IOO-year coastal flood could induce a major disruption of
surface soil cover and ~ssociated contaminants.
Groundwater does
not appear to be a significant transport pathway for organics,
~
heavy metals or inorganics.
!
Receptors
-------
#.'''''''''''_.h--''' _.._..~---- --..... ',-
RI, the potentin1 receptors for contaminants at the CEC-P1ymouth
Site are:
o Innividua1s who work in the vicinity of the site and may breathe
contami~ated soil p~rticles
-0 Indivinua1s who trnverse the site and come into di~ect contact
with contaminated soils
o Environmental receptors including aquatic hiota in the tidal
stn~aJl\ and Plymouth Hart'lor
o Human receptors who conSUMe aquatic organisms such as shellfish
Of the ahove potential recepto~s, the ones who a~e likely to he
most at risk are innividuals who traverse the site and come into
contact with contaminnted soils.
Risks Presented ~ Existing Site Contamination
In general, ingestion an~ inhalation of contaminant~ are two of
the most iMportant routes for receptor uptake of hazar.dous Materi~ls.
Under. the existing site conditions, i.e. those th~t would persist if
the no-action alternative was selected, inhalation of vapors or
contaminated soil particles noe~ not appear to he a significant mo~e
of exposure.
Rowever, as mentioned earlier, disru~tion of the soil
cover could re~ult in the gen~ration of contaminated p~rticulates
into the air vector increasing the significance of this exposure
route.
Grounnwater has not heen greatly iMpacted, ann is not
-------
, .6. .. --...---..----- ._......~ - '-.. .
utilized as a drinking water source in the study area.
ConsuMption
of contaminaten groundwater is not ~ significant exposure route for
this site.
The primary exposure mechanisM that would exist as a
consequence of selecting the "o-action alternative would be site
access resulting in direct contact of contaminated soils.
Because,
many of the contaminants of co"cern are poorly absorbed through the
skin, ingestion of contaMinated soils would be necessary for
significant exposure to occur.
Most of the contaminants and their
respective concentrations are not thought to present an acute
toxicological hazard.
Areas onsite where the lead concentration
is highest (inside the tank berms) could be of concern if the
soil was ingested re~ulting in an increased hody hurden of lead,
especially in children, whose absorhtive capacity for lead is much
greater than for adults.
Other contaminants identified, including
PAH's and pesticides located both inside and outside the tank
berms, as well as lower lead levels locaterl outside the tank
berms could also be accinentally ingested.
~owever, it is EP~'S
opinion that the hazards pr.esented by the lower concentr~tions and
randoM distribution of these other site contaminants are less
significant than the potential hazards presented by the shallow
lead contamination inside the soil berms.
Therefore, based upon the ahove considerations, the lead soil
contamination inside the tank berms are the areas which may present
either a potential threat to puh1ic health through direct exposure
,/
to contaminants or a source area from which contaminants could
-------
..-.......~~...-~~ .~... .
., '.#- ...#..
~igrat~ to environMental receptors such as the tidal strean and
Plymouth Hi'lrhor.
An innirect Mechanis~ for exposure to site contalninant~ would
be cor,~u"'pt.ion of aquat ic 1 ife which has bioaccul1\ulated con-
taminants that may have migraten offsite.
Shell fish tend to he
highly slJsceptihle to acclJI'I'IlJli'\ting marine contamination.
Howevl'!r,
the ris~ from this situation should be low as the bulk of the
Plymouth Harhor i~ closed to shell fl~hing: In any event, the
.
major toxicologic effects reslJlting froM consumption of Plymouth
Harbor shellfiRh woul~ likely be due to bacterial contamination
which is not site related.
v
-------
.:~-,-~~---_..- -__A'_a. .._~....
.. ....' .. -- .'.
ENFORCEMENT ANALYSIS
Enforcement related activities are currantly ongoing for this
Ritp..
It is the intent of the EPA to either have a responsihle
party or parties undertake cleanup of this site or to recover
remedial related expenseR associated with cleanup of this site.
At this time, no formal agreements havp. been entered into which
would reRult in responRibl~ party cle~nup of the site or agrpement
to furnish costs related to site remediation.
-------
:.-......--
~.._d.......... ....
COMMUNITY RELATIONS
EPA has undertaken several processes to keep the state, the
town, concerned citizens, and legislators informed of the ~tAtus
of the CEC-Plymouth Site.
The activities include:
1.
A town meeting to describe the Remedial Investigation/Feasihility
Study (RI/FS) and respond to citizen questions.
"
The town
meeting was held on July 11, lQR5.
Issues of concern were as follows:
o What were the health concerns presentert by air releases
during the period the tanks were used to store hazardous
waste?
o will the EP~ consider future land uses in selecting a
remedial ~ltern~tive?
o Is there enough existing information to select a remedial
alternative?
o Have funds been allocated for Fiscal Year 86 - cleanup,
when will remedial design/remenial implementation begin? .
2.
A puhlic he~ring was held on July 24, IQRS, to record for the
public record comments relating to the RI/FS and selection of
the appropriate remedial alternative.
A summary was prepared
of written comments and comments read into the record, and
the agency responses. to those comments are presented in the
-------
...- -- _.....t....~.. . .'-:_- .
ALTERNATIVES EVALUATION - FEASIBILITY STUDY SUMMARY
The RI of the CBC-PlYMouth ~ite has identified that there is a
potential for direct contact hazard with site contaminants and
for offsite migration of contaminants.
Therefore, the remedial
action alternatives presented in the CBC-Plymouth FS are intended
to addrp.ss two primary objectives:
1.
Mitigate threats to public health and welfare by minimizing
the potential for direct contact with contaminated soils
2.
Mitigate threats to the environment by minimizing the potential
for offsite migration of hazardous chemicals
The FS screened a number of technologies for their applicability
to remediation of the CEC-Plymouth Site.
These are presented
below:
GENERAL RESPONSE ACTIONS AND ASSOCIATED REMEDIAL TECHNOLOGI8S
CEC-PLY~OUTH SITE
PLYMOUTH, MASSACHUSETTS
General Response
Action
~emedial Technologies
No action
Some monitoring and analyses po~sihle
Containment
.
Capping, groundwaterparrier walls
Diversion
Grading, dikes and berms, stream
diversion ditches, trenches
Complete removal
Tanks, drums, soils, sediments,
contaminated structures
,/
-------
.10- ..._~----_..- .,
General Response
Action
Re~edial Technologies
Selective removal
Tanks, ~rums, soil, ~~ctiments
Treatmel"\t
tncineration, biological, cheMic~l,
and physical tr~atment
storage on!';ite
Tempor~ry storage structurp.s
Onsite disposal
RCRA la ndf ill
Offsite di!';posal
RCRA landfill, land applicAtion
The above technologies underwent an initial screening process
incorp()r~ting review requirem~nts a!'\ olltlinect in the' NationAl Oil
and Hazardous Substances Contingency Plan (NCP: 40 C.F.R. Part 300).
The intent of the screening process is to narrow th~list of
remedial options to those that are economically feasible, are
functional with respect to the att~inment of the desiren ob-
jective(s), and are feasible for the site specific situation(s).
~cc~rding to 40 C.F.R. P~rt 3nO.~8(h) three crit~ria should be
used in the initial screening process.
These include:
o Cost - the cost of installing or implementing the re~ectial
action must he considered including operation and Mainten~nce
cost
o Effect of the Alternative - the effects of the alternative
should he evaluated with regarct to any resulting adverse
environmental effects, whether the alternative is likely to
achieve adequate control of source material (when applicahle),
or for offsite remedial action whether the alternative is likely
to effectively mitig~te ann Minimize the threat of har~ to
-------
:.-......-.-..................._~._. ... -...
puhlic l1eal t h, we I face or the envi ronment
o Acceptahle ~ngine~ring Pr~ctices - Alternatives Must be feasi~le
for the location and conditions of the release, applicable to the
prohlem, and r.epresent a reliahle means of addressing the prohlem.
Screening Summary
o No Action:
Ii
There are no cost, or engineering limitations which preclude
consideration of the No Action alternative, therefore, this option
was retained for further evaluation.
o Containment
- Surface capping:
~pplication of this technology would reduce the spread of. con-
tamination by wind, surface water runoff ann minimize the potenti~l
for direct contact.
Capping is a commonly used, economically
fea~ihle technology that will be retained for further consider~tion.
- Grounowater barrier walls:
This technology woulo be applicahle primarily as an ancillary
technology for excavation ~elow the water table, and will be re-
tainen as an ancillary technology to be used in conjunction with
the e~cavation option.
o Diversion
- Grading dikes and berms:
These technologies would be used to direct surface water runoff
from contaminated areas, an0 also can serve to protect areas from
flood iMpacts.
They are commonly used tecl1nologies that will he
-------
_...~_.._-. - .~..-
retained for inclusion in remedial alternative~.
- Strea~ diversion trenches anrl ditches:
These technologies would be used to reroute an existing watercourse
during excavation of contaminated sediments from the tidal stream.
This technology was rejected based upon cost considerations for
diversion ~el~tive to the level of effoit for excavating the
sediments.
In addition, it is felt that adequate sedimentation
,.
controls could be institutel" in the stt'eam bed itself during sediment
excavation without diverting streamflow.
Implementation of diversion
ditches cou1~ also result in t~ansport of contaminated sediment
directly into the harbor.
o Removal
Excavation of wa~tes can be employed to remove contaminants from
areas on the site and dispose of it on or offsite.
This technology
is feasible, attains remedial ohjectives, is economically feasihle,
and was r.etained for further evalu~tion.
o Treatment
- In situ treatment technologies:
These technologies, which include chemical oxidation, solvent or
water flushing, biodegradation, and vitrification have been rejecte~
because of cost issues, uncertainty of positive benefits, ann non-
applicability to all waste types found on the site.
- Off~ite treatment technologies:
"
Treatment of solid wastes originating offsite appears to be limited
to incineration of contaninAted soils and sediments.
This tech-
nology has been used successfully on contaminated soils, although
expen~ive, it is economicAlly feasihle and will be retained f~r
further evaluation.
-------
...~..... ~~~.-...-....o-.": - -"~ -- . .. .
o Onsite Disposal
~ properly constructed landfill is often used to dispose of con-
taminated material.
However,
this tech~ology has been excluded
from consideration because an onsite disposal facility would re-
quire an ancillary storage area to cont~in excavated soils while
the landfill was being constructed.
The site does not contain
sufficient space to accomodate hoth types of storage areas (an-
ciliary storage area, landfill).
o
o Offsite Disposal
- RCRA landfill:
Offsite disposal in a RCRA-approved landfill is a proven remedial
technology and is economically feasihle.
This technology will he
retained for further evaluation.
- Land application:
This technology has been rejected because of the environmental and
health implication associated with th@ toxic metal loads of site
soils being applied in unrestricted offsite areas.
o Summary
As a result of the screening process, viable technologies
were identified includinq no action, surface capping, groundwater
barrier walls, grading qikes and berms, removal, offsite treatment,
and off site rtispo~al.
A set of appropriate re~edial alternatives
relying on these tech~ologies was developed.
Ten remed ial al ternat i ves were developed in to.he CEC-P1ymout h
FS.
Alternatives 2-10 all assume that the storage tanks will have ,)
-------
.._--~...-.__._-~- --- . -- .
been removed, a~d t~uS do not reflect that level of effort.
These
altern3tives are surnm~rize~ helow:
Remedial Action Alternative 1 - No Action
As the name implies, Altern~tive I provides for allowing the site
to remain in an as-is conctition~
Any eventual change of conditions
will he left to natural forces.
Many of the contaminants found
onsita are relatively persistent in the soil environment, therefore,
their presence would he expected to persist onsite as an outcome ~f
selecting this alternative.
Remedial Action - Alternative 2 - RCM Cap with Groundwater
Monitoring
Alternative 2 provides a RCRA approved cap over those portions
of the site shown to contain contamin~tion.
The cap will reduce
the risk of direct exposure to contamination and stabilize con-
taminated soil i~ place.
This ~lternative does not attempt to .
remediate the tidal stream sediments (see Alternative 7) but does
provide for ~onitoring ti~al ~treaM contamination for five (5)
years~
Post closure care for the capped area and groundwater
~onitoring will also he conducte~.
The FS specifies a cap which
will cover 8,800 square feet of site area.
The FS indicated a
capped area which exclu~e~ the b~rmed area ar.ound the central
tank (tank 2).
Remedial Action Alternative 3 - Two-Foot-Thick Soil Ca
This alternative has the same intent, em~loys rel~ted technologies
and covers the same surface area as that specified under Remedial
-------
. . Jo..-...-..-" ..
. - - . - ..' . -* . . - - .
Action Alternative 2.
The major distinction between the RCRA
Cap and the soil cap i~ thAt the soil cap con~ists of two fp.p.t
of soi 1.
with respect to ffiinimizi~g the offsite transport of
contaminated soil and the potential for nirect contact, this
alternative offers essentiAlly the saMe degree of remediation ~s
AlternAtive 2, however, does not provide An impermeable barrier
and is thus subject to percolation of liquids through the cover
u
and waste materials.
Remedial Action Alternative 4 - Selective Soil Excavation
(including sediments) and offsite disposal
Alternative 4 attempts to remediate the potential source of
contaminant migration by removing contaminated soil from the
site and stream sediMents offsite.
The volume of contaminated
soil and sediments to hP. reMoved under this alternative is
limited to those soils which have been determined .to contain
contaminants by the f.indings of the RI.
80ils and sediments
excavated under this alternative would be hauled to a permitted
secure offsite PCRA hazArdous waste disposal facility.
Remedial Action Alternative 5 - Soil Excavation Down to the Top
of the Peat Layer, Sediment Excavation and Offsite Disposal
Alternative 5 is similar to Alternative 4 except that it provides
for the excav~tion of a larger volUMe of soil in an effort to
provide a more extensive excavation alternative.
Excavated soils
and sediments would he transported to a RCRA permitted, secur.e
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,:,,--..'____-""'-.h''''--- ""-."'--
Remedial Action Alternative 6 - Roil, Sediment, and Peat Layer
Excavation and Off~ite Disposal
Alternative 6 incluoes all t~e ~oil and sediment to be excavated
under Alternative 5 an~ adds the pe~t layer to the total excavated
volume.
Alternative 6 is the ~ost extensive of the remedial al-
ternatives includeo in this FS.
'-
Remedial Action Alternative 7 - RCRA - Approved Cap, Excavation,
and Offsite Disposal of Tidal Stream Sediments
Alternative 7 provides for placing a RCRA-approved cap over the
contaminated site area descri~ed for Alternative 2 and for
excavating and removing tioal stream sediment.
The excavated
material will be dispose~ in a R~~A permitted, secure off~ite
hazardous waste landfill.
Remedial Action Alternative 8 - Two-Foot-Thick 80il Cap, Ex-
cavation, and Off site Disposal of Tinal Stream Sediments
Alternative 8 anticipates placing a 2-foot-thick soil cover over
the contam~nated ~ite area, ~escribed for Alternative 3 and ex-
cavating and removing of the tidal stream sediment.
T~e excavated
material will be transported to a RCRA permitted, secure offsite
hazardous waste facility for disposal.
Remedial Action Alternative 9 - Relective Excavation with Offsite
Incineration of Contaminated Soils
The materials to he excavated under Alternative 9 are the same as
those described for Alternative 4.
Alternative 9, however, in-
cludes off site incineration as the means for di~posing of excav~terl
-------
'-""".'--""'-"-'-.-". .---. ....~- ...
Remedial Action Alternative 10 - Selective Soil Excavation and
Offsite Disposal
Alternative 10 is similar to Alternative 4 except that Alternative
10 does not i.nclude excavation of the tidal stream sectiMents.
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:""I.~.~~""'~ .
'~-_.' -. ...-..."......-. ......'. .
CONSISTENCY WITH OTHER ENVIRONMENTAL LAWS
The developMent of the ren~ntal alternative~ for the CEC-?lymouth
Site has incluned an evaluation of. c0mpliance with other environ-
mental laws.
The principal regulAtion in addition to CERCLA which is
relevant to the CEC-Plymouth site remedi~tion is the Resource
Conservation and Recovery Act (RCRA).
In addition Executive
Orders llqRR and 11990 and the cor.responding EPA policy on
compliance with the Floodplains and wetlands Assessment Guidance
for CFRCLA Remenial Actions have heen ~onsidered.
Of the ten remedial alternatives generated for the CEC-Plymouth
St~e, All but the no action alternative represent some variatinn
in the extent of application of sever~l technologies, specifically:
excavation, capping, offsite land dispo~al, and off site incineration.
A discussion of the regulatory consideration of each technology
follows.
Excavation
The RCRA closure regulations require that closure consist of th~
removal or decontamination of all waste and waste residues (40
C.F.R. Part 264.228).
In order to leave some residual contam-
ination in soils, it must he determined that the residual con-
tamination poses no threat to health or the environment.
There-
for.e, an excavation re~eoial action at the CEC-P1YMouth Site will
be obligated to remove suff.icient material to re~ult in a site
-------
.~.;.-~. - - -- =.~ co....... ~.
-. " .". ~.....'... '-"" -'4_>- . -.
Capping
The CEC-Plymouth FS proposed two types of surface caps.
One de-
sign is intended to me~t ~rRA requirements, and at the same time
would fulfill CERCLA goals.
The second type of cap design proposed
consists of a two-foot soil
cap.
This design would Meet CERCLA
objectives by minimizing the potential for human exposure and
off.site migration of contaMinants through surface runoff.
How-
ever, a soil cap would not Meet RCRA closure requirements as out-
lined in Title 40, Part 264.310.
There are two major deficiencies
of the soil cap as compared to the RCRA cap:
the permeable cove~
materials in th~ soil c~p do not minimize the process of percolation
of liquids through the covered material as required by RCRA, and
the permea~le cnvpr cap does not provide for ground w~ter monitoring
during the post-closure period.
Another RCRA consideration relevant to the capping alternativ(
for the CEC-Plynouth Site is that RCRA requires that facilities
located in a IOO-year floodplain be designed, operated and main-
tained to prevent washout by a IOO-year flood (40 C.F.R. Pnrt
264.18(b».
Flood protection needs to be addressed if a capping
alternative is implemented in a lOO-year floodplain unless it can
be shown that no adverse environmental or health effects would
r.esult from a washout.
Executive Order IlQij8, "Protection of Floodplains," and the EPA
policy on Wetlands and Floodplains Assessments both r.equire that if
one or more remedial alternatives will be located in a floodplain,
as in the capping alternatives, those alternatives may not be
-------
"--..-.-- M"h -_. ---. ..
selected unless a determination is made that no practicable
siting alternative exists outside the floodplain.
Therefore,
because the site is located within a floooplain and excavation
.,.
and offsite oisposal may he 3 viahle alternative, the capping
alternatives will require further study before implementation
would he consistent with Executive Order llq88 and EPA. policy
concerning Flo~dplains and wetlands.
Because of the limitations
on offsite disposal discussed helow, a comparative analysis must
be made of the costs and environmental risks associated with onsite
and offsite remedial alternatives.
Offsite Landfilling
Offsite landfi11ing involves transporting waste and soils to an
approved hazardous waste disposal facility.
Department of Trans-
poration (DOT) regulations concerning the transport of hazardous
materials would he applicahle, ano the facility must be a RCPA. ap-
proved hazardous waste landfill which is capable of accepting the
waste.
However, offsite disposal is precluded by section 101(24)
of CERCLA 42 U.S.C. ~ 9601(24), unless the offsite remedy meets
one of the following critp.ria:
The offsite remedy
1. is more cost effective than other remedial actions;
2. will create new capacity to m~nage hazardous substances; or
3. is necessary to protect the environment, puhlic health or wel-
fare. .
Incineration
Incineration would fulfill all existing guidance in terms of the
ultimate fate of thp. contamin~ted materials if incinerated at an
-------
approved facility.
Residual ash must be analyzed and properly
disposed of at an approved facility.
Logistical considerations
could arise due to insufficient availahility of incineration
capacity.
+
-------
........-... -.. .... - -.. "" ...... .. .....
DETAILED ANALYSIS OF RF.MEDIAL ALTERNATIVE
Acco~ding to t~e NCP, 40 C.F.~. 3nn.~8(j),
"th~ appro~~i~ta ey-
tent of remedy shall ~,~ determined by the lead agency's selection
of the remedial altern~tive which the agency deterMines is cost-
effective (i.~. the lowest cost alternative that is technologic~lly
feasibl~ and reliable and which effectively mitigates and miniMizes
damage to a:hd provides adequate protection of public health, wel-
fare or the environment)."
In formulating the ~ppropriate remedial action for the con-
ditions existing at the CEC-Plymouth site, the Agency has evaluated
the following considerations with respect to the NCP and CERCLA:
1.
The reMedial objectives for this site based upon the informati~n
presented in the CEC-Plymouth RI
are:
o minimize
the potential for direct contAct with surface ~oil
o minimize the potential for oEfsite migration of hazardous che~ic31~
Th~ technologies which appe~r most applicable to source control
with the intent of meeting the above objectives are capping or ex-
cav3tion in conjunction with offsite disposal.
Capping
Before a cap could be specified for the source area, it would
he highly desirahle to know more conclusively ~hether there
were additional sources of contamination underneath the tanks.
(,
In addition, confirMation of the e~isting pattern of con-
...
tamination as verified through supplemental saMpling onsite
-------
......-- -,.'.~'---~""-_. .
will result in a more confident oetermination of capping extent
and placement.
Knowledge of contaninant type, concentration,
and potential for migration are important pieces of information
'to ~ave to evaluate the effectiveness of a capping alternative
prior to selection of a remedial alternative.
In addition, because much of the site lies within a flood-
plain, the provisions of RCRA, 40 C.F.R. S 264.l8(b), the Flood-
plain Management Executive Order 11988, and the EPA policy on
Floodplains and Wetlands Assessment all require that a flood-
plains assessment be perfor~ed to evaluate the effects of onsite
remedial actions on floodplains, public health, welfare, and
other environmental values.
In conjunction with this assess-
ment, the need for flood protection measures ancillary to on-
site remedial actions must also be evaluated.
Finally, the
results of the onsite analysis must be compared with offsite
remedies to determine whether ofF-site remedies are practicahle,
cost effective, or necessary to protect public health or welfare
or the environment in comparsion to the onsite remedies.
Excavation
Excavation and off.site disposal, if implemented would require
.
excavation of contaminated ~aterial to a level protective of
human health and the environment (~CRA).
The areas of concern
relative to lead levels are fairly well defined.
However, un-
certainty about the distribution of contaminants underneath the
storage tanks precludes definitive identification of all contaminants
and areas of concern.
-------
In addition, the uncertainty about the potential vertical
extent of contaminants underneath the tanks precludes definitive
estimates of the volume of contaminated soil which will be ex-
cavated and disposed.
The reliability of the data base g~nerated
for the RI would benefit from suppleMental sampling both under
the tanks and other onsite locations outside the tank berms.
The
additional onsite sampling is necessary to more completely define
contaminant distribution.
The tank removal and subsequent sampling
will also result in more accurate estimates of contaminated soil
and more reliable removal cost estimates.
Reliahle cost estimates
are necessary for accurate comparisons of cost-effectiveness.
An
accurate cost-effectiveness comparison, in turn, is necessary in
order to justify offsite disposal under the terms of Section lOl( 24)
of CERCLA.
2.
The existing analytical data base consists of information
generated from a single sampling round.
The information generated
has resulted in the current understanding of contaminant distrihution.
The offsite contaminant pattern as indicated by the sampling conducted
for the RI has suggested that pesticides and PAHs are present in the
sediments of the tidal stream adjacent the site.
To make a more
informed judgement as to the potential sources of contamin~tion in
the tidal stream, and to ensure that the existing contaminant dis-
tribution does not contain areas of significantly higher contamination
.~
than what is currently known, a second round of offsite sample col-
lection and analysis is necessary to address the above concerns.
The
-------
additional sampling will result in more informed decision making
relative to offsite remedial Action, and the impact of the
CEc-plymouth site on the surrounding environment.
There is also some uncertainty concerning the impact oftid~l
flux on the distribution of groundwater contaminants.
To verify
the existing understanding of groundwat~r quality, sampling of
existing monitoring wells at high and low tide should be conducted.
Through careful planning, quality control, and quality assurance
procedures, a reliable date base has heen generated for the CEC-
PlymouthRI.
However, the current understanding of contaminant
distribution indicates a random distribution of most organic
constituents throughout tp.e site.
Because ther~ is variability
and uncertainty associated with any analytical data, it is
sometimes necessary to vprify existing information with additional
sampling.
In addition, replicate sa~ples collected during the RI
did not exhibit a good analytical correlation, further neces~itating
confirmatory sampling.
3.
Based on this analysis of relevant regulatory and policy
requirements, the EPA has detprmined that selection of the final
cost-effective alternative should be deferred until the following
activities have been performed;
a) tank removal
b) supplemental sampling
\1
c) floodplains assessment
-------
These tasks are described in more detail in the section
below e~titled "SELECTION OF REMEnIAL ACTION" which describes
the recommendations for this phase of the final cost-effective
alternative.
~
-------
:..-----".-.-'-.. ..", '''.''-''''~ .-" '.'...- -- .
SELECTION OF REMEDIAL ACTION
It has been determined that selection of th~ cost-effective
remedial <'Ilternative would hest he serveti hy generating Sllp-
plemental information (additional saMpling/analy~is, floonplain~
assessment) ann d~ferring selection of th~ final remedial al-
ternative until the new information has been generated and
evaluateti.
The ROD for the CEC-Plynollthsite woulti tt,en he
amended following evaluation of the new data and wou~d specify
the remedial measur.es deemed appropriate to address contamination
remaining at the site.
Therefore, the tasks necessary to generate
the supplemental information necessary for this further remeninl
analysis are:
1) Tank Removal -
In order to evaluate potential contaminant
distribution undern~ath the storage tan~s, tanks no. 1,2, and 3
and associated piping will be dismantled and disposed of offsite
in an appropriate manner.
Pending confirmation of the efficacy
of tank decontamination, much of the tank structure could be
disposeti of at an appropriate salvage yard.
Contaminated material,
if present, would be disposed of in an appropriate RCRA regulated
hazardolls waste landf ill.
2) Supplemental Sampling -
supplemental sampling is being specifierl
to:
a) confirm the pattern of contamination identified in the RI,
Ii
b) to char~cterize the contamjnant distribution underneath the storaqe
tanks.
The following sampling scope will he performed:
-------
_:.--..........~~_.:._. "_"_a
o soil samples consisting of surface an~ subsurface saMples of
th~ tank berms, the areas underneat~ the tanks, and othe~ on~ite
locations outside the tank her.ms.
o groundwater sample~ from the 5 existing mo~itoring wells
(high tide and low tide saMples)
"
o surface water and sediment locations (tidal stream and h~rhor
shoreline)
o Analyses are assuMed to be comparable to a full contract lab
analysis (EPA!CLP)
3) Floodplains Assessment -
A floodplain~ assessment will he con-
ducted and will include:
o a detailed floodplains classification of the site
o a review of relevart floonplains st~ndards
o implications of siting in a fldodplain
o analysis of alternativ~~ relative to floodplains
issues
o analysis of appropriate measures to mitigate flood har~
The assessment will he conducted consistent with Floodplai~s
Management Executive Order 11988.
Cost Estimates
The projectect costs associated with this portion of the remedial
decision are as follows:
-------
....................-.-. ----"-'
Supplemental sampling
Floodplains assessment
Tank dismantling
total
Capital Costs
S 171,000
10,000
169,000-252,000
$350,000 - 433,000
There is no operation and Mainten~nce associated with these costs.
Cost-Effectiveness and Consistency with the NCP and CERCLA
The remedial ~ctions specified in this ~ocurnent must be performed
in order to generate the information necessary to select the
final cost-effective remedy. No feasihle alternatives to these
remedial actions are available to generate this information.
The
tasks outlined here nre not the final re~edy for the CEC-Plymouth
Site, because they are necessary to .select the final remedy. These
remedial actions are ~n integral component of any final cost-effective
remedy.
~ more detaile~ analysis of the final cost-effective
remedy will be perforMed in the amended ROD which will descrihe
the full recommendation for site remediation.
The rationale for the need to conduct the preliminary studies
outlined in this section as part of the final cost-effective remedy
is summarizen below:
o Tank Removal - Necessary to characterize the nature and vertical
extent of any conta~inants underneath the tanks.
T~is informati0n
is necessary to evaluate the effectiveness of a cap or to estimate
the volume of co~taminated soil which Might need to he excavated
u
and disposed of~site.
o Supplemental Sampling - Necessary to characterize the con-
-------
.-J.'~"""""'- ---""~--"'_._-' "'. - --- ,- .
ta~inant nature of the soils underneath the tanks and to confirm
the contaminant distrihutinn throughout the ~ite a~ reported i.n the
RI.
Although the CBc-plymouth RI provides a reliahle data base,
the apparently ranoom distribution of contaminAnts needs to be
confirmed to propose a remedy that ef.fectively deals with all
known source arpas that could potentially present a hunan health
or environmental concern.
In addition, poor correlation between
replicate $amples (especially organic analyses) in the RI war~
rants confirmatory sampling to reinforce the existing data base
for the CFC-Plymouth site.
To adequately evaluate the potential
impact of ~ite contaminants on the tidal stream and Plymouth
Harbor, it is necessary to conduct a second round of sampling to
further the understanding of contaminant distribution in these
water hndies.
To evaluate the impact of tidal flu~ on the
distribution of contaminants on groundwater, high and low tide
groundwater ~ampling has been specified.
o Floodplains Assessment - Necessary to characterize floodplain
locations relative to the CEC-Plymouth site, to assess the potentinl
impact of floodplains on the site and vice versa, and to evaluate
the need for ancillary flood ~ontrol measures for on~ite remedial
actions situated in a floodplain.
This assessment is required by
and will be done in accordance with the Floodplains Managem~nt
Executive Order 11988.
Future Actions
'"'
When all data from the supplemental sampling and floodplains
assessment has heen generated, the informa~ion will be presen~ed
-------
. ~'-"'-'--_"4-......... '--"".-"-
to the public for comment and review.
Following receipt of com-
ments an evaluation of appropriate remedial rpsponses will be
undertaken.
The selection of the remedial response, and the sup-
por.ting data which rationalizes the reMedial action selected ~ill
be documented in an amel'1ded ROD.
~
-------
./
CANNON ENGINEERING CORPORATION
PLYMOUTH SITE
-------
--'--'-~'-"-"-_.""'.''''''''.''''''''_. --
RESPONSIVENESS SUMMARY
CANNON ENGINEERING CORPORA110N PLYMOUTH SITE
TOWN OF PLYMOUTH. MASSACHUSETIS
Introduction
This Responsiveness Summary for the Cannon Engineering Corporation (CEC)
. Plymouth Site documents for the public record the concerns and Issues raised
during remedial planning. comments raised during the comment period on the
feasibility study. and EPA's response to these concerns.
Concerns Raised PriOf to the feasibility stUdy Comment Period
Community Interest first focused on the site in the spring of 1983, when It was
revealed that two of the three storage tanks were leaking chemical waste and that
contamination might be spreading. Although drinking water was not affected, local
residents and industrial park employees were worried about their health.
The potential for explosion and for airborne transport of contaminants was another
concern expressed by the community. Residents of the more remote parts of the
town and other South Shore Massachusetts communities expressed concern about
contamination 01 shellfish, Irish moss areas. and bird sanctuaries.
The Plymouth selectmen have named a Hazardous Waste Committee. Members
include a marine biologist, an expert on 011 spill cleanup, and a representative from
the League of Women Voters. No ad hoc citizens' groups have been formed. The
following community relations activities were Implemented:
. A" Community Relations Plan (CRP) was drafted by the EPA in November
1983.
. On April 30, 1984, the Plymouth Hazardous Waste Committee held a
public meeting at the Plymouth Town Hall. At the meeting, EPA
presented plans for the Superfund cleanup study.
. Information repositories were established at the Plymouth Town Hall and
at the Plymouth Public Library.
. The Remedial Investigation (RI) and Feasibility Study (FS) reports were
felelsed to the public on July 3, 1985. At thlt time, copies of the reports
were placed in the information repositories at the Plvmouth Town Hall
and the Plymouth Public Library, and the July 11 and July 24 public
meetings were announced.
. The public comment period began on July 5, 1985.
-------
~--.-........ .__._0.__.. - "*-
Concerns Raised During the Comment Period
The feasibility study public comment period for the CEC Plymouth Site began on
July 5, 1985, and was extended to August 9, 1985. The EPA held two public
meetings during the comment period, one on July 11 and one on July 24. to solicit
Input from the community. Approximately 25 members of the local community
attended the first meeting and about 12 residents attended the second. On
August 6, 1985, the EPA released for public review a study of wetlands at the site.
The Wetlands Assessment characterizes plant and animal life and environmental
- recreational and aesthetic value of the wetlands, as well as the potential Impact 01
each cleanup alternative on the wetlands.
Remaining Concerns
All community issues and concerns are outlined in the following section under
-------
1.
2. .
3.
- 4.
5.
6.
7.
. 8.
9.
10.
11.
12.
13.
14.
15.
16.
17.
18.
19.
20.
21.
22.
INDEX TO PUBUC COMMENTS
Funding and Scheduling
Soli Sampling
No-Action Alternative
. No Justification for Action
Tanle Removal
Recommended Alternatives
Additional Sampling and Analysis
Capping the Site
Selection Process
Types and Amounts of Contaminants
Potential Health Hazards
PfPpe"y Values
Restricting Site Access
Public Health Rlsle
Installation of Fences
~
Sampling Bias
Capping Alternatives
Sediment Excavation
Unjustifiable Alternatives
Repo" Inaccuracies
Reliability and Completeness of Data
-------
PUBLIC a~ERN
c
RESPf~SE
._-------
1.
I-\.mdirg and SChedulirg
A representative from senator KenneOY's office
asked whether funds had definitely been allocated
for site cleanup for FY86 and when cleanup would
beyin on the site. It was also suggested that
EPA pay ~)r the cleanup and later sue responsible
parties- to recover costs, instead of negotiatincJ
with PRPs to have them perform the cleanup.
'!tie fiscal year '86 bl.Jdget has not yet been final i7.ed.
In addition, uncertainties related to reauthorization
of Superfund preclude any definitive budget allocations.
HONever, funds for Remedial Design have heen requested
for fiscal year '86, although the final dispositi.on of
this request will be ciictated hy the above cnnsidera-
- tions.
If negotiations with potential rP.sponsihle I~rti.es are
successful, the Agency will cons icier PRP undertaking of
remediation as this woulci freeup SUperfund lTIoney that
'.«>uld have been spent on this site for other Sllpt~rfund
-------
PUBLIC OONCERN
RESPONSE
2.
soil Sampling
A representative. fran CongresSlY1an Gerry Studd's office expressed
the Congressman's concern that the soil beneath the storage
tanks be sant>led, once the tanks are reroved. He feels that a
conclusive detenninatioo about the extent of contamination
cannot be made until deeper soil sant>les are taken, particularly
from directly beneath the tanks. Studds believes that, without
the data, it is inadvisable to select a cleanup alternative
and a budget. He believes it is critical that the preliminary
data collection be toorough in order to avoid a repeat of a
situation at the ReSolve site. (Cleanup was delayed two years
when contamination was discovered to be roore widespread than
was initially thought).
The Town of Plyroouth is also in favor of roore extensive soil
sampling onsite and offsite.
The EPA has recognized all along that a
potential data gap existed concerning the
distribution.of chemical contaminants
underneath the storage tanks. The
possibility that a localized shallow
source area exists directly underneath
the tanks cannot be ruled out without
further sanpling. This possibility
was considered in tormulating the recan-
mended action. It is useful to evaluate
the lessons learned fran past remedial
actions. The situation at the CEC-Plymouth
Site has been carefully evaluated, and ac-
tivities have been proposed that wi11
ensure the EPA wi11 undertake an adequate
-------
PUBLIC roNCE~
c
.
~
,
i
I
!
RESPOOSE
3.
No-Action Alternative
The Ta.m ot Plymouth is strongly opposed to the
No-Action Alternative. The town believes the per
tential for any contammation ot Plyrrouth Harbor
and its aquatic life via the adjacent tinal stream,
as well as the tuture industrial/camercial growth
of the area, justifies this position.
:.
It is EPA's position that the removal ot existing
structures is crucial to fully understanding contam-
inant dlstribution at the slte. Theretore, at a
minimum, EPA intends to remove existing structures,
and conduct addl tional stOOles. The t inal decislon
as to the appropriate method of site rernecHation will
he deferred until new information has been generated
-------
PUBLIC OONCEm
~
t
f.
[
REsroNSE
..
4.
No Justification for Action
One party stated that, since any public health
risks at the si te are minimal, there can 00 no
justification either tor pertonnil'YJ a multimillion
dollar remedial action at the site or for limiting
future land use of the site. In accordance with
controlling statutory and regulatory criteria
that require the remedy be cost~ffective to
tre~t public health objectives, either no action
or a highly selective remedial measure is called
for at the site, aCCOrding to an attorney for the
party.
'!he justification presented in the public ccmnent is
not entirely accurate in that analytical data does
SJggest that the interior of the bermed storage areas
00 contain contaminants of concern. Lead levels of
up to l, 700 MJ/kg were reported for shallow soil
Mmpling inside the berm, disputing the contention
that there are no near surface contaminant sources
warranting remedial action.
fbwever, ctecision on a specific remedial approach
to the site will be deferned until more information
-------
'--
~
c.
PUBLIC OONCERN
RESRJIISE
5.
Tank Removal
A representative fran the TcMn of Plyrrouth
commented that any alternative or combination
of alternatives chosen must include the
removal of tanks that presently remain on
site.
As explained in the dratt Feasibility Study pUbliShed
in June 19R5, the underlying asSUIt{>tion tor all
alternatives presented in that study is that the
storage tanks and exposed piping will be removed
tran the site prior to int>leJIentlng a reTOOdial
alternative. The R)[) specifies tank ret'1Oval as an
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PUBLIC CDNCERN
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6.
Recarmended Alternatives
The Town of Plyrrouth supports a canbination of
alternatives, including the selected soil and'
tidal stream sediment excavation and offsite dis-
posal, and the installatim of a RCRA-approved,
impervious cap covering the site area. The ta.rm
believes that, at this stage, there is insuffi-
cient data to select one alternative over another
or to detemine the overall costs for tre project.
EPA is deferring its selection of an
appropriate remedial response until
new information is generated and
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PUBLIC CDNCERling on site,
the Town of Plyrrouth [~I.lIends the following
actions:
o Additional on~ite and offsite sampling and
analysis of surface water sediments am surface
soil to determine backgroooo levels of poly-
nuclear aromatic hydrocarbons, pesticides,
ard inorgamc contaminants.
The analytical data available as a result ot
sampling already completed provides a useful
database. Additional onsite sampling is
planned prior to the design of the selected
remedial alternative. The additional field
data "will aid in the effective development
of an appropriate remedial alternative.
o Additional sampling and apalysis of onsite
shallow soil to further delineate the
lateral and vertical extent of soil
contamination.
The lard uses surroundirg the site vary
widely over a small area. It is therefore
considered as unlikely that adrtitional oft-
SIte sampling could establish a meanIngtul
nroad view of existing nackgroum levels.
o Onsite and off site sampling and analysis
of seeps to obta in data to fully determine .
the source at inorganic contaminants at
the site.
o sampling and analysis ot the peat layer
onsite and off site to determine whether
peat is a possIble source ot contamination.
o sanpl ing and analysis of groundwater during
periods of high and low tide to determine
the relationship bebeen tide cycle!'> and
the concentration of inorganIc contaminants
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8.
Capping the Site
A ment>er of the Hazardous Waste Carmittee for the
Town of Plymouth requested an additional study to
determine the etfect of a coastal tlOOd on any tyPe
of a cap that might t:e installed on the si te. He
stated that there is a ~sibility that installation
of any type of cap may not be an effective method
in the event ot a coastal t 1000.
To tully evaluate floodplain issues relative
to an awrq>riate remedial response, EPA has
specified that a floodplains assessment be
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RESlUNSE
9.
Selection Process
'Ihe decision-1Mking process surrounding the
selection of the cleanup alternatives was of
concern to several residents. Com1I.lni ty menDers
also wanted to know who makes the final selection,
whether the contractor has made any recarrneooations.
Several citizens inquired about the significance
of cost and whether cost was a major tactor in the
final decision. One citizen asked how soon the
cleanup process would begin once the "Record of
Decision (ROD) is signed. He also wanted to
kJ1()lN whether EPA considers the possibility
for. long-term irrpacts when considering
alternatives. At the July 11, 1985, public
meet ing, one person asked if EPA had enoogh
information at that time to choose a cleanup
alternative.
"
The decision-1Mking process with regard to selection of
remedial action alternatives at NPL Superfund sites consists
of the EPA issuing the Feasibility Study of reJ11:!CUal
alternatives to the public for their review and comment,
consideration ot toose canrrents, and selection ot the
appropriate remedy by EPA management, or in the case
of this site, the EPA Regional Administrator. All public
carments are considered, h<::Mever final judgement on al ter-
native selection lies with the EPA. .
Cost is a signf icant factor evaluated in selecting the
appropriate remedial alternative. Cost considerations
are weighed against environmental and public health
considerations, canpliance with other envirormental laws,
and technical feasibility in arriving at an appropriate
decision.
Once the R'JD is signed, funding of the remediation process
is pursued. This may consist of a request for Superfund
money or negotiation/litigation of responsible party action
and/or funding. The remedial design phase is ini t iated ,
then the appropriate remedial action is i"t>lemented.
In evaluating the appropriate remedial alternative, all
relevant information is considered, including future land
uses.
To increase the existing data base to make a 1'OOre fully
inforrneO decision, EPA intends to conduct additional
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21.
Reliability and ~leteness of IBta
One group questions the reliability of avail-
able data. The group is al9::> concerned that
the data iroicating the possible hazards to the
enviromtent are insufficient. In review of the
Remedial Investigation and Feasibility Study
Reports by a technical consultant of this group,
the consultant expressed concern that there are
gaps in the available data and also that the
suggested alternatives vary radically in price.
Because of these data considerations, the techni-
cal consultant for the group would like to have a
technical review meeting with the EPA technical
consultant. The group consultant feels a meeting
to discuss its technical concerns would benefit
both SideS.
')
Fleld sanples taken fran the site were sul:Jnitted to
the EPA' s Contract Lahoratory Progran for analysis am
the laboratory results were subjected to a rigorous
validation procedure.
It 1S EPA's view, that the currently available data
ba~ is reliable. supplemental sampling has been
specified in the IDO to enhance the understanding of
contaminant distribution.
The remedial alternatives presented in the Feasibility
Study do vary considerahly in price. The remedial
alternatives also very considerably in scope. The
Feasihility Study included a hroad range of potential
remedial alternatives both to meet regulatory require-
ments and to provide EPA with a broad base fran which
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22. Contaminant Sources
The technical consultant to one concerned
group of citizens states, .Of the critical,
identified contaminants, the phthlates,
pesticides, and lead are likely either to have
been naturally occurring ,In the fill material
used on the site, or to have been the result of
sources other than the storage tanks, such as
'pesticides used In surrounding agricultural
areas. Moreover, it is notable that, prior to the
use of two of the tanks by Cannon Engineering
Corporation, the tanks were used for the
storage of fuel 011, which is a source of
polynuclear aromatic hydrocarbons CPAHs).
Therefore, the PAHs found in the soil are
,probably not to be attributable to Cann"on's
actlvities'-
In terms of selection of the appropriate remedial
response, the source of the contaminants and responsible
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PUBUC CONCERN
RESPONSE
10. Types and Amounts 01 Contaminants
local residents wanted to know the types and
amounts of contaminants present at the site.
One citizen expressed concern over the effect
of a combination of contaminants. He
requested that there be 8 study of the additive
effect of the different contaminants that are
present on the site.
The types and concentrations of contaminants found on
the site were described In the draft Remedial
Investigation Report published In June 1985.
The net risk presented by the combination of
contaminants found on the site Is a legitimate concern.
While It Is understood that a variety of contaminants,
when mixed, may have a net effect that Is equal to,
greater than, or less than that of the Individual
contaminants, the current state-of-the-art of toxicology
Is not adequate to determine the actual net risk for a
specific situation.
Due primarily to the current state-of-the-art of
toxicology, a study to determine the additive effect of
the different contaminants that are present on the site Is
far beyond the scope of the studies performed on the CEC
Plymouth Site.
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11. Potential Health Hazards
The possible health risks to the community
were mentioned by one local resident, who
asked what the real danger was to adults and
children. One man asked about the possibility
of contaminant seepage. He also expressed his
fear of a higher risk for cancer, not just now,
but In the future. He stated his belief that the
whole town should be sued for cancer. One
resident commented that; although health risks
are remote now, the future should be
considered also.
The potential health risks to the community were
discussed in the draft Remedial Investigation Report
published in June 1985.
The health risks formerly presented by the site, with
regard to fire or explosion, were adequately mitigated
with the draining and cleaning of the onsite storage tanks
and exposed piping. Storage tank removal will be an
integral part of any remedial alternative Implemented on
the site. That action will mitigate any safety hazards due
to structures now on the site.
Some of the contaminants found on the site may be
described as potential carcinogens. The draft Feasibility
Study, published in June 1985, discusses the risk reduction
aspect of potential remedial alternatives presented in
that study. The remedial measures finally implemented
on the site will reduce the concentration of contaminants
on the site and/or reduce the po.tentlal for exposure such
that the long-term, chronic exposure frequencies and
concentrations necessary for carcinogenic effects will not
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PUBlIC CONCERN
RESPONSE
12. Property Values
A private citizen told EPA, ,he site (and Its
surrounding area) 15 prime real estate."
Residents are concerned that this factor not be
forgotten when alternatives are reviewed In the
selection process.
As Indicated In an earlier response. EPA considers all
relevant Information when selecting an appropriate
remedial alternative. .
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PUBLIC ~CERN'
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13.
~stricting Site Access
One resident said that warning signs posted a~
the citizens' request were not sturdy enough.
It was suggested to mention hazardous waste on
the sign. '!he resident also requested that a
fence be erected to prevent children frm
entering the site.
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The fahrication of ten 18-inch by 12-inch warning sic.Jns
was cmpleted Septemberr 9, 1985. P.ach si..Jn reads "Nn
Trespassing - Hazaroous Materials." EPA will inst;ill
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PUBLIC mNCERN
RESPONSE'
14.
Public Health Risk
ere ci t izen contends there is no evidence that the
site poses any danger of contamination of any
drinking water supply, nor does the si te pose a
threat to publ ic health or the envirorment. Also,
it is unlikely that contamination is moving off
site.
There <'Ire areas on the site that contain levels of
contaminants that. present a toxicological concern.
This is particularly true with regard to the areas
within the perimeter of the hems f';Urroundinu the
storage tanks. These areas do represent potential
risk to puhlic health and the environment.
Additionally, physical haz<'Irds are present on site,
which may affect trespassers (e.g., chi.ldnm) gain-
ing access to onsite structures. As a minimum,
floodtides and storm runoff are possihle mechanisms
for contaminant transport.
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15.
Installation of Fences
The lawyers for one party believe it is difficult
to justify any remedial action beyond tre installa-
tion of additional fences or other fonn of site
security to prevent the possibility of direct c0n-
tact with the site, although trey believe this
possihility of nirect contact is unlikely. This
alternative, they believe, is cost-effective if
rrore than the No-Action Alternative is needed.
Because it has been detennined that site conditions
present a potential public health ann environmental
concern, installation ot CKtditional fences alone,
would not adequately protect health or the
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RESPONSE
16. Sampling Bias
One group believes NUS sampling was biased
because locations for shallow soil sampling
were selected .where discolorations or soil
textures were Indicative of spills. (RI,
page 6-32). Therefore. there Is no basis to
assume broader contamination distribution,
according to the group.
Field samples were taken from specific onslte locations in
an effort to Identify worst-case conditions regarding
onslte contamination. The fact that samples were taken
from locations that appeared visually to be contaminated,
Is no reason to assume that contamination was confined to
the locations sampled. Although contamination may, In
fact, be confined to the sampled areas, It Is equally just
as likely to extend beyond those areas. The planned
supplemental sampling program is intended to address this
Issue.
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17.
Capping Alternatives
The caTl'Renting party believes a cap of limited
dimensions would be appropriate for the site,
and states that, since the Feasibility Study
concludes that the soil cap and the synthetic
cap offer basically the same degree of remedia-
tion, a soil cap is the nnre cost-effective
remedy. The party recarmaoos that a seeped ver-
sion at Alternative R (soil capping the site),
nocIitied to incorporate onsite sediment disposal,
be adopted at the sHe if the No-Action Alternative
is not se lected.
A decision on recommendation at a specific remedial
act ion at the Ri te is he ing deferred until new
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PUBLIC OONCE~
RESroNSE
18.
, .
Sediment Excavation
One party and its lawyers disagree with NUS'
assumpt ion that 900 cubic yards of sediments
in soils should be,excavated fram the tidal
stream because the figure was calculated basec1
on faulty aS5\..DnPtions. The party is concerned
that, based on these assumptions, there is a
risk that the selected alternative will not be
cost -eft ect i ve.
A decision on reccmnendation of a specific remedial
alternative at the site is being deferred until neW
information is generated and evaluated.
The party suggests placing these sediments under
the onsi te cap, and thus avoiding the costs, de-
lay, transportation risks, and off site capacity
availability problems associated with offsite
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PUBLIC riate. The group's
technical consultant is concerned that the
excavation and removal alternatives would
represent an increases threat to public
health and the envirorment, owing to
increased exposure to the contaminants.
A detailed assessment of alternatives
will be presented in the anrnended
IDD.
Alternative 9, which involves "selective"
soil excavation for otfsite incineration ot
contaminated soils, far exceeds any cost-
effective remedy for the site, according to
one COTmenting group.' The party and its
legal representatives also expressed concern
about the air emi~sions fran the incineratim
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20. Report Inaccuracies
The legal counsel for one party believes there
are factual Inaccuracies In the Feasibility Study
Report. These reported errors are as follows:
.
'The Inaccuracies notad In the Feasibility Study will be
corrected when the study Is published In Its final form.
.
The report states -CEC rented the storage
tanks from the Cordage Company In 1975.-
This Is Incorrect. CEC rented one tank
from Cordage Park beginning In 1976.
CEC later rented a. second tank from
Cordage Park.
.
The Salt Water Trust's contractors emptied
and decontaminated one tank In 1983, and
EPA's contra~tor performed the work on
the second tank. The Feasibility Study
Report states -at the expense of the Salt
Walter Trust, tanks were emptied and
cleaned In 1983 and 1984.- .
.
Salt Water Trust bought the site property
In 1969, not 1959, as stated In the
Feasibility Study Report.
.
Salt Water Trust believes that, while It has
performed all actions required of It In
connection with successful removal and
decontamination activities at the site, thus
acting responsibly in the public Interest. it
was ordered to do these activities on
threat of penalty by EPA and DEQE. The
Feasibility Study states that Salt Water
Trust -agreed to pay for the removal of
waste from one of the two full ta,nks on the
site, even though they had not been held
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