Boston, Massachusetts 02129 Telephone: (617) 242 -6000

4 MASSACHUSETTS WATER RESOURCES AUTHORITY Charlestown Navy Yard 100 First Avenue Boston, Massachusetts 02129 Telephone: (617) 242 -6000

April 24, 1989 Board of Directors John P. DeVillars, Chairman John J. Carroll Robert J. Ciolek William A. Darity Lorraine M. Downey Anne Bingham, Esq. Anthony V. Fletcher Charles Lyons Office of General Counsel Joseph A. MacRtchlDepartment of Environmental Quality Engineering Samuel G. MygattEniomtaQult Thomas E. Reilly, Jr.One Winter Street Walter J. Ryan, Jr. Boston, MA 02108

Executive Director Restriction Paul F.Levy RE: Fore River Staging Area Land-Use Dear Ms. Bingham:

I wish to acknowledge receipt of a revised draft of the land-use restriction document, which you sent to MWRA by telecopier on Friday afternoon. We would like an opportunity to discuss this draft further with you and with the MWRA's Fore River Advisory Task Force before the document is made available for broader public distribution and comments.

The document you sent us contains several substantive changes from the one which Gary Wilson of MWRA forwarded to you on January 10 (that draft was labelled December 20, 1988). Chief among these is the reintroduction of language excluding uses of the site for other than commercial or industrial purposes. This language appears to be overly restrictive. Our November 20, 1988 draft called for all activities at the site (as these are defined in the Procedures) to be performed in accordance with the Proce- dures. This we thought sufficiently addressed DEQE's concern. S -

Anne Bingham, Esq. April 24, 1989 Page 2

I would look forward to discussing the draft land-use restriction with you and MWRA legal staff at your earliest convenience.

Very truly yours,

Christopher J. Barnett Technical Manager

CJB/Ajp cc: Marilyn Hotch Steven Lipman Sharon Gerolamo Karen Stromberg 46

TELEPHONE CONVERSATION NOTES MASS DEQE/NERO/DSHW

SITE REFERENCE Ih0 ol-&clral DDATE inviCS SUBJECT k/eijfnnU re Rver TIME

FROM (Yin 7(ono REPRESENTING DMEO Le

the etmotcRIv dhst n,wh> nouds e J I I prfom7 iMidussoled nl/ls n1l/grease , Mot 6 Fthe S Imhn rii e. 3:r0, .f nnmCS "MILuine 2eektin d hei Off7&e2, als planninq h dc Yamphng in t) h-e Wirmnd 2(re R1iver. I requsted ha mrnpin of wakr and ryanne.r I',f, in 4he anea at Ren DOwnamics be jhnod, r 0nfrumnanh (bsre ', D

ACTION REQUIRED/REFERRED TO Ms Lshra inrhohed Shw Would syc&i ey s s Pcwi it n see IF t 001t eand the p .P OF hcir |Nw K iin inude n more noneentrakd eft in 4e arPa. to L0m %rCmcs. T of- rccl 10 lA6t; wd-h them ft cevelop n. Nork pwl) DANIEL S.GREENBAUM L Kommn usea/4 diae Commissioner

SUMMARY OF DEQE'S RESPONSE TO PUBLIC COMMENTS ON THE DRAFT PUBLIC INVOLVEMENT PLAN AND MWRA'S CONSTRUCTION PROCEDURES

Fore River Shipyard (Formerly General Dynamics) Disposal Site 97 East Howard Street, Quincy

In response to a petition filed by the East Braintree Civic Association, the Department of Environmental Quality Engineering (DEQE) has designated the Fore River Shipyard disposal site a Public Involvement Plan site, pursuant to thE !.assacnus~tts Ctnir~nnc P MCV2'tn 2 ,uC 4-C r:Eea...... the Department prepared a draft Public :nvolvement Plan vhich established a process to inform the public of activity on the site and obtain comments on proposed remedial response actions.

Comments on the draft Public Involvement Plan were received from January 26 until February 16, 1989. During this same time period, three other site- related documents were made available for public comment, specifically: MWRA's "Procedures Associated with Construction Activities at the Fore River Staging Area"; and General Dynamics' "Feasibility Study, Subsurface Soil/Oil Plume Area", and "Evaluation of Petroleum-Related Contamination in Area 5/Section E".

During the public comment period, the Department received a number of comments on the draft Public Involvement Plan and MWRA's Construction Procedures. No comments were received on either of General Dynamics' reports. This document identifies the comments received and how they are being addressed. (Note: Comments, exactly as submitted, are indicated by C: and DEQE's response by R:).

GENERAL COMMENTS

1. C: Our Demand for full site remediation is still not met. :ndu-trial cleanup has no rritten star.cards to which we could assure the level of cleanup.

R: DEQE agrees that there are still areas of the site which have not been fully remediated. These areas are now being investigated or are areas where remediation has started. Those areas include: subsurface soil contamination associated with the floating oil plume (Phase III), oil contaminated soil in Area 5E (Phase II), and the Southeastern Boundary (Phase :T). The Department is also still evaluating the need for 2.

remediation in the areas where long term monitoring of groundwater contaminated with chlorinated solvents or mineral spirits was conducted. Recovery of the contaminated groundwater associated with the floating oil plume is also on-going.

Some areas have been determined to have met DEQE's requirements for remediation. These include several areas where surface soils stained with oil or contaminated with PCBs were removed, to the extent feasible.

The Department determines cleanup levels by examining a number of factors. One of these factors is future use of the site. Since DEQE's initial involvement in 1986, General Dynamics, and later !WRA, assured the Department that the site's use would remain industrial/commercial in nature. Given such an assurance, DEQE outlined the requirements for cleanup in a letter dated September 20, 1987. Under this approach, some low levels of contamination will remain on-site. It is, therefore, necessary that a land-use restriction be put in place to prevent development of the site as something other than industrial or commercial,

"ithout DEQE's approva . It is also necessar' ha c procedures be put in place to protect public health and the env:ronment, since development of the site may result in the disturbance of hazardous materials.

Remediation to a level that would be acceptable for use as residential property is not appropriate for this site, given its present and proposed future use. It is, however, clearly indicated in the Department's September 20, 1987 letter that if the site's use were to change for any reason, the Department will have to re-evaluate its cleanup requirements.

There are no written "standards", industrial or otherwise, for site remediation. DEQE looks at each site on a case by case basis in order to establish cleanup requirements.

2. C: Asbestos in buildings on site is not being removed.

R: Prior to the sale of the Shipyard, General Dynamics removed or repaired damaged or exposed materials containing asbestos in exterior locations to prevent potential asbestos releases to the environment. Soil samples were taken across the site and no asbestos was detected.

The Department of Labor and Industry, Department of Public Health, the occupational Safety and Health Administration and DEQE's Division of Air Quality Control (DAOC) all share some responsibility for regulating asbestos. The first three agencies are primarily concerned with worker exposure to asbestos. The DEQE DAQC's Asbestos Program regulates asbestos removal, building renovation and demclition. Any future work of this type requires prior written notification to DAQC. It is DEQE's understanding that the future occupants of a particular building on the Shipyard will be responsible for asbestos removal within that building, be it MWRA, the Mass Shipbuilders or any other future lessee. Under M.G.L. c. 21E, DEQE's Waste Site Cleanup Program is responsiale for overseeing remedial response 0 0

actions at sites where there has been a release, or there is a threat of a release, of oil or hazardous materials to the environment. If the asbestos in the Shipyard is not being released to the environment and it is not posing a threat of release (i.e., it is not friable), it does not fall under the jurisdiction of c. 21E.

3. C: Concerns over the Fore River as addressed in the NUS report and supported by us as to the effect on marine life and humans appear to be dismissed. We remind all parties this is a recreational river for boating and swimming.

R: General Dynamics has done assessment of the risks posed by the site. It examined the potential impacts of contamination from the Shipyard to human health and the environment. The assessment indicated that the site presents minimal risks to the Fore River.

*her '-ayre a larCe: CULStIOn cf the general cuality of the water :n th river. Further information on Quincy Bay can be found in a study done by Metcalf & Eddy for EPA Region 1, titled: "Assessment of Quincy Bay Contamination, Summary Report, June 1988". In addition, DEQE's Division of Water Pollution/Westboro Office is planning to sample the Fore River this summer, as part of its annual river basin survey. The Division of Hazardous Waste will work with the Westboro Office to develop the sampling plan for the river. This report will also be made available to the public.

4. C: The southerly portion of the site with respect to levels of cyanides, toxic metals, and other unidentified materials remains and in fact is upgraded in level of urgency to be addressed since this now will be the site of the permanent facility is not addressed to the degree we would like and does not carry the importance and significance given it by NUS.

R: The Department considers the Southeastern Boundary an area of significant contamination and required that General Dynamics conduct additional investigation to define the extent and level of contamination. A report documenting the results of this investigation is expected by the end of April and will be placed in the information repositories for public review.

5. C: !:y concern was with the effect of any contanination on the shtlfish found ir, Laundry Cove in North Weymouth. .... there is a possibility that contaminants could be carried on tidal flows into the Weymouth Cove, which is on the Fore River...... Laundry Cove is an area with good shellfish beds which are regularly dug. I know that they are tested for coliform bacteria, but do not know if they are tested for anything else. .... It might be wise to initiate a more thorough analysis of the shellfish here in light of the information of the shipyard contamination. 4.

R: The Department believes that further examination of the quality of the shellfish in this area is warranted. The Division of Hazardous Waste will work with the appropriate Divisions within DEQE and the other relevant regulatory agencies to pursue testing the shellfish and having them analyzed for the contaminants of concern.

DRAFT PUBLIC INVOLVEMENT PLAN

aUe 3.

C. C: "... decisions about the adequacy of remedial actions at the shipyard have been based on the understanding that the property will continue to be used for industrial uses in the future" and further, an agreement between the DEQE and MWRA which will limit the use of the site to ensure that :uturc uses wil: not pose a thrept to jublic health or the enrironment". FclowiL am acreemenz with the city of Quincy, by contract, a tri-own committee was established, through which potential future uses of the Yard were to be examined. This prior limitation and assumption by MWRA and DEQE appears to be in violation of that contractual agreement.

E: See rsponse #1. DEQE is not a party to the contractual agreement between MWRA and the City of Quincy.

7. 0: The general principal of leaving restrictions on the land, places the expense and responsibility of future cleanup back on the tax payers, not on General Dynamics, where the responsibility should lie.

R: Under c. 21E, any present or past owner is always considered a potentially responsible party for the site. There is an agreement in place between MWRA and General Dynamics about who is responsible for remedial actions at the Shipyard. DEQ: is not involved with this agreement, it is between the parties who entered into it.

Page 4.

8. C: RE: Surficial oil contamination: this report indicates removal of large quantities of contaminated soil during May and June of 1988, after submission of the petition for public involvement. One of the primary concerns which was not addressed at the time of soil and ccntamina:ion removal in 1988, and is not addressed in this plan, is the timing of load removal, to avoid transportation while chiliren were in transi- to and from school.

R: The Department's requirement for the removal of oil-contaminated soil was made in September 1987, prior to the submission of the public involvement netition 5.

DEQE has no regulatory authority to specify the timing of load removals from the Shipyard. However, the Public Involvement Plan (page 10) requires that notification be given to local officials prior to remedial field work involving heavy equipment or protective clothing (level A or B protection). This notification will include information on the type of work, its approximate duration, and any off-site shipments of contaminated material. It is the Department's understanding that MWRA and General Dynamics will work with the affected communities to address ntofication procedures in more detail.

Pace 5.

9. C: Asbestos is examined only in exterior locations, when clearly demolition of asbestos containing buildings is planned. Why are such limitations in place for this analysis, which should be for the overall state of the property, not the contingency of the sale of the land.

R: See response #2.

r. No mention of asbestos on interior o: existing buildin. r responsibility for removal appears to fall on MWRA rate-payers, not General Dynamics. Also, plan should consider local notification (i.e. Quincy Health Department) in regards to removal operations.

R: See response #2. It is the Department's understanding that MWRA will work out notification procedures with local cfficials in the affected communities.

11. C: GZA Risk Assessment - Focus was on the risks associated with ingestion of seafood, potentially contaminated by groundwater. This site currently is transporting volumes of materials via rail system off site, to areas that are not protected cr fenced in at all in East Braintree. Development plans call for at least four times increasing the capacity of materials leaving the site via rail; plus transportation of demolition materials by rail and truc: off site. In addition, workers will be bringing potentially contaminated clothing and shoes home with them during demolition and construction, should these risk factors also be addressed?

R: The evaluation of risks posed by transporting hazardous materials via rail and truck off-site is beyond the scope of what is required under the MCP. However, the Department of Transportation and other state and federal transportation requirenents must be met.

see response tE.

NWRA's Construction Procedures contain nrovisions for insurina that worrers cc not inadvertently carry any contamination :rom tnesz:e.

2. C: Our concern is that the risk assessment focuses on groundwater contamination only. All potential migratior. pathways and exposure points should be considered in detail. 6.

R: The risk assessment did consider all potential migration pathways and exposure points. It focused on groundwater because it is the only relevant pathway of exposure at this site. Other routes of exposure such as ingestion of soil and groundwater, inhalation of vapors and particulates, and direct contact with soil were not examined in detail because the site is paved and fenced, the saline groundwater in this area is not a potential drinking water source, and therefore, there is no access to the contamination through these routes.

Paae 8.

13. C: "many decisions regarding the adequacy of assessment and some remedial response actions have been made...". Many of these decisions are recent, and certainly fall within the time frame of application of the Public Involvement Petition in May 1988 and presentation of data in late January of 1929. Why was the public input not requested for, or respected?

:EQE made no decision: recarcing assessment or renmcdial response actions at this site between May 1988 and January 1989. There were some actions taken at the site during this period pursuant to approvals that were given prior to May 1988, such as removal of soil contaminated with oil and PCBs. DEQE respected the public's request for involvement and made no new site-related decisions until the draft Public Involvement Plan had been submitted for public comment in January 1989. Three technical site reports were made available for public comment at that time and no decisions were made on those reports until after the Department reviewed and incorporated public comments, where appropriate, as indicated by this document.

~4. C: Quincy Health Department, Fire Department, and Building Department snould be notified nior to any buildinc demolition, and joint inspections be conducted as necessary.

R: This is not something that DEQE has the authority to regulate under c. 21E. However, it is the Department's understanding that MURA will work with local officials in the affected communities to establish acceptable notification -ocedures.

Ve vould prefer the same meetinc cate as the KWRA Fore Ri-er Adv:sory Task Force meeting; PlP meeting should be held immediate>y after MWRA meetinc 's adiourned.

L: -L the draft Public -nvolvement Plan, DEQE proposed that a subcommittee be formed of the Fore River Advisory Task Force, which would serve as the focus for public involvement during the cleanup of the site. The Department did not receive any public comments opposed to the proposal, therefore, DEQE has agreed to meet with the Subcommittee at 6:00/6.30, directly after the regularly scheduled Task Force reetings. 7.

The Department is concerned that this meeting time may not be convenient for everyone who may want to participate. All meeting notices will include a note to this effect and if DEQE hears that the meeting time is inconvenient, the Department will consider changing it.

Exhibit I

16. C: These concerns must be addressed jointly by DEQE, NWRA, and General Dynamics. In addition, a clear delineation of the responsibility of any regulatory agencies involved in the site cleanup must be established. Such a plan must include all assessment areas covered in the NUS report - both exterior and interior; and all contaminants as so reported. The NUS Report recommendations should be implemented and/or overseen by the appropriate regulatory agency.

R: The community concerns listed in Exhibit I will be addressed jointly by the potentially responsible parties (General Dynamics and MWRA) and DEQE. In a site cleanup under c.21E, DEQE is the only regulatory agency that har resprsiM:::t. Thtnpublicr'v~vmnr prcss UUM C . 2:CQ:. only address releases, or threats ot releases, to the environment. Buildings can only be addressed if there is some way that the contamination is entering the environment from the building (e.g., a storm drain, window, smokestack, etc.). DEQE reviewed all the information in the NUS report and feels that it does not indicate any significant new areas of contamination that require assessment or remediation.

XWRA'S CONSTRUCTION PROCEDURES

General

17. C: It is understood that DEQE views these procedures as applicable to those portions of the FRSA bounded by the security fence, and that any problems known or subsequently determined with respect to the !WA-ovne& areas in Quincy or Braintree not within the bounds of Hill Avenue, Quincy Avenue, East Howard Street, South Street, Washington Street and the Fore River will be dealt with "de novo". Quincy supports this understanding.

R: This understanding will be clearly stated in the introduction to the Procedures.

18. C: Quincy is concerned -hat this Cocument perpetuates the concept that future uses :f the FESA are restricted to commercial or industrial uses, and that this document would tend to further restrict that utilization to industrial purposes only. The Quincy position has been and continues to be that the on-site contamination should be remediated so as to neither restrict future development options nor to require special procedures during construction.

R: See response t:. it is not the intent of this document to further restrict uses of the site. 8.

19. C: The City understands that this document is intended to apply only to activities by the MWRA or any lessees thereof; and that a further document covering activities by future purchasers of part or all of this property is intended.

P: This understanding will be clearly stated in the introduction to the Procedures.

20. C: Quincy also requests that roles and responsibilities of local officials which may be appropriate from a statutory, regulatory, or practical point of view be considered and clarified. It is noted that this may be different with respect to the Authority as contrasted to its lessees.

R: MWRA owns the Fore River Staging Area and is exempt by statute from al' >ocal permits/approvals, but must obtain all applicable state and federal approvals/permits. Lessees must obtain all applicable local, state and federal approvals. The Procedures specifically state that they n'!acYlar< Zwtcr=0tv cranleccTc: ecuatory agencies.

: should also be made clear that this proposed document is specific to the FRSA; that it is in no way a generic document with wider application. In that context, the use of terms such as "urban fill" should be scrupulously avoided.

R: A statement to this effect will be made in the introduction of the Procedures. The term "urban fill" will be struck from the Procedures and soils will be classified as Categories A through D.

22. C: The construction-related activities procedure for the Fore River staging area as submitted in draft form by the MWRA is totally lacking any degree of local notification, input or involvement. Although not required by any regulatory statute (as the property is state-owned and operated) it would appear to be in the best interest of the NWRA and the DEQE to consider some rasiC invoveMent of local officials at least in terms of notification. Often, when residents and/or businesses have questions or concerns over an activity happening in their neighborhood they typically cal local officials not State officials. If local officials are aware of an activity and/or have participated in its regulation or oversight then those local officials can then alleviate or reduce many concerns or at rinimu: serve as a liaison with the proper state agency to address those concerns. Therefore, Ye recommend that the final draft procedures include nc:ification of and i-clvement by the local health department, building depar:ment, NY, fire deparzmen, and community leaders.

R: The Department agrees that local officials should be kept informed of ac:ivities being conducted a- the staging area since they will most likely be the first ones called by concerned citizens. DEQE has been informed that MWRA will work with loca: officials in the affected communities to establish notification procecures, in addition to those required in the "uitc involvcent Plar (page 10 9.

Section 1-01

23. C: The statement "Although the levels of contaminants remaining under the site are no higher than the levels of contamination expected to be present on any industrial site, ..." (emphasis added) is an unacceptable condemnation of industrial sites throughout the Commonwealth or elsewhere. It is an unacceptable and transparent effort to assuage the legitimate concerns of the affected municipalities and citizens, and should be deleted from the document.

F: This statement will be deleted fro, the Construction Procedures.

24. C: The statement that ":t is the intent of MWRA to comply with all regulations..." is a gratuitous recognition (inappropriately stated) of the Authority's unconstrained responsibility to so comply, and should be revised.

R: This statement will be re-worded to reflect this comment.

Lection 1-04

25. C: "ajor construction projects" and "routine operation and maintenance and emergency repairs" are critical terms in this document, and lead to major differences in the nature and extent of Authority responsibilities and DEQE response. They should, therefore, be clearly defined.

R: These terms will be defined.

26. C: :t is understood that the twenty-one (21) calendar day period for DEQE response is only with respect to YWRA projects, and that DEQE will not be so constrained with respect to projects of any lessee. :t is also understood that DEQE's legitimate and acceptable response within this tie constraint may be tnat additional time is required, in which case no further action will be taken by the Authority pending further response. Both of these understandincs should ne clear' -et fo::th in, this document.

F: The twTenty-one calendar day review period by DEQE will be further elaborated to reflect this understanding.

27. C: With respect to Fore River Railroad tract ballast, it is understoot that DEQE intended to require notification of any contamination other tha: that which nicht reasonably resulted fror normal leakaae of netroleum products used by rollinc stock on the railroad (:.e., fuel and lubricatin cil contar.na:on resultzng from drps, :.ot spills). This should he

rf. tcathtn - . ~ ?&~cu~- -- C - 'mno --htis uncler tanznrc -

£E. C: In. the f:nal paragraph of this subsection, it shouLd be clear that an additional review burden is placed oh the KYRA and that this paragrah does not operate -o imi tne reviev respnonsibilities er authorit:es of DEQE. 10.

R: This paragraph will be re-worded to reflect this understanding.

29. C: This section lacks mention of local involvement in terms of review of environmental workplans and specifications as well as in terms of notification (routine operations and maintenance activities and emergency repairs).

R: See response #20 and #22.

Section 1-05

30. C: The first paragraph of th:s section should be amended to include "building construction/renovation". This provision, and in fact this t' entire procedure, should be clearly incorporated into any lease between the MWRA and the Massachusetts Land Bank prior to its execution.

To reiterate, the role of local authorities with respect to LVRF lessees should be reexamined.

R: See response #20 and #22.

32. C: This section as well lacks local involvement in review of plans, and/or notification of routine or emergency repairs or activities undertaken by a lessec of the MVRA property.

R: See response #20.

Section 2-C:

33. C: The limitation of the site "as an industrial size" should be deleted. The last paracrah of this section should >e amended by changiss the as: sentence to read "One Purpose of these procedures is to cnde suture development

R: The limitation of the site to an industrial site will be re-worded to "industrial/commercial site". The last paragraph will be revised as proposed in this comment.

ect:ot 2-CL

34, : The third"bullet" should be e::nanded to include Eirec reference t: Snowrn pCE-contaminated areas, the Southern Boundary area, and ary other :novn areas of sinica contaminazzon to whic: :ris restric::o shoul

7e zz:d "zulet" r D..ne re:sec. 'c -ncorDorate t.is comment 11.

Section 2-03

35. C: Mention is made of soil analysis according to the following criteria: Hazardous Substance List of volatile and semi-volatile organic compounds, heavy metals, total and free cyanides, PCB's and pesticides, and petroleum hydrocarbons. How will these analysis parameters be determined?

R: There was a typographical error in the draft Procedures which made it unclear as to which compounds will be analyzed for. This error will be corrected to indicate that all of the samples will be analyzed for these parameters.

Section 2-04

36. C: The intent of this plan should be to protect public health and safety. Allowing a contractor to "troceed with the construction of any facility with a minimum of delay" should cea-ly be secondary to that primary objective.

F! The intent cf the procedures is tc otec: puelic health and thE environment during construction. They were never intended tc compronisE such protection for the sake of proceeding with a "minimum of delay". This section will be re-worded to reflect this position.

Section 2-05

37. C: DEQE is urged, both in this instance and as a general matter, to be much more specific about the characteristics of materials used to underlie or cover stockpiles of soil. The use of flimsy sheets of polyethylene, subject to ultraviolet and other environmental degradation, is inappropriate, occurs frequently, and should be terminated by the development of appropriate guidance.

R: The Procedures will be revised to indicate that polyethylene sheeting «must be at least I rils in t-icness.

38. C: The use of the term "urban fill" should be avoided. It is suggested that the on-site soils be categorized as Categories I through IV.

R: The term "urban fill" will be struck from the Procedures and soil will be classified as Catecories A throuch

3?. r: When stochoiling soils for creater than si:: months, notified. Local zfficials should be nc:ified as well.

F: See response #*2.

40. 0: Several cLassifications of soil and methods of handling are discussec, however, generally, if urban or Cat. I and II soils are stockpiled and reused, what is the possibility of cross contamination, or increasing levels of contamination by movinc materials from one site -c another? 12.

R: The Procedures will be revised to indicate that the excavated soil shall be replaced in the area it was removed or, if riot logistically feasible, in an area of comparable contaminant conditions.

41. C: Are adequate measures taken to ensure that surface water runoff during soil excavation and redistribution will not leach inadequate levels of contamination into the Fore River and into the MWRA drainage system?

R: The Department believes that the measures proposed in the Construction Procedures will be adequate to prevent contaminated surface runoff into the on-site drainace system and the Fore River.

Picure 1

42. C:- The term "previously approved concentrations", also appearing in this tale as "pree. ccnce.", i. understood to mean those concentrations approved for retention on-site pursuant to the DEQE letter of September 20, 1987. This should be clarified. Prior to the acceptance of those

concentrations lis-cd in Table ,evewers shovd-1 - rovided vith a coZrehenls:Ve List of the approval F-nets and pr- d r± opportunizv to review and comment thereon.

R: References for where each one of the contaminant concentrations came from will be provided in the revised Table 2. Documentation on DEQE's approval of these levels can be found in the Department's September 20, 1987 letter to Genera2 Dynamics, which is in the information repositories. These decisions were made before Nay 1988. Therefore, the Department will not be soliciting public comment.

Picure 2

: here is concern with the application, in zzis igure and Figure I, of the terr "re-evaluate". This process as presented can be interpreted to leaving open the possibility of the retention on-site of extensive, hichiv contaminated soils. ;.lthough it is understood this is not the iraention of the decision flov chtrt, clarificatin is essential, (even trhough this is an unlikely occurrence).

P: This term will be clarified to reflect this comment.

Table -

. -is understood that thse numbers are still under review by the DEQE Cffic- cf Research and Standards. Therefore, comment is withheld until tha offic has completed its review and its recommendazions, and the reasons therefore are available for further review and comment. Howeve:. tle catecorization as "urban fil. should be replaced by "Category I Soils". :t should also be clear that the detection limit referred to is that of an EPA-apvroved method. This narticular comment also applies to 13.

R: The term "urban fill" will be struck from the Procedures and soil will be classified as Category A through D. For the time being, the urban fill/Category A soil has been withheld from the Procedures. All soil excavated will be covered during stockpiling. This presents a more conservative approach. The referenced detection limit will be defined as an EPA approved analytical method.

Table 2

45. C: How were the concentration values determined? No source or reference identified in terms of these valucs. Please supply this source.

5: The concentration values in Table I were derived from inappropiate assumpzions and, subsequently, were elinjinated from the Procedures.

,eE responSE #44.

46 . C: "Previously approved" concentrations in Table -Are used. Tiest

R: The contamination concentrations which could remain on-s:e were approved by the Department in a letter to General Dynamics, dated September 20, 1987. These concentrations were approved on the basis that (in their present state) they pose no significant threat to public health or the environment, given the site's intended use.

Section 3-01

47. C: It should be clear that asbestos removal will be in full conformance with DEQE regulations and all applicable requirements of the Massachusetts Department of Labor and Industries and the Federal Occupational Safety and V/ health AdministraioI.

F: The Procedures will be revzsed to reflect this comment.

48. C: This is another provision in which the appropriate role of local authorities should be established and identified.

R: See response #20.

4?. 0: There -s concern rith leavinc to the ! VRA and its demolition contractor tne determination that demolition spoils require special handlinc and therefore further definition of the extLnt and ltvel of contamination. It seems appropriate that there be a State cr local r-ole :-is decisonr process anc i: shoulc be sc identified.

R: The Department us currently identifying the agency with jurisdiction for this issue. Th final Procedures will be revised accordingly. 14.

50. C: Mention is made of sweeping and properly disposing dust containing fine metal particles and paint chips. We recommend that this "sweeping" be performed with a HEPA vacuum, and workers be protected as necessary, (i.e., respirators, disposable coveralls, etc.).

R: The Department will not specify how the sweeping must be conducted. N/ However, DEQE will require that a worker Health and Safety Plan be prepared and followed. This Plan will address issues such as respirators and protective clothing.

52. C: Currently in Quincy, prior to the issuance cf a demolition permit, a toint inspection must be conducted by the local Health and Building Departments, and the Fire Department. Will there bc similar involvement and notification during demolition activities at the MWRA property?

F: See response #20 and V22.

Section 3-04

:The:ole of t statbuili ng insrecto'-r" ths process shoule be established as to whether it is a Matter of laW, regulation, or custom; and the role of local authorities pursuant to Sections 150-A or 150-E of Chapter 111, NGL, should be recognized.

R: See response #20.

53. 0: DEBRIS DISPOSAL - How will the materials be transported, when and what type of notification will be given to transit communities?

R: See response #22.

section 4-0:

54. C: There should be a provision in this section for resolution of any con-1icts between these nrocedures and the State Buildinc Code.

R: This comment is beyond the scope of DEQE's review of the Construction Procedures. It is the Department's understanding that MWRA will address this concern.

Section 4-03

BE. C: An NPDES permit will be granted to the MWRA for the ERSA.

F: This comment will he incornorate:.

.. :Th uetho of determinat:on of a :ecuirement flo interim measures snou be Spelled out. Since modificazion of an UPDES permit i. a rather cumbersome procedure, every effort should be made to incorporate limits E:all recocn:zed noen:a contar-nants :n the :nitial NPDEZ. 15.

R: Measures will be taken to incorporate the contaminants observed to date at the site into the pending NPDES permit.

57. C: It should be specified that the disposal of activated carbon or sludges resulting from a treatment process should be as hazardous waste in conformance with 310 CMR 30.00.

R: There are options available for used activated carbon other than disposal as a hazardous waste. DEQE prefers on-site or off-site regeneration (cleaning of the carbon for re-use). If, however, the carbon is disposed of, it must be handled as a hazardous waste under 310 CMR 30.00.

Section 4-04

58. C: Rain and groundwater treated and pumped into the Fore River may well be of considerable magnitude, based on the proposed construction projects by the MWRA. Vill there be ongoing environmental assessments made of the water quality of the river, the surrounding ocean basin, and the seafood inhabiting that environ?

R: See response #41. The Department does not intend to sample the river based on additional discharges due to construction activities, since any discharges to the river must meet the NPDES discharge requirements. However, DEQE's Division of Water Pollution Control/Westboro Office is planning, as part of its annual river basin survey, to sample the Fore River this summer. This report will be made available to the public.

Section 5-01

59. C: More detail should be provided for the "qualified person familiar with V the plan and excavation activities who will monitor the HMMP plan's implementation". A definition of "qualified person" should be provided, as well as an indication as to how much time (approximate) will be devoted to this task.

R: The Procedures will be revised to further define a "qualified person".

Section 5-02

60. C: The application of the OSHA standard for general nuisance-type dust to this situation is seriously questioned. In addition to the concern about the adequacy of worker protection, the visibility and off-site implications of such a release rate also require further evaluation.

R: The proposed dust level is currently being re-evaluated by MWRA's environmental consultant, E.C. Jordan. A report is expected by the end of April for DEQE's review. This report will be made available for public comment before DEQE makes its final approval. 16.

61. C: As a general procedure, when environmental concentrations of a contaminant are found to be in excess of standards or guidelines, the first step should be to stop work. If, after assessment, it is determined that the work is not the source of the problem then it should be allowed to resume. The management approach set forth in this section should be

equally applicable to all contaminants, and not limited to VOCs.

R: This section will be re-worded to reflect this comment. Section 5-03

62. C: Concerns over this section exist. If significant concentrations of VOC's are found via air monitoring, it would seem that source identification followed by remediation (if necessary) would be appropriate, rather than proceeding with construction activities. R: See response #61.

Section 5-05

63. C: In this Section especially, notification of the presence of potentially hazardous material or hazardous conditions not contemplated by the plan must be made to local officials as well as DEQE. R: See response #22.

Section 6-02

64. C: Statement that "The KWRA will require all contractors whose workers will handle soil, or groundwater, or who will be involved in building demolition, if it is suspected that there will be worker contact with hazardous materials, to prepare a H&S plan, subject to review by the MWRA." Will these conditions be applicable to all leases of the site, i.e. shipbuilders? And will the necessary clean-up activities required prior to occupancy by a lessee be covered by a similar H&S Plan? R: The Procedures apply to both the MWRA and its lessees.

Prepared by the DEQE Northeast Regional Office, Site Assessment and Cleanup Section April 1989 976 6momwzwwea/i/v fhsacusettv

U. i~~fet 9 6t v 0o&,q, - -IrtA-& eat fezoq 6XI ConwwneoeakA A'ea&

Daniel S.Greenbaum f&$w-n4, -fa&ac aecas O16vO1 Commissioner

MEETING NOTICE

A Subcommittee of the Fore River Advisory Task Force is meeting to discuss the status of the Fore River Shipyard Disposal Site

Monday, April 24, 1989 6:30 PM*

Fore River Staging Area Administration Building 97 East Howard Street, Quincy

AGENDA

Update on the status of the site e; "!' k csot 1-0 o 7"(Reujw-ef public comments received on the following reports:

0 Draft Public Involvement Pla n/ MWRA's Construction Procedure Document

+ Draft Land Use Restrictionen DEQE and MWRA o Other site related issues

o Any outstanding organizational items for the Subcommittee

For further information, please call Karen Stromberg at DEQE at (617) 935-2160.

* Please note: if you would like to attend these meetings but find it difficult due to the meeting time, please contact Karen Stromberg. 0 S

9/Jmow ea//oA aa &y

DANIEL S.CREENBAUM 5 Q&//Mn Commissioner A wadume&i0.6

Chronology of Events Associated with the 84" Drain Line Fore River Shipyard (Formerly General Dynamics) Quincy, MA April 24, 1989

03/12/85 Chief Rondomanski (Coast Guard Marine Safety Office) reported to DEQE that (1) vapors were present in an 84" drain line that runs through the General Dynamics Shipyard and (2) an oil sheen was present on the Weymouth Fore River at the outfall of the 84" line. 03/21/85 Coast Guard divers went down into the drain line with an explosimeter and recorded 30-40% of the lower explosive limit (LEL). Coast Guard set out a boom in the Weymouth Fore River at the outfall. 03/28/85 DEQE sampled the 84" drain line at a manhole located at the intersection of East Howard Street and South Street. Results indicated trace to low levels of chlorinated solvents and petroleum constituents. 04/05/85 An oil sheen was observed on the Weymouth Fore River at the outfall of the 84" pipe. General Dynamics would not accept responsibility for the release. DEQE hired Clean Harbors to replace the saturated booms in the river. 05/17/8f DEQE obtained samples from the 84" pipe at three (3) points along the line and at the outfall and had them run for an oil identification. Results were: Point 1, Amber aqueous sample with some solids present; Points 2 and 3, 50% by volume gray aqueous layer on top of gray sediment; Outfall, 1% by volume black oil layer on top of an aqueous layer. 05/30/85 Divers from Quincy's Environmental Inspection Unit obtained a composite sample of an unknown silvery precipitate oozing through four joints in that part of the 84" drain that runs directly under the Shipyard's pipefitting shop. They also obtained water samples from the outfall and at a point inside the drain. Sludge results indicated: trace levels of anthracene; possibly low levels of Polychlorinated Biphenyls (PCBs), however, not quantifiable; no detectable volatile organic compounds (VOCs); and low levels of heavy metals. Water samples indicated trace to low levels of chlorinated solvents. Chronology Page 2

09/04/85 Coast Guard hired Clean Harbors to change absorbent booms in the Weymouth Fore River.

09/10/85 General Dynamics notified DEQE that an underground line for an aboveground #2 fuel oil tank was leaking. They also reported that an oil sheen was present on the Weymouth Fore River at the outfall of the 84" drain.

09/10/85 General Dynamics hired Inland Pollution Control to excavate contaminated soil from around the leaking underground pipeline.

09/10/85 DEQE hired Clean Harbors to place sorbent booms in the river to contain the oil sheen located at the outfall of the 84" drain.

09/10/85 Coast Guard obtained samples from: the 84" drain outfall (water sample), the sheen on the Weymouth Fore River (oil sample), the hole around the leaking pipe (soil sample), and the tank feeding the leaking line (oil sample) and analyzed them for an oil identification. Results indicated that the samples from the outfall and the river came from a common source, and the sheen on the river and the water sample from the river were related. 09/12/85 DEQE conducted an inspection of the work being conducted in the area of the underground leaking oil line. 11/07/85 General Dynamics hired Camp, Dresser & McKee to sample the 84" drain line. Results indicated that no petroleum based oil/grease were present. Numerous joints were observed leaking groundwater into the pipeline.

12/24/85 An oil sheen was observed on the Weymouth Fore River at the outfall of the 84" drain. General Dynamics hired Inland Pollution Control to boom the area of the outfall. 0 GENERAL DYNAMICS Quincy Shipbuilding Division 116 East Howard Street, Quincy, Massachusetts 02169

21 April 1989

Data for Sharon Gerolamo

Oil Recovery as of Friday, 21 April 1989 " 374,670 gallons

Water Treatment as of Friday, 21 April 1989 - 81,200,000 gallons

Draft Report on Bent's Creek Area in progress. Final report expected sometime in May or June.

Tentative meeting with MWRA to discuss Area 5A planned for mid-May. 0 0 GENERAL DYNAMICS Quincy Shipbuilding Division 116 East Howard Street, Quincy, Massachusetts 02169

April 12, 1989

Ms. Karen Stromberg Regional Planner Department of Environmental Quality Engineering 5 Commonwealth Ayenue Woburn, MA 01801

Dear Karen, Please note that General Dynamics has today transferred a report entitled Hydrogeologic St , Quincy Shipyard, Building 55 and 57 Area, prepared by our consultants Goldberg-Zoino & Associates, Inc. (GZA) to Mr. Richard Chalpin, P.E. as part of our continuing site assessment and remediation program at the Quincy Shipyard, now the Fore River Staging Area (FRSA) of the Massachusetts Water Resources Authority (MWRA).

Please confer with Ms. Sharon Gerolamo and review this report so as to determine whether it is ready and suitable for transfer to the appropriate parties involved in our Public Information Plan (PIP). As agreed, we stand ready to transfer three copies to the FRSA-PIP Subcommittee and one copy to each of the three designated community libraries.

Please contact us on this matter at your convenience. Sincerely yours,

Robert F. White Manager of Operations

cc: Sharon Gerolamo OFFICE OF THE MAYOR

FRANCIS X. MCCAULEY

April 11, 1989

Karen Stromberg Regional Planner Dept. of Environment Quality Engineering 5A Commonwealth Avenue Woburn, MA 01801

Dear Ms. Stromberg:

I, as Chief Municipal Officer, am appointing the following persons to the D.E.Q.E. Sub-Committee Task Force on the Fore River Shipyard clean up:

PETER KOLSON 215 PALMER STREET QUINCY, MA 02169

CYNTHIA DECRISTOFARO, SANITARIAN QUINCY HEALTH DEPARTMENT 1120 HANCOCK STREET QUINCY, MA 02169 773-1380, ext. 417

DAVID H. SMITH, PERSONNEL DIRECTOR QUINCY CITY HALL 1305 HANCOCK STREET QUINCY, MA 02169 773-1380, ext 412

Thank you for allowing the City of Quincy participation in this process.

Sincerely,

FXM:cak FRANCIS X. MCCAULEY MAYOR

L DANIEL S.CREENBAUM Commissioner 935-2160~~ 060

April 7, 1989

Board of Selectmen Town Hall 1 JFK Memorial Drive Braintree, MA 02184

Dear Selectmen,

In response to a petition filed under M.G.L. c. 21E, Section 14(b) by the East Braintree Civic Association, DEQE designated the Fore River Shipyard (formerly General Dynamics) disposal site a "Public Involvement Plan Site" in accordance with the Massachusetts Contingency Plan, Section 40.203(1). The Department prepared a draft Public Involvement Plan which established a process for informing the public of activity on the site and obtaining comments on proposed remedial response actions. The draft Plan was presented at a public meeting held on January 26, 1989, and was made available for public comment until February 16, 1989.

In developing the proposed Public Involvement Plan, DEQE took steps to identify community concerns that the Plan should address. One of the comments made to the Department was that there are a number of groups in this area meeting on a variety of issues relative to the Shipyard. The request was made that an existing group be used as the focus for public involvement during the cleanup of the site. WRA's Fore River Advisory Task Force seemed to be the most appropriate existing group, as it is looking at long term use of the Shipyard and provides input from the communities of Braintree, Quincy and Weymouth.

In the draft Public Involvement Plan (page 11), DEQE proposed that a subcommittee of MWRA's Task Force be formed to deal specifically with disposal site issues raised throughout the remainder of the remediation process. The Subcommittee would be comprised of at least one current Task Force member (for continuity) and two additional members from each community, all to be appointed by the Chief Municipal Official. Meetings would be open to the general public. A meeting schedule would be determined by the Subcommittee and DEQE, but meetings would be held at times and in a location convenient to the public. Subcommi ttee Page 2

Because cleanup work at the site is proceeding and DEQE is currently meeting with the Task Force on a monthly basis, the Subcommittee needs to be established as quickly as possible. The next Task Force meeting is April 24, 1989, and I would like to be able to announce the membership of the Subcommittee at that time. If at all possible, I request that you inform me of the three Braintree designees by April 21, 1989. The Department looks forward to working with local officials and the public during the cleanup of the Shipyard. The Subcommittee will play an integral part in the process. If you have any questions, please contact Karen Stromberg at (617) 935-2160 or the letterhead address.

Very truly yours,

Karen Stromberg Regional Planner

Richard al Deputy Regional Environmental Engineer

cc: Board of Health, Town Hall, 1 JFK Memorial Drive, Braintree, MA 02184 Representative Suzanne Bump, State House, Room 443, Boston, MA 02133 Senator Paul Herald, State House, Room 507, Boston, MA 02133 Daniel Johnson, NWRA, Public Affairs, Charlestown Navy Yard, 100 First Avenue, Boston, MA 02129 Robert White, General Dynamics, 116 East Howard Street, Quincy, MA 02169 Sarah Weinstein, DEQE, DHW, 1 Winter Street, Boston, NA 02108 Ne S /wiommomaea//&u/assac/aet/A 9e/w,/rtnent o/ %nsz6onen~ad uc4 poyceenmp, 904/ 209ai //

DANIEL S.CREENBAUM oMunmea/t4S/ Commissioner 935-2160

April 7, 1989

Mayor Francis McCauley City Hall 1120 Hancock Street Quincy, NA 02169

Dear Mayor McCauley,

In response to a petition filed under N.G.L. c. 21E, Section 14(b) by the East Braintree Civic Association, DEQE designated the Fore River Shipyard (formerly General Dynamics) disposal site a "Public Involvement Plan Site" in accordance with the Massachusetts Contingency Plan, Section 40.203(1). The Department prepared a draft Public Involvement Plan which established a process for informing the public of activity on the site and obtaining comments on proposed remedial response actions. The draft Plan was presented at a public meeting held on January 26, 1989, and was made available for public comment until February 16, 1989.

In developing the proposed Public Involvement Plan, DEQE took steps to identify community concerns that the Plan should address. One of the comments made to the Department was that there are a number of groups in this area meeting on a variety of issues relative to the Shipyard. The request was made that an existing group be used as the focus for public involvement during the cleanup of the site. MWRA's Fore River Advisory Task Force seemed to be the most appropriate existing group, as it is looking at long term use of the Shipyard and provides input from the communities of Braintree, Quincy and Weymouth.

In the draft Public Involvement Plan (page 11), DEQE proposed that a subcommittee of )WRA's Task Force be formed to deal specifically with disposal site issues raised throughout the remainder of the remediation process. The Subcommittee would be comprised of at least one current Task Force member (for continuity) and two additional members from each community, all to be appointed by the Chief Municipal Official. Meetings would be open to the general public. A meeting schedule would be determined by the Subcommittee and DEQE, but meetings would be held at times and in a location convenient to the public. - \ S

Subcommi ttee Page 2

To begin implementing the Public Involvement Plan, the Department met with the Task Force on March 14, 1989. It was agreed that Subcommittee meetings would be scheduled to follow the regular Task Force meetings at the Shipyard, unless public concern was expressed that this is not convenient to other people who wished to attend. Neetings will be advertised to everyone on the mailing list which DEQE maintains for the site. The Department also agreed to contact the Chief Nunicipal Official in each of the three communities to request the appointment of the Subcommittee members. Because cleanup work at the site is proceeding and DEQE is currently meeting with the Task Force on a monthly basis, the Subcommittee needs to be established as quickly as possible. The next Task Force meeting is April 24, 1989, and I would like to be able to announce the membership of the Subcommittee at that time. If at all possible, I request that you inform me of the three Quincy designees by April 21, 1989.

The Department looks forward to working with local officials and the public during the cleanup of the Shipyard. The Subcommittee will play an integral part in the process. If you have any questions, please contact Karen Stromberg at (617) 935-2160 or the letterhead address.

Very truly yours,

Karen Stromberg Regional Planner

Richard J Chalpin Deputy Regional Environmental Engineer

cc: N. Jane Gallahue, Board of Health, City Hall, 1120 Hancock Street, Quincy, NA 02169 Representative Suzanne Bump, State House, Room 443, Boston, NA 02133 Senator Paul Herald, State House, Room 507, Boston, NA 02133 Daniel Johnson, NWRA, Public Affairs, Charlestown Navy Yard, 100 First Avenue, Boston, NA 02129 Robert White, General Dynamics, 116 East Howard Street, Quincy, MA 02169 Sarah Weinstein, DEQE, DEW, 1 Winter Street, Boston, MA 02108 99 5NNOItnh f/4z-

DANIELS. CREENBAUM ,% nw aud Commissioner 935-2160

April 7, 1989

Board of Selectmen Town Hall 75 Middle Street Weymouth, NA 02189

Dear Selectmen,

In developing the proposed Public Involvement Plan, DEQE took steps to identify community concerns that the Plan should address. One of the comments made to the Department was that there are a number of groups in this area meeting on a variety of issues relative to the Shipyard. The request was made that an existing group be used as the focus for public involvement during the cleanup of the site. NVRA's Fore River Advisory Task Force seemed to be the most appropriate existing group, as it is looking at long term use of the Shipyard and provides input from the communities of Braintree, Quincy and Weymouth.

In the draft Public Involvement Plan (page 11), DEQE proposed that a subcommittee of NWRA's Task Force be formed to deal specifically with disposal site issues raised throughout the remainder of the remediation process. The Subcommittee would be comprised of at least one current Task Force member (for continuity) and two additional members from each community, all to be appointed by the Chief Municipal Official. Meetings would be open to the general public. A meeting schedule would be determined by the Subcommittee and DEQE, but meetings would be held at times and in a location convenient to the public. Subcommi ttee Page 2

Very truly yours,

Karen Stromberg Regional Planner

Richard J.halpin Deputy Regional Environmental Engineer

cc: Richard Narino, Board of Health, Town Hall, 75 Niddle Street, Weymouth, MA 02189 Representative Suzanne Bump, State House, Room 443, Boston, MA 02133 Senator Paul Herald, State House, Room 507, Boston, NA 02133 Daniel Johnson, NWRA, Public Affairs, Charlestown Navy Yard, 100 First Avenue, Boston, NA 02129 Robert White, General Dynamics, 116 East Howard Street, Quincy, NA 02169 Sarah Weinstein, DEQE, DRW, 1 Winter Street, Boston, NA 02108 March 29, 1989

Richard J. Chalpin Deputy Regional Environmental Engineer Department of Environmental Quality Engineering Metropolitan Boston - Northeast Region 5A Commonwealth Avenue Woburn, MA 01801

Re: Flibotte's Auto Salvage Co., DEOE Case No. 3-1605 Dear Mr. Chalpin:

I acknowledge receipt of your letter to Flibotte's Auto Salvage Co. dated March 15, 1989. Please be advised that Flibotte's Auto Salvage Co. will agree to perform the Phase I Limited Site Investigation as requested. Depending on the results of that Phase I Investigation, Flibotte's Auto Salvage Co. is also willing to consider the performance of a Scope of Work for a Phase II Comprehensive Site Assessment, as also requested in your letter. We believe it is premature until the Phase I Limited Site Investigation has been completed, however, to commit to the Phase II Scope of Work. Nothing in this letter should be taken as an agreement by Flibotte's Auto Salvage Co. with the assertions in your letter. I request that you provide immediately a copy of the so-called "preliminary assessment" performed by the Department and also a copy of the Goldberg, Zoino & Associates site investigation report which you reference in your letter. MASSACHUSETTS WATER RESOURCES AUTHORITY S;fl Charlestown Navy Yard 100 FirstAvenue Boston, Massachusetts 02129 Telephone: (617) 242-6000 March 20, 1989

Board of Directors John P DeVillars, Chairman Paul N.Anderson John J. Carroll Robert J.Ciolek Mr. Richard J. Chalpin, P.E. Lorraine M.Downey Anhony V.letcher Deputy Regional Engineer Charles Lyons Samuel G.Mygat Department of Environmental Quality Engineering MargaretA Riley Metropolitan Boston - Northeast Wafter J. Ryan, Jr. Region Jonatan z Souweine 5A Commonwealth Avenue ExecutivDirector Woburn, MA 01801 Paul FLevy Re: QUINCY/BRAINTREE - Former General Dynamics Shipyard - Area 5/Section E - Lancaster Road - DEQE Case #3-0536

Dear Mr Chalpin:

In response to your letter dated March 7, 1989 regarding the above site, the Massachusetts Water Resources Authority hereby advises you that it will undertake to install a fence around Area 5(E), as approved in your letter.

We have received a copy of a letter dated March 16, 1989 from General Dynamics, which responds to the other provisions of your letter.

Very truly yours,

Catherine L. Farrell General Counsel

cc: Laurie Burt, Esq., Foley Hoag & Eliot Robert F. White, General Dynamics GENERAL CYNAMICS Quincy Shipbuilding Division 116 East Howard Street, Quincy, Massachusetts 02169

March 16, 1989

Mr. Richard J. Chalpin, P.E. Deputy Regional Engineer Department of Environmental Quality Engineering Metropolitan Boston - Northeast Region SA Commonwealth Avenue Woburn, Massachusetts 01801 Re: Subsurface Soil/Area 5/Section E Quincy Shipyard, Quincy, Massachusetts DEQE Case #3-0536

Dear Mr. Chalpin:

On behalf of General Dynamics and in response to your letter dated March 7, 1989, we inform you of our intent to comply with the provisions of your letter by addressing the additional sections of the Massachusetts Contingency Plan ("MCP") specified in Section II of your March 7 letter, as appropriate. We are advised by the MWRA that it will install a fence around Area 5(E) as a short-term measure, as approved by DEQE. We look forward to working closely with DEQE in concluding this matter. Your attention and continued assistance in this regard is appreciated. Sincerely yours,

Robert F. White Manager of Operations

cc: Frank J. Basile - GDC Laurie Burt, Esq. - FH&E Catherine Farrell, Esq. - MWRA Lawrence Feldman - GZA Dean A. McCallum - GDC C. Robert Stoker - GDC Edward J. Willwerth - GD/Consultant 97 Gommonwa jI/aaacw/ueu

Ii Yba'r/nenb J /?w/vnnz/es/ &aa4 &/f95?4e/Vq9

-fAMe2ropo/ab eon,2 - jorr~eaaetgey& 6A 6'ommonawea//- Aoenza& Daniel S.Greenbaum * 2o e/'m/M fzacZ4eoseoi 04901 Comm issioner 935-2160

March 15, 1989 Mr. Joseph Flibotte Flibotte's Auto Salvage, Co. 45 Columbia Terrace Braintree, MA 02184 RE: BRAINTREE - Flibotte's Auto Salvage, Co. - Corner Columbia Terrace/Lancaster Road - NOTICE OF RESPONSIBILITY PURSUANT TO M.G.L. CHAPTER 21E DEQE Case No. 3-1605

Dear Mr. Flibotte:

This is to notify you that a "Preliminary Assessment" as defined in Section 40.541 of the Massachusetts Contingency Plan (MCP) has been conducted by the Department of Environmental Engineering (the Department) for a parcel of land located at the corner of Columbia Terrace and Lancaster Road, Braintree, MA. Based upon the results of this assessment a condition of soil contamination by petroleum products has been documented at the site.

Be advised that such a condition constitutes a "release" of oil at the subject site. The prevention and/or mitigation of such a release or threat of release is governed by Massachusetts General Law, Chapter 21E, the "Massachusetts Oil and Hazardous Material Release Prevention and Response Act."

Chapter 21E identifies as responsible parties the current owner or operator of a site at which there has been a release or threat of release of oil or a hazardous material; the past owner or operator of a site where a release of a hazardous material has occurred; any person who directly or indirectly arranged for the transport, disposal, storage or treatment of hazardous materials to or at such a site; and any person who caused or is legally responsible for a release or a threat of release of oil or a hazardous material at such a site. Such parties are liable without regard to fault; the nature of this liability is joint and several. (N.G.L. Chapter 21E, Section 5 a). Mr. Flibotte Page 2

This letter is to inform you in writing that: (1) The Department has determined that a release of oil has occurred at the subject site.

(2) Additional investigation and assessment is needed to adequately define the impact of this release on public health and the environment and to determine what remedial/cleanlup measures are necessary.

(3) Information available to the Department indicates that you as owner and operator of the subject site are a liable and "responsible" party pursuant to Section 5(a) of Chapter 21E.

(4) Should you fail to implement those actions deemed necessary by this Office, the Department may, pursuant to M.G.L. Chapter 21E, take or arrange for any and all necessary actions at the site. If public funds are expended under such conditions, Chapter 21E, Section 11 stipulates that the Attorney General of the Commonwealth of Massachusetts may initiate legal action against the responsible party(s) to recover all costs incurred by the Department in the assessment, containment, and removal of any release or threat of release of oil or hazardous materials.

(5) The liability of responsible parties in (4) above includes up to three times the cost of:

a. all response costs incurred by the Department due to the release/threat of release, including all contract, administrative, and personnel costs; and

b. all damages for any injury to, destruction, or loss of, natural resources due to the release/threat of release.

This liability constitutes a debt to the Commonwealth. The debt, together with interest, would constitute a li'en on all your property in the Commonwealth. In addition to the foreclosure remedy provided by the lien, the Attorney General of the Commonwealth may recover that debt or any part of it in an action against you. You may also be liable for additional penalties or damages pursuant to other statutes or common law.

A copy of Massachusetts General Law Chapter 21E and the Massachusetts Contingency Plan are available at the State House Bookstore in Boston.

Requisite Site Actions In order for the Department to evaluate the extent of contamination at the subject site and its potential impact on public health and the environment, the following information must be submitted: Mr. Flibotte Page 3

(1) A Phase I Limited Site Investigation as defined in Section 40.543 of the MCP, and

(2) A Scope of Work for a Phase II Comprehensive Site Assessment as defined in Section 40.545 of the MCP.

Be advised that, based upon information available to the Department, you are also a potential responsible party pursuant to Chapter 21E Section Sa(5) for a parcel of land located on Lancaster Road immediately north of the subject site. This property was previously owned by General Dynamics and is currently owned by the Massachusetts Water Resources Authority. A limited site investigation conducted by General Dynamics' environmental consultant, Goldberg, Zoino & Associates, identified extensive contamination of onsite soils by petroleum products.

A written response indicating your intentions to comply with the provisions of this letter is required within 14 days.

If you have any further questions regarding this matter, please contact Sharon Gerolamo at the letterhead address or 935-2160. All future communications regarding this site must reference the DEQE Case Number designated in the subject heading.

Very truly 'yours,

Sharon A. Gerolamo vironmental En ' eer III

Richard J. alpin Deputy Reg al Environmental Engineer RJC/SG/ae cc:

DEQE, DHW, 1 Winter St., Boston, MA 02108, Attn: SAC Chief, 5th Floor DEQE, OGC, 1 Winter St., Boston, MA 02108, Attn: Anne Bingham, 3rd Floor Braintree Board of Health, 1 JFK Memorial Dr., Braintree, MA 02184 Quincy Board of Health, 1120 Hancock Street, Quincy, MA 02169 Weymouth Board of Health, 75 Middle St., Weymouth, MA 02189 Robert White, General Dynamics, 116 East Howard Street, Quincy, MA 02169 Ken Wenger, MWRA, Charlestown Navy Yard, 100 First Ave., Boston, MA 02129 Beji Malek, Cities Service Oil & Gas Corp., 110 West 7th St., Box 300, Tulsa, OK 74102 Laurie Burt, Foley, Hoag & Elliot, One Post Office Sq., Boston, MA 02109 John Grabowski, Citgo Petroleum Corp, One Warren Pl, Box 3758, Tulsa, OK 74102 Cheryl Lee, Clean Harbors, Inc., 325 Wood Rd., Braintree, MA 02184

.4 Mr. Flibotte Page 4

Donna Sullivan, East Braintree Civic Assoc., 59 Hayward St, Braintree, MA 02184 Mayor Francis McCauley, 1305 Hancock St., Quincy, MA 02169 Representative Suzanne Bump, State House, Room 443, Boston, MA 02133 Senator Paul Harold, State House, Room 507, Boston, MA 02133 David Standley, 4 Spillers Lane, Ipswich, MA 01938 Brian McDonald, Board of Selectmen, 75 Middle St., Weymouth, MA 02189 Joseph Sullivan, Board of Selectmen, 1 JFK Memorial Dr., Braintree, MA 02184 Rep. Brian Donnelly, 438 Cannon House Office Bldg., Washington, DC 20515 Peter Koff, Weston & Patrick, 84 State St., Boston, MA 02109 Paul Anderson, DPW, 55 Sea St., Quincy, MA 02169 Steve Lipman, DEQE, 7th Floor, 1 Winter St., Boston, MA 02108 0

DEPARTMENT OF ENVIRONMENTAL QUALITY ENGINEERING PUBLIC INVOLVEMENT PROCESS SUBCOMMITTEE OF THE FORE RIVER ADVISORY TASK FORCE MINUTES MARCH 14, 1989 Attendees: Kathleen Chojnowski, Foley, Hoag & Eliot Bob White, General Dynamics Edward J. Willwerth, General Dynamics consultant James Goldstein, ESRG Barbara Tobex, Clean Harbors Judith A. Barker, Clean Harbors Susan Swieck, Warner & Stackpole Glenn Keith, Weymouth Gerry Hughes, EBCA Braintree Robert Jabaily, EBCA Braintree William J. Reardon, Quincy Citizens Association Gregory Meade, No. Weymouth Prospect Hill Improvement Association Donna O'Sullivan, Braintree RTF/EBCA Cynthia DeCristofaro, City of Quincy Health Department Joseph Lyons, Representative Bump's Office Paul Donnelly, City of Quincy Sarah Weinstein, DEQE/Boston Karen Stromberg, DEQE Sharon Gerolamo, DEQE Chris Barnett, MWRA Danny Johnson, MWRA Diane Gray, Howard/Stein-Hudson Associates

This meeting was the first meeting of the !ubcommittee to discuss the status of the Fore River Shipyard Disposal Site.'

Karen Stromberg of DEQE opened the meeting and introduced her colleagues, Sarah Weinstein and Sharon Gerolamo. She stated that during DEQE's community interviews for the draft Public Involvement Plan, people said they were overburdened and asked that an existing group be used as the focus for public

involvement activities during the cleanup of this site.

-I- Ms. Weinstein discussed organizational issues pertaining to the subcommittee. The group decided that the chief municipal officials should be asked to appoint three membrs to the subcommittee. They may end up being the same members as the Fore

River Task Force. The subcommittee will meet at 6:00, following the Task Force meeting.

DEQE will set the agenda of the meetings and incorporate recommendations from the subcommittee. The group will meet on a monthly basis for the next three to four months. Future meetings will occur based on the progress of the site cleanup, as there are issues to discuss. In response to a question from Ms. O'Sullivan as to how the mailing list was generated, Ms. Stromberg answered that notice of the meeting was mailed to all the Task Force members, other

interested people that DEQE knows of and anyone who has signed

the sign-in sheet at public meetings. The notice was put in the

Braintree Forum and posted with the town/city clerks in all three

communities.

Ms. Decristofaro stated that there were many issues brought

up in the Fore River Task Force meetings that were more appropriate to bring up in this DEQE meeting.

Ms. Gerolamo reviewed the status report for the site (see

handout).

In response to a question from Mr. Johnson about who receives copies of comments that DEQE gets on the documents it puts out for public comment, Ms. Gerolamo stated that DEQE sends

-2- copies of comments to MWRA, General Dynamics, the information repositories and everyone who submitted comments. A written response to the comments will be distributed to the subcommitee at the next meeting.

In response to a question from Mr. Lyons regarding how DEQE responds to comments, Ms. Stromberg stated that DEQE will respond to all public comments in writing.

Ms. O'Sullivan suggested putting two copies of documents at each information repository so one copy could be taken out. The library is only open limited hours.

Ms. Gerolamo then responded to many of the public comments DEQE had received on MWRA's Construction Procedures document.

(None were received on the two General Dynamics documents.) She stated that these responses will be put in writing for the next meeting.

Mr. Lyons commented that the DEQE Public Involvement Plan

(PIP) is late to the process. Ms. Weinstein responded by saying that though there has been informal implementation of public involvement at sites for quite some time, the formal process only began in October, 1988, with the promulgation of the

Massachusetts Contingency Plan.

Ms. DeCristofaro stated that key agenda items for future meetings are: information on what actions have been taken to date; where DEQE stands in calling areas clean and how DEQE deems areas to be clean. She emphasized that details and clarification are needed. Some of that information, Ms. Stromberg answered, is

in the PIP, and she asked for a more specific request.

-3- Ms. DeCristofaro asked that DEQE focus on the NUS report, specifically the follwing: chlorinated hydrocatbons in the groundwater; cyanide; and the outfall pipe in the shipyard that was found to have volatile organic compounds and metals in it and dumps into Fore River.

Ms. Gerolamo answered that an investigation of this pipe in

1986 found the source of contamination to be off-site. Mr.

Donnelly stated that they have since traced the pipe and it does not exist outside of the shipyard, so the contamination must be coming from the site. Ms. Gerolamo will look into this subject.

Mr. Donnelly stated that the city has to inform the workers at the shipyard of hazards in the workplace. He asked how they

should inform the workers and if they should call OSHA.

Mr. Donnelly said that at the point of calling OSHA, the workers have already been exposed to asbestos. Ms. Stromberg

said she understood that OSHA can be called in when the buildings

are being prepared for workers. Ms. Weinstein said that DEQE's authority stops at the building walls and that DEQE only deals

with releases to the environment or the threat of releases to the

environment. Ms. DeCristofaro stated that the concern is for workers involved in the preliminary cleanup prior to occupation.

Ms. Stromberg said that she could have the DEQE asbestos

specialist come to a meeting. Ms. DeCristofaro agreed with the

idea but stated that someone from the Department of Labor and

Industries (DLI) should also attend.

-4- Ms. DeCristofaro asked about leasees, specifically the

Massachusetts Shipbuilders. Mr. Barnett stated that MWRA is not

surveying those buildings that will be leased, and that such

buildings are being leased in their present condition. Ms.

DeCristofaro was concered that general cleaning may disturb the

fryable asbestos in these buildings.

At this point, Ms. Stromberg stressed that topics in the

subcommittee will have to be confined to issues that relate to Chapter 21E. All other items should be raised ih MWRA's Task Force meetings.

A man asked how people can comment on MWRA's asbestos plan. Mr. Barnett answered that the plan was not included in the

Construction Procedures document. The plan was only detailed in the contract with the -removal company and is not part of the 21E process. Mr. Barnett's preliminary position is that this is not an issue for public comment.

Mr. Donnelly asked where the site number is posted. Ms.

Stromberg said the number refers to a wetland permit. Ms.

Weinstein explained that some hazardous waste sites are posted but only when there is a fear of people gaining access to the

site. This is not an issue at the shipyard. C.:3 PM The next meeting will be April 24, 1989 at e.ma. Anyone with questions should call Ms. Stromberg at 935-2160.

-5- flo, a oort - ylorcesYfcior SA JonwzonweakA Xoenuc.-

Daniel S.Greenbaum f 0 aW $SaSdaz444s& t161Of Commissioner

935-2160 March 15, 1989

Paul F. Levy, Executive Director Mass. Water Resources Authority Charlestown Navy Yard 100 First Avenue Boston, NA 02129 RE: QUINCY - Former General Dynamics Shipyard 97 E. Howard Street DEQE Case 13-0536 CONDITIONAL APPROVAL Dear Mr. Levy:

The Department has reviewed an updated version of the Procedures Associated with Construction Related Activities at the Fore River Staging Area as provided to this Office on March 6, 1989. This version was intended to incorporate the necessary revisions to reflect the discussions held between our respective staffs on March 1, 1989, relative to public comments filed with the Department as provided for in the Public Involvement Plan pursuant to NGL Chapter 21E, Section 14(b).

Be advised that the Department herewith approves of the referenced document subject to the following conditions:

(1) The Authority incorporates final revisions to the text of the document which will be provided by Sharon Gerolamo of my staff.

(2) The following wording shall be incorporated into the text on Page 3 after the sentence ending, ".... are needed."

"If due to unlikely circumstances beyond its control, DhQE is unable to complete its review of workplans and specifications and to notify the MYRA within the twenty-one day period whether additions or modifications are needed, DEQE will notify the MRA in writing that additional time will be required and the date by which DEQE will complete its review and notification regarding whether and what additions or modifications will be necessary."

100 % Recycled Paper Mr. Levy Page 2

(3) The text of Section 5-02, Air Quality Monitoring should be amended to indicate (footnote is recommended) that the 5 milligrams per cubic meter particulate matter criteria currently included in the text is considered a tentative criteria subject to verification through the additional assessment to be performed by MWRA.

(4) The text in Section 2-05, Soil Handling Procedures, and other pertinent sections of the document will be revised as discussed below: Indicate that Categories A and B in the referenced version of the document are being combined (at least temporarily) into one single category as defined in the current document as Category B (requires all excavated materials which are temporarily stockpiled on-site to be covered with polyethylene).

As has been discussed by our staffs, condition (4) is being incorporated into this document at this time in order to allow DEQE to approve the document which will then allow the Authority to proceed forward with the final permitting and design activities at the Fore River Staging Area (FRSA) needed to implement the various pollution abatement projects for the cleanup of Boston Harbor. If it is eventually determined that a Category A (uncovered excavate) classification would in fact be useful to the Authority, and our staff can agree on the contaminant-specific criteria, MWRA will file a formal request with DEQE to amend the procedures. At that point in time, DEQE will determine whether or not the proposed amendment needs to go through additional public review.

If you have any questions regarding this correspondence feel free to contact Sharon Gerolamo at the letterhead address or 935-2160. All future correspondence regarding this site must reference the DEQE Case Number designated in the subject heading.

Very truly yours, sR' r Chap& Deputy Regional Environmental Engineer

RJC/SL/SG

cc: DEQE, DHV, 1 Winter St., 5th Fl., Boston, MA 02108 Attn: Site Assessment Section Chief DEQE, 1 Winter St., Boston, NA 02108 Attn: Anne Bingham, OGC, 3rd. Fl. Mr. Levy Page 3

DEQE, 1 Winter St., Boston, MA 02108 Attn: Steve Lipman, DWPC, 7th. Fl. DEQE, 1 Winter St., Boston, MA 02108 Attn: Caleb Hemphill, ORS, 10th Fl. Ken Wenger, MWRA, Charlestown Navy Yard, 100 First Ave., Boston, MA 02129 Robert White, General Dynamics, 116 East Howard St., Quincy, MA 02169 Braintree Board of Health, 1 JFK Memorial Drive, Braintree, MA 02184 Quincy Board of Health, 1120 Hancock St., Quincy, KA 02169 Weymouth Board of Health, 75 Middle St., Weymouth, MA 02189 Foley, Hoag & Elliot, One Post Office Sq., Boston, MA 02109 Attn: Laurie Burt Cities Service Oil and Gas Corp., 110 West 7th St., Box 300, Tulsa, OK 74102 Atta: Beji Malek Citgo Petroleum Corp., One Warren Pl., Box 3758, Tulsa, OK 74102 Attn: John Grabowski Clean Harbors, Inc., 325 Wood Rd., Braintree, MA 02184 Attn: Alan McKim East Braintree Civic Association, c/o Donna Sullivan, 59 Hayward St., Braintree, MA 02184 Mayor Francis McCauley, 1305 Hancock St., Quincy, MA 02169 Representative Suzanne Bump, State House, Room 443, Boston, MA 02133 Senator Paul Harold, State House, Room 507, Boston, MA 02133 David Standley, 4 Spillers Lane, Ipswich, MA 01938 Brian McDonald, Board of Selectmen, 75 Middle St., Weymouth, MA 02189 Joseph Sullivan, Board of Selectmen, 1 JFK Memorial Dr., Braintree, MA 02184 Representative Brain Donnelly, 438 Cannon House Office Bldg., Washington, DC 20515 Peter Koff, Weston & Patrick, 84 State St., Boston, MA 02109 Paul Anderson, DPW, 55 Sea St., Quincy, MA 02169 DANIEL S.CREENBAUM OsV nO aM Sea Commissioner 018621

Status Report Fore River Shipyard Disposal Site Quincy, MA

April 24, 1989

Floating Oil Plume and Associated Contaminated Groundwater

The oil and groundwater recovery and treatment system continues to operate in the central portion of the Shipyard. As of April 21, 1989, approximately 374,670 gallons of oil have been recovered. The on-site air stripper has been effective in treating over 81 million gallons of contaminated groundwater to approved discharge limitations.

As required by DEQE, additional work has been conducted in the central portion of the Shipyard to further define the extent of the oil plume. A report documenting the results of this investigation is currently being prepared by General Dynamic's consultant, Goldberg, Zoino, & Associates (GZA), and is expected to be submitted within the next two months. Once finalized, this report will be placed in the information repositories.

Oil-Contaminated Soil Feasibility Study

The Department has completed its review of GZA's April, 1988 report entitled: "Feasibility Study, Subsurface Soil/Oil Plume Area". This document went out for public comment between January 26, 1989 and February 16, 1989, however, no comments were received during this period. DEQE will be issuing a final determination on this matter by the end of April.

Southeastern Boundary

A report documenting the results of additional investigation conducted in the Southeastern Boundary has been completed by GZA. This report is entitled: "Additional Investigation of Southern Boundary Source Areas, Quincy Shipyard" and was submitted to the Department on April 21, 1989. This document will be placed in the information repositories immediately. Long Term Monitoring

The four quarterly groundwater monitoring reports (for selected areas of the site where the Department determined that long term monitoring of groundwater was necessary to observe trends in contaminant concentrations over Status Report Page 2

time) are currently under review by the Department. Additional information on one of these areas was submitted to DEQE on April 12, 1989 in a GZA report entitled: "Hydrogeologic Study, Quincy Shipyard, Building 55 and 57 Area, Quincy, MA". This document will be placed in the information repositories immediately. The Department will be issuing a final determination on the need for remediation of these areas within the next month.

Area 5E

Based upon a review of GZA's November, 1988 Area 5E assessment report, DEQE issued a letter to General Dynamics and the MWRA on March 7, 1989 which stated that: (1) additional investigation is required to further define subsurface conditions and (2) the installation of a fence around the parcel as a short term measure is approved. General Dynamics responded in a letter dated March 16, 1989 indicating that they will comply with the Department's requirements for additional investigation. MWRA responded in a letter dated March 20, 1989 indicating that they will install a fence around Area 5E within the next month.

Construction Procedures

DEQE is currently working with MWRA to finalize the Construction Procedures, incorporating public comments where appropriate. The Department conditionally approved of the Procedures in a letter to the KWRA date March 15, 1989. The major outstanding issue is the need for chemical specific "action levels" for fugitive dust. These "levels" are currently being developed by MWRA's consultant, E.C. Jordan, utilizing methods approved by DEQE. Once completed, these chemical specific "action levels" will be made available for public comment.

Land Use Restriction

A draft of the land use restriction agreement between NWRA and DEQE is expected to be completed by the end of April. Once finalized, this document will be made available for public comment. DANIEL S.GREENBAUM 5 j 6 MM/w n J2e&na Commissioner A omIY

STATUS REPORT FORE RIVER SHIPYARD DISPOSAL SITE QUINCY, MA

MARCH 14, 1989

FLOATING OIL PLUME AND ASSOCIATED CONTAMINATED GROUNDWATER

THE OIL AND GROUNDWATER RECOVERY AND TREATMENT SYSTEM CONTINUES TO OPERATE IN THE CENTRAL PORTION OF THE SHIPYARD. AS OF MARCH 3, 1989, APPROXIMATELY 373,200 GALLONS OF OIL HAVE BEEN RECOVERED. THE ON-SITE AIR STRIPPER HAS BEEN EFFECTIVE IN TREATING OVER 60 MILLION GALLONS OF CONTAMINATED GROUNDWATER TO APPROVED DISCHARGE LIMITATIONS.

ADDITIONAL WORK HAS BEEN CONDUCTED TO FURTHER DEFINE THE EXTENT OF THE PETROLEUM PLUME. A REPORT DOCUMENTING THE RESULTS OF THIS INVESTIGATION IS CURRENTLY BEING PREPARED BY GENERAL DYNAMIC'S CONSULTANT, GOLDBERG, ZOINO & ASSOCIATES, AND IS EXPECTED TO BE COMPLETED WITHIN THE NEXT TWO MONTHS.

OIL CONTAMINATED SOIL - FEASIBILITY STUDY

THE DEPARTMENT PUT THE APRIL, 1988 FEASIBILITY STUDY CONCERNING THE REMEDIATION OF SUBSURFACE PETROLEUM CONTAMINATED SOIL ASSOCIATED WITH THE MAIN PLUME, OUT FOR PUBLIC COMMENT ON JANUARY 26, 1989. THE COMMENT PERIOD EXTENDED THROUGH FEBRUARY 16, 1989. NO COMMENTS WERE RECEIVED BY THE DEPARTMENT DURING THIS PERIOD. THE DEPARTMENT IS CURRENTLY REVIEWING THIS DOCUMENT AND A DECISION IS EXPECTED WITHIN THE NEXT MONTH.

SOUTHEASTERN BOUNDARY

ADDITIONAL INVESTIGATION HAS BEEN CONDUCTED IN THIS AREA TO FURTHER DEFINE SITE CONDITIONS. A REPORT DOCUMENTING THE RESULTS OF THIS INVESTIGATION IS CURRENTLY BEING FINALIZED AND IS EXPECTED TO BE SUBMITTED IN MID APRIL.

LONG TERM MONITORING

THE FOUR QUARTERLY GROUNDWATER MONITORING REPORTS ARE CURRENTLY UNDER REVIEW BY THE DEPARTMENT. A DECISION IS EXPECTED WITHIN THE NEXT TWO MONTHS. 2.

AREA 5E

THE DEPARTMENT PUT THE NOVEMBER, 1988 AREA 5E ASSESSMENT REPORT OUT FOR PUBLIC COMMENT ON JANUARY 26, 1989. THE COMMENT PERIOD EXTENDED THROUGH FEBRUARY 16, 1989. NO COMMENTS WERE RECEIVED BY THE DEPARTMENT DURING THIS PERIOD. BASED UPON THE DEPARTMENT'S REVIEW OF THIS DOCUMENT, A LETTER WAS SENT OUT ON MARCH 7, 1989 INDICATING THAT ADDITIONAL INVESTIGATION IS REQUIRED AND APPROVING OF THE INSTALLATION OF A FENCE AS A SHORT TERM MEASURE.

CONSTRUCTION PROCEDURES

THE CONSTRUCTION PROCEDURES FOR FUTURE DEVELOPMENT AT THE SITE WENT OUT FOR PUBLIC COMMENT ON JANUARY 31, 1989. THE COMMENT PERIOD EXTENDED THROUGH FEBRUARY 20, 1989. MANY COMMENTS WERE RECEIVED ON THIS DOCUMENT. THE DEPARTMENT IS CURRENTLY FINALIZING THIS DOCUMENT WITH THE MWRA, INCORPORATING PUBLIC COMMENTS WHERE APPROPRIATE.

LAND USE RESTRICTION AGREEMENT

A DRAFT OF THE LAND USE RESTRICTION AGREEMENT BETWEEN MWRA AND DEQE IS EXPECTED TO BE AVAILABLE FOR PUBLIC COMMENT BY THE END OF APRIL. JXAonwwnweae&kgJI//5vactseuir& ~$areow2t Jcouw&nenca/~2 aa4y c9 q~uzeo~y

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Daniel 5. Creenbaum *2oAvz~ JJfa&SeZCACM4&& 0/60/ Commissioner

MEETING NOTICE

A Subcommittee of the Fore River Advisory Task Force is meeting to discuss the status of the Fore River Shipyard Disposal Site

Tuesday, March 14 6:00 P.M.

Fore River Staging Area - Administration Building 97 East Howard St.,Quincy

AGENDA

o Review of public comments received on the following reports:

- Haley Aldrich Construction Procedure Document

- Feasibility, Subsurface/Oil Plume Area Report - Evaluation of Petroleum-Related Contamination in Area 5/Section E

o Update o the Status of the Site

o Structure of the Subcommittee

For further information, please call Karen Stromberg at DEQE at (617) 935-2160.

A0 C % lecyc ec Poce' 0. 0

PUBLIC INVOLVEMENT PLAN (draft)

Disposal Site: FORE RIVER SHIPYARD (Formerly - GENERAL DYNAMICS) 97 East Howard Street, Quincy, Massachusetts

Prepared by:

Massachusetts Department of Environmental Quality Engineering Northeast Regional Office Site Assessment and Cleanup Section 5 Commonwealth Avenue Woburn, MA 01801 January, 1989

Contact for more information:

Karen Stromberg Public Involvement Coordinator (617) 935-2160 DRAFT PUBLIC INVOLVEMENT PLAN

FORE RIVER SHIPYARD DISPOSAL SITE (Formerly - GENERAL DYNAMICS) QUINCY, MASSACHUSETTS

I. INTRODUCTION

In May 1988, the Department of Environmental Quality Engineering (DEQE) received a petition from the East Braintree Civic Association. The petition expressed the group's concerns about the General Dynamics site (now known as the Fore River Shipyard disposal site) and requested that the site be designated a "Public Involvement Site" in accordance with the Massachusetts Contingency Plan, Section 40.203(1).

Under the Massachusetts "Superfund" Law (M.G.L. c. 21E), DEQE is responsible for overseeing remedial response actions at sites where oil or hazardous materials have been released to the environment. Remedial response actions include: determining the nature, source and extent of the contamination; identifying risks posed by the site; determining whether cleanup actions are necessary, and if necessary, determining and implementing the most appropriate actions. In addition, the remedial response action process provides opportunities for public involvement throughout the process. The remedial response action process is established by the Massachusetts Contingency Plan (310 CMR 40.00).

Public involvement during the remedial response action process is undertaken to ensure that the public is both informed of and involved in planning for remedial response actions. For disposal sites at which the public indicates interest in becoming involved in this process, DEQE designates the site as a "Public Involvement Plan Site", and prepares a plan which identifies specific activities that will be undertaken to address public concerns to the extent possible. The draft Plan is reviewed by the public and revised, where appropriate, based on comments submitted to DEQE. The final Plan is then implemented in conjunction with the development and implementation of remedial response actions for the disposal site. DEQE has designated the Fore River Shipyard site a Public Involvement Plan site, in accordance with the Massachusetts Contingency Plan.

This document is the proposed Public Involvement Plan for the Fore River Shipyard disposal site. Section II contains background information on the site, the history of remedial response actions and public involvement. Section III explains how community concerns which have been raised during the development of the draft Public Involvement Plan can be addressed during the remedial response action process. Section IV describes the public involvement activities which are proposed. Section V outlines the roles and responsibilities of those involved in carrying out the Public Involvement Plan. Section VI explains how the Plan can be revised in the future. 2.

DEQE will present this draft Plan for review at a public meeting which will be held on January 26, 1989, at the Braintree Town Hall Auditorium, 1 JFK Memorial Drive, Braintree, at 7:00 p.m. This meeting will also provide an update on the status of remedial response actions at this site. Anyone who wishes to comment on the draft Public Involvement Plan is encouraged to do so. Comments may be submitted at the meeting, or by telephoning or writing to Karen Stromberg, DEQE/Northeast Regional Office, Site Assessment and Cleanup Section, 5 Commonwealth Avenue, Woburn, MA 01801 (telephone: 617/935-2160). Comments must be submitted by February 16, 1989.

II. BACKGROUND INFORMATION

A. Site History

The Fore River Shipyard site consists of approximately 180 acres, most of which are in Quincy, with the remainder in Braintree. The Shipyard is bordered by East Howard Street on the west, South and Washington Streets to the north, the Weymouth Fore River to the east, and the Clean Harbors and CITGO facilities and Quincy Avenue to the south. The site has been used for shipbuilding since 1901. From 1901 to 1913, the Shipyard was owned by the Fore River Ship and Engine Company. Between 1913 and 1963, it was owned by the Bethlehem Steel Company. In January 1964, General Dynamics Corporation purchased the Shipyard. The Shipyard was formally closed in May 1986, and all industrial operations ceased.

In February 1986, in anticipation of the sale of the property, General Dynamics hired Goldberg-Zoino & Associates (GZA) to begin a comprehensive environmental assessment. General Dynamics submitted the results of this investigation and proposed remedial actions to DEQE in May 1986. This site assessment revealed certain areas of soil and groundwater contaminated with fuel oil, gasoline, chlorinated solvents, acid extractable/base neutral compounds, metals and PCBs. On October 21, 1986, DEQE formally notified General Dynamics of its responsibilities and liabilities under M.G.L. c. 21E by issuing a Notice of Responsibility (NOR) letter.

During 1987, General Dynamics submitted several supplemental assessment reports. After reviewing this information and performing a number of site inspections, DEQE determined that overall, the assessment was sufficient to identify all areas of the site that may pose a significant threat to public health or the environment. Based on that determination, DEQE, in a letter dated September 20, 1987, established remediation requirements for the contaminants identified. This letter also contained the Department's requirements for additional information. 3.

In November 1987, the Massachusetts Water Resources Authority (MWRA) purchased the Shipyard. MYRA will be using portions of the property for various components of the Boston Harbor Cleanup program, including as a staging area for construction of the new Deer Island wastewater treatment facility and as a short term sludge processing facility during the cleanup of Boston Harbor. Currently, the Shipyard is being considered as a location for MWRA's long term sludge processing facility. In October 1988, MWRA leased 50 acres of the southern and central portions of the site to the Massachusetts Landbank for use by the Massachusetts Shipbuilders to resume shipbuilding.

As part of the Purchase and Sales Agreement between General Dynamics and MWRA, MWRA hired NUS Corporation to conduct an independent review of all previous assessment and cleanup activities at the site, and conduct its own assessment of environmental conditions on the property. In March 1988, MWRA provided the results of NUS's investigation to DEQE. At General Dynamics' request, GZA evaluated the NUS study and conducted an evaluation of the risk to public health and the environment posed by the Shipyard. This evaluation was based on the highest contaminant concentrations reported by both NUS and GZA. After reviewing both these reports, DEQE has determined that no new significant areas of contamination have been identified by these reports.

DEQE's decisions about the adequacy of remedial actions at the Shipyard have been based on the understanding that the property will continue to be used for industrial purposes in the future. To ensure that future construction at the Shipyard does not pose a threat to workers at the site, site neighbors or the environment, MYRA has hired a consulting firm (Haley and Aldrich) to prepare a document which provides: (1) criteria to be used to determine the extent of contamination, if any, in the specific area being developed, (2) procedures to be used to classify, handle, reuse or dispose of excavated soils and groundwater generated during dewatering, and (3) procedures to be followed by contractors to prevent any potential exposure of workers to contaminants and prevent the contaminants from leaving the construction area, either in the air, water, or inadvertently on vehicles. This document must be approved by DEQE and will be part of an agreement between DEQE and MWRA which will limit the use of the site to ensure that future uses will not pose a threat to public health or the environment.

General Dynamics, under the direction of DEQE, has conducted assessment and remedial activities in several areas of the site. The major remedial activities that have been performed to date are summarized below.

O Floating Oil Plume and Associated Contaminated Groundwater and Subsurface Soil: During the initial site assessment, a large release of oil from a leaking underground pipeline was identified in the central portion of the Shipyard. In the October 1986 NOR, DEQE approved General Dynamics' proposal to recover this oil. A system which recovers and treats oil and groundwater has been operating since October 1986. As of December 30, 1988, approximately 370,000 gallons of oil has been recovered. The thickness of oil in the area has decreased from approximately 8 feet in some areas to 2 feet or less. An air stripper has lowered contaminant concentrations in over 57 million gallons of recovered groundwater to discharge limits specified by DEQE and the US Environmental Protection Agency. 4.

General Dynamics submitted a proposal in August 1988, to further define the northern boundary of the plume. This proposal was conditionally approved by DEQE on August 26, 1988, and the work has-started. As required by DEQE, in April 1988, General Dynamics submitted a feasibility study which evaluates remedial alternatives for the subsurface contaminated soil associated with the oil plume. DEQE is currently reviewing this report.

0 Surficial Oil Contamination/Stockpiled Soil: During a site inspection, DEQE identified several areas of oil stained surface soils requiring removal. During May and June 1988, approximately 760 cubic yards of contaminated soil were removed from these areas and disposed of at out-of-state facilities approved to accept such materials. Reports documenting the soil removal were submitted to DEQE in July and November 1988. Based on these reports, DEQE determined in a letter to General Dynamics dated December 7, 1988, that the Department's requirements for remediation of these areas have been met.

One of the areas of oil stained surface soils, located next to the main plume, was too extensive to completely remove all the oil-contaminated soil. The contaminated soil was excavated, to the extent feasible, and replaced with clean soil under DEQE approval and will be addressed in connection with DEQE's review of the April 1988, feasibility study described above.

Another extensive area of oil/gasoline-contaminated soil was identified on a parcel outside the main Shipyard site, near its southwest boundary. This area is referred to as "Area 5E". The extent of contamination and proposed remedial actions were described in a report submitted to DEQE by General Dynamics in November 1988. DEQE is reviewing this report.

o Polychlorinated Biphenyls (PCBs): Prior to closing the Shipyard, General Dynamics began a program of decommissioning and retrofilling its electrical equipment containing PCBs. General Dynamics removed soil and cleaned up foundation pads at locations of equipment which formerly contained PCBs . Where feasible, PCB contaminated soil was removed until PCB concentrations were lower than 1 milligram/kilogram and pads stained with PCB oil were cleaned until PCB concentrations were lower than 100 micrograms/100 square centimeters.

The removal of PCB-contaminated soil and oil-stained pads was completed in April 1988, and sampling to verify the initial sampling results was completed in May 1988. Approximately 115 tons of contaminated soil and debris were removed from the site. A report summarizing these activities was submitted to DEQE in August 1988. DEQE conditionally approved these response actions in a letter dated December 7, 1988 to General Dynamics, indicating that the Department's requirements for remediation of these areas have been met with the stipulation that the results of sampling conducted prior to the remediation must be submitted and a deed restriction must be established for the areas that have been capped, in order to receive final approval. 5.

o Asbestos: General Dynamics removed or repaired damaged or exposed material containing asbestos in exterior locations was removed or repaired to prevent potential asbestos releases to the environment. No asbestos was detected in any soil samples taken across the site. Any future asbestos removal will be overseen by the DEQE Division of Air Quality Control's Asbestos Program. o Southeastern Boundary: General Dynamics is currently in the process of further defining subsurface conditions near the site's southeastern property boundary, adjacent to the Clean Harbors and CITGO facilities. General Dynamics is discussing the possibility of joint efforts for the assessment and remediation of this area with Clean Harbors and Cities Service/CITGO. Clean Harbors and CITGO are also investigating subsurface contamination in this general area on their properties.

In December 1987, #2 fuel oil was discovered in one of the groundwater monitoring wells located next to the southeastern boundary area. The source appears to have been an above-ground fuel oil tank and associated piping, which are now empty. Remediation of this area has been completed and a final report was submitted to DEQE in December 1988. DEQE is currently reviewing this report.

O Confirmatory Sampling: As required by DEQE, samples were taken and analyzed from 21 groundwater monitoring wells across the site to verify the results of previous sampling which identified the locations of groundwater contamination. General Dynamics submitted the results of this sampling to DEQE in a report dated May, 1988. DEQE is reviewing this report to ensure that prior decisions regarding remedial response actions are sufficient. o Long Term Monitoring: As required by DEQE, quarterly monitoring of contaminated groundwater in selected areas of the site was performed by General Dynamics. These locations include three areas where groundwater has been contaminated with chlorinated solvents or mineral spirits. Monitoring was done to observe trends in the levels of contamination over time. The results were submitted to DEQE in reports dated May, July and October 1988, and January 1989. Based on these results, DEQE will determine if additional investigation or remediation of these areas is required.

* Risk Assessment: MWRA presented the results of NUS's environmental assessment and comments on previous assessments and remedial activities to DEQE in a report dated March 17, 1988. At General Dynamics' request, GZA reviewed the NUS study and conducted an assessment of the risks posed by the Shipyard. The GZA risk assessment focused on groundwater contamination from the site and its impact on the Fore River. It was based on the highest contaminant concentrations reported by either NUS or GZA. The risk assessment examined potential impacts to human health from eating seafood from the river. Other routes of exposure (such as ingestion of soil and groundwater, inhalation of vapors and -1 -C 'I 'I ce :1 = LI

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particulates, and direct contact with soil) were evaluated, but not examined in detail because the site is paved and fenced, the saline (salt) groundwater in this area is not a potential drinking water source, and therefore there is no access to the contaminants on the site. The GZA risk assessment was submitted to DEQE in a report dated June, 1988. DEQE's Office of Research and Standards reviewed the risk assessment and agreed with the report's conclusion that the site, under its current use and present state, presents minimal risk to human health.

DEQE has overseen the above response actions to ensure that they meet the requirements of M.G.L. c. 21E. In 1986, the law was ammended to add a number of requirements for site cleanup. DEQE's regulations detailing the remedial response action process, the Massachusetts Contingency Plan, took effect in October, 1988. Most of the response actions described above were performed before the regulations took effect and DEQE's approvals were based on agency policies in effect at the time. Remedial response actions performed after October 1988, must comply with the MCP.

At this time, DEQE is continuing to oversee the assessment and cleanup of the site conducted by General Dynamics, to ensure that MCP requirements are met. DEQE is also working closely with MWRA regarding their plans for future development of the site.

In summary, many decisions regarding the adequacy of assessment and some remedial response actions have been made. Implementation of remedial response actions for some areas have not yet been completed and remedial response action plans for other areas are still being considered by DEQE. Issues remaining for DEQE include: subsurface soil contamination associated with the floating oil plume; oil contaminated soil on an off-site piece of property ("Area 5E); the "Southeastern Boundary"; areas of elevated levels of chlorinated solvents and/or mineral spirits in groundwater; the document describing MWRA's excavation and construction procedures for future work in contaminated areas of the site; and the land-use restriction. (See Exhibit III)

B. Public Involvement History

East Braintree is the location of several large industries. In the winter of 1987, the East Braintree Civic Association was formed by neighborhood residents to "improve and maintain the quality of life in Braintree, specifically East Braintree". At the time of the group's formation there were several specific issues facing the community. Clean Harbors, Inc. was proposing to site a hazardous waste incinerator on its property, and the MWRA was proposing that the General Dynamics Quincy Shipyard be used as the location for one of its Piers and Staging facilities during the cleanup of Boston Harbor. Shortly afterwards, the MWRA purchased the Shipyard from General Dynamics and it is proposed as the site for the MWRA's short term sludge processing facility and staging area for Deer Island construction. 7.

As a result of the East Braintree Civic Association's concern about the oil and hazardous materials on the General Dynamics property and MWRA's proposals for use of the Shipyard, the Association submitted a petition to DEQE [under M.G.L. c. 21E, Section 14 (b)] on May 5, 1988, requesting that:

* a public meeting be held (at a time and location convenient to them) involving Braintree residents in decisions regarding response actions at the General Dynamics site, and

o that DEQE's "proposed Public Involvement Plan" ensure that interested members of the public will have sufficient notice for the public meeting, access to documents, and the opportunity to comment on and affect the decisions regarding response actions at the General Dynamics disposal site.

The petition also stated that, "as an abutting community, there has been, is and will be imminent hazards to their health, safety, welfare and their environment". The petitioners requested that "a moratorium be placed on building at this site and abutting sites contaminated with chlorinated solvents, PCBs, mercury, cyanide and other metals". They also asked that "DEQE take immediate action to stop environmental harm, and control the potential for human exposure and health damage".

In developing this proposed Public Involvement Plan, DEQE took several steps to identify community concerns that the Plan must address. Documents in DEQE's files relating to the agency's past involvement with the site and the community were reviewed, and interviews were conducted by DEQE with local officials, groups and individuals in Braintree, Quincy and Weymouth. Concerns identified are listed in Exhibit I.

At a meeting of MWRA's Fore River Advisory Task Force on September 27, 1988, DEQE and General Dynamics briefed the Task Force on the status of the cleanup work done on the site and discussed the Public Involvement requirements of I.G.L. 21E, Section 14 and the Massachusetts Contingency Plan (310 CMR 40.00).

The Fore River Task Force is reviewing plans for long term use of the Shipyard and will provide input from the communities of Braintree, Quincy and Weymouth into the redevelopment plans for parcels that will not be used by MWRA. The Task Force is comprised of nine members who are appointed by the chief municipal officials in the three communities. All three of Braintree's members are also members of the East Braintree Civic Association. The Task Force serves as a vehicle for communication between MWRA and the communities, and is not a voting body.

III. ADDRESSING PUBLIC CONCERNS

The process for assessing and cleaning up disposal sites (as set forth in the Nassachusetts Contingency Plan, 310 CMR 40.00), is designed to address the effects of the site on health, safety, public welfare, and the environment. 8.

Once a release of oil or hazardous materials has been confirmed at a disposal site (Phase I of the remedial response action process), the process proceeds to:

* a comprehensive field investigation of the nature and extent of the contamination, and an evaluation of any risks posed to the public and the environment from the site (Phase II),

o identification and evaluation of remedial response action alternatives and selection of feasible measures that will achieve a permanent cleanup at the site (Phase III), and

O implementation of the selected remedial response actions (Phase IV).

Physical work at a disposal site includes sampling and other environmental field testing, and the implementation of the selected remedial response actions. It may also include the implementation of measures designed to stabilize conditions at the site (short term measures) to prevent conditions from degenerating while remedial response action planning is underway.

At each step of the remedial response action process, plans for work are developed, the work is conducted, and reports describing results and recommendations for the next step are prepared. The documents which describe each of these steps are the cornerstone of the remedial response action planning process, since they provide both the Department and the public with the information necessary to make decisions about how a site should be cleaned up.

As noted in Exhibit 1, the public has raised a number of concerns about the Fore River Shipyard disposal site. The remedial response action planning process is designed to address the concerns about the nature and extent of contamination, routes of exposure and neighborhood health issues, and the adequacy of proposed cleanup measures. Usually these issues are addressed in Phases II and III of this process. For example, the assessment of off-site contamination is considered in Phase II, as is the impact of the disposal site on public health and the environment. Phase III usually addresses the adequacy of proposed remedial response actions to provide permanent solutions for the contamination problems. At this site, many decisions regarding the adequacy of assessment and some remedial response actions have been made. For remaining remedial response actions, DEQE will work with the public to address concerns, where feasible.

Other concerns about the availability of information and opportunities for the public to comment on documents, and the accuracy of documents produced by consultants, are related to the process that DEQE will establish to ensure that the public is involved in planning for the remaining remedial response actions. To address these concerns, DEQE is proposing several public involvement activities in this draft Plan that are intended to provide information to Braintree, Quincy and Weymouth residents and officials, and to provide opportunities for the public to comment on documents describing specific remedial response actions. These activities are described in Section IV of this Plan. 9.

IV. PUBLIC INVOLVEMENT ACTIVITIES

In accordance with the Massachusetts Contingency Plan (40.200), activities undertaken to involve the public in response actions serve two purposes:

o for all disposal sites, public involvement activities inform the public of risks posed by the disposal site, remedial response actions, and opportunities for public involvement; and

o for Public Involvement Plan Sites, public involvement activities solicit the concerns of the public about the disposal site and remedial response actions, so that to the extent possible, these concerns can be addressed and incorporated in planning remedial response actions.

To meet each of these objectives, DEQE is proposing to undertake specific activities for the Fore River Shipyard disposal site. The activities proposed in this draft Public Involvement Plan have been selected to address the concerns about information and opportunities for involvement described in Exhibit 1. These public involvement activities are described below.

Activities for Providing Information

1. Information Repositories

Publicly Accessible Site File: A file on the Fore River Shipyard (formerly General Dynamics) disposal site is maintained at the DEQE Northeast Regional Office. The file contains all documents pertaining to the site, with the exception of enforcement sensitive material, if any. Appointments to view the file can be made by contacting Renee Mason, DEQE/Northeast Regional Office, Site Assessment and Cleanup Section, 5 Commonwealth Avenue, Woburn, MA 01801 (telephone: 617/935-2160).

Local Information Repositories: To provide Braintree, Quincy and Weymouth residents with easy access to information relevant to the site cleanup process, local Information Repositories have been established at specific branches of the town libraries. These repositories will contain information such as: official correspondence, reports and documents regarding the site; the Public Involvement Plan; briefing summaries; and summaries of responses to comments received. Information will be sent to the repositories as it becomes available. The libraries and their hours are as follows:

Library Address Hours

Watson Park 318 Quincy Avenue Tuesday 9:00am-5:30pr. Public Library Braintree Wednesday 12:00pm-8:00pm Thursday-Friday 9:00am-5:30pm 10.

Thomas Crane 40 Washington Street Monday, Tuesday, Thursday Public Library Quincy 9:00am-9:00pm Wednesday 10:00am-9:00pm Friday 10:00am-6:00pm Saturday 10:00am-5:00pm

Tufts Public 46 Broad Street Monday-Thursday 9:00am-9:00pm Library Weymouth Friday-Saturday 9:00am-5:00pm Sunday 2:00pm-5:00pm

Site information is also available in MWRA's library located at their offices at the Charlestown Navy Yard, 100 First Avenue, Boston. The MWRA library hours are Monday-Friday 8:30am-4:30pm. Please contact Mary Lydon, at 617/242-6000 ext. 2560, if you wish to use the MWRA library.

In addition, Boards of Health are routinely provided with copies of DEQE correspondence regarding the site.

2. Site Mailing List

DEQE has established a mailing list of concerned citizens, government officials, organizations, and the news media to keep the public informed during the remediation process. DEQE will maintain the list and update it as necessary. The list will also be given to MWRA and General Dynamics so that they may do any required mailings. If you are not already receiving information about the Fore River Shipyard disposal site from DEQE and would like to be added to the site's mailing list, please contact Karen Stromberg, DEQE/Northeast Regional Office, Site Assessment and Cleanup Section, 5 Commonwealth Avenue, Woburn, MA 018C1 (telephone: 617/935-2160).

3. Notification to Local Officials and Residents of Major Milestones and Events

DEQE requires community notification of major planning and implementation milestones at disposal sites. Major milestones include the start of remedial field work involving heavy equipment or protective clothing (level A or B protection), and the completion of a phase of the remediation process. Notification of remedial field work will include information on the type of work, its apprcximate duration, and any expected off-site shipments of contaminated material. Notification at the conclusion of a remedial phase will include a summary of the Phase report and information on where the report can be reviewed. The notification will be made by General Dynamics, MWRA or DEQE (depending upon who is performing the work) to the Notification List by telephoning the day before the activity will begin. Those to be notified include: 11.

Affiliation Name Address Phone

Board of Selectmen Joseph Sullivan 1 JFK Memorial Drive 848-1870 Braintree, MA 02184

Mayor Francis McCauley 1305 Hancock Street 773-1380 Quincy, MA 02169

Board of Selectmen Brian McDonald 75 Middle Street 335-2000 Weymouth, MA 02189

Board of Health Thomas Gesewicz 1 JFK Memorial Drive 848-1870 Braintree, MA 02184

Board of Health M. Jane Gallahue 1120 Hancock Street 773-1380 Quincy, MA 02169 ext. 219

Board of Health Richard Marino 75 Middle Street 335-2000 Weymouth, MA 02189

State Representative Susan Bump State House, 722-2460 Room 443 Boston, MA 02133

State Senator Paul Harold State House, 722-1494 Room 507 Boston, MA 02133

East Braintree Civic Donna O'Sullivan 59 Hayward Street 843-8794 Association Braintree, MA 02184

In addition, local Police and Fire Depar tments will also be notified in situations where public safety is a concern.

Opportunities for Public Involvement

1. Briefings of a Fore River Task Force Subcommittee

DEQE proposes that a subcommittee of the MWRA Fore River Advisory Task Force be formed to deal specifically with the disposal site issues raised throughout the rest of the remediation process. The subcommittee would be formed of at least one current Task Force member from each town, and two additional members from each of the three towns, to be appointed by the chief municipal officials. Meetings would be open to the general public. A meeting schedule would be determined by the subcommittee members, but meetings would be held at times and in a location convenient to the public. 12.

DEQE, along with General Dynamics and MWRA, would provide briefings for the Subcommittee to: 1) give local officials, their representatives and the general public regular status reports on progress toward planning and implementing remedial response actions at the disposal site and 2) to provide an opportunity to comment on the remedial response action.

MWRA would notify the site mailing list of these meetings and would participate, along with General Dynamics, at each briefing. MWRA would prepare summaries of the meetings, and place a copy of these summaries in the local Information Repositories.

2. Public Comment Periods for Documents

When key documents are available in draft form, they will be provided to the Information Repositories, and a notice of their availability will be sent to the site's mailing list. The notice will include the title of the document, where it is available for review, information about how to submit comments to DEQE, and the length of the comment period. DEQE will determine the length of the comment period, which will normally be 20 calendar days, but may be longer if warranted by the complexity of a particular document. Public comment periods will be established for documents prepared for each discrete area on the Fore River Shipyard disposal site, and for any documents concerning the site as a whole. General Dynamics and/or MWRA will be responsible for providing copies of documents they produce to the Information Repositories and sending out notices of availability. DEQE will make available any documents it produces.

Documents usually available for comment include scopes of work for comprehensive site investigations (Phase II), evaluations of the feasibility of alternative remedial response actions and the final remedial response plan (Phase III), design plans for the selected remedial response actions (Phase IV), and plans for short term measures. Exhibit II is a generalized schedule of public involvement activities during the remedial action process. Exhibit III indicates outstanding site-related issues currently being considered by the Department. Documents prepared for response actions concerning these issues will be available to the public as they are developed.

DEQE will respond to public comments received on each document available for comment during the remedial response action process.

Please see the attached chart (Exhibit II) for a general schedule of the proposed public involvement activities.

V. RESPONSIBILITIES FOR IMPLEMENTING PUBLIC INVOLVEMENT ACTIVITIES

In accordance with the Massachusetts Contingency Plan (310 CMR 40.206), DEQE will delegate certain proposed public involvement activities to General Dynamics and MWRA. These activities are generally those designed to provide 13.

the public with information regarding remedial response actions. They can include providing copies of reports to local officials and information repositories, mailing notices of meetings and the availability of site reports, notifying local officials and residents of major field work on the site, providing an update on the status of the site to local officials and residents, and drafting fact sheets or report summaries. DEQE usually conducts public involvement activities related to obtaining and responding to public comments on proposed remedial response actions. DEQE will oversee MWRA's or General Dynamic's implementation of their delegated tasks, and will also conduct the required activities for its own technical work concerning this site.

VI. FUTURE PLAN REVIEW AND AMENDMENTS

This Public Involvement Plan may be revised whenever necessary during the course of the cleanup process. If revisions are proposed, DEQE will place a copy of the proposed revised Plan in the Information Repositories, and a notice of its availability will be sent to the site's mailing list Comments on the proposed revisions will be accepted during a 20 calendar day comment period. DEQE will review any comments received and revise the Plan as appropriate. The final Plan and any revisions will be placed in the Information Repositories. Exhibit I

Camumity Concerns about the Fore River Shipyard Disposal Site

A. Concerns about the nature and extent of contamination:

o What contaminants are on-site, where, and at what levels?

o Is groundwater contaminated and in what direction does it move?

o Is the Fore River, its sediments, banks or fish contaminated?

o What contamination is caning fra the Citgo and/or Clean Harbors property/ies (Southern boundary issue)?

o There should be an assessment of what hazardous and nonhazardous materials exist along the Fore River rail system.

B. Concerns about routes of exposure and neighborhood health issues:

o Is there any ongoing exposure to any contaminants?

* Will there be airborne cotamination during costruction or removal activities?

o Residents of the areas abutting the Shipyard feel they have been exposed to health risks over the years fro this site and other heavy industries in the area.

C. Concerns about the site remediation process:

o Nothing should be constructed on the property until all the hazardous waste there has been cleaned up.

o What are "industrial cleanup levels" and how will they affect future developnent on this site?

o Cleanup should be pennanent, with no contamination left on-site. Restrictions should not be placed on future land use, which will happen if waste is left on-site.

o General Dynamics should implement a permanent cleanup now, so that MWRA (i.e., rate payers) will not have to pay for any cleanup work in the future.

o How will clean up be done?

" The final cleanup should get an approval letter fro D2E.

o There is a lack of faith in DB2E's oversight; efficiency is being traded for expediency.

o The coments made by NIUS about previous response actions at the Shipyard in their March, 1988, site assessment report should be addressed.

(continued) Exhibit I (continued)

o That assessment/remediation work has been done on the site to date, by whorr, when?

SWhat assessment/remediation work is left to do, by who, when?

* Will DEQE have further requirements for the removal of asbestos ar-site?

o A single report should be developed about the air and water quality along the Fore River.

o Hazardous materials are being transported through the neighborhoods by truck and/or rail. This should be stopped.

* Where are hazardous materials being removed to?

o Cleanup work should be coordinated with all the other projects going on at the Shipyard.

D. Concerns about opportunities for public involvement during the remedial response action process:

o There should be one contact from each agency on this particular project (21E cleanup).

o People should be notified of ongoing work at the site.

* The local Boards of Health should be more involved. Specifically, they should receive: copies of all site-related correspondence/documents; notification of all activities related to asbestos removal 20 days in advance of the removal; notification of which days contaminated materials are to be removed, and an opportunity to witness the process; and copies of all hazardous waste manifests.

* Copies of documents should be placed in local libraries and/or Town Halls.

* There should be simplified sunraries of reports.

0 Information should be sent out before meetings and all information should be kept simple.

* Public meetings should be held in the evenings.

* Meeting notices should advertise the specific topics of the meeting, in clear language so that people do not have unrealistic expectations of what willbe discussed.

o Use existing groups and organizations to infor, their nerbers of site activities.

* People are over-burdened with meetings in this area, an existing group should be used for the focus of public involvement in cleanup activities at this site.

o The IWRA's Braintree/QuincyiVcymouth Fore River Task Force would be an appropriate group for the focus of the public involvement process during site cleanup. f-Y '- / A 0 0 04) A:> -vO

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0 0 Exhibit III

The chart in Exhibit II indicates a generalized schedule for the public involvement activities at this site. However, some remedial actions have been completed, or are already being implemented. These areas of the site will not go through the whole process again. Indicated below are the areas still in the remedial action process and where in the process they are. The last two site-related issues listed are not remedial response actions, but relate to the site as a whole.

Outstanding Site-Related Issues Response Action Phase

Subsurface soil contamination associated III - Development of Remedial with the floating oil plume Action Alternatives and the Final Remedial Response Plan

Oil contaminated soil on an off-site piece II - Comprehensive Site of property ("Area 5E") Evaluation

"Southeastern Boundary" II - Comprehensive Site Evaluation

*Areas where long term monitoring of *III - Development of Remedial groundwater contaminated with Action Alternatives and chlorinated solvents or mineral spirits the Final Remedial was being conducted Response Plan

Document describing MWRA's excavation and Not in a Phase, document construction procedures for future work in relates to the site as a any areas of the site whole

Land-use restriction Not in a Phase, document relates to the site as a whole

* Will go into Phase III only if remediation is recuired. GENERAL CYNAMICE INTER-OFFICE MEMO Quincy ShipbuilingDivision March 13, 1989

TO: Distribution

FROM: Robert White

SUBJECT: Vacation

I will be on vacation commencing Friday, March 17, 1989 and ending Sunday, March 26, 1989. During my absence, Ed Willwerth will respond to all environmental matters concerning the Shipyard Remediation program. Ed will be available each work day of the above dates from 8:00 A.M. to 12:00 P.M. In the event of an emergency, either Ed Willwerth or Dan Gale (GD/QSD) may be reached at the following Numbers.

Name Business Phone Home Phone

Ed Willwerth (617) 786-8300 x 303 (508) 747-1036 Dan Gale (617) 786-8300 x 307 (617) 585-2656

Your cooperation will be appreciated.

Robert White Manager of Operations Distribution: C. Barnett - MWRA F. Basile - GD/CO L. Burt - FH&E K. Chojnowski - FH&E L. Feldman - GZA D. Gale - GD/QSD S. Gerolamo - DEQE D. Kelley - AMSEA R. Lohmann - GTI D. McCallum - GD/CO C. McDermott - GZA C. R. Stoker - GD/CO K. Twombley - MWRA E. Willwerth - GD/Consultant

0 442 REV. ,79 ,hctol v Oo~vtzt - yAortteas &yie 6J Josnnwnweakk At&me

Daniel S. Greenbaum 0AU/4 jf0e (60 Commissioner

935-2160 March 7, 1989

Mr. Robert F. White General Dynamics/ Quincy Shipbuilding Division 116 East Howard Street Quincy, MA 02169

Mr. Ken Wenger MWRA Charlestown Navy Yard 100 First Ave. Boston, MA 02129 RE: QUINCY/BRAINTREE - Former General Dynamics Shipyard - Area 5/ Section E - Lancaster Road - DEQE Case #3-0536

Dear Sirs:

The Department of Environmental Quality Engineering (the,Department) is in receipt of a report prepared by Goldberg, Zoino & Associates (GZA) entitled: "Evaluation of Petroleum Related Contamination in Area 5/Section E, Quincy Shipyard, Quincy, Massachusetts, November, 1988." This report contains: (1) an assessment of petroleum contamination in Area 5/Section E (Area 5(E)) of the shipyard, (2) an evaluation of several techniques for remediating petroleum contaminated soil, and (3) a proposal for implementation of both a short and long term remedial measure in Area 5(E).

Since the "Former General Dynamics Shipyard" site has been designated a "Public Involvement Site" as per Massachusetts General Law Chapter 21E (MGL Chapter 21E) Section 14, the November, 1988 document was made available for public comment prior to the Department making any decisions on its content. The comment period extended from January 26, 1989 to February 16, 1989. No comments were received by the Department during this period.

Based upon a review of this document by this Office, the Department has the following conclusions/requirements for additional information:

100 % Recycled Paper Mr. White Page 2

I. IDENTIFICATION OF RESPONSIBLE PARTIES

GZA's November, 1988 report indicated that significant releases of petroleum products have occurred in Area 5(E). The exact source(s) of the releases were not identified, however, GZA stated that, in their opinion, "the most likely source of the gasoline contamination of the soils are the operations carried out on and adjacent t9 Section E by Flibotte's Auto Salvage."

Flibotte's Auto Salvage (Flibotte's) occupies several parcels in the Columbia Terrace/Lancaster Road area of Braintree. Two of these parcels abut Area 5/Section E to the north and south. The Department placed Flibotte's on the October 15, 1988 "List of Locations to be Investigated", a list published quarterly in accordance with MGL Chapter 21E, Section 3A(b) and the Massachusetts Contingency Plan (MCP) (310 CMR 40.00). The Department is currently pursuing Flibotte's for the assessment of environmental conditions on their property located at the corner of Columbia Terrace and Lancaster Road which abuts Area 5(E) to the south.

As you know, General Dynamics as prior owner and MWRA as current owner of Area 5(E) are liable and responsible parties pursuant to MGL Chapter 21E Section 5a(1) and 5a(2), respectively. Be advised that the Department will be notifying Flibotte's that they are a potential responsible party for Area 5(E) pursuant to Chapter 21E Section 5a(5).

II. REQUIREMENTS FOR ADDITIONAL ACTIVITIES

As defined in the MCP, GZA's November, 1988 report constitutes a combination partial Phase II report (310 CMR 40.545) and partial Phase III report (310 CMR 40.546). In order for the Department to approve of the Phase II Report, the following Sections of the MCP must be addressed:

40.545 3(a)2 40.545 3(a)8 40.545 3(a)9 40.545 3(b)2 40.545 3(d) 40.545 3(e) 40.545 3(g) 40.545 3(h)

As a short term measure to prevent future disposal at the site and to eliminate dermal contact with contaminated surface soils, the Department approves of MWRA's January 24, 1989 proposal to install a fence around Area 5(E). Mr. White Page 3

A written response indicating your intentions to comply with the provisions of this letter is required within 14 days.

If you have any questions, please contact Sharon Gerolamo at the letterhead address or 935-2160. All future correspondence regarding this site must reference the DEQE Case Number designated in the subject heading.

Very truly yours,

Sharon A. Gerolamo vironmental En 'neer

Richard J Calpin Deputy Reg nal Environmental Engineer

RJC/SG/ae cc: DEQE, DHW, SAC, 1 Winter St., 5th Fl., Boston, MA 02108 DEQE, 1 Winter St., Boston, MA 02108 Attn: Steve Lipman, DWPC, 7th. Fl. DEQE, 1 Winter St., Boston, MA 02108 Attn: Anne Bingham, OGC, 3rd Fl. DEQE, 1 Winter St., Boston, MA 02108 Attn: Caleb Hemphill, ORS, 10th Fl. Braintree Board of Health, 1 JFK Memorial Dr., Braintree, MA 02184 Quincy Board of Health, 1120 Hancock St., Quincy, MA 02169 Weymouth Board of Health, 75 Middle St., Weymouth, MA 02189 Foley, Hoag, & Elliot, One Post Office Sq., Boston, MA 02109 Attn: Laurie Burt Cities Service Oil and Gas Corp., 110 West 7th St., Box 300, Tulsa, OK 74102 Attn: Beji Malek Citgo Petroleum Corp., One Warren Pl., Box 3758, Tulsa, OK 74102 Attn: John Grabowski Clean Harbors, Inc., 325 Wood Road, Braintree, MA 02184 Attn: Alan McKim East Braintree Civic Assoc., c/o Donna Sullivan, 59 Hayward St., Braintree, MA 02184 Mayor Francis McCauley, 1305 Hancock St., Quincy, MA 02169 Representative Suzanne Bump, State House, Room 443, Boston, MA 02133 Senator Paul Harold, State House, Room 507, Boston, MA 02133 David Standley, 4 Spillers Lane, Ipswich, MA 01938 Brian McDonald, Board of Selectmen, 75 Middle St., Weymouth, MA 02189 Joseph Sullivan, Board of Selectmen, 1 JFK Memorial Dr., Braintree, MA 02184 Rep. Brian Donnelly, 438 Cannon House Office Bldg., Washington, DC 20515 Peter Koff, Weston & Patrick, 84 State St., Boston, MA 02109 Paul Anderson, DPW, 55 Sea St., Quincy, MA 02169 Joseph Flibotte, Flibotte's Auto Ser., 45 Columbia Ter., Braintree, MA 02184 OST PRAINTREE CIVIC ASSOCI ON 346-348 Washington St. s-175 Braintree, Ma. 02184

Karen Stromberg Feb. 19,1989 DEQE/Northeast Region Site Assessment 5 Commonwealth Ave Woburn Ma. 01801 Re: Fore River Shipyard Disposal Site

Dear Ms. Stromberg

After considerable discussion at the 1/26/89 public hearing and after review of both public documents, we would like to make the following comments for the record.

1. Our demand for full site remediation is still not met. Industrial cleanup has no written standards to which we could assure the level of cleanup.

2. Asbestos removal in buildings on site is not being removed.

3. Concerns over the Fore River as addressed in the NUS report and supported by us as to the effect on marine life and humans appear to be dismissed. We remind all parties this is a recreat= ional river for boating and swimming.

4. The southerly portion of the site with respect to levels of cyanides, toxic metals and other unidentified materials remains and infact is upgraded in level of urgency to be addressed since this now will be the site of the permanent facility is not' addressed to the degree we would like and does not carry the importance and significance given it by NUS. It is our opinion that until issues such as the above can be addressed to the satisfaction of the residents we will never be assured of even partial site remediation. We again remind all parties that this is now to be the permanent facility for MWRA's sludge facility. Activity on the southerly portion will be even more intense than anticipated.

East Braintree Civic Assoc. ( Petitioners Frank Toland, Chairman Donna O'Sullivan Treasurer 1615 Commercial Street E. Weymouth, Massachusetts February 4, 1989

Ms. Sharon Gerolamo Department of Environmental Quality Engineering 5 Commonwealth Avenue Woburn, Massachusetts 01801

Dear Ms. Gerolamo: I was unable to attend the open meeting at Braintree Town Hall recently held in connection with the clean-up of the Fore River Ship- yard. I did have a question I wanted to ask. My concern was with the effect of any bontamination on the shellfish found in Laundry Cove in North Weymouth. If you will look at the map of the area, you will see that there is a possibility that contaminants could be carried on tidal flows into the Weymouth Cove, which is on Fore River. Laundry Cove is an area with good shellfish beds which are regularly dug. I know that they are tested for coliform bacteria, but do not know if they are tested for anything else. I am chairman of the Weymouth Back River Committee, and have reason to check the river in the area of Webb State Park. Last week on my way into the park, I passed Laundry Cove and saw a large number of commercial diggers at work. I hope that these shellfish are in no way contaminated by the condition at the Fore River shipyard since Laundry Cove is part of the Fore River system. It might be wise to initiate a more thorough analysis of the shellfish here in light of the information of the shipyard contamination.

Sincerely,

Chairman, Back River Committee 7

1120 HANCOCK STREET I~~~ QUINCY, MASSACHUSETTS 02169 assg'jiII11III 773-1380 ~IIA u IlauS

M. JANE GALLAHUE, M.PH., C.H.O. Commissioner of Public Health aJohn iii JArnnedtj lieatth (fentrrT

DEPARTMENT OF HEALTH

February 15, 1989

Ms. Karen Stromberg c/o DEQE, Northeast Regional Office Site Assessment and Clean-up Section 5 Commonwealth Avenue Woburn, MA 01801

Dear Ms. Stromberg,

Attached please find appropriate comments as submitted by the Quincy Health Department for the draft plan entitled, "p rocedures Associated With Construction Related Activities at the Fore River Staging Area."

If you have any questions regarding these comments please feel free to contact our Sanitarian, Cynthia DeCristofaro at 773-1380 X 417.

Sincerely,

ry M. Jane Callahue,M.P.H. Commissioner of Public Health

MJG:mc

Encl.

CC: Christopher Barnett, Technical Manager, MWRA iiuuSet 1120 HANCOCK STREET QUINCY, MASSACHUSETTS 02169 773-1380

M JANE GALLAHUE, M.P.H., C.H.O. Commissioner of Public Health John ki Jftedtj Thaith QCpntr DEPARTMENT OF HEALTH

Comments on Draft Plan, "Procedures Associated with Construction Related Activities at the Fore River Staging Area"

Submitted by the Quincy Health Department

General Comment: The construction-related activities procedure for the Fore River staging area as submitted in draft form by the MWRA is totally lacking any degree of local notification, input or involvement. Although not required by any regulatory statute (as the property is state-owned and operated) it would appear to be in the best interest of the MWRA and the DEQE to consider some basic involvement of local officials at least in terms of notification. Often, when residents and/ or businesses have questions or concerns over an activity happening in their neighborhood they typically call local officials not State officials. If local officials are aware of an activity and/or have participated in its regulation or oversight then those local officials can then alleviate or reduce many concerns or at minimum serve as a laison with the proper state agency to address those concerns. There- fore, we recommend that the final draft procedures include notification of ail involvement by the local health department, building department, DPW, fire department and community leaders.

Specific Comments

Section 1 - 04 Enforcement of the Pro- cedures Pages 2 and 3 This section lacks mention of local involvement in terms of review of environment workplans and specification as well as in terms of notification (routine operations and maintenance activities and emergency repairs).

(Continued on Page Two) Page Two 0

Section 1 - 05 Non-MWRA Activities Pages 3 and 4 This section as well lacks local involvement in review of plans, and/or notification of routine or emergency repairs or activities undertaken by a leasee of the MWRA property.

Section 2 - 03 Preconstruction Activities Pages6 and 7 Mention is made of soil analysis according to following criteria: Hazardous Substance List of volatile and semi-volatile organic compounds, heavy metals, total and free cyanides, PCB's and pesticides, and petroleum hydrocarbons. How will these analysis paramaters be determined? Will it be based on "history of the site" in terms of contaminants known or suspected to exist in the area?

Table I and II How were the concentration values determined? No source or reference is identified in terms of these values. Please supply this source. "Previously approved" concentrations in Table II are used. These concentrations were approved by whom and on what basis?

Section 2 - 05 Soil Handling Procedures Page 8 - When Stockpiling Soils for greater than six months, DEQE is to be notified, Local officials should be notified as well.

Section 3 - 02 Activities Conducted Prior to Demolition - Page 9 Mention is made of sweeping and properly disposing dust containing fine metal particles and paint chips. We recommend that this "sweeping" be performed with a HEPA vacumm, and workers be protected as necessary, (ie, respirators, disposable coveralls etc.). Currently in Quincy, prior to the issuance of a demolition permit, a joint inspection must be conducted by the local Health and Building departments, and the Fire Depart- ment must be notified. Will there be

(Continued on Page Three) 4

Page Three

similar local involvement and notification during demoliton activities at the MWRA property?

Section 5 - 01 Introduction Page 12 More detail should be provided for the "qualified person familiar with the plan and excavation activities "who will monitor the HMMP plan's implementation, A definition of "qualified person" should be provided, as well as an indication as to how much time (approximate) will be devoted to this task.

Section 5 - 03.2 Volatile Organic Compounds Page 13 and 14 Concerns over this section exist. If significant concentrations of VOC's are found via air monitoring, it would seem that source indentification followed by remediation (if necessary) would be appropriate, rather than proceeding with construction activities.

Section 5 - 05 Contigency Procedures Pages 14 and 15 In this Section especially, notification of the presence of potentially hazardous material or hazardous conditions not contemplated by the plan must be made to local officials as well as DEQE.

Section 6 - 02 H&S Plan Page 16 Statement that "The MWRA will require all contractors whose workers will handle soil, or groundwater, or who will be involved in building demolition, if it is suspected that there will be worker contact with hazardous materials, to prepare a H&S plan, subject to review by the MWRA." Will these conditions be applicable to all leasees of the site, ie shipbuilders? And will the necessary clean-up activities required prior to occupancy by a leasee be covered by a similar H&S Plan? DAVID RANDLEY, RE. Consulant in Environmentai Magmnmt

February 14, 1989

Ms. Sharon Geralamo Mr. Chris Barnett Northeast Regional Office Technical Director Massachusetts Department of Massachusetts Water Quality Engineering Resources Authority 5 Commonwealth Avenue. Charlestown Navy Yard Woburn, MA 01801 100 First Avenue Boston, MA 02129

Re: Draft Procedures Associated with Construction Related Activities at the Fore River Staging Area

Dear Sir and Madam:

These comments relate to concerns of the City of Quincy with respect to the proposed draft "Procedures Associated with Construction Related Activities" at the Fore River Staging Area, as prepared for the Massachusetts Water Resources Authority by Haley and Aldrich, Inc., January 1989. These comments have been. discussed extensively with Ms..Geralamo, and certain questions were also responded to by Mr. Barnett. First, some general concerns of the City are addressed. o It is understood that DEQE.views these procedures as applicable to those portions of the FRSA bounded by the security fence, and that any problems known or subsequently determined with respect to the MWRA-owned areas in Quincy or Braintree not within the bounds of Hill AvenuE, Quincy Avenue, East Howard Street, South Street, Washington Street and the Fore River will be dealt with "de novo". Quincy supports this understanding. o Quincy is concerned that this document perpetuates the concept that future uses of the FRSA are restricted to commercial or industrial uses, and that this document would tend to further restrict that utilization to industrial purposes only. The Quincy position has been and continues to be that the on-site contamination should be remediated so as to neither restrict future development options nor to require special procedures during construction.

o The City understands that this document is intended to apply only to activities by the MWRA or any lessees thereof; and that a further document covering activities by future purchasers of part or all of this property is intended.

4 Spillers Lane, Ipewich, Massachuells 01 (506) 356--582 o Quincy also requests that roles and responsibilities of local officials which may be appropriate from a statutory, regulatory, or practical point of view be considered and clarified. It is noted that this may be different with respect to the Authority as contrasted to its lessees. It should also be made clear that this proposed document is specific to the FRSA; that it is in no way a generic document with wider application. In that context, the use of terms such as "urban fill" should be scrupulously avoided.

The following comments are organized by section and subsection of the draft document.

I. INTRODUCTION 1-01. PURPOSE AND SCOPE The statement "Although the levels of contaminants remaining under the site are no higher than the levels of contamination expected to be present on any industrial site,.. ." (emphasis added) is an unacceptable condemnation of industrial sites throughout the Commonwealth or elsewhere. It is an unacceptable and transparent effort to assuage.the legitimate concerns of the affected municipalities and citizens, and should be deleted from the document. The statement that "It is the intent of MWRA to comply with all regulations ... " is a gratuitous recognition (inappropriately stated) of the Authority's unconstrained responsibility to so comply, and should be revised.

1-04. ENFORCEMENT OF THE PROCEDURES "Major construction projects" and "routine operation and maintenance and emergency repairs" are critical terms in this document, and lead to major differences in the nature and extent of Authority responsibilities and DEQE response. They should, therefoie, be clearly defined.

It is understood that the twenty-one (21) calendar day period for DEQE response is only with respect to MWRA projects, and that DEQE will not be so constrained with respect to projects of any lessee. It is also understood that DEQE's legitimate and acceptable response within this time constraint may be that additional time is required, in which case no further action will be taken by the Authority pending further response. Both of these understandings should be clearly set forth in this document. With respect Fore River Railroad tract ballast, it is understood that DEQE intended to require notification of any contamination other than that which might reasonably resulted from normal leakage of petroleum products used by rolling stock on the railroad (i.e., fuel and lubricating oil contamination resulting from drips, not spills). This should be clarified.

In the final paragraph of this subsection, it should be clear that an additional review burden is placed on the MWRA and that this paragraph does not operate to limit the review responsibilities or authorities of DEQE.

1-05. NON-MWRA ACTIVITIES The first paragraph of this section should be amended to include "building construction/renovation". This provision, and in fact this entire procedure, should be clearly incorporated into any lease between the MWRA and the Massachusetts Land Bank prior to its execution.

To iterate, the role of local authorities with respect to MWRA lessees should be reexamined.

II. SOIL EXCAVATION, TREATMENT, AND DISPOSAL

2-01. INTRODUCTION

The limitation of the site "as an industrial site" should be deleted. The last paragraph of this section should be amended by changing the last sentence to read "One purpose of these procedures is to guide future development..."

2-02. DESIGN POLICIES

The third "bullet" should be expanded to include direct reference to known PCB-contaminated areas, the South Boundary area, and any other known areas of significant contamination to which this restriction should apply.

2-04. EXCAVATION

The intent of this plan should be to protect public health and safety. Allowing a contractor to "proceed with the construction of any facility with a minimum of delay" should clearly be secondary to that primary objective.

2-05. SOIL HANDLING PROCEDURES

DEQE is urged, both in this instance and as a general matter, to be much more specific about the characteristics of materials used * 0 to underlie or cover stockpiles of soil. The use of flimsy sheets of polyethylene, subject to ultraviolet and other. environmental degredation, is inappropriate, occurs frequently, and should be terminated by the development of appropriate guidance. The use of the term "urban fill" should be avoided. It is suggested that the on-site soils be categorized as Categories I through IV.

FIGURE 1 - DETERMINATION OF USE AND STORAGE OF EXCAVATED SOILS The term "previously approved concentrations", also appearing in this table as "prev. concs.", is understood to mean those concentrations approved for retention on-site pursuant to the DEQE letter of September 20, 1987. This should be clarified. Prior to the acceptance of those concentrations listed in Table 2, reviewers should be provided with a comprehensive list of the approval documents and provided an opportunity to review and comment thereon.

FIGURE 2 - EXCAVATED SOIL USE AND STORAGE DECISION FLOWCHART There is concern with the application, in this Figure and Figure 1, of the term "re-evaluate". This process as presented can be interpreted to leaving open the possibility of the retention on- site of extensive, highly-contaminated soils. Although it is understood this is not the intention of the decision flow chart, clarification is essential, (even though this is an unlikely occurrence).

TABLE 1 - CRITERIA FOR SOIL DISPOSAL MWRA FORE RIVER STAGING AREA It is understood that these numbers are still under review by the DEQE Office of Research and Standards. Therefore, comment is withheld until that office has completed its review and its recommendations, and the reasons therefore are available for further review and comment. However, the categorization as "urban fill" should be replaced by "Category 1 Soils". It should also be clear that the detection limit referred to is that of an EPA-approved method. This particular comment also applies to Table 2.

III. BUILDING DEMOLITION

3-01. SUMMARY OF AVAILABLE INFORMATION

It should be clear that asbestos removal will be in full conformance with DEQE regulations and all applicable requirements of the Massachusetts Department of Labor and Industries and the Federal Occupational Safety and Health Administration. 0 0

3-02. ACTIVITIES CONDUCTED PRIOR TO DEMOLITION This is another provision in which the appropriate role of local authorities should be established and identified. There is concern with leaving to the MWRA and its demolition contractor the determination that demolition spoils require special handling and therefore further definition of the extent and level of contamination. It seems appropriate that there be a State or local role in this decision process and it should be so identified.

3-04. DEBRIS DISPOSAL The role of the state building inspector in this process should be established as to whether it is a matter of law, regulaLion, or custom; and the role of local authorities pursuant to Sections 150-A or 150-B of Chapter 111, MGL, should be recognized.

IV. CONSTRUCTION DEWATERING

4-01. INTRODUCTION

There should be a provision in this section for resolution of an. conflicts between these procedures and the State Building Code.

4-03. WATER TREATMENT

An NPDES permit will granted the MWRA for the FRSA.

The method of determination of a requirement for interim measures should be spelled out. Since modification of an NPDES permit is a rather cumbersome procedure, every effort should be made to incoroorate limits for all recognized potential contaminants in the initial NPDES. It should be specified that the disposal of activated carbon or sludges resulting from a treatment process should be as hazardous waste in conformance with 310 CMR 30.00.

V. HAZARDOUS MATERIAL MANAGEMENT PLAN 5-02. AIR QUALITY MONITORING The application of the OSHA standard for general nuisance-type dust to this situation is seriously questioned. In addition to the concern about the adequacy of worker protection, the visibility and off-site implications of such a release rate also require further evaluation. As a general procedure, when environmental concentrations of a contaminant are found to be in excess of standards or guidelines, the first step should be to stop work. If, after assessment, it is determined that the work is not the source of the problem then it should be allowed to resume. The management approach set forth in this section should be equally applicable to all contaminants, and not limited to VOCs.

5-03. CONTAMINANT MIGRATION CONTROL The same comments as presented immediately above apply to this section as well. This concludes the comments of the City of Quincy on this proposed construction procedures at this time. As indicated, it is anticipated that a further opportunity will be provided to comment on aspects of these procedures either as revised or as further documented. Respectfully,

David Standley, P.E. Consultant to the Ci y of Quincy cc: Commissioner Anderson J. A. MacRitchie, Esq. David Smith Councilor DeCristofaro Commissioner Gallahue Peter Koff, Esq. Donna O'Sullivan

9 1120 HANCOCK STREET QUINCY, MASSACHUSETTS 02169 iupneml it 773-1380

M.JANE GALLAHUE, M.P.H.. C.HO. Commissioner of Public Health JoAn kh Jrnnedtj Ifraith G:,ntr

DEPARTMENT OF HEALTH

February 13, 1989

Ms. Karen Stromberg c/o DEQE, Northeast Regional Office Site Assessment and Clean-up Section 5 Commonwealth Avenue Woburn, MA 01801

Dear Ms. Stromberg,

Attached please find appropriate comments as su bmitted by the Quincy Health Department for the draft Public Involvement Plan - Disposal Site: Fore River Shipyard (Formerly General Dynamics) 97 East Howard Street, Quincy MA.

If you have any questions regarding these comments please feel free to contact our Sanitarian, Cynthia DeCristofaro at 773-1380 X 417.

Sincerely,

M. Jane Gallahue,M.P.H. Commissioner of Public Health

MJG:mc

Encl. 0 1120 HANCOCK STREET QUINCY, MASSACHUSETTS 02169 2rri!t'___ 773-1380 M. JANE GALLAHUE, M.P.H., C.H.O Commissioner of Public Health John Iii Rrnnedij IRpaith (Cntpr DEPARTMENT OF HEALTH

Comments on: Draft Public Involvement Plan Disposal Site: Fore River Shipyard (Formerly General Dynamics) 97 East Howard Street Quincy, MA

Submitted by Quincy Health Department

Page 5, Asbestos - No mention of asbestos on interior of existing buildings. Financial responsibility for removal appears to fall on MWRA rate-payers, not General Dynamics. Also, plan should consider local notification (ie Quincy Health Department) in regards to removal procedures.

Page 5, Risk Assessment - Our concern is that risk assessment focuses on ground water contamination only. ALL potential migration pathways and exposure points should be considered in detail.

Page 11 Notification - Quincy Health Department, Fire Department and Building Department should be notified prior to any building demolition,and joint inspect- tions be conducted as necessary.

Page II Opportunities - We would prefer the same meeting date as the for Public In- MWRA Fore River Advisory Task Force meeting; volvement PIP meeting should be held immediately after MWRA meeting is adjourned.

Exhibit I Community Con- - These concerns must be addressed jointly by cerns about the DEQE, MWRA and General Dynamics. In addition, Fore River Shipy- a clear delineation of the responsibility of yard Disposal Site any regulatory agencies involved in the site cleanup must be established. Such a plan must include all assessment areas covered in the NUS report - both exterior and interior; and all contaminants as so reported. The NUS Re- port recommendations should be implemented and/ or overseen by the appropriate regulatory agency. I I -IV

Donna O'Sullivan 59 Hayward St. E. Braintree, Mass. 02184 Feb. 9, 1989

Karen Stromberg. Public Involvement Co-ordinator DEQE Northeast Regional Office Site Assessment and Cleanup Section 5 Commonwealth Ave. sioburn, Mass. 01801

Dear Ms. Stromberg,

Enclosed please find my hopefully brief comments on the Public Involvement Plan - Fore River Shipyard; and the '"Procedures Associ- ted Jith Constructidd-Related ActivitieU-Atthe.Fote River Staging Area"

P. 3 "....decisions about the adequacy of remedial actions at the shipyard have been based on the understanding that the property will continue to be used for industrial uses in the future" and further, dan agreement betwe'en the DEQE and MdRA which will limit the use of the site to ensure that future usess will not pose a threat to public health or the envirnnment" Following an agreement with the city of Quincy, by contract, a tri-town committee was established, through which potential future uses of the Yard were to be examined. .'his prior limitation and assumption by M.JRA and DEQE appears to be in violation of that contractual agreement. 'he general principal of leaving restrictions on the land, places the 1expense and responsibility of future cleanup back on the tax payers, not on General Dynamics, where the responsibility should lie. P.4 RE: Surficial oil contamination 'his report indicates removal of large quantities of contaminated soil during May and June of 1988, after submission of the petition for public involvement. One of the primary concerns which was not addressed at the time of soil and contamination removal in 1988, and is not addresses in this plan, is the timing of load removal, to avoil transportation while children were in transit to and from school.

P. 5 Asbestos is examined onl'y in exterior locations, when clearly demolition of asbestos containing building3 is planned. Why are such limitations in place for this analysis, which should be for the overall state of the property, not the contingency of the sale of the land.

P. 5 GZA Risk assessment - Focus was on the risks associated with ingestion of . seafood, potentiallt contaminated by groundwater. 'his site currently is transporting volumes of materials via rail system off site, to areas that are not protected or fenced in at all in East Braintree. Development plans call for at least 4X increasing the capacity of materials leaving the site via rail; plus transportation of demolition materials by rail and truck off site. In addition, workers will be bringing potentially contaminated clothing and shoes home with them during demolition and construction, should Ihese risk factors also be addressed? I 1

P.2 P. 8 - "many decisions regarding the,adequacy of assessment and some remedial respose actions have been made..." Many of these decisions are recent, and certainly fall within the time frame of application of the Public Involvement Petetion in May 1988 and presentation of data in late January of 1989. Why was the public input not requested for, or respected?

Document 12, Haley & Aldrich File #07779-50 Jan. 1989 Section 2-05 Soil Handling Procedures Several classification of soil and methods of handling are discussed, however, generally, if urban or Cat. I and II soils are stockpiled and reused, what is the possibility of cross contamination, or increasing levels of contamination by moving materials from one site to another? Secondarily, are adecuate measures taken:to- nsure that surface water runoff during soil excavation and redistribution will not leach inadequate levels of contamination into the Fore River and into the MdRA drainage system? Section 3-04 Debris Disposal How will the materials be transported, when and what type of notification will be given to transit communities? Sectionst4-01-04 Rain and groundwater treated and pumped into the Fore River may well be of considerable magnitude, based on the proposed construction projects by the "ARA. Will there be ongoing environmental assessments made of the water quality of the river, the surrdhding ocean basin, and the seafood inhabiting that environ?

hank you for allowing me to present these comments.

Sincerely,

Donna O'Sullivan Ms. Sharon Gerolamo Page two February 8, 1989

We will keep you informed of our future progress in these areas.

Sincerely yoursD

iEdward J. illwerth Consultant to General Dynamics

XC: R. White - GD/QSD L. Burt - FH&E L. Feldman - GZA W. Gary Wilson - MWRA F. J. Basile - GD/CO C. R. Stoker - GD/CO D. A. McCallum - GD/CO 0 0 GENERAL DYNAMICS Quincy ShipbuildingDivision 116 East Howard Street, Quincy, Massachusetts 02169

February 8, 1989

Ms. Sharon Gerolamo Assistant Sanitary Engineer Department of Environmental Quality Engineering 5 Commonwealth Avenue Woburn, MA 01801

Dear Sharon, Pursuant to our discussion on Friday, February 3, 1989, this letter serves to document the issues discussed and decided at that time.

General Dynamics has received the Petrex soil gas studies from Northeast Research Institute, Inc. (NERI) for both areas of the shipyard recently studied. The intention to use this non- disruptive technique to gather information was discussed with your office on November 18, 1988. We have decided to submit these studies to DEQE as part of separate reports.

The first report will focus on the Bent's Creek/Well GD-1154 area of the Shipyard. The report will include the results of the scope-of-work approved by DEQE in August of 1988, as well as the soil gas study and the findings associated with borings and wells to be installed as guided by data from the soil gas study. We intend that the study will be conducted by Goldberg-Zoino & Associates (GZA) in close cooperation with Groundwater Technology (GTI). Our tentative schedule to have this report completed is early spring.

The second report will concern a hydrogeological study of the Building 55 and 57 area, near Well GD-3141. The report will summarize hydrogeological work done in the area by GZA involving borings, wells, several past and recent rounds of groundwater sampling, and the NERI Petrex soil gas study conducted in this area. We hope to have this report ready for DEQE sometime in the spring.

In both of these studies the work has been essentially for consideration of field adjustments for existing recovery/ remediation systems or to clarify data collected in studies dating back to 1986. GENERAL DYNAMI 3 Quincy Shipbuilding Division 116 East Howard Street, Quincy, Massachusetts 02169

January 27, 1989

NOTICE OF DOCUMENT AVAILABILITY

Site: Fore River Shipyard 97 East Howard Street Quincy, MA 02169

Documents: Feasibility Study, Subsurface Soil/Oil Plume Area Quincy Shipbuilding Facility, Quincy, MA April 1988 (Goldberg-Zoino & Associates)

Evaluation of Petroleum-Related Contamination in Area 5/Section E, Quincy Shipyarq, Quincy, MA November 1988 (Goldberg-Zoino & Associates)

As announced by DEQE at the public meeting on January 26, 1989 concerning the Fore River Shipyard disposal site, these documents are available for public review and comment. Copies may be reviewed at the following locations:

o Watson Park Public Library, 318 Quincy Avenue, Braintree

o Thomas Crane Public Library, 40 Washington Street, Quincy

o Tufts Public Library, 46 Broad Street, Weymouth

o DEQE Northeast Regional Office, 5 Commonwealth Avenue, Woburn (Please call Renee Mason at 617/935-2160 to make an appointment to review the documents).

Please send comments to:

Karen Stromberg, Public Involvement Coordinator DEQE Northeast Regional Office 5 Commonwealth Avenue Woburn, MA 01801

Comments must be received by February 16, 1989. For more information, please call Karen Stromberg of DEQE at (617) 935-2160. MASSACHUSETTS WATER RESOURCES AUTHORITY Charlestown Navy Yard 100 First Avenue Boston, Massachusetts 02129 Telephone: (617) 242-6000

Board of Directors John P DeVillars, Chairman Paul N. Anderson January 27, 1989 John J. Carroll Robert J. Ciolek Lorraine M. Downey Anthony V.Fletcher Charles Lyons NOTICE OF DOCUMENT AVAILABILITY Samuel G. Mygatt Margaret A. Riley Walter J. Ryan, Jr. Jonathan Z.Souweine Executive Director Site: Fore River Shipyard Paul F.Lev 97 East Howard Street Quincy, MA

Document: Procedures associated with the c6nstruction and related activities at Fore River Staging Area, January 1989 (Haley & Aldrich)

This document is available for public review and comment. -Copies may be reviewed at the following locations: Thomas Crane Library, 40 Washington Street, Quincy

Tufts Library 46 Broad Street, Weymouth

Watson Park Library, 398 Quincy Avenue, Braintree DEQE Northeast Regional Office, 5 Commonwealth Avenue, Woburn (Please call Renee Mason at (617) 935-2160 to make an appointment to revview the document.)

Please send comments to:

Karen Stromberg, Public Involvement Coordinator DEQE Northeast Regional Office Site Assessment and Cleanup Section 5 Commonwealth Avenue Woburn, MA 01801

Comments must be received by February 20, 1989. For more information, please call Karen Stromberg at (617) 935- 2160. x ,'g on7toea /

Daniel S.Greenbaum &$m 1$ksac&as OAfOf Comm issioner

*NOTICE OF MEETING*

The Department of Environmental Quality Engineering (DEQE) will hold a public meeting to present the draft Public Involvement Plan for the Fore River Shipyard (formerly General Dynamics) disposal site located at 97 East Howard Street in Quincy. An update on the status of the cleanup actions at the site will also be provided. Residents will have an opportunity to ask questions and provide corrents.

Date: Thursday, January 26, 1989

Time: 7:00 p.m.

Place: Braintree Town Hall Auditorium 1 JFK Memorial Drive Braintree

Copies of the draft Public Involvement Plan will be available at the meeting. If you have any questions, please contact Karen Stromberg at (617) 935-2160 or the above letterhead address.

Please share this notice with anyone you know who may be interested in attending this meeting. We look forward to seeing you on the 26th.

100 % Recycled Paper MASSACOSETTS WATER RESOURCEStTHORITY Charlestown Navy Yard 100 First Avenue Boston, Massachusetts 02129 Telephone: (617) 242-6000

Board of Directors John P.DeVillars Chairman Paul N.Anderson January 24, 1989 John J.Carroll Robet J.Ciolek Lorraine M.Downey Anthony V.Fletcher Charles Lyons Samuel G.Mygatt Margaret A.Riley Waller J.Ryan, Jr. Jonathan 2.Souweine F~ecuive Director Paul FLevy

Mr. Richard Chalpin, P.E. Deputy Regional Engineer Department of Environmental Quality Engineering Metropolitan Boston - Northeast Region 5 Commonwealth Avenue Woburn, Massachusetts 01801

Re: Subsurface Soil, Area 5, Section E - Fore River Staging Area (FRSA) - interim remedial response recommendation by General Dynamics Corp.

Dear Mr. Chalpin:

By letter of November 23, 1988, General Dynamics submitted to DEQE a report entitled "Evaluation of Petroleum-Related Contamination in Area 5/Section E." The report presents the results of site assessment work performed by General Dynamics and summarizes several alternative remedial response measures for potential use at the referenced site. The report further suggests other potential sources of the contamination found at the site (principally the Flibotte salvage operations on adjacent property) and recommends capping the site as an interim measure, pending further investigation of offsite pollution sources. The Authority has reservations about the plan for capping, but understands that the issue is moot because it is not feasible to cap the site at this time. As to the matter of cleanup, given the importance of the site and the public's understandable concern with the remediation effort, it would appear most beneficial to all concerned to come A

to agreement on a remedial alternative and conclude the remediation as quickly as possible. In the interim, in order to prevent new contamination, the Authority is taking action to install a security fence around the entire site.

Very truly yours,

Catherine L. Farrell General Counsel

cc: Ms. Laurie Burt, Esq., Foley, Hoag & Eliot Ms. Sharon Gerolamo, DEQE, Northeast Region Mr. Paul Levy, Executive Director, MWRA

020g GENERAL DYNAMIC Guincy Shipbuilding Division I16 East Howard Street, Quincy, Massachusetts 02169

January 11, 1989

Ms. Karen Stromberg Department of Environmental Quality Engineering 5 Commonwealth Avenue Woburn, MA 01801

Subject: Delivery of Copies of Environmental Reports and Letters to Public Libraries Dear Ms. Stromberg: Per your request in our telephone conversation of January 9, 1989, all copies of environmental reports and letters to and from General Dynamics and DEQE were delivered to the Public Libraries in Quincy, Braintree and Weymouth on January 10, 1989. Extra copies of the Reference Appendices by Date and by Subject were delivered and thoroughly explained to the receiving librarian.

Should theu have. ny uweebena bhuy have my name a phens number and I wilbe pleased to assist them. Sincerely,

1(obert '.White Manager of Operations

cc: File E. J. Willwerth, GD/Consultant GENERAL DYNAMICS 4 9 Quincy Shipbuilding Division 116 East Howard Street. Quincy, Massachusetts 02169

January 4, 1989

Mr. Richard J. Chalpin Deputy Regional Engineer Department of Environmental Quality Engineering 5 Commonwealth Avenue Woburn, MA 01801 Re: Quincy Shipyard Petroleum Contaminated Surface Soil Removal Program, DEQE Case # 3-0536

Dear Mr. Chalpin,

On behalf of General Dynamics I wish to thank you for your letter dated December 7, 1988, concerning final approval of the remediation program to remove petroleum contaminated surface soil from the former General Dynamics/Quincy Shipyard. The GZA Reports and correspondence concerning this work were submitted to your office in July and November of this year.

In response to your statement concerning additional soil stockpiles at the site, included on page 2 of your December 7, 1988 letter. Please be advised that the soil generated by work in the area of Well GD-3145C and test pitting near the main plume area has been removed to a licensed disposal facility. Copies of the Uniform Hazardous Waste Manifests documenting this soil removal are enclosed for your convenience. With the completion of the remaining action item, General Dynamics has now complied with all DEQE's requests on this particular portion of our environmental work, with the exception of Area 5, Section E and Area B near Building 53 which, as noted in your letter, will be addressed in separate letters from DEQE. Please send us an updated approval letter acknowledging this fact at your earliest convenience.

Thank you for your continued assistance in this matter. General Dynamics appreciates your response to its environmental work at the Shipyard, and we eagerly await your review of the other reports we have submitted to the Department.

Sincerely yours,

Robert F. White Manager of Operations Mr. Richard J. Chalpin Page Two January 4, 1989

cc: E. J. Willwerth - GD/Consultant C. R. Stoker - GD/CO F. J. Basile - GD/CO L. Feldman - GZA C. McDermott - GZA

DEQE, 1 Winter St., Boston, MA 02108 Attn: Site Assessment Section Chief, DHW, 5th Floor Attn: Steve Lipman, DWPC, 3rd Floor Attn: Anne Bingham, OGC, 4th Floor Attn: Caleb Hemphill, ORS, 10th Floor Braintree Board of Health, Town Hall, Braintree, MA 02184 Quincy Board of Health, 1120 Hancock St., Quincy, MA 02169 Weymouth Board of Health, 402 Essex St., Weymouth, MA 02188 Foley, Hoag & Eliot, One Post Office Square, Boston, MA 02109 Attn: Laurie Burt, Esq. MWRA, Charlestown Navy Yard, 100 First Ave., Boston, MA 02129 Attn: Gary Wilson, Esq. Cities Service Oil and Gas Corp., 110 West 7th St., Box 300, Tulsa, OK 74102 Attn: Beji Malek Citgo Petroleum Corp., one Warren Place, Box 3758, Tulsa, OK 74102 Attn: John Grabowski Clean Harbors, Inc., 325 Wood Rd., Braintree, MA 02184 Attn: Alan McKim East Braintree Civic Association, c/o Donna Sullivan, 59 Hayward St., Braintree, MA 02184 Mayor Francis McCauley, 1305 Hancock St., Quincy, MA 02169 Representative Suzanne Bump, State House, Room 443, Boston, MA 02133 Senator Paul Harold, State House, Room 507, Boston, MA 02133 David Standley, 4 Spillers Lane, Ipswich, MA 01938 Brian McDonald, Board of Selectmen, 23 Prospect Hill Dr., Weymouth, MA 02191 Joe Sullivan, Board of Selectmen, 1 JFK Memorial Dr., Braintree, MA 02184 Representative Brian Donnelly, 438 Cannon Office Building, Washington, DC 20515 Peter Koff, Weston & Patrick, 84 State St., Boston, MA 02109 -a' a- DEPARTMENT OF ENVIRONMENTAL PRXECTION -flu Iazardous Waste MANIFEST SECTION, State House, Station 17, Augusta, ME 04333 Please print or type. (Form designed for use on elite (12-piltch) typewriter) Form Approved. OMB No. 2050-U039 Expires 930 i UNIFORM HAZARDOUS I Generators US EPA IDNo Manifest 2. Page I information in the shaded areas a not 0 WASTE MANIFEST gy of0Louil Stut. La. btm 3. Generators Name and Mailing Address GeneAstate Ma a m umber Z

116 East iHowawrd tret ME A o0 q ocy, Ma. 0217U Ggtr 1 Sameat n: 4. Generator's Phone 1 6 17 )bU Some 0 5. Transporter I Company Name 6. US EPA ID Number C.State fil 0-. Jet-Line 3ervicee Lrc-. V A po 6 2 11 1 71 91 1 91 C uana.oril eV ,,A')9 420 io 7 Transporter 2 Company Name 8 US EPA ID Number -Etii flngparteindID' fill I I Fm pla mmn. c)-1 II I IIII I i In 9. Designated Facility Name and Site Address 10. US EPA ID Number G4tata FA A N2H -.... Consolidated Waste Services, Inc. 0 Rt 2 Airport Rd. H.F ncri idgewock, Maine 04957 P. 0 002 7|7 9|1 H.Facty1211719 12. Containers 13. 14. 11 US DOT Description (Including Proper Shipping Name Hazard Class, and ID Number) Total Unit I. Na Tp Q WtIVt Waste Na a. (.1 Coztainated Earth (MA. REG.) I 't O 0 3 D1 T0 -- E b. N E

______I _ _ 0 J. Additional Descriptions for Materials Listed Above K.HarnIng es for Wastes Listed Above oil cent, dirt a b. a. b

c d C. d.

15. Special Handling Instructions and Additional Information (0 to

0) :ict Hiazardout. in lliairie 03 16. GENERATOR'S CERTIFICATION: I hereby declare that the continis of this consignment are fully and accurately described above by proper shipping 0 name and are classified, packed, marked. and labeled arid are ir al respects in proper inilition for transport by highway according to Applicable 0) international and national government regulations. '-Jo to reduce the volume and toxicity of waste generated to the degree I have C 'U fI am a large quantity generator I certify that I have a program in place C determined to be economically practicable and that I have selected the practicable method of treatment, storage, or disposal currently available to a me which minimizes the present and future threat to human healt and th nvironment. OR, if Iam a small quantity generator. Ihave made a good N 02 faith effort to minimize m waste generation and select the best wae man ement method that Is available to me and that I can afford r-~ dirypedName Mgnn -'Uro c C - 1 ote erd f Rceit of Maei Date 0 _ Acknow T 17. Transporter I Acknowledgemen I Receipt of Materials Date r 0)

C) C) cc - Sign Month Day Year C C A PrintedTyped Name o o 1 (3 C) A = 0) 19Discrepancy Indication Space 'a a to "V

-cc

EPA Form 8700 22 (Rev. 9-86) Previous editions are obsolete '/ .5 *STAE OF MAINE S DEPARTMENT OF ENVIRONMENTAL PROTECTION IHazardous WasteiMANFESr SECTON, State House, Station 17, Augusta, ME 04333

Please print or type. (Form designed for use on elite (12.pitch) typewriter.) Form Approved. OMB No. 2050-0039. Expires 9-30- l

in the shaded iras is not 1. Generators US EPA ID No Manifest 2. Page 1 iotmation UNIFORM HAZARDOUS Document No. required by Federal law but may be WASTE MANIFEST 1fI j 2Aihb I0'1/1 "' ' 'quiredby state L. 0 A.State Man e t umber 3. Generator's Name and Mailing Address rn General Dynamics ME A ,T -4 B.StateGeneratorsjD 116 EaSG fowawvd Street - 4. Generators Phone (4aCy, Ma. 02170 6.. saw 5. Transporter 1 Company Nanm 6. US EPA ID Number i C.State TransportetA.ID 0 :V FlansporterlsPhonte 9. Designated Facility Name and Site Address 10. US EPA W0Number G.State Factilitya 1D 0 Consolidated Wniste services, Inc.- -v Rtt 2 Airport Rd. H.Facilty'sPhone ,1 - l1 A I D [I I Ifnl I 1e 71 l 2111777 Als1A tl - 12.Contalners 13. 14.- 11. US DOT Description (including Proper Shipping Name. Hazard Class. and ID Number) Total Unit Na Type Quantity Wi/Vol Waste No a 011 Contamlnateo Earth (MA. REG.) _t.. Add d tIt -'-1iTA-7,Y-111A-71 E b. N E A

T 0

-o J. Additional Descriptions for Materials Listed Above K.Hardig Codes for Wastes: Listed Above

a. oil cont. dirt b b.

c. d c d.

15 Special Handling Instructions and Additional Information

C) flot Haza idousin Mare 16, GENERATOR'S CERTIFICATION: I herety drclare that the contents of this consignment are fully and accurately described above by proper shipping Scm name and are classrfied. packed. mark'd. and labeled and ae in all respects in proper condition for transport by highway according to applicable international and national government regulations If I am a large quantity generator. I certify that I have a program in place to reduce the volume and toxicity of waste generated to the degree I have no determined to be economicaly practicable and that I have selected the practicable method of treatment. storage. or disposal currently available to me which minimies the present and feture threat to human health and the environment OR, if I am a small quantity generator, I have made a good faith effort to minimize my waste generation and select the best waste2!lgement method that is available to me and that I can afford -C, dpdaMonth Day Year

4,- PT 17 ansporter 1 Acknowledgement of Receipt of Materials Date nt ped a Sign a Mo - 4

=i 18. Transporter 2 Acknowledgement or Receipt of Materials Date T Printed/Typed Name gnature Month Day Year

19. Discrepancy Indication Space A I' F C 20. F 11ily OwnerOe Cer 'cation of rcept of hazar ous materials covered by this manifest excep s noted in Item 19 Y fia ,..D t Sg ure npilh ea C0 /P)ledrTypedpe r e// ErN) C-0 EPA Form 8700 22 (Rev 9 -6) P 'v-oums editions are obsolete. DEPARTMENT OF ENVIRONMENTAL PROTECTION a Hazardous Waste MANIFEST SECTION, Stale House, Station 17, Augusta, ME [4333 "

Please print or type. (Form designed for use on elite (12-pitch) typewriter.) Form Approved. OMB No. 2050.0039. Expires 9 io-r Manifest 2 Pa e normation In the aed area Is no UNIFORM HAZARDOUS 1 Generators US EPA IDNo 'equired byFederal law but may be WASTE MANIFEST P1 P Yf/ed Of oqu by State Law 3 Generator's Name and Mailing Address A.State Ma e umber General Dynamics ME A 116 East Howawi B.StateGeneratoreID 4. Generators Phone ( 617 786 168A , Ma. 02170 s Transporter 1 Company Name 6. US EPA ID Number CState Transpio tntsAD n Jet-Line Services, Inc. IMIAI Di I 2 LM1'19 D 9 99 t 2r.,13i*510 7 Transporter 2 Company Name 8. US EPA ID Number EStite llerditEflNLY ier I1I1 III I jjIj a. FlraorPheo.e v 9. Designated Facility Name and Site Address 10. US EPA ID Number G.StataEilliwt ID, consolidaLed Waste bervices, Inc. 1E 2 A 2PCrt Rd. H. FactiityPhon Ncrridgewock, Maine 04957 IMi Al Pi 01 01 01 0 7 91 3 107 6 2714 12. Cont:aIners 13. 14. 11 US DOT Description (including Proper Shipping Name, Hazard Class, and ID Numbl Total Unit - |. No. Type Quantity WtNo Waste No. C Oil Con-aaminated Earth (1A. BEG.) G~~~~ 0 1jQ 7 T A A 0 1 E b N E

T c 0 R d.

J. Additional Descriptions for Materials Listed Above K HandlIng eos for Wastes Listed Above

oil cont. dirt b. LIN b.

C d C. d.

15 Special Handling Instructions and Additional Information

Not l azt ou in Kaine 6 GENERATOR'S CERTIFICATION: I hereby declare that the contents of this consignment are fully and accurately described above by proper shipping name and are classified, packed. marked, and labeled, and are in all respects in proper condition for transport by highway according to applicable international and national government regulations. IfI am a large quantity generator, I certify that I have a program In place to reduce the volume and toxicity of waste generated to the degree I have determined to be economically practicable and that I have selected the practicable method of treatment, storage, or disposal currently avaiablee - me which minmizes the present and future threat to human health and the environment: OR. if I am a small quantity generator, I have made a gone( falefcr t mnmize my waste geneaton and select the bpes wj! genn metho thtiviable to me and tat I can affr

T 17 Transporte ckn dgement of ReceIpt of Materials Date A tedled S a e Month Day Year

1 ra sporte T2c r owledgeme I Receipt of Materials 'D T Printed/Typed Name Signature Month Day Year

9 Discrepancy Indication Space

F C 7

as noted in Item 1 20 Fity Owner or ,peraor C rti cdl on of recelpt f hazardous materials covered by this manifest exiept

M Day rted/Typed Nam9 S ature / Mpn/h Yea,

ElI F 8 i R 9i edition areobsolete. FPA. Forr d7 flO2.1 'Pv 9 86) Previous editions are obsolete - *EiPiANF iOF MAINAL * DEPARTMENT OF ENVIRONMENTAL PROTECTION Hazardous Waste MANIFEST SECTION, State House, Station 17, Augusta, ME 04333 I.,

Please print or type. (Form designed for use on elite (12-pitchi typewriter.) ,4 Form Approved. 0MB No. 2050-0039 Expires 9-30 88h

io laes Is iot UNIFORM H AZARDOUS 1 Generators US EPA ID No p 2. Page I kiorrnuo nedrd WASTE MANIFEST Orinl317 d/ i6I *foL / equired by 5.e1. Law 3. Generator's Name and Mailing Address A.State Ma et c m illi umber General Dynamics ME A f T'V 1.16 Ea Howawrd Street 8.State Generators ID 4. Generator's Phone 7 ) 'A ARCY, 1a. 02170 6 5. Transporter I Company Name 6. US EPA ID Number C.State Tansporte ID Trit -T i nue, qpi-v i esrit ?n AMI n i l 7 10I 7| d A d i D.Transgoier's lo'p 2 i 7 Transporter 2 Company Name 8. US EPA ID Number E.91stt 1nsporlet 10 |1 | [1 1 1 Flrmati Phton 9. Designated Facility Name and Site Address 10. US EPA ID Number GState Flaoty'. 10, -,

Consolidated Waste Services, Inc. Rt 2 Airport, Rd. H.FacilitytPhone - nl ID 7 i Mu lrmXr 5PtQriru1 Mj n, nLioloa l" I I " inl N 11. US DOT Description (Including Proper Shipping Name Hazard Clas and ID Number Total Unitl No. Type Quantity WtVol Waste No.

Oil Contaminated Earth (MA. REG.)

E b N

TA 0

C-u d.

-o Above K.Haritlng Codes4fr Waste Listed Above C J. Additional Descriptions for Materials Listed a Oil cont. dirt a L b

~n C; cc c d c d.

.0 15. Special Handling Instructions and Additional information C-,

0) d) - hot lHazardoius in i4ainc - r3 C 16 GENERATOR'S CERTIFICATION: I hereby declare that the contents of this consignment are fully and accurately described above by proper shipping 0 name and are classified packed marked and labeled and are in all respects in proper condition for tralsport by hihway according to applicable 4) = international and national government regulalions 0' C in place to reduce the volume and toxicity 01waste generated to the degree I have C C f Iam a large quantity generator. I certify that I have a program 0 determined to be economically practicable and that I have selected the practicable method of treatmen1. storage or disposal currently available to C- me which minimizes the present and future threat to human health and the environment OR, if I am a small quantity generator, I have made a good r.J afford 0)~ faith effort to minimize my waste generation and select the best waste anagement method that is available to me and that I can ted/Typed Name )I Month Day Year Cu = C * ( C _ c Rer frft T 17 Transporter 1 Acknowledgement of Receipt of Materials Date - C R z a: n / pt eMonth Day , Year C, La P -. I1/ 1 Date o a 0 18. Transporter 2 Acknowledgement or Receipt of Materials * C TR Printed/Typed Name Signature Month Day Year C C o 0 o 0 = 4) 19. Discrepancy indication Space a .2 K '4 'V

C C t is covered by ths manifest except as noted in item IS

0) = 4 K- Date 0.i 0- C fure Mnh ay Ye .

/ I i ri /11 \l EPA Form 8700-22 (Rev 9 86) Previous editions are obsolete. I)EPARTMENT OF ENVIRONMENTAL PROTECTION * Hazardous Waste MANIFEST SEC'flON, State House, Station 17, Augusta, ME 04333

Please print or type. (Form designed for use on elite (12-pitchi typewriter.) Form Approved. OMB No. 2050-0039. Expires 9 3( Hi'

US EPA IDNo Manifest 2 Pag 1 Inormalion in Ihe saieda amas s UNIFORM HAZARDOUS 1 Generator's Docmen ii requireol by Federal Iaw but may c, WASTE MANIFEST IA |a|* of required by State* 3. Generators Name and Mailing Address AState Ma t umber Ueneral Dynamics ME A i10 E it ]lowaWrd Stlret BState Generators ID 4. Generator's Phone( 7 )7 C M8. 02170 SaneB3 5. Transporter 1 Company Name 6. US EPA ID Number CState Transporters ID

T~df-T jj. in rN1 1 Al r RiZranosfpoftq Phone 3T4 7 Transporter 2 Company Name . US W6 ID uber9 Es.tate flestsporsl* A 5 Fl'ansporterls Phone 9. Designated Facility Name and Site Address 10. US EPA ID Number G.State Facility's ID, Consolidated Waste Services, Inc. Ht 2 Airport lid. H. Facility's Phone ,r Itloti-r" r'-I na. a-ar 7 L l Ir> n a l oiIr17 It1 , .- ra - t .... -12. Cntainers 13.1. 11. US DOT Description (including Proper Shipping Name, Hazard Class, and ID Numir) Total Unit . No. Type Quantity WtiVoi Waste Na

oil Contaminated Earth (MA. REG.)

E b N E

T 0

J. Additional Descriptions for Materials Listed Above K.Handling Codes for Wastes Listed Above ( - a. oil cont. dirt bT& jQ b.

C, d. c d.

15. Special Handling Instructions and Additional Information

Not fHazarc-us in Inaine 16. GENERATOR'S CERTIFICATION: I hereby declare that the contents of this consignment are fully and accirately described above by proper shippogq name and are classified, packed, marked. and labeled and are in all respects in proper condition for transport by highway according tio app irabli international and national government regulations If I am a large quantity generator, I certify that I have a program in place to reduce the volume and toxicity of waste generated to the degree I have determined to be economicaly practicable and that I have selected the practicable method of treatment, storage, or disposal currently availtable 1n me which minimizes the present and future threat to human health and the environment OR, if Iam a small quantity generator. I have made a gorI faith effort to minimize my waste generation and select the best waste ement method that is available to me and that I can afford P ypod Name Month Day Year

T 17. Tra sporter 1 Acknowledgement of Receipt of Materials Date A Signat ontI Daa N& S 0 SO.-ransporter 2 Ackndwledgement or Receipt of Materials T PrintediTyped Name Signature Month Da Year E A I I 19 Discrepancy Indication Space

F A

20. cilty 0nr orOpeatorCe ificon of receipt of hazardous materials covere by this manifest except a1 noted in Item

ninted yped Na ,SI ure M nth Day Year

EPA Fort, 8700 22 (Rev 9 86) Previous editions are obsolete *PRMNOAkF NVO MALN PTETO I)EPARTMENT OF ENVIRONMENTAL PROTECTION a. IIazardous Waste MANIFEST SECTION, State House, Station 17, Augusta, ME 04333

Please pint or type. (Form designed for use on elite 12-piltch typewriter.) Form Approved. OMB No. 205U.0039. Expires 9 30 i UNIFORM HAZARDOUS t Generators US EPA ID No Manifest 2 Page 1 iniorin in th: shaded aas not WASTE MANIFEST I of requiredbyStateawmaye In 3 Generator's Name and Mailing Address A.Stale Ma * nber z GEflERAL DYhA?!ICS Th 11t EAST HOWARD S REE A 617 786 830C QUINCY, MA. 02169 B1aexe1r4F~utPaeari2 Pnohon i h hddaesi o 0 4. Generator's Phone ( ) 5 Transporter 1 Company Name 6. US EPA ID Number GSta.1 kaIesr5l~a772 Qj 7 JET-LINE SE2VICLS, INC. M AiDI IJ 61 21 li 71 9 4 9 6 P DNumber 7 Transporter 2 Company Name a. u Em~ftte WanipoterflyiY -4

9. Designated Facility Name and Site Address 10. US EPA ID Numbby "We ibtyu a aac maye CLUGLiDATELD WASTE SERIVICES 0 BLv . 21 A.I1A.S'a RD. HmF IIQJ'i1_DcEWoCK, AINE o4957 11 F, ) 19 id12 514616i9i ' 20 6 34?21A 12. Containers G S13' I US DOT Description (including Proper Shipping Namne, Hazard Clans and 0D Numbit) Toa Unit No. f Ouantlty Wtuoi Waste No.

G 0 01 1Z- A0 E bt N

A . tarecritCompany Naerl L USovEPA Num CD

d2 Cont inr | 1. | 1. SeDOT Hadlrin (nstrctuingPrope SddipingInaomeazadCasadioumnTta nt1

J. Additional Descriptions for Materials Listed Above K.Handling Codes for Wastes Listed Above OIL C0r$. DIRT b.I.b

n d. c. d.

lSpecial Handling Instructions and Additional Information

A 6U UMAll42r;

GENERATOR'S CERTIFICATION: I hereby declare that the contents of this consignment are fully and accurately described above by proper shipping amie and are classified, packed, marked. and labeled, and are in all respects in proper condition for transport by highway according to applicabie milernatonal and national government regulations it I am a large quantity generator, I certify that I have a program In place to reduce the volume and toxicity of waste generated to the degree I have determined to be economically practicable and that I have selected the practicable method of treatment, storage, or disposal currently available to ;ie m11mm'r11es the present and future threat to human health and the environment. OR, if I am a small quantity generator, I have made a goo Tathwh11ch effort to minimize y waste generation and select he best waste ma ement method that is available to me and that I can afford ddTyped Name Sin ur Month Day Year -egO /rT/ / T 17 Transporter I Acknowledgement of Receipt of Materials Date A tede N Sign Month Day a

0 18 ransporter 2 Acknowledgement or Receipt of Materials Date T Printed/Typed Name Sigri ure Month Day Yea' E R 19 Discrepancy Indication Space

F A

ctet yped ameJ Sn ture -y nh ).Y 7,~ Oi I

A rm b700- 22 (Rev q F6' Previous editions are obsolete *S'1A1E0 MFNAINIE * DEPARTMENT OF ENVIRONMENTAL PROTECTION % IlIazardous Waste MAN!FEST SECTION, State H1otuse, Station 17, Augusta, ME 04333 t

Please print or type. (Form designed for use On elite (12-pitch) typewriter.) Form Approved. OMB No 2050-0039, Expires 9-3t i- UNIFORM HAZARDOUS 1 Generator's US EPA tD No Manifest 2. Page 1 Iormation In the shoaed ara, s required by Fedleral law but may tio C) WASTE MANIFEST &AA'b a 7 o41 6|i n)N. of reqred by State aw 3. Generator's Name and Mailing Address GENERAL DYNAMICS A.S tate Ma e t umber 116 EAY HCWA RD SHEET ME A 617 786 h300 QUINCY, HA. 02169 B5state4neators 4. Generator's Phone ( 0

5. Transporter 1 Company Name 6. US EPA ID Number C.State ilanaporttr's 2D - 0 JET-LINE SERVICEG, 114C. (I A D1 0 6 2|li 71 9 81i9 | DQraotpoe ...... 1 ;.. 7. Transporter 2 Company Name 8 US EPA ID Number E.State Wanspottefl10 q- |lI I I I i i s3nsportinmaon* -4 Ml 9. Designated Facility Name and Site Address 10. US EPA ID Number O.Statefacilltyts ID a CCNZOLIDATED WASTE SERVICES 0i 0 HrTL. 2 AIWUPr' HD. -T) 6 NIORRIDGEWOCK, MAINE 049.71 p p ?15 14 619|9 H.FaW "t 2 7 1 12. Containers 13. 14 11. US DOT Description (including Proper Shipping Name, Hazard Class, and ID Number) Total Unit N. Type Quantity WtIVol Waste No.

I,-L CIU02kpNATill) EAH (MA .REG.) DT- iA 0 1 GOiil E b N E

______I I IW UL - _ c 0 R

_ _ _ _ _I______I - J. Additional Descriptions for Materials Listed Above K.Handlng Codes for Wastes Listed Above OIL CONT. DIRT a00

c. c d.

15 Special Handling Instructions and Addiional Intormaln tiv HAZARDuUS IN rAiNE

16 GENERATORS CERTIFICATION: I here'y declare thai to ,.ntentsof this consignment are fully and accurately described above by proper shiin;; narme and are classified, packed, marked, and labelo <,nI arr in all respects in proper condition for transport by highway according to applrable internahonal and national government regulations If I am a large quantity generator, I certify that i have a program in place to reduce the volume and toxicity of waste generated to the degree I hav- determined to be economically practicable and that I have selected the practicable method of treatment, storage or disposal currently available ?-o me which nmnir-zes the present and tuture threat o hunran health no the environment OR, it I am a small quantity generator, I have made a q' 1 faith effort to minimize my waste generation and select the best waste ement method that is available to me and that I can afford ri ed/Typed Name Signa e Month Day Year

T 17 Transporter I Acknowledgement of Receipt of Materials Date A t y ame Sign r Month Day Year

0 1 . Transporter 2 Acknowledgement or Receipt of Materials Date T Printed/TypedE Name Signature Month liDay Year

~AcsL tJ 2. J@ 1' -0)CIO (TI46 V~cWQwTL/ . cati oOf r Q)t~ f~f- eaa~ous;matoriats covered by this manifest except_ 4 noted in item t9

. rin /Ttyp4Nar ISig46 re Aoh Dg ea

EPA Form 87002 (Piwv q ious editions amt orsolte a. 1 "r' *~ IA1% 01, MAINE I

DEPARTMENT OF ENVIRONMENTAL PROTECTION .oft

1~. *.~rn hazardous Waste MANIFEST SECTION, State House, Station 17, Augusta, ME 04333 -. , Please print or type. (Form designed for use on elite (12-pitch) typewriter) Form Approved. OMB No. 2050-0039 Expires 930 -

UNIFORM HAZARDOUS 1 Generator's US EPA ID No Manifest 2 Page 1 inlormation In in* shaded ares is WASTE MANIFEST A4 1m03 Ff id 4 P' 15] JM o' required by Slate Law, 3. Generators Name and Mailing Address AState Mat n umbr

116 EAST HOWABD STREET ME A 617 736 3300 QUINCY, MA. 02169 B1tate Gentor's 4 4. Generators Phone 5 Transporter 1 Company Name 6. US EPA ID Number -QState kanspo JET-LiNE SERViCES, ING. 54 9 9 I ii 199 0.banspo p.4s 7. Transporter 2 Company Name -8 US EPA ID Number EState arpRfllftDtID ' |II!|II |t I 11| | iiSf tR"etai'

9. Designated Facility Name and Site Address 10. US EPA ID Number GSaIae Facility' ID, - CONSOLIDATED WASTE SERVICES I . RTE. 2 AlRPUKT RD. H IIORHIDGEWOCK, MAIl 04957 P4 4 I'j f6 P 19 .F 12. Cont-lners 13 14. 11. US DOT Description (Including Proper Shipping Name, Hazard Class, and 10 Number) Tota Unit No. ype Quantit WtioI Waste Nos a h~

G lb U,JTAMINATED EAlrni (RA . REG.) 0l 0 ______Oi IOT Y! A E b N E i i A I______I T 0 R c

J. Additional Descriptions for Materials Listed Above K.Ha- n|I es Above

a.OIL CONT. DIRT I.

c d c d.

15 Special Handling Instructions and Additional Information

" H.QA.IDCU2 iN YAI NE 16 GENERATORS CERTIFICATION: I hereby declare that the contents of this consignment are fully and accurately described above by proper shipp ng nme and are lassified packed marked, and labeled and are in all respects in proper condition for transport by highway according to applicable international and national government regulations If I am a large quantity generator I certify that I have a program in place to reduce the volume and toxicity of waste generated to the degree I h;e determined to be economically practicable and that I have selected the practicable method of treatment, storage. or disposal currently available to Me which ronimtives the present and future threat to human health and the environment: OR, if I am a small quantity generator. I have rnade a goid faith effort to minimize my waste generation and select the best was,~t ement metho that is a lable to me and that I can afford r Month Day Y -I ,- ed/yped Name.

T 17 Transporter 1 Acknowledgement of Receipt of Materials Date R A Punted ype Name Month Da Yar P

0 18. Transporter 2 Acknowledgement or Receipt of Materials Date a T Printed/Typed Name Sgnature Month Day Year E

19 Discrepancy Indication Space

F A A &c AAkfC /6tCt1 f b D6 oe I tmI

IT i gor C catIon of recelt of hazardous materials covered by this manifest except as noted In Item 19 r')ciio 1%h 1, ! V r I "I'/ teasI Date /

Please print or type. (Form designed foruse on elite (12-pitch) typewriter.) Form Approved. OMB No 2050-0039. Expires 9-30 H UNIFORM HAZARDOUS I Generator's US EPA IDNo Manifest 2 Page law but may be ;94 :reire by Federal WASTE MANIFEST 4A& DI0 Y ?Ir Ne O IquwedbySlateLSw Z 3 Generator's Name and Mailing Address AState Ma e I mber GENERAL DYhNICS 116 EAST HOWARD STREET MEA f17 786 8300 QUINCY, MA. 02169 BStateGeneratorsIDELM 5 0 4. Generators Phone ) 5. Transporter 1 Company Name 6. US EPA ID Number OStats Trtripoiters40 0 2 JET-LINE SERVICES. INC. iMai Dj 0 611 l71 4 1 4Tranapoi Ptie 3$! Z510 7 Tansporter 2 Company Name 8. US EPA ID Number a f B.SCotainefl Geert3'quansprrte d bPhoStL1D 0 9. Designated Facility Name and Site Address 10. US EPA 10 Number G.State Failtum ID CONSOLIDATE WASTE SERVICES 0 No. js tat 5ssprea Wtd I Wat K1l'. 2 AIRPORT RD. NORRIDGEWLXCK, MAINE 04957 [1 ID19 1812 15 1 11 619 H a Pr . am, HZ~d COS12. Containers 1 13, 14. 11 U 11,USDTOcluin esritin(icldig OTDesritio PrperoerShpin Shppng Nme Hzad ls, and 1D Number) NoTotal Unlt -I. N. Typey Quantity Wti\l waste Nar

OIL UC0JiA 14ThATED EARTH (MA . REG.)

E b N

T 0 R

J. Additional Descriptions for Materials Listed Above K Handling Codes for Wastes Listed Above

ab. a.b.0Rb

c. d. c d.

15 Special Handling Instructions and Additional information

16 GENERATORS CERTIFICATION: I hereby declare that the contents o' this consignment are filly and ;ccurate[y described above by proper shipping name and are classified. packed marked and labeled, and are in all respects in proper condition for transport by highway according to applicable international and national government regulations If I am a large quantity generator. I certify that I have a program in place to reduce the volume and toxicity of waste generated to the degree I have determined to be economically practicable and that I have selected the practicable method of treatment, storage. or disposal currently available to me which miiizes the present and future threat to human health and the environment: OR, it I am a small quantity generator, I have made a good failf±ort to minimize my waste generation and select the best waste rent method that is available to me and that I can afford P yped Name Month Day Year

T 17. Transporter I Acknowledgement of Receipt of Materials Date I A in Month Day Yar A 7u d Nae W, fWa4drC4 0 18.Transporter 2 Acknowtedgenment or Receipt of Materials Date T Printed/Typed Name Signature Month Day Year E A

19 Discrepancy Indication Space

F A C

20. Facilit Owner or Operatio Cercation of receipt f hazardous materials covered by this manifest except , noted In 1iem 19

I ari' Sig- areM hD - PA o Rva r tPA ro rmf 8700 22 (Rev 9 86) Previous editions are obsolete S/IiiV0FIMAINE DEPARTMENT OF ENVIRONMENTAL PROTECTION a te.. hazardous Waste MANIFEST SECTION, State House, Station 17, Augusta, ME 04333 , , Sii Please print or type, (Form designed for use on elite (12-pltch) typewriter) Form Approved. OMB No. 2050-0039, Expires 9-3

2 Page 1 intormation In the thaded are&$ Is .Il UNIFORM HAZARDOUS I Generators US EPA ID No Manifest 0 WASTE MANIFEST *nN Of rneqwradby State LrW, btmyb 3. I'i Generators Name and Mailing Address GENRAL DYNAMIC" i um 116 EASt IOWARD STREET ME A - 0M 617 786 8300 QUINCY, M!A. 02169 MI 4. Generators Phone ( ) 0 5. Transporter 1 Company Name 6. US EPA 10 Number 0 8 JEY-LINE SERVICES', INC. I 16 12|1A1 7 9) g9 , 7 Transporter 2 Company Name V" P1US EPA2 tD Number Le" flefin 1' I I I I I I I I FinI 1 n11he on s e ao s not r 9. Designated Facility Name and Site Address . US EPA ID Number GS,FCt IV au i CoW&;-OLIDATED WASTrE SERVICEC'2 4 V * OA2V1 F&E. 2 AIRPORT HI).H.fy" W NORBIDGEWOCK, MAINE 04957 p ~g511 1 14 16 619j9V 1' 12. Coainners 13. 14/ 7. US DOT Description (Including Prop Shipping Name, Hazard Class, and ID Number Tot Un No. I t Quant Wt Waste No, a. UIL COinmAIUFATED EARTH (MA . REG.) G0± ______J~ ~- -1 E b N A A T' c 0

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K.adlin C for Wasltes Listed Above 0 J. Additional Descriptions for Materials Listed Aboe" CNT. DICn 2OIL nr 13. 1 NCYIN ILAINI~IZ~hD0S

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a Special Handling Instructions and Additional Information N5 U,

- tt 0) C, - - I. of this consignment are fully andKors accurately described above by proper Shipping i. GENERATOR'S CERTIFICATION: I hereby declare fa the applicable 0 name and are classified, packed, marked, and labeled and ire in all respects in propei condition for transport by highway according to international and national government regulations ia~ 0 I1 am a large quantity generator, I certify that I have a program in place to reduce the volume and toxicity of waste generated to the degree I have C *V I to o determined to be economically practicable and that I have selected the practicable method of treatment, storage, or disposal currently available C. me which minimizes the present and future threat to human ha'dlth and te environment. OR. if I am a small quantity generator. I have made a good faith effort to minimize my waste generation and select the best waste mang ent method that is available to me and that I can afford SC Sign Month Day Year -v I drryped Name - C = I. 0 _ T 18. Transporer I Acknowledgement of Receipt of Materials ~0 R Sgni Month Dlay Year a- A Pr~ N m . 4

0) or Receipt of Materials '1VDate C) C) 0 18. Transporter 2 Acknowledgement n Co R Printed/Typed Name Signature Month Day Year C C o 0 Li C) = a) 19. Discrepancy Indication Space - C in r~ F A C C C r MTS ciityjlb of Opera r Tchi o( ra erd6us attrials oovdrd by this rianlfest except as noted In Item 19, I heriff 0) = SDate a. M I-, 'drnted fld Nd Signaturow nt Day Year

- - EPA Form 8700-22 (Rev 9-86) Previous editions ire obsoleic sii 6 A, it OF M'IAiN k" 41 DEPARTMENT OF ENVIRONMENTAL PROTECTION sm-es Ilazardous Waste MANIFEST SECTION, State House, Station 17, Augusta, ME 04333 ""

Please print or type. (Form designed for use on elite (12-pitch) typewriter.) Form Approved. OMB No. 2050-0039 Expires 930 8%h

1 Generators US EPA ID No Manifest 2 Page 1 Information in the shaded areas is rnot UNIFORM HAZARDOUS Documen required by Federal law but may be WASTE MANIFEST 1 h h n 1NuIh10141I10101 ored by State.aw 3 Generators Name and Mailing Address GENERAL DYNAMICS ASfate Ma ber 116 EAST HOWARD STREET MEA 617 786 J300 QUINCY, MA. 02169 Get 1Mat 4. Generator's Phone ( ) 5. Transporter I Company Name 6. US EPA 1D Number OState trsporter ID JET-LINE SERVICES, INC. |A 1D1 0 6 2 1 7 8 g n

7 Transporter 2 Company Name . US EPA NumberiD E.State Transporter%1 0 " II I I I I I I I I I Fnsportef Phone 9. Designated Facility Name and Site Address 10. US EPA ID Number G.Stste FacIlityi ID CON1SOLIDATED WASTE SERVICES rL. 2 AIh?CIfV RD. 2 NORRIDGEWOCK, MAINE 04957 p 19 18 4 6 6 H F a P

12. ContaIners 13. 14 11 US DOT Description (including Proper Shipping Name, Hazard Class, and ID Number) Total Unit H az a rdC la ssa nd_0_N u m b er) 0No. Ty p e Q u a n tity W tI oi W a ste N o.

OIL CO!NAMINITED EARTH (MA REG.) 0031D9 T 7T A 0 E b. N E

R T 0

J. Additional Descriptions for Materials Listed Above K.Handling Codes for Wastes Listed Above T. COb. DITb.

C, d. c d.

15 Special Handling Instructions and Add'tional information

Ni2l LiAZADt)U i.N 1AINE

16 GENERATOR'S CERTIFICATION: I hereby declare that the contents of this consignment are fully and accurately described above by proper shipping name and are classified. packed. marked, and abeled and are in all respects in proper condition for transport by highway according to applicable international and national government regulations. Ift am a large quantity generator, I certify that I have a program in place to reduce the volume and toxicity of waste generated to the degree I have determined to be economically practicable and that I have selected the practicable method of treatment storage, or disposal currently available to me which mrorrni.es the present and future threat to human health and the enironment. OR. if I am a small quantity generator. I have made a good faith effort to minimize my waste generation and select the best wagi. nagement method that is available to me and that I can afford pod Name Sign Month Day Year d I - / 7~ I| ge 7 17, Transp 1 cknowledgement of Receipt of Materials Date N AIl Typ dame Meonth D a p o 1 Transporter 2 Acknowledgement or Receipt of ateriais Date Printed/Typed Name Signature Month Day Year E T 19 Discrepancy Indication Space

F A c -

L k 20. F city Owner or Oprator Certificatfon of receipt of hazardous materials covered by this manifest ex t as noted in Item 19 /. Ie' , 4 ~tDate Day Year Sigr y i / ri t d4 dtA an n FPm Form) 8700 22 (Rev q 'fP) Previous editions are obsolete a-wi DEPARTMENT OF ENVIRONMENTAL PROTECTION Hazardous Waste MANIFEST SEuION, State House, Station 17, Augusta, ME 04333

Please print or type. (Form designed for use on elite (12-pitch) Iypewriter.t Form Approved. OMB No. 205U0019, Expires 9 30 6h

1 Generators US EPA ID No Manifes1 2. Page 1 Information in Ihe shaded areas IS not UNIFORM HAZARDOUS Docume N, requsred by Fede.al law but may be WASTE MANIFEST M in i n J 1 f o 1 4 a .o required by Slate Law 3. Generators Name and Mailing Address A.State.Me trmber GENERAL DYNANICS A a 4 u 0 116 EAST HOWARD STREET MEsA IT 617 786 8300 QUINCY, 1A. 02169 ,MtDG . F54 4. Generator's Phone ({ 0 5. Transporter I Company Name 6 US EPA ID Number CStalb Transporter's ID -v jET-LINE SEfVICES, INC. iA ID01 6 2 11 7 9 Q 9 il anspou ploji$P0 g II 7 Transporter 2 Company Name 8 US EPA ID Number EState an1potelImoC2,T 1 1 1 1 1 1 11111 Ftansporter Phone,-, -_4 9. Designated Facility Name and Site Address 10. US EPA ID Number G.Staie Faitiotyb ID -

CONSQL..DATED WASTE SERVICES 0 WE. 2 AIRPOT RD. H.FaItP e -a ?iC'RIIDGEWOCK, MAINE 04957 P 12 [5 1416 91 9 207 2'(14, 12 Containers 13 14 11. US DOT Description (Including Proper Shipping Name, Hazard Class, and ID Number) Tota Unit I. N. Type Quantity Wt/Vol Waste No.

OiL CONTAMINATED EARTH (MA . REG.)

a 61 0| 11 DI i ' 010017 Y 4 A 0 1 E b N E R T 0

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0 J. Additional Descriptions for Materials Listed Above K.Handling Codes for Wastes Listed Above ,-, -~ OIL COWT. DIRT ..

c. d C d.

C-, 15 Special Handling Instructions and Additional Information

- 0~ 0)- i"II1AZPAUlD{Lf HA INL - 'V 16. GENERATOR'S CERTIFICATION: I hereby declare that the contents of this consignment are fully and accurately described above by proper shipping C-) name and are classified. packed. marked. and labeled and are in al respects in proper coindition for transport by highway according to applicable 0) = international and national government regulations Id' 0 generated to the degree I have C *C If I am a large quantity generator. I certify that I have a program in place to reduce the volume and toxicity of waste and that I have selected the practicable method of treatment, storage. or disposal currently available to c-tnC determined to be economically practicable rd me which minizes the present and future threat to human health and the environment OR. iflam a small ouantity generator, I have made a gond C - faith effort to minimize my waste generation and select the best waste m ement method that is available to me and that I can afford P5 d/Typedl Name }(iMonth Day Year Co C C ~ C A&4A"7- A0 yrw73 |090 T 17 Transporter 1 Acknowledgement of Receipt of Materials Date 'V 0 r 0: a La~ LU o Ca 0 18. Transporter 2 Acknd Iecgemrent or Receipt of Materials Date 'V CV R Printed/Typed Name Signature Month Day Year C C o 0 C.) C-)

0) 19 Discrepancy Indication Space

u-S CO F A - C c J C -L F- 4'1 CC' L I t yi 20I ci~ fr oYcperafor Certilica i otreceipt of hazardous mnateriats covered y this manifest as noted n Item 19 4 Y (.- ' . . j~. ~>.~ Date 0. vL~ P ted/Typed Name Sig arerh

FPA Form 870 22 IRPv 9 86) Preious editions are obsolete .1 i "Il o;F NIAI"%1N i" V S.- DEPARTMENT OF ENVIRONMENTAL PROTECTION

- Ilazardous Waste MANIFEST SECTION, State House, Stalion 17, Augusta, ME 04333 1 1

Please print or type. (Form designed for use on elite 112-pitch) typewriter.) Form Approved. OMB No. 2050-0039 Expires 9-30 88

I Generators US EPA ID No. Manifest 2 Page I information in the shaded areas Is not UNIFORM HAZA RDOUS Document No 'eqred by Federal law but may be WASTE MANIFEST Af 11 o I hlredeu1 bil State L 3. Generators Name and Mailing Address AState Ma e t c nt umber IT, GENERAL DYNAMICS ME A 116 EAST HOWARD 2TIIEET s.state Generators ID 4. Generator s Phone 7 7P6 6300 QUINCY, MA. 02169 DQ . 5. Transporter 1 Company Name 6. US EPA ID Number CState T ansporterfai 0 JET-LINE 3ERVsGEZ INC. ii A E 0 6 P 1! 7 4 n T"w''P*'''s'Ah9"" M 7 39! 7en 7 Transporter 2 Company Name 8. U$ EPA D Num"ber EState ftnspornefl1d itRlEnspoirterls Phon -' -4 m 9. Designated Facility Name and Site Address 10. US EPA ID Number G.tate Facility) ID

uGoCLIDkiED WASTE SFRUVCE 0 *1Z.2 H.Facility) Phone UCRRIDQLUC:. iUE 04 57 MI oj ni j a 2 1 4 i rp ? A; , 1pr 12. Containers 13. 14, il, 11. US DOT Description including Proper Shipping Nama Hazard Class, and 10 Number t Total Unit 1. No. Type uantity Wtivol Waste No a. GIL CUNTAMAIiA'xhD EA!rTH (MA REG.)

E b N

A ______I I I - C T 0 I- I- d C

J. Additional Descriptions for Materials Listed Above K.Handling Codes for Wastes Lsted Above

aOIL CONT. DIRT b. a L b,

c d c d.

15 Special Handling Instructions and Additional lnto'mation

i6 GENERATOR'S CERTIFICATION: I h-rty declare that the contents of this consigrament a' fully and acc uratey described above by proper shipping name and are classifinr parked markrd. and labeled. and are in all respects In proper condition for transport by highway according to applicable international and natinqaovmmont eguIlattons If I am a large quantify generator. I certify that I have a program in place to reduce the volume and toxicity of waste generated to the degree 1 have determined to he c-onolmirafy practicabe and that I have selected the practicable method of treatment storage. or disposal currently available to Ie which m mt . trorentr aind futur. threat to human health and the environment OR if I am a small Quantity generator. I have made a good faith effort to minize my waste generation and select the best waste ement method that is available to me and that I can afford P dyedName SdaMonth Day Year aE& 1ir( / /41M i C T 17. Transporter 2 Acknowledgeme of Receipt of Materials Date

o I8 Transporter 2 Acknowliodgemeent or Receipt of Materials Dt T Printed/Typed Name Signature Month Day Year E

19 Discrepancy linocalt r Space

F A C

20. Faicility Oikne't or 0:. iitor' Cer~i tlin of rIeceipl o~ hazardousmaterialsovereid by this manifest except as no te s

yPA Date

F PA Form A87'- 2' U edions are obsoletfe *,ATE OF MAINEL DEPARTMENT OF ENVIRONMENTAL PROTECTION a- Iazardous Waste MANIFEST SECTION, State House, Station 17, Augusta, ME 04333 .,

Pleasern print or type. (Form designed for use on elite (12-pitch) typewriter.) Form Approved. OMB No. 2050-0039, Expires 90 Ch UNIFORM HAZARDOUS Generators US EPA IDNo Manifest 2. Page 1 Informanon in the saded areas Is no I Document N f required by Federal law but rnay be WASTE MANIFEST ,.r Document N o 'orired by Sate -aw u 3 Generators Name and Mailing Address A.State et umber Z GENERAL DY!UAICS 116 EAST HOWARD STREET M B.State Generator's I -4 617 756 8300 QUINCY, MA. 02169 r r 54 0 4. Generators Phone ) 5. Transporter 1 Company Name 6 US EPA ID Number .State TransotterD4 JET-LINE SERVICES, I4C. iAiDiOi6i 2j 71i A MansportPM 617,344 2510 9 7 Transporter 2 Company Name 8. US EPA ID Number E.1tate Wansporteflcldc. - Flnaporter'e Phone-- 9 Designated Facility Name and Site Address 10. US EPA ID Number G.$tate Factlity' ID CONS"uLIDATED WASTE SERVlCES ifiL. 2 AIRPORtt', RD. "e NOCRIDGEWOCK , MAINE 04957 V P p 1 IS 12 15 111 66 6 91 9 . F, 2T1. - 12. Cont;ainers 13. 1 14.- II US DOT Description (Including Proper Shipping Name, Hazard Class, and ID Number) Tota Unit No. Type QOuantity Wt/Vol Waste No. a. OIL CGflTAN4INATED EARITH (M.A . REG.) 0 01 Di0 0101117 Y : A 0 1 E 1

N R

T 0

______I I I J. Additional Descriptions for Materials Listed Above K.Handling Codes for Wastes Listed Above OIL CONT. DIRT

c d c d.

- C 19 Special Handling Instructions and Additional Information

:w'*Kl1AIiDGli N! 11AINE

C, - 16 GENERATOR'S CERTIFICATION: I hereby declare that the contents of this consignment are fully and accurately described above by proper shipping lame and are classified. packed. marked, and labeled and are in all respects in proper condition for transport by highway according to applicable - C, international and national government regulations If t am a large quantity generator. I certify that I have a program n place to reduce the volume and toxicity of waste generated to the degree I have determined to be economically practicable and that I have selected the practicable method of treatment. storage, or disposal currently available tor whichOe nimizes the present and future threat to human health and the environment OR. it I am a small quantity generator. I have made a good f'aith effort to minimize my waste generation and select the best waste manaqement method that is available to me and that I can afford ed/Typed Name ShtMonth Day Year

4, ~ 17 Transporter 1 Acknowledgement of Receipt of Materials Date - 0 A PrintegType ame -Sgns Month Day Year Gt It/G6Z (2LC /M

T Factity w3,ner ror Openrato: eriflcaiti of eept of hazardous materials covered by this manife except a ;sn oted inltel i 19- Date

P cne~y- r4 e Si ar Month Day Ye.

4 87!1 2Rev q-86) Previous editions are obsolete DEPARTMENT OF ENVIRONMENTAL PROTECTION lazardous Waste MANIF.ST SECTION, State House, Station 17, Augusta, ME 04333

Please pint or type. (Form designed for use o, elite (12-pitch) typewriter) Form Approved. OMB No. 2050-0039 Expires 9.3) di UNIFORM HAZARDOUS I Generator's US EPA ID No Manifest 2 Page 1 Inbormalon in the shaded are&. Is no' 8 WASTE MANIFEST i P i 1 I 12 In 14 5 |Y 1 of 1 requid'. bu may bv 3 Generators Name and Mailing Address AState T C GENERAL DYNAMICS ME A 1 116 EAS' H AhD STEE' B.State Generators. -1 3 00 QUINCY, MA. 02169 4. Generator's Phone( X-) . Transporter 1 Company Name 6. US EPA ID Number Pae o 0 JET-LINE SERVICES. INC. 1) 062121 7 Transporter 2 Company Name . US EPA ID Number CaI naepfib T I> 2510190 I!IIl I iiIli I Rllmpoasabfllone' 9 Designated Facility Name and Site Address 10. US EPA 10 Number GSlate Flijty-av ID, 0 CONSULIDATED WAS TE SERVICES ii'21. 2 AINUHS RD* H. Facilty-Phon NORTD G CK. MATNE 0 7 A fl 3 4 i 6 N 14 207 6 2714 12. Containers 13. 14. 11. US DOT Description (including Proper Shipping Name, Hazard Class. and ID Number) Total Unit L No. Type Quantity W/to Waste No a. aIL CiJNTANINATED EiARTH (MA .REG.) III G I P I'm '~r~T T A IDI E b N E R

A 0 R

-*0

J. Additional Descriptions for Materiats Listed Above K.HMandling.Codes for Wastes Listed Above

aCIL CONT. DIRT b. N. b. C c d. c. d.

15 Special Handling Instructions and Additonal Inormalion

NC0± IA;A.1:i. t AliL 16 GENERATOR'S CERTIFICATION: I hereby declare that Ih,h rrc- ts of this consignment are fully and accurately described above by proper shipping name and are classified. packed, marked ard labeled and are i al respects in proper condition for transport by highway according to applicable nternational and national government regulat ors If l am a large quantity generator, I certify that I have a program in place to reduce the volume and toxicity of waste generated to the degree I hav.e determined to be economically practicable and that I have selected the practicable method of treatment; storage, or disposal currently avaiable in me which minimizes the present and future threat to human health and the environment: OR, it I am a small quantity generator, I have made a good faith effort to minimize my waste generation and select the best waste management method that Is available to me and that I can afford d/Typed Name Sig Month Day Year rcdr /9/A /171 & . - T 17 Tr nsporter 1 Acknow gement of Receipt of Materials Date A Printed/Typed Nanr Sign Mo 4 D Yejr N/ 0 18. Transporter 2 Ac nowledgement or Receipt of Materials Date T Printed/Typed Name Signature Month Day year E

1g Discrepancy Indication Space

F 1 A

D T

EPA Form 8700-22 (Rev 9 86) Previous edition ire ot)-.ltp DEPARTMENT OF ENVIRONMENTAL PROTECTION IFaardous Waste MA NEI ST SEFCION, State House, Station 17, Augusta, ME 14333 Please print or type. (Form designed for use on elite (12-pitch) typewriter.) Form Approved. OMB No. 2050.0039 pires 9-30 88

1. Generator-s US EPA IDNo Manitest 2. Page 1 lntormatanri in the anaded areas is not UNIFORM HAZARDOUS Documerj N requred by Federal law but may be WASTE MANIFEST I I N o!I & i iI c I hi A A A 410* reuired by Sate Law 3. Generators Name M and Mailing Address GENERALG E DPflD-S AI! S A.State 1,1 umber MEA 116 EAST HOWARD STREET B.State G enerator's I%LDG. 617 736 3300 QUINCY, MA. 02169 #54 4. Generators Phone( ) 5. Transporter 1 Company Name 6. US EPA ID Number C.State Transporter's 1 D 4 ( -4 JET-LINE SERVICES INC. A PI 10 6 |21117191891 D.Transpoil(i Phj 67 3. 7 Itansporter 2 Company Name . US EPA ID Number E;State Wen@*dterseID Ftasnsporete Phone mIn 9. Designated Facility Name and Site Address 10. US EPA ID Number G.StaLe Faciltys ID WASTE SERVIUS CONSCLIDA'ED 0 IIE. 2 ARP0RT 1D. H4 !IRRIDGEWiCK, NAIIE 04957 F, P P P 12 1 4 6 619 9 H. "' 31M'2714 12. Containers 13. 14. 11 US DOT Description (including Proper Shipping Name. Hazard Chlass and ID Numbe) Total Unit No. Type Quantity Wi/ol Waste No:

OIL CO'TAKINATED EAHTH (MA . REG.) G GU1 D1 - M 01 E b N E

Tc 0 R

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C-., 15 Special Handling Instructions and Additional Information CA)

0-' - - thY)1AJ~'RUCU: il iAiNlf 1 GENERATOR'S CERTIFICATION: I hereby declare that the contents of this consignment are fully and accurately described above by proper shipping C-, name and are classified packed, marked, and labeled, and are in all respects in proper condition for transport by highwav according to applicable 0) nternational and national government regulations. ~0 C C 11am a iarge quantity generator. I certify that I have a program in place to reduce the volume and toxicity of waste generated to the degree I have 0 - determined to be economically practicable and that I have selected the practicable method of treatment, storage. or disposal currently available to c-re ire which minmizes the present and future threat to human health and the environment, OR, it I am a small quantity generator. I have made a good '0 C - faith effort to minimize my waste generation and select the best waste m enment method that is available to me and that I can afford daSigrta Month Day Year -~0 - C C ~ 0 coo T 17 Transporter 1 Acknowledgement of Receipt of Materials ( Dale z A y N Signa te Mo D 7 ~ LUa: -Co

o c~ 0 18. Transporter 2 Acknowledgement or Receipt of Materials Date (0 T Pinted/Typed Name Signatu Month Day Year C C e o 0 E C-, 0

= OA 19 Discrepancy Indication Space

ye Cc A C -c

C-, p Fac ty Ower r pertor, Certificatto of rec pt of hazardousifiaterials c vered uyti ranest ejWtpt as noted in Item 19, Co Y I N < (-r% 0- k~Date vO P ntedyped Na e Sig re on0h D Y

F PA Fom 8700 22 (Rev 9-86) Previous editions are obsolete. ' DEPARTMENT OF ENVIRONMENTAL PR(TECTION

., a * Iaanrdous Waste MANIFEST SECTION, State liouse, Station 17, Augusta, ME 04333 Please print or type. (Form designed for use on elite (12-pitch) typewriter.) Form Approved. OMB No. 2050-0039 Expires YJt Hh

1 Generators US EPA ID No Manifest 2 Page 1 intormti in the haded amas. s not UNIFORM HAZARDOUS No. ofiquired by Fearal law but may fie ,Document by State Law WASTE MANIFESTWAST MAIFET ! 1AIn I In'I 01 '1 dd II iihl r~nnn~ooddrd d(it12 1 'f i1 '4'required '' 0 3. Generators Name and Mailing Address A.State Maa t umber GEN~ERAL DYNAMICS - m 116 EAST HU DBi)STREET ME nA 617 786 3300 QUINCY, !A. 02169 5State4enerators 4. Generator's Phone ) r 5. Transporter 1 Company Name 6. US EPA ID Number C.Stale TransporteriD40 JET-LINE SERVICES, INC. II 0 p jpb62j117j9 91 D.Tansporte Phone 4, 2510 7. Transporter 2 Company Name 8 US EPA ID Number E.State WasportertlD I I I I II Fansportri hne 0 9. Designated Facility Name and Site Address 10. US EPA ID Number G.State Faciltys ID,- '10 CONSOLIDATED WASTE ZERVICES 0

WuE. 2 AIRPORT HD. H. Fa:i 'M NOR1IGEWOCK, MAINE 04957 p 1 6 99 ;0 14 12. Containers 13. 14 11 US DOT Description (Including Proper Shipping Nam, Hazard Clas and ID Numb.?) Total Unit No. Type Quantity W'IVol Waste No;

0O--L CONTINATED) EART- 1 (MA .REQ.) G010 1 Di T I I~Il __ A 0 1 E b..- N E R

T C 0 R

J. Additional Descriptions for Materials Listed Above K Handin Codes for Wastes Listed Above OIL COWT. DIRTR a.b. a.b

c d C d.

15 Special Handling Instructions and Additional Information

52 16 GENERATOR'S CERTIFICATION: I hereby declare that the contents of this consignment are fuly and accurately described above by proper shipping name and are classified packed. marked. and labeled, and are in at respects in proper condition for transport by highway according to applicable international and national government regulations 0) =- f I am a large quantity generator, I certify that I have a prog-am in place to reduce the volume and toxicity of waste generated to the degree I have determined to be economically pravticabie and that I have selected the e method of treatment, storage, or disposal currently available to minimizes the present a d uIe threat to human health he ny n nt:O9. it t a mao tity generator. I have made a good C irhich ca el --- e mwaste nA alect the best ste a is aand that l can afford - Month Day Year M M Fa.ll F .1 # /r // 7 17. Tra sporter IA no dement of Receipt of Materials te A fry dNa e Signatu Month Day Year N 1 1

0 18. a poree ck gem nt recei I Mater ats -- D a- Year cl. R Printed/Typed Name Signature Month Day 9U

19 Discrepancy Indication Space C

20. Ility i or Oerator: CertifcatioT m erl4ov'r is teohazardLsnifest except as noted in Item 19

drType 6Nim Soe re

E PA Form 8700-22 (Rev 9-86) lPtvious editions; are obsolete. I . I *STAIL 01 IVm.:ir 0 DEPARTMENT OF ENVIRONMENTAL PROTECTION iazardous Waste MANItESf SECTION, State House, Slation 17, Augusta, ME 04333 C Please print or type. (Form designed for use on elite (12-pitch typewriterj Form Approved. OMB No. 2050-0039 Expies 9.30 8h UNIFORM H AZARDOUS 1 Generators US EPA ID No Manifest 2 Page 1 Informaton In the shaded area. is nor Document N.required by Federal law but may ie -/14 1 1jD1 o re.uredby State ..w 0 WASTE MANIFEST 1TI 3.Generator's Name and Mailing Address bcyt Aat MaL mber z 6&I"Xt-ALMEA n-io odB.State Generator's 1D 4. Generator's Phone (; y A A 18 0 1Ii 5. Transporter I Company Name 6. US EPA ID Number CState Transpoterb ID -4 "TTA&M& p QP4J, CS 1~ ~A.pLi ii Drnlspotq(JspOn 0 7 Transporter 2 Company Name B. US EPA ID Number EState W nspoter161 I II I I I I I I I I I Fivraolei ft r" 0 9. Designated Facility Name and Site Address 10. US EPA ID Number G.State Faoliity, ID CoTrokibgT eA i$ e SetsZE~ Qw~~~ ~ ~ 22i1tlyH FQo7J 1 \3oklyaoct A e.o6f ~ ~ t12. ContaIners 13. 14. 11 US DOT Description ilncluding Proper Shipping Name Hazard Class, and1 Numbe) TotaL Unit No. Tr Ouantity WtIVol Waste N.

G ~opl r oDp Io, E b N E R

T 0 A

J. Additional Descriptions for Materials Listed Above K Har1ling Codes for Waste Listed Above

a, of b. . lb.

c d C. d.

15 Special Handling instructions and Additional Informaton

16. GENERATOR'S CERTIFICATION: I hereby declire that the contents of this consignment are fully and accurately described above by proper shipping name and are classified packed marked and labeled and are in all respects in proper condition for transport by highway according to applicable international and national government regulations If I am a large quantity generator I certify that I have a program in place to reduce the volume and toxicity of waste generated to the degree I have determined to be economically practicable and that I have selected the practicable method of treatment, storage, or disposal currently available to me which mlnmizPs the present and future threat to human health and the environment OR. itI an a small quantity generator. I have made a good faith effort to minimize my waste generation and select the best waste management method that is available to me and 1b 4T afford rinted/Typed Name /S/g onth Day Year Alor'//ifr j VAW/V 81kr9 17. Tr orter kn Hiem of iptofMatri Is Date A . r yp Sgnatu nth Da y jr/i/1/| 0 18. Transporter 2 Acknowledgement or Receipt of Materials T Printed/Typed Name S gnature E

19 Discrepancy Indication Space y F Date mn Illf

T ~ ~ r ~ m. ~ 20onO&ea of ri't, "t f hazardous riatetiats covered by this manifest exceqpjjs noted ithem 19 20 gcl$ty.O ner or Ojera or 7 ertifit on o .d.p aadu aeiascvrdb hsmnfstecpsntdi tm1

P ned/Typed Nar , , Sig ture Mn Day Year

C.-3 EPA orm 8700 22 (Rev 9 86i Previous editions are obsolete L- STIAIiE OF MIAINE DEPARTMENT OF ENVIRONMENTAL PROTECTION llazardous Waste MANIFEST SECTION, State House, Station 17, Augusta, ME 04333

Please print or type. (Form designed for use on elite (12-pitch) typewriter.) Form Approved. OMB No. 2Q50039 Expires 930 r

UNIFORM HAZARDOUS 1 Generators US EPA ID No Mif 2. Page 1 inlormalion In t shaded area i, rqiebyFderal law but may h WASTE MANIFEST I W'00) 01 Doc of I require bySlate l-aw. 3. Generators Name and Mailing Address AState M ber GeN'aR.AJ.l -)v?'1AM CJ I1I Z,'-q7-ft,7 ME A

4. Generators Phone ( ) . ,0- 5. Transporter I Company Name 6. US EPA ID Number GBSab*

6. US EPA ID Number GNtate I i I I | l | I I i ffita" tll" t ptwi"i 9. Designated Facility Name and Site Address 10. US EPA ID Number G.Sta F y Dr

O .H. FailtsPrae 12. Contanr 1, 14. - 11 US DOT Descriotion (Including Proper Shipping Name, Hazard Class, and ID Number) Unit . N. Type Quantity WtI/oI Waste Na a

G a OOOil- E bo N

T 0

0~ r'-. 0 d

J Additional Descriptions for Materials Listed Above K.Ha-d1ing Codes for Waste Listed Above ofik GoVr3T. h 'T . b

C d. c d

15 Special Handling instructions and Additional Information

16 GENERATOR'S CERTIFICATION: I hereby declare that the contents nt this consignment are uly and accurately described above by proper shipping name and are classified, packed, marked, and labeled, and are in all respects in proper condition for transport by highway according to applicable international and national government regulations if Iam a large quantity generator, I certify that I have a program in place to reduce the volume and toxicity of waste generated to the degree I have determined to be economically practicable and that I have selected the practicable method of treatment. storage. or disposal currently avaidable to mie w1hich miriees the present and future threat to human health and the environment, OR. f I am a small quantity generator I have made a gird faith effort to minimize my waste generation and select the best waste mii ent method that is available to me and that I can afford iig t Month Day Year

T 17 Transporter 1 Acknowledgem it of Receipt of Materials Date A Printed/Typed Name Sig Month.inli Day . Year N Z. .

0 18 Transporter 2 Ackno ement or eceipt of aterats Date Printed/Typed Name Signature Month Day Year E R 19 Discreoancv Indicann Space

SFacility wnr or cation of r ceipt of hazardous materials covered by th s manifest excepl as notedn Ifemn1 8. B.. Lir Date PrjnledfTyped Nam9 Sig ure Month Day Year

p; f rIM 8700 22 (Rev 9 86) Previous editions are obsolete I. DEPARTMENT OF ENVIRONMENTAL PROTECTION Hazardous Waste MANIFEST SECTION, State House, Station 17, Augusta, ME 04333 "1 Please print or type. (Form designed for use on elte (12-pitch) typewrier.) Form Approved. OMB No. 2050-0039, Expires 930 bH

HAZARDOUS I Generator s US EPA tD No Manifest 2 Page 1 uvo-0.ori In the shaded areas is not UNIFORM law but may be WASTE MANIFEST MIA L)|0 101 1 921 bio0141 Si TDocumJ U11e N11--' o i','d"*''required y Federal 3. Generator's Name and Mailing Address A.Stale Ma e u t umber Z1*11 General DynamnicsaE 116 East Howard Strtfeu;M A7 617 7606 300 11EatHwr tetstate Generator'sl -D quincy, Ma. 02169 4. Generator's Phone ( 5. Transporter 1 Company Name 6. US EPA ID Number C.State Transporter's ID Jet-Line Servicesy InC, 1M1Al D| 0| 2 1 9 4 9 phnportO FP9'6L7 344 2510 7 Transporter 2 Company Name a. US EPA ID Number E.State flnSpoteaft J I I I II II I II II F.RanaporterlarPhoneni 9. Designated Facility Name and Site Address 10. US EPA ID Number GStat. Facility's 10 Consolidated Waste Servicez

Rr; 2 airport fs. 1H.Facilityls Phone - Norridgewock , qaine 04957 IH i I D 9 31 4 '4 ( 2'07 64,27.1 12. Contalners 13. 14- 11. US DOT Descriptton (Including Proper Shipping Name. Hazard Class, and ID Number) Total Unit l. No. Type Quantity WtfVol Waste No. a. Gil Contaminated Earth (Ma. Beg.) 010ll DIT 010 1 i Y A 0 E b N E _ I I |I |I A T c

J. Additional Descriptions for Materials Listed Above K.Handling Codes for Wastes Listed Above

a. oil cont. dirt b. M 0 b.

c. d. c d.

15 Special Handling Instructions and Additional Information Net Hamsrdous in faine

16 GENERATOR'S CERTIFICATION: I hereby declare that the contents of this consignment are fully and accurately described above by proper shipping name and are classified. packed, marked ard labeled and are in all respecis in proper condition for transport hv highway according to applicable international and national government regulations I I am a large quantity generator. I certify that I have a program in place to reduce the volume and toxicity of waste generated to the degree I have determined to be econorlcally practicable and that I have selected the practicable method of treatment storage. or disposal currently available to me which minimizes the present and future threat to human health and the environment OR. if Iam a small quantity generator I have made a good faith effort to minimize my waste generation and select the best waste m ement method that is available to me and that I can afford Printed/Typed Name / Signs Month Day Year 1//rV\/ T 17. Transporter 1 Acknowledgement of Receipt of Materials Date A Printed/Typed Name MotISign DGY

0 18. Transporter 2 Acknowledgement or Receipt of Materials Date T Printed/Typed Name Signature Month Day Year E R 19 Discrepancy Indication Space

F A - c

20. Facihty Owner or Operator Certificahlon of receipt nd manifest except as noted In Item 19

Printed/Typed Name gigat onth Day Yea

Ivi PA Form 8700 22 fRev, 9 86) Proviiotis editions are Obsolete won SiAI E OF MAINE 0 DEPARTMENT OF ENVIRONMENTAL PROTECTION a liazardous Waste MANII EST SECTION, State louse, Slation 17, Augusta, ME 04333 Please print or type. (Form designed for use on elite (12-pItch) typewrtler.) Form Approved. OMB No. 2050-0039. Expires 9-30-8a UNIFORM HAZARDOUS 1 Generators US EPA IDNo Manifest 2 Page 1 nformation in the shaded areas Is not WASTE MANIFEST fillIin n 1 l In I tnN of requid* *may* by Stat... 3. Generator-s Name and Mailing Address AZtats Mafa I tumber GENERAL DYNAMICS

116 EAST HOWARD S':HEET E A - 617 786 8300 QUINCY, MA. 02169 4. Generators Phone ( ) 5. Transporter I Company Name 6. US EPA ID Number Ostate .N rzD

JET-LINE SERVICES, INC. tIA 1D 0 6 2 11 71 Datan2bol p R 4 7. Transporter 2 Company Name 8. US EPA ID Number EState tanspitfrlso; I I F.Ihoflfl Ph1lone r. 9. Designated Facility Name and Site Address 10. US EPA ID Number GState Fc~ljtyf ID. CWl.aSLIDATED WASTE OtERVICES Th. 2 AiltPORtQ 20 H.FaciP a L NORRIDGZVIuCK, 2AINE 04957 V | 918 12,2.Fs 1416|691 3T I 12. Containers 13. 14. 1. US DOT Description (Including Proper Shipping Name, Hazard Class, and ID Number) Total Unit No. Type Ouantity Wtl - Wast* No

cJL CONTAMIIIATED EAIRTH (HA . REG.) I ' ' 0 0 3 j O0 Q0l' 1 i 0A1 E b-- N R E

J. Additional Descriptions for Materials Listed Above K.andling Codes for Wastes Listed Above OIL, Cb.NT. DR'- b.

C d. C d.

15 Special Handling instructions and Additional information

LiOt HLAI wA )US 11 piA iJ 16 GENERATOR'S CERTIFICATION: I hereby declare that the contents of this consignment are fully and accurately described above by proper shipping rame and re classified. packed. marked and labeled arid are in all respects in proper -ndition fnr transport by highway according to applicable .Iernational and national government regulations I i am a large quantity generator. I certify that I have a program in olace to reduce the volume and toxicity of waste generated to the degree I have determined to he nconnocally practicable and that I have selected the practicable method of treatment, storage. or disposal currently available to me which nimirires the present and future threat to human health and the environmerlnt. OR. if I am a small quantity generator, I have made a good faith effort to minimize my waste generation and select the best was anagement method that is available to me and that I can afford /Tffryped Name Month Day Year

T 17 Tra sp er I Acknowledgement of Recelpt of Materials r D A P e aeSignal Month Day Year

o /ansporter 2 Act nowledgement or eceipt of Materials Oate T Printed/Typed Name Signature Month Day Year E

19 Discrepancy lidicalion Space

F A A \ L'I I I Is Ia?kk 1.1 t DR cJJ)~~) 2 Fa-it Ovefr or Operator Cenificatlon of receipt of hzardous malerials covered try the ranifest "xcept as noted In Item 19

Y if T / t . I I h-a. azardoup Date

ted -I Month Day Year 7Typ'edNan I 'll{ ~" S u e / I I.) it~ AXif,. FPA F , mi 8 / n RiP v ivit Previous edilions are obsolete. DEPARTMENT OF ENVIRONMENTAL PRTECTION I- *0 Hazardous Waste MANIFEST SECTION, State Hlouse, Station 17, Augusta, ME 04333 Please print or type, (Form designed for use on elite 112-pitch) typewriter.) Form Approved OMB No. 2050-0039 Expires 9(9 or UNIFORM HAZARDOUS 1. Generators US EPA ID No Manifest 2 Page 1 formation In the sad aua is , WASTE MANIFEST ofnnn;unredn bySerat La but may 3. Generator's Name and Mailing AddressEEAL DYNAMICSAtate a t ber 110 EAST HOWARD STEEl MEA 617 78t 8300 QUINCY, 4A. 02169 99ate enei ror."lu t 4. Generators Phone (. 5. Transporter 1 Company Name 6. US EPA ID Number "tlat Than JET-LINE SERVICES, INC. Q 17 9 8 19 1U anporI 7. Transporter 2 Company Name 8. US EPA ID Number Estat anslirtit1) naffaapoteraftfltntA00 IT: 9. Designated Facility Name and Site Address 10. US EPA ID Number GStale F8atyt $A yorra-2. CNSULIDATED WASTE SERVICES RTE. 2 AIRPOT RD. HF l b NURRIDGEWOCK, MAINE 04957 ! l 4 9 4 ? Jp 9in191 12. Containers 13. 14 11. US DOT Description (including Proper Shipping Name, Hazard Class,and ID Number) Total Unit I No. Type uantity WtIVoI Waste No,

OiL CONTidUlATED EARTH (MA REG.) a00|1 DIT p 10 X7 Y k 01, E b N E A Tc 0 R

d c;

J. AddItional Descriptions for Materials Listed Above K.Hannlnj s for wastes. Listed Above OIL CONT. DIRT 0 b a.ba. -b

c. d c d. Oso *0 15. Special Handling Instructions and Additional Information Ct

0) Ne IAZAIDJU2 -'I N-M11ii", 4) - - to C 16 GENERATOR'S CERTIFICATION: I hereby declare that the contents of this consignment are fully and accurately described above by proper shipping 0 name and are classified packed, marked, and labeled arnd are in all respects In proper condition for transport by highway according to applicable 4) = international and national government regulations to C C C 1t I am a large quantity generator. I certify that I have a program in place to reduce the volume and toxicIty of waste generated to the degree I have 0 determined to be economically practicable and that I have selected the practicable method of treatment, storage, or disposal currently available to C, nie which minimizes the present and future threat to huma, health and the environment OR, if Iam a small quantity generator. I have made a good 4, faith effort to minimize my aste generation and select the best waste ma eent method that Is available to me and that I can afford

to a yidaeSig u Month Day Year C C= T 17 Transporter 1 Acknowledgement of Receipt of Materials - Date A z - a- A t Signat aon S ILl

Li 0 18 Transporter 2 Acknowledgement or Receipt of Materials Date I. CV Month Day Year C C T PrintedfTyped Name Signature o 0 C, C)

- 0) 19 Discrepancy Indication Space C F A - C C- -c- 20 Fa ji'Owner or Operator Ce Tdtion of receidt of hadirdousmaterials colvere'by is manifest exc as noted n tem 19. Date

te d/Type'd N e 9 ignature MIFtich Day Yea,

EPA Form 8700 2'2 i(Rev q rt) Preovious editioris are obsolete. a. 0SIA llK OF MAIM.' 0 DEPARTMENT OF ENVIRONMENTAL PROTECTION 1, laardouti Waste MANIFEST SECTION, State House, Station 17, Augusta, ME 04333

Please print or type. (Form designed for use on elite (12-plich) typewriter.) Form Approved. OMB No. 2050-0039. Expires 9-30 14t

UNIFORM HAZARDOUS 1 Generators US EPA IDNo Manifest 2 Page 1 informatioin the shaded ea. is not WASTE MANIFEST of required by Fe . 3. Generator-s Name and Mailing Address AStateA Ma e tumber mZ 1±6 Lamifaf~ai MEA

Iii .CLTY , s~ '9 State Generator's ID 4. Generators Phone ( -ldg) 5. Transporter I Company Name 6. US EPA ID Number OStale TranspoflersD. V] -,: c jCe ifl: : , C ..nsportflPjwn4,, IVcO!I A' 1 -i lotrq urdbnFdit la 1umyb 7 Transporter 2 Company Name G US EPA ID Number EState'hnspoderlI' .1 'V Q~~ll~1,d Fa 0 I 1 1t El1ansprer's Phone 0 1 xi (aatep.)bero.JV.to.~A.Stater. I 9. Designated Facility Name and Site Address 10. US EPA ID Number G.State Fail ID -v1-v

-0 ____B.StateGenerator' ID - ~~~~C"~~~~,It ~ ~9~cG A~ f~ .Fcit"'by" Phonle '207.613* 2T14

11US DOT Description (including Proper Shipping Name, Hazard ClUas an IDNumber) Toa Unit __N o. Typ reqt Wtre l Waste No. a.

G ______qr__ X AO01 E

T 0

-o 0 J. Additional Descriptions for Materials Listed Above K Handling Codes for Wastes Listed Above a. Cont a .nersb13. 1. / 6,150ri r- ri (/a)///. IS//"yr

C, d cd. C C.. C-, 15 Special Handlinginstructions and Additional InfamHaon '-0

0, C, - - it C 16 GENERATOR'S CERTIFICATION: t hereby declare that the contents of this consignment are 1,ity and ac, -irl11 described above by proper shipping C., A name anid are classified. packed, marked, and labeled and1 are in all respects in proper conlo,r' i.r by hw~lhay according to applicable a, = international and national government regulations 'ft 0 It l am a large quantity generator. I certify that I have a program In C *C place to reduce the volume and toxicity of waste generated to the degree t have 0 - determined to be economically practicable and that I have selected the practicable method of treatment, storage, Or disposal currently available to me ehich mnitimizes the, present and future threat to human health and the environment. OR. :t i amna small quantity generator. I have made a good faith effort to minimize my waste generation and select the best waste management method that is available to me and that I Can afford Name No. Typeyped W Month Day Yea, -- C * C = S 0 axTx17, Transporter I Acknowledgement of Receipt of Materials DMZ-ale r A a: A Wyped ak g fillur Month Day yar * LU 7 4

0 18. Transporer 2 Acknowledgement or Receipt of Materials C (3 Date in Prnefye aeSignature Month Day Year C C E o 0 C) C' 19 Discrepanc( ''di atonr Space =a .sa) in F r

C- -C adityin escr onr for Certfiaton of ecept of hazardous materils coveredgbyshifstrrt od in ItemWa 19

0.' = a. . bc *-0 Pr ted!TpedNa e Sigr7 te A Month Oay Year , C, yp( // _r,, |||A L Y EPA Forn 8700 22 lRio 9 86; Pmvitous editions are obsolete dd DEPARTMENT OF ENVIRONMENTAL PROTECTION Ilazardous Wuse MANIFEST SECTION, State House, Station 17, Augusta, ME 04333

Please print o type. (Form designed for use on elite (12-pitch) typewriter.) Form Approved. OMB No. 2050-0039 Expires 9-30 hi

1 Generator's US EPA ID No Manifest 2 Page 1 Iniormanon in the shaded areas Is not UNIFORM HAZARDOUS Document Nrequired by Federal law but may be by State WASTE MANIFEST n . iI ' li of 'required *aw 3 Generators Name and Mailing Address Grnterai v anict AState Ma e t c t umber 'I1 Eanr m ME A H ' , ;4UIncy, kia. u21t B.State Generstors ID 4. Generators Phone( O; jfj ju 5 Transporter I Company Name 6. US EPA ID Number C.Sta TransportertD . -2

ijU-Li A VICU nc ,4 III IA i ) In 16 I1 IQ h D.ransporters Pq 7 Transporter 2 Company Name 8. US EPA 1DNumber E.State hansporter's 10 II I t I I FRanspooriters Phone- 9. Designated Facility Name and Site Address 10. US EPA ID Number QStale Facility's ID

.tj,11I *cUtltttiU< Vic H. Fracttyli Phone lilt

12. Containers 13. 14. 1 US DOT Description (including Proper Shipping Name, Hazard Ciass, and ID Number) Total Unit 1. No. Type Quantity WtVol Waste No. a U1

:: j -niriL I: h h: 1- y a r. E b N

0 R d

J. Additional Descriptions for Materials Listed Above K.Hafdling odes for Wastes Listed Above

a b. b.

c d. c d.

15 Special Handling Instructions and Additional Information

16 GENERATOR'S CERTIFICATION: I hereby declare that the contents of this consignment are fully and accurately described above by proper shipping name and are ,assified packed marked, and labeled, and are in all respects in proper condition for transport by highway according to applicabie .nternational and national government regulations. if I am a large quantity generator. I certify that I have a program In place to reduce the volume and toxicity of waste generated to the degree I have rintermined to h-, economically practicable and that I have selected the practicable method of treatment. storage or disposal currently available to ,eIh annmur the pren,,sent and future threat to human health and the environment, OR, it I am a small quantity generator, Ihave made a gocod tapth effort to nuiize my waste generation and select the best waste management method that is available to me and that Ican afford Prytell/Typed Name MnhDyYa

T 17 Transporter 1 Acknowledgement of Receipt of Materials

0 18. Transporter 2 Acknowledgement or Receipt of Materials Date R T Printed/Typed Name Sign ore Month Day Year E R 19 Duscrepancy indication Space

F A c

0nr O erarc rt aion f chip4 Wazar'd ndkrial d yovmanifest except as noted in Item 19 Y Date tedy~d ame g e o hDay Year

EPA I W IFil v 9 36 PrevrouLs editions Are obsolete A

DEPARTMENT OF ENVIRONMENTAL PROTECTION a r Ilanardous Waste M ANI-ESTI SECTION, State liotuse, Station 17, Augusla, ME 04333 Please print or type. (Forr designed for use on elite (12-pitch) typewriter. Form Approved. OMB No 2050-0039 Expires 9-30 N8

. Generators US EPA IDNo Manifest 2 Page 1 information in the shaded ares Is nor UNIFORM HAZARDOUS Document N required by Federal law bul may be WASTE MANIFEST 'o k L L 4 1 (1 1 )Il "'requiredf4 by Slate Law C 3 Generators Name and Mailing Address Ge x Dyrldln ica AState Ma et umber 1.16 In e - ~ etME;A ia Cy , ba. U ljdB.State Generators 1D 0 4. Generator's Phone ( UOw ) 7UO QuU 5. Transporter .0 I Company Name 6. US EPA ID Number C.State Transpo 10 Jut-.0-'V -. C tc i Dansporta tM1%.k g 7 Transporter 2 Company Name 8. US EPA ID Number E.State Tsansporteft I-0 -v 1 1 1Fa I IlAnsporters Phone 9. Designated Facility Name and Site Address 10. US EPA ID Number G.State Facilitys ID 0 0 -V H. Facliltys Phone

12. Containers 13, 14 11 US DOT Description (including Proper Shipping Name, Hazard Class, and ID Number) Total Un t L No. Type Quantity WtVol Waste No. a. LCf aud Earth (iI.Reg.) ..Ii

E b N E

A c

J. Additional Descriptions for Materials Listed Above K Handling Codes for Wastes Listed Above

a (Art;*b. b.

c. d. c d.

15. Special Handling Instructions and Additional Information

--' , ( : 1- .. ,

16 GENERATOR*S CERTIFICATION: I hereby declare that the contents of this consignment are fully and accurately described above by proper shipp.ng name anc are cLassified, packed. marked and labeled, and are in all respects in proper cnndtlion lor transport oy hrqhway according to applicable international and national government reguiations. I I am a large quantity generator, I certIfy that I have a program in place to reduce the volume and toxicity of waste generated to the degree I have determined to be economically practicable and that I have selected the practicable method of treatment, storage or disposal currently available to roe whh r--minimizes the present and future threat to human health and the environment OR. if I am a small quantity generator. I have made a good faith effort to minimize my waste generation and select the best waste mana ement method that is available to me and that I can afford ind/Tdqi ad Nam SmSi Monoth DayyY Year 6, rt ~ rl I/J-1ilgfI T 1 Transporter 1 Acknowledgement of Receipt of Materials Date Printed/TypedName Signa Month Day ar

0 18 Transporter 2 Acknowledgement or Receipt of Materials Date T Printed/Typed Name Signature Month Day Year E

19 Discrepancy Indication Space

F A C

T 20 Flity dwnr or Orerator Certificition of recelpt of hazardous materials covered by this manifest -x a not ni 19 k- f( { ) Date P ntedfrTyped Ppmr Sign re Month Day Yea,

E ' Formr 700t ., RP, 86) Previous editions are obsoletr B

S 9J t DEPARTMENT OF ENVIRONMENTAL PROTECTION a Hazardous Waste MANIFEST SECTION, State House, Station 17, Augusta, ME 04333 ., Please punt or type. (Form designed for use on elite 112-pttch) typewriter.) Form Approved. 0MB No. 2050-0039 Expires 9-3We

UNIFORM HAZARDOUS 1 Generators US EPA 10 No Manifest 2 Page 1 informaton In th. shaded ores. Is nut 0 WASTE MANIFEST A,60n o byStatt I'll 3. Generator's Name and Mailing Address j A at Ma a t Tumber z .L s. iwa.6U e ME A ed !U1 i;If !,~'. 217 BStat Generator'ti1O DO 04 4. Generators Phone( ). 0 5. Transporter I Company Name 6. US EPA ID Number .Stderanspot utH nii .tcVnces, incO. ~P F ' C p ,~la require by Feea1a tmyb 7. Thansporter 2 Company Name 8 US EPA ID Number EtMl flnsoflfi 10 0 I III I I I I I I FirhsngbotfleealB.SCotae Geerto. 14 0V 9. Designated Facility Name and Site Address 10. US EPA ID Number G.8tatsbl~aoly ID. -

Sas 2 man e9 H.Filty PhQM 207 63 2

11 US DOT Description (including Proper Shipping Name, Hazard Cla ss and 10Number) not n

. 1 D F ilityj tNamela SArisi i1 0.eg. I G D 0 1 23D -U j Y X A 0) 1 E b. N E

A T 0

C-, R ft.- C' d

-C2 C J. Additional Descriptions for Materials Listed Above K.Handling Codes for Wastes Listed Above -~co a. oil can. airt b a- b-

c d. c d. a 03 0 15 Special Handling Instructions and Additional Information Cr .0 - CV

C-: 0)- 16, GENERATOR'S CERTIFICATION: I hereby declare that the contents of this consignment are fully and accurately described above by proper shipping (.2 lame and are classified. packed, marked, and labeled. and are in all respects in proper condition (or traispor by highway according to applicable o = mternational and national government regulations. t0= .cC If I am a large quantity generator, I certify that I have a program in place to reduce the volume and toxicity of waste generated to the degree I have determined to be economically practicable and that I have selected the practicable method of treatment, storage, or disposal currently available to "I me which minimi2es the present and future threat to human health and the environment, OR. if I am a smal quantity generator, I have mhade a good efrt tomniiem wat geeation ard slect the best wast mng etmetho hti vial to me and that Icn affr

C t~ 0 _ T Transporter 1 Acknowledgement of Receipt of Materials Date z~0 a: A 'r ad S Month DayYa La* In NI L/ ed~ _ A" . Cl (3 (.3 o 8, Transporter 2 Actio iedgenent or Receipt of Materials Date I. (~ T Printed/yped Name Signature Month Day Yea, e C o a C) (~)

- Ca 19 Discrepancy Indication Space ~,, e~ F LC LW 0Ic 02 20 F y wner orOperator Certriation of receipt of hazarlous materials covered by this manifest except as noted in tem 19

P dfTye a rr> Signa M Day Year

P 9 r r 2 d s b /: £ PA I orn) 8700 22 (Rev. 9 86) previous eiditions, :ire ohbsfolt A ao a SIAI" OF MAINE DEPARTMENT OF ENVIRONMENTAL PROTECTION -a. Fhazardous Waste MANIFEST SECTION, State House, Station 17, Augusta, ME 04333

Please print or type. (Form designed for use on elite (12-pitch) typewriter.) Form Approved. OMB No. 2050-0039. Expires 9-30 Bh UNIFORM HAZARDOUS 11 Generators US EPA ID No. Manifest 2 Page I Intormation in the shaded area Is not Doumn N. euiedb Frederal law but rnay be WASTE MANIFEST I l 1 41 911?lU I1N O 1 required by State Law. 3 Generator's Name and Mailing Address uCtetal y'fantlcz AState Ma V umber 116lb M ard Street ME A ;ILcy,:, 1Jd BJ.tate Oeneral 4. Generator's Phone ( ) G 5. Transporter 1 Company Name 6. US EPA ID Number OState TranspootrteAr , Je.Lffit Sc. -vtsct, £luC. & 2 1y ( | 9( Oa 29$ 34V| 2 510 7. Transporter 2 Company Name 8. US EPA ID Number EtStkt Wandte O0

| I I I I I I I I I I I 1 1 are"" "hn . 9. Designated Facility Name and Site Address 10. US EPA ID Number G.tae Faciftyb ID

, n. HMID, GH 2l Si 41 Haclity's 20Y;634 2714 12. Cont:iners 13. 14. 11 US DOT Description (including Proper Shipping Name, Hazard Class, and ID Number) Total Unit 1. No. Type Quantity Wt/Vot Waste No, a

.. ~...... , A Farrht!, ig.

E b. N E R

Tc 0

of -

J. Additional Descriptions for Materials Listed Above K.Handling C es for Wastes Listed Above

a. -, d b, 17.b

c d. c. d.

15. Special Handling Instructions and Additional Information

16. GENERATORS CERTIFICATION: I hereby declare that the contents of this consignment are fully and accurately described above by proper shipping name and are classified. packed. marked. and labeled, and are in all respects in proper condition for transport by highway according to applicable international and national government regulations If I am a large quantity generator. I certify that I have a program in place to reduce the volume and toxicity of waste generated to the degree I have determined to he economically placticable and that I have selected the practicable method of treatment, storage, or disposal currently available to me which minimizes the present and future threat to human health and the environment: OR. if I am a small quantity generator, I have made a good faith effort to minimize my waste generation and select the best waste mana ment method that is available to me and that I can afford. d/Typed Name Signl~tur Month Day Year ~er /,..c / T 17. nsporter 1 Acknowledgement of eceipt of Materials Date R A te y e ame Mon th Day Yea r N

p 0 1. Transporter 2 Ack ledgement or Receipt of Mat isr Date T PrintedlTyped Name Month Day Year RE 19 Discrepancy Indication Space

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- Date Prited/Typed - Month Day Year EN/1n 7i 9 re, / orrn1 8 Of2 (Rellffv 9 8f) t r i , bs lete. e 9 GENERAL DYNAMICS Quincy ShipbuildingDivision 116 East Howard Street, Quincy, Massachusetts 02169

January 4, 1989

Mr. Richard J. Chalpin Deputy Regional Engineer Department of Environmental Quality Engineering 5 Commonwealth Avenue Woburn, MA 01801 Re: Quincy Shipyard PCB Remedial Activities DEQE Case #3-0536

Dear Mr. Chalpin,

On behalf of General Dynamics, I wish to thank you for your letter, dated December 7, 1988, concerning conditional approval of assessment and remedial activities conducted on polychlorinated biphenyls over the last several years at the former General Dynamics Quincy Shipyard. The Goldberg-Zoino & Associates (GZA) report detailing this work was delivered to your offices on August 22, 1988.

We are in the process of satisfying the requests in your letter, as clarified in discussions held on November 30 and December 7, 1988 with representatives of General Dynamics, GZA and Ms. Sharon Gerolamo of your office. The additional pre- remediation sampling data to confirm the adequacy of the remediation is being collated from data base files by GZA and will be submitted to Ms. Gerolamo as soon as possible. As to the requirement for deed notification, a statutory notice with respect to environmental matters and remedial actions at the Shipyard property was recorded on November 17, 1987 with the deed of the property from General Dynamics to the Massachusetts Water Resources Authority. See Norfolk Registry of Deeds, Instrument No. 132776; Norfolk Registry District, Document No. 535417. The notice specifically references the DEQE case number for this matter to facilitate review of records on file with the Department. In accordance with DEQE's request, the August, 1988 GZA report on PCB remedial activities includes a figure identifying remediated soil locations greater than 1 mg/kg and less than 40 mg/kg and pad locations greater than 100 mg/100 sq. c.m., properly sealed with two coats of epoxy or acrylic sealant. We understand that the current property owner, MWRA, has submitted appropriate protocols for any future disturbances of these areas in accordance with DEQE procedures. Mr. Richard J. Chalpin Page two January 4, 1989

When we provide the requested sampling data, General Dynamics will have complied fully with the Department's requirements for PCB remediation. The Department's letter of September 20, 1987 stated that "soil remaining at concentrations greater than 1 mg/kg and less than 40 mg/kg must be capped with a minimum of ten inches of clean compacted soil" (p. 6, Section D, first paragraph). General Dynamics conformed completely with this Department requirement for cleanup. As you know, these clean up objectives were based on an extensive review of available federal and state guidances and a risk evaluation of PCB contamination to human health and the environment at this industrial site. Furthermore, General Dynamics worked vigorously toward and complied with the Department's cleanup goal of 1 mg/kg whenever feasible in its remedial construction program. We are proud that in working to achieve this goal, we have met and exceeded the most stringent relevant federal guidelines in all areas of the property. See 40 CFR Part 761, EPA Polychlorinated Biphenyls Spills Policy. The success of this cleanup program was acknowledged by MWRA's independent consultant NUS, Inc. in its March 1988 Report, Quincy Shipyard Site Assessment.

Your letter is appreciated in that it marks the successful completion of an enormous amount of work at the facility in this area. The personnel who remain with the Division, will continue to work closely with you and your staff, and will eagerly await your comment and final approval of the other reports we have submitted to the Department. Sincerely yours,

obert F. White Manager of Operations 0

Mr. Richard J. Chalpin Page Three January 4, 1989

CC: E. J. Willwerth - GD/Consultant C. R. Stoker - GD/CO F. J. Basile - GD/CO L. Feldman - GZA C. McDermott - GZA

DEQE, 1 Winter St., Boston, MA 02108 Attn: Site Assessment Section Chief, DHW, 5th Floor Attn: Steve Lipman, DWPC, 3rd Floor Attn: Anne Bingham, OGC, 4th Floor Attn: Caleb Hemphill, ORS, 10th Floor Braintree Board of Health, Town Hall, Braintree, MA 02184 Quincy Board of Health, 1120 Hancock St., Quincy, MA 02169 Weymouth Board of Health, 402 Essex St., Weymouth, MA 02188 Foley, Hoag & Eliot, One Post Office Square, Boston, MA 02109 Attn: Laurie Burt, Esq. MWRA, Charlestown Navy Yard, 100 First Ave., Boston, MA 02129 Attn: Gary Wilson, Esq. Cities Service Oil and Gas Corp., 110 West 7th St., Box 300, Tulsa, OK 74102 Attn: Beji Malek Citgo Petroleum Corp., one Warren Place, Box 3758, Tulsa, OK 74102 Attn: John Grabowski Clean Harbors, Inc., 325 Wood Rd., Braintree, MA 02184 Attn: Alan McKim East Braintree Civic Association, c/o Donna Sullivan, 59 Hayward St., Braintree, MA 02184 Mayor Francis McCauley, 1305 Hancock St., Quincy, MA 02169 Representative Suzanne Bump, State House, Room 443, Boston, MA 02133 Senator Paul Harold, State House, Room 507, Boston, MA 02133 David Standley, 4 Spillers Lane, Ipswich, MA 01938 Brian McDonald, Board of Selectmen, 23 Prospect Hill Dr., Weymouth, MA 02191 Joe Sullivan, Board of Selectmen, 1 JFK Memorial Dr., Braintree, MA 02184 Representative Brian Donnelly, 438 Cannon Office Building, Washington, DC 20515 Peter Koff, Weston & Patrick, 84 State St., Boston, MA 02109 GENERAL DYNAMICS Quincy Shipbuilding Division 116 East Howard Street, Quincy, Massachusetts 02169

December 29, 1988

Mr. Lawrence Polese Sanitary Engineer Massachusetts Department of Environmental Quality Engineering Division of Solid and Hazardous Waste 1 Winter Street, 5th Floor Boston, MA 02108 Dear Mr. Polese:

Pursuant to the letter dated September 15, 1986 from Mr. Steven DeGabriele outlining the D.E.Q.E.'s criteria for designating the recovered No. 2 Fuel Oil at our facility as unused oil meeting specification, attached is a copy of the analysis report for the seventeenth tank car load of fuel oil (UTLX 059572, sampled August 8, 1988). This oil was transferred to our Electric Boat Division this fall as needed.

Please note that the oil met all the necessary criteria.

Recovery of fuel oil at the Quincy Shipyard is continuing, but as expected at this point in time, at a much slower rate. We have returned the railroad tank cars we were using as temporary storage for the recovered product, and transferred the product recovery lines over to a smaller capacity tanker truck. We intend to continue, under our agreement with DEQE, to collect and test this oil for reuse as fuel oil. We will continue to keep your office informed under the terms of the September 15, 1986 letter from Mr. DeGabriele.

I believe that it is worthwhile to summarize the success of this program to date: approximately 370,000 gallons of No. 2 fuel oil have been recovered and productively used since August of 1985.

Thank you for your continued assistance in this matter. If you have any questions, please contact Mr. Robert F. White, General Dynamics Manager of Operations, at the address above (telephone (617) 786-8300).

fSierely yours

Edward J. illwerth Environmental Resources Manager Attachment

xc: R. F. White - GDC/QSD (ltr only) S. Gerolamo - DEQE (ltr only) W. G. Wilson, Esq. - MWRA (ltr only) GENERAL DYNAMICE Ouincy Shipbuilding Division 116 East Howard Street, Quincy, Massachusetts 02169

December 28, 1988

Ms. Sharon Gerolamo Environmental Engineer III Department of Environmental Quality Engineering 5 Commonwealth Avenue Woburn, MA 01801

Dear Sharon,

As of January 1, 1989, my status as a full time employee of General Dynamics will end. However, I will continue as a consultant to the Corporation to assist in completing the remaining tasks associated with the environmental remediation of the Quincy Shipyard.

Since General Dynamics voluntarily began the clean out and environmental assessment of the facility in 1985, an enormous amount of work has been successfully completed. The major objective of this work has been to assure that the facility will continue as an asset to the community of which it has been a part since the beginning of this century. Now that the MWRA has begun its work in earnest, and the real prospect exists of continued shipbuilding or repair in some form at the facility, it appears that it will continue to serve the needs of Massachusetts in an essential way.

Mr. Robert F. White, Manager of Operations, will assume primary responsibilities for General Dynamics for the environmental remediation work that remains. I will be working closely with Bob. Please direct all future correspondence to Mr. White.

It has been a pleasure working with you during this memorable project.

Sincerely yours,

Edward Willwerth Environmental Resources Manager

EJW:ad GENERAL DYNAMICS Quincy ShipbuildingDivision 116 East Howard Street, Quincy, Massachusetts 02169

December 12, 1988

Ms. Sharon Gerolamo Assistant Sanitary Engineer Department of Environmental Quality Engineering 5 Commonwealth Avenue Woburn, MA 01801

Dear Ms. Gerolamo, Pursuant to our telephone conversation today, this letter is to confirm your approval of the installation of two monitoring wells through the west end of the floor of Building 54, the Turret Shop. These wells will serve as part of our continuing investigation near the southern boundary of the MWRA Fore River Staging Area (formerly the Quincy Shipyard).

We will continue to keep your office informed concerning the matter.

Sincerely yours,

Edward( J. illwerth Enviro me tal Resources Manager

xc: L. Feldman - GZA L. Burt, Esq. - FH&E R. F. White - GD/QSD C. W. Eltzroth - GD/QSD F. E. Sussman - GD/QSD W. G. Wilson - MWRA MEMORANDUM

TO: Files FROM: Bill Sirull, Enforcement Branch DATE: August 3, 1988 SUBJECT: Flibottes Auto Services ("Flibotte") 45 Columbia Terrace - Braintree

On August 2, 1988 the writer inspected the three Flibotte properties on Columbia Terrace (Lot 1), at the corner of Cliff Street and Lancaster Road (Lot 2) and at the corner of Columbia Terrace and Lancaster Road (Lot 3), Braintree. The inspection was performed at the request of Sharon Geralomo of the DHW-NERO Site Assessment staff in order to verify reports that Flibotte personnel were dumping oil or hazardous materials onto the soils at these locations The writer surveyed the NW and W fence lines of the property on Columbia Terrace. The NW boundary abuts the General Dynamics Section C parking lot. No evidence of surface dumping was observed at these locations. The writer did observe several groundwater monitoring wells in place to the west of the SW fence line. Lot 2 is used by Flibotte to store wrecked cars. I met and spoke with Bob Flibotte who explained that oil is not drained from wrecks on this lot but rather a wreck to be dismantled is brought to Lot 3. The soil surfact at Lot 2 did not appear to be significantly contaminated. An inspection of Lot 3 revealed a concrete pad upon which, according to Bob Flibotte, car engines are dismantled and the crankcas' oil drained and collected in the on-site 200 gallon waste oil storage tank labeled "oil". Flibotte stated that the company ships its waste oil with Cyn Oil at the rate of 200-250 gallons every'four months. The writer was later shown hazardous waste manifests to confirm shipment of waste oil and also shipment of 45 gallons of waste paint solvent at a time with Hazco Co. Flibotte's generator status is therefore SQG-waste oil, VSQG - other hazardous waste. The concrete pad on Lot 3 had an oil - stained surface and contained several old engine blocks. The terrain slopes downhill in a westerly direction from the pad and the surface soil is stained with oil indicating sloppiness in containing oil draining from the engines. The writer also inspected Lot 1, including the on-site garage but observed no evidence of dumping. The writer inquired of company practices in dealing with gasoline and anti-freeze drained from wrecks to be dismantled. Mr. Flibotte stated that the company tries to reuse these materials in company vehicles and in rehabilitated used cars. The writer did not observe any accumulation of used gasoline or antifreeze. The writer explained to Mr. Flibotte that the Department had received a complaint of disposal of gasoline on property across Lancaster Road from Lot 3. Mr. Flibotte explained that parhaps the reference was to a young employee who had been working on his own car in that location and may have poured out a small quantity of gasoline from a paint can onto the soil. Flibotte's Auto Services notified the Department on 6/16/86 that it was an SQG and obtained the USEPA ID Number, MAD049443187. 4 1~~.

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EPA ID: MAD049443187 REASON FOR TEMP ID: NOT ENTERED MASS LICENSE: 9999 DATE ISSUED: 99/99/99 DATE EXPIRES: 99/99/9 SIC: 9999 TYPE OF AUTHORIZATION: STORAGE? NO TRANSPORTER? NO USER? NO DISPOSAL? No GENERATOR ONLY? YES COMPANY ALPHA NAME : FLIBOTTES AUTO COMPANY NAME/MAIL ADDRESS: FLIBOTTES AUTO SERVICES INC 45 COLUMBIA TERR BRAINTREE MA 021640000 SITE ADDRESS: 45 COLUMBIA TERR BRAINTREE MA 021040000 CONTACT PERSON: JOSEPH FLIBOTTE MGR PHONE: (6i7) 343-2b1 SIZE/STATUS -GEN SIZE SQG STATUS : ACTIVE N - NEXT PANEL I - REINQUIRE R - RETURN TO EPA ID t MENU I DEQE HAZARDOUS WASTE MANIFEST TRACKING SYSTEM *** COMPANY INQUIRY PANEL TWO *** EPA ID: MAD049443137 AUTHORIZED WASTE CODES: DO-i F003 F005 j I Ito 7T I w - zji '.1 *. ~- lllkrr T A -1

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935-2160

December 7, 1988

Mr. Edward J. Willwerth General Dynamics Corporation Quincy Shipbuilding Division 16 East Howard Street Q:incy, MA 02169 RE: QUINCY - Former General Dynamics Shipyard - 97 East Howard Street - Petroleum Contaminated Surface Soil Removal Program - FINAL APPROVAL DEQE CASE # 3-0536

Dear Mr. Willwerth:

The Department of Environmental Quality Engineering (the Department) is in receipt of two reports prepared by Goldberg, Zoino, & Associates (GZA) entitled: "Soil Stockpiles and Stained Surface Soil Removal, Quincy Shipyard, Q.incy, MA, July, 1988" and "Response to DEQE Review Comments on the Soil Szockpies and Stained Surface Soil Removal Program Report, Quincy Shipyard, Quincy, MA, November 23, 1988". These reports document the efforts of GZA and General Dynamics (GD) to remediate petroleum contaminated surface soils at the shipyard and offsite properties in accordance with the requirements of Section I:(C) of the Department's September 20, 1987 letter.

Section II(C) required the removal of petroleum contaminated surface soils to the extent feasible in order to: (1) eliminate the potential for human exposure by future occupants of the site, and (2) eliminate continuing sources cf groundwater contamination. The procedures and criteria to be used for remediation of such soils were related to GD by DEQE in a telephone conversation held on May 19, 1988. These discussions were confirmed by GD in a letter dated May 20, 1988.

Please be advised that, based upon information contained in the July, 1988 and November, 1988 reports, the Department has determined that the requirements of Section II(C) of the September 20, 1987 letter have been satisfied and therefore does not anticipate requiring any additional response or enforcement action in this regard, with the exception of the following two areas:

(1) Area 5 Section E (Adjacent to Flibotte's Auto Salvage), and

(2) Area B (North of the aboveground Storage Tanks adjacent to Building 53). 0 9

Page 2

These areas are, however, being addressed as follows:

(1) Area 5 Section E The removal of petroleum contaminated soil was continued to a depth of approximately 16 inches in this area but was terminated because the contamination was found to be extensive. An assessment was subsequently conducted by GZA to define the level, extent, and nature of contamination. The results of this ass-ssment were submitted to DEQE in a report dated November, 1988 and entitled: "Evaluation of Petroleum Related Contamination in Area 5/Section E". This report is currently under review by the Department. The need for remediation of this area will be addressed under a separate cover.

(2) Area B

The removal of petroleum contaminated soil was continued to a depth of approximately 2.5 feet in this area, however, was ceased since the contamination was found to be extensive. Under approval by DEQE, this area was backfilled with clean soil and will be considered as part of the main oil plume. The feasibility of remediating subsurface soil in tne area of the main plume was addressed in a GZA report dated April, 1988 which is currently under review by the Department. The need for remediation of this area will be addressed under a separate cover.

GZA's July, 1988 report also documents the removal of stockpiled petroleum contaminated soil generated during the removal of subsurface tanks and the installation of the recovery system in the center of the facility. Please be advised that the removal of such soil has been completed to the Department's satisfaction, however, as a result of recent assessment and remedial activities at the site (i.e., test pitting in the main plume area and remediation in the area of well 3145C) additional petroleum contaminated soil stockpiles currently exist at the site. These piles must be removed to an approved disposal facility.

The Department's determination on this matter shall not limit the response or action we might take with respect to other sites in the area or the response or action we might take regarding this property in the event that further information comes to the attention of the Department.

The conclusions set forth in this letter are based upon the information contained in GZA's and GD's reports of July, 1988 and November 23, 1988 and therefore should not be relied upon without further review by the Department if this information has any omissions or misstatements.

Page 3

Very truly you s,

Richard J. Chalpi Deputy Regional Environmental Engineer

RJC/SG cc: DEQE, 1 Winter St., Boston, MA 02108 Attn: Site Assessment Section Chief, DEW, 5th Floor DEQE, 1 Winter St., Boston, MA 02108 Attn: Steve Lipman, DWPC, 3rd Fl. DEQE, 1 Winter St., Boston, MA 02108 Attn: Anne Bingham, OGC, 4th Fl. DEQE, 1 Winter St., Boston, MA 02108 Attn: Caleb Hemphill, ORS, 10th Fl. Braintree Board of Health, Town Hall, Braintree, MA 02184 Quincy Board of Health, 1120 Hancock St., Quincy, MA 02169 Weymouth Board of Health, 402 Essex St., Weymouth, MA 02188 Foley, Hoag, & Elliot, One Post Office Square, Boston, MA 02109 Attn: Laurie Burt MWRA, Charlestown Navy Yard, 100 First Ave., Boston, MA 02129 Attn: Gary Wilson Cities Service Oil and Gas Corp., 110 West 7th St., Box 300, Tulsa, OK 74102 Attn: Beji Malek Citgo Petroleum Corp., One Warren Place, Box 3758, Tulsa, OK 74102 Attn: John Grabowski Clean Harbors, Inc., 325 Wood Rd., Braintree, MA 02184 Attn: Alan McKim East Braintree Civic Association, c/o Donna Sullivan, 59 Hayward St., Braintree, MA 02184 Mayor Francis McCauley, 1305 Hancock St., Quincy, MA 02169 Representative Suzanne Bump, State House, Room 443, Boston, MA 02133 Senator Paul Harold, State House, Room 507, Boston, MA 02133 David Standley, 4 Spillers Lane, Ipswich, MA 01938 Brian McDonald, Board of Selectmen, 23 Prospect Hill Dr., Weymouth, MA 02191 Joe Sullivan, Board of Selectmen, 1 JFK Memorial Dr., Braintree, MA 02184 Representative Brain Donnelly, 438 Cannon Office Building, Washington, DC 20515 Peter Koff, Weston & Patrick, 84 State St., Boston, MA 02109 DANIEL GREENBAUMs ~ a &~ tne commitnoner rie 935-2160

December 7, 1988

Mr. Edward J. Willierth General Dynamics Quincy Shipbuilding Division 116 East Howard Street Quincy, )A 02169 RE: QUINCY - Former General Dynamics Shipyard - 97 East Howard St. - PCB Remedial Activities - CONDITIONAL APPROVAL DEQE CASE #3-0536

Dear Mr. Willwerth:

The Department of Environmental Quality Engineering (the Department) is in receipt of a report prepared by Goldberg, Zoino, & Associates (GZA) entitled: "Summary of Polychlorinated Biphenyl Remedial Activities, Quincy Shipyard, Quincy, MA, August, 1988". This report documents the efforts of GZA and General Dynamics (GD) to remediate polychlorinated biphenyl (PCB) contaminated soil/solid surfaces at the shipyard and offsite properties in accordance with the requirements of Section II(D) of the Department's September 20, 1987 letter.

In Section II(D), the Department established cleanup goals for PCBs in soil at 1 mg/kg and on solid surfaces (i.e. concrete pads) at 100 ug/100 sq cm. For those areas where remediation to these levels was infeasible, the Department offered an alternative of capping/sealing in conjunction with a deed notification. The Department's cleanup requirements were derived based upon the assertion that the site would remain commercial/industrial in nature. At the time these goals were established, all soil containing PCBs at concentrations greater than 40 mg/kg had been removed from the site.

As a point of clarification, the 40 mg/kg cleanup criteria repeatedly referenced by GZA in the August, 1988 report as a DEQE established level is erroneous. The only cleanup criteria set by the Department are those identified above.

Please be advised that, based upon information contained in GZA's report of August, 1988, the Department has determined that the requirements of Section I(D) of the September 20, 1987 letter have been satisfied and therefore does not anticipate requiring any additional remedial response actions in this regard, subject to the following conditions: 00

Page 2

(1) The results of sampling conducted prior to remediation must be submitted in order for the Department to confirm the adequacy of the remediation, and (2) A deed notification must be made identifying all areas of the site where PCBs remain at concentrations greater than the Department's established cleanup goals. Future disturbance of these areas must be in accordance with DEQE approved procedures.

The Department's determination on this matter shall not limit the response or action we might take with respect to other sites in the area or the response or action we might take regarding this property in the event that further :nforration comes to the attention of the Department.

The conclusions set forth in this letter are based upon the information contained in GZA's report of August, 1988 and therefore should not be relied upon without further review by the Department if this information has any caissions or misstatements.

Very truly you s,

SRichard J. Chalpi Deputy Regional Environmental Engineer

P.JC/SG

cc: DEQE, 1 Winter St., Boston, MS 02108 Attn: Site Assessment Section Chief, DHW, 5th Fl. DEQE, I Winter St., Boston, MA 02108 Attn: Steve Lipman, DWPC, 3rd Fl. :EQE, 1 Winter St., Boston, MA 02108 Attn: Anne Bingham, OGC, 4th Fl. ZEQE, 1 Winter St., Boston, MA 02108 Attn: Caleb Hemphill, ORS, 10th Fl. Braintree Board of Health, Town Hall, Braintree, MA 02184 Quincy Board of Health, 1120 Hancock St., Quincy, MA 02169 Weymouth Board of Health, 402 Essex St., Weymouth, MA 02188 Foley, Hoag, & Elliot, One Post Office Square, Boston, MA 02109 Attn: Laurie Burt MWRA, Charlestown Navy Yard, 100 First Ave., Boston, MA 02129 Attn: Ken Wenger Cities Service Oil and Gas Corp., 110 West 7th St., Box 300, Tulsa, OK 74102 Attn: Beji Malek Citgo Petroleum Corp., One Warren Place, Box 3758, Tulsa, OK 74102 Attn: John Grabowski Page 3

Clean Harbors, Inc., 325 Wood Road, Braintree, MA 02184 Attn: Alan McKim East Braintree Civic Association, c/o Donna Sullivan, 59 Hayward St., Braintree, MA 02184 Mayor Francis McCauley, 1305 Hancock St., Quincy, MA 02169 Representative Suzanne Bump, State House, Room 443, Boston, MA 02133 Senator Paul Harold, State House, Room 507, Boston, MA 02133 David Standley, 4 Spillers Lane, Ipswich, MA 01938 Brian McDonald, Board of Selectmen, 23 Prospect Hill Dr., Weymouth, MA 02191 Joe Sullivan, Boird of Selectmen, 1 JFK Memorial Dr , Braintree, MA 02184 Representative Brian Donnelly, 438 Cannon House Office Building, Washington, DC 20515 Peter Koff, Weston & Patrick, 84 State St., Boston, MA 02109 Paul Anderson, DPW, 55 Sea St., Quincy, MA 02169 0

MASS DEQE/NERO/DHW FIELD NOTES

~fA0, TOWN 14 0C DATE SITE REFERENCE (Kyr Yi Ailnai lic CASE #

WEATHER CONDITIONS \ timOI

ONSITE PERSONNEL

Onle b [ltrnohIf REPRESENTING E- Of~

REPRESENTING

REPRESENTING SD i1haron (4uiai REPRESENTING DGUFE PURPOSE OF VISIT jo fgnmhafize 6R5 inIh thc S1e- IOavlt noe e are re v eng +he nsk aus mnd

NOTES

- &oopied 0()fn111ieVm&{ 5nJ Yte(o(in> (Al the. SI in It . 0//n of SD 1I 9 an- C 145a a 0e &NCYH 1120HANCOCKSTREET QUINCY, MASSACHUSETTS 02169 - ur773-1380

M. JANE GALLAHUE, M.P.H, C H.O. Commissioner of Public Health 4lAn YJrnnrdtj 1talth (LIIPr

DEPARTMENT OF HEALTH

November 3, 1988

Mr. Richard Chalpin Deputy Regional Environmental Engineer Department of Environmental Quality Engineering,Northeast Region Commonwealth Place Building 5 Commonwealth Avenue Woburn, MA 01801

Dear Mr, Richard Chalpin,

The Quincy Health Department has specific concerns regarding the following contaminants, which have been identified in the March, 1988 N.U.S. Report on conditions at the Quincy Shipyard Site, now owned by the Massachusetts Water Resource Authority (M.W.R.A.).

1.) Cyanide, which is present in detectable levels in surface soils, in groundwater and inside Building 27 (Yard Office 1).

2.) Asbestos Containing Materials (ACM)- were found inside many buildings. Of concern are those A.C.M. which are significantly damaged and friable, and those A.C.M. which have the potential to become damaged and friable during the cleaning/renovation activities required to prepare the building(s) for occupancy.

As determined by the Secretary of Environmental Affairs, the lease arrangement between th M.W.R.A. and the Mass. Ship- builders Corporation does not require the preparation of an En- vironmental Impact Report. In light of this fact, along with the anticipated return of the shipbuilders to work at the site, the Quincy Health Department hereby requests that the Department of Environmental Quality Engineering (D.E.Q,E,), in conjunction with

(Continued on Page Two) Page Two the Mass. Department of Labor and Industries (D.L.I.) and the Federal Occupational Safety and Health Administration (O.S.H.A.), conduct a thorough and immediate investigation of the site prior to occupancy. This investigation is necessary to evaluate the following:

1.) The extent and location of cyanide and asbestos contamination.

2.) The risk of exposure to such contaminants by the shipbuilders returning to work, M.W.R.A. workers on site and nearby residents. All potential migration-pathways and exposure routes will thus require identification.

3.) The measures necessary to mitigate all risk exposure(s) and the clean-up level which will be attained by those mitigative measures.

4.) A clear and well defined delineation of the responsibilities and regulatory roles of all respective agencies involved with both worker and public protection from contaminants at this work site.

This comprehensive investigation should be conducted immediately, before the shipbuilders return to work on the site. The results of your findings will thus serve to protect the health and safety of all occupants of the shipyard and the public at large. Your timely response to this request is therefore greatly appreciated.

Sincerely.

M. Jane Gallahue,M.P.H. Commissioner of Public Health

MJC:mc

CC: Mr. Louis Brinn, Safety and Health Inspector,D,LI Mr. Fred Malaby , Industrial Hygienist, OSHA Mr. Paul Levy, Executive Director,M.W,R.A. Mr. Christopher Barnett, Technical Manager, M.W.R.A. Ms. Sharon Gerolamo , Environmental Engineer, D.E.Q.E. Ms. Karen Stromberg, Regional Planner, D.E.Q.E. TO: W. Leigh Bridges, Assistant Director FROM: Jack P. Schwartz, Ph.D., Chief of LaboratoryeS2

SUBJ: Review of Quincy Shipyard Site Assessment DATE: July 18, 1988

1 have read the Quincy Shipyard report we received from DEQE. It's difficult to draw too much from this report because we don't have any of the earlier analytical results from the individual wells at the site. The procedures used to determine the risk from consumption of seafood (clams, flounder, and lobster) appear to be straight EPA "cookbook" applications of existing formulas. However, the risk assessment did not include PCBs or PAHs, because numerically these values were not as prevalent as some of the other compunds on the overall site. The reason is because they (GZA) use the geometric mean instead of the arithmatic mean which tends to flatten-out sample sets that are highly skewed. In the case of PCEs, only one well produced groundwater with measureable amounts. But this well (GD-1124) is situated at the end of a pier and is some distance from all other wells. Although this well may be an isolated hot soot it is in close proximity to the river and should be further investigated.

Nearly one-third of all wells contained PAHs, but none of this data is included in any assessment of risk to the public or the marine environment. Again, it's difficult to interpret the significance of this observation without having seen the distribution pattern of PAHs in relation to potential discharges into marine waters. The report goes to great lengths to construct theoretieal contaminant levels in seafood. If possible this study would be better served by obtaining actual samples from the area in question. Many of the substances detected are omitted from this risk assessment, apparently without any explanation, whereas a small group of contaminants were selected as indicator substances because they are considered representative" of the various chemical classes. This report seems to be an abbreviated assessment of risk, and I would recommend that the authors explain why they didn't consider the 66 contaminants they detected, instead of the 13 contaminants evaluated in this report. As far as DMF contaminant data is concerned I could find no reference to any of our work, although they do quote catch estimates for lobsters and clams from published estuarine and statistic reports as well as contacts with the depuration plant and people in the Boston office. TELEPHONE CONVERSATION NOTES MASS DEQE/NERO/DSHW

SITE REFERENCE {( - pner a JnanYlirs DATE 1'1qR 0 SUBJECT Pira. nt di I U 2r Jkt TIME RE T FROM 5Wffirnl &rnI amn REPRESENTING

TO ed Wliwufh REPRESENTING -D.

DISCUSSION 0 L.wlVlaef1 li4t1 mOrrnnle /reaufs3 add tnad infnmainn on &2A's revort enh~~uI 5i 3iwkvIesAn&L

5faind S rfwee 5)i femoval Cij noI 1 lhignrel, Gunna MA'.p

Li LOpes of rnaniksts must be 'ihft for all contaminated 56| rcmcVed (rM -e Pe inohu i l %i4nrkles , rf5ifae sTls, zls q mrv kd dunn tf-1 Vufallaion of he rnec 5zirnm ,efc.

(1) otr of , . Area B Ins noL been cleaned ft a he fnrimenLs rnhsfacn . The Dk . nIinal ts are bi niOkfillet Anoe ihe rrka. OucnaninferL c4i inns exkngve. -Ths area uh be mnsrrec pat of fly major (Awrel dnid the erilq Of rmtmnj the I tijik k. Evaluatcd (5) Pag 5- Aa .9r /tornmmt, c' a-3ve. (4) lly7 9 '1i|6 -pil , E naoched? 6)For all nreas nnFirmhi on )ht iam sa%da emunterrL aL krinabm of exonat Ion must ke darunenkel- ()Pq. q -ea 5 SeA&E, fmb of exvabon in dihkm ernd.

ACTION REQUIRED/REFERRED TO 1120 HANCOCK StREET QUINCY, MASSACHUSETTS 02109 773-1380

M.Commissioner JANE GALLAHUE. of Public M P.H., Health C.H.O.

DEPARTMENT OP HEALTH

September 26, 1988

Karen Stromberg Department of Environmental Quality Engineering Northeast Regional Office 5 Commonwealth Avenue Woburn, MA 01801

Dear Ms. Stromberg,

Our Sanitarian, Cynthia DeCrisotfaro, will bp our Health Department's representative regarding activities related to the clean-up of hazardous materials at The General Dynamics shipyard.

In order to effectively carry out her responsibilities the following information needs to be forwarded to her prior to any proposed actions by your Department, The M.W.R.A. and/ or The Potential occupants:

1. Receipt of all correspondance related to the actual and proposed clean-up of hazardous materials required by your Department or the E.P.A. If additional remediation work is deemed necessary on sites proposed for occupancy, such data must be also forwarded.

It must be noted that the Quincy Health Department has not received all such relevant correspondance within the past year.

2. Notification of all activities related to the removal of asbestos twenty days prior to the actual date of the abatement work.

3. Notification of the date(s) contamined materials are to be removed prior to the date of removal. Mrs. DeCristofaro will thereby be given the opportunity to witness the removal process if deemed necessary.

(Continued on Page Two) Page Two

4. Receipt of copies of hazardous waste manifest documents stating removal to the approved site for disposal of hazardous materials.

5. Correspondance on all meetings regarding The Public Involument Pnrticipntion Process with the E. Braintree Civic Association and any other informational meetings regarding clean-up activities at The Shipyard.

I thank you in advance for your assistance in keeping Cynthia DeCristofaro informed of your activities related to The Shipyard. Mrs. DeCristofaro, will in turn, relay the necessary information to me on a regular basis.

Sincerely,

M. Jane Gallahue,M.P.H. Commissioner of Public Health

CC: Mayor Fraf1cis. X. McCauley David fladdey, Environmental Consultant David Smith, Chairman, Quincy Environmental Task Force Cynthia P. DeCristofaro, Sanitarian DAVID STANDLEY, P.E. Consuant in Environmnal Management

September 22, 1988

Mr. Richard J. Chalpin Deputy Regional Environmental Engineer Department of Environmental Quality Engineering Metropolitan Boston - Northeast Region 5 Commonwealth Avenue Woburn, MA 01801 Re: Quincy - General Dynamics DEQE Case No. 3-0536 Your Letter of September 14, 1988 Dear Mr pin: The positive and comprehensive response of you and your staff to my request of August 10, as most recently indicated by your letter of September 14, is acknowledged with appreciation. Both Karen Stromberg and Sharon Gerolamo have been very helpful, and I look forward to working with them further on this matter. I will make any further requests for information or copies of material directly to them. I will also take this opportunity to express, through you, my appreciation for the efforts of your staff in reviewing and responding to submittals by GHR Engineering on behalf of the City of Quincy respecting the Quincy Landfill. I look forward to working with you in the future. Sincerely,

David Standley, P.E. cc: Edward Kunce Commissioner Greenbaum

4 Spiller, Lane, Ipwinch. Massachusetla 01938 M 356-5662 MASS DEQE/NERO/DHW MEETING NOTES

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MASS DEQE/NERO/DHW FIELD NOTES

TOWN DATE SITE REFERENCE (UO -T D., CASE # 3-653 C

WEATHER CONDITIONS

ONSITE PERSONNEL

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REPRESENTING

DmL& REPRESENTING

REPRESENTING

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NOTES

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