The location of the Site is 41 Summer Street in Attleboro, Massachusetts. Page 58 on Deed Book 2617 in the Bristol County Registry of Deeds provides a legal description of the Leavens Awards property. Lot 222B on Map 33 in the Attleboro Tax Assessor’s Office depicts the boundaries of the property together with surrounding parcels. The boundaries of the Site are the Ten Mile River and residential properties to the north, the Ten Mile River and railroad tracks to the east, commercial properties to the south, and commercial and residential properties to the west.
The building has been secured in this photo.
The Site is located on a 4.2-acre parcel in a mixed residential/industrial area. The estimated population within one-quarter mile is 769 people, and there are four public schools within one mile. Passenger trains routinely use the railroad track passing by the Site. Summer Street is a dead-end road with its terminus in the parking lot for the Leavens Awards facility. Most of the property outside the building is pavement for parking. The property is generally flat, but with a gradual slope down toward the River. At the southeast corner is a surface impoundment, from which the property descends steeply to the Ten Mile River. The surface impoundment has a locked fence around it. The Ten Mile River is a Class B water body, suitable for fishing and swimming.
On November 29 and 30, 2004, EPA performed a Superfund Removal Program Preliminary Assessment/Site Investigation (PA/SI). The building at the site was not secure, and graffiti was present inside and outside the building. Inside the building were drums and tanks, a plating vat, suspect asbestos-containing material on the floor, and a flooded basement with drums in this water. Drums were also present outside.
EPA collected samples from drums inside the building, suspect asbestos-containing material on the floor of the building, and standing water in the basement. Samplers observed a submerged drum in the water in the basement, as well as several tanks estimated to be over 1000 gallons each. To avoid the unknown chemical hazard and unnecessary physical risks associated with working in approximately two feet of dark, standing water, personnel did not sample the tanks and drums in basement. Labels on drums included "marine pollutant," "corrosive," and "oxidizer."
Removal PA/SI testing confirmed that the contents of one drum inside the building contained corrosive material with a pH of 14.4. The residue in a plating vat leached the hazardous substance silver at a concentration nearly three times the federal limit necessary to qualify as a hazardous waste. Pipe insulation on the floor inside the building contained 30 to 40 percent chrysotile asbestos. One drum of fiber drum outside the building was degraded, and a solid, white material was spilling out. Test results on the contents revealed a pH of 13.4. Sample personnel covered this material with sheets of plastic to limit access.
Hazardous substances were also detected present in the water in the basement, including trichloroethylene, tetrachloroethylene, and silver. Test results also revealed the presence of hazardous substances in subsurface soil in the surface impoundment, including but not limited to tetrachloroethylene at a maximum concentration of 280 parts per million (ppm). State regulation provides that the maximum acceptable concentration of tetrachloroethylene for this soil at this site is 30 ppm. Testing also reveals that this soil is a hazardous waste. Testing reveals that tetrachloroethylene is present in leachate from this soil at a concentration of 2.1 ppm. Federal regulation provides that the maximum allowable concentration in leachate is 0.7ppm.
An EPA Closure Memorandum dated May 10, 2005, formally documents the conclusion of the removal evaluation of this Site. It recommends that a removal action is appropriate because conditions at this Site meet the criteria in the National Contingency Plan (NCP) for initiating a removal action.
Just prior to initiating a fund-lead response action, the mortgage holder for the property volunteered to do work at the site. Work was performed on a voluntary basis with no enforcement instrument. EPA provided on-site technical oversight as part of a unified command with the mortgage holder by reviewing the scope of work with the mortgage holder's contractor prior to initiating work, and via a joint inspection of the work that had been done.
EPA was successful in getting the mortgage holder to address the more immediate threats. Although some residual chemical in and under a plating bath was overlooked, and inspection of tanks in the basement was not documented with a report or photographs, the building has been secured from tresspass, and drums of chemical waste were shipped off site. The mortgage holder, however, was steadfast in his desire that hazardous waste buried in the surface impoundment be addressed under state authority.
Because of the work the mortgage holder completed, current conditions do not warrant assigning the limited funds available to EPA's removal progarm to address remaining conditions. Based the position taken by the mortgage holder regarding the work remaining, site conditions, the site's low priority with DEP, and the absence of a request for assistance from DEP, the Removal Program is no longer maintaining an active case file on this site. This was conveyed to DEP via certified letter dated 7 April 2006, effectively transferring the role of lead agency responsible for this site to DEP.
The removal actions planned for this site are shown below, and are also found in the action memorandum. These actions were performed with the exception of removing contaminated subsurface soil in the impoundment, which the mortgage holder wants to address using state regulation.
Removal activities will include a site walk with the cleanup contractor, sampling and characterizing the hazardous substances present, consolidating and repackaging containers for safe transport, collecting friable asbestos-containing pipe insulation, and disposing of hazardous substances at approved off-site disposal and/or recycling facilities. A security guard will secure the Site to reduce the likelihood of access to hazardous substances in the building. The OSC anticipates discontinuing the security service after drums and the contents of tanks are off-site.
Response actions in the building will include removing the water in the basement to allow assessment of that area, and if possible, securing major points of entry to prevent water from accumulating during the response action. Measures to prevent the basement from flooding will be temporary in nature, designed to last only for the duration of this response action. Drums or other containers located in the basement will be stored together at a common staging area with those found in other parts of the building. Response actions in the basement will include inspection of the tanks, sampling any contents, and disposal based on the presence of hazardous substances, or pollutants or contaminants.
Response actions outdoors will include moving drums indoors to the staging area established for those found inside the building, and the excavation and disposal of soil that meets the federal definition of hazardous waste. This activity is applicable to the surface impoundment and any other area discovered prior to the completion of planned response actions. Based on available funding and receipt of applicable Massachusetts Contingency Plan standards from DEP, the cleanup may include removing soil that exceeds state standards.
Personnel will collect samples of waste, soil, water, and air to comply with the requirements of the Site’s health and safety plan, characterize waste, and to document meeting cleanup goals.
|
