1.1.1 Incident Category

CERCLA Incident Category: Inactive Production Facility - Chromium plating facility

1.1.2 Site Description

The Walton & Lonsbury (W&L) Site (the Site), located at 78 North Avenue, Attleboro, Bristol County, Massachusetts, is owned by Walhard Realty Trust and consists of a 13,500 square-foot chromium plating facility, formerly operated by Walton & Lonsbury, Inc. on a 2.72-acre lot. It is identified as Map 89, Lots 2D, 4 and 5.

The Site is zoned for industrial use, and was previously operated as an industrial plating facility, with the unique ability to chrome-plate very large and/or long objects (e.g., pistons for large hydraulic equipment, rollers for paper mills).

Electroplating operations had been conducted at the Site since 1940; W&L operated chromium plating operations at the Site until it ceased operations in 2007. Copper plating was also conducted at the facility until the building was remodeled in the late 1950s. Facility operations included solvent-based parts degreasing, hard chrome plating, stripping with acids, aqueous rinsing, grinding, and polishing.

Throughout the years of operation, on-Site chemical usage has included trichloroethylene (TCE), 1,1,1-trichloroethane (TCA), chromic oxide, hydrochloric acid, sulfuric acid, phosphoric acid, cyanide, paint thinner, aluminum oxide, sodium hydroxide, sodium bisulfate, sodium hydrosulfate, and lead sulfate. Wastes generated at the Site include hydrochloric acid, chromium hydroxide sludge, chromic acid wastewater, chromic acid contaminated solids, TCE, TCA, aluminum oxide dust,and cyanide plating bath solution.

From 1940 until 1970, wastewater and wastestreams generated at the Site discharged directly to the wetlands on the southern portion of the property via an underground pipe from the plating room. In 1970, W&L abandoned and plugged this underground pipe and installed a wastewater treatment facility on Site to treat electroplating wastes (primarily chromium hydroxide sludge)which were then discharged to a surface impoundment and lagoon for dewatering. The effluent from the dewatering impoundment and lagoon was then discharged into the wetland area via a storm water trench located on the west side of the property.

While initially closing the impoundment and lagoon, only visual criteria were used to assure all contamination was removed prior to capping in 1985-86. Environmental sampling in 2001 (conducted by W&L's contractors), with supporting samples taken by EPA in 2010 during the Preliminary Assessment/Site Investigation (PA/SI), indicates that contamination remains and continues to contribute to the sub-surface soil and groundwater impacts.

In the late 1980s, the wastewater treatment system was converted to closed-loop for process water, while chromium hydroxide sludge was accumulated and shipped off-site for disposal (approximately 4,000 gallons of sludge were shipped off-Site every 90 days). Employee interviews have indicated that the closed-loop system was consistently compromised. Regularly, a quantity of water in excess of the wastewater treatment capacity would slowly discharge through a hole in the wall leading to an area of rip-rap on the west side of the facility. This water would either flow through the rip-rap towards the wetlands, and/or be absorbed into the porous soil adjacent to the facility. It has been indicated that this process water in the closed-loop system was sometimes contaminated with chromic acid leaking from cracked heating coils.

Lead is also a contaminant of concern. Lead was used for a variety of operational processes in the chrome-plating operations. A small lead smelter and exhaust hood are found in the mechanic’s shop in the south-west corner of the facility, which were used to make the anodes involved in electroplating. The lead anodes would eventually melt away in the 140^⁰ F chromic acid tanks, and contribute to the waste stream from the plating process.

The employee lunchroom once was the site of the W&L copper plating operations. There appears to be evidence of a former trench emanating from this side of the building, to the location of the historic storm-water/surface water discharge (before it was buried when the lagoon and impoundment were installed).

An abandoned dry-well located on the south side of the facility has also been identified as a possible source of volatile organic compound (VOC) contamination in the sub-surface. It has reportedly been used for the disposal of waste TCE, and is considered to be a potential source area for TCE, TCA and other VOCs.

On the west side of the building, two 275-gallon above-ground storage tanks (ASTs) of TCE & TCA were historically located near the smoke stack. The ASTs stored TCE and TCA for internal degreasing operations. TCE was used on Site from an unknown period of time until prior to 1983, at which time TCA was determined a more environmentally permissible alternative. From 1983–1994, TCA was then used for parts degreasing. Based upon hazardous waste reports from 1988, 1989, and 1991, the average annual usage of TCA was 147 gallons. According to the consultant reports, in addition to interviews of past employees, several overflow spills are known to have occurred during the early 1980s.

The roof of the electrical room on the south side of the facility is located immediately beneath the exhaust ducts from the chromium plating tanks. Over the years of operation (prior to installation of air emissions controls in 1997), chromium residue accumulated on the roof. During storm events, runoff from the roof dissolved the chromium residue and then discharged to the ground surface adjacent to the building.

Owing to the configuration of the plating area floor trenches, a thorough inspection of the integrity of the walls and trenches has not been feasible. Given the condition of the visible floor areas near the plating tanks, it is believed that the concrete trenches are extremely porous and have been impacted by the strongly acidic and corrosive (pH of<1) properties of the chromic acid used in the plating process. Interviews with former employees and historic photographs indicate the condition of these tanks has contributed to contamination below the foundation of the building. Environmental samples from alongside these tanks demonstrate that there are extremely high concentrations of total chromium, as well as very toxic hexavalent chromium.

In 2007, when W&L terminated its operations, there were four active plating tanks (out of six that were in operation when the dry scrubber air handling systems were installed in 1997). Still present in the building, these tanks have capacities of 740 gallons, 680 gallons, 1,440 gallons and 1,210 gallons.

During the PA/SI in August 2010, chromic acid and large quantities of chromic acid sludge were determined to still be present in the tanks, despite the emergency removal of materials performed by MassDEP from January 25–February 18, 2008.

1.1.2.1 Location

The Site is located at 78 North Avenue in Attleboro, Bristol County, Massachusetts. The geographical coordinates, as measured from the approximate center of the property, are 41° 57' 26" north latitude and71° 17' 51" west longitude.

The Site is bounded by Walton Street to the north with industrial and residential properties beyond; North Avenue to the east with residential properties beyond; industrial properties to the west; and wetlands and residential properties to the south.

Though the Site is the first property in a small industrial park that extends due west from the Site, this industrial zone is surrounded by not only a residential neighborhood, but is also situated directly across the street from the City of Attleboro’s largest recreational facility, the Hayward Recreation Center (an open-space recreation zone that includes Spatcher Pool & Bathhouse, playground equipment, two baseball fields, and two football fields).

According to the United States Census data for 2000, approximately 8,136 people live within a 1-mile radius (with 2,246 living within a ½ mile, and 829 living within ¼ mile). Based upon EPA Region 1’s Environmental Justice Mapping Tool, the Site is not located within an environmental justice area.

1.1.2.2 Description of Threat

During August 2010, a Preliminary Assessment / Site Investigation was conducted by EPA, at which sample results confirmed the Site is predominantly contaminated with metals (total chromium, hexavalent chromium, and lead), polycyclic aromatic hydrocarbons (PAHs), and volatile organic compounds (VOCs) . Through information derived from interviews and physical evidence, it is believed that chrome plating waste materials were disposed of behind the building in the wetlands from the late 1940s through 2007.

Chromium VI (Cr-VI), and chromium compounds (i.e., total chromium) are hazardous substances as defined by Section 101(14) of CERCLA, 42 U.S.C. §9601(14). In 2001, Cr-VI and total chromium were indicated to be present in levels as high as 81,800 mg/Kg (i.e., parts per million, “ppm”) in the wetlands (near the location of the 1940-1970-era facility waste discharge outfall); and again in 2010 these compounds were present as high as 42,000 ppm in the facility. Historic and current data show Cr-VI and total chromium contamination present at the Walton and Lonsbury Site, wetlands/conservation land, and some nearby residential properties. Therefore, a release into the environment of hazardous substances has already occurred, and impacted source soils continue to contribute to the residential and wetland contamination. (Additional investigatory sampling concurrent to the Removal Action will be conducted in the wetlands behind W&L and at the homes on Paulette Lane and North Avenue; allowing for EPA to refine the current extent of contamination volumes necessary for excavation.)

Other hazardous substances as defined by Section 101(14) of CERCLA that have been released at W&L and abutting properties and are shown in the tables below with the highest concentrations detected compared to the remediation standards identified in the MCP.

[1] The Soil Category S-1 standards are based on a residential exposure scenario in which the potential receptor may come into contact with the contaminated soil in their yard while playing or gardening. The evaluation also includes the ingestion of home-grown fruits and vegetables from a small garden.
http://www.mass.gov/dep/cleanup/laws/prop_s1.htm

[2] MCP Method 1: SOIL CATEGORY S-1 STANDARDS defines that the Total Chromium standard is applicable in the absence of species-specific data for Chromium III (Cr-III) and Cr-VI.
http://www.mass.gov/dep/cleanup/laws/0975_6a.htm

[3] The MCP GW-2 groundwater standards (310 CMR 40.0974(2)) apply to groundwater that is considered both shallow and where there is currently a structure built on the land above the groundwater. These standards are intended to address the potential migration of volatile oil or hazardous material from groundwater into the indoor air. Both GW-2 and GW-3 standards apply.
http://www.mass.gov/dep/cleanup/laws/gw2.htm

[4] The MCP GW-3 groundwater standards (310 CMR 40.0974(2)) apply to all groundwater in the Commonwealth. These standards are intended to address the adverse ecological effects that could result from discharge of oil or hazardous material to surface water. Both GW-2 and GW-3 standards apply.
http://www.mass.gov/dep/cleanup/laws/gw3.htm

The presumed migration route(s) for contaminants of concern were summarized in the October 29, 2001 Conceptual Model by Resource Controls (See Attachment I).

In addition to the known contamination listed above (and because W&L was a hard chrome plating facility of an era that traditionally generated or contained additional contaminants of concern not previously evaluated); EPA has begun supplementary site investigations to determine other pollutants or hazards, including (but not limited to): cyanides, PCBs, and asbestos. Sample results are forthcoming, and the asbestos removal was completed in December 2010.

In the event that PCBs are identified at the Site and exceed or have the potential to exceed default standards and cleanup levels considered protective of public health including: EPA’s PCB Cleanup and Disposal Regulations, 40 CFR Section 761.61,(1 ppm for unrestricted use, and 10 to 100 ppm with a compliant cap); the preliminary remediation goals (1 ppm for residential areas, 10 to 25 ppm for industrial use) specified in EPA OSWER Directive 9355.4-01; and the Massachusetts Contingency Plan Method 1 default standard of 2 ppm for both residential and industrial soils.

1.1.3 Preliminary Removal Assessment/Removal Site Inspection Results

See Above.

EPA OSCs seve as liaison officers.

Liaison Officer (LNO) = Elise Jakabhazy
Assistant Liaison Officer (ALNO) = Elsbeth Hearn

U.S. Environmental Protection Agency’s (EPA) Liaison Officers (LNOs) met with the mayor of the City of Attleboro on October 12, 2010 and then again on December 22, 2010 to update the city on activities at the Site.  The EPA LNOs met with the Attleboro Chief of Police on December 15, 2010 to discuss Site issues including security, and safety of officers in the case they ever need to enter the property.

EPA’s LNOs have discussed building demolition, wetland excavation, contamination, residential air monitoring, and restoration activities with the following local, state and federal agencies:

• Massachusetts Department of Environmental Protection (Boston and Southeast Region)
• U.S. Fish and Wildlife Services
• U.S. Army Corps of Engineers
• Attleboro City Hall (Mayor)
• Attleboro Planning Department
• Attleboro Conservation Commission
• Attleboro Police Department
• Attleboro Department of Public Works
• Attleboro Building Inspector
• Attleboro Health Department
• Attleboro Water Department

• Massachusetts Department of Environmental Protection (MassDEP)
• Army Corps of Engineers (USACE)
• Massachusetts Department of Public Health (MA DPH)
• Agency for Toxic Substances and Disease Registry (ATSDR)