Proposed Keith Middle School Site

       EPA Proposes Approval of McCoy Field Cleanup Plan

What is EPA's Role in Redeveloping the McCoy Field?
Locating the new middle school at the McCoy Field is a local decision over which EPA has no authority.
EPA's involvement with this school project is triggered by the presence of PCBs. Under the Toxic
Substances Control Act, EPA is required to oversee the cleanup and disposal of PCBs at this site. The
MA Department of Environmental Protection is addressing the other contaminants of concern including
metals and semi-volatile organics.

EPA's oversight at the McCoy Field includes the following:
   •   requiring a cleanup plan from the City of New Bedford;
   •   reviewing the cleanup plan;
   •   rendering a decision on the cleanup plan's technical merits that is either: approval, approval
      with conditions, or denial;
      providing implementation and maintenance  oversight of the cleanup plan.
                                                     Want More Information?
                                                Come to an informational meeting 7 pm,
                                                  Wednesday, June 22, 2005 at the Keith
                                                Middle School Library, 70 Hathaway Blvd.,
                                                            New Bedford.

                                                Copies of EPA's proposed approval and all
                                                relevant site documents are available for
                                                 review at the New Bedford Free Public
                                               Library (613 Pleasant St., New Bedford) and
                                                   at EPA (One Congress St., Boston).
 What Does it Mean that EPA has Issued a "Draft Approval" for a Risk-Based Cleanup
 and Disposal Plan for the McCoy Field?
 At this point in the process, EPA has completed its review of the cleanup plan submitted by the City
 of New Bedford.  Based on the technical components, EPA has issued a draft approval of the plan.
 Final approval is pending public input on the plan's technical merits and long-term monitoring and
 maintenance plan.
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  What are PCBs?
  PCBs (polychlorinated biphenyls) are
  man-made  chemicals  which  are
  typically oily liquids, ranging from
  colorless to light yellow in color. They
  have no smell or taste.  PCBs were
  widely used as coolants and lubricants
  in transformers, capacitors, and other
  electrical equipment until 1977 when
  the  manufacturing  of PCBs  was
  banned.

  Although  PCBs  are  no  longer
  manufactured, they  are persistent
  chemicals  and   once   in   the
  environment, do not break down
  easily. Due to their limited volatility
  and solubility, PCBs they tend to
  remain  attached to  particles of soil,
  although any process that moves soil
  can  also move the attached PCBs.
  Airborne PCBs are a health risk only
  when one breathes HIGH airborne
  levels of PCBs for a LONG time.

  The health effects from PCBs  may
  include liver and immune system
  damage; neurological, developmental,
  and reproductive effects; and cancer.
What Input can Citizens Have at this Point?
   •   EPA welcomes comments on the technical
      merits  of the cleanup plan.  If new technical
      information is presented which was not included
      in the Application, was not considered in EPA's
      decision-making process, and would impact
      EPA's  determination on the  safety  of the
      proposed plan, EPA could direct the cleanup
      plan to be modified or decline final project
      approval.
   •   EPA is also soliciting comments regarding the
      site's long-term monitoring and maintenance
      implementation plan (MMIP). The MMIP shall
      also include a communications component
      which  details  how the maintenance  and
      monitoring results will be communicated with
      all site users.  Public comment will be considered
      in determining the final requirements for the
      site's monitoring program.
   •   Comments must be received or postmarked by
      Friday, July 15, 2005 and can be sent to:
                  Kimberly Tisa, PCB Coordinator
                  U.S.  Environmental Protection
                  Agency
                  One Congress Street, Suite 1100
                  (CPT)
                  Boston, MA 02144-2023

                  By e-mail:
                  tis a .kimberly @ep a. go v
                  By fax: Attn: Kimberly Tisa at 617-
                  918-0527
 How is this Cleanup Plan 'Risk-Based'?
 The risk-based cleanup plan, submitted to EPA on March 21, 2005, is designed to address all known
 soil contamination at the site, but focuses primarily on the most prevalent and toxic contaminants
 including PCBs, PAHs,  and metals.  In order to have health risks from chemicals, one has to have
 exposure  to those chemicals at levels that can be harmful. A Human Health Risk Assessment
 determines what possibility there is that chemicals from a site will cause current or future health
 risk to individuals who  come into contact with them.  Risk assessments are conservative, to prevent
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underestimating the health risks to the public. These risk assessments are used to develop cleanup
plans that protect human health and the environment.

The City conducted a Human Health Risk Assessment for the McCoy Field with the future reuse
being a school.  In performing the assessment, it evaluated a number of activities that could result in
exposure to humans. Direct contact exposure could occur if contaminated soil comes in contact with
skin or if contaminated soil is ingested through unintentional hand-to-mouth transfer.  The possible
activities were evaluated with students, school employees, visitors, municipal employees, and current
workers, such as construction and utility workers as part of the scenarios.

This human health risk assessment and the proposed cleanup actions were reviewed by EPA and
were found to be consistent with EPA methodologies and risk guidelines.  EPA has determined that
the City's proposed  plan is acceptable and there will be no unreasonable risk to site users when the
cleanup is completed. As an added safety measure, a long-term monitoring and maintenance program
will be implemented to insure continued protectiveness of the cleanup actions.

 Cleanup Plan Overview
 EPA's draft Approval is only for the McCoy Field site and does not address contamination to adjacent
 wetlands, on residential properties, or at the existing High School. In general, the proposed cleanup
 plan includes the following:

      Removal of PCBs of greater than or equal to 100 parts per million within the excavation areas.
      Installation of a  surface cover outside the building footprint, which includes:
             landscaped areas: a geotextile liner and a minimum of a 3-foot soil cap;
             parking areas: a geotextile liner and a minimum 2-foot soil cap with an asphalt cover.
      Construction of the school building on pile caps/grade beams above ground surface.
      Installation of a  passive vapor collection system and solid vapor barrier beneath the building
      footprint.
      Establishment of a long-term monitoring and maintenance plan for the surface covers  and
      indoor and groundwater monitoring.
      Development of a communications plan as part of the long-term monitoring and maintenance
      implementation plan  (MIPP).

 While the MIPP has not been  fully developed, the application does provide a  proposed plan for
 monitoring and maintenance for the surface covers, indoor air,  and groundwater.  More detailed
 information on the clean up plan can be found in the site documents at the New Bedford Free Public
 Library (613 Pleasant St., New Bedford) and at EPA (One Congress St., Boston).

 What Additional Safeguards are being Included in the Cleanup Plan?
 EPA believes the excavation of the most contaminated soil and the installation of the  surface covers
 are protective  of human health, and has determined that there will be no unreasonable risk to site


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    users when the cleanup is completed.  However, the following required additional protective
    measures will provide an added level of safety. These include:
           indoor air monitoring;
        •   solid vapor barrier;
        •   passive ventilation system.

   Have  Other Contaminated Sites been Redeveloped for Reuses that  Include
   Children?
   Yes.  Throughout the country, there are many examples where contaminated sites have been
   redeveloped in ways that protect human health and the environment. Schools, educational, and
   municipal buildings have been built in Everett, Lowell and Springfield, MA; New  Haven, CT;
   and Providence, RI. These serve as examples where contaminated sites now safely host children.
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U.S. Environmental Protection Agency
Boston, MA
Doug Gutro
Special Assistant to the
Regional Administrator
617-918-1021
Toll Free 1-888-372-7341, ext. 81021

MA Department of Environmental
Protection - Lakeville Office
Gerard Martin
508-946-2799

Additional information on PCBs may be
found   on   EPA's  website   at
www.epa.gov/pcb and on the City's
website at www.ci.new-bedford.ma.us.

EPA's draft approval  is posted at:
http://www.ci.new-bedford.ma.us/
mccoy.htm
Background
The proposed site for the new Keith Middle School occupies
approximately 7 acres and is bounded by Hathaway Blvd, Ruggles.
Summit and Durfee Streets.  The site is owned by the City of New
Bedford and was previously used as a recreational field. Historic dumping
and burning activities from the operations at the former municipal burn
dump (located  at the existing New Bedford High School) is likely
responsible for  the PGBs, metals, (including lead and barium) and
polyaromatic hydrocarbons (PAHs) contaminating the site.

In March 2004, the City determined that PGBs were present in soil
samples collected from the site and along the proposed utility corridor at
greater than 50 parts per million. As a result, EPA and the City entered
into a Consent Agreement and Final Order (GAFO) on May 21, 2004.
This agreement:
        allowed  excavated soil disposal based on existing  PGB
        concentrations;
        required the City to conduct sampling to characterize the site's
        contaminants in areas proposed for utility corridors and within
        the proposed building footprint;
        Required the City to cleanup the PGBs in accordance with the
        requirements of federal PGB Regulations.

EPA amended the GAFO on October 16, 2004 to incorporate additional
areas  for characterization and soil removal.

As the party responsible for conducting the cleanup, the City of New
Bedford officially designated the site as a Public Involvement Plan Site
on March 30,  2004  after the  MA  Department of Environmental
Protection received a request to have the site designated  as such.  The
City has established information repositories and has held regular public
meetings to provide site activity updates.
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