EPA’s Removal Program performed a Preliminary Assessment/Site Investigation that began by reviewing existing information. Based on this information, a sample grid was established, and soil samples collected at 69 locations. Samples were also collected of exposed waste at 4 locations, and solid waste in 2 drums. A surface soil sample (0-3 inches) was collected at each grid point, and about half were selected for sample collection at 1.5 and 3 feet, although not all reached these depths due to refusal. Based on existing data, analysis of soil was limited to metals, except for a fraction that were also analyzed for asbestos and hexavalent chromium to fill this data gap. Drums and waste were tested for a full range of analytes, including the Toxicity Characteristic Leaching Procedure (TCLP).
The results of testing performed at EPA’s New England Regional Laboratory (NERL) on surface soil samples identifies the presence of the hazardous substance lead in 14 surface samples and 9 subsurface samples at a concentration that exceeds EPA’s Removal Management Level (RML) that corresponds to either a 10-4 risk level for carcinogens or a Hazard Quotient (HQ) of 3 for non-carcinogens in industrial settings.
NERL data also shows that several hazardous substances are present in all drum and waste samples, including bis(2-ethylhexyl)phthalate in one drum at 170 million parts per million (ppm), which exceeds the industrial RML of 16 million ppm. In addition, the waste in this drum is a hazardous waste, as a Toxicity Characteristic Leaching Procedure (TCLP) test yielded a concentration of 3.2 ppm for cadmium, which exceeds the regulatory limit of 1.0 ppm. Lead is present in two of the four waste samples at concentrations of 5,370 ppm and 7,270 ppm, each of which exceed the RML of 800 ppm. While RMLs are designed for comparison to soil, the comparison to drums and waste at this Site is useful because accessibility is the same as soil.
The Site can be accessed by walking around the end of a fence line that stops in the woods in the northeast corner. Historically the fence is regularly breached at various locations.
A Closure Memorandum dated 27 July 2016 formally documents the conclusion of the removal evaluation, and 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.
