U.S. ENVIRONMENTAL PROTECTION AGENCY
POLLUTION/SITUATION REPORT
Central Steam Plant oil spill - Removal Polrep
Initial Removal Polrep
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Region I
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Subject:
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POLREP #1
Initial
Central Steam Plant oil spill
Z1CZ
Fitchburg, MA
Latitude: 42.5683510 Longitude: -71.8436711
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To:
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From:
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Richard Haworth, On-Scene Coordinator
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Date:
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7/11/2012
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Reporting Period:
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06/29/2012 - 07/13/2012
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1. Introduction
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1.1 Background
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Site Number: |
Z1CZ |
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Contract Number: |
EP-W-08-062 |
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D.O. Number: |
30 |
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Action Memo Date: |
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Response Authority: |
OPA |
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Response Type: |
Emergency |
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Response Lead: |
FEMA |
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Incident Category: |
Removal Action |
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NPL Status: |
Non NPL |
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Operable Unit: |
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Mobilization Date: |
7/9/2012 |
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Start Date: |
7/9/2012 |
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Demob Date: |
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Completion Date: |
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CERCLIS ID: |
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RCRIS ID: |
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ERNS No.: |
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State Notification: |
Yes |
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FPN#: |
E12106 |
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Reimbursable Account #: |
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1.1.1 Incident Category
On-shore, non-transportation, EPA-lead, OPA-funded response action
1.1.2 Site Description
Oil seeping through a stone & motar retaining wall into the North Nashua River.
1.1.2.1 Location
The former Central Steam Plant at approximately 465 Westminster Street, Fitchburg, Massachusetts.
1.1.2.2 Description of Threat
Oil releasing from the site was creating a sheen on the North Nashua River, a navigable waterway of the United States. The North Nashua River flows to the Nashua River to the Merrimack River to the Atlantic Ocean.
1.1.3 Preliminary Removal Assessment/Removal Site Inspection Results
The OSC inspected the scene on 6/27/12, observed and photodocumented oil in the North Nashua River. The Massachusetts Department of Environmental Protection (DEP) requested EPA take action to stop the release as it did not have the resources to do so itself. The OSC met with DEP, the property owner (City of Fitchburg), and the Nashua River Watershed Association on 6/29/12. The Mayor of Fitchburg stated the City did not have the resources to respond to the incident in a timely fashion. Later on 6/29/12 after this meeting, the OSC obtained funding from Coast Guard's National Pollution Funds Center to respond to the site.
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2. Current Activities
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2.1 Operations Section
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2.1.1 Narrative
A discharge of oil was identified in the North Nashua River. EPA was notified by the Massachusetts Department of Environmental Protection (DEP) via NRC report 1015356 on Friday 6/22/12. DEP responded and deployed boom to contain the spill. DEP contacted EPA Region 1 on Tuesday 6/26/12 asking that EPA initiate further cleanup actions as the release was still ongoing. The OSC visited the site on Wednesday 6/27/12. The property is a former power generating plant that was purchased by the City some years ago (not taken for taxes; purchased). The City requested a meeting on Friday 6/29/12 at which time the OSC confirmed neither DEP nor the City of Fitchburg had resources to carry out response actions to stop the release of oil. The OSC opened FPN E12106 on the afternoon of 6/29/2012. The contracting officer issued a verbal task order to the Emergency and Rapid Response Services on Monday 7/2/12. As DEP agreed to maintain boom in the North Nashua River, arrangements were made for EPA to mobilize on 7/9/12.
2.1.2 Response Actions to Date
Week of 2 July 12
On 3 July, the OSC met with DEP and a Response Manager for EPA's Emergency and Rapid Response Services (ERRS) contractor at the site. The required personnel, equipment, and supplies for mobilization on Monday 9 July were agreed upon.
The ERRS Disposal Coordinator made arrangements for disposal of waste that was anticipated would be generated and had the site marked by Dig Safe.
EPA's Superfund Technical Assistance and Response Team (START) generated a site-specific health and safety plan for review and concurrence by the OSC and the ERRS contractor.
The City's contractor used Ground Penetrating Radar (GPR) to identify pipes in the area where test pits would be dug.
Monday 9 July 12
Equipment, personnel, and supplies arrived on site. Equipment included a small (2,500 gallon) vacuum truck and two 30-cubic-yard, water-tight roll-off containers. This equipment was on-hand as a contingency in the event excavation disrupted/damaged the retaining wall, or a pipe exiting the wall, unintentionally increasing the flow of oil to the river. It also provided a means to immediately remove soil and liquid grossly contaminated with oil.
Work zones were established and the HASP was reviewed. An excavator was used to remove pavement in the area to be investigated. A test pit was cautiously excavated as a pipe was expected at approximately 3 feet. Oil was not associated with this pipe. The location of this test pit is at the furthest point up river where oil is seeping through the retaining wall.
The excavation continued until a second pipe and groundwater were encountered at approximately 6 feet and 7 feet, respectively. These were discovered simultaneously due to the size of the excavator bucket. This pipe was not anticipated, as it had not been identified by GPR. The pipe is approximately 12 inches in diameter, appears to be made of clay, and runs parallel to the building and river. Oil trickled from the pipe creating a film of oil on the groundwater. Sorbent boom was deployed to absorb oil overnight. The vacuum truck was demobilized. The excavation was secured for the evening with high visibility fence and warning signs. An existing chain link fence around the work area and the steam plant was locked and warning signs posted. An existing chain link fence to the property was locked, and bollards to prevent vehicular traffic were re-installed. These procedures were employed each day.
Soil that could not be stockpiled adjacent to the excavation where pavement had been removed was placed on a sheet of polyethylene and covered at the end of the work day in accordance with an existing Soil Management Plan established pursuant to state regulation.
Based on the information available, it was concluded that the pipe discovered this day is the source of oil discharging to the river.
Tuesday 10 July 12
The OSC received lab data from the DEP documenting that a sample of oil taken from the river oil at this site does not contain Polychlorinated Biphenyls (PCBs).
The City of Fitchburg provided an in-pipe camera for the purpose of locating the source of oil, such as a perpendicular pipe connecting to the building. However the camera could not advance up the pipe as too much debris/sludge was present.
A sample of the oil in the test pit was collected and sent to an ERRS-subcontracted lab for PCB and Oil Identification analyses. Materials to construct a recovery well were located and ordered.
A second test pit was dug further along the retaining wall where oil is seeping into the river. This test pit is located between the river to the west and the location of an oil tank to the east that was the source of a spill 12 years earlier, and which was removed years ago. The location of this test pit is also between the test pit dug on 9 July to the south and a transformer pad abutting the retaining wall to the north.
What appeared to be an electrical conduit was encountered at approximately 1.5 feet contained no oil. Excavation continued to groundwater. No petroleum odor or sheen was observed. Sorbent material was placed into the water, agitated, removed, and inspected. No evidence of oil was observed. Excavated soil was replaced into the test pit, filling it in completely.
Based on the absence of oil in this test pit, it was concluded that neither the former tank area nor the tranformer pad were contributing to the discharge to the river. Furthermore, it strengthened the conclusion that the pipe discovered on 9 July was the source of the discharge to the river, although the oil's point of origin remains unknown.
DEP contractor personnel replacing sorbent boom in the river reported that less oil was present than the day before. This was interpreted as another signal that the pipe located on 9 July is the discharge point of oil to the North Nashua River, as the flow path to the river was disrupted due to the excavation. However, there has been little rain in the past weeks, and the water level in the river decreases daily. The lessening groundwater pressure behind the retaining wall can not be discounted as a contributing to the reduced discharge of oil to the river. The extent of this contribution is expected to be more clear when a significant rainfall event occurs.
A 24-inch, heavy duty plastic pipe was delivered to the site for use as an oil recovery well. ERRS personnel began drilling holes in at one end at regular intervals to allow oil to flow into it.
The City of Fitchburg delivered stone to the site that will be used around the base of the recovery well to create a path of least resistance for oil to follow into the recovery well rather than the river.
Wednesday 11 July 12
ERRS completed drilling holes in the bottom 3 feet of the recovery well pipe, then lowered it into the 9 July excavation at a location directly between the discharge pipe and the retaining wall/river. Stone was placed around it about half distance to the surface of the ground. The upper level was backfilled with soil excavated from that location.
Thursday 12 July 12
The balance of excavated soil was spread over the entire unpaved work area. Initial compaction was performed in lifts (layers) using the excavator bucket and tracks, followed by a drum roller. Larger stones and debris at the surface were removed.
The City of Fitchburg provided a truck, truck driver, and approximately 5 tons of asphalt which ERRS personnel spread and compacted. A small area around the recovery well was left unpaved to accommodate the installation of a protective concrete collar for the plastic recovery well. The collar was manufactured specifically for this application, and could not be delivered until 13 July.
Friday 13 July 12
The protective concrete collar was delivered and installed by ERRS personnel. The plastic well was cut so that a manhole cover could be installed over it, on top of the concrete, without protruding above the finished grade. The City of Fitchburg's driver and truck returned to the site with approximately 3 tons of asphalt, allowing the ERRS crew to complete paving around the recovery well.
Equipment was demobilized or positioned such that it could be picked up by the subcontracted supplier at a later date. Asphalt was cleaned out of the bucket of the bobcat used to bring asphalt from the dump truck to the area to be paved. The work area was policed, and unused supplies were loaded onto a trailer for deliver to the contractor's local office tomorrow.
Representatives of the City of Fitchburg, including the Mayor, met with the OSC and DEP on site to review the work accomplished, the conclusions about the flow of oil outlined above, and the potential that additional work might be necessary if site conditions worsen or remain unchanged in spite of the recovery well. DEP reiterated that it expected the City to assume responsibility for boom maintenance with a bona fide contractor under the oversight of a Liscensed Site Professional, per state regulation.
2.1.3 Enforcement Activities, Identity of Potentially Responsible Parties (PRPs)
A Notice of Federal Interest was provided to the Mayor of Fitchburg at the meeting at City Hall on 6/29/2012.
2.1.4 Progress Metrics
Waste resulting from this response action remains on site at this time. With DEP's consent, oil-absorbing boom and pads used by EPA were added to the roll-off maintained on site by DEP for oil-contaminated sorbent pads and booms removed from the river. When the rolloff is full or the response action is complete, it will be shipped off site to an approved facililty.
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Treatment |
Disposal |
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2.2 Planning Section
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2.2.1 Anticipated Activities
DEP will continue to maintain boom in the North Nashua River until the City of Fitchburg assumes this responsibility or oil stops discharging. Based on site conditions on 13 July, DEP plans to lessen boom replacement from every day to twice a week. The recovery well will also be inspected and sorbent material changed as necessary.
2.2.1.1 Planned Response Activities
None at this time.
2.2.1.2 Next Steps
See section 2.2.1.
2.2.2 Issues
If the pipe discovered on 9 July is the source of oil discharging to the Nashua River, and the recovery well is fully effective, it is anticipated that oil caught inside the cracks of the retaining wall will continue to seep into the River, but should decrease as time passes. This oil will continue to be captured by boom.
When rainfall returns and raises the groundwater and river level, it is anticipated that a flow of oil from the pipe may resume, however it will be intercepted and captured by the recovery well rather than discharging to the river.
If site conditions do not improve or worsen, additional investigatory and/or remediation work may be necessary.
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2.3 Logistics Section
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Logistics were handled by the On-Scene Coordinator with assistance from the DEP and City of Fitchburg.
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2.4 Finance Section
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No information available at this time.
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2.5 Other Command Staff
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2.5.1 Safety Officer
The On-Scene Coordinator was the Safety Officer for this response action, as provided by the National Contingency Plan. A site-specific, OSHA-compliant health and safety plan was developed and implemented. No injuries or near misses occurred.
2.5.2 Liaison Officer
The on-site DEP representative acted as Liaison Officer with the City of Fitchburg.
2.5.3 Information Officer
A Public Information Officer from EPA's Boston office was assigned and attended the June meeting at City Hall.
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3. Participating Entities
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3.1 Unified Command
EPA & DEP
3.2 Cooperating Agencies
The City of Fitchburg and the Nashua River Watershed Association
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4. Personnel On Site
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EPA, ERRS, START, DEP and the City of Fitchburg.
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5. Definition of Terms
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OSC - On-Scene Coordinator
ERRS - Emergency and Rapid Response Services
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6. Additional sources of information
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6.1 Internet location of additional information/report
epaosc.net
6.2 Reporting Schedule
Periodic.
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7. Situational Reference Materials
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Available at epaosc.net.
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