United States Environmental Protection Agency Region) Jf Kennedy Federal Building, Boston, Massachusetts 022;30-2211

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION) JF KENNEDY FEDERAL BUILDING, BOSTON, MASSACHUSETTS 022;30-2211

April 9.,9r

Mr. Harish Pancnal Division of Hazardous Waste Department of Environmental Protection One Winter Street, Fifth Floor Boston, MA 02108

Dear Harish:

On March 25, 1990, at the request of the DEP, the former General Dynamics Shipyard in Quincy, HA was added to CERCLIS (MAD00392045), The following week. on April 2, 1990, I received a Preliminary Assessment for the site prepared by the DEP. To date, I have not commented on the PA report.

1have lately oiscovered, however, that this site should not have been entered into CERCLIS. The site was previously consiaered for CERCLIS listing in 1988, after Congressman Brian Donneliy expressed an interest in the Ouincy Shipyard. An agreement was reached at that time between the State (DEP Commissioner Daniel Greenbaum) and EPA (former Regional Administrator Michael Deland) not to list the site, Instead, it was decided that the State would assume an active lead'at the site, and would ensure that a thorough assessment and remediation of the site is undertaken by General Dymanics. I have attached copies of the July 196- correspondences between the State, EPA, and Congressman Donnelly on this matter.

Therefore, based upon this understanding of the situation, I am renoving the former General Dynamics Shipyard site from CERCLIS. and returning the DA to you. Nc credit will be given fOr this product. Please indicate the number of hours tnat wete charged to the MSCA for this PA on the aocoming Quarterly Report.

If you nave any questions regarding this decision. I may be reached at 573-9697.

Sincerely,

Nancy SNith MA Site Assessment Coorcnator UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION I J. F.KENNEDY FEDERAL BUILDING. BOSTON, MASSACHUSETTS

July 25, 19B8

Honorable Brian Donnelly 438 Cannon House Office Building Washington, D.C. 20515

Dear Mr. D This letter is in response to your inquiry regarding the status of site investigations at the Quincy Shipyard and the Environmental Protection Agency's plans for conducting a preliminary assessment at that location. As you are aware, the Massachusetts Water Resources Authority has conducted extensive site investigations at the Shipyard and has developed a cleanup program which is now being implemented. As a result of your concerns, I did meet with Daniel Greenbaum, Commissioner of the Massachusetts Department of Environmental Quality Engineering, concerning the State's ongoing and planned oversight role in site remediation. I have been assured by Commissioner Greenbaum that DEQE will play an active role in ensuring that a thorough cleanup of the site is undertaken by General Dynamics. By letter of July 8 (copy enclosed), the Commissioner outlined for me in detail DEQE's ongoing activities and plans. Because of the scope of the studies already completed and the commitment by DEQE to play a strong oversight role, I do not feel a preliminary assessment by EPA is warranted at this time. We will, however, be monitoring the situation, and if the cleanup program is delayed or determined to be inadequate then EPA would reserve its option to undertake additional studies at the site. I believe this approach provides for the most expeditious cleanup of the Shipyard, while still allowing significant involvement by the Agency, should it become necessary. I know of the great concern that you and your constituents have that the site be adequately cleaned up and that environmental problems be resolved. I am confident that the DEQE is committed to seeing that this is done. Your office will be kept informed of any actions considered by the Agency. If you need further assistance, please contact me, or have your staff contact Betsy Horne or Michael Ochs of the Office of Government Relations and Environmental Review at (617) 565-3414 or FTS 835-3414.

Sincerely,

MihDeland Regional Administrator Enclosure 09

&reralive Ern0wymea1 -1( s^ esate fenbont q/a/crmaals Zfiiemv

0Uau Daniel S. Greenbaum $qNreawo aele Com""ssi""er"wOne 'aWer Jfe4e , Oaston, J a. os2od MEMORANDUM TO: Helen Wald f FROM: Pat Mullan'k DATE: March 28, 1990 SUBJECT: Preliminary Assessment, Former General Dynamics Shipyard, Quincy, MA

Attached please find a final copy of a Preliminary Assessment for the Former General Dynamics Shipyard, Qunicy, MA, site number 3-0536, to be submitted for the quarter ending March 31, 1990.

ras * ow THEDEPATMTOr INYJRONMENTALFUOFET1IN

Orngi|la I'' :oted on N \T ced PKape PRELIMINARY ASSESSMENT REPORT FORMER GENERAL DYNAMICS 97 EAST HOWARD STREET QUINCY MA

INTRODUCTION

General Dynamics Shipyard occupies approximately 180 acres of industrial/commercial propery abutting the Fore River on the Quincy/Braintree town line. The former shipyard, located at 97 East Howard Street, Quincy, Massachusetts, commenced activity in 1901 and continued active operation until 1986. Prior to 1900 this was a residential area known as Quincy Point. Lead paint, asbestos, oils, lubricants and chemicals were used in the shipbuilding process. The company notified as a large quantity generator (LQG) of hazardous waste in 1980. Reports indicate VOCs, metals, cyanide, pesticides, PCBs, acid and base neutral extractable compounds and petroleum hydrocarbons are present in varying concentrations contaminating the site. Preliminary analysis of site assessment reports indicate that elevated levels of a diverse range of contaminants are present in localized areas of the site. CURRENT AND PAST OWNERSHIP

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 on the north, the Weymouth Fore River to the east, and the Clean Harbors and Citgo facilities and Quincy Avenue to the south (figure 1). 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 November 1987, the Massachusetts Water Resources Authority (MWRA) purchased the Shipyard. MWRA 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. -2-

SITE USE AND NATURE OF OPERATION Shipbuilding has been the main operation at this site since 1901. Located on the site are buildings and structures which house the industrial activity associated with shipbuilding. For the most part, the remainder of the site, not covered by buildings or structures, is paved. In addition to the structures and paved open areas, the site also contains one wet basin, four piers and five dry docks. Substances that were mainly used in the shipbuilding process include lead paint, asbestos, oils, lubricants and chemicals. Site activity has been limited to remediation activities since 1986 when active shipbuilding was halted. RCRA STATUS General Dynamics obtained a RCRA permit in August 1980 as a Large Quantity Generator (LQG), under the ID # HAD003926045. There are no reports of any RCRA violations during the period of operations from 1980 through 1986; RCRA Annual Reports were filed for these years also. Although the shipbuilding activity has ceased the company has retained their ID number to facilitate the disposal of hazardous wastes generated during the remedial activities. WATER SUPPLY, ENVIRONMENTAL SETTING AND POPULATION The city of Quincy has a population of 84,743 (1980), and encompasses approximately 17 square miles. The shipyard abutts the Weymouth Fore River to the east, Clean Harbors and Citgo facilities and Quincy Avenue to the south, East Howard Street on the west and South and Washington Streets on the north. Land use in the area is a mix of residential/commercial/industrial. The Metropolitan District Commission (MDC) supplies all of Quincy's residents with drinking water. The neighboring communities of Braintree and Weymouth receive their water supply from the Great Pond Reservoir upgradient from the site. Therefore no water supplies within a 4-mile radius are impacted by contamination from the site.

TYPE AND NATURE OF CONTAMINATION AND REMEDIATION MEASURES The Department commenced remedial activity at the site in January 1986 by issuing a Notice Of Responsibility (NOR) referencing a September 1985 release of approximately 190 gallons of #2 fuel oil from an underground piping system which connects to a 10,000 gallon above ground storage tank located within the Shipyard; and an April 1985 release of #2 fuel oil at the outfall stormdrain originating within the General Dynamics facility. -3-

Upon receipt of the NOR General Dynamics hired a consultant, Goldberg-Zoino, Associates (GZA), to assess environmental conditions at the site. GZA submitted an Environmental Assessment Report to the Department in May 1986, in addition supplements were submitted in August 1986, October 1986 and March 1987. GZA's investigation included the excavation of test pits; installation of borings and the subsequent installation of monitoring wells; screening of soil and groundwater samples for volatile organic compounds (VOCs); the analysis of selected soil and groundwater samples for VOCs, PCBs, metals, acid base/neutral extracts, and petroleum hydrocarbons; and screening of monitoring wells for an immiscible floating product. Specific contaminants identified by GZA during the course of the study include the following: 1) Tetrachloroethylene, trichloroethylene and 1,1,1- trichloroethylene solvents in the groundwater; 2) Mineral spirits in the groundwater; 3) Fuel oil products (i.e. gasoline, #2 fuel oil, weathered #6 fuel oil, and residual oil) in the groundwater; 4) PCB contamination in the surface soils; 5) Plume of oil contamination extending over the central portion of the site. The following remedial response actions were taken subsequent to the submission of GZA's report: (1) Removal of PCB contaminated soil; (2) Removal of 10 subsurface tanks; and (3) installation and operation of a passive oil recovery system (upgraded to an active recovery system 10/86). As a part of the Purchase and Sale Agreement between General Dynamics and MWRA, MWRA agreed to undertake a portion of the future remedial activity at the site and so hired their own consultant, NUS. NUS conducted a review of the existing site assessment reports and conducted sampling of their own. The resulting report "Quincy Shipyard Site Assessment, March 1988" was also submitted to the Department. Reports commissioined by General Dynamics and MWRA, indicate that Vocs, metals, cyanide, pesticides, PCBs, acid base/neutral extractable compounds and petroleum hydrocarbons are present in varying concentrations contaminating the site. The Department is currently reviewing the reports and sampling results to ensure the design of a comprehensive remedial action strategy. -4-

CONCLUSION AND RECOMMENDATION

Based on the investigation of the site and its documentation in the site assessment reports as well as several other letter reports compiled by GZA and NUS, and their preliminary review, it is concluded that extensive contamination exists at the site. Petroleum products seem to have caused extensive contamination, and sampling and monitoring well results indicate the presence of several other hazardous constituents. Although no drinking water supplies are within a 4-mile radius of the site, and current and future use is limited to industrial activity, DEP feels that due to the nature of the contaminants present, future Federal Superfund Rermedial Action is appropriate to remediate and monitor the site.

The Department, based on the above conclusion, recommends that a medium priority Screening Site Inspection (SSI), under CERCLA be conducted. UNI IhD buiAiLb - DEPARTMENT OF INTERIOR aCOMMON WE. OEOLOOC.L_ RV EY DEPART - 7 001 36S E Gil ro MASS 3 8 57'30" 339 42 *5 5rrih 1 .!ut'. jor Riw n R i e r m 1 4 oW

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r K-2 2- &,nIflO REFERENCES

1) Environmental Site Assessment, General Dynamics/Quincy Shipbuilding Division, Quincy, Massachusetts Goldberg-Zoino, Associates May 1986

2) Public Involvement Plan, Former General Dynamics Shipyard Department of Environmental Protection May 1989 3) Quincy Shipyard Site Assesssment NUS March 1988 POTENTIAL HAZARDOUS WAS TE SITE L CENTIFICATION PREUMINARY ASSESSMENT 1 ArE 0- mfh A .81 EPART 1- BITE INFORMATION AND ASSESSMENT

L JUTE NAME ANO LOCATI0N a] arTE eMe. a..----...- -.. QZ ffsrU. RouT NO.., Oft5PECJ;C'Qcanonw otrnE

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3 TYPE of RHOEU~ c * A. PWVATE C B. FEDERAL O C. STATE OD.COuNrTY C E. MUNCPAL

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a QW~tuIopA roP TCT Oomc n c.. oteae.v.,. C A. RCHA 300 1 DATE RECSVED: ' ' CO B..UNCONTROEDl WASTE Srmac a - DATE RECEIVED: ' 0 C. ONE hm0r CIACar eew oCA YVtAA IV. CXARACTR.CATION OF POTENTAL HAZARD at On srrE SPECOC a, rse..w.. o YES DA E , , A. EPA O a. EPA CONTRACTOR C C. STATE C 0. OTHER CONTRACTOR oacon. PA O E. LOCA EALT) OFFCAL C F. OTHER:

CONTRACTOR NAMEISl: 02 SrE STA To-s - ca YEARS OF o.tRA7On C A. ACTVE BRAC"NE C C.LuIOwN O IL UNKNOWN

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.?, PL o 20 0. 2 ? -4 11 6y V Site Name: CERCLIS No.: TDD No.: Reference No.:

NPL ELIGIBILITY CHECKLIST

YES NO COMMENTS Are the wastes onsite considered hazardous, as defined in CERCL-A? ------*Sites covered by other authorities: Are the hazardous materials at the site solely petroleum products (gasoline, oil, natural gas)? ------Is the contamination at the site caused solely by pesticides that were applied using an accepted practice? ------

If the release is into public or private drinking water systems, is it due to deterioration of the system through ordinary use? ------:s the release from products which are part of the structure, and result in exposure within residential, business, or community structures? ------Did the release result in exposure to people solely within a work place? ------Does the facility have an Underground Inlection Control permit under the Safe Drinking Water Act? ------

Is the release the result of the normal azolicaticn of fertilizer? ------

Does the release involve naturally occurring substances in their unaltered form? ------

Does the contamination at the site consist solely of radioactive materials generated by Department of Energy/Atomic Energy Commission activities? ------

Is the contamination at the site caused solely by coal mining operations? --- -

Does the facility have a permit from EPA or the U.S. Army Corps of Engineers (under the Marine Protection, Research, and Sanctuaries Act) to dispose of dredged materials in ocean waters? AK R~c &e~iPdd j &tAM C$~ ce Name: 0 iCLIS No.: TDD No.: Reference No.:

YES NO COMMENTS

*Other issues of site definition:

is the site defined solely as a contaminated well field? Is the site currently owned or operated by a federal agency, or has it been in the past? Is the site a municipal landfill?

-- Check if there is documentation of industri.al waste disposed of. --- Does the waste consist of a "special waste" such as fly ash? ------

-- Check if there is documentation of a hazardous component-to the waste.

Does the facility have an NPDES permit? --- c 6wett

Check if the facility has a history 27 55C of permit violations. --- Is the facility subject to ambient air quality standards under the Clean Air Act? ---

Does the facility have a permit under the Clean Air Act?

*RCRA status

Has the facility notified as a RCRA generator?

Has the facility ever had RCRA interim status or a RCRA permit?

If yes, check any that apply: - -- The facility is a boA quantity generator.

-- The facility is a NnonnotifierN or "protective filer" (identified as such. by EPA or the state). U~kvN@4\PA 40~t# e Name :!RCLIS No.: TDD No.: Reference No.:

*RCA status (continued)

-- The owner of the facility is bankrupt, c: the owner has filed for protection under bankruptcy laws (if known).

-- A RCRA compliance order or notice of violation has been issued for the facility at some time. The order or notice concerned: - conditions that posed a hazard (i.e. a release of contamination to the environment) OR

- administrative violations (i.e. recordkeeping or financial requirements).

-- Some RCRA enforcement action is currently pending at the facility.

-- A RCRA permit has been denied or interim status has been revoked for the facility. The permit or interim status was revoked:

-because ol conditions at the facility that nosed a hazard OR

-because the facility failed to meet an administrative requirement (i.e., failed to file an acceptable Part B permit application).

-- A closure plan has been requested or submitted for the facility under RCRA.

-- A closure plan has been approved for the facility under RCRA.

-- The facility is closed and currently monitoring under RCRA regulations. 0

CERCLIS DATABASE FORM

DATE: 3 /:C SITE NAME: FaMy (iweN i cs b CERCLIS No.,p 9, P C:' TDD No. PROJECTMANAGER:

DIRECTIONS TO SITE: ixHyu fS9r5{gLy -C,4i U;:t i 5.3t NWj\frAOjf~ Can\d~ ( Gua nt-I A- ayrur ort ta-ft efVerrd eytf

ELEMENT CERCLIS CODE DESCRIPTION ENTRY (No. of positions)

1. FOR ALL PROJECTS

State C2(2) Postal code

Site ID C101(12) Dun & Bradstreet (if available) or GSA

Site Name C 104(40) 9 Eqct d Ste

Street Address C 110(25)

City C111(25) g t e County *TBD Noy 1L

Ownership C136(2) FF Federally owned ST State owned CO County owned D District owned IL Indian lands Ml Mixed ownership UN Unknown *TBD Municipally owned "TBD (Privatey owned OH Other

Years of operation *TBD t9Ly to /y!t FMS Number (if assigned) C315(4) P 01 0

ELEMENT CERCLIS CODE DESCRIPTION ENTRY (No. of positions)

11.ONLY FOR SITE WITH HRS

Coordinates *TBD Latitude and Longitude

Type of Facility of Source C137(1) B Chemical Plant C City Contamination L Landfill M Manufacturing Plant N Military Facility F Other Federal Facility T mines/tailings P Lagoons A Abandoned/Midnight dumping

If unknown, Type of Waste Present R Radioactive Waste J Inorganic Waste *TBD Organic Waste Other Industrial Waste D Dioxin

If unknown, Type of Receptor Affected V Waterways/river H Housing Area W Drinking Water Wells *TBD Ecological Receptors 0 Other

Abstract C201(240) Site Description ELEMENT CERCLIS CODE DESCRIPTION ENTRY (No. of positions)

Recommendation C2103(1) For PAs: of Most Recent H = High = SSI Required Project at Site Med. = 551 Recommended N = NFRAP = No Further Remedial Action Planned

For 551s: R = Recommended for an L15 D = Deferred to another authority N = NFRAP = No Further Remedial Action Planned

For LSls: G = Recommended for an HRS Scoring N = NFRAP = No Further Remedial Action Planned

Note C2105(20) Abbreviated Comments

Reasons for Ineligibility (for Sites Determined Ineligible under CERCLA) *TBD *TBD Petroleum contamination only *TBD Active RCRA facility *TBD Properly applied pesticide *TBD Nuclear/radioactive waste *TED All other reasons

Agency Responsible for Work at Site C2117(2) F EPA, Fund financed 5 State, Fund financed SN State, no fund financing FF Federal facility *TBD Responsible Party J6V2nwwa4§fT 6 M Ae/

Daniel S. Greenbaum Commissioner 6twt /Aee. 2os/n, N at. (2/0N

MEMORANDUM

TO: File

FROM: Harish Panchal

DATE: September, 9, 1988

SUBJECT: Fore River Shipyard (General Dynamics)

This memorandum provides an update on the status of the ongoing remedial and other response actions. The site is being addressed by the Department out of the N.E. Regional Office in Woburn and all the response actions are being taken under the technical directives of that office.

The site-status as a whole, is phase II--IV. This is because different portions of the site are at different remedial response stages. There is no major progress since the Department explained its position to EPA in July, 1988. (Refer to the Commissioners' letter to Michael Deland, EPA, date July 8, 1988

) The following summarizes the current status of the different units at site:

I. Immiscible Petroleum Plume and Associated Contaminated Groundwater and Subsurface Soil

The active product/groundwater and recovery treatment is ongoing and an additional total product recovery of about 2000 gallons has occurred since May 1988. It is expected that with this recovery the original product thickness of 8 feet may have decreased to a little less than 1 foot. A feasibility study submitted by General Dynamics (GD) to address the subsurface petroleum contamination of soil is still being reviewed by the Department.

II. Surficial Petroleum Contamination Stockpiled Soil

After removing and disposing about 600 tons of petroleum contaminated soil and covering an extensive contaminated area with clean fill (that was not feasible for remediation), as mentioned in the July '88 letter, there is no major activity in this area. The feasibility study as mentioned in I above has addressed this area due to its proximity to the immiscible plume. A report by GD, recommending potential remedial measures for this area is being currently reviewed by the Department, -2-

III- Polychlorinated BIphenyls (PCBs)

In areas where it was feasible, most of the PCB contaminated soil has been cleaned and removed upto 1 ppm. In areas where it was not feasible and/or economical, the soils were cleaned upto 16 ppm: Eventhough most of the transformers have been removed from the site, there are still about six transformers on site but they are decommissioned.

IV. Southern Boundary

This is an extensive area where remedial response actions are ongoing and also joint assessment is conducted by GD, Clean Harbors and Cit ies Service/Citgo to identify need and type/extent of future remedial actions. The area in which a free floating product was recovered in one of the wells a Petrex Soil Gas Survey was conducted as mentioned in the July '88 letter. As a result of the survey, it was concluded that the free product in the well was due to some localized contamin ation in the surrounding area. It is decided to excavate the contaminated area and remove and dispose the contaminated soil.

V. Sampling and Long Term Monitoring

Confirmatory sampling and analyses were conducted on selected wells throughout the site. GD, as required by the Department has also undertaken long term monitoring of groundwater quality in selected areas of site. Results of sampling analyses are being reviewed by the Department and based on this, further need of additional sampling and future remedial response actions will be decided.

VI. Site Assessment Activities by GD and MWRA

Site Assessment and remedial actions were initiated by GD subsequent to the Department's issuance of Notice of Responsibility and an emergency approval of active recovery of immiscible petroleum plume in October 1986. Sine then, GZA, the GD's consultant has submitted a series of site assessment reports. Massachusetts Water Resources Authority (MWRA) pruchased the property from Gl in November 1987. MWRA hired NUS Corp. as their consultant for site assessment and remediation activities as a part of the Purchase and Sale Agreement. As a result of their studies and review of previous reports, NUS presented their own report. This report is being reviewed by the Department. Based on this report., GZA has prepared a 'Risk Evaluation Report' considering the highest contaminant concentrations observed at site. This report is also currently reviewed by the Department., -3

VI I. Site-Stat us and the Dlepar tment's Position with Res pecl to the Federal Superfund Program

Congressman Brian J. Donnelly, in September, 1987 proposed that the site he included in the Federal Superfund program. As a result of an extensive assessment and site characterization, the Department successfully directed GD to undertake remedial response acitons, by which the site conditions are under control. Further assessment to determine future remedial actions and long term monitoring of groundwater quality along the southern boundary and across the site are under active supervision and directives by the Deparmtent. Explaining these facts to EPA in the July '88 letter, the Department also reiterated that it would delay the cleanup activities by several years if the site be nominated to the National Priority List (NPL). EPA rejected the request o name the site a Superfund site in July 1988 stating that it will be a duplication of efforLs. (copy attached.)

This memo is to provide an update on he sile-status and any site- specific questions should be directed to Sharon Gerolamo at 935-2160

HP/sc cc: Jim Colman, Director OIR for information Sharon Gerolamo ac/ 6 0 wtcnnnaSan4eae 64' Daniel S. Ceenhar-r Corrmaisionr Q~

MEMORANDUM

TO: File

FROM: Harish Panchal

DATE: August 30, 1988

SUBJECT: Fore River Shipyard (General Dynamics)

This memorandum provides an update on the status of the ongoing remeilal and other response actions. The site is being addressed by the Department out of the N.E. Regional Office in Woburn and all the response actions are being taken under the technical directives of that office.

The site-status as a whole, is phase II-IV. This is because different portions of the site are at different remedial response stages. There is no major progress since the Department explained its position to EPA in July, 1988. (Refer to the Commissioners' letter to Michael Deland, EPA, date July 8, 1988.) The following summarizes the current status of the different units at site:

I. Immiscible Petroleum Plume and Associated Contaminated Groundwater and Subsurface Soil

The active product/groundwater and recovery treatment is ongoing and an additional total product recovery of about 2000 gallons has occurred since May 1988. It is expected that with this recovery the original product thickness of 8 feet may have decreased to a little less than 1 foot. A feasibility study submitted by Ceneral .ynamics (GD) to address the subsurface petroleum contamination of soil is still being reviewed by the Department.

II. Surficial Petroleum Contamination/Stockpiled Soil

III. Polychlorinated Biphenyls (PCBs)

In areas where it was feasible, most of the PCB contaminated soil has been cleaned and removed upto 1 ppm. In areas where it was not feasible and/or economical, the soils were cleaned upto 16 ppm. Eventhough most of the transformers have been removed from the site, there are still about six transformers on site but they are decommissioned.

IV. Southern Boundary

This is an extensive area where remedial response actions are ongoing and also joint assessment is conducted by GD, Clean Harbors and Cities Service/Citgo to identify need and type/extent of future remedial actions. The area in which a free floating product was recovered in one of the wells,a Petrex Soil Gas Survey was conducted as mentioned in the July '88 letter. As a result of the survey, it was concluded that the free product in the well was due to some localized contamination in the surrounding area. It is decidedto excavate the contaminated area and remove and dispose the contaminated soil.

V. Sampling and Long Term Monitoring

VI. Site Assessment Activities by GD and MWRA

Site Assessment and remedial actions were initiated by GD subsequent to the Department's issuance of Notice of Responsibility and an emergency approval of active recovery of immiscible petroleum plume in October 1986. Sine then, GZA, the GD's consultant has submitted a series of site assessment reports. Massachusetts Water Resources Authority (MWRA) pruchased the property from GD in November 1987. MWRA hired NUS Corp. as their consultant for site assessment and remediation activities as a part of the Purchase and Satt: Agreement. As a result of their studies and review of previous reports, NUS presented their own report. This report is being reviewed by the Department. Based on this report, GZA has prepared a 'Risk Evaluation Report' considering the highest contaminant concentrations observed at site. This report is also currently reviewed by the Department. -3-

VII. Site-Status and the Department's Position with Respect to the Federal Superfund Program

Congressman Brian J. Donnelly, in September. 1987 proposed that the site be included in the Federal Superfund program. As a result of an extensive assessment and site characterization, the Department successfully directed GD to undertake remedial response acitons, by which the site conditions are under control. Further assessment to determine future remedial actions and long term monitoring of groundwater quality along the southern boundary and across the site are under active supervision and directives by the Deparmtent. Explaining these facts to EPA in the July '88 letter, the Department also reiterated that it would delay the cleanup activities by several years if the site be nominated to the National Priority List (NPL). EPA rejected the requestto name the site a Superfund site in July 1988 stating that it will be a duplication of efforts. (copy attached.)

This memo is to provide an update on he site-status and any site-specific questions should be directed to Sharon Gerolamo at 935-2160

HP/sc

Vt" Cc)/~.4 A DANIEL S. GREENBAUM Commissioner

July 8, 1988

Michael Deland, Regional Administrator RE: Fore River Shipyard Environmental Protection Agency (General Dynamics) J.F.K. Building, 22nd Floor 21E Site Assessment and Boston, MA 02203 Remediation Activities Dear Mr. Deland: As we discussed at our meeting on June 24, 1988, hazardous waste site assessment and remediation at the Fore River Shipyard has been under state direction since 1986, and is well underway. As requested, uny staff has prepared this update of these assessment and remedial activities. Formal enforcement actions by DEQE began on October 21, 1986, when General Dynamics (GD) was issued a "Notice of Responsibility" letter (NOR) (attached) indicating their liabilities/responsibilities under Massachusetts General Law Chapter 21E. Due to the urgency of the situation, the NOR also gave GD an emergency approval to begin active recovery of an immiscible petroleum plume located in the central portion of the shipyard. This plume was estimated to cover an area of approximately 1.8 acres and was over 8 feet thick at some points. Due to the proximity of the Weymouth Fore River, there was serious concern that the plume might reach that water body if some type of control was not initiated immediately. During 1987, GD's consultant Goldberg-Zoino and Associates, Inc., (GZA) submitted a series of site assessment reports. The Department determined that GZA's assessment was sufficient and set forth requirements for remediation in a letter dated September 20, 1987 (attached). This letter also cpntained the Department's requirements for additional information. In November 1987, while assessment and remedial activities were being conducted at the shipyard. GD sold the property to the Massachusetts Water Resources Authority (SRA). As part of the Purchase and Sale Agreement, MWRA engaged the services of NUS Corp. to (1) review all previous assessment and remedial activities conducted at the shipyard and (2) initiate their own assessment of environmental conditions on the property. NUS provided the results of their investigation to DEQE in a report dated March 17, 1988.

100% Recycled Pap' S -1- At this time, the Department is reviewing existing requirements for cleanup and identifying next steps in light of the new information submitted by GZA and NUS. The Department is also working closely with EWRA regarding their plans for development of the site. The following is a brief surary of the major remedial activities conducted to date at the shipyard. 1. Immiscible Petroleum Plume and Associated Contaminated Groundwater and Subsurface Soil An active product/groundwater recovery and treatment system has been operating in the central portion of the site since October, 1986. As of May 27, 1988, product recovery had totaled approximately 363,640 gallons, product thickness has decreased from approximately 8 feet to I foot, and the air stripper had been effective in reducing influent contaminant concentrations to approved discharge limitations. In regards to the extensive subsurface petroleum contaminated soil located in this area, General Dynamics has submitted a feasibility study dated April, 1988 which evaluates remedial alternatives. This study is currently under review by the Department. II. Surficial Petroleum Contamination/Stockpiled Soil

Several areas of surficial petroleum contamination were identified by the Department at the site. From May 17, 1988 to June 2, 1988, where feasible, these soils were removed. Approximately 600 tons of contaminated soil were removed from across the site and disposed of at the Stablex facility in Canada. One area of surficial contamination was observed to be so extensive complete removal became infeasible and as such was backfilled with clean soil. This area is located adjacent to the main plume and therefore will be considered an extension of that area and is being addressed in the previously mentioned feasibility study. A report documenting the conditions described in the April feasibility study and recommending potential remediation activities is expected to be submitted to DEQE this July. III. Polycholorinated Biphenyls (PCB's) Where feasible, PCB contaminated soil was removed to 1 mg/kg and PCB oil stained pads were cleaned to 100ug/100 sq cm. The removal of contaminated soil/stained pads was completed on April 29, 1988. Approximately 122.5 tons of contaminated soil/debris and 8 tons of concrete were removed from the site. Confirmatory sampling was completed on May 24, 1988. A report summarizing these activities is expected within the next couple of months. IV. Southern Boundary As required by the Department, General Dynamics is currently in the process of installing additional groundwater monitoring wells at the southern boundary to further define subsurface conditions. General Dynamics has also been holding active discussions with Clean Harbors and to a lesser extent with Cities Service/Citgo regarding joint efforts for the assessment and remediation of this area. -2-

During the course of continuing explorations in the southern boundary area, free floating product was discovered in one of the wells in December of 1987. In order to define the extent of this layer, a Petrex Soil Gas Survey was conducted. The results of this survey were submitted in a report dated May, 1988 and General Dynamics will be submitting a proposal for remediation of this area in the near future. V. Confirmatory Sampling As required by the Department, confirmatory sampling/analyses was conducted on selected wells from across the site to verify groundwater quality. The results of this sampling were recently submitted to the Department in a report dated May, 1988 and is currently under review. VI. Longterm Monitoring As required by the Department, longterm monitoring of groundwater quality in selected areas of the site has been initiated by General Dynamics. To date, two rounds have been conducted. The results of the first round were recently submitted in a report dated May, 1988 and the results of the second round are pending. VII. IWRA Site Assessment Activities As previously indicated, NUS presented the results of their environmental assessment and comments on previous assessments and remedial activities in a report dated March 17, 1988. Currently, this report is under review by the Department. Upon receipt of this report, GD asked GZA to evaluate NUS's assessment and to conduct a risk evaluation of the shipyard based upon the highest contaminant concentrations observed to date. The results of this evaluation were submitted to DEQE in a report date June, 1988. GD and GZA made a formal presentation on the contents of this report to DEQE July 7, 1988. Level of Remediation Section 3A(g) of Chapter 21E requires that feasible permanent solutions be implemented at all disposal sites. A permanent solution is defined as " a measure or combination of measures that, at a minimum, will ensure the attainment of a level of control of each identified substance of concern at a disposal site or in the surrounding environment such that no such substance of concern will present a significant or otherwise unacceptable risk of damage to health, safety, public welfare, or the environment during any foreseeable period of time, considering existing public health standards and foreseeable uses of the site". Further, where feasible, permanent solutions shall include "measures designed to reduce to the extent possible the level that would exist in the absence of the disposal site of concernNu

The Department's requirements for the level of investigation and the level of remediation at this site is based upon General Dynamics assertion -3-

that site use would be limited to activities of industrial or business office nature. The Department has stated to General Dynamics and MWRA that it reserves the right to reexamine the site investigation/remediation program should any change in the proposed site use warrant it. The Department is working closely with WRA regarding its proposed utilization plans for the site to ensure that the level of remediation being performed at the site will be sufficient for the anticipated site use. As this sunmary clearly indicates, extensive assessment and remedial activities have been conducted at the shipyard. Given both 6ZA's and NUS's environmental assessments, it is the Department's opinion that a complete characterization of contaminant conditions across the majority of the site is available. Additional investigation will, however, be required at the Southern Boundary Area. The sufficiency of remedial actions completed will be reevaluated based upon the most recent information submitted by GZA and NUS, however significant changes are not anticipated. State versus Federal Program This Agency would welcome any assistance EPA would like to offer in reviewing and cornenting on any aspect of the assessment or remediation of the site. The Department would not, however, recommend that the shipyard be ranked for the National Priorities List for the reasons explained below. The Department believes that a change in the site cleanup lead from the DEQE 21E Program to the EPA Superfund Program would cause significant delays in the remediation work being performed without benefit to the ulti- mate goal of remediating the site. Nomination to the National Program List (NPL) at this time would duplicate cleanup efforts completed to date and cause significant delays in future State enforcement and remediation activities. Those delays could amount to several years. The Department further believes that its actions at the site adequately address concerns with the site and that it is not a good candidate for the NPL. Requests for federal Superfund assistance on sites are normally based on a number of factors, which include difficulties in getting responsible parties to complete site work; and the degree to which the sites: are of particular regional significance based on complex site conditions; involve wastes with which the Department has very little experience such as radioactive waste and explosives; or where a federal agency is involved in the site contamination as a reponsible party. Finally, regulations for implementing the amended Massachusetts Superfund Law have been promulgated. The Massachusetts Contingency Plan, similar to the National Contingency Plan under CERCLA, contains the notification, requirements, and guidelines for the assessment and remediation of releases or threats of releases of oil or hazardous materials. It also includes a comprehensive public participation process. The Department has also been given additional resources for its cleanup program and has enhanced its ability to enforce compliance with environmental laws. These changes have increased the Department's ability to cleanup sites similar to the authorities and programs EPA has under CERCLA as amended by SARA. -4-

Public Involvement Plan In response to a petition recently filed with DEQE by residents in Braintree and Quincy, the Department is developing a formal Public Involvement Plan (PIP) for the 21E activities at the shipyard. A series of discussions have been held among staff from my Divisions of Water Pollution Control and Hazardous Waste and MWRA to determine the efficacy of utilizing the MWRA's RMFP Quincy-Braintree-Weymouth Regional Task Force as a vehicle for the 21E PIP. Such a procedure would also be very advantageous to EPA since the EPA is concurrently preparing an EIS for the MRA's RMFP and is directly involved in this public participation process, and there fore would have direct access to the 21E PIP. I hope that this correspondence provides you with the information you require. If any portions of this correspondence need clarification or expansion or you require additional documentation feel free to contact me or have your staff contact Mr. Lipman directly (292-5698). As I indicated at our June 24th meeting, I would be happy to par- ticipate with EPA in a briefing for Congressman Donnelly. Very truly yours

Daniel Greenbaum Commissioner DG/SGL/sf (417) cc: Jeffry Fowley, EPA - Office of General Counsel 3. RUSSELL SYLVA 5fme,,n4

935-2160

- October 21, 19866

fr. G.S. Grimes Vice President - General Manager- General Dynamics Corporation 97Quincy East ShipbuildingHowardSt. Division , Quincy , MA 0216 9 R E: QUINCY - General Dynamics/Quincy Shipbuilding Division - 97 East Howard Street NOTICE OF RESPONSIBILITY PURSUANT TO CHAPTERO.G.L. 21E DEQE CASE NO.: 3-511 Dear Mr. Grimes: The Department of Environmental Quality Engineering is in -receipt of an engineering -report -prepared by Goldberg-Zoino & Associates, Inc. (GZA) concerning environmental conditions at the subject site. This report is dated May 1986 and is entitled: "Environmental Site Assessment, General Dynamics/Quincy Shipbuilding Division, Massachusetts". Additional information regardi ng -remedial actions conducted at the site was submitted to the Department in a GZAsQreport dated August 1986 and entitled "Supplement to Environmental Site Assessment, Quincy Shipbuilding Facility, Quincy, Massachusetts". Accordin to GZA the subject site has been utilized as a shipbuilding' facility since 1901. Currently the site is inactive. The investigation conducted by GZA included the excavation of testapits ; the installation of 61 borings and the subsequent installation of 4-4,groundwater -monitoring wells; the screening of soil and groundwater samples for volatile organic compounds (VOC's)1 the analysis of selected soil and groundwater samples for VOC's,.PCB's, metals, acid-base neutral extractables, and petroleum hydrocarbonsvand the screening of monitoring wells for an itiscible floating product. Mr. C.S. Crimes Page 2.

The results of OZA's investigation indicated that elevated levels of a diverse range of contaminants are present in localized areas of the site, the most significant of these areas being the area around buildings 5 and 11 where approximately 10 feet of floating product (#2 oil) was observed. To date, remedial actions initiated at the site include: (1) the removal of PCB contaminated soil; (2) the removal of 10 subsurface tanks, and (3) the installation and operation of a passive recovery system in the area of Anilding #5. Your cooperation in this matter in voluntarily initiating and pursuing site investigative and remedial measures is appreciated. Please excuse the legalistic tone of this letters we are compelled by regulatory policy to outline statutory provisions relative to your potential liabilities at this site. Statement of Conclusions/Statutory Liabilities

Based upon the aforementioned investigation, a condition of soil and groundwater contamination have been documented at the subject site. Be advised that such conditions constitute a "release" of oil/hazardous materials at the 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 anhazardous material has occurred; any person who ditactly 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 Jreat 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. (M.G.L. Chapter 21E, Section 5 a). This letter is to inform you in writing that: (1) The Department has determined that a "release" of oil/ hazardous materials has occurred at the subject site. Mr. 0.S. Grimes Page 3.

4 (2) Initial remedial/cleanup measures are necessary at the - site to mitigate adverse public health/environmental impacts. (3) Information available to the Department -indicates that you as owner 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 Comonwealth 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 Cozionwealth. The debt, together with interest, would constitute a lien on all your property in the Commonwealth. In addition to the foreclosure remedy provided by the lien, the Attorney General of the Comonwealth 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 synopsis of M.G.L. Chapter 21E is attached for further delineation of the liabilities and penalties contained in this statute A complete copy of this statute, as Ammended, is available at the State House Bookstore in Boston. Mr. G.S. Grimes Page 4.

Recuisite Site Actions

Based upon the information contained in GZA's report of May 1986, the Department hereby approves the i=ediate installation of an "active" product recovery system in. the area of Buildings 5 and 11. Plans for such a system were submitted by Groundwater Technology, Inc. in a report entitled "Proposed Groundwater Rehabilitation Program, General Dynamics, Quincy Shipyard, 97 East Howard Street, Quincy, Massachusetts, September 1986". The approval for the installation of such a product/groundwater recovery and treatment system is based ;upon the plans dated September 1986, and subject to the following conditions: (I) MONITORING SCHEDULE The following monitoring schedule, as developed by the Department and agreed to by Groundwater Technology, must be implemented at the subject site: (A) Initially (1) Monitoring Wells Piezometric head levels and floating product thicknesses must be determined in "key wells", 1, 3, and 7 days following system startup. (2) Influent/Effluent Water to/from the Air Stripper The influent and effluent water to/from the air stripper must be analyzed for VOC's according to Groundwater Technology's modified EPA Method 602. 1, 3, and 7 days following system startup. In lieu of the "Modified" 602, a portable GCamay be utilized for days 1 and 3. (B) First Month (1) Monitoring Wells Piezometric head levels and floating product, thicknesses must be determined in "key wells", weekly for the first month. Mr. C.S. Crives Page 5.

(2) Influent/Effluent Water td/from the Air Stripper The influent and effluent water to/from the air stripper must be analyzed for VOC's according to EPA Method 624 (GC/MS) for the first week of the first month, to insure that only petroleum constituents are being drawn through the stripper. If the results of EPA Method 624 indicate that in fact, only petroleum constitutents are present, Groundwater Technology's modified EPA Method 602 may be utilized weekly for the remainder of the month. However, if the results of EPA method 624 indicate that contaminants other than petroleum constituents are pr'esent, EPA Method 624 must be utilized weekly for the remainder of the month. -(C) -Second~ Month (1) 'Monitoring Wells Piezometric head levels and floating product thicknesses must be determined in "key wells", bimonthly for the second month. (2) Influent/Effluent Water to/from the Air Stripper The influent and effluent water to/from the air stripper must be analyzed for VOC's by means of the most appropriate testing method (EPA Method 624 or Modified 602 depending upon the results of prior analysis), bimonthly for the second month. (D) Thereafter (1) Monitoring wells Piezomettic head levels and floating product thicknesses must be determined in "key wells" on a monthly basis.

(2) Influent/Effluent Water to/from the Air Stripper The influent and effluent water to/from the air stripper must be analyzed for VOC's on a monthly basis utilizing the most appropriate testing method (EPA Method 624 or the Modified 602 depending upon the results of prior analysis). Mr. G.S. Grimes Page 6.

(II) REPORTING SCHEDULE

Written reports detailing system operation and maintenance, system and site water quality data, and site piezometric data must be submitted to the Depart- ment 21 days following system startup and monthly thereafter. Piezometric/product thickness data must be contoured; tabulations, charts, and sketches shall be utilized as needed to facilitate the presentation and evaluation of data. (III) DISCARGE CRITERIA The Department has established a discharge criteria of 100 ug/1 total benzene, toluene, ethyl benzene, and xylenes for the effluent water from the air stripper. This concentration is the result of discussions between DEQE, EPA, and Groundwater Technology. (IV) SUFFICIENCY OF RMEDIA. ACTIONS Iterative actions will undoubtedly be needed to "fine- tune" system operations and optimize steady-state remedial efforts. Field decisions and actions in this regard shall be documented in submitted reports. Following startup and system stabilization, Groundwater Technology shall continuously assess system performance and adequacy, and if warranted, shall propose system modifications and/or additions that may be needed to meet remediation objectives. In this regard, the Department questions the adequacy of the four proposed recovery wells in recovering the entire floating product plume. Based upon calculations contained in Groundwater Technology's report of September 1986, the "capture zone" of each recovery well is estimated at 41' + downgradient. The results of screening monitoring wells indicate that the inmiscible plume extends approximately 150' downgradient of the most downgradient recovery well. Therefore, .a portion of the floating plume may not be recovered. Under such conditions, additional investigation and remedial actions must be initiated in this area. Recovery operations may be terminated following a written determination by the Department that remediation objectives have been adequately fulfilled. Mr. G.S. Grimes Page 7.

Please be informed that start-up of the recovery system may not occur until approval is obtained from the Department's Division of Air Quality Control. Since there is a free floating layer present in close proximity to the Weymouth Fore River, the U.S. Coast Guard is issuing a variance from the NPDES permit at this time, thereby allowing the effluent water from the air stripper to be discharged to an onsite storm drain. As part of the overall review of the site, the Department is continuing to assess what impact the repainder of the documented contamination may have on public health and the environment and will determine the need for additional investigation and/or the need for remedial actions at the site in the near future. A written response indicating your intentions to comply with the provisions of this letter is required by November.1, 1986. If you have any further questions regarding this mater, please contact Sharon Gerolamo at the letterhead address or 935-2160.

Very truly yours,

Richard ,Jhalpin Acting Regional Environmental Engineer RJC/SG/gg cc: DEQE/DSHW, 1 Winter St., Boston, MA 02108- ATTN: Madeline Snow Quincy.Bd. of Health, 2120 Hancock St., Quincy, NA 02169 Ms. Laurie Burt,YFoley, Hoag & Elliot, One Post Office Sq., Boston, MA 02109 Mr. Thomas J. Kern, Goldberg Zoino & Assoc., The Geo Bldg., 320 Needham St., Newton Upper Falls, MA 02164 Mr. John Grabowski, Citgo Petroleum Corp., One Warren Place Box 3758, Tulsa, OK 74102 Ms. Jeji Malek, Cities Service Oil and Gas Corp., 110 West 7th St. Box 300, Tulsa, OK 74102 Mr. Michael Hatch, Clean Harbors, Inc., 325 Wood Rd., Braintree, 1 Mr. David Tordoff, US EPA, 60 Westview St., Lexington, MA 02173 Commanding Officer, U.S. Coast Guard, Marine Safety Office, 447 Cocercial St., Boston, MA 02109-1096 Mr. Richard Kowalski, Groundwater Technology, Inc., Suite 101 1420 Providence Highway, Norwood, MA 02062 50mmmea-A. ,4dAnue0

A~~cmazoauce6 atk //aacae S. RUSSELL SYLVA Cmamsioner 9

September 20, 1987

Mr. Fredrick Sussuan General Dynamics/QuiUcy Shipbuilding Division 10 Forbes Road East Braintree, HA 02184 -RE: QUINCY - General Dynamics/ Quincy Shipbuilding Facility 97 East Howard Street - DEQE Case No. 3-536

Dear Mr. Sussman:

Over the past year, the Department of Environmental Quality Engineering (the Department) has received numerous reports from General Dynamics Corporation concerning environmental conditions at the General Dynamics/Quincy Shipbuilding Facility (the shipyard). Collectively, these reports represent the results of an extensive environmental assessment conducted by Goldberg-Zoino & Associates (GZA) at the shipyard.

At this point in the Department's continuing review of these documencs, we are prepared to comment on the following three issues: (1) the adequacy of the environmental assessment conducted to date at the shipyard, (2) Department requirements for remedistion/clesnup, and (3) other Department requirements. Each of these issues will be addressed in detail below.

I. ADEQUACY OF THE SITE ASSESSMENT

The results of the environmental assessment conducted to date at the shipyard are contained in the following reports:

(1) Entironmental Site Assessment,-General Dynauics Quincy Shipbuilding Division, Quincy, MA, GZA, May 1986

(2) Supplement to Environmental Site Assessment, Quincy Shipbuilding Facility, Quincy, MA, GZA, August 1986

(3) Supplemental Information, Environmental Site Assessment, General Dynamics/Quincy Shipbuilding Division, Quincy, MA, Willverth, October 1986

(4) Supplemental Information, Environmental Site Assessment, General Dynamics/Quincy Shipyard, Quincy, MA GZA, March 1987

(5) Preliminary Risk Assessment, Oil Recovery Ares, General Dynamics/Quincy Shipyard, Quincy, MA GZA, March 1987 2

(6) Investigation of Potential Southern Boundary Source Areas, Quincy Shipbuilding Facility, Quincy, MA, GZA, March 1987 (7) Summary Table of PCB Chemical-Screening and Analytical Results and Remedial Measures, July 15, 1987 (8) Tank Removal Observation Summary, April 26, 1986 and Field Summary Sheets, April 22-25, 1986 - (9) Report on Asbestos Abatement Activities at the General Dynamics Corp/Quincy Shipbuilding Division, ERT, July 1987 Based upon a review of these documents, it is the Department's determination that, overall, they appear adequate in identifying all areas of the site thet may pose a significant threat to public health and/or the environment.. The basis for this determination is addressed in Section Il below. In reviewing these reports, the Department has several requests for additional confirmatory information. These requests will be addressed in Section III of this letter.

II. DEPARTMENTAL REQUIREMENTS FOR CLEANUP Section 3A(g) of Massachusetts General Law Chapter 21E requires that feasible permanent solutions be implemented at all disposal sites. A permanent solution is defined as "a measure or combination of measures that, at a minimum, will ensure the attainment of a level of control of each identified substance of concern at a disposal site or in the surrounding environment such that no such substance of concern will present a significant or otherwise unacceptable risk of damage to health, safety, public welfare, or the environment during any foreseeable period of time", considering existing public health standards and foreseeable uses of the site. Further, where feasible, permanent solutions shall include "measures designed to reduce to the extent possible the level of oil or hazardous materials in the environment to the.level that would exist in the absence of the disposal site of concern." The Department's requirements for the level of investigation and the level of remediation at this site is based upon General Dynsamics' assertion that site use would be limited to activities of industrial or business office nature. Be advised that, the Department reserves the right to reexamine the site investigation/remediation program should any change in the proposed site use warrant it.

The following is a list of areas/types of contamination identified at the shipyard:

(A) Am Immiscible Petroleum Plume and Associated Contaminated Groundwater in Area 2 of the Site, '> (B) Subsurface Petroleum Contaminated Soil in Area 2 (associated 3

with the immiscible plume),

(D) Polychlorinated Biphenyl (PCB) Contaminated Soil,

(E) Mineral Spirits

(F) Chlorinated Solvents

(H) Asbestos

(1) Properties Outside of the Shipyard Proper

(J) Southern Boundary

The following is a summary of the Department's requirements for cleanup relative to each of these areas/types of contamination:

A. THE IMMISCIBLE PETROLEUM PLUME AND ASSOCIATED CONTAMINATED GROUNDWATER

An immiscible plume, consisting primarily of #2 fuel oil, exists in Area II of the site, in the vicinity of building 11. This plume extends over an area approximately 1.8 acres in size and when originally discovered, was approximately 8 feet thick. Realizing the urgency of this situation, General Dynamics immediately contracted Groundwater Technology to recover this plume. In August of 1986, a product/groundwater recovery and treatment system was installed for the purpose of containing and recovering the oil. This system originally consisted of a few recovery wells and an air stripping tower. The system has since received several modifications. Passive recovery of the oil began on August 19, 1986 and active recovery began on October 22, 1986. To date, the system has recovered approximately 327,000 gallons of oil and has been.effective in treating contaminated groundwater.

The requirements for cleanup of this area (ie. how long this system would have to run) was a major topic of discussion between DEQE, General Dynamics, and OZA. It was agreed that remedistion would follow a phased approach, specifically: Phase I-Product Recovery, Phase II-Groundwater Recovery and Treatment, and Phase III-Long-term Monitoring. In a letter dated August 17, 1987, CZA submitted a proposal to implement this approach. Please be advised that, after reviewing this submittal, the Department has established a modified final approach for General Dynamics to follow. This approach is described below:

Phase I - Product Recovery

Note: The existing product/groundwater recovery and treatment system is operating under this phase. 4

Obje ctive: To recover all immiscible floating product. - Requirements:

(1) The product/groundwater recovery and treatment system aust run until all floating product has been removed (ie., no measurable amounts observed in impacted wells), or (2) If General Dynamics can demonstrata that achiaving Requirement I is technically and economically infeasible, the Department will consider the use of a technology based limit (TBL). The Department has defined this TEL as that point when product recovery (under optimal conditions) has become asymptotic (leveled off for a period of 6 months) and the product thickness in impacted wells is less than two inches. Monitoring: The system along with "key wells" must continue to be monitored monthly as required in the October 21, 1986 Notice of Responsibility (NOR) letter. Reporting: Reporting must continue on a monthly basis as required in the October 21, 1986 NOR letter.

Phase 11 Transition: When the requirements of this phase have been achieved, remedial actions can move into Phase 11. Note: If applicable, groundwater monitoring data collected during this phase may be credited towards the jequirements of Phase 11.

PHASE 11 - GROUNDWATER RECOVERY AND TREATMENT

Objective: To determine the appropriateness of continued groundwater recovery and treatment and to confirm that the objective of Phase I has been met.

Requirements:

(1) The groundwater recovery and treatment system must continue to tun through one hydrologic cycle (1 year). 'During this year, groundwater in key wells must be monitored to observe the effects of seasonal fluctuations on floating product thickness and dissolved contaminant concentrations. (2) The entire product recovery system must remain in place and operational in the event that immiscible petroleum reappears during this phase. Monitoring: The influent and effluent to the treatment system along with "key wells" must be monitored monthly during this phase for parameters (including floating product) to be specified at the end of Phase 1.

Reporting: Monitoring reports must be submitted on a monthly basis. 5

Transition to Phase III: Based upon the results of one year of monitoring, the Department will determine if the recovery/treatment system can be shut down and as such if operations can move into Phase III. If General Dynamics can demonstrate that contaminant concentrations In groundwater in impscted wells have become asymptotic (is., no significant change in contaminant concentrations for a period of 6 months at a concentration at or below a concentration derived through an approved risk assessment), the Department will consider the requirements of this phase met. Else, the system, or a modified version thereof, must continue to run under the above monitoring And reporting requirements. Following receipt of each monthly monitoring report, the Department will evaluate the possibility of shutting down the system. Upon approval by the Department, remedial actions can move into Phase III.

PHASE III - LONG-TERM MONITORING

Objective: To monitor the area under non-pumping conditions.

Requirements:

(1) "Key wells" in Area II must be monitored quarterly for one year for parameters to be specified by the Department at the end of Phase II.

(2) During this phase, the product/groundwater recovery and treatment system must remain in place and intact in the event that it needs to be reactivated.

Reporting: The results of monitoring "key wells" must be submitted on a quarterly basis.

Approval: After 1 year of monitoring under non-pumping conditions, the Department will determine if the system must be reactivated, if it can be removed, and/or if any additional monitoring is required.

Z. SUBSURFACE PETROLEUM CONTAMINATED SOILS ASSOCIATED WITH THE IMMISCIBLE PLUME IN AREA 2

General Dynamics muat submit a feasibility study to evaluate appropriate remedial/cleanup actions for petroleum contaminated soil associated with the immiscible plume in Area 2. As indicated by GZA in a letter dated August 18, 1987, this study will be completed in approximately 3 months.

C. SURFICIAL PETROLEUM CONTAMINATED SOIL

Surficial petroleum contaminated soils at the shipyard proper and on off-site properties, previously identified by the Department during a field inspection with Mr. Ed Willwerth of General Dynamics, must be excavated and removed from the site to an approved facility for 6

disposal or reuse. If such soil Is found to be extensive and excavation becomes infeasible, a more feasible remedial option must be submitted to the Department for approval.

D. POLYCHLORINATED BIPHENYLS -To date, all soil found to contain polychlorinated biphenyls (PCBs) at concentrations greater than 40 ppm has been removed from the site. The Department has determined that soil remaining at the site at concentrations less than 1 ppm PCBs does not require any type of cleanup. However, soil remaining at concentrations greater than 1 ppm and less than 40 ppm must be capped with a minimum of 10 inches of clean, compected soil as previously proposed by GZA and a deed notification must be made to prevent future disturbance of these areas without DEQE approval. General Dynamics has recently agreed to remove soils containing-PCBs at concentrations greater than I ppm to an approved disposal facility. For PCI contaminated concrete pads at the site, the Department has established a cleanup requirement of 100 ug/100 aq cm. This level was obtained from the existing Federal Regulations which state that for decontaminating spills in areas with "restricted access" and where the contaminated surface is a "low contact outdoor surface", cleanup is required to 100 ug/100 sq ca. In the instance that this level is unachievable, the surface must be properly sealed and a deed notification must be made. E. Mineral Spirits Mineral spirits were observed in one area of the site where two subsurface storage tanks were formerly located (south and east of building 26). Based upon the results of groundwater aampling/analysia conducted in this area, the Department does not enticipate requiring any remedial/cleanup ections at this time. However, additional groundwater sampling/analysis vill be required to insure that contaminant levels are decreasing over time. F. Solvents

There are four areas of the site where elevated levels of chlorinated solvents were observed, namely: (1) south of building 77, (2) the area of the immiscible petroleum plume, (3) the area west of building 57, and (4) the southern boundary area. Excluding the southern boundary, which will be discussed in more detail in Section II(K) of this letter, the Department does not anticipate the need for any remedial/cleanup actions at this time. However, additional sampling/analysis will be required et selected locations to insure that contaminant concentrations are decreasing over time.

G. Acid/Base Neutrals

Acid extractable compounds were observed in one water sample from a well located in the southern boundary area. 7S

Base neutral compounds were observed in groundwater from the southern boundary area and the hazardous waste staging area. Base neutrals were also detected in soil from one of the offaite parking lots and the pipe shop laundry (BIdg. 8).

Excluding the southern boundary area which will be addressed in Section II(K) of this letter, the Department does not anticipate requiring any cleanup at this time. However, additional groundwater aampling/analyais will be required particularly in the area of the Immiscible petroleum plume. B. Asbestos Based upon the historical use of asbestos throughout the shipyard, several soil samples were obtained from selected locations for analysis. No detectable levels of asbestos were observed in any of the samples. Therefore, the Department does not anticipate requiring any remedial/cleanup actions at this time.

In addition, General Dynamics has submitted a July, 1987 report by ERT regarding the location, condition, and remediation of asbestos lagging. The Department's Division of Air Quality Control/Asbestos Section will review and respond to this submittal under a separate cover.

I. Metals

Soil and groundwater samples from across the site were analyzed for the Priority Pollutant metals. Based upon the results of this analysis, the Department does not anticipate requiring any remedial/cleanup actions at this time.

J. OFFSITE PROPERTIES

There are several properties outside of the shipyard proper where no subsurface investigation was conducted based upon the results of a Phase I assessment (including a historical literature search and visual inspection) which indicated that these areas were never industrial is nature. Since there is no information to indicate that there has been a release of oil/hazardous materials in these areas, the Department cannot require any additional work at this time.

K. Southern Boundary

There are two properties that abut the General Dynamics' southern boundary area, namely: Citgo Braintree Terminal and Clean Harbors of Braintree, Inc. Preliminary information submitted to date by General Dynamics indicates that the contaminants observed in groundwater at the boundary area are likely from an off-site source. However, the Department feels that there is insufficient information available to clearly characterize this area. The Department will pursue this matter with the adjacent property owners as well as General Dynamics.

III-. ADDITIONAL DEPARTMENT REQUIREMENTS a

The following is a list of Department requirements.,for additional confirmatory information. These requirements have been numbered sequentially to facilitate your response.

1. Identify the compounds stored In aboveground tanks in building 8 (the pipe shop laundry) and confirm that the analysis conducted on samples from MW 1114 was appropriate to detect thase compounds.

2. Explain the alevated level of total patroleum hydrocarbons In MW 1113, 1116, 1117, and 1118.

3. Idantify the chemical(s) atorad It undarground tanks west of building 2 and west of building 12 and the appropriate analysis to detect such compounds.

4. Identify the compound(s) atored in underground tanks located in the current shape 'storage area and the appropriate analysis to detect such compounds.

5. Identify all wall head elevations.

6. Submit the results of screening soil samples from Area 5.

7. Confirm that all remaining above ground storage tanks have been drained and cleaned and associated piping disconnected, drained, and sealed off or decommissioned.

8. Confirmatory sampling must be conducted on all areas where cleaning has occurred for PCB's (soil and concrete pads) to insure that what remains is in conformance with Department requirements as per section II(D) of this letter. Actual laboratory data sheets must be submitted.

9. All stockpiled soil associated with the removal of several underground tanks, if contaminated, must be removed to an approved facility for disposal or reuse. Uncontaminated soil may be reused onsite subject to Department approval.

10. Submit all information relative to tlie newly discovered subsurface tank undir building 45.

11. Provide the Department with a report detailing site surveys or Investigations addressing licenses from the Nuclear Regulatory Commission, or other appropriate agencies regarding nuclear materials which may have been used, stored, or otherwise handled at the.site.

12. A groundwater sampling/analysis plan must be prepared to confirm previous monitoring results from across the site. This plan must include the requirements of Sections II(E), 11(F), and 11(C) of this letter. 9

These requirements are the result of the Department's review to date of the existing site assessment. Please be advised that the Department is still in the process of reviewing the extensive assessment and as such may have additional requirements in the future with respect to such assessment. General Dynamics has agreed to respond, without waiver of its rights, to all such Department requirements even in the avant that the property is sold.

The Department's detarmination in 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 informatiob comes to the attention of the Department.

The conclusions set forth in this letter are based upon information subm'.tted to the Depsrtment in reports identified in Section I and therefore'should not be relied upon without further review should the reports have any omissions or misstataments.

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

ory tru yo ,0

Richard J. Chalpin Deputy gional Environmental Engineer cc:

DEQE, 1 Winter Street, Boston, MA 02108, Attn: Madeline Snow, DHW, 5th Floor Quincy Board of Health, 1120 Hancock St., Quincy, MA 02169 Ms. Laurie Burt, Foley, Boag & Elliot, Ode Post Office Square, Boston, MA 02109 * Mr. Lawrence Feldman, Goldberg Zoino & Associates, The Geo Bldg., 320 Needham St., Newton Upper Falls, MA 02164 Ms. Beji Malek, Cities Service Oil and Gas Corp., 110 West 7th St., Box 300, Tulsa, OK 74102 Hr. John Grabowski, Citgo Petroleus Corp., One Warren Place, Box 3758, Tulsa, OK 74102 Mr. Alan McKim, Clean Harbors, Inc., 325 Wood Road, Braintree, MA 02184 -fwa?!Z//6////

recac Cc MIr/~ (:rninn4a L

r/dmen/ vu('on nern/a/ &ua/r2y Jybicrrnr

Tioma; c McManor. Director

July 6, 1988

Leigh Bridoes, Director RE: Weymouth Fore River - Division of Marine Fisheries General Dynamics Shipyard 100 Canbradcc S-reet (Fore River Shipyard) Boston, MA 02203 Dear Mr. Bridges:

Within the week DWPC will be transmitting a report to DE for your review and comment, the report being titled: Review of NUS Quincy Shipyard Site Assessment, prepared for General Dynamics (GD) by Goldberg - Zoino & Associates. The report was recently submitted to DEQE's Division of Hazardous Waste/Office of Incident Response as part of GD's 21E Superfund Site Assessment and Remediation Plan for the Quincy site (now owned by MWRA and known as the Fore River Shipyard).

The remediation of this site is extremely important to DEQE for two reasons: (1) the shipyard is a critical element of the Boston Harbor Cleanup Plan and, (2) potential impacts of site contamination on the Weymouth Fore River and its fishery resources. Since this report comes on the heals of the EPA Quincy Bay Study and also uses flounder, shellfish and lobster as its indicator and impact species, it will be viewed by some as an aspect of tnat study. Throughout the fishery consumption impacts portion of the report (beinning on page 26) there are numerous references to DMF reports, unpublished data and personal communications. The Department does not want to complete its review of this document without checking with DMF to ensure that there hasn't been any misuse or misunderstandings of the information provided by DMF.

Mr. Lipman of my staff will be contacting you in the near future to arrange a mutually convenient time to meet with you to discuss this report and develop a timeline for review and comment of this report. As background, I have included a document recently prepared by Mr. Lipman regarding the shipyard site and interactions with the 21E program. -1-

Unfortunately, we are cn a very tight timeframe for the review of this report, and would greatly appreciate your expedited review of this document.

Very truly yours,

Thomas C. McMahon Director TCM/SGL /sf (417) cc: Sharon Gerolamo, DEQE/DHW Carol West, ORS Michael Murphy, ORS Bob Bois, DEQE/DHW Jicin V. Sm/C b~c of tbc

tLC Sj/J - 33ouse of i&rpresrntatiuss t Se6a4 t$/ur &v&k2(&kIdafs BRIAN DONNELLY October 28, 1937 MASSACHUSETTS ELEVENTH DISTRICT

Mr. Michael R. Deland Regional Administrator Environmental Protection Agency JFK Federal Building Boston, Massachusetts 02203 Dear Michael:

Thank you for your recent letter concerning my request that a Preliminary Assessment of the Quincy Shipyard be completed. I appreciate your prompt attention to my request.

I had been aware that the Massachusetts Water Resources Authority had retained a firm for discovery and analysis of hazardous waste at the Quincy Shipyard. Although I certainly do not wish to impugn the motives of any party involved, I'm sure you understand my concern that there be no potential for conflict of interest during the initial assessment of the site. The prospect of a conflict of interest could be raised in the eyes of the public when the owner cof the site is responsible for the hazardous waste assessment. I urge you to use great diligence in monitoring the work contracted for by MWRA. Additionally, I am curious to know if there is precedent for this action. If possible, please provide me with a list of instances where the owner of a suspected hazardous waste site was allowed to conduct the Preliminary Assessment. More specifically, is such a procedure precedented.

Thank you for your attention to my request, Michael, and thank you again for your prompt response.

With warm regards, Sincerely,

BRIAN DONNELLY Nov; Z 1981. Member of Congress

BD/ trb

438 CANNON HOUSE OFFICE BUJLOING 2307 JOHN F. KENNEDY FEDERAL BUILDNG 47 WASHINGTON STREET 61 MAIN STREET TOLt FREEUNE TO WASHINGTON. D C 20S15 BOSTON, MA. 02203 QUINCY MA 0216- BROCKTDN. MA 02401 WASHNGTON 12021225-3215 1671 2234038 (617 .2 18M 16171W 6 0 I " 4249112 UNITED TES ENVIRONMENTAL PROTEC@N AGENCY

REGIONI

J.F. KENNEDY FEDERAL BUILDING, BOSTON, MASSACHUSETTS 02203-2211

October 21, 1987

Honorable Brian Donnelly House of Representatives Washington, D.C J 0515 Dear Mr. nl

Thank you for your letter of September 23, 1987 to Merrill Hohman, Waste Management Division Director for Region I, requesting a Preliminary Assessment of the Quincy Shipyard property. As you know, a Preliminary Assessment is generally an initial evaluation of a site based on existing information such as data concerning site management practices, review of land use data from local planning agencies and review of geological, hydrological and topographical data available from federal, state and local institutions. The Massachusetts Water Resources Authority has informed us that it intends to commence an extensive study of the site to determine the nature and extent of whatever hazardous materials may be present there. This study is scheduled for completion within the next six months. In light of the fact that this sort of study provides precisely the type of data EPA typically employs in conducting a Preliminary Assessment, and that the study is scheduled for completion in the near future, I believe it makes sense to await the result of the study before determining what steps would be appropriate for this office to take.

Your Office will be kept informed of any actions considered by the Agency. If you need any further assistance, please contact me, or have your staff contact Betsy Horne of the Office of Government Relations and Environmental Review at (617) 565-3414. Sincerely,

Michael R. Deland Regional Administrator cc: S. Russell Sylva 'V >0 444.4 I\- K. I i (0' 5AChWWIZWZZ/YV ~

6tca~&gpa#&wownrd9 S. Russell Svlva Commissioner 4nrne $ nt6 men Sc/forua0.< (617) 292-5851

MEMORANDUM t ~

TO: James C. Colman, Director, OIR

THRU: Edmond Benoit

FROM: Madeline Snow

DATE: October 13, 1987

SUBJECT: General Dynamics/Quincy Shipyard The Department's Position on Taking a Lead for Further Actions

Congressman Brian J. Donnelly, through a news release on September 24, 1987 has expressed a desire to place the above on the NPL. (copy of article attached). The Department, through our Northeast Region Office has been actively working on this site. General Dynamics has been issued two notices of responsibility under MGL c. 21E since January 1985, and has hired GZA to carry out environmental studies on the site. As a result of about nine study reports by GZA and ERT, the Department has identified and evaluated the type and extent of contamination on- site as well as off-site. General Dynamics has responded to our notices and is in the process of carrying out remedial actions and under our technical direc- tive providing further data per our requirements for further evaluation. In light of this fact and MWRA's involvement on this site, this is and should remain a DEQE -lead site under 21E.

Because of changes being made in the nomination process, as required by SARA, EPA Region I is not accepting any new non-federal sites for nominating until after the next two updates of the NPL (in November and March of 1988.) During the course of continued and detailed site investigation, this site may eventually be scored to check its eligibility for nomination to NPL by applying EPA's MITRE model of the Hazard Ranking System, because this model is in the process of revision and a new HRS model will not be available for application before the middle of the next year. If the site scores the Department could decide at that time, based upon the situation then whether to nominate this site to NPL and have EPA take the lead or to continue with the DEQE-lead. -2-

In view of the fact that this site was operated under contract and even by the federal government during (WWII) there is some thought it may be considered a federal facility. In addition, if MWRA owns the site, its status could be interpreted as a state owned facility if it were on the NPL. We believe that, for these reasons, the legal office should get involved in this site. The situation is further complicated by purchase and sales agreements alluded to in the press which supposedly say MWRA will assume responsibility for contamination 6 months after they buy the property. We are trying to find out more details about this.

Encl. A copy of press release of Rep. Donnelly's public statement; dated September 24, 1987.

A copy of ERic Schwarze's (Patriot Ledger) comments on the property transfer dated September 24, 1987.

A copy of the Department's letter to General Dynamics dated September 20, 1987.

HP/sc

cc: Anne Bingham S&Russell Sylva 4 W/9 Commissioner (617)292-5851 ~'~~<~~

MEMORANDUM

TO: To The Files

FROM: Harish Panchal

DATE: October 8, 1987

SUBJECT: General Dynamics/Quincy Shipyard

This memo is to address cleanup responsibilities legal implications and our Departments' position with respect to a recent purchase of the Shipyard by our sister agency MWRA and Congressman Brian J. Donnely's public statement stating that "this site should be placed on NPL." (A copy of the press release is attached.)

A letter from our Northeast Region Office (copy attached) dated September 20, 1987, to General Dynamics explains in detail, the type and extent of contamination as observed to date, remedial actions already in progress and further actions required for additional confirmatory information.

Cleanup Responsibilities: To what extent General Dynamics, as a previous owner, is going to accept the responsibility of cleanup after the property is sold is relatively unclear at this time. However it seems that General Dynamics has agreed to cleanup whatever contamination that is noticed as a result of a six month study, assessment and evaluation of the site (effective September 23, 1987.) to an industrial standard - a standard that our Department has to decide considering its future use, risk assessment level, potential threat to public health and the environment, weighed against the cleanup-cost. As it appears from the press release, whatever contamination that may be noticed after this six months study period, it will be the responsibility of M4WRA to cleanup such contamination and whatever deems acceptable to the standard set forth by our Department. (Our office is awaiting a copy of the purchase agreement for a clear interpretation.) At this time our Department does not anticipate any future difficulty in assigning or delineating moral, financial or legal responsibilities, as all the sections of MGL c. 21E as amended are very well defined. General Dynamics have already been issued two notices of responsibilities under MGL c. 21E on January 14, 1985 and October 21, 1986 by our Department and they have responded to both of these. It may be useful to know that our Northeast Region Office is aware of the current development and actively working on this site. -2-

Legal Implications: The purchase of Quincy Shipyard by MWRA is likely to develop some legal implications which are important to consider ahead of time. In the first place it is imperative that we interpret each and every clause of the agreement in the correct legal term. This may help our Department to draw a line, should any ambiguity or confusion arises in delineating responsibilities for remedial action between General dynamics and MWRA. There are reports that MWRA wants to utilize this site for remedial actions and cleanup activities for remediating the Deer Island and Nut Island sewage treatment plant. It is possible that our Department may have different position with MWRA on the Shipyard as a responsible party whereas different one on cleanup of the sewage treatment plants. It is also possible that some political forces may try to push this site to the National Priority List. (It is a very long process and the Department is not sure if that happens.) in that case, the Departments' position will be different as MWRA is one of our sister agency. Eventhough Quincy

Shipyard was a base for many activities under different defense contracts, there is no documentation available at this time to indicate that this can be regarded as a Federal facility. *Considering all the above possibilities, it is the Department's position that it is imperative to involve our legal staff on this site. *Clean Harbor of Braintree abuts the site on the Southern boundary, where GW contamination is found due to an off-site source.

Congressman Donnelly's Press Statement: With respect to Rep. Donnelly's views regarding placing this site to the National Priority List, it is the Department's position that it is premature at this time to imagine any such possibility. As indicatd earlier in this memo, the Department is constantly working on this site and has already defined the necessary actions pertinent to our regulations, applicable and relevant to the type of contamination found present until this time. General Dynamics has agreed and responding by taking remedial actions as per our technical direction and under MGL c. 21E. However the main criteria, that governs any site to be nominated for NPL i.e. the Hazardous Ranking System is being revised. EPA has released a draft version of this model which is in circulation for review and comment. After receiving comments from environmental and other related agencies and public group, nationwide, EPA will publish a semifinal draft which will be open for public comments This draft will become a final model after incorporating the necessary comments at the end of the comment period. The Department will then be able to score the site applying this model to the site conditions. The site will then be eligible to 4PL be placed on MPH if it scores above 28.5. until this time, the site will continue to be addressed by our Department under MGL c. 21E. eptember 23, 1987 af ~cpesetatgs Mr. Mel Hollman LU V Superfund Director BRIAN DONNELLY U.S. Environmental Protection Aaencv MASSACHUSETTS Region I ELEVENTH DISTRICT 2203 J.K.F. Federal Building REGION I Boston, Massachusetts 02203 WASTE MGMT. DIVIISION Dear Mr. Hollman:

The Comprehensive Environmental Response, Compensation and Liability Act ("CERCLA") of 1980 requires certain actions by the EPA when there is a release to the environment of "any pollutant or contaminant which may present an imminent and substantial danger to the public health or welfare."

Consistent with the discovery section of the regulations implementing CERCLA (40 CFR 300-63), I am writing to inform you that based on my personal knowledge and belief, the property located at 97 East Howard Street, Quincy, Massachusetts (commplly known as the "Quincy Shipyard") is a potential hazardous waste site. Therefore, I request that pursuant to 40 CFR 300.63 (d) (1), a preliminary assessment of the site be undertaken.

The property in Quincy to which I refer has been used for over 100 years as a shipyard. During that time, lead paint, asbestos, oils .lubricants and chemicals were used in the shipbuilding process. I think that these facts form a logical presumption that the shipyard or portions of it are possibly a hazardous waste site.

Let me stress that I expect that this assessment will be thorough, consistent, and completed in a expeditious manner. As you are aware, section 310 of CERCLA grants standing for citizen suits to be brought against any federal governmental official that fails to perform any noiliscretionary duties under the Act. I fully intend to avail myself of all legal remedies to insure that the provisions of CERCLA are enforced.

Please advise me of your planned action oni this matter, and your proposed timeta-i* , through my Washington office. I am also bringing my concerns to the attention of the Massachusetts Department of Environmental Affairs.

Thank you for your attention to this matter.

Sincerely,

BRIAN DONNELLY Member of Congress AM CANNON HOUSE OFFICE BUILDING 2307 JOHN F. KENNEDY FEDERAL B LDiNG 47 wASHINGTON STREET 61 MAIN STREET TOLL FREELINE TO WASHINGTON, D C. 2051 BOSTON. MA. 22 OUINCY, MA 0216E BROCKTON, MA. 02401 WASHINGTON =22 225-3S (617) 223O7] 161714 72 1IH (6171SU C"0 1-9WJ 424 9112 Sl ;eCn0m al. Iinc. . t

April 24. 2003

GZA File No. 11930.82-C

Nis. Sharon Gobiel Department of Environmental Protection Northeast Regional Office 205 Lowell Street Wilmington. Mlassachusetts 01887

Re Deconmissioning Activities Central Yard Oil Plume Area Quincy/Fore River Shipyard Quincy. Massachusetts RTN # 3-0536

I \\A -1 - - l Dear Ms. Gohiel: 1 i- , ' '

On behalf of General Dynamics Corporation (GD), GZA GeoEnvironimental, lic. (GZA has prepared this letter to inform vou that decommissioning activities associated With the Central Yard Oil Plume (CYOP) reimedial system, and nKIitoring welk across the shipyard property, are scheduled to occur in the near future. These decommissioning activities are tentatively scheduled to begin during the first half of May 2003, and are expected to he completed this sunier. We will notifv the Dcpamtwii once the decoimuissioning has been conpleted.

As alvays, we appreciate your continued assistance with this project. Please feel free to contact mL at (508) 755-1700 if you have any questions.

Ver truly vours.

GZA GEOENVIRONM ENTAL, INC.

C-. K-.

Lawience Feldman. LSP Senior Principal

Cc: Kristin Fletcher, GD Laurie Burt, Esqj., FH Stephen Pitrowski, GZA

1 IEl0 /( )Y 1% 4f 5 I\ idN 'kkl-.sPL fl) -Notki in II Systeu I tunauii Apl . tol i

\n I - I 1111-r!Ir i , I i \l T \ F I OFFICE OF THE COUNCIL UINCY D.\\itai G. Rm\ i

Dear Ms. Gobiel: RE: FORE RIVER SHIPYA RDOQINCY. MA

I am writing to you as the Chair of the Fore River Redevelopment Committee. The Committee includes Massachusetts State Representatives, local elected officials, civic, neighborhood and planning officials from the communities of Quincy, Braintree and Weymouth, who are interested in re-establishing the prominence of the Fore River parcel as a major contributor to the economy of this region. I am enclosing a copy of the City of Quincy resolution establishing the Committee together with a copy of correspondence from the Executive Secretary of the Braintree Board of Selectmen regarding the Town of Braintree's support for the creation of the Committee. As perhaps you are aware, in 2002 the United States Maritime Administration seized control of the Shipyard and on January 16, 2003, at auction, car dealer Daniel Quirk was the high bidder.

I am writing to request your attendance at the next meeting of the Committee which is FRIDAY, A PRIL 11, 2003, at 10:00 AM, A T THE SOUTH SHORE CHAMBER OF COMMERCE BUILDING, 36 MILLER STILE ROAD, QUINCY. Your appearance would assist the Committee in better understanding the following:

" What are the environmental issues at the site that are within the jurisdiction of the Massachusetts Department of Environmental Protection? " What input does the community have regarding the cleanup of the site? " What input does the community have regarding any agreement that the Government may enter into with the new owner of the Shipyard? * What other Government agencies are involved in the cleanup of the site?

Your prompt attention to this request is appreciated. If this date is not convenient for you, will be more than pleased to arrange for another date that may be more conven nt. Thank you foryour cooperation.

Sincery,

Daniel G. Raymondi f COUNCIL PRESIDENT and CHAIRMAN FORE RIVER REDEVELOPMENT COMMITTEE jr Enclosures QY- Gt City Hall, 1305 Hancock Street, Quincy, MA 02169-510 2 (617 376- 3 i 1w)(AIt ti&Ydnflo of cAr C 1 I calltGj *Y INR E WARD TW COUNCILLOR DANIEL G. RAYNWNDI INTRODUCED BY

CITY OF QUINCY IN COUNCIL

ORDER NO. 2002-011 January 22, 2002 ORDER E SOLUTION ESTABLISHING FORE RIVER REDEVELOPMENT COMMITTEE

Whereas, the residents of the towns of Weymouth and Braintree and the City of Quincy are justifiably proud of the great tradition of shipbuilding at the Fore River Shipyard, and

Whereas, the closing of the Shipyard more than a decade ago not only had a dramatic and negative effect on our local and regional economies, but more importantly, our families suffered as employment opportunities were denied to thousands of workers, and

Whereas, recent efforts to revitalize the Yard have not been successful to date, and

Whereas, the citizens of Quincy, Braintree and Weymouth are looking for leadership on this issue, we need to look to the future. We need a master plan for the redevelopment and revitalization of this most significant asset, and we need to create a regional planning mechanism to achieve our goal.

NOW, THEREFORE, BE IT RESOLVED THAT THE QUINCY CITY COUNCIL HEREBY ESTABLISHES THE FORE RIVER REDEVELOPMENT COMMITTEE. SAID COMMITTEE SHALL CONSIST OF THE FOLLOWING FOURTEEN (14) MEMBERS:

State Representative Joseph Sullivan, Fifth Norfolk District State Representative Ronald Mariano, Third Norfolk District Quincy City Councillor Daniel Raymondi, Ward Two Quincy Director of Planning & Development, Richard Meade Braintree Board of Selectmen Chairman, James Casey Braintree Director of Planning & Conservation, Peter LaPolla Weymouth Planning & Economic Development Director, James Clarke Quincy Point Business Association President, Thomas O'Brien Quincy Ward Two Civic Association President, Zaida Shaw East Braintree Civic Association, Representative South Shore Chamber of Commerce, Representative South Shore Building Trades Council, Representative Quincy 2000 Corporation, Representative Quincy Mayor Phelan's Representative.

ADOPTED IN COUNCIL JANUARy 22, 2007 APPROVED ATTEST: 2S 2002 CLERK OF COUNCIL

YEibh ail, Connolly, Coughlin, Finn, Gutro, Hanley, McCauley, Newton, Raymondi

NAYS Cahill, Connolly, Coughlin, Finn, Gutro, Hansey, McCauley, Newton, Raymondi EXECUTIVE SECRETARY OFFICE OF SELECTMEN Teri S. Ackerman James M. Casey Chairman

David M Shaw TOWN OF BRAINTREE Vice Chair-man ONE JFK MEMORIAL DRIVE BRAINTREE, MASSACHUSETTS 02184 Leland A. Dingee TELEPHONE: 781-794-8 UD FAX. 781-794-8128 Hawold J, Randolph Alfred W. Varraso

January 30, 2002

City Councilor Daniel Raymondi Quincy City Hall Quincy, MA 02169

RE: RESOLUTION SUPPORTING THE ESTABLISHMENT OF THE FORE RIVER REDEVELOPMENT COMMITTEE

Gentlemen:

This is to advise you that at their January 28, 2002 Board of Selectmen meeting, the Board voted to support the Resolution Establishing the Fore River Redevelopment Committee established by the Quiney City Council.

Very truly yours,

Tern S. Ackerman, Executive Secretary

ApLerovai BOS S

(cIi\ li~llldll llc. 5 : ME

Marcli 26, 2002 GZA File No. 11930.82-C'

Ms. Siarol Gobiel Deparmnit EInviromnental ProtectionI Northeast Reeional Office 205 Lowell Street Wilmingiton, Massachusetts 0 1887

Re: Notilication of Post- Rciiediation Contiratory Monitoring Central Yard Oil Plume Area Quincy/Fore River Shipyard Quiricy, Massachusetis RTN # 3-0536

Dear Ms. Gobiel:

N 1 On behalf of General Dynamics (GD), GZA GeoEnvironiental, Inc. (GZA) is pleased to SI\\I V-, advise you and the Massachusetts Depanrment of lnvironmental Protection (DiP) that we have initiated confiniatory monitoing to verify that the remedial goals ti the Central Yard Oil Plune (CYOP) area of the Quincy/Fore River Shipyard have been achieved. Specifically, the pulse pumping and bioventing remedial system has been shut down for an indefinite penod of time to allow GZA to conduct post-reimediatioii confiinnatory niiitorling for separate phase hydrocarbons (SPH) in the CYOP area.

A remedial system has been operating essentially continuously at the Site since 1986, with the exception of brief shutdowns for system maintenance and/or inonitoring, a brief shutdown for system modifications in 1999 (see our March 2000 Completion Report on Renrdial System Modifications report), and scheduled shutdowns during "pulsed off' cycles with the existing pulse pumping and bioventing rentdial systen

Notification of Post- Reimediation Confirmatory Monitoring

On October 25, 2001, the pulse pumping and biovent systems at the CYOP were turned off for a scheduled "pulsed off' cycle. The results of the first round (taken on November 2, 2001) of SPH thickness measurements taken following shutdown indicated that less than 2 inch of SPH was present in each of the surveyed wells within the CYOP. Since this shutdown, the system has remained off and five additional rounds of gauging data under static conditions have been collected, each indicating that the average thickness of SPH in the CYOP area wells is below h inch. The results of these six gauging rounds are presented in tabular form as an attachnrent to this letter for reference The first three of these gauging tables were presented in the latest Monitoring Report #123, submitted to the DEP in Januarv 2002.

Given the limited residual thickness of SPH in the CYOP, and the limited SPH recoveries experienced recently, it is GZA's opinion that substantial quantities of recoverable SPH do not exist at the Site. Moreover, conditions for a Pennanent Solution with respect to 310

I L , , ' I ri ,- \rj \ II Department of 1-onmental Protection 0 March 26, 2002 RTN # 3-0536 Pace 2

CMR 40.0996 (i.e., less than 12 inch of SPH) have been indicated during our recent Surveys. It thus appears that the pulse pumpiing aid bioventing remedial systm ihat was implemented in August 1999 by GZA to augiient the existing reniedial system' has attained the remedial coals for SPH in the CYOP. Accordingly, GZA reconiiids that the CYOP svstem remain off indeintely to allow continued ninitoring for SP. In accordaicc with recent DEP guidaice (implementation of the MADEP VPH/EPH Approach - Final Draft, June 2001, Section 4,6), the monitornug will he perhnned lor a full hydrologic Cycle (i.e., OIe yar from the October 25, 2001 shutdown) to confinrm that the SPH1 cleanup cr1't coals (i.e., less than h inch average thickness of SPH) in the CYOP have been attained. Ie nonitoing will be conducted on a monthly basis to provide sufficieti data points with respect to valying groundwater elevations iII support of Site closure under the MCP.

Sihoua ld the cointinued oririn ing indicate the rcappeanne of an avcrage SPlI thickness ureater than H inch in the CYOP, or should other data he observed indicating the ieed for continued oil recovery (e.g., migration of SPH to downgradient areas), GZA will resun operation of the pulse pumping and bioventing renedial system The renledial system has been and will continue to be fully maintained during the one-year monitoring period ir this scenario and nxmitoring reports will continue to be issued during this period.

As always, we appreciate your continued assistance with this project. Please contact aiv of the undersigned if you have any questions regarding this letter or the project in general.

Very truly yours,

GZA GEOENVIRONMENTAL, INC.

Stephen T. Pitrowski Albert Ricciardelli, PE roject Manager Senior Principal

Lawrence Feldman, LSP Senior Principal

Attachments: Gauging Sheets

CC: Daniel Keley (GD) Laurie Burt, Esq. DEP File

( U 19304ZY\0930-82 BvHDCORRFsSIMI) - MoonnNoc - M 200)2-final In DIEPdo

The pulse pumping and bioventing remedial systen was implemented to augment and accelerate remedmation of the SPH. Previous remediation involved more traditional methods (i e., continuous groundwater extraction and product recovery) and had reached asymptotic recovery levels after 13 years of operation since 1986. Project Naine General jInaincs

P'olecO Numnher 119 il 92

WELL MIONITORING FORM sHuICTle %IK licer Ile I| D2 MryI

ASt|MI D ( (1kHIl11) wl 1 1(I~ Illi law DI- I I MNDR(X Asill H 1I1- l/H ' )lI -it \\ [ ID1 l z0:P I T 1 1--\ R 1 10l1ARI111lI~N I-.S S RA\ 1)Y HI AD (feu I ((ee)(I IecT (tcti (ctI) 1 n li(eth e I 23 73 96.29 13.63 ND ND ND NA 82.66 + V' >17i 90(2 NM NM NA NA NA NA MW-C 12.4 90.26 8.15 ND ND ND NA 82.11 \* \ I k iksuil ikniiwn VM N 1 NA NA N A NA SMW- 22.65 100.26 17.72 N) ND ND NA 82.54 \ A 9997 17 1N- NI ND N-\ H \ Unknown Unknown 17,60 ND ND ND NA NA \ 268 9600 NM Mi NA NA NA NA M 9 19.40 94.54 12.98 ND ND ND NA 81.56 \1\\ Unkmn I nknown NM NM NA NA NA NA \ 17S55 95.13 11.96 ND ND ND NA 83.17 I5 3- 94 32 11 ) \D NDI) ND NA 2 ' + MW-i 3 Unknown Unknown NM NM NA NA NA NA + M\ I x 20.40 92.54 1H 10 ND ND ND NA Q 44 + MW-ISS 18.94 90.63 NM NM NA NA NA NA + W -II 14.36 9146 74 ND ND ND NA 82 7 MW-1I 27.73 100.80 17.67 ND ND ND NA 83.13 * 1 I 2S 47 100 9 17.9 17 94 001 1)12 0I8, 82 9G ' RW-1 A, 35.25 97.32 14.92 14.90 0.02 0.24 0.85 82.42 ' R\*- 29'") 96 1 127 13 2i 002 D24 0 8, C29 ' RW-3A\ 36.90 100.50 18.02 1798 0.04 0.48 0.85 82.51 * Ri )J w' I 9h ND ND NI) NA 12 - RW A 36.70 95.92 13.80 13.78 0,02 0.24 0 85 82 14 * R 10 33.01 98 4 l'9 179S 0 0 03 0 9X X()0SI RW - 34,55 96,38 13 81 13 79 0.02 0.24 0.85 82.58 ":\\ 2' s1 9692 14 29 ND ND NI NA K] 6 "RW- 28,60 95 96 14.65 ND ND ND NA 81.31 " 'A\ 2-.3' 98,2) 1b6 ND NI) ND NA 80 55 * RW-10 20.58 98.60 16.33 ND ND ND NA 82.27 " R\\- I 29.3i 98 83 1X.21 ND ND NJ) NA 8O62 ' RW-12 22.05 99.93 18.40 ND ND ND NA 81.53 + GD-il) Unknown Unknown NM NM NA NA NA NA + GD-1154 Unknown Unknown NM NM NA NA NA NA + GD-2 is 2 90 40 7 28 ND ND ND NA $3 12 * GD-2129A 30.40 100.40 17.67 ND ND ND NA 82.73 + GD-2133 Unknown Unknown NM NM NA NA NA NA * GD-2152 Unknown Unknown NM NM NA NA. NA NA * GD-21' 24.34 99.71 17.14 17.33 0.01 0.12 0 85 82 58 GD-2157 13.4 99.31 0.56 ND ND D NA 88.75 * 11 2158 1856 9918 17.04 ND ND ND NA 8214 * GD-9... ;2312 *40joo'j -V I.O . ND .,D 'ND - NA 82.80 * 4)-2268. 26.90 10084 17.81 ND ND ND NA 83.03 * GDP2OA Unknown .0NM-n!n -A . NA NA NA + GD-2270 Unknown Unknown NM NM NA NA NA NA + GD,2390A Unknown :Uaknon #NM NM -NA NA NA NA + GD-2391 Unknown Unknown NM NM NA NA NA NA + GD-2392 .16.32 90.51. 7.0 ND ND ND NA 82.61 + GD-2393A 15.29 S9.50 7.23 ND ND ND NA 82 27 + GD-2394 Unknown Uniown NM NM NA NA NA NA + GD-2395A 20.0 90.67 7.45 ND ND ND NA 8322 + GD-2396 Unknown Unknown NM NM NA NA NA NA + GD-2397 Unknown Unknown NM NM NA NA NA NA GD-27126 Unknown UnkopwD NmM. . -M NA NA NA NA * GD-27 2-2 Unknown Unknown 6.25 ND ND ND NA NA GD-27128 Unknown Unrinw 4 NM JA .NA NA NA GD-2750 2785 101.70 1823 ND ND ND NA 8347 OD-27tS2 Unknown I UnJE* ijla47 D _..: 1 NA * GD-2715 Unknown Unknown 1775 ND ND ND NA NA Total Average Hvdrocarbon Thickness (fcc) 0 Wi, 0 W, inches

Comniments N - Not Applicable Well on General Dynanic propeny included in hydrocarbon averagc ( gauged ND None Detected + Wcll in "Bents Creek" area included in hydrocarbon average if gauged NM = Nol Monitored TOC Top of Casing "Average" based on those wells gauged and included on this Form where oil has been detected and/or is within the ( YOP

GA 1930 zgyI1930 52 tivrlTatles\GD- GZA Gauging Data PosiShOTdown (Monanng 11.-01] 'rolet Name rnridal PyTumuni Pmjiei Niniber I 191) X2

WEL L MONIIORING FORM S iilii J I ti her Daue i 09001 W, Weatdher V Slun1 4'1 IM 'M I Di (I ) I I i

W I-II T ' JIYDR1) ARBON ',IIF(H(Il I/ l(I I R1k

W i I H 'I \ WIlI IR l IIIcROCANPHI1)' lil( KNISS XI%lIY III N te-t) ( fe (fe t lIe)c fee) (iches) (teet)

\tW- I 23.73 96.29 13.62 ND ND ND NA 8267 1u-2 17 902 NM \M N\ NA N\ NA MW-3C 12.54 90.26 8,07 ND ND ND NA 82.19 \iu I l'kn (se kimwnI NM N\l Nl NA N. NA MW-> 22.65 100.26 17.56 17.55 0.01 0.12 (1,85 82.71 \ln ' '#7 (.2) N I Nit NID NAx1 -' Uiknoiwn Unknown 17,60 ND NI) ND NA NA -. 'e 9 h o NM\ N\i NA NA N\ N: "I\k. 19,40 94.54 NM NM NA NA NA NA l\ I li knm I'TkiOi NM NM NA NA NA NA MW- 17.55 95.13 1 .75 ND ND ND NA 83.38 .X\' Is5 04.32 1| 29 N ) ND ND NA 83 01 MW-13 Unknown Unknown NM NM NA NA NA NA M -14A 20 4.) 92 54 9 1'1 9 10 0 01 0 12 0 S5 83 44 MW-ISS 18.94 90.63 NM NM NA NA NA NA MW -1c 14 .u 91 4h 9 75 ND ND ND NA R1I7) MW-I? 27.73 100.80 17.60 ND ND ND NA 83,20 I\\I1 2647 l0089 '.80 17 7> 0.01 0.12 it) s3 I o RW-IA 35.25 97.32 14.66 14.65 0.01 0.12 0,85 82.67 kr ' 20.00 961" 1 19 13 lI G01 0 12 118> 82'97 RW-3A 36.90 100.50 17.75 17,73 0.02 0.24 0,85 82.77 S .1 2S 4') 9?82 1. 8O ND NI) ND NA '1 4, RW-5A 36.70 95.92 13.65 13.63 0.02 0.24 0.85 82.29 \\ '1c 13 (i 9t 4c 1I 77 17 74 0 03 036 C S5 8(0 7? RW-6 34.55 96.38 13.67 13.66 0.01 0.12 0.85 82.71 N\\ \ 27 S0 9692 14.02 ND ND ND NA 8290 RW-8 28.60 95.96 14.35 ND ND ND NA 8L61 R\Wi 27.38 98.20 17 25 N ) ND ND NA 80.9s RW-10 20.58 98.60 17.89 ND ND ND NA 80.71 R\\ I [ 29.3 98.83 18 10 ND ND ND NA 80 73 RW-12 22,05 99.93 18.34 ND ND ND NA 81.59 GD 1 10 Unknown Unknown NM NM NA NA NA NA GD-I 154 Unknown Unkndwn NM NM NA NA NA NA

GD-2128 18 2 5 9040 747 745 002 024 0185 8295 GD-2129A 30.40 100.40 17.4 ND ND ND NA 82.76 (D-21 1 Unknown Unknown NM NM NA NA NA NA GD-2152 Unknown Uninown N0 NM NA NA NA NA GlD-21i 2434 9971 1694 1693 001 012 085 8278 GD-2157 13.44 /99.31 ..; 10.55. . ND. ND ND NA . 88.76 G1) 21 ?r 18 56 99.18 1664 ND ND ND NA 82.54 GD-2j59 . 23.12 ;0929 .(7 ND, ND ' ND NA 83.00 GD-2268A 26.90 100.84 1762 17.61 0,01 0.12 0.85 83.23 O41%IL Uknowa$gm S4W .- KNMo- NA .4WA NA . NA GD-2270 Unknown Unknown NM NM NA NA NA NA GD2S9O UnhjiliaJM En 241W NM xNA NA NA iA GD-2391 Unknown Unknown NM NM NA NA NA NA GD.232 16,32 90751 '492 ND ND ND NA 82.59 GD-2393A 15.29 89.50 7.45 ND ND ND NA 82,05 GD-2394 Unknown Unknown M NM NA NA NA NA GD-2395A 20 05 9067 760 ND ND ND NA 83 07 GD-2396 Unknown Unknown , , NM NM NA NA NA NA GD-2397 [Jnkncwn Unknown NM NM NA NA NA NA GD-27126 Unknown . Unknown N4 NM 'NA NA NA NA GD-2712 Unknown Unknown NM NM NA NA NA NA 0D-27128 Unknown . , . b . .M ,NA NA. :,WA --- A GD-27150 27.85 101.70 18.34 ND ND ND NA 83.36 GD-27012; - lnuir ' i .p 5M' : 4,lKKMSKYS ' .$MA GD-27155i Unknown Unknown NM NM NA NA NA NA Total Averaec Hvdrocarbon Thickness (feet 0 005 I 0 6 mches |

Comments NA - Not Appicable * - Well on General Dynamic property included in hydrocarbrnii average if gauged ND = None Detected + - Well in "Bents Creek" area included in hydrocarbon average if gauged NM - Not Monitored lOC Top of Casing "Average" based on thosewells gauged and included on this Foirm where 0il ha been deiected and/or is within the NYOPi

Gl 1930 zgtu 1930-82 ov'Tables'GD -G2A Gauoog Data - Pour Shuldown (Momiong 11-09011 'loyec i Name Gineral Dyimits Piioei Number I1J')41 2

WElL MONITORING FORM 1 nle i UINer

Weiaihe I I Ih 'lud iC

A' MHi iNliXDl) 0IR I11( 1) 5 1-II W IMPt'Il I DI P~ij o HlfDR0(M ARi )\ Sill 111( PI11/1IN1 kRI, WEi I I ap Ill:7[l) EI WAV IITR I IR0((ARI A I I( KNI: (,RA\ iY 1 Il)

1 fecii (fe) (lcI rt) (mnches) Ice)I I1 feet 4 (feez) o'cet) (feet)(fect) (left) (Inuile') MW1- 23.73 96.29 13.67 ND ND ND NA 8262 MN -' 17.9% 90.02 NM NM NA NA NA NA MW-3C 12.54 90.26 8.05 ND ND ND NA 82.21 \ - Inknown ('rknowi NIM NM NA NA NA NA M.- 22,65 100,26 17.43 17.425 0.005 0.06 085 82.83 m 'A 26A 1 99.97 16 35 ND NI) Nil '\ 'i-i I W-7 Unknown Unknown 17.32 Ni) ND ND NA NA \11 26 MX 96.00 NM NM NA NA NA NA MW 9 19,40 94,54 1141 NI) ND ND NA H3.11 '1' I inkin wn 1inkown NM NM NA NA Nx NA MWA.-I1 L7.55 95.13 12.36 ND ND ND NA 82.77 11\\ 1' I )D 7 94 32 1 05 it b44 00) 0 01)6 M., :7 MW-13 Unknown Unknown NM NM NA NA NA NA MW -IA 20.41 92.54 991 Ni) N) ND NA 2 6) MW-15S 18.94 90.63 NM NM NA NA NA NA MW -16 14.3, 91 4t x 90 8 h9 00i 0 12 05 2S I/ MW-I 7 27.73 100.80 17.34 ND ND ND NA 83.46 \M1 I 2S4' 10089 17 5 1 7. t 0 19 228 0 83 2o RW-1A 35.25 97.32 14.34 14.33 0.01 0.12 0.85 82,99 k% 2 29.00 9(1.1 13 26 NI) NI) ND NA M2K- RW-3A 36.90 100.50 17.52 17.50 0.02 0.24 0.85 83.00 ISO 4 28.40 9825 1,63 NI) NI) ND NA X1 61 RW-5A 36.70 95.92 13.15 13.14 0.01 0.12 0.85 82.78 R A 33.(H '4846 [- 6R 1762 0D6 0.72 n)85 MI) I RW-t 34.55 96.38 13.33 13.32 0.01 0.12 0.85 83.05 1- 27.5o 969 139 73 NI) NI) ND NA AI 19 RW-8 28.60 95.96 14,08 ND ND ND NA 81.88 I?% 2 7.3S 98.20 17.05 NI) NI) ND NA 61 i5 RW-IO 20.58 98.60 17,80 ND ND ND NA 80.80 MW11 29.3S 9883 1792 Nit ND ND NA 8091 RW-12 22.05 99.93 18.13 ND ND . ,ND NA 81.80 GD-1 110 Unknown Unknown NM NM NA NA NA NA GD-1 154 Unknown Unknown NM NM NA "iNA NA 'NA' GD-2128 18.25 90.40 7.88 ND ND ND NA 82.52 GD-2129A - 3.40 100.40 17.10 ND N 4A 83J0 GD-2131 Unknown Unknown NM NM NA NA NA NA GD-2132 Unlikown Unknown NM . MM ; A ; . . GID-21 24.34 99.71 16 71 ND ND ND NA 83.00 GD-2157 3344 '9921 . 1023 ND -R A 48AS 3D-21N8 18.56 99.18 1635 ND ND ND NA 82.83 Gl2159 . 3.12 100.0 37ND GD-2264\ 26.90 10084 1750 17-41 0.09 1.08 0.85 83.42 GD-220A Unknown Unlnowy 2 fl* "Z - ~ twb A:"Ai GD-2270 Unknown Unknown NM NM NA NA NA NA GD-290A. Udkoown' tlnknoln .. i NM ANA'T NA :NA GD-2391 Unknown Unknown NM NM NA NA NA NA NA . 1 - NA NA GD23.92 .16,32 90.51 r :" M GD-2393A 1529 89.50 79 75R 001 0.12 065 8192 GD-2394 Unknown Unknown 'NM NM 'NA "NA NA NA GD-2395A 2005 90.67 NM NM NA NA NA NA GD-2396 Unkiown Unknown NM. NM NA -4 NA NA GD-2397 Unknown Unknown NM NM NA NA NA NA ID-27126 Unkown Unknown INM NM NA -. ?MA-NA NA GID-2712-' Unknown Unknown NM NM NA NA NA NA GD47.128 jJJnknown Unlinfrn "NM NM GD-27150 27.85 101 70 18 10 ND ND. .$NMilWA.-: ND NA 83 A60 GD127152 Linknown Unk4w . hmM GD-271 Unknown Unknown 17.42 ND ND ND NA NA Total Average 11dirocarbon Thickness (fee) 01013 | 15 inches |

Comments: NA = Not Applicable * Well on General Dynaniic properly included in hydrocarbon acrage if gauged ND - None Detected + Well in "Bents Creek" area included in hydrocarbon average if gauged NM = Not Monitored TOC - Top of Casing "Average" based on hose wells gauged and included on this Fomi where oil has been detected and/or is witin dir CYOP

GO\1930 zgysi11930-82 DeqhTables;GO GZA Gau.gingData -Post Shuidown [Mionixog 12-06-011 0 0

PjecIt Namic icneral lnaunis Project Numhci IL)) J(1 [l cani Qun , ,lMs%^ helsi, WELL MONTORING FORM Saile. I telici Dat 0l 0 ?];0(1 Weathie1 laith' ( ohd. 4r'

A.S.l31- 1) ( ()RRHI ll) W H I0(' DHl'IH 1,1 DI11P11 to H)YDROCARk)t P].IR P MII1K( WYl- I rD DIePI'l I-.I .V 0.A IFR IIYDRi(AkON I IC11KNISS (ikAVI 11Y 11 AD (fe et) (ILcc ) ifIe) (feet) (fect) Itcnlic ) (fce0 MW-I 2373 96.29 13.05 ND ND ND NA 83.24 \n -2 17)6 9002 NN1 NM NA NA NA NA MW-3C 12 54 90.26 7.45 ND ND ND NA 821 I%\I ljokowr I Iknain NM NM NA NA NA NA M" 22.65 100.26 16.70 16.69 0.01 0 12 0.85 8357 264 )9t7 Isif ND NI) N N A A40 Unknown Unknown 16.64 ND ND ND NA NA 2o68 9? 00 NM NM NA NA NA NA \NW 19.40 94.54 1086 ND ND ND NA 83.6s i 1 I ist I /nknown N M NM NA NA NA NA M1 I 17.55 95.13 11l74 ND ND ND NA 83.39 _ 1/I5S 9432 1001 ND) NI) NI) NA 8$ 5 MW-13 Unknown Unknown NM NM NA NA NA NA MIW- 14A 2o) 40 92 54 9 35 NI) ND NI) NA 83 1) MW-15S 18,94 90.63 NM NM NA NA NA NA M161 14 36 91 46 9 20 ND NI) NA 83 21 MW-17 27.73 100.80 16.78 ND ND ND NA 84,02 \IS ]. 2141 I10( 9 17 14 17 0o) 0 58 C% $3 '74 RW-IA 35.25 97.32 13.87 13.86 0,01 0.12 0.85 83.46 P% 29.00 9615 [2 70 NI) ND) NI) NA X345 RW-3A 36.90 10050 17.00 16,97 0.03 0.36 0.85 83.53 IN\\ . 1 41 '98 2S 16 (IS NI) ND NI) NA A2 17 kW-SA 36.70 95.92 13.03 1302 0.01 0. 12 0.85 82.90 u Nil 33 111 9946 11996 1092 0104 04S SI 5 RW-6 34.55 96,38 16.36 16.35 0.01 012 0.85 80.02 INN -\ 27.50 96.92 1;20 ND ND NI) NA 8372 RW-8 28.60 95.96 13.54 ND ND ND NA 82.42 RN1 ) 27.38 98211 1650 NI) ND NI) NA l 70 RW-10 20.58 98.60 17.03 ND ND, ND NA 81.57 W -r] 293> 983 1717 ND N) NI) NA 81 66 RW-12 22.05 99.93 17.43 ND ND 'ND NA 82.50 G1D-1110 Unknown Unknown NM NM NA NA NA NA GD-1154 Unknown Unknown NM NM NA NA NA NA 0-2128 18.25 90.40 6.87 ND ND NI) NA 83 53 GD-2129A 30.40 100.40 16.51 ND ND ND NA 83.89 GD-2133 Unknown Unknown NM NM NA NA NA NA GD-2152 Unknown Unknown NM NM ;NA 'NA NA NA (Id) 24.34 99.71 16.57 1656 001 0.12 0.85 83.15 GD-2157 13.44 99.31 9.98 ND ND *ND NA 89.33 iD-2158 8 56 99.18 1583 ND ND NI) NA 83.35

' 7 GD-2159 .3.12a 400.0 l3 ~D~ t AID tCNP, NA .83.67 ' (iD-2268\ 26.90 100.84 16.83 16.81 0.02 0.24 085 84 03 * GD2269A .: Unioan 'TIdi i-NM $M, '-NA !A. NA 'NA

+ GD-2270 Unknown Unknown NM NM NA NA NA NA + GD-2390A- tUXknbwn 6n; N JM NM NA 5.SMA NA NA + GD-2391 Unknown Unknown NM NM NA NA NA NA

+ GD-2392 . 10 2.? .90.51' ',740 ND ND ID$ NA 83.11

+ GD-2393A 1529 89,50 NM NM NA NA NA NA

+ GD-2394 Unknown Uinown NM m NA .NA NA NA

+ (i)-2395A 20 05 90,67 7.09 NID ND ND NA 83 58

+ GD-2396 .Unknown Unkmown -NM- M NA

+ GD-2397 Unknown Unknown NM NM NA NA NA NA G-27126 Uukwn MSIR1n tMAt M -NA$1AA NA NA ' I)D-2' I- Unknown Unknown NM NM NA NA NA NA GD-27128 .Undkisp 3iS0 IM& , 4AMA A- .. A GD-27150 27.85 101.70 1747 ND ND ND NA 84 23 GD-22152C.MUi&i -i!Lab;. 4 GID-2755 Unknown Unknown 1696 ND ND ND NA NA Total Average Hydrocarbon Thickness (feet) 002 0 2: inches

Comments NA - Nol Applicable * Well on General Dyanbc property included in hydrocarbon ascrage I gauged NJ) None Detected + Well in "Bents Creek" areaincluded in hydrocarbon average if gauged NM = Noi Monitored TOC =Top of Casing "Average" based on those wells gauged and included on this Formi where oil has been detected and/or is within the CYOP

G 5 '930 zgA) 1930-82 bvti\Tables\GD GZA Gaugong DaLa.l'ost Shutdow [Monxtonng 0)-10-021 Project Namie General Dyiiarnn Project Nuinber I 1910 52 1 mOnJKIQumes. M.111,1huseCtt WVELL MONITORING FORM Isxpr J Ilahel

Weather 1rily ( ludv. 40,

A. lsI 1II) ( )RRI ll1) Wl !1, To( D]I-PT 1, MEl111 1, I Yl)RO( ARII IN P:(l1 IP/I' OMII J( 3H I IID DEI'I I FlI A I I IllYDRiAR)l 1IlCKNl:SS (;RA\ 11Y I EAD (Ieei (feel) (feel) (feel) (feel) (iclie ) (CC) I MW.I 23.73 96.29 12.78 ND ND ND NA 83.51 90 02 6 84 ND ND ND NA 8 Is MW-3C 12.54 90.26 7.02 ND ND ND NA 83.24 i . I I 1k1 n 1 Unknow T NIM 'i Ni NA N.1 NA NA MW 22.65 100.26 16.14 16.135 0.005 0,06 0.85 84.12 \ 2604 999 1 46 N ) ND NI) NA 51 I Unknown Unknown 16.03 ND ND ND NA NA 9600 NM N NI NA NA NA, N A \ - 19.40 94.54 10.23 ND ND ND NA 84,31 I nknown NI NM NA NA NAA NA M W 1 17.55 95.13 11.09 ND ND ND NA 84.04 \u 1 15.7 94,32 9 88 9'.5: ).01 0 12 4,05 84 43 MW-13 Unknown Unknown NM NM NA NA NA NA MW 14AA 204( 92 54 8 87 ND ND ND NA 83b7 MW-15S 18.94 90.63 NM NM NA NA NA NA MW- 14 31 91.46 7 98 NI) ND ND NA 83 4K MW-] 7 27.73 100,80 16.21 ND ND ND NA 84,59 M\\- I n 28.47 100.89 16.73 16 1 0.17 2 04 0 )5 84 it) RW-IA 35.25 9732 13.26 13,24 0.02 0.24 0.85 84.08 11w2 29 00 96 15 1203 ND ND NI) NA 84 12 RW-3A 36.90 100.50 16,38 16.37 0,01 0.12 0,85 84.13 44\ 4 28 40 98.25 15 55 NI) ND NI) NA 52270 RW-SA 36.70 95.92 12.51 12.49 0.02 0.24 0.85 83.43

R%%\\ 33.04) 98 46 16.37 NI) ND ND NA K209) RW-6 34.55 96.38 15.74 15.71 0.03 0.36 085 80.66 R\4 - 3 27.50 96.92 12.37 N I) ND ND NA 84.35 RW-S 28.60 95.96 12.79 ND ND ND NA 83.17 R\\ 0 27.38 98,20 15 94 ND NID ND NA 82 26 RW-10 20.58 .98.60 16.53 ND ND ND NA 82.07 RW . II 29.35 98 83 1660 ND ND ND NA 82 23 RW42 22.05 -993 16.95 ND .-ND ND NA 82.98 GD- 110 Unknown Unknown NM NM NA NA NA NA GD-l154 Uhinown Uuknowna NM NM ,NA NA NA NA GD-2128 18.25 90.40 6 79 ND ND ND NA 8361 OEI:9A ,.'40 I5.88 ND -)-D ND NA 84.52 GD-2133 Unknown Unknown NM NM NA NA NA NA rD, 52 - Ab6dii 1M5 -J4A "§NA -NA NA (ii)-21-.o 2414 99.71 1562 15,60 0.02 0.24 083 84 .[ NDp YNDA 89.1 GD-2lhS 1856 9918 15.24 ND ND ND NA 83 94 MA 820;.* GD-228A 26.90 100.84 16.21 ND ND ND NA 84.63 AA-lAA GD-2270 Unknown Unknown NM NM NA NA NA NA OO A .NA - NA 'NA NA GD-2391 Unknown Unknown NM NM NA NA NA NA tTNXNeO -t2.NA 83.35 Aw -NM, 2 GD-2393A 15.29 ljjabwu~.u.-4jN489.50 2. 5.88 ND ND ND NA 83.62 GnI4 4id1ibwn2'11 tain . NA )'NA NA NA 0D-239A 06Y~o~i~,MQV"AAIW_%7.'2005 9067 6.1 X.ND-:WMVND ND ND NA 83.86 IA ~&A NA NA NA GD-2397 Unknown Unknown NM NM NA NA NA NA NA GD1)-27127 Unknown Unknown NM NM NA NA NA NA NA / GD-27150 27.85 101.70 1701 ND ND ND NA 84.69

- Us .~I3M?~ 715$71 Unknown Ulnkntown 16.40 ND ND ND NA NA Unknown 1640 ND ND ND NA Total Average Hydrocarbon Thickness (fect 0 01 I 0 09 inches |

Comments NA - Not Applicable - Well on General Dynamic properly included in hydrocarbon average if gauged. ND = None Detected + - Well in "Bents Creek" area included in hydrocarbon average i[gauged NM = No[ Monitored TOC = Top of Casing "Average" based on those wells gauged and included on this Form where oil has been detected and/or is within the CYOP

G 11930 zgySi 1930-82 bvnTaNes GO - GZA Gauiong Data -Post ShUtdown [Mlioong 02-07-021 S 0

D Potjeci Name (eCral ynamis I'rojct|Ninnber I I 10 2 [. catm Quinen %s hm)

WELL MONITORING FORM .NAI 1 IltT J Hutcier IIst 031(1 2uii. Weair Nuim. 41)s

AH)) IMI I) ( ~RRl1 )10

W511.L (X DIIIil Dl.1111 io. IIY R(X)AkRIIN NPEl. l( PII)I/IOMI IRI( II10 DFI'III lLI.\~ s RI 1 Dki ARHiN I IIkKNI \S , IRA\tI) I Il-AD (feel) (fect deco (fect) I(fec 0 (im c s (feel) | MW- 2173 96.29 12.40 ND ND ND NA 83.89 MW 2 17"6 9002 142 ND ND ND NA HI) MW-3C 12.54 90.26 8.71 ND ND ND NA 81.55 \M\ I Unknown Unknown NNI NM NA NA N NA MW--' 22.65 100.26 15.83 ND ND ND NA 84.43 .. ' 6)h 9997 .5 190 ND ND N NA S4 7n Unknown Unknown 15.75 ND ND ND NA NA

\' ' 26(8 9600 NM NM NA NA NA NA MW-Q 19.40 94.54 10.04 ND ND ND NA 84.50 \ I''1- Unknown Unknown NM NM NA NA NA NA NM -1) 17.55 95.13 10,85 ND ND ND NA 84.28 11W 1' 15.75 94 32 '177 9 10 0 17 2 04 .1 94 60 MW-13 Unknown Unknown NM NM NA NA NA NA MW -14.A 20.40 92 54 S 61 N) ND ND NA X3 93 MW-15S 18.94 90.63 NM NM NA NA NA NA MW-lI, 1436 9146 '50 ND ND ND NA 83 96 MW-17 27.73 100.80 15.97 ND ND ND NA 84.83 \l\\ 1I 28 47 100.89 I6 7 16 31 0.40 4.80 0 i5 84 52 RW- IA 35.25 97.32 13,07 13.06 0.01 0.12 0.85 84.26 /5 29.0' 96.I 1 II1 7 ND ND ND NA 84 40 RW-3A 36.90 100.50 16.16 16.16 0.00 0.06 0.85 84.34 R) 4 284C 98.25 1> 19 15 1 0 01 0.12 0 85 83 1;. RW-5A 36.70 95.92 11.88 11.87 0.01 0,12 0.85 84.05 'Wm 33.00 98.4), I, I6 ND ND ND NA 8230 RW-6 34.55 96.38 15.50 15.47 0.03 0.36 0.85 80.90 R,>\ 27 50 96 92 12 38 ND ND ND NA 84 54 RW-8 28.60 95.96 12.54 ND ND ND NA 83.42 RW5 9 27.3 98.20 15.70 ND ND ND NA 82.50 RW-10 20.58 98.60 16.28 ND . ND NflD.NA .82.32 R-ll 29.35 9883 16.40 ND ND ND NA 82.43 RW-12 -,22.0$ 9$3 16.67 'ND d.YA'";.tD-- :-NA .. 9'26 GD l[10 Unknown Unknown NM NM NA NA NA NA GD-1154 UnkMown Unl&bu NM NM . NA NA GD-2128 18.25 90.40 602 ND ND ND NA 84.38 GD2129A .3040 10i GD-2133 Unknown Unknown NM NM NA NA NA NA GD-2152 1 Uiknown .unl : M ,NM kVf NNA- 6D-21%s 2434 9971 15 32 5.31 0,0 1.A 0.12 0.851 84 40 GD-2157 13.44 - j99 3 ND rNA eM94'+ lI)-'I15 18.56 99.18 1496 ND ND ND NA 84 22 G3D-2159. .: 52.3 ik.'. (D-22.XA 26,90 100.84 1596 ND ND ND NA 84.88

GD-2270 Unknown Unknown NM NM NA NA NA NA GD-2390A" D~lf' n kia M M 4A GD-2391 Unknown Unknown NM NM NA NA NA NA GD-2392 .'tl&2 967 13.84 A GD-2393A 15.29 89.50 545 ND ND ND NA 84,05 GD-2394 Unknown _Unkliv - NM, ,NM.N,2 GD-2395A 20.05 90.67 6.44 ND ND ND NA 8423 GD2396 . -AUnkn i n UnWn NM. NA e GD-2397 Unknown Unknown NM NM NA NA NA NA GD47126 Al~iw , - , iki (iD-271I2 Unknown Unknown NM NM NA NA NA NA GD427128 .85 . GD-27150 27.85 101.70 16.74 ND ND ND NA 84,96

GD-271SN Unknown Unknown 16 16 ND ND ND NA NA Total Average Hydrocarbon Thickness (feet): 0 02 0 22 inches

Comments NA = Not Applicable * Well on General Dynanic property included in hydrocarbon average i gauged. ND = None Detected + - Well in "Rents Creek" area included in hydrocarbon average if gauged NM Not Monitored TOC= Top olCasing "Average" based on those wells gauged and included on ihis Form where oilhas been detected and/or is within the CYOP

G 11930 zg19A30 82 bvtTables\GD - GZA Gaigng Data - Pos) Shuidawni [Mioon03-04-02 I 0 'D.-FILE COMMONWEALTH OF MASSACHUSETTS COPY EXECUTIVE OFFICE OF ENVIRONMENTAL AFFAIRS DEPARTMENT OF ENVIRONMENTAL PROTECTION Metropolitan Boston - Northeast Regional Office

JANE SWIFT BOB DURAND Governor Secretary AUG 2 8 2091 LAUREN LISS Commissioner

General Dynamics Corporation RE: Quincy 116 East Howard Street 97 East Howard Street Quincy, MA 02169 RTN 3-0536

Attention: Robert F. White

NOTICE OF AUDIT FINDINGS REMEDIAL SYSTEM COMPLIANCE INSPECTION

Dear Mr. White:

On July 26, 2001, the Massachusetts Department of Environmental Protection (the Department) conducted an inspection of the remedial system operating at the above-referenced disposal site. The purpose of this Notice is to outline the results of that inspection.

The inspection focused primarily on the remedial system discharges. This inspection does not preclude future audits of past, current, or future response actions or activities at the site or inspections to confirm compliance with applicable requirements of other laws or regulations enforced by the Department. The inspection involved:

I. On-site screening of the treatment system effluent for contaminant concentrations with portable instrumentation: and

2. Comparing the results of the screening to previously submitted data and applicable permit(s), conditions of approval(s), and/or Policies.

This information is available in alternate format by calling our ADA Coordinator at (617) 574-6872. 205A Lowell St. Wilmington, MA 0 1887 a Phone (978) 661-7600 * Fax (978) 661-7615 * TDD # (978) 661-7679 0 Pnnted on Recyced Paper INSPECTION FINDINGS

Intpyrinn of the groundwater treatment ytem

A groundwater treatment system utilizes dual pneumatic groundwater pumps within each of 10 extraction wells to depress the water table and recover product at the site. The groundwater extraction system was operational on the day of the inspection, and the pumping rate was approximately 40 gallons per minute (gpm).

On-site screening of system effluent was conducted using a photoionization detector (PlID) and in accordance with the Jar Headspace analytical screening procedure outlined in the Department Policy # WSC-94-400. The result is as follows:

Effluent concentration: <1 parts per million by volume (ppmv)

In.pectinn of the hinvent treatment ystPen ut thP .itP'

The biovent portion of the system was operational on the day of the inspection. The system consists of 10 extraction wells connected to a blower. The vapor collected from the wells is not connected to off gas controls.

1. On site screening of treatment system effluent from the biovent system was conducted using a PID. The results are as follows:

Effluent concentration: <1 ppmv

INSPECTION OUTCOME

Based on the results of the inspection, the Department has not identified any violations or deficiencies with the operation of the remedial systems.

If you have any questions regarding this Notice, please contact the Wes Perry at (978) 661-7824. Please reference the Release Tracking Number identified in the subject heading of this Notice in any future correspondence regarding the site.

Sincerely,

Wes Perry Environmental Analyst

Patricia Donahue Chief, Audit Section Bureau of Waste Site Cleanup cc: Data Entry/File PhaseV SNAUDI-07/26/01 AUDINS-NAFNVD Office of the Mayor, 1305 Hancock Street, Quincy, MA 02169 Quincy Health Department, 1585 Hancock St., Lower Level, Quincy, MA 02169 Attention: Director of Public Health GZA, Inc., One Edgewater Drive, Norwood, MA 02062 Attention: Larry Feldman, LSP #8107

3 S1 S

Massachusetts Department of Environmental Protection BWSC-102B Bureau of Waste Site Cleanup Release tracking Nurnber RELEASE LOG FORM ATTACHMENT

E. LOGJRELEASE LOCATION INFORMATION: (cowle If using EVSC-1O2Bonly) cityrrown: (mO: (run AM[] PM Ad- -meew 1 srewa Use ofAtta t (dck one): mendment to Reles LUg Fon E Aahpt Pagos) F. INSPECTIONS OR SITE ViSs (also Foow-up Ofice Response (check one)-

ita Cowplince Fli Repom.Announcd [ ls Conmpae nappw - Unaninounced Comnihnce FWd ResponsM Annone [3 Compliane Fiel Wpqnq tnannounmed E Shut Notice Audit Inspection - ield]Raeinse-DrcOweulght- -- - Foo. pOrCn Q Folloup OffeResponse a ADDITIONAL DESCRIPTiON: -F

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Stafg Lead Assignied (ifdifferent frorn preparer): SD chekM here ir the Releas or Threa of Release is unassignedB [ Check here if this RLFA records a change in staff lead. Revised 11/22/99 Do Not Alter This Form Page 2 of 2 MASSACHUSETTS WATER RESOURCES AUTHORITY -r Charlestown Navy Yard 100 First Avenue Boston. Massa husetts 02 129 SA c H Telephon:q (6 1 7) 2 4 2 -6000 Fasirnide: 617) 241 -6070

February 16, 2001

Ms. Sharon Gobiel Massachusetts Department of Environmental Protection Bureau of Waste Site Cleanup 205A Lowell Street Wilmington, MA 01887

RE: Tier II Extension Submittal MWRA Fore River Staging Area Building 9 Oil Plume Release Tracking Numbers 3-0536 and 3-10266

Dear Ms. Gobiel:

On February 19, 1999, the Massachusetts Water Resources Authority (MWRA) filed a Tier II Extension Submittal (Fomi BWSC-107A) for the Building 9 Oil Plume Area of the Fore River Staging Area (FRSA) property. On February 22, 2000, a second Tier 11 Extension Submittal was submitted. Additional activities have not yet resulted in a Response Action Outcome statement for a Temporary or Permanent Solution; therefore, the MWRA is filing this additional Tier 11 Extension Submittal for the Building 9 Oil Plume Area of the FRSA. The additional activities completed since February 22, 2000 arc outlined in the attached Tier 11 Extension Submittal.

If you have any questions, please contact me at (617) 788-2759.

Sincerely,

Mark Radville Program Manager Real Property & Environmental Management Department

Attachments: Form BWSC-107A Attachment to BWSC-107A

@ii iP Itr, I i ii I I ',Ri-I~I I ( I' cc: Leon Lataille. MWRA Robert White, General Dynamics/American Overseas Marine S. David Graber, Consulting Engineer ATTACHMENT

Supporting Documentation for Form BWSC-107A, Sections D and F

D. Tier II Extension Submittal Requirements

The Massachusetts Department of Environmental Protection (DEP) granted a Waiver of Approvals (RTNs 3-536 and 3-10266) on March 2, 1994 to the Massachusetts Water Resources Authority (MWRA) and General Dynamics Corporation for MWRA's property at the Fore River Staging Area (the FRSA or the Site), in Quincy Massachusetts. The effective date of the Waiver of Approvals was April 19, 1994. On February 19, 1999, MWRA submitted a Tier 11 Classification Extension for its portion of the Site, which included only the Building 9 Oil Plume Area at the FRSA. A second Tier Il Classification Extension was submitted to DEP on February 22, 2000. The current Extension for the Building 9 Oil Plume Area is being submitted because additional response actions will be required. This Tier 11 Classification Extension relates only to the MWRA's Building 9 Oil Plume Area.

Status of Permanent or Temporary Solution (per 310 CMR 40.0560(7)(c)(1))

Following is information summarizing why a Permanent or Temporary Solution has not been achieved at the Building 9 Oil Plume Area:

The Building 9 Oil Plume Area is in Phase V (Operation, Maintenance, and/or Monitoring) of the Massachusetts Contingency Plan. Work already completed at the Site has included extensive subsurface investigations, completion feasibility studies, and remediation of the subject plume. A Permanent or Temporary Solution has not yet been achieved at the Building 9 Oil Plume Area due to the continued presence of >0.5 inches of free product in the subsurface. Oil recovery efforts were hampered during the year 2000 due to a poorly functioning oil recovery well. To correct this, a Remedial Method Optimization Evaluation was finalized in November 2000. Based on recommendations made in this evaluation, the grading of site paving around the recovery well was corrected in November 2000 to prevent surface water runoff from entering the well and interfering with the functioning of oil recovery equipment. The oil recovery equipment also underwent cleaning, maintenance, and testing.

The Remedial Method Optimization Evaluation also assessed the potential effectiveness of several possible modifications to the oil recovery system. These included the following:

* Skimming/Passive NAPL Removal e Groundwater Depresssion and NAPL Recovery * Dual Phase Extraction * Bioslurping It was detennined that due to the confined nature of the free product plume, technical approaches that would ordinarily be cost effective and significantly improve product recovery are not applicable. The benefits of Groundwater Depression, Dual Phase Extraction, and Bioslurping are negated when the free product is confined below the water table as it is at the Building Oil Plume Area. Consequently, the recommendation was made that the approach that remains cost effective and has the highest potential for success remains skimming and passive recovery. This selected approach required rehabilitation of the existing recovery well and maintenance of the recovery system equipment, which was completed in November 2000 as described above.

Status of Response Actions, and Plan and Schedule for Achieving a Response Action Outcome (Class C or Better) (per 310 CMR 40.0560(7)(c)(2))

Prior Response Actions undertaken by MWRA are described in the Tier II Classification Extension submittals filed with DEP in February 1999 and February 2000. MWRA is currently in the process of reinitiating oil recovery operations after having implemented the recommendations made in the November 2000 Remedial Method Optimization Evaluation. Oil recovery and monitoring activities conducted in 2001 will be documented as required by 310 CMR 40.0892. A Response Action Outcome Statement for the Building 9 Oil Plume Area will be submitted at the conclusion of remedial activities.

F. Disposal Site Compliance History Summary

Following is a list of all periits or licenses that have been issued by DEP that are relevant to this Disposal Site:

Program Description Permit # Permit Facility ID

Category Air Quality Building 19 Boiler MBR-89-COM- BWP AQ 02 119 304

113 Sludge Plant Dryer MBR-95-IND-056 BWP AQ 02 119 304

Train Sludge Plant Odor MBR-89-INO- BWP AQ 02 119 304 Control, Sludge 115A Storage Tanks, & Transport Barges Storm Water EPA Multi-sector MAR05A676 General Storm Water Permit Hazardous FRSA Sludge Plant MV6173762500 EPA Sludge Plant Waste (M.G.L Generator c.2 1C) ID# Vehicle MAV000016820 EPA Vehicle Maintenance Generator Maintenance

Facility ID# 0 0I

South Maintenance MAR000010793 EPA Vehicle Yard Generator Mainter ance ID# .4 .4 Class A Recycle Transmittal # BWPHW21 Permit (Sludge 122564, 11/20/97 Plant) Massachu Department of Environmentalatection BWSC-107A Bureau of l te Site Cleanup

TIER CLASSIFICATION, TIER II EXTENSION & Release Tracking Number TIER 11TRANSFER TRANSMITTAL FORM I 3 - 536 Pursuant to 310 CMR 40.0510 and 40,0560 (Subpart E) A. DISPOSAL SITE LOCATION: Disposal Site Name: MWRA Fore Rivei StagingArea

Street: 551 SouthStreet LocationAid: Formerly 97 East Howard Street City/Town Quincy ZIPCode: 02169-0000 Related Release Tracking Numbers That This Submittal Will Address: 3-10266

B. THIS FORM IS BEING USED TO: (check all that apply) Submit a new or revised Tier Classification Submittal for a Tier I Site, including a Numerical Ranking Scoresheet (complete Sections A, B, C. I, J, K and L). I Submit a new or revised Tier Classification Submittal for a Tier Il Site, including a Numerical Ranking Scoresheet (complete Sections A, B, C, F, G, I, J, K and L).

Submit a Notice that an additional Release Tracking Number(s) is (are) being linked to this Tier Classified Site and rescoring is not required at this time (complete Sections A, B, J, K and L). If this submittal is for a Tier I Site, you must also submit a Minor Permit Modification Transmittal Form (BWSC-109). List Additional Release Tracking Number(s)

Submit a Phase I Completion Statement supporting a Tier Classification Submittal (complete Sections A, B, , J, K and L)

Submit a Tier || Extension Submittal for Response Actions al a Tier 11Site (complete Sections A, B, D, F, G, I,J, K and L).

Submit a Tier 11Extension Submittal for Response Actions taken after expiration of a Waiver, pursuant to 310 CMR 40.0630(4) (complete Sections A, B,D, F, J, K and L, and also complete Sections G and I or Section H).*

Submit a Tier IlTransfer Submittal for a change in person(s) undertaking Response Actions at a Tier I Site (complete Sections A, B, E, F,G, I,J, K, L, M, N and 0).

Submit a Tier |1 Transfer Submittal for a change in person(s) undertaking Response Actions at a Waiver Site, pursuant to 310 CMR 40.0630(6) (complete Sections A, B, E, F, J, K, L, M, N and 0,and also complete Sections G and I or Section H).* You must attach all supporting documentation required for each use of form indicated, including copies of any Legal Notices and Notices to Public Officials required by 310 CMR 40.1400. "NOTE: The Waiver expires on the effective date of this submittal and all further Response Actions must be taken as a Tier il Site.

C. TIER CLASSIFICATION SUBMITTAL: Numerical Ranking Score for Disposal Site: (from Numerical Ranking Scoresheet)

Proposed Tier Classification of Disposal Site: (check L Tier IA Tier B Tier IC Tier It one) Check which, if any, of the Tier I inclusionary criteria are met by the Disposal Site, pursuant to 310 CMR 40.0520:

Groundwater is located within an interim Welihead Protection Area or a Zone 11,and there is evidence of groundwater contamination by an Oil or Hazardous Material at the time of Tier Classification at concentrations equal to or exceeding the applicable RCGW-1 Reportable Concentration set forth in 310 CMR 40.0360. An Imminent Hazard is present at the time of Tier Classification. Check here if this Tier Classification revises a previous submittal for this Disposal Site. You must include a revised Numerical Ranking Scoresheel with this submittal. If a Tier I Permit has been issued, you may also need to submit a Major Permit Modification Application (BWSC 10). it incorporating additional Release(s) into the Disposal Site, list Release Tracking Number(s):

D. TIER 11EXTENSION SUBMITTAL REQUIREMENTS: Slate the expiration date of the Tier Il Classification or Waiver for the Disposal Site, whichever is applicable: 4/19/2001 Attach a statement summarizing why a Permanent or Temporary Solution has not been achieved at the Disposal Site. A Tier It Extension is effective for a period of one year beyond the current expiration date of the Tier 11Classification or Waiver.

E. TIER || TRANSFER SUBMITTAL REQUIREMENTS: State the proposed effective date of the change in person(s) undertaking Response Actions at the Disposal Site:

Attach a statement summarizing the reasons for the proposed change in person(s) undertaking the Response Actions. All Response Actions must be completed by the deadline applicable to the person who first filed either a Tier Classification Submittal for the Disposal Site or received a Waiver of Approvals. Revised 4/6/95 Supersedes Forms BWSC-010 (in part) and 014 Page 1 of 4 Do Not Alter This Form Massach tts Department of Environment rotection BWSC-107A Bureau o ste Site Cleanup

TIER CLASSIFICATION, TIER 11 EXTENSION & Release Tracking Number TIER || TRANSFER TRANSMITTAL FORM Pursuant to 310 CMR 40.0510 and 40.0560 (Subpart E) 3 536 F. DISPOSAL SITE COMPLIANCE HISTORY SUMMARY:

> If providing either a Tier Classification Submittal for a Tier I Site or a Tier II Extension Submittal for a Waiver Site, the person named in Section J must provide a Compliance History. > If providing a Tier |1 Extension Submittal for a Tier Il Site, the person named in Section J must update their Compliance History since the effective date of the Tier || Classification. > If providing a Tier Il Transfer Submittal for a Tier 1Ior Waiver Site, the person named in Section M must provide a Compliance History

Compliance History for (provide only one name per History): MWRA .Fore River Staging Area (SEE ATTACHMENT)

q Check here if there has been no change to the Compliance History of the person named above (Extension Submittal for a Tier II Site ONLY).

List all permits or licenses that have been issued by the Department that are relevant to this Disposal Site:

PROGRAM: PERMIT NUMBER: PERMIT CATEGORY: FACILITY ID.

Air Quality

Hazardous Waste (M.GL. c. 21C) Solid Waste Industrial Wastewater Management

Water Supply Water Pollution Control/Surface Water Water Pollution Control/Groundwater

Water Pollution Control/Sewer Connection

Welland & Waterways

List all other Federal, state or local permits, licenses, certifications, registrations, variances, or approvals that are relevant to this Disposal Site: ISSUING AUTHORITY OR PROGRAM, OR DOCUMENTATION TYPE: IDENTIFICATION NUMBER: DATE ISSUED:

If needed, attach to this Transmittal Form a statement further describing the Compliance History of this Disposal Site. This statement must describe the compliance history of the person named above with the following: (1) OEP regulations, and (2) other laws for the protection of health, safety, public welfare and the environment administered or enforced by any other government agency. Such a stalement should identify information such as: (1) actions relevant to the Disposal Site taken by the Department to enforce its requirements including, but not limited to, a Notice of Noncompliance (NON), Notice of Intent to Assess Civil Administrative Penalty (PAN), Notice of Intent to Take Response Action (NORA), and an administrative enforcement order: (2) administrative consent orders: (3) judicial consent judgements; (4) similar administrative actions taken by other Federal, state or local agencies: (5) civil or criminal actions relevant to the Disposal Site brought on behalf of the DEP or other Federal, state, or local agencies; and (6) any additional relevant information. For each action identified, provide the following information

(1) name of the issuing authority, type of action, identification number and date issued; (2) description of noncompliance cited; (3) current status of the matter; and (4) final disposition, if any

Revised 4/6/95 Supersedes Forms BWSC-010 (in part) and 014 Page 2 of 4 Do Not Alter This Form , Massac h tts Department of Environmentn rotection BWSC-107A Bureau o aste Site Cleanup

- TIER CLASSIFICATION, TIER 11 EXTENSION & Release Tracking Number TIER If TRANSFER TRANSMITTAL FORM

3 - 536 Pursuant to 310 CMR 40.0510 and 40.0560 (Subpart E)

G. CERTIFICATION OF ABILITY AND WILLINGNESS: > if providing either a Tier || Classification Submittal or a Tier 11Extension Submittal, the person who signs this certification MUST be the person named in Section J, or that person's agent. > If providing a Tier 11Transfer Submittal, the person who signs this certification MUST be the person named in Section M. or that person's agent.

I attest under the pains and penalties of perjury that (i) lithe person(s) or entity(ies) on whose behalf this submittal is made has/have personally examined and am/is familiar with the requirements of M.G.L. c. 21E and 310 CMR 40.0000; (ii) based upon my inquiry of the/those Licensed Site Professional(s) employed or engaged to render Professional Services for the disposal site which is the subject of this Transmittal Form and of the person(s) or entity(ies) on whose behalf this submittal is made, and my/that person's(s') or entity's(ies') understanding as to the estimated costs of necessary response actions, that/those person(s) or entity(ies) has/have the technical, financial and legal ability to proceed with response actions for such site in accordance with M.G.L. c. 21E, 310 CMR 40.0000 and other applicable requirements; and (iii) that I am fully authorized to make this attestation on behalf of the person(s) or entity(ies) legally responsible for this submittal. lithe person(s) or entity(ies) on whose behalf this submittal is made is aware of the requirements in 310 CMR 40.0172 for notifying the Department in the event that lithe person(s) or entity(ies) on whose behalf this submittal is made learn(s) that il/they is/are unable to proceed with the necessary response actions.

By: Title: (signature)

For: Date: (pnnt name of person or entity recorded in Section J or M, as appropriale)

If you are submitting either a Tier I Extension Submittal for a Waiver Site or a Tier It Transfer Submittal for a Waiver Site, you may choose to sign the alternative Ability and Willingness Certification found in Section H in place of providing the certification in Section G and the LSP Opinion in Section 1. H. ALTERNATIVE CERTIFICATION OF ABILITY AND WILLINGNESS: > If providing a Tier 11Extension Submittal for a Waiver Site, the person who signs this certification MUST be the person named in Section J, or that person's agent > If providing a Tier il Transfer Submittal for a Waiver Site, the person who signs this certification MUST be the person named in Section M. or that person's agent. I attest under the pains and penalties of perjury that (i) I/the person(s) or entity(ies) on whose behalf this submittal is made has/have personally examined and am/is familiar with the requirements of M.G.L. c. 21E and 310 CMR 40.0000; (ii) based upon my inquiry of the Consultant-of-Record for the disposal site which is the subject of this Transmittal Form and of the person(s) or entity(ies) on whose behalf this submittal is made, and my/that person's(s') or entity's(ies') understanding as to the estimated costs of necessary response actions, that/those person(s) or entity(ies) has/have the technical, financial and legal ability to proceed with response actions for such site in accordance with M.G.L. c. 21E, 310 CMR 40.0000 and other applicable requirements; and (iii) that I am fully authorized to make this attestation on behalf of the person(s) or enfity(ies) legally responsible for this submittal, 'the person(s) or entity(ies) on whose behalf this submittal is made is aware of the requirements in 310 CMR 40.0172 for notifying the Department in the event that l/the person(s) or entity(ies) on whose behalf this submittal is made learn(s) that it/they is/are unable to proceed with the necessary response actions.

By:t A K524--Q-tTitle: Program Manager (signature)

For: Mark E. Radville. _ Date: 2/16/2001 (print name of person or entity recorded in Section J or M, as appropriate)

I. LSP OPINION: I attest under the pains and penalties of perjury that I have personally examined and am familiar with this transmittal form, including any and all documents accompanying this submittal. In my professional opinion and judgment based upon application of (i) the standard of care in 309 CMR 4.02(1), (ii) the applicable provisions of 309 CMR 4.02(2) and (3), and (iii) the provisions of 309 CMR 4.03(5), to the best of my knowledge, information and belief.

> if Section 8 of this form indicates that a Tier I or Tier I/ Classification Submittal which relies upon a previously submitted Phase I Completion Statement is being submitted, this Tier Classification Submittal has been developed in accordance with the applicable provisions of M.G.L. c. 21E and 310 CMR 40.0000.

> if Section 8 of this form indicates that a Phase I Completion Statement or a Tier I or Tier 11Classification Submittal which does not rely upon a previously submitted Phase I Completion Statement is being submitted, the response action(s) that is (are) the sublect of this submittal (i) has (have) been developed and implemented in accordance with the applicable provisions of M.G.L. c. 21E and 310 CMR 40.0000, (11)is (are) appropriate and reasonable to accomplish the purposes of such response action(s) as set forth in the applicable provisions of M.G.L. c 21E and 310 CMR 40.0000, and (iii) complies(y) with the identified provisions of all orders, permits. and approvals identified in this submittal;

SECTION I IS CONTINUED ON THE NEXT PAGE

Revised 4/6/95 Supersedes Forms BWSC-010 (in part) and 014 Page 3 of 4 Do Not Alter This Form Massac g tts Department of EnvironmenW rotection BWSC-107A Bureau o aste Site Cleanup

TIER CLASSIFICATION, TIER 11EXTENSION & Release Tracking Number TIER 11 TRANSFER TRANSMITTAL FORM 3 -536 Pursuant to 310 CMR 40.0510 and 40.0560 (Subpart E) - 536 1. LSP OPINION: (continued) > if Section B of this form indicates that a Tier II Extension Submittaf or a Tier HTransfer Submittal is being submitted, the response action(s) that is (are) the subject of this submittal (i) is (are) being implemented in accordance with the applicable provisions of M.G.L. c. 21 E and 310 CMR 40.0000, (ii) is (are) appropriate and reasonable to accomplish the purposes of such response action(s) as set forth in the applicable provisions of M.GL. c 21E and 310 CMR 40.0000, and (iii) complies(y) with the identified provisions of all orders, permits, and approvals identified in this submittal. I am aware that significant penalties may result. including, but not limited to, possible fines and imprisonment. if l submit information which I know to be false. inaccurate or materially incomplete.

Check here if the Response Action(s) on which this opinion is based, if any, are (were) subject to any order(s), permit(s) and/or approval(s) issued by DEP or EPA. If the box is checked, you MUST attach a statement identifying the applicable provisions thereof. LSP LSP #: Stamp: Name: Telephone. Ext.:

FAX: (optional)

Signature. Date: J. PERSON MAKING SUBMITTAL: (For Transfer Submittals describe person currently undertaking response actions, not transferee) NameofOrganization: Massachusett-s. Water Resources Authority

Name of Contact: Mark E . _Radville _ _ Title: Program Manager Street: Charlestown_ Navy- Yard, 100 FirstAvenue _ City/Town: aston._ State: MA ._ ZIP Code: 02129- 0000

Telephone: 617-788:2759 _. Ext.: FAX:(optional) 617 -788-4898 K. RELATIONSHIP TO DISPOSAL SITE OF PERSON MAKING SUBMITTAL: (check one) RP or PRP Specify: 4 Owner Operator : Generator Transporter Other RP or I- PRP: Fiduciary, Secured Lender or Municipality with Exempt Status (as defined by M G.L. c. 21E, s. 2) Agency or Public Utility on a Right of Way (as defined by M.G.L. c. 21 E, s. 5(j)) Any Other Person Making Submittal Specify L CERTIFICATION OF PERSON MAKING SUBMITTAL: 1 ___ Mark E-. Radville _._ , attest under the pains and penaities of perjury (i) that I have personally examined and am familiar with the information contained in this submittal, including any and all documents accompanying this transmittal form, (ii) that, based on my inquiry of those individuals immediately responsible for obtaining the information, the material information contained in this submittal is, to the best of my knowledge and belief, true, accurate and complete, and (iii) that I am fully authorized to make this attestation on behalf of the entity legally responsible for this submittal. I/the person or entity on whose behalf this submittal is made am/is aware that there are significant penalties, including, but not limited to. possible fines and imprisonment, for willfully submitting false, inaccurate, or incomplete information. By: -i___ Title: Program Manager (signature) For Date: 2/16/2_001 (print name of person or entity recorded in Section J) Enter address of the person providing certification(s), including Ability and Willingness Certification where applicable, if different from address recorded in Section J: Street:

City/Town: State: ZIP Code: Teiephone: Ext FAX: (optional)

YOU MUST COMPLETE ALL RELEVANT SECTIONS OF THIS FORM OR DEP MAY RETURN THE DOCUMENT AS INCOMPLETE. IF YOU SUBMIT AN INCOMPLETE FORM, YOU MAY BE PENALIZED FOR MISSING A REQUIRED DEADLINE, AND YOU MAY INCUR ADDITIONAL COMPLIANCE FEES.

Revised 416/95 Supersedes Forms BWSC-010 (in part) and 014 Page 4 of 4 Do Not Alter This Form 0 & orporation i Hniwr-ble flri ' ho kflme, t 011 0II11It TVl. ?~8.082. 08H the 1. o .i/ O J q

I-ebruary 14. 2001

Regional Administrator Massachusetts Department of Environmental Protection Bureau of Waste Site Cleanup Northeast Regional Office 205A Lowell Street 'ilmington,. MA 01887

Subject: LSP of Record Termination DEP RTNs: 3-0536 and 3-19102 Fore River Staging Area Site Quincy, Massachusetts

Dear Sir or Madam:

Eric (. Nelson, license number 2516, was the ISP of Record for response actions being conducted by I larding ESE at the above referenced sites located in Quincy. Because Mr. Nelson changed his employer in December 2000. it is his understanding that his services as I SP of Record have ceased.

You are hereby advised, as required by 310 CMR 40.0169(2). that Mr. Nelson has been effectivelN terminated as LSP of Record for the referenced sites.

If you have any questions, please call me.

Sincerely,

IT Corporation

Iric G Nelson. LSP Business Line Manager

'dI ' (c iialin %\k\ RA do, MassacNsefts Department of Environmental Protection BWSC-108 Bure,- of Waste Site Cleanup COMPREHENSIVE RESPONSE ACTION TRANSMITTAL Release Tracking Number FORM & PHASE I COMPLETION STATEMENT [ . O 36 I Pursuant to 310 CMR 40 0484 (Subpart D) and 40.0800 (Subpart H) -E LOCATION: oIteName (optional) _Former General Dnamics/Quincy Shiovard (Central Yard Oil Plume) Street 97 East Howard Street LocationAid: ouincy Shicvard

ZIP Code 02169 City/Town: Qui nc y Related Release Tracking Numbers that this Form Addresses:

Tier Classificaion: (check one of the following) 0 Tier JA ] Tier IB 7 Tier IC [b Tier II Not Tier Classified Ifa Tier I Permit has been issued, state the Permit Numoer: B. THIS FORM IS BEING USED TO: (check all that apply) [ Submit a Phase I Completion Statement, pursuant to 310 CMR 40.0484 (complete Sections A, B, C, G, H, I and J).

EJ Submit a Phase il Scope of Work, pursuant to 310 CMR 40 0834 (complete Sections A, B, C, GH, Iand J) -

Submit a final Phase || Comprehensive Site Report and Completion Statement, pursuant to 310 CMR 40 0836 . (complete Sections A,B, C, D G,H, I and J). --

Submit a Phase IlIlRemedial Action Plan and Completion Statement, pursuant to 310 CMR 40.0862 i , (comlete Sections A. B. C. G H I and J). F] Submit a Phase IV Remedy Implementation Plan, pursuant to 310 CMR 40.0874 (complete Sections A. B. C. G, H, 1and J). F] Submit an As-Built Construction Report. pursuant to 310 CMR 40.0875 (complete Sections A, B. C. G, H. Iand J). E] Submit a Phase IV Final Inspection Report and Completion Statement, pursuant to 310 CMR 40.0878 and 40 0879 (complete Sections A, B, C, E G, H, I and J).

Submit a periodic Phase V Inspection & Monitoring Report. pursuant to 310 CMR 40.0892 (complete Sections A B. C. G, H, I and J) Submit a final Phase V Inspection & Monitoring Report and Completion Statement, pursuant to 310 CMR 40 0893 (complete Sections A, B C, F, G, H, I and J), You must attach all supporting documentation required for each use of form indicated, including copies of any Legal Notices and Notices to Public Officials required by 310 CMR 40.1400. C. RESPONSE ACTIONS: F Check here if any response action(s) that serves as the basis for the Phase submittal(s) involves the use of Innovative Technologies (DEP is interested in using this information to create an Innovative Technologies Clearinghouse.) Descnbe Technologies.

D. PHASE |1 COMPLETION STATEMENT: Specify the outcome of the Phase ilComprehensive Site Assessment

Additional Comprehensive Response Actions are necessary at this Site, based or the results of the Phase IIComprehensive Site Assessment

The requirements of a Class A Response Action Outcome have been met and a completed Response Action Outcome Statement (BWSC-104) wilkbe submitted to DEP. The requirements of a Class B Response Action Outcome have been met and a completed Response Action Outcome Statement (BWSC-104) will be submitted to DEP. Rescoring of this Site using the Numerical Ranking System is necessary, based on the results of the final Phase I Report. E. PHASE IV COMPLETION STATEMENT: Specify the outcome of Phase IV activities Phase V operation, maintenance or monitoring of the Comprehensive Response Action is necessary to achieve a Response Action Outcome (This site willbe subject to a Phase V Operation, Maintenance and Monitoring Annual Compliance Fee.) The requirements of a Class A Response Action Outcome have been met No additional operation, maintenance or nonitoring is necessary to ensure the integrity of the Response Action Outcome. A completed Response Action Outcome Statement (BWSC-104) willbe submitted to DEP. The requirements of a Class C Response Action Outcome have been met. No additional operation, maintenance or monitoring is necessary to F] ensure the integrity of the Response Action Outcome. A completed Response Action Outcome Statement (BWSC-104) willbe submitted to DEP. SECTION E IS CONTINUED ON THE NEXT PAGE

Revised 3/30195 Sunorcnde3 Fnrms BWSC-010 tin ngrtt and 013 Paoe I o1 Do Not Alter This Form Massachusetts Department of Environmental Protection BWSC-108 Bureau of Waste Site Cleanup

COMPREHENSIVE RESPONSE ACTION TRANSMITTAL Release Tracking Number i FORM & PHASE I COMPLETION STATEMENT - Pursuant to 310 CMR 40.0484 (Subpart D) and 40.0800 (Subpart H) E. PHASE IV COMPLETION STATEMENT: (continued) The requirements of a Class C Response Action Outcome have been met. Further operation. maintenance or rmonitonng of the remedial action is necessary to ensure that conditions are maintained and that further progress is made toward a Permanent Solution. A completed Response Action Outcome Statement (BWSC-104) will be submitted to DEP Indicate whether the operation and maintenance will be Active or Passive. (Active Operation and Maintenance is defined at 310 CMR 40.0006)

0 Active Operation and Maintenance O Passive Operation and Maintenance (Active Operation and Maintenance makes the Site subject to a Post-RAO Class C Active Operation and Maintenance Annual Compliance Fee.) F. PHASE V COMPLETION STATEMENT: Specify the outcome of Phase V activities: The requirements of a Class A Response Action Outcome have been met and a completed Response Action Outcome Statement (BWSC-1104) will be submitted to DEP.

The requirements of a Class C Response Action Outcome have been met. No additional operation, maintenance or rnonitonng is necessary to ensure the integrity of the Response Action Outcome. A completed Response Action Outcome Statement (BWSC-1 04) will be submitted to DEP

The requirements of a Class C Response Action Outcome have been met. Further operation, maintenance or rmonitonng of the remedial action is necessary to ensure that conditions are maintained and that further progress is made toward a Permanent Solution A completed Response Action Outcome Statement (BWSC-104) will be submitted to DEP. Indicate whether the operation and maintenance will be Active or Passive (Active Operation and Maintenance is defined at 310 CMR 40.0006

) Active Operation and Maintenance Q Passive Operation and Maintenance (Active Operation and Maintenance makes the Site subject to a Post-RAO Class C Active Operation and Maintenance Annual Compliance Fee) G. LSP OPINION: I attest under the pains and penalties of perjury that Ihave personally exarrined and am familiar with the information contained in this transmittal form, including any and all documents accompanying this submittal. In my professional opinion and judgment based upon application of (i) the standard of care in 309 CMR 4.02(1), (ii) the applicable provisions of 309 CMR 4.02(2) and (3), and (iii) the provisions ot 309 CMR 4.03(5), to the best of my knowledge, information and belief, > if Section S indicates that a Phase I, Phase It, Phase Ill, Phase IV or Phase V Completion Statement is being submitted, the response action{ s) that is (are) the subject of this submittal (i) has (have) been developed and implemented in accordance with the applicable provisions of M G L c. 21 E and 310 CMR 40.0000, (ii) is (are) appropriate and reasonable to accomplish the purposes of such response action(s) as set forth in the applicable provisions of M.G L. c. 21 E and 310 CMR 40.0000, and (iii) complies(y) with the identified provisions of all orders, permits, and approvals identified in this submittat > if Section S indicates that a Phase Il Scope of Work or a Phase IV Remedy Implementation Plan is being submtted, the response action(s) that is (are) the subject of this submittal (i) has (have) been developed in accordance with the applicable provisions of M G.L c. 21E and 310 CMR 40 0000, (ii) is (are) appropriate and reasonable to accomplish the purposes of such response action(s) as set forth in the applicable provisions of M G L c 21E and 310 CMR 40.0000, and (iii) complies(y) with the identified provisions of all orders, permits, and approvals identified in this siihmittal- > if Secton 8 indicates that an As-Built Construction Report or a Phase V Inspection and Monitoring Report is being submitted. the response action(s) that is (are) the subject of this submittal (i) is (are) being implemented in accordance with the applicable provisions of M.G.L. c. 21 E and 310 CMR 40.0000, (ii) is (are) appropriate and reasonable to accomplish the purposes of such response action(s) as set forth in the applicable provisions of M.G L c. 21E and 310 CMR 40.0000, and (iii) complies(y) with the identified provisions of all orders, permits, and approvals identified in this submittal. I am aware that significant penalties may result, including, but not limited to, possible fines and imprisonment, if I submit information which I know to be false, inaccurate or materially incomplete.

Check here if the Response Action(s) on which this opinion is based. if any, are (were) subject to any order sj m6(S) skid/or approval(s) issued by DEP or EPA. If the box is checked, you MUST attach a statement identifying the applicable provisijrswereof. LSPName Lawrence Feldman LSP#: 07 -

Telephone: 781-278-3807 Ext L Stamp 4 - FAX: (optional) N., - Signature .J-A, L Date: -

Revised 3/30/95 Supersedes Forms BWSC-010 (in part) and 013 Pagd f Do Not Alter This Form V0

Massachusetts Department of Environmental Protection BWSC-108 Bureau of Waste Site Cleanup

COMPREHENSIVE RESPONSE ACTION TRANSMITTAL Release Tracking Number FORM & PHASE I COMPLETION STATEMENT 7 _536 Pursuant to 310 CMR 40.0484 (Subpart D) and 40.0800 (Subpart H) H. PERSON UNDERTAKING RFSPONSE ACTIONISI Name of Organization: General Dynamics Corporation

Name of Contact: Daniel Kelley Title: VP * '- i GL.-LV .

Street: 116 East Howard Street

City/Town: Quincy _State: ZIP Code 02169

(optional) 617-770-4568 Telephone: 617 - 7 8 6 - 8 3 0 Ext.: FAX

[-] Check here if there has been a change in the person undertaking the Response Action. I. RELATIONSHIP TO SITE OF PERSON UNDERTAKING RESPONSE ACTION(S): (check onel Prior Owner RPorPRP Specify: Q owner Q Operator Q Generator Q Transporter Other RP or PRP:

Fiduciary Secured Lender or Municipality with Exempt Status (as defined by M.G L. c. 21 E, s. 2)

LJ Agency or Public Utility on a Right of Way (as defined by M.G.L. c 21 E, s. 50))

[ Any Other Person Undertaking Response Action Specify Relationship: J. CERTIFICATION OF PERSON UNDERTAKING RESPONSE ACTION(S): Danle 1 We1l ev attest under the pains and penalties of perjury (i) that I have personally exarrned and am familiar with the information contained in this submittal, including any and all documents accompanying this transrnittal form, (ii) that based on my inquiry of those individuals immediately responsible for obtaining the information, the material information contained in this subrnittal is, to the best of my knowMledge and belief, true, accurate and complete, and (iii) that I am fully authorized to make this attestation on behalf of the entity legally responsible for this subrnittal. I/the person or entity on whose behalf this subrrittal is made anis aware that there are significant penalties including, but not limited to, possible fines and imprisonment. for willfully submitting false, inaccurate, or incomplete information

By L.A Title- (signature) - For- General Dynamics Corporation Date (pnnt name of person or entity recorded in Section H)

Enter address of the person providing certification, if different from address recorded in Section H Street:

City/Town: State: _ ZIP Code:

Telephone: Ext. _ FAX (optional)

YOU MUST COMPLETE ALL RELEVANT SECTIONS OF THIS FORM OR DEP MAY RETURN THE DOCUMENT AS INCOMPLETE. IF YOU SUBMIT AN INCOMPLETE FORM, YOU MAY BE PENALIZED FOR MISSING A REQUIRED DEADLINE.

Revised 3/30/95 Supersedes Forms BWSC-010 (in parl) and 013 Page 3 of 3 Do Not Alter This Form FOLEY, HOAG & ELIOT LLP ONE POST OFFICE SQUARE BOSTON, MASSACHUSETTS 02109-2170

Laune Bur[ TELEPHONF 617-S32.1000 1747 PENNSYLVANIA AVE'., N\ 617-S32-llli FACSIMILE 617-832-700C StI1TE I2A' Ib-unirtr fte,com hnrp:/www fhe comI1t WASHINGTON, ID.C 200t, Til 202-2231A FAX. 202-785-6687

January 5, 2001

Ms. Sharon Gobiel Dcpartment of Environmental Protectic Northeast Regional Office 205 Lowell Street Wilmington, MA 01887

Re: Quincy/Fore River Shipyard Central Yard Oil Plume DEP Site No. 3-0536 Notification1- of Remedy Operating Status Dear Ms. Gobiel:

Please be advised of the availability at the local information repositories of the Remedy Operation Status Submittal, prepared by GZA GeoEnvironmental, Inc. and dated December 29, 2000, which was recently submitted on behalf of General Dynamics Corporation to the Massachusetts Department of Environmental Protection. This information is provided with respect to the status of remediation of the Central Yard Oil Plume ("CYOP") at the former General Dynamics Shipyard.

Veryt yours,

Laurie Burt

Enclosure cc: See Attached Sheet

16/332472 I Department of Environmental Protection January 5, 2001 Page 2

cc: Local Repositories: Watson Park Public Library (w/ enclosure) Tufts Public Library (w/ enclosure) Thomas Crane Public Library (w/ enclosure)

Mark Radville, MWRA (w/o enclosure) Rhonda Russian, Esq., MWRA (w/o enclosure) The Honorable James A. Sheets, Mayor, City of Quincy (w/o enclosure) Board of Health, Quincy (w/o enclosure) The Honorable David M. Madden, Mayor, Town of Weymouth (w/o enclosure) Board of Health, Weymouth (w/o enclosure) Board of Selectmen, Braintree (w/o enclosure) Board of Health, Braintree (w/o enclosure) Daniel Kelley, GDC (w/o enclosure) Robert White, GDC (w/o enclosure) Lawrence Feldman, Senior Principal, GZA GcoEnvironmental, Inc. (w/o enclosure) Stephen T. Pitrowski. GZA GecoEnvironmental, Inc. (w/o enclosure)

16/332472.1 Massachusetts Department of Environmental Protection BWSC-108 Bureau of Waste Site Cleanup

COMPREHENSIVE RESPONSE ACTION TRANSMITTAL Release Tracking Number FORM & PHASE I COMPLETION STATEMENT - 0s36 Pursuant to 310 CMR 40.0484 (Subpart D) and 40.0800 (Subpart H) A. SITE LOCATION: Site Name: (optional) MWRA - Fore River SLaging Area

Street: 551 SouLh St (ornerlv 97 E. Howard St) Location Aid: 02169-000 CityrTown: Quincv ZIP Code: Related Release Tracking Numbers that this Form Addresses: 3-0536 and 3-10266

Tier Classification: (check one of the following) E Tier IA E Tier B H Tier IC Tier I Not Tier Classified If a Tier I Permit has been issued state the Permit Number- B. THIS FORM IS BEING USED TO: (check all that apply)

H Submit a Phase I Completion Statement, pursuant to 310 CMR 40.0484 (complete Sections A, B, C, G, H, I and J) Subnit a Phase 11Scope of Work, pursuant to 310 CMR 40.0834 (complete Sections A, B, C. G. H, I and J)

Submit a final Phase 11Comprehensive Site Report and Completion Statement, pursuant to 310 CMR 40 0836 (complete Sections A, B, C. D, G, H. I and J). 40.0862 Action Plan and Completion Statement, pursuant to 310 CMR O SubmitI'comolete a Phase Sections III Remedial A. B, C. G. H. I and J1. Submit a Phase IV Remedy Implementation Plan, pursuant to 310 CMR 40.0874 (complete Sections A, B, C. G, H, I and J).

Subrnit an As-Built Construction Report, pursuant to 310 CMR 40.0875 (complete Sections A. B, C, G, H, Iand J). Submit a Phase IV Final Inspection Report and Completion Statement, pursuant to 310 CMR 40.0878 and 40.0879 (complete Sections A, B, C. E. G, H I and J).

Submit a periodic Phase V Inspection & Monitoring Report, pursuant to 310 CMR 40.0892 (complete Sections A B, C, G, H, I and J). Subnit a final Phase V Inspection & Monitoring Report and Completion Statement, pursuant to 310 CMR 40.0893 (complete Sections A, B, C, F, G, H. I and J) You must attach all supporting documentation required for each use of form indicated, including copies of any Legal Notices and Notices to Public Officials required by 310 CMR 40.1400. C. RESPONSE ACTIONS: Check here if any response action(s) that serves as the basis for the Phase submittal(s) involves the use of Innovative Technologies. (DEP is interested in using this information to create an Innovative Technolooes Cleannohouse i Describe Technologies: D. PHASE || COMPLETION STATEMENT: Specify the outcome of the Phase il Comprehensive Site Assessment:

H Additional Comprehensive Response Actions are necessary at this Site based on the results of the Phase Il Comprehensive Site Assessment. H The requirements of a Class A Response Action Outcome have been mel and a completed Response Action Outcome Statement (BWSC-104) will be submitted to DEP.

The requirements of a Class B Response Action Outcome have been met and a completed Response Action Outcome Statement (BWSC-104) will be submitted to DEP.

Rescoring of this Site using the Numerical Ranking System is necessary, based on the results of the finalI

E. PHASE IV COMPLETION STATEMENT: Specify the outcom of Phase IV activities: 20 r7Phase V operation, maintenance or mrnoitoring of the Comprehensive Response Action is necessary to ac Response Action Outcome .) (This site will be subject to a Phase V Operation, Maintenance and Monitonng Annual Compliance Fee.) DF h A$ H The requirements of a Class A Response Action Outcome have been met. No additional operation, maintanoe oW idF rt4 4 to ensure the integrity of the Response Action Outcome. A completed Response Action Outcome Statement ( C~u4 WI1 5uiMminuu LU -e DEP. The requirements of a Class C Response Action Outcome have been met No additional operation, maintenance or monitonng is necessary to F ensure the integrity of the Response Action Outcome. A completed Response Action Outcome Statement (BWSC-104) will be subrnitted to DEP. SECTION E IS CONTINUED ON THE NEXT PAGE Revised 3/30195 Supersedes Forms BWSC-010 (in part) and 013 Page 1 of 3 Do Not Aller This Form Massachusetts Department of Environmental Protection BWSC-1 08 Bureau of Waste Site Cleanup

COMPREHENSIVE RESPONSE ACTION TRANSMITTAL Release Tracking Number FORM & PHASE I COMPLETION STATEMENT Pursuant to 310 CMR 40.0484 (Subpart D) and 40.0800 (Subpart H) H. PERSON UNDERTAKING RFSPONSF ACTION(SI: NameofOrganization: Massachusttes Water Resources Authority Manaer Name of Contact: Mark Radville Title: Proaram Street: Charlestown Navv Yard, 100 First Avenue

02129-000 City/Town: Bo s ton State: MA ZIP Code: FAX (optional) 617-788-48 98 Telephone: 617-788-2759 - Ext.:

Check here if there has been a change in the person undertaking the Response Action. I. RELATIONSHIP TO SITE OF PERSON UNDERTAKING RESPONSE ACTION(S): (check onel RP or PRP Specify: i2 Owner Q Operator Q Generator Q Transporter Other RP or PRP:

Fiduciary, Secured Lender or Municipality with Exempt Status (as defined by M.G.L. c. 21E, s. 2)

Agency or Public Utility on a Right of Way (as defined by M.G.L. c. 21E, s. 5())

Any Other Person Undertaking Response Action Specify Relationship: J. CERTIFICATION OF PERSON UNDERTAKING RESPONSE ACTION(S): Ma-rk Pa dvi 1 1 e , attest under the pains and penalties of perjury (i) that I have personally examined and am familiar with the information contained in this submittal, including any and all documents accompanying this transmittal form, (ii) that, based on my inquiry of those individuals immrnediately responsible for obtaining the information, the rnaterial information contained in this submittal is, to the best of my knowledge and belief, true, accurate and complete, and (iii) that (am fully authorized to make this attestation on behalf of the entity legaly responsible for this submittal, /the person or entity on whose behalf this submittal is made amlis aware that there are significant penalties, including, but not limited to. possible fines and imprisonment, for willfully submitting false, inaccurate. or incomplete information.

Program Manager By: n-Title: (signature)

For: Massachusetts Water Resources Authority Date: I I - Z i ~ 0 _ (print name of person or entity recorded in Section H)

Enter address of the person providing certification, if different from address recorded in Section H:

Street

City/Town: _ State: _ ZIP Code:

Telephone: Ext.: - FAX (optional)

YOU MUST COMPLETE ALL RELEVANT SECTIONS OF THIS FORM OR DEP MAY RETURN THE DOCUMENT AS INCOMPLETE. IFYOU SUBMIT AN INCOMPLETE FORM, YOU MAY BE PENALIZED FOR MISSING A REQUIRED DEADLINE.

Revised 3/30/95 Supersedes Forms BWSC-010 (in part) and 013 Page 3 of 3 Do Not Alter This Form Massach tts Department of Environmen rotection BWSC-108 Bureau of ste Site Cleanup W

COMPREHENSIVE RESPONSE ACTION TRANSMITTAL Release Tracking FORM & PHASE I COMPLETION STATEMENT Number 3 0536 Pursuant to 310 CMR 40 0484 (Subpart D) and 40.0800 (Subpart H) E. PHASE IV COMPLETION STATEMENT: (continued) The requirements of a Class C Response Action Outcome have been met Further operation. maintenance or monitoring of the remedial action is necessary to ensure that conditions are maintained and that further progress is made toward a Permanent Solution A completed Response Action Outcome Statement (BWSC-104) will be submitted to DEP. Indicate whether the operation and maintenance will be Active or Passive. (Active Operation and Maintenance is defined at 310 CMR 40.0006.): Active Operation and Maintenance Passive Operation and Maintenance (Active Operation and Maintenance makes the Site subject to a Post-RAO Class C Active Operation and Maintenance Annual Compliance Fee) F. PHASE V COMPLETION STATEMENT: Specify the outcome of Phase V activities: The requirements of a Class A Response Action Outcome have been met and a completed Response Action Outcome Statement (BWSC-1 04) will be submitted to DEP The requirements of a Class C Response Action Outcome have been met. No additional operation. maintenance or monitoring is necessary to ensure the integrity of the Response Action Outcome A completed Response Action Outcome Statement (BWSC-104) will be submitted to DEP

The requirements of a Class C Response Action Outcome have been met. Further operation, maintenance or monitoring of the remedial action is necessary to ensure that conditions are maintained and that further progress is made toward a Permanent Solution A completed Response Action Outcome Statement (BWSC-104) will be submitted to DEP Indicate whether the operation and maintenance will be Active or Passive (Active Operation and Maintenance is defined at 310 CMR 40 0006.): Active Operation and Maintenance Passive Operation and Maintenance (Active Operation and Maintenance makes the Site subject to a Post-RAO Class C Active Operation and Maintenance Annual Compliance G. LtP8PINION: I attest under the pains and penalties of perjury that I have personally examined and am familiar with the information contained in this transmittal form, including any and all documents accompanying this submittal In my professional opinion and judgment based upon application of (i) the standard of care in 309 CMR 4 02(1), (ii) the applicable provisions of 309 CMR 4 02(2) and (3), and (iii) the provisions of 309 CMR 4.03(5), to the best of my knowledge information and belief,

> if Section B indicates that a Phase I, Phase II, Phase lil, Phase IV or Phase V Completion Statement is being submitted, the response action(s) that is (are) the subject of this submittal (i) has (have) been developed and implemented in accordance with the applicable provisions of M.G.L. c. 21E and 310 CMR 40.0000. (ii) is (are) appropriate and reasonable to accomplish the purposes of such response action(s) as set forth in the applicable provisions of M G.L c. 21E and 310 CMR 40.0000, and (iii) complies(y) with the identified provisions of all orders, permits, and approvals identified in this submittal.

> if Section B indicates that a Phase I/ Scope of Work or a Phase IV Remedy Implementation Plan is being submitted, the response action(s) that is (are) the subject of this submittal (i) has (have) been developed in accordance with the applicable provisions of M.G.L c. 21E and 310 CMR 40.0000, (ii) is (are) appropriate and reasonable to accomplish the purposes of such response action(s) as set forth in the applicable provisions of M.G L. c. 21E and 310 CMR 40.0000, and (iii) complies(y) with the identified provisions of all orders, permits, and approvals identified in this submittal, > if Section B indicates that an As-Built Construction Report or a Phase V Inspection and Monitoring Report is being submitted, the response action(s) that is (are) the subject of this submittal (i) is (are) being implemented in accordance with the applicable provisions of M G.L. c. 21 E and 310 CMR 40.0000, (ii) is (are) appropriate and reasonable to accomplish the purposes of such response action(s) as set forth in the applicable provisions of M G L c 21 E and 310 CMR 40.0000, and (iii) complies(y) with the identified provisions of all orders, permits, and approvals identified in this submital.

I am aware that significant penalties may result, including, but not limited to, possible fines and imprisonment, if I submit information which I know to be false, inaccurate or materially incomplete.

Check here if the Response Action(s) on which this opinion is based. if any, are (were) subject to any order(s), permit(s) and/or approval(s) issued by DEP or EPA. If the box is checked, you MUST attach a statement identifying the applicablplawsioris thereof. LSP Name: Eric G. Nelson LSP# 2516 Stamp

Telephone 781-245-6606 Ext : 5612 ER 1 FAX: 781-246-5060 (optional)

Signature

Date: -

Revised 3/30/95 Supersedes Forms BWSC-010 (in nart) and 013 Page 2 of 3 Do Not Alter This Form Sz

-7/.yg ~ o Massachusetts Department of Environmental Protection BWSC-102B Bureau of Waste Site Cleanup Release Tracking Number RELEASE LOG FORM ATTACHMENT

E. LOG/RELEASE LOCATION INFORMATION: (complete if using BWSC-1028 only) City/Town: C '. __ .. Date: - Time M PM Release Address L Use of Atlachment (check one): ] Amendment to Release Log Form J Attachment Page(s): of:

F. INSPECTIONS OR SITE VISITS (also Follow-up Office Response): (check one) I Initial Complianoe Field Response - Announced C Initial Compliance Field Response - Unannounced [ Compliance Field Response - Announced [ Compliance Field Response - Unannounced Short Notice Audit Inspection L Field Response - Direct Oversight C Follow-up or Other Field Response \4 Tollow-up Office Response G. ADDITIONAL DESCRIPTION:

1/ A14- h/ /v

H. DEP ASSIGNMENT: (complete if using BWSC-102A and 1026 or BWSC-1028 only) Preparer of RLFA (please print) . Signature

Staff Lead Assigned (if different from preparer): - i Check here if the Release or Threat of Release is unassigned.

Check here if this RLFA records a change in staff lead.

Revised 11/22/99 Do Not Alter This Form Page 2 of 2 FOLEY, HOAG & ELIOT LLP

ONE P3ST OF11-11'1 SQU AR BOSTON. MASSACHUSEIT'S 02109-2170

TELEPHONE 617-832-1000 1747 ITNNSYl.VANIA AVENULI. N W. FACSIMILE 617-832-7000 [111 120) Rndan E Kromm www.he com WASHINGTON, D.C. 20006 oli) 3:-1251 1l1i 202-223-1200

rrn.mQ hcom I-AX: 202-785-66S7

March 20, 2000

Mr. David Brown Watson Park Library 85 Quincy Avenue Braintrec, MA 02184

Re: Documents to be Filed at Local Information Repositories Quincy Shipyard DFP Release Tracking Number 3-0536

Dear Mr. Brown:

Enclosed are copies of a Tier II Extension Application submitted to the Department of Environmental Protection (DEP) by General Dynamics Corporation (GDC). This document concerns ongoing environmental cleanup activities at the Quincy Shipyard, also known as the Fore River Shipyard.

In accordance with the Public Involvement Plan (PIP) developed for this site, documents related to the Shipyard cleanup are being made available to the public at three local Inforiation Repositories, one of which is the Watson Park Library. The enclosed document is submitted for iriclusion in the Library's files on this subject.

Thank you for your assistance in making this information available.

Sincerely,

Randall E. Kromm

Enclosures cc: Sharon Gobiel, DEP Robert F. White, GDC 0 0

FOLEY, HOAG & ELIOT LLP ONE IOST OFFICE SQU ARE BOSTON, MASSACHUSETT S 02109-2170

TELEPI)NE 617-832-1000 1747 NNNSYLVANIA AViN U.N W FACSIMILE 617-832-7000 0K)2ra Rndal E Kroin www(Ihecon WASHINGTON, D.(. 20006 (tm 8 21251 ITE: 202 223 1200 rkrorn:, Ili nm FAX 202 785-6697

March 20, 2000

Ms. Judith Pat Tufts Library 46 Broad Street Weymouth, MA 02188

Re: Documents to be Filed at Local Information Rcpositorics Quincy Shipyard DEP Release Tracking Numbcr 3-0536

Dear Ms. Patt:

In accordance with the Public Involvement Plan (PIP) developed for this site, documents related to the Shipyard cleanup are being made available to the public at three local Information Repositories, one of which is the Tufts LIbrary. The enclosed document is submitted or inclusion in the Library's files on this subject.

Thank you for your assistance in making this information available.

Sincerely,

Randall E. Kromm

Enclosures cc: Sharon Gobiel, DEP Robert F. White, GDC

102945 1 FOLEY, HOAG & ELIOT LLP ONE POST OFFICE SQUARE BOSTON, MASSACHUSEFITS 02109-2170

TELEPHONE 6[7-632-1000 1747 PINNSYLVANIA AVINl , N W FACSIMILE: 617-32.7000 S0111 1"A lindall E. Krommn www jli.com WASHINGTON, ) C 20006 (0)2,332-1251 TEL: 202-2 3 210 rkromm 1weTe.coIm FAX: 202-785 6087

March 20, 2000

Ms. Linda Beeler Thomas Crane Public Library 40 Washington Street Quincy, MA 02169

Re: Documents to be Filed at Local Information Repositories Quincy Shipyard DEP Release Tracking Number 3-0536

Dear Ms. Beeler:

Enclosed are copies of a Tier II Extension Application submitted to the Department of Environmental Protection (DEP) by General Dynamics Corporation (GD). This document concerns ongoing environmental cleanup activities at the Quincy Shipyard, also known as the Fore River Shipyard.

In accordance with the Public Involvement Plan (PIP) developed for this site, documents related to the Shipyard cleanup are being made available to the public at three local Infonnation Repositories, one of which is the Thomas Crane Public Library. The enclosed document is submitted for inclusion in the Library's files on this subject.

Thank you for your assistance in making this information available.

Sincerely,

Randall E. Kromm

Enclosures cc: Sharon Gobiel, DEP Robert F. White, GD

31) i I f

FOLEY, HOAG & ELIOT LLP ONE P0T OFFICE SQUARE BOSI ON, MASSACHUSETTS 02109-2170

TELEPHONE 617-332-1000 1747 P[ENNVHL VANIA AiI4I NAX FACSIMILE 617-832-7000 SU IT- L Laur Bun wwwfhe c[m WASHINGTON, D.C. 20006 ti7 82- 1ii1 TEL: 202-223-1200 lhun 11th FAX. 202-7S5-6657

September 3, 1999

Waiver Submittals Attn: Sharon A. Gobiel Massachusetts Department of Environmental Protection Bureau of Waste Site Cleanup Northeast Regional Office 205 Lowell Street Wilmington, MA 01887

Re. Fore River Staging Area (former General Dynamics Shipyard) -- Central Yard Oil Plume, DEP Waiver Site DEP Site No. 3-0536 Consultant of Record for Remediation

Dear Ms. Gobiel:

On behalf of General Dynamics Corporation, I wish to advise you that GZA GeoEnvironmental, inc ("GZA") has replaced IT Corporation (formerly known as Groundwater Technology, Inc. and Fluor Daniel GTI, Inc.) as the Consultant of Record with respect to remediation of the Central Yard Oil Plume ("CYOP") at the Fore River Staging Area (former General Dynamics Shipyard). GZA iias assumed all cespunsibilities foue61iiiy unidcrtaken by IT Corporation with regard to remediation of the CYOP. Lawrence Feldman (LSP #8107) of GZA has been, and will continue to be General Dynamics' chief Consultant of Record, and now the overall LSP of Record for this site.

If you have any questions, please feel free to call.

Very truly yours,

Laurie Burt Sharon A. Gobiel September 3, 1999 Page 2

cc: Robert F. White. General Dynamics Lawrence Feldman, LSP, GZA Mark Radville, MWRA Steve Buttner, MHI Harding Lawson Associates

* . I-

April 1, 1999

Ms. Sharon Gobiel Massachusetts Department of Environmental Protection Bureau of Waste Site Cleanup 205A Lowell Street Wilmington, MA 01887

RE: Remediation System Modification Plan MWRA Fore River Staging Area, Building 9 Oil Plume Release Tracking Numbers 3-0536 and 3-10266

Dear Ms. Gobiel:

On behalf of the Massachusetts Water Resources Authority (MWRA), Harding Lawson Associates ( ILA) is pleased to submit a copy of a Remedial System Modification Plan (RSMP) for oil removal from the Building 9 (Truck Queue Area) oil plume. This Plan is being submitted in anticipation of the Site transitioning from a Waivered site to a Tier 1I site in April 1999.

The Building 9 Oil Plume is in Phase V (Operation, Maintenance, and/or Monitoring) of the Massachusetts Contingency Plan. This is consistent with the work already completed at the Site, including an extensive subsurface assessment, completion of a site-specific risk assessment and feasibility studies, and ongoing remediation of the subject plume. To date, remediation efforts have resulted in the removal of approximately 1,000 gallons of residual hydrocarbons from the Building 9 oil plume. The objective of the proposed activities is to refine our understanding of the plume boundaries, and provide sufficient information on thickness and distribution of residual hydrocarbon to evaluate the feasibility of increasing the product recovery rate.

Please feel free to call me if you have any questions regarding the attached. Questions may also be referred to Mark Radville, Program Manager, MWRA, at (617) 788-2759.

Sincerely,

HARDING L.AWSON ASSOCIATES

Herbert W. Colby Senior Project Manager

Attachment

cc: M. Radville - MWRA E. Nelson, LSP - HLA

C* MASSACHUSETTS WATER RESOURCES AUTHORITY

MODIFICATION NO. I TO TASK ORDER NO. I

REMEDIATION SYSTEM MODIFICATION PLAN FOR THE BUILDING 9 OIL PLUME INVESTIGATION

A. GENERAL APPROACH

Current product distribution information from monitoring wells in the vicinity of the former Building 9 (herein after referred to as the Truck Queue Area) suggest that the existing network of monitoring wells is not adequate to confidently delineate the free-product. The objective of the investigation is to install sufficient monitoring wells in the area of the oil plume with enough detail and certainty so as to define the extent of the free product and conduct a meaningful evaluation of remedial options. To achieve that objective, HLA proposes to conduct the following:

* Install eight shallow monitoring wells with screens positioned to permit determination of free- product presence and thickness. * One week after well installation and development, perform an initial baildown of free-product from all wells to reduce effects of boring advancement/well construction on free-product thickness. Monitor free-product recovery. * Measure thickness of product in all relevant monitoring wells two weeks after the initial baildown. Product will also be removed from the wells during this measuring event. * Prepare well logs, a plan of monitoring well locations, and tabular summary of product thickness data for review by MWRA.

Following the completion of the proposed work, HLA will discuss the results and possible future activities with MWRA. In addition to the above tasks, HLA will supervise disposal of approximately 150 gallons of recovered oil contained in the oil tank within Building 8.

B. PROPOSED WELL LOCATIONS

Figure 1 depicts proposed locations for the eight monitoring wells. HLA proposes to install two wells in apparent upgradient locations and six wells in apparent downgradient locations. HLA will install the two upgradient locations first, followed by the six downgradient locations. Well locations depicted on Figure I are approximate. Due to the uncertain migration pathway of the free-product, the exact location of each of the 8 wells may change based upon field conditions in order to define the areal extent of free-product in the vicinity of the Truck Queue Area. All boring locations will be marked and approved in the field by Steve Giacchetti, FRSA Facility Engineering Manager. Digsafe will also be notified of subsurface activities. In addition, no borings shall be allowed within the area 50 feet from the south face of Building 8, to allow for proposed construction of new railroad track in that area.

Harding Lawson Associates

q:\w4statemwra\proposal\Iskprop\PTSK I AWP.doc 2341.01 C. WELL CONSTRUCTION METHODS

Soil Boring Installation

A total of eight soil borings will be advanced to obtain data on subsurface soil conditions, and to define the extent of free-product in the Truck Queue Area. An HILA engineer/geologist will provide oversight during the drilling and monitoring well installation phases, maintain drilling and construction logs, and screen soil samples. Soil borings will be advanced using hollow stem auger (H-AS) drilling techniques. The drilling of soil borings and the installation of monitoring wells will be conducted following the methodologies outlined in the MADEP Standard Reference for Monitoring Wells (WSC-310-9 1). The final depth of the borings will be determined based on depth to groundwater and field observations. It is assumed that these borings will be drilled to a minimum depth of 20 feet below the ground surface. Each soil boring will be advanced using 4 1/4-inch hollow stem augers.

Continuous split spoon soil samples will be collected within each boring beginning at the ground surface and continuing to the bottom of the boring. Soil samples will be collected using decontaminated 2-foot long, 3-inch or 2-inch outside diameter ("OD") stainless steel split spoon samplers. Samples will be logged in the field, and headspace screened for volatile organic compounds (VOCs) with a photoionization detector (PID). Soil descriptions will include soil textures, visual observation, odors, PID meter readings, and depth of observed groundwater levels. Soil Boring Logs will be completed by field personnel and will include sampling depth, soil description, date, weather conditions, and any other pertinent information. Soil samples, which exhibit visual evidence of being impacted with petroleum, will be photographed. Between each soil sample obtained, split spoons will be decontaminated with alconox, methanol, and distilled water. Soil cuttings will containerize in 17H open top drums for disposal. HLA anticipates that five drums of soil will be generated and disposed of as oily solids (MAC I).

Monitoring Well Installation

Eight monitoring wells will be installed and completed flush to the ground surface. Monitoring wells will be installed with 5 feet of well screen designed to intersect a high permeability zone previously identified in the vicinity of the plume. It is anticipated that the bottom of each well screen will be at an assumed depth of 20 feet below the ground surface. Monitoring wells will be constructed of 2-inch diameter Schedule 40 polyvinyl chloride (PVC) riser and screen. The screen will be factory-slotted, with a slot width of 0.010-inch. Screen and riser will be flush joint threaded. Risers will be set round, plumb, and true to line. The riser will be equipped with a vented cap. Well screens will be filter-packed with silica sand and sealed with bentonite. The remaining well annulus will be grouted to surface. Each monitoring well will be labeled (i.e., MW-1) at the time of completion. All details of monitoring well construction will be documented on Monitoring Well Construction Diagrams.

Monitoring Well Development

Each monitoring well will be developed to stability following installation, using a pump and surge

Harding Lawson Associates

q:\w4sLale\mw ra\proposal\tskprop\PTSK! AWP.doc 23-11 01 2 0 0

technique. The purpose of development is to reduce the amount of fine-grained material entering the well from the surrounding formation. Monitoring well development procedures and observations will be documented in a field logbook. Water will be evacuated with a hand-operated inertial pump with tubing. No water or other liquids will be introduced into the well other than formation water from that location. The development apparatus will be decontaminated prior to use in the next monitoring well. Groundwater purged during monitoring well development will be containerized in 17H drums for disposal. HLA anticipates seven drums of groundwater will be generated and disposed of as oily liquids (MAO 1).

D. FIELD TESTING

One week after monitoring well installation and development, HLA will perform an initial baildown test to reduce effects of boring advancement/well construction on free-product thickness. Prior to initiation of the initial baildown test, HLA will conduct groundwater monitoring and obtain water level and free-product measurements of all wells in the vicinity of the Building 9 oil plume.

Groundwater Monitoring

Groundwater monitoring will begin with the least contaminated monitoring wells and end with the most contaminated monitoring wells. HLA will check each monitoring well for proper identification and location, open the road box cover, unlock the monitoring well and remove the cap. The well will immediately be scanned with a PID meter and the reading will be recorded on the Field Data Record. The distance between the top of the monitoring well riser and the ground surface will also be measured and recorded on the Field Data Record. Using an electronic oil/water interface probe, HLA will measure for the presence of free-product, the static water level, and the depth of the monitoring well to the nearest 0.01 foot. Between each well monitored the interface probe will be rinsed with an alconox and potable water solution and then rinsed with DI water.

Baildown Testing

HLA will conduct the initial baildown testing using a pump. During the baildown testing, free- product will be removed from each monitoring well. After recharge, each well will be monitored for water level and free-product measurements and recorded as previously discussed. Two weeks after the initial baildown test, HLA will return to the site and monitor all monitoring wells in the vicinity of Building 9. Product also will be removed from each well during this second monitoring event.

E. HEALTH AND SAFETY

HLA has prepared a Health and Safety Plan for the Building 9 Oil Plume Investigation, which is included as Appendix A. HLA anticipates a personal protection level of Modified D during well construction and field testing activities.

Harding Lawson Associates

q;\w4statc\nwra\proposal\tskprop\PTSK AWP.doc 2341.01 3 F. PROPOSED DRILLING SUBCONTRACTOR

Drilling will be conducted by Earth Exploration, Inc. Earth Exploration Inc. was identified as the team member in our original MWRA proposal. HLA anticipates a three day drilling program to complete the well installation and a one day well development program.

Harding Lawson Associates

q:\w4state\mwra\proposal\tskprop\PTSK I AWPdoc 2341.01 4 Harding Lawson AssocIates FIGURE 1 PROPOSED MONITORING WELL LOCATIONS BUILDING 9 OIL PLUME MWRA-FRSA QUINCY, MA APPENDIX A Site: Building 9 - Fore River Staging Area Contact: Mark Mark Radville (617) 788-2759 Street Address: Fore River Staging Area, Quincy, MA Proposed Date(s) of Investigation: March 1999 Job Number: 2341.01 Prepared by: Scott Shelton Date: February 23, 1999 Approved by: Date: Proposed Activity(s): Well Installation/Field Testing/Contractor Oversight Known or Suspected Chemicals (include PELs): #2 Fuel Oil (none)

HAZARD EVALUATION (Check all that apply):

Overall Hazard Estimation: Serious Moderate LALowUnknown None

Major Exposure Route(s): Dermal Inhalation Ingestion Puncture

Contaminant Location(s): Surface i Underground Soil Sediment Water Tank WOther (list): Health Hazard(s): Liquid Xi Solid Sludge Corrosive Igjgnitable Volatile |% Radioactive Reactive Unknown

Safety Hazard(s): Height Equipment Cold Stress Noise 7 Eye Near Water Confined Space Heat Stre Machinery Burns Lifting $j Slips/Falls Other (list): Slow moving tractor/trailers.

EQUIPMENT (check all that apply): Initial Level of Personal Protection: Modified D PPE Selected: Cartridge Respirator Coveralls Gloves Escape Respirator Safety Glasses inner Safety Boots/Shoes Face Shield -outer Chemical Resistant Boots 1 Hard Hat Tyveks Disposable Boot Covers L- Ear Protection > regular Other (list): -coated

Monitoring Equipment: Combustible Gas/Oxygen Meter Explosimeter |OVA Hydrogen Sulfide Meter r:Draeger Tubes PID Radiation Alert Meter r List: Dosimeter Badge [Other (list):

Emergency Equipment: $ First Aid Kit lFire Extinguisher X] Eye Wash Other (list):

CONTAMINANT LEVELS FOR MODIFICATION OF PROTECTIVE EQUIPMENT: 5 ppm PID (sustained)

q \w4tate\nwrn\proposaltvskprop\health xis 02341.0 1 DECONTAMINATION/DISPOSAL: All personnel and/or equipment leaving contaminated sites are subject to decontamination. Under no circumstances (except emergency evacuation) will personnel be allowed to leave the site prior to decontamination. The decontamination procedures to be used at the site are as follows: Tyvek and disposal items will be placed in garbage bags and properly disposed of.

EMERGENCY MEDICAL TREATMENT/FIRST AID: First aid will be rendered to any person injured on-site, as appropriate. The injured person will then be transported to a medical facility for further examination and/or treatment. An ambulance will be used to transport the injured person to the hospital unless one is not readily available or could result in excessive delay. In this case, other transport is authorized. Under no circumstances will injured persons transport themselves to a medical facility for emergency treatment.

EMERGENCY EVACUATION: In the event of an emergency requiring evacuation, the HSO assumes the role of on-site coordinator. Evacuation responses will occur at three levels: (1) withdraw from the immediate work area (100+ feet upwind); (2) site evacuation; and (3) evacuation of surrounding area. If the residences and commercial operations require evacuation, the local agencies will be notified and assistance requested. Designated on-site personnel will initiate evacuation of the immediate off-site area without delay.

EMERGENCY TELEPHONE NUMBERS:

Local Police Department (617) 479-1212 or 911 Local Fire Department (617) 376-1010 or 911 Local Rescue Service (617) 376-1341 or 911 Primary Hospitat Quincy Hospital (617) 773-6100 Health Resources - (800) 350-4511 - Pager (leave area code and telephone number) (800) 455-0964 National Poison Control Center (800) 492-2414 Chemical Manufacturing Association-Chemical Referral Center (800) 262-8200 Health and Safety Manager: Cindy Sundquist (207) 775-5401 (w) (207) 892-4402 (h)

AUTHORIZED PERSONNEL:

'+ Garth Hirsch *+ Herbert Colby * Current First-aid Certification + Current CPR Certification

FIELD TEAM REVIEW: I have read and reviewed the health and safety information in the HASP. I understand the information and will comply with the requirements of the HASP.

Name: Date: Name: Date: Name: Date: Name: Date: Name: Date:

q:\w4state\mnwa~roposam~skprop~health. ls 0234L.01 Veasjel

:d(omoon ishmd DiMoiIdnd MIOoI

f MooniIl-an ROUTES TO EMERGENCY MEDICAL FACILITIES

PRIMARY HOSPITAL:

Facility Name: Quincy Hospital Address: 114 Whitwell Street Telephone Number: (617) 773-6100

DIRECTIONS TO PRIMARY HOSPITAL (attach map):

From the Fore River Staging Area take Washington Street. Take a left on Adams Street in Quincy Center. Take a left onto Whitwell Street. Quincy Hospital is on Whitwell Street.

q:\w4state\mrna\proposal\tskprop\health. xis 02141.0Ot FOLEY, HOAG & ELIOT LLP ONE POST OFFICE SQUARE BOSTON, MASSACHUSETrS 02109-2170

TELEPHONE 617-832-1000 1747 PENNSYLVANIA AVINUE, N.W FACSIMILE 617-832-7000 SUi 1200 Randall E. Kromm www.fhe.com WASHINGTON, D.C. 20006 (617) 832-1251 TEL: 202-223-1200 rkrormfehe.com FAX: 202-785-6687

February 24, 1999

Ms. Linda Beeler Thomas Crane Public Library 40 Washington Street Quincy, MA 02169

Re: Documents to be Filed at Local Information Repositories Quincy Shipyard DEP Release Tracking Number 3-0536

Dear Ms. Beeler:

Enclosed are copies of a Tier I Extension Application and Remediation System Modification Plan submitted to the Department of Environmental Protection (DEP) by General Dynamics Corporation (GDC). These documents concern ongoing environmental cleanup activities at the Quincy Shipyard, also known as the Fore River Shipyard.

In accordance with the Public Involvement Plan (PIP) developed for this site, documents related to the Shipyard cleanup are being made available to the public at three local Information Repositories, one of which is the Thomas Crane Public Library. The enclosed documents are submitted for inclusion in the Library's files on this subject.

Thank you for your assistance in making this information available.

Sincerely,

Randall E. Kromm

Enclosures cc: Sharon Gobiel, DE 3 Robert F. White, GDC Mark Radville, MWRA

302880.1 I

FOLEY, HOAG & ELIOT LLP ONE POST OFFICE SQUARE BOSTON, MASSACHUSETTS 02109-2170

TELEPHONE 617-832-1000 1747 PENNSYLVANIA AVENUE, N W FACSIMILE 617-832-7000 SUITE [200 Randall P. Kromm www.the.com WASHINGTON, D.C. 20006 (617) 832-1251 TEL: 202-223-1200 [email protected] FAX: 202-785-6687

February 24, 1999

Ms. Judith Patt Tufts Library 46 Broad Street Weymouth, MA 02188

Re: Documents to be Filed at Local Information Repositories Quincy Shipyard DEP Release Tracking Number 3-0536

Dear Ms. Patt:

Enclosed are copies of a Tier II Extension Application and Remediation System Modification Plan submitted to the Department of Environmental Protection (DEP) by General Dynamics Corporation (GDC). These documents concern ongoing environmental cleanup activities at the Quincy Shipyard, also known as the Fore River Shipyard

In accordance with the Public Involvement Plan (PIP) developed for this site, documents related to the Shipyard cleanup are being made available to the public at three local Information Repositories, one of which is the Tufts Library. The enclosed documents are submitted for inclusion in the Library's files on this subject.

Thank you for your assistance in making this information available.

Sincerely,

Randall E. Kromm

Enclosures cc: Sharon Gobiel, DEP Robert F. White, GDC Mark Radville, MWRA

302945.1 Geolnsirollllicnt11 Inc. November 1800 File No 7-400 50

Ms. Sharon A Gobiel Massachusetts Department of Env ironmental Protection Northeast Reuional Office 25 Lowell Street Gia Wilmington, Massachusetts 01887 DEP Waiver Site I D. Number 309536 and 3-10266

Re. Waiver Submittal Completion and Startup of \ ij k i ir i Groundwater Extraction Well - RW-5B Central Yard Oil Plume

I IL I IT - Quincy Shipyard, Quincy, Massachusetts

Dear Ms. Gobiel:

This letter confirms the replacement of groundwater extraction well RW-4 and RW-5A at the above-referenced site (the "Site"). This work was performed in accordance with GZA GeoEnvironmental, Inc.'s (GZA) letter report dated July 1, 1998.

BACKGROUND

As indicated in our July 1, 1998 letter, planned reconstruction in the Building I I area by Massachusetts Heavy Industries (MHI), the current owner of Building i1, necessitated modifications to the product recovery system which had been installed in the area of the Central Yard Oil Plume (CYOP). Specifically, it was necessary to either replace or repipe RW-5A to accommodate the planned reconstruction and reuse of the building by MHI Based on a shutdown test performed in April/May, 1998 as well as on historic operating data, it was concluded that RW-4 and RW-5A could be replaced with a single recovery \ I s well (identified as RW-4A in the July I, 1998 letter but subsequently renamed RW-5B) located outside of Building I1 approximately 50 feet east of RW-4 and southwest of RW- 5A.

INSTALLATION AND STARTUP OF RW-4A

RW-5B was installed under the oversight of Fluor Daniel/GTI (GTI) at the location shown on the attached Figure on July 22, 1998. A well installation log for RW-5B is attached. Connection of RW-5B to the groundwater treatment system and electrical distribution systems was delayed pending completion of trenching for the connection piping by MHI Copyright © 1998 GZA GeoEnvironmental, Inc.

DPr NOV 2 6

\i~ili s le lii .. I 'a l Massachusetts Department of Environmental Protection November 13. 1998 File No 7400 50 Page 2

and their contractors Once those activities were completed, RW-SB was connected on September 28, 1998 and pressure tested on September 30, 1998. The recovery system in RW-5B was started up on October 13, 1998

Please do not hesitate to call if you have any questions or comments regarding the above

Very truly yours.

t-lbert J R'eiardelli. P.E , LSP Principar

-tawrence Feldman. LSP Senior Principal

Encl. - Figure Boring Log

cc. Laurie Burt, Esq. (Foley, Hoag & Eliot) Robert F. White (General Dynamics) Dan Kelly (General Dynamics) John Mitchell (Fluor Daniel/GTI)

g:\7400.zgn\7400-1 7.dja\corresp\zgn 7109.doc ATTACHMENT 1

EXPLORATION LOCATION PLAN I

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BORING LOG osmdimt ieSNit iegaerc

Drilling Log FUOR DAME TI Recovery Well RW-5B

See Site nap Project General Dynamics/urncyM Owner General Dynamics For Boring Location Location Quincy, MA Proi. No. 102722 Surface Elev. Total Hole Depth 34 ft, Diameter /2 In. COMMEN TS: Top of Casing Water Level Initial /8.0 ft. Static Screen: Dia /0 in. Length 20.0 ft. T ype/Size Stainless Stee/O.035 in. BDL = Below OVM Betechon Lirit Casing: Dia /0 in. Length /4,0 ft. Type Stainless Steel Fill Material Jessie Morrie #1 Rig/Core Drill Co. American Drlling Method Hollow Stem Auger Driller Kenny Bylund Log By W. Holt Date 7/22/98 Permit i NA Checked By J Mitchell License No. - p - p p - p . P C C

.1 0 Description I-aa-E E U c1U ao W 41 0, (Color, Texture, Structure) E E- om a 0 W 0 Trace < 10%. Little 10% to 20%. Some 20% to 35%. And 35% to 50% u- -w

- 0 -4----,,

-2

-4

BOL ||CG-1 Dark brown, moist, coarse to medium SAND, some fine gravel, ittle -6 clay, little silt

- 8

-rybon - 10

- 12 SP

- 14

16 80.2 jCG-2 Gray/brown. moist. medium to fine SAND, little fine gravel, trace little st (petroleum odor) 18

20-4

Gray, "et, meum to fine SAND, ittle coarse sand (petroleum odor) 22 76 CG-3

- 24 Paqe: of 2 1l/09/199611thiog-June.961/09/19% Itbicg-June.96 Page: ! of 2 09 S Drilling Log FUOR DANIEL GTE9 Recovery Well RW-5B

Project General Dynamics/QuxncvMA Owner General 0ynamics I ti Quinctv MA Pr I'102722

0~ OE CoDe4 o 1 scription V- 3 .,IO=- : C nI (Color, Texture, Structure) 0 0a D LAn.Trace < 10%. Little 10% to 20%. Some 20% to 35%, And 35% to 50%

-24-4

- 26 -

-28- - -- Sarre as above

-- SP -30 -32-

- 3 Bottom of exploration at 34'

-36-

-38 -

-40-

-42--

-44-

-46-

-48

-50-

-52-

-54-

- 56 - I I

11/09/1998Blithlog--June,96 Page: 2 of 2 en Q#Ac C / GeL-mlonm ma In\

April 28, 1998 File No. 7400.50

Ms. Sharon A. Gobiel Massachusetts DEP Northeast Regional Office 10 Commerce Way Woburn, Massachusetts 01801 on Re: Waiver Submittal Scope of Work RW-5A Shutdown Test Quincy Shipyard Quincy, Massachusetts Release Tracking No. 3-0536 and No. 10266 Ii.

Dear Ms. Gobiel: WI On behalf of General Dynamics Corporation (GD), GZA GeoEnvironmental, Inc. (GZA) is pleased to submit for your information the following Scope of Work to perform an evaluation of product recovery in the vicinity of the eastern portion of the Central Yard Oil Plume (CYOP) at the above- referenced site. This Scope of Work is part of our ongoing activities to improve the efficiency of product recovery at the CYOP.

The current owner of the Building II has indicated that, because of planned reconstruction and future use in the building, it will no longer be possible to maintain the existing well casings, associated product and groundwater discharge lines and electrical lines above floor level in Building I1. The RW-5A shutdown test will evaluate the need to either leave RW-5A in place and modify existing piping, or move RW-5A to a new location outside Building 11.

We will provide you with the results of the shutdown test once they are available. Should you have any questions or comments, please do hesitate to contact the undersigned.

Very Truly Yours

I - i INC.

Lawrence Feldman, LSP c' Senior Principal WV AJR:rvh

Attachments: Scope of Work

cc: Waiver Unit, DEP G:\7400.ZGN\7400-17 )JA\COR RESP\Zgn 17106.dot

1 . , a d 'l-i . -' : - -. I , - . - \ \ I S PROPOSED PLAN FOR RW-SA SHUTDOWN TEST

BACKGROUND

Massachusetts Heavy Industries (MIHI), the current owner of the Building II area, has advised General Dynamics that due to safety issues associated with the roof of Building i1, and planned reconstruction of the entire roof of Building I I and renovation of the building interior for planned reuse, it will be necessary to make modifications to existing recovery and monitoring wells in Building 11. Existing monitoring wells include MW-I and MW-8. Existing recovery wells in Building I I include RW-2 which is currently inactive, and RW-5A which is currently active. Based cia\ on hydrogeologic testing in 1994, RW-2 was removed from active status (with DEP notification) since oil recovery from this well was minimal and it was no longer necessary to contain the plume. Results of pump tests in the CYOP performed by GZA in 1994 indicated that RW-5A was necessary to contain the eastern portion of the CYOP from migrating downgradient. Since that time, apparent oil thicknesses measured in wells in this area have continued to decrease. Because of planned roof reconstmuction and future use in Building 11, we understand that MH[ has indicated that it will no longer be possible to maintain the existing well casings, associated product and groundwater discharge lines and electrical lines above floor level in Building II . The planned modifications to Building I I provides the opportunity to evaluate the current effectiveness of RW-5A in containing the eastern portion of the CYOP and the recovery of oil in this area. This evaluation can be undertaken by performing a limited shutdown test of RW-5A Because RW-5A is currently an active part of the CYOP recovery system, the RW-5A shutdown test is proposed to evaluate the need to either leave RW-5A in place and modify existing piping, or move RW-5A to a new location outside Building 11, and cut RW-5A to floor level, remove associated piping and leave the recovery well in place.

PURPOSE

According to the remedial requirements of the September 20, 1987 letter from DEP (then DEQE), establishing the requirements for the CYOP, the CYOP cleanup is still in the active product recovery Phase of remediation (Phase I). DEP requirements provide that Phase I may transition to Phase II when it can be demonstrated that product recovery has become asymptotic for a period of six-months and that product thickness in all impacted wells is less than two-inches. Requirements for Phase II indicate that the groundwater portion of the recovery system must remain active for one hydrologic cycle (one-year) to assess the effects of seasonal fluctuations on product thickness. Although the product recovery pumps will not be active during this cycle, DEP requirements provide that the full system needs to be operational should product reappear.

Monitoring of the eastern portion of the CYOP in the area of RW-5A indicates the product thicknesses in monitoring wells have been below 2-inches for more than 6 months. Product recovery from RW-5A has been asymptotic for at least six months and therefore General Dynamics has achieved the objectives of Phase I in the eastern portion of the CYOP. GZA proposes performing a shutdown test in the vicinity of RW-5A to assess whether substantial quantities of SPH would be released with the groundwater depression system at RW-5A shutdown for the eastern portion of the CYOP. If results of the shutdown test indicate that SPH does not accumulate in monitoring wells at greater than two inches in the eastern portion of the CYOP, it may be possible to meet the requirements of the DEP 1987 letter by terminating recovery of groundwater and product from RW- 5A and installing an alternate recovery well (RW-5B) either to the north or south of Building I I and piping and operating a groundwater depression pump in that well for at least one year. Alternatively, if the shutdown test indicales RW-5A is still necessary, it will be necessary to repipe the discharge lines from RW-5A to allow use of Building I I by MHL.

The following Scope of Work provides a description of our proposed plan for assessing the future use of RW-5A. In summary the objectives of this scope of work are two-fold:

0 Assess whether SPH becomes available under non-pumping conditions in the eastern portion of the CYOP.

* Assess the appropriate well configuration for capture of residual SPH in this portion of the 01\X CYOP. SCOPE OF WORK

Performance of Shutdown Test

Upon authorization to proceed with this scope of work, GZA will coordinate with Fluor Daniel GTI to gauge groundwater elevations and apparent fuel oil thickness measurements in all normally monitored wells. These measurements will serve as a pre-shutdown evaluation of groundwater flow and apparent oil thickness. It is anticipated that Fluor Daniel GTI will perform most groundwater elevation and fuel oil thickness measurements. GZA will perform limited measurements, but oversee and coordinate the shutdown test. Due to the safety issues concerned with working in Building I1, it is anticipated that Flour Daniel GTI will make arrangements with MHI to ensure that adequate protection of safety is provided. It is further anticipated that this shutdown test will not commence until GT1 agrees that an adequate level of safety is provided.

Subsequent to pre-shutdown measurements, GZA will coordinate with GT1 to shut down RW-5A as well as RW-4 (also located in the eastern portion of the CYOP) and keep all other normally operating recovery wells active. It is anticipated that RW-4 and RW-5A will be shutdown for approximately three weeks depending on observed conditions. The following provides a schedule of periodic measurements.

For the first three days of shutdown, measurements of apparent fuel oil thickness and groundwater elevations will be made for monitoring and recovery wells in the RW-5A area (GZ-5A, MW-1, MW- 5, MW-8, MW-14A, MW-15S, MW-16, GD-2269A, RW-4 and RW-5A). Measurable quantities of fuel oil will be removed from the well (i.e. via hand bailing), quantified and transported to the onsite oil storage tank.

On a weekly basis for three weeks, that is, three separate measurements after the pre-shutdown readings, measurements of apparent fuel oil thickness and groundwater elevations will be taken in the monitoring and recovery wells in the RW-5A area. At the two week time, measurements of groundwater elevation and apparent fuel oil thickness will be made for all normally monitored wells. Based on previous hydraulic testing at the Site, it is anticipated that this should be sufficient time to allow hydraulic equilibration in this area. Measurable quantities of oil will be removed from wells in the RW-5A area after the one week measurements. This will allow two weeks to ascertain if SPH will accumulate in the monitoring wells. It is possible that because RW-5A has been pumping for so long that an area of increased permeability in the highly heterogeneous subsurface (fill, construction debris, etc.) around the well will allow minor, intermittent residual oil in the area to settle around the recovery well upon shutdown. During this period, the monitoring wells and recovery wells located within Building I1 will be modified as requested by MHI to permit open use of the main floor level of the facility.

Following completion of the three weeks of monitoring, RW-4 will be restarted, with RW-5A shutdown and continued operation of other recovering wells to allow assessment of the capture of the eastern portion of the CYOP with this well alone.

Evaluation of Results

Based on results of the test as well as an evaluation of historic data, GZA will evaluate the future use of RW-5A. Our conclusions and recommendations will be discussed with all concerned parties and forwarded to DEP for notice and review of system modifications. As stated above, based on results of this test, RW-5A will either be left in place with modifications to existing piping, or moved to a new location outside Building 11. The RW-5A casing will be cut to floor level, associated piping removed and the RW-5A well left in place. Recommendations will be in keeping with the requirements set forth in the September 20, 1987 remediat ion letter from DEP.

If oil recoveries and thicknesses diminish to negligible quantities during this test, it may indicate that RW-5A is not necessary over the long-term for oil recovery.

If results indicate that RW-5A can be moved to a new location (RW-5B), it will be installed either to the north or south of Building I1. The pumping and level control equipment in RW-5A will be relocated to RW-5B by GTI and the discharge piping trenched below ground to the groundwater treatment system located to the west of Building 11. The new location for a potential RW-5B would likely be on the southern side (upgradient) of building 11, east of monitoring well GD-2269A. It is anticipated that the upgradient side of Building I I will be more efficient in containing the plume and logistically completing the installation. However, if results of the test indicate that measured quantities of fuel oil are found in monitoring wells on the northern (downgradient) portion of the building, then RW-5B may be located north of the building. If this is the case, GZA will recommend limited hydraulic testing of existing monitoring wells. Because the former Bents Creek was filled in this area, the potential for high permeability fill in this area may make operating a recovery well impractical. Pumping from high permeability fill adjacent to a large water body (the Fore River) means high flow rates with very little drawdown and a very inefficient recovery well.

System Modifications

Regardless of the recommendation (i.e., repipe RW-5A or install RW-5B). system modifications would be made by Fluor Daniel GTI in conjunction with other planned maintenance/repair work at the CYOP. The attached Table provides an estimate for the cost to perform the proposed scope of work. For the purposes of this estimate, we have assumed that RW-5B will be installed. -s 0 0 ( I liii, 10k '\Th Kv+ ',s., April 28, 1998 - (C '-

Ms. Sharon A, Gobiel Massachusetts DEP Northeast Regional Office 10 Commerce Way Wobum, Massachusetts 0 180 1

Re: Waiver Submittal Scope of Work RW-5A Shutdown Test Quincy Shipyard Quincy, Massachusetts -1 Release Tracking No. 3-0536 and No. 10266 Dear Ms. Gobiel:

On behalf of General Dynamics Corporation (GD), GZA GeoEnvironnental, Inc. (GZA) is pleased to submit for your information the following Scope of Work to perform an evaluation of product recovery in the vicinity of the eastem portion of the Central Yard Oil Plume (CYOP) at the above- referenced site. This Scope of Work is part of our ongoing activities to improve the efficiency of product recovery at the CYOP.

The current owner of the Building 1I has indicated that, because of planned reconstruction and future use in the building, it will no longer be possible to maintain the existing well casings, associated product and groundwater discharge lines and electrical lines above floor level in Building 11. The RW-5A shutdown test will evaluate the need to either leave RW-5A in place and modify existing piping, or move RW-5A to a new location outside Building I 1.

We will provide you with the results of the shutdown test once they are available. Should you have any questions or comments, please do hesitate to contact the undersigned.

Very Truly Yours

. . 1 GZA GEOENV MENTAL, INC.

ibert J. Ricciardelli, LSP Lawrence Feldman, LSP t Principal Senior Principal AJR:rvh

Attachments: Scope of Work

cc: Waiver Unit, DEP G:\7400.ZGN\7400-17.DJA\CORRESP\Zgn 17106. doe

I . , 1 N S

PROPOSED PLAN FOR RW-5A SHUTDOWN TEST

BACKGROUND

Massachusetts Heavy Industries (MiHI). the current owner of the Building II area, has advised General Dynamics that due to safety issues associated with the roof of Building 1I, and planned reconstruction of the entire roof of Building II and renovation of the building interior for planned reuse, it will be necessary to make modifications to existing recovery and monitoring wells in Building 11. Existing monitoring wells include MW-I and MW-8. Existing recovery wells in Building I I include RW-2 which is currently inactive, and RW-5A which is currently active. Based cr1' on hydrogeologic testing in 1994, RW-2 was removed from active status (with DEP notification) since oil recovery from this well was minimal and it was no longer necessary to contain the plume. Results of pump tests in the CYOP performed by GZA in 1994 indicated that RW-5A was necessary to contain the eastern portion of the CYOP from migrating downgradient. Since that time, apparent oil thicknesses measured in wells in this area have continued to decrease.

Because of planned roof reconstruction and future use in Building 11, we understand that MHI has indicated that it will no longer be possible to maintain the existing well casings, associated product and groundwater discharge lines and electrical lines above floor level in Building I1. The planned modifications to Building II provides the opportunity to evaluate the current effectiveness of RW-5A in containing the eastern portion of the CYOP and the recovery of oil in this area. This evaluation can be undertaken by performing a limited shutdown test of RW-5A. Because RW-5A is currently an active part of the CYOP recovery system, the RW-5A shutdown test is proposed to evaluate the need to either leave RW-5A in place and modify existing piping, or move RW-5A to a new location outside Building 11, and cut RW-5A to floor level, remove associated piping and leave the recovery well in place.

PURPOSE

According to the remedial requirements of the September 20, 1987 letter from DEP (then DEQE), establishing the requirements for the CYOP, the CYOP cleanup is still in the active product recovery Phase of remediation (Phase I). DEP requirements provide that Phase I may transition to Phase II when it can be demonstrated that product recovery has become asymptotic for a period of six-months and that product thickness in all impacted wells is less than two-inches. Requirements for Phase II indicate that the groundwater portion of the recovery system must remain active for one hydrologic cycle (one-year) to assess the effects of seasonal fluctuations on product thickness. Although the product recovery pumps will not be active during this cycle, DEP mquirements provide that the full system needs to be operational should product reappear.

Monitoring of the eastern portion of the CYOP in the area of RW-5A indicates the product thicknesses in monitoring wells have been below 2-inches for more than 6 months. Product recovery from RW-5A has been asymptotic for at least six months and therefore General Dynamics has achieved the objectives of Phase I in the eastern portion of the CYOP. GZA proposes performing a shutdown test in the vicinity of RW-5A to assess whether substantial quantities of SPH would be released with the groundwater depression system at RW-5A shutdown for the eastern portion of the CYOP. If results of the shutdown test indicate that SPH does not accumulate in monitoring wells at greater than two inches in the eastern portion of the CYOP, it may be possible to meet the requirements of the DEP 1987 letter by terminating recovery of groundwater and product from RW- 5A and installing an alternate recovery well (RW-5B) either to the north or south of Building I I and piping and operating a groundwater depression pump in that well for at least one year. Alternatively, if the shutdown test indicates RW-5A is still necessary, it will be necessary to repipe the discharge lines from RW-5A to allow use of Building I by MHI.

The following Scope of Work provides a description of our proposed plan for assessing the future use of RW-5A. In summary the objectives of this scope of work are two-fold:

" Assess whether SPH becomes available under non-pumping conditions in the easlem portion of the CYOP.

" Assess the appropriate well configuration for capture of residual SPH in this portion of the 0lx CYOP. SCOPE OF WORK

Performance of Shutdown Test

Upon authorization to proceed with this scope of work, GZA will coordinate with Fluor Daniel GTI to gauge groundwater elevations and apparent fuel oil thickness measurements in all normally monitored wells. These measurements will serve as a pre-shutdown evaluation of groundwater flow and apparent oil thickness. It is anticipated that Fluor Daniel GTi will perform most groundwater elevation and fuel oil thickness measurements. GZA will perform limited measurements, but oversee and coordinate the shutdown test. Due to the safety issues concerned with working in Building 11, it is anticipated that Flour Daniel GTI will make arrangements with MHl to ensure that adequate protection of safety is provided. It is further anticipated that this shutdown test will not commence until GT1 agrees that an adequate level of safety is provided.

Subsequent to pre-shutdown measurements, GZA will coordinate with GTI to shut down RW-5A as well as RW-4 (also located in the eastern portion of the CYOP) and keep all other normally operating recovery wells active. It is anticipated that RW-4 and RW-5A will be shutdown for approximately three weeks depending on observed conditions. The following provides a schedule of periodic measurements.

For the first three days of shutdown, measurements of apparent fuel oil thickness and groundwater elevations will be made for monitoring and recovery wells in the RW-5A area (GZ-5A, MW- 1, MW- 5, MW-8, MW-14A, MW-15S, MW-16, GD-2269A, RW-4 and RW-5A). Measurable quantities of fuel oil will be removed from the well (i.e. via hand bailing), quantified and transported to the onsite oil storage tank.

On a weekly basis for three weeks, that is, three separate measurements after the pre-shutdown readings, measurements of apparent fuel oil thickness and groundwater elevations will be taken in the monitoring and recovery wells in the RW-5A area. At the two week time, measurements of groundwater elevation and apparent fuel oil thickness will be made for all normally monitored wells. Based on previous hydraulic testing at the Site, it is anticipated that this should be sufficient time to allow hydraulic equilibration in this area. Measurable quantities of oil will be removed from wells in the RW-5A area after the one week measurements. This will allow two weeks to ascertain if SPH will accumulate in the monitoring wells. It is possible that because RW-5A has been pumping for so long that an area of increased permeability in the highly heterogeneous subsurface (fill, construction debris, etc.) around the well will allow minor, intermittent residual oil in the area to settle around the recovery well upon shutdown. During this period, the monitoring wells and recovery wells located within Building II will be modified as requested by MHI to permit open use of the main floor level of the facility.

Evaluation of Results

Based oi results of the test as well as an evaluation of historic data, GZA will evaluate the future use of RW-5A. Our conclusions and recommendations will be discussed with all concerned parties and forwarded to DEP for notice and review of system modifications. As stated above, based on results of this test, RW-5A will either be left in place with modifications to existing piping, or moved to a new location outside Building 11. The RW-5A casing will be cut to floor level, associated piping removed and the RW-5A well left in place. Recommendations will be in keeping with the requirements set forth in the September 20, 1987 remediation letter from DEP.

If oil recoveries and thicknesses diminish to negligible quantities during this test, it may indicate that RW-5A is not necessary over the long-term for oil recovery.

If results indicate that RW-5A can be moved to a new location (RW-5B), it will be installed either to the north or south of Building 11. The pumping and level control equipment in RW-5A will be relocated to RW-5B by GTI and the discharge piping trenched below ground to the groundwater treatment system located to the west of Building 11. The new location for a potential RW-5B would likely be on the southern side (upgradient) of building i1, east of monitoring well GD-2269A. It is anticipated that the upgradient side of Building I 1 will be more efficient in containing the plume and logistically completing the installation. However, if results of the test indicate that measured quantities of fuel oil are found in monitoring wells on the northern (downgradient) portion of the building, then RW-5B may be located north of the building. If this is the case, GZA will recommend limited hydraulic testing of existing monitoring wells. Because the former Bents Creek was filled in this area, the potential for high permeability fill in this area may make operating a recovery well impractical. Pumping from high permeability fill adjacent to a large water body (the Fore River) means high flow rates with very little drawdown and a very inefficient recovery well.

System Modifications

Regardless of the recommendation (i.e., repipe RW-5A or install RW-5B), system modifications would be made by Fluor Daniel GTI in conjunction with other planned maintenance/repair work at the CYOP. The attached Table provides an estimate for the cost to perform the proposed scope of work. For the purposes of this estimate, we have assumed that RW-5B will be installed. 9 0

FOvernriwtnte, kj..- - State environmental agency says yard free of toxic waste By Eric Niler .Deer Island sewage treatment plai The Patriot Ledger Under an agreement with t he M ~ki state, General Dynamics assumi QUINCY - State environmental responsibility for cleaning up eLy officials say the Fore River shipyard sps found by 1987, when t has been scrubbed of potentially,, MWRA bought the property. TIhe; dangerous toxic materials and is WRA has been responsible f4 ready for use as an industrial site. spills discovered since then. Mass r- Massachusetts Heavy Industries, chusett Heavy Industries is respo n-; the yard's new owner, has removed aible for any new discoveries of tox ic j nearly all of the asbestos from the chemicals. dilapidated buildings and chemical ,h bgs environmental bai waste in the ground has either been at the yard has been asbestos, removed or does not pose a serious a fibrous insulating and fir -proofb risk to workers. material that was widely used in "There's nothing significant out there right now," said Sharon Go- caiprsiadilmnt a eto 1w biel, an environmental engineer for 3, and ilme ts oaersa the state Department of Environ- mental Protection, the agency over- Many of the former workers seeing the cleanup."The site is safe." ceived financial settlements fr Officials found contamination asbestos manufacturers. One of throughout much of the 180-acre site them. Robert Galotti of Quin ,y; when General Dynamics closed the received a $2.5 million jury award in shipyard in 1986. 1994. Two months later, he died fo rn The Massachusetts Water Re- mesothelioma, a lung cancer tied to sources Authority took over part of asbestos exposure, Mid his lawy er, 5, the yard to build a sludge-to-fertilizer James Ferraro of Miami* plant, and as a staging area for "He'd be excited that the yard is workers and construction equipment reopening'" Ferraro Mid. "But not if barges used in the construction of the ther was asbestos thret." * p

COMMONWEALTH OF MASSACHUSETTS EXECUTIVE OFFICE OF ENVIRONMENTAL AFFAIRS DEPARTMENT OF ENVIRONMENTAL PROTECTION ONE WINTER STREET, BOSTON MA 02108 (617)292-5500

ARGEO PAUL CELLUCCI TRUDY COXE Governor Secretary

DAVID B. STRUHS Conuissioner

December 5, 1997 BY HAND DELIVERY

Donald S. Berry McDermott, Will & Emery 75 State Street Boston, MA 02109-1807

Re: Cuincy Shipyard, Release Tracking Number 3-0536

Dear Don:

Attached please find two executed originals of the Special Covenant Not to Sue Agreement ("Covenant") with respect to Massachusetts Heavy Industry, Inc.'s ("MHII") purchase of a portion of the above referenced site ("Site") .

I appreciate your assistance in completing this project and look forward to the continued cleanup and redevelopment of the Quincy Shipyard Site. Please do not hesitate to contact me or Sarah Weinstein if you have any questions.

Sincerely,

Marga t R. Stolfa Ac:ing Deputy General Counsel

Attachments cc: Betsy Harper, Assistant Attorney General (with original) Leon Lataille, Environmental Manager, MWRA (with original) James Colman, Assistant Commissioner, DEP/WSC (with original) Laurel Mackay, Deputy Regional Director, DEP/NERO (with copy) COMMONWEALTH OF MASSACHUSETTS EXECUTIVE OFFICE OF ENVIRONMENTAL AFFAIRS DEPARTMENT OF ENVIRONMENTAL PROTECTION ONE WINTER STREET. BOSTON MA 02108 (617)292-5500

ARGEO PAUL CELLUCCI TRUDY COXE Governor Secreary

DAVID B. STRUHS Commissioner

COMMONWEALTH OF MASSACHUSETTS EXECUTIVE OFFICE OF ENVIRONMENTAL AFFAIRS DEPARTMENT OF ENVIRONMENTAL PROTECTION AND THE OFFICE OF THE ATTORNEY GENERAL

IN THE MATTER OF: SPECIAL COVENANT NOT TO SUE MASSACHUSETTS HEAVY AGREEMENT INDUSTRIES, INC.

I. Parties

This SPECIAL COVENANT NOT TO SUE AGREEMENT (the "Agreement"1 ) is entered into by and among the Commonwealth of Massachusetts (the "Commonwealth"), acting by and through THE DEPARTMENT OF ENVIRONMENTAL PROTECTION (the "Department"), with offices located at One Winter Street, Boston, Massachusetts 02108 and THE ATTORNEY GENERAL, with offices located at 200 Portland Street, Boston, Massachusetts; and MASSACHUSETTS HEAVY INDUSTRIES, INC ("MHI") with its principal place of business at 505 Paradise Road, Suite 123, Swampscott, Massachusetts 01907.

II. Authority

The Department, through its Bureau of Waste Site Cleanup (the "Bureau"), implements and enforces the Massachusetts Oil and Hazardous Material Release Prevention and Response Act, MGL, c. 21E ("Chapter 21E"), and regulations promulgated, inter alia, under that statute and codified at 310 CMR 40.0000, known as the Massachusetts Contingency Plan (the "MCP") . The Commonwealth, acting by and through the Department and the Attorney General, enters into this Agreement pursuant to its authority under Chapter 21E, § 3A(j) .

NOW, THEREFORE, in consideration of the mutual promises and agreements set forth in this Agreement, the Commonwealth, acting by and through the Department and the Attorney General, in reliance on MHI's representations described in this Agreement, and MHI agree as set forth below. Special Covenant Not To Sue Agreement December 1, 1997 Page 2

III. Definitions

A. "Agreement" shall mean this Special Covenant Not to Sue Agreement, and all attachments appended hereto.

B. "Acquisition Date" shall mean May 7, 1997, the date MHI acquired the Property.

C. "Attorney General" shall mean the Attorney General of the Commonwealth of Massachusetts.

D. "Chapter 21E" shall mean the Massachusetts Oil and Hazardous Materials Release Prevention and Response Act, M.G.L. c. 21E, as amended.

E. "Commonwealth" or "State" shall mean the Commonwealth of Massachusetts. The Massachusetts Water Resource Authority ("MWRA") shall not be included in this definition for the purposes of this Agreement.

F. "Department" or "DEP" shall mean the Massachusetts Department of Environmental Protection, and any successor departments or agencies of the Commonwealth of Massachusetts, its agents, servants, and employees.

G. "Existing Contamination" shall mean any oil or hazardous material present or existing on or under the Site, whether known or unknown, as of the Acquisition Date.

H. "MCP" or "Massachusetts Contingency Plan" shall mean the Massachusetts Contingency Plan promulgated pursuant to Chapter 21E, M.G.L. c.21A, M.G.L.c.21C and M.G.L. c. 111, and codified at 310 C.M.R. §40.0000, including, but not limited to, any amendments thereto.

I. "Oil or hazardous material" shall mean any oil or hazardous material as each of those terms is defined in Chapter 21E, §2.

J. "Property" shall mean the portion of the Site acquired by MHI from MWRA on the Acquisition Date identified as Lots 6 and 8 in the Subdivision and Easement Plans attached hereto and incorporated herein as Exhibit A and Parcels two through eleven as described in the Notice of Land Use Stipulation recorded in the Norfolk Registry of Deeds, instrument number 36965, and filed with the Norfolk County Land Court on May 17, 1995, instrument number 714486; expressly excluding Parcel 4 as described therein, a copy of which is attached hereto and incorporated herein as Exhibit B.

K, "Site" shall mean the former General Dynamics Quincy Shipbuilding Facility, DEP Release Tracking Number 3-0536, subject Special Covenant Not To Sue Agreement December 1, 1997 Page 3

to the "waiver of approvals" granted by the Department in March 1994 to General Dynamics and the Massachusetts Water Resources Authority.

All terms contained in this Agreement which are defined in Chapter 21E or the MCP, unless otherwise defined in this Agreement, shall have the meanings set forth therein.

IV. Parties Bound

A. The provisions of this Agreement and any attachments, amendments, modifications or additions shall be binding upon the Parties, their respective successors and assigns, officers, employees, agents and servants.

B. A breach of this Agreement by any persons acting for or on behalf of MHI shall be deemed a breach of this Agreement by MHI.

C. MHI, as further set forth herein, shall perform and shall cause their respective employees, agents and contractors to perform all terms and conditions of this Agreement in compliance with all federal, State and local statutes, regulations, ordinances and other applicable laws. Nothing in this Agreement shall relieve MHI of its obligations to comply with other statutes, regulations, ordinances, and other applicable laws.

V. Scope of Agreement

This Agreement represents the entire understanding and agreement among the Parties with respect to the performance of response actions at the property pursuant to Chapter 21E and the MCP.

VI. Statement of Facts and Law Solely for the purpose of this Agreement, the Parties stipulate to the statement of facts and law set forth below. A. Summary of Law. This Agreement is entered into pursuant to and is governed by the "Massachusetts Oil and Hazardous Material Release Prevention and Response Act, " M.G.L. c. 21E and the regulations promulgated thereunder as the Massachusetts Contingency Plan (the "MCP") at 310 C.M.R. 40.0000 et. seg. B. Summary of Facts.

1. The Site was listed as a confirmed disposal site pursuant to M.G.L. c. 21E on or about January 15, 1987.

2. On March 2, 1994 a waiver of approvals ("waiver") was granted to MWRA and General Dynamics pursuant to 310 CMR 40.000. Special Covenant Not To Sue Agreement December 1, 1997 Page 4

3. MWRA is the current owner and operator of the Site, excluding the portion of the Site identified herein as the Property, and General Dynamics is the former owner and operator. 4. As of the Acquisition Date, MHI is the current owner of the portion of the Site identified herein as the Property.

5. MWRA and General Dynamics are implementing response actions at the Site pursuant to the waiver.

6. Prior to the Acquisition Date, MHI has had no ownership of or control over, and has not conducted any operations at, the Site. VII. Response Action

A. Description of the Resronse Action. Pursuant to the waiver issued under the 1988 Massachusetts Contingency Plan ("1988 MCP") , other parties are performing response actions at the Quincy Shipyard to comply with the requirements of MGL c. 21E and the 1988 MCP. Massachusetts Heavy Industries (MHI) will conduct certain response actions as specified in this Agreement on the Property. All construction activities shall comply with the requirements as applicable of the Notice of Land Use Stipulation recorded in the Norfolk Registry of Deeds a copy of which is attached hereto and incorporated herein as Exhibit B. The additional response actions to be performed by MHI comprise:

1. Release Abatement Measure in coniunction with construction of an addition to Building 3/12 (and former transformer cage). In conducting excavation of contaminated soils or dewatering of contaminated groundwater at the Property, MHI shall comply with the provisions of 310 CMR 40.0440 through 40.0447, regarding performance of a Release Abatement Measure ("RAM") . Prior to completing the RAM Plan required by 310 CMR 40.0444, MHI shall review and evaluate all relevant and reasonably available data compiled for the Property and shall conduct additional soil and groundwater sampling and analysis needed to ensure proper management of contaminated materials that are excavated. The RAM Plan shall provide for the reuse of excavated soil on site, to the extent allowed by 310 CMR 40.0442 (2) (b) , and by redevelopment plans for the Property. The RAM Plan shall also include a plan for stockpiling, testing, and arranging for off-site disposal of soils which cannot be reused on site. MHI shall complete the work as set forth in the RAM Plan. In conducting excavation of contaminated soils or dewatering of contaminated groundwater at the Property, MHI shall Special Covenant Not To Sue Agreement December 1, 1997 Page 5

submit RAM Status Report (s) in compliance with 310 CMR 40.0445, and a RAM Completion Report pursuant to 310 CMR 40.0446.

Subsequent to filing a RAM Completion Report for any excavation or dewatering subject to the requirements set forth above, MHI shall submit a Class A Response Action Outcome Statement for the areas where the aforementioned excavation or dewatering has been conducted, unless such Response Action Outcome Statement cannot be achieved based upon the work required pursuant to the RAM Plan, in which case MHI shall submit an LSP Opinion addressing whether further response actions are needed in the areas where the aforementioned excavation or dewatering has been conducted.

B. The Commonwealth agrees that the Department will promptly issue to the Applicant the Certificate (s) of Completion ("Certificate") attached hereto as Exhibit C and made a part hereof upon:

1. receipt of a Class A Response Action Outcome Statement (s) pursuant to Section VII (A) of this Agreement at the Property prepared in accordance with MGL c. 21E; 310 CMR 40.0000; MGL c. 21A, 9§19-19J; and 309 CMR 1.00-8.00; or

2. an LSP Opinion addressing whether further response actions are needed in the areas where excavation of contaminated soils or dewatering of contaminated groundwater has been conducted by MHI, prepared in accordance with MGL c. 21E; 310 CMR 40.0000; MGL c. 21A, §§19-19J; and 309 CMR 1.00-8.00.

VIII. Property Access

A. From the Acquisition Date forward, MHI shall provide to the Department and/or to its employees, agents, consultants, contractors and authorized representatives, an irrevocable right of access at all reasonable times to the Property, for all purposes authorized by Chapter 21E and the MCP. MHI shall permit such persons to record all field activities on its Property by means of photographic or other recording equipment as the Department deems appropriate. Notwithstanding any provision of this Agreement, the Department retains all of its authority and rights, including enforcement authority related thereto, under Chapter 21E and the MCP.

B. Within 30 days after the effective date of this Agreement, MHI shall record a certified copy of this Agreement with the Norfolk County Registry of Deeds. MHI shall provide to the Department a copy of the recorded Agreement, evidencing recording data, once it is available. After this Agreement has been recorded, each deed, title, or other instrument conveying an interest in the Property shall contain a notice stating that the Special Covenant Not To Sue Agreement December 1, 1997 Page 6

interest is conveyed subject to this Agreement. Any party conveying such an interest shall provide a copy of each such instrument to the Department.

IX. Commonwealth's Covenant Not to Sue

A. Effective Date of Commonwealth's Covenant Not to Sue

1 . The Commonwealth's covenant not to sue, set forth below, shall be effective only upon the signature of the Agreement by the Commonwealth.

B. Commonwealth's Covenant Not to Sue 1. Pursuant to the terms and conditions of this Agreement and Chapter 21E, §3A(j), the Commonwealth,acting by and through the Department and the Attorney General, except as specifically provided in Section XIII (Commonwealth's and Department's Reservation of Rights) and otherwise subject to the limitations set forth in this Agreement;

a. covenants not to sue, or to take any other civil or administrative action against MHI for claims pursuant to Chapter 21E and the MCP for the reimbursement of response action costs and injury or damage to property owned by the Commonwealth or to natural resources arising out of Existing Contamination.

2. Except as expressly set forth in this Agreement to the contrary, these covenants shall also extend to employees, officers, and directors. Except as expressly set forth herein, the Commonwealth also covenants with MHI not to sue MHI's heirs to, successors to or assignees of MHI's ownership interest in the Property, or any lessee, licensee or tenant of MHI of all or any part of the Property.

3. These covenants shall not apply to response action costs arising from any of the following: a. releases or threats of release of oil or hazardous material at the Property occurring after the Acquisition Date, exclusive of passive leaching from Existing Contamination;

b. any release or threat of release of oil or hazardous material which MHI, their employees, officers, directors, or tenants at the Property, or any other person to whom the benefits of this covenant inure, causes or contributes to or causes to become worse than it otherwise would have been. The covenant shall be void only against those persons who cause or contribute to a release or threat of release or cause such to become worse than it otherwise would have been; or Special Covenant Not To Sue Agreement December 1, 1997 Page 7

c. any release or threat of release of oil or hazardous material not expressly covered by paragraph B. 1, preceding. 4. Notwithstanding the foregoing, these covenants:

a. shall be void as to MHI if MHI fails to perform, or fund and cause to be performed, in accordance with applicable requirements, any obligation of MHI contained in this Agreement with respect to the Property; b. shall be void as to any of the persons identified in paragraphs B. 1. and B. 2. of this section, or any other person to whose benefit these covenants inure, if such person:

i. fails to comply with the release and threat of release notification requirements of Chapter 21E and the MCP with respect to the Property; or ii. unreasonably denies DEP, its agents, contractors or authorized representatives, access to the Property to investigate, sample and inspect any records conditions, equipment, practice or equipment to ensure compliance with and fulfillment of the terms of the Agreement, Chapter 21E and the MCP or for purposes of conducting necessary response actions at the Property; provided however, that the covenant shall be void only against those persons who unreasonably deny such access, and against any other person to whose benefit this covenant inures subsequent to such denial.

S. The issuance of these covenants shall not operate to bar the Commonwealth or the Department from auditing any person, site, or response action (as defined in Chapter 21E and the MCP), or from requesting any person to provide information to the Department, or to relieve any person of the obligation to comply with any such request.

6. MHI shall ensure that a copy of this Agreement is provided to any current lessee or sublessee on the Property at the effective date of this Agreement and shall ensure that any subsequent leases, subleases, assignments or transfers of the Property are consistent with this Agreement.

X. Commonwealth's and Department's Reservation of Rights A. The Commonwealth and the Department reserve all claims other than those released pursuant to the above covenants, including but not limited to claims based on the following: Special Covenant Not To Sue Agreement December 1, 1997 Page 8

1. failure by MHI to meet a requirement of this Agreement; 2. conditions previously unknown or undetected by the Department or the Commonwealth, that are discovered at the Site, or information previously unknown to the Department or the Commonwealth that is received by the Department or the Commonwealth if the Department or the Commonwealth determines, based upon such previously unknown conditions or new information, together with any other relevant information, that the implementation of the requirements of this Agreement is no longer protective of the public health, safety, welfare or the environment; 3. liability for future disposal of oil or hazardous material at the Site;

4. violation of Chapter 21E or any applicable law or regulation which occurs during or after implementation of the response action; and 5. criminal liability.

B. Nothing in this Agreement shall preclude the Department or Commonwealth from enforcing the provisions of this Agreement in any administrative or judicial process. C. If MHI fails to satisfactorily perform or fund and cause to be performed any response action that it is obligated to perform under this Agreement, the Department reserves its right pursuant to Chapter 21E and the MCP, in addition to any other remedies which are available, to undertake such response actions as it reasonably deems necessary at the Property, in its sole and reasonable discretion. In such event, the Commonwealth and the Department expressly reserve all legal and equitable rights to take any action to recover from MHI all response action costs incurred by the Department against MHI, interest thereon, and all other costs associated with the recovery of such costs, including, without limitation, all reasonable attorneys' fees.

XI. Covenant by MHI to the Commonwealth

MHI hereby covenants not to sue or assert any claims or causes of action against the Commonwealth or the Department, including their respective officers, trustees, employees and agents, with respect to Existing Contamination at the Property, provided however, that (i) MHI reserves all rights and remedies which it may have with respect to any release or threat of release of oil or hazardous material which the Commonwealth, the Department or any of the aforementioned persons causes or contributes to, causes to become worse that it otherwise would have been, or is otherwise legally responsible for. Special Covenant Not To Bue Agreement December 1, 1997 Page 9

XII. Contribution Protection

MHI, and the other persons identified in paragraph IX.B.2, shall be entitled, as of the effective date of this Agreement, to contribution protection pursuant to Chapter 21E, Section 3A(j) (2) for any claim arising out of or related to Existing Contamination except that such contribution protection shall not apply to any such claim by the MWRA. XIII. Modification of Agreement

This Agreement may only be modified upon the written agreement of both the Department and the Attorney General, by signature of their authorized representatives, and by MHI by signature of their authorized representatives. XIV. Separate Documents This Agreement may be executed in two or more counterparts, each of which shall be deemed an original, but all of which together shall constitute one and the same instrument.

Xv. Severability

If any term or provision of this Agreement or its application to any person or circumstance is unenforceable, the remainder of this Agreement or its application, will not be affected, and each remaining term and provision shall be valid and enforceable to the full extent permitted by law.

IT IS SO AGREED:

MASSACHUSETTS HEAVY INDUSTRIES, IN

By Date: QctuferL, (?47 AAgent

MASSACHUSETTS DEPARTMENT OF ENVIRONMENTAL PROTECTION By. L /d 6Lki y '4)6t*W)C (dY6%Ctz Date: ~4-Y f James C. Colman Assistant Commissioner special Covenant Not To Sue Agreement December 1, 1997 Page 10

COMMONWEALTH OF MASSACHUSETTS Scott Harshbarger, Attorney General

By: E Date: / 1 3 7~f Nancy E. Harper, Es . Assistan Attorney General

COMMONWEALTH OF MASSACHUSETTS

Then personally appeared the above-named Nancy E. Harper, Esq. and acknowledged the foregoing to be her free act and deed before me, /

Notay Public eI -

My commission expires;:9-1O- 0 It 0 (jJO Lxi IJ 0 P - It

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to NOTICE OF LAND USE STIPULATION

NOTICE is hereby given as of the 1oh. day ofmay , 1995, by Massachusetts Water Resources Authority, a public body corporate and politic, with an office at 100 First Avenue, Charlestown Navy Yard, Boston, Massachusetts ("Grantor") that:

1. Grantor is the owner in fee simple of the land located in Quincy and Braintree, Norfolk County, Massachusetts, with the buildings and improvements thereon more particularly described on Exhibit A attached hereto and made a part hereof (the "Property").

2. The Property is a disposal site as the result of a release of oil and/or hazardous material.

3. The response actions for the Property have been approved by the Massachusetts Department of Environmental Protection ("DEP") based upon the Grantor's assertion that use of the Property would be limited to:

(a) activities in connection with the use of the Property for industrial and business office purposes; and

(b) such other activities which, in the opinion of (i) the "Consultant of Record" under the terms of the 'Waiver of Approvals" dated March 2, 1994 and granted to Grantor; or (ii) a person licensed by the Board of Registration of Waste Cleanup Professionals or any successor agency (a holder of such license hereinafter referred to as an "LSP"), present no greater risk of harm to health, safety, public welfare or the environment than the use of the Property for industrial or business office purposes. Such opinions shall be set forth in writing, signed and sealed by the Consultant of Record or the LSP, as applicable, and recorded and/or registered with the appropriate Registry of Deeds and/or Land Registration Office. A certified Registry copy of the same shall be filed with DEP within 30 days of recording and/or registration.

4. Any proposed change in activities and uses at the Property which may result in higher levels of exposure to oil and/or hazardous material than the exposures which would occur as a result of the use of the Property for the purposes set forth in Section 3 above shall be evaluated (i) by the Consultant of Record, during the term of the Waiver of Approvals, who shall make a determination (hereinafter the "Consultant's Determination") or (ii) by an LSP who shall render an LSP Opinion, in accordance with the DEP Waiver of Approvals and the Massachusetts Contingency Plan , as applicable, as to whether the proposed changes will present a significant risk of harm to health, safety, public welfare or the environment. Any and all requirements set forth in the Consultant's Determination or LSP Opinion to ensure a condition of No Significant Risk in the implementation of the proposed activity or use shall be satisfied before any such activity or use is commenced. Such Determination or Opinion shall be set forth in writing, signed by the Consultant of Record or the certifying LSP, as applicable, and recorded and/or registered with the appropriate Registry of Deeds and/or Land Registration Office. A certified copy of same shall be filed with DEP within 30 days of recording and/or registration. Upon the recording of either the Consultant's Determination or the LSP Opinion, the Property shajl be conclusively presumed to be available for use for the purposes set forth in such Determination or Opinion as well as for the purposes set forth in Section 3 above.

5. Construction activities which may involve the disturbance of contamination soil and/or groundwater shall include preparation and implementation of a hazardous materials management plan ("HMMP") to minimize migration of and exposure to hazardous materials. The HMMP shall be prepared in accordance with the requirements of the "Waiver of Approval" and the Massachusetts Contingency Plan, as applicable.

WITNESS the execution hereof under seal this 10th day of May 1995.

MASSACHUSETTS WATER RESOURCES AUTHO TY

By: __

COMMONWEALTH OF MASSACHUSETTS

uffolk ss. M n 1995

Then personally appeared the above-namedDouglas B. MacDonals Jijarj of MwRA and acknowledged the foregoing instrument to be the free act and deed of MWRA before me.

Notary Public

My Commission expires: io/r// '/6

-2- I 9

EXHIBIT A

Legal Description

The real property in Quincy and Braintree, Norfolk County, Massachusetts conveyed to Massachusetts Water Resources Authority by General Dynamics Corporation by deed dated November 16, 1987 and filed with the Norfolk County Registry District of the Land Court as Document No. 535415 shown as Transfer Certificate of Title No. 127626, filed in Registration Book 639, Page 26, and recorded with the Norfolk County Registry of Deeds in Book 7803, Page 211; said real property being more particularly described as Parcels 1 through 15, inclusive, in Exhibit A to said Deed, a copy of the land description in such Deed is attached hereto as Exhibit A-1; but expressly excluding Parcel 4 as described in such Exhibit A to said Deed and in Exhibit A-1 hereto, and in Exhibit B hereto. Said parcels are shown on a plan of land entitled "General Dynamics Quincy, MA. and Braintree, MA." (consisting of a Plan Index an d fourteen drawings numbered 150.011 M to 150.151M, inclusive, but excluding 150.081M) dated October 15, 1986 and November 4, 1986, as revised, by New England Survey service, recorded November 16, 1987 in Plan Book 361 as Plan #1372 of 1987, Sheets 1-15. EXHIBIT A-I

All those fifteen (15) certain parcels of land in Quincy and Braintree, Norfolk County, Massachusetts, bounded and described as follows:

PARCEL 1:

A CERTAIN PARCEL OF LAND IN THE COMMONWEALTH OF MASSACHUSETTS, COUNTY OF NORFOLK, CITY OF QUINCY AND TOWN OF BRAINTREE, SITUATED ON EAST HOWARD STREET, SOUTH STREET, NASH AVENUE, WASHINGTON STREET, HILL AVENUE, AND QUINCY AVENUE AS SHOWN ON SAID PLAN, DATED OCTOBER 15, 1986, DRAWING 150.011M, DRAWING 150.021M, DRAWING 150.031M, DRAWING 150.041M, AND DRAWING 150.051M.

CONTAINING 647,688 SQUARE METERS, MORE OR LESS, OR 6,971,625 SQUARE FEET, MORE OR LESS, OR 160.046 ACRES, MORE OR LESS.

EXCLUDING FOUR PARCELS OF LAND NOW OR FORMERLY OF FORE RIVER RAILROAD CORPORATION DESCRIBED AS FOLLOWS:

(1) LAND DESCRIBED AS TRACT NO. 1 IN THE INDENTURE BETWEEN FORE RIVER SHIPBUIDING CORPORATION, AND FORE RIVER RAILROAD CORPORATION DATED APRIL 30, 1919, RECORDED AT BOOK 1421, PAGE 264, EXCEPT THAT PORTION THEREOF CONVEYED BY FORE RIVER RAILROAD CORPORATION TO BETHLEHEM STEEL COMPANY BY DEED, DATED MARCH 13, 1962, RECORDED AT BOOK 3975, PAGE 742;

(2) LAND DESCRIBED AS PARCEL 2 IN THE DEED FROM THE COMMONWEALTH OF MASSACHUSETTS TO FORE RIVER RAILROAD CORPORATION, DATED AUGUST 6, 1920, RECORDED AT BOOK 1466, PAGE 81;

(3) LAND DESCRIBED AS LOT E ON LAND COURT PLAN 531E, A COPY OF A PORTION OF WHICH IS FILED WITH CERTIFICATE NO. 4770, REGISTRATION BOOK 24, AND MORE PARTICULARLY DESCRIBED IN CERTIFICATE NO. 4871; AND

(4) LAND DESCRIBED AS LOT 4 ON LAND COURT PLAN 18298C, A COPY OF A PORTION OF WHICH IS FILED WITH CERTIFICATE NO. 70284, REGISTRATION BOOK 352, AND MORE PARTICULARLY DESCRIBED IN CERTIFICATE NO. 74481.

INCLUDED AS PART OF THE ABOVE-DESCRIBED PARCEL 1 ARE THE FOLLOWING LOTS OF REGISTERED LAND:

LOT 5 ON LAND COURT PLAN 18298D WHICH PLAN IS DATED JULY 17, 1987, AND WAS PREPARED BY NEW ENGLAND SURVEY SERVICE AND IS FILED WITH CERTIFICATE OF TITLE NO. 74465.

LOTS D, F AND G ON LAND COURT PLAN 531H.

FOR TITLE REFERENCE, SEE CERTIFICATE OF TITLE NO. 74465, FILED IN REGISTRATION BOOK 373, PAGE 65; CERTIFICATE OF TITLE NO. 88974, FILED IN REGISTRATION BOOK 445, PAGE 174; DEED FROM BETHLEHEM STEEL COMPANY DATED DECEMBER 31, 1963, RECORDED AT BOOK 4132, PAGE 459; AND DEED FROM THE UNITED STATES OF AMERICA, ACTING BY AND THROUGH THE ADMINISTRATOR OF GENERAL SERVICES, DATED APRIL 30, 1970, RECORDED AT BOOK 4660, PAGE 495.

PARCEL 2:

A CERTAIN PARCEL OF LAND IN THE COMMONWEALTH OF MASSACHU- SETTS, COUNTY OF NORFOLK, TOWN OF BRAINTREE, SITUATED ON HILL AVENUE, LANCASTER ROAD, CLIFF STREET, AND COLUMBIA TERRACE AND IS SHOWN ON SAID PLAN, DATED NOVEMBER 4, 1986, DRAWING 150.061M.

CONTAINING 9,066 SQUARE METERS, MORE OR LESS, OR 97,584 SQUARE FEET, MORE OR LESS, OR 2.240 ACRES, MORE OR LESS.- --

INCLUDED AS PART OF THE ABOVE-DESCRIBED PARCEL 2 IS A PARCEL OF REGISTERED LAND BEING SHOWN ON LAND COURT PLAN 23255A.

FOR TITLE REFERENCE, SEE CERTIFICATE OF TITLE NO. 82202, FILED IN REGISTRATION BOOK 412, PAGE 2; DEED FROM BETHLEHEM STEEL COMPANY DATED DECEMBER 31, 1963, RECORDED AT BOOK 4132, PAGE 459; DEED FROM WILLIAM N. MCQUARRIE, JR. AND JOAN MCQUARRIE DATED JUNE 1, 1967, RECORDED AT BOOK 4431, PAGE 170; DEED FROM FRANCES RIVELLI, ADMINISTRATOR OF THE ESTATE OF NUNZIATO LUISI, DATED JUNE 15, 1967, RECORDED AT BOOK 4447, PAGE 557; DEED FROM ARTHUR V. OLSEN AND GLADYS M. OLSEN DATED JANUARY 16, 1968, RECORDED AT BOOK 4488, PAGE 42; DEED FROM RAYMOND F. BARRETT, ADMINISTRATOR OF THE ESTATE OF ANNIE DRUMMOND, DATED JANUARY 31, 1968, RECORDED AT BOOK 4491, PAGE 277; AND DEED FROM JOHN J. SULLIVAN AND ANNE SULLIVAN DATED JUNE 14, 1968, RECORDED AT BOOK 4519, PAGE 541.

PARCEL 3:

A CERTAIN PARCEL OF LAND IN THE COMMONWEALTH OF MASSACHUSETTS, COUNTY OF NORFOLK, TOWN OF BRAINTREE, SITUATED ON COLUMBIA TERRACE AND CLIFF STREET AND IS SHOWN ON SAID PLAN, DATED NOVEMBER 4, 1986, DRAWING 150.061M.

CONTAINING 1,778 SQUARE METERS, MORE OR LESS, OR 19,138 SQUARE FEET, MORE OR LESS.

FOR TITLE REFERENCE, SEE DEED FROM JAMES E. DHOOGE DATED MAY 2, 1967, RECORDED AT BOOK 4425, PAGE 517; DEED FROM GERALD D. DHOOGE, ALSO KNOWN AS GERALD D. DEWEY, AND MABEL DHOOGE, ALSO KNOWN AS MABEL DEWEY, DATED APRIL 10, 1967, RECORDED AT BOOK 4431, PAGE 604; DEED FROM THERESA LUISI DATED JUNE 15, 1967, RECORDED AT BOOK 4447, PAGE 555; AND TWO DEEDS FROM THE TOWN OF BRAINTREE DATED DECEMBER 11, 1967, RECORDED AT BOOK 4483, PAGES 447 AND 450.

PARCEL 4:

A CERTAIN PARCEL OF LAND IN THE COMMONWEALTH OF MASSACHUSETTS, COUNTY OF NORFOLK, TOWN OF BRAINTREE, SITUATED ON

- 2 - 0 S

LANCASTER ROAD, AND IS SHOWN ON SAID PLAN, DATED NOVEMBER 4, 1986, DRAWING 150.061M.

CONTAINING 1,301 SQUARE METERS, MORE OR LESS, OR 14,000 SQUARE FEET, MORE OR LESS.

FOR TITLE REFERENCE, SEE DEED FROM BETTY A. DIBONA DATED JUNE 1, 1970, RECORDED AT BOOK 4666, PAGE 467.

PARCEL 5:

A CERTAIN PARCEL OF LAND IN THE COMMONWEALTH OF MASSACHUSETTS, COUNTY OF NORFOLK, TOWN OF BRAINTREE, SITUATED ON HILL AVENUE AND LANCASTER ROAD AND IS SHOWN ON SAID PLAN, DATED NOVEMBER 4, 1986, DRAWING 150.061M.

CONTAINING 6,551 SQUARE METERS, MORE OR LESS, OR 70,509 SQUARE FEET, MORE OR LESS, OR 1.619 ACRES, MORE OR LESS.

FOR TITLE REFERENCE, SEE DEED FROM BETHLEHEM STEEL COMPANY DATED DECEMBER 31, 1963, RECORDED AT BOOK 4132, PAGE 459; DEED FROM JAMES J. FLAVIN DATED JANUARY 7, 1967, RECORDED AT BOOK 4404, PAGE 639; DEED FROM JOHN F. JOHNSON AND JESSIE M. JOHNSON DATED MARCH 3, 1967, RECORDED AT BOOK 4414, PAGE 552; DEED FROM CATHERINE MCQUARRIE DATED OCTOBER 5, 1967, RECORDED AT BOOK 4465, PAGE 73; AND DEED FROM WILLIAM N. MCQUARRIE AND CATHERINE MCQUARRIE DATED OCTOBER 5, 1967, RECORDED AT BOOK 4465, PAGE 74.

PARCEL 6:

A CERTAIN PARCEL OF LAN IN THE COMMONWEALTH OF MASSACHUSETTS, COUNTY OF NORFOLK, TOWN OF BRAINTREE, SITUATED ON LANCASTER ROAD AND IS SHOWN ON SAID PLAN, DATED NOVEMBER 4, 1986, DRAWING 150.061M.

CONTAINING 643 SQUARE METERS, MORE OR LESS, OR 6,916 SQUARE FEET, MORE OR LESS.

FOR TITLE REFERENCE, SEE DEED FROM BETHLEHEM STEEL COMPANY DATED DECEMBER 31, 1963, RECORDED AT BOOK 4132, PAGE 459.

PARCEL 7:

A CERTAIN PARCEL OF LAND IN THE COMMONWEALTH OF MASSACHUSETTS, COUNTY OF NORFOLK, TOWN OF BRAINTREE, SITUATED ON LANCASTER ROAD AND COLUMBIA TERRACE AND IS SHOWN ON SAID PLAN, DATED NOVEMBER 4, 1986, DRAWING 150.061M.

CONTAINING 660 SQUARE METERS, MORE OR LESS, OR 7,108 SQUARE FEET, MORE OR LESS.

FOR TITLE REFERENCE, SEE TWO DEEDS FROM THE TOWN OF BRAINTREE DATED DECEMBER 11, 1967, RECORDED AT BOOK 4483, PAGES 446 and 449.

- 3 PARCEL 8:

A CERTAIN PARCEL OF LAND IN THE COMMONWEALTH OF MASSACHUSETTS, COUNTY OF NORFOLK, TOWN OF BRAINTREE, SITUATED ON COLUMBIA TERRACE, AND IS SHOWN ON SAID PLAN, DATED NOVEMBER 4, 1986, DRAWING 150.061M.

CONTAINING 391 SQUARE METERS, MORE OR LESS, OR 4,212 SQUARE FEET, MORE OR LESS.

FOR TITLE REFERENCE, SEE DEED FROM THE TOWN OF BRAINTREE DATED DECEMBER 11, 1967, RECORDED AT BOOK 4483, PAGE 448.

PARCEL 9:

A CERTAIN PARCEL OF LAND IN THE COMMONWEALTH OF MASSACHUSETTS, COUNTY OF NORFOLK, TOWN OF BRAINTREE, SITUATED ON HILL AVENUE, PATTEN AVENUE, AND QUINCY AVENUE AND IS SHOWN ON SAID PLAN, DATED NOVEMBER 4, 1986, DRAWING 150.071M.

CONTAINING 15,390 SQUARE METERS, MORE OR LESS, OR 165,659 SQUARE FEET, MORE OR LESS, OR 3.803 ACRES, MORE OR LESS.

FOR TITLE REFERENCE, SEE DEED FROM CHARLES A. SMITH DATED MARCH 17, 1967, RECORDED AT BOOK 4416, PAGE 50; DEED FROM SIGNE E. WHITEHOUSE DATED MAY 1, 1967, RECORDED AT BOOK 4424, PAGE 327; DEED FROM GEORGE W. NOYES, JR. AND JOYCE E. NOYES DATED MAY 29, 1967, RECORDED AT BOOK 4430, PAGE 659; DEED FROM RAYMOND E. ELLIS DATED JUNE 13, 1967, RECORDED AT BOOK 4434, PAGE 110; DEED FROM RENE BIGANZOLI AND MARY BIGANZOLI DATED JUNE 16, 1967, RECORDED AT BOOK 4435, PAGE 531; DEED FROM HENRY SEPPALA AND VIOLET SEPPALA DATED JUNE 15, 1967, RECORDED AT BOOK 4435, PAGE 533; DEED FROM WILLIAM PERRY AND JOHN S. PERRY DATED JUNE 27, 1967, RECORDED AT BOOK 4438, PAGE 395; DEED FROM RAYMOND F. BARRETT, ADMINISTRATOR OF THE ESTATE OF ANNIE DRUMMOND, DATED JANUARY 31, 1968, RECORDED AT BOOK 4491, PAGE 277; AND DEED FROM AGNES DRISCOLL DATED JANUARY 4, 1969, RECORDED AT BOOK 4568, PAGE 707.

PARCEL 10:

A CERTAIN PARCEL OF LAND IN THE COMMONWEALTH OF MASSACHUSETTS, COUNTY OF NORFOLK, TOWN OF BRAINTREE, SITUATED ON COLUMBIA TERRACE AND PATTEN AVENUE AND IS SHOWN ON SAID PLAN, DATED NOVEMBER 4, 1986, DRAWING 150.071M.

CONTAINING 2,796 SQUARE METERS, MORE OR LESS, OR 30,095 SQUARE FEET, MORE OR LESS.

FOR TITLE REFERENCE, SEE DEED FROM WALTER J. LATHAM AND DORIS M. LATHAM DATED MAY 4, 1967, RECORDED AT BOOK 4425, PAGE 516; DEED FROM THERESA LUISI DATED JUNE 15, 1967, RECORDED AT BOOK 4447, PAGE 555; AND DEED FROM SARAH R. FERGUSON DATED JULY 12, 1967, RECORDED AT BOOK 4443, PAGE 483.

- 4 - 0 S PARCEL 11:

A CERTAIN PARCEL OF LAND IN THE COMMONWEALTH OF MASSACHUSETTS, COUNTY OF NORFOLK, CITY OF QUINCY, SITUATED ON EAST HOWARD STREET, CHUBBUCK STREET, DES MOINES ROAD, AND SOUTH STREET AND IS SHOWN ON SAID PLAN, DATED OCTOBER 15, 1986, DRAWING 150.091M.

BEING SHOWN AS LOT 2 ON A PLAN DRAWN BY ERNEST W. BRANCH, INC., CIVIL ENGINEERS, DATED DECEMBER 16, 1958, AND NUMBERED 18298-B, SHEETS 1 THROUGH 6 INCLUSIVE, ALL AS MODIFIED AND APPROVED BY THE COURT, A COPY OF A PORTION OF WHICH IS FILED IN NORFOLK REGISTRY DISTRICT WITH CERTIFICATE NO. 69622, BOOK 349.

FOR TITLE REFERENCE, SEE CERTIFICATE OF TITLE NO. 74465, FILED IN REGISTRATION BOOK 373, PAGE 65.

PARCEL 12:

A CERTAIN PARCEL OF LAND IN THE COMMONWEALTH OF MASSACHUSETTS, COUNTY OF NORFOLK, CITY OF QUINCY, SITUATED ON LAWRENCE STREET, CHASE STREET, CHECKER STREET, AND CLEVERLY COURT AND IS SHOWN ON SAID PLAN, DATED OCTOBER 15, 1986, DRAWING 150.101M.

CONTAINING 7,381 SQUARE METERS, MORE OR LESS, OR 79,448 SQUARE FEET, MORE OR LESS, OR 1.824 ACRES, MORE OR LESS.

FOR TITLE REFERENCE, SEE DEED FROM BETHLEHEM STEEL COMPANY DATED DECEMBER 31, 1963, RECORDED AT BOOK 4132, PAGE 459.

PARCEL 13:

A CERTAIN PARCEL OF LAND IN THE COMMONWEALTH OF MASSACHUSETTS, COUNTY OF NORFOLK, CITY OF QUINCY, SITUATED ON SOUTH STREET AND CLEVERLY COURT AND IS SHOWN ON SAID PLAN, DATED OCTOBER 15, 1986, DRAWING 150.101M.

CONTAINING 11,485 SQUARE METERS, MORE OR LESS, OR 123,625 SQUARE FEET, MORE OR LESS, OR 2.838 ACRES, MORE OR LESS.

FOR TITLE REFERENCE, SEE DEED FROM BETHLEHEM STEEL COMPANY DATED DECEMBER 31, 1963, RECORDED AT BOOK 4132, PAGE 459.

PARCEL 14:

A CERTAIN PARCEL OF LAND IN THE COMMONWEALTH OF MASSACHUSETTS, COUNTY OF NORFOLK, CITY OF QUINCY, SITUATED ON WASHINGTON STREET AND READ AVENUE AS SHOWN ON SAID PLAN, DATED OCTOBER 15, 1986, DRAWING 150.111M.

CONTAINING 4,865 SQUARE METERS, MORE OR LESS, OR 52,367 SQUARE FEET, MORE OR LESS, OR 1.202 ACRES, MORE OR LESS.

- 5 - FOR TITLE REFERENCE, SEE DEED FROM THOMAS F. DRAPER DATED NOVEMBER 29, 1968, RECORDED AT BOOK 4560, PAGE 223; DEED FROM HECTOR A. FRAZIER DATED MARCH 4, 1969, RECORDED AT BOOK 4579, PAGE 87; AND DEED FROM MADELINE FRAZIER DATED MARCH 4, 1969, RECORDED AT BOOK 4579, PAGE 88.

PARCEL 15:

A CERTAIN PARCEL OF LAND IN THE COMMONWEALTH OF MASSACHUSETTS, COUNTY OF NORFOLK, CITY OF QUINCY, SITUATED ON SOUTH STREET, READ AVENUE, WASHINGTON STREET, AND NASH AVENUE AND IS SHOWN ON SAID PLAN, DATED OCTOBER 15, 1986, DRAWING 150.111M.

CONTAINING 8,147 SQUARE METERS, MORE OR LESS, OR 87,688 SQUARE FEET, MORE OR LESS, OR 2.013 ACRES, MORE OR LESS.

INCLUDED AS PART OF THE ABOVE-DESCRIBED PARCEL 15 IS A PARCEL OF REGISTERED LAND BEING SHOWN AS LOT B ON LAND COURT PLAN 10629B, A COPY OF A PORTION OF WHICH IS FILED WITH CERTIFICATE NO. 16150, REGISTRATION BOOK 81.

FOR TITLE REFERENCE, SEE CERTIFICATE OF TITLE NO. 117791, FILED IN REGISTRATION BOOK 589, PAGE 191; DEED FROM BETHLEHEM STEEL COMPANY DATED DECEMBER 31, 1963, RECORDED AT BOOK 4132, PAGE 459; DEED FROM ADELE M. FERRIS DATED APRIL 10, 1967, RECORDED AT BOOK 4419, PAGE 599: DEED FROM JOHN A. MORRISON AND WINIFRED J. MORRISON DATED APRIL 10, 1967, RECORDED AT BOOK 4419, PAGE 600; DEED FROM ROBERT J. GILMORE AND ELAINE M. GILMORE DATED JUNE 9, 1967, RECORDED AT OOK 4434, PAGE 109; DEED FROM MARIE NORCOTT DATED JULY 10, 1967, RECORDED AT BOOK 4441, PAGE 440; AND DEED FROM ARMAND F. BRODEUR AS TRUSTEE OF THE RONALD BRODEUR TRUST, AND RONALD J. BRODEUR AND ANNA M. BRODEUR, DATED JULY 22, 1967, RECORDED AT BOOK 4445, PAGE 299.

- 6 - EXHIBIT B

Parcel Four

A certain parcel of land in The Commonwealth of Massachusetts, County of Norfolk, Town of Braintree, situated on Lancaster Road, and shown on drawing 150.061M of a plan of land entitled "General Dynamics Quincy, MA. and Braintree, MA." (consisting of a Plan Index and fourteen drawings numbered 150.011M to 150.151M, inclusive, but excluding 150.081M) dated October 15, 1986 and November 4, 1986, as revised, by New England Survey Service, recorded November 16, 1987 in Plan Book 361 as Plan #1372 of 1987, Sheets 1-15.

Containing 1,301 square meters, more or less, or 14, 000 square feet, more or less.

Said parcel is identified as Parcel 4 in Exhibit A of the deed of General Dynamics Corporation to Massachusetts Water Resources Authority dated November 16, 1987 and filed with the Norfolk County Registry District of the Land Court as Document No. 535415 and recorded with the Norfolk County Registry of Deeds in Book 7803, Page 211. Said parcel is further described as Parcel 4 on Exhibit A-1 hereto. 0 EXHIBIT C

CERTIFICATE CF COMPLETION SPECIAL COVENANT NOT TO SUE AGREEMENT M.G.L. c. 21E, § 3A(j)

From: The Department of Environmental Protection

To: Massachusetts Heavy Industries ("MHI")

Date of Issuance:

DEP Release Tracking No. 3-0536

Property:

This Certificate of Completion ("Certificate") is issued in accordance with a certain Special Covenant Not To Sue Agreement entered into by the Department of Environmental Protection and the Commonwealth of Massachusetts with MHI, dated , 1997, to signify only that the Department has received (i) a RAM Completion Statement for the Property; and (ii) a Class A Response Action Outcome Statement(s) for any release at the Property prepared in accordance with MGL c. 21E; 310 CMR 40.0000; MGL c. 21A, §§19-19J; and 309 CMR 1.00-8.00; or (iii) an LSP Opinion addressing whether further response actions are needed in the areas where excavation of contaminated soils or dewatering of contaminated groundwater has been conducted by MHI, prepared in accordance with MGL c. 21E; 310 CMR 40.0000; MGL c. 21A, §§19-19J; and 309 CMR 1.00-8.00.

This Certificate shall not be deemed or construed to imply the Department's approval of the adequacy of any response action(s) undertaken at the subject property, nor shall issuance of this Certificate operate to bar the Department from auditing any person, site or response action, or from requesting any person to provide information to the Department, or to relieve any person of his/her obligation to comply with any such request.

Issued by: Assistant Commissioner, Bureau of Waste Site Cleanup MASSACHUSETTS WATER RESOURCES AUTHORITY Charlestown Navy Yard 100 First Avenue Boston, Massachusetts 02129 Telephone (617) 242-6000 Facsimile. (617) 241-6070

October 17, 1997

James C. Coleman Assistant Commissioner Commonwealth of Massachusetts Department of Environmental Protection One Winter Street Boston, MA 02108

Re: Confirmation of Responsibility Letter, Quincy Shipyard, RTN # 3-0536

Dear Mr. Coleman:

Enclosed please find the facsimile of the above noted letter, bearing the original signature of MWRA's authorized representative. It is our understanding that this document will meet your needs. Please contact me at 617/241-2758 if you need additional information.

Thank you for your help in this matter.

Sincerely,

Le n ataille Environmental Manager

Enclosure: Signed facsimile cc: Douglas MacDonald Tom Powers Maggie Debbie Trudy Reilly Peg Stolfa-DEP

Printed on 100% Recycled Paper 10-17- 1997 14:28 6f92+5721 MASS. DEP / N LEQAL P.03/04

COMMONWEALTH OF MASSACHUSETTS ExEcu-nvE OFFICE OF ENmIoNMENTAL AFFAIRS DEPARTMENT OF ENVIRONMENTAL PROTECTlON ONE WiTEK STAT. DWTUN, MA 0210 617.29>$500

TRUDY (XMf ARGEO PAUL CELLUCC - DAVID B. TRUHM

October 17, 1997

Leon Lataille Massachusetts Water Resource Authority Charlestown Navy Yard 100 First Avenue Boston, MA 02129

Re: Massachusetts Water Resources Authority Confirmation of Responsibility for Existing Contamination at the Quincy Shipyard. Reasue Traeking Number 3-056

Dear Mr. Lataille:

Attached please find the latest draft of the Special Covenant Not to Sue Agreement ("Covenant") with respect to Massachuuettu Heavy Industry, Inc.'s ("MHI") purchase of that portion of the above referenced site ("Site") that is defined in the Covenant as the "Property." Prior to approving the final Covenant, the Department of Environmental Protection (the "Department") must be assured by the Massachusetts Water Resources Authority ("MWRA") that the Existing Contamination on the Site will be addressed. As defined in the Covenant, "Existing Contamination" means "any oil or hazardous material present or existing on or under the Site, whether known or unknown, as of the Acquisition Date." As discussed, this letter serves to memorialize the agreement in principle between the Department and the MURA that the MWRA confirms its responsibility for such Existing Contamination.

The Department is aware that the MWRA has executed indemnification agreements with General Dynamics and MH1 regarding this issue. While indemnification agreements between private parties provide specified protections among the parties, as you are no doubt aware, it does not affect any obligation to the

DEP on ftmWr Wie Wb:MtmwAnstema.ufmlp I Pined rn tnd Popwr 10-17-1997 14:28 617 292+5721 MASS. DEP / 80 LEGAL P.04/04

Leon Lataille KMNA Confirmation of Responsibility for Existing Contamination at the Quincy Shipyard, RTS 3-0536 October 17, 1997 Page 2

Department pursuant to M.G.L. c. 21E, 310 CMR 40.0000 (the "MCP") and any other applicable law.

Please have the authorized representative of MWRA sign the statement below and return the original copy of this letter to my attention. Upon receipt the Department will circulate the final Covenant for the signatures of the authorized representatives of MHI, the Department and the Office of Attorney General.

S' erely,

Ja eeu. Colman As istant Commissioner

MWRA hereby confirms its responsibility for the Existing Contamination on the Property, as identified in the Covenant, and will address such contamination pursuant to chapter 21E and 310 CMR 40.0000 (the "MCP") and the terms of the March 2, 1994 "waiver of approvals" ("waiver") that was granted to MWRA and General Dynamics pursuant to 310 CMR 40.000.

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Julv 31, 1997 File No. 7400.5-CPC 7400-C G\ Ms. Sharon A. Gobiel Department of Environmental Protection 10 Commerce Way Woburn, Massachusetts 01801

DEP Waiver Site I.D. Number: 3-0536 and 3-10266

Re: Replacement of Recovery Well RW-6 Central Yard Oil Plume Quincy Shipyard, Quincy, Massachusetts

Dear Ms. Gobiel:

In May 1997, existing recovery well RW-6 at the Central Yard Oil Plume (CYOP) at the Quincy Shipyard (QSY) in Quincy, Massachusetts, became inoperable due to screen damage. As with other recovery wells at the site, failure occurred due to iron fouling in the screen and other factors. Since the oil recovery system went in operation in 1986, four recovery wells have become inoperable and have been replaced. These four wells included RW-l, RW-3, RW-5 and RW-7. which have been replaced with new wells RW-1A, RW-3A, RW-5A and RW-7A.

Fluor Daniel GTI has proposed a location for replacement recovery well RW-6A which is approximately 15 feet north of well RW-6. This location is considered the most optimum

in light of existing underground utilities and planned building demolition. Piping will be placed in a trench from the new well vault to pre-existing piping from RW-6. The piping that ran to RW-6 will be capped in place. Electrical supply will be provided from the Quincy Fire Academy Building. The decommissioning of RW-6 and its associated well vault, installation and development of RW-6A and the installation of a new well vault for RW-6A, will be performed by Fluor Daniel GTI.

On behalf of General Dynamics, Inc., GZA GeoEnvironmental, Inc. (GZA) has assessed whether the location of the proposed RW-6A will be adequate to continue capture of the CYOP in the RW-6 area. Based on previous pump testing and groundwater modeling of extraction configurations, the location of RW-6A will effectively capture the plume in the former RW-6 area. The location for RW-6A was approved by MWRA and MH.

Please do not hesitate to call if you have any questions or concerns.

Very truly yours, Caz GZA GEOENVIRONMENTAL, INC. /4 I David J. Adilinan, P.G. Lawrence Feldman, LSP Project Manager Senior Principal

Attachment: Figure I

cc: L. Burt, Esq. (FH&E) Robert F. White (General Dynamics) John Mitchell, Fluor Daniel GTI

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Ms. Sharon A. Gobiel rjzw\ Department of Environmental Protection 10 Commerce Way Woburn, Massachusetts 01801

DEP Waiver Site 1.D. Number: 3-0536 and 3-10266

I r Re: Groundwater Monitoring Requirements Central Yard Oil Plume Quincy Shipyard, Quiney, Massachusetts

Dear Ms. Gobiel:

On behalf of General Dynamics, Inc., GZA GeoEnvironmental, Inc. (GZA) has reassessed the groundwater monitoring requirements for the Central Yard Oil Plume (CYOP) at the Quincy Shipyard (QSY) in Quincy, Massachusetts. In particular, wc have assessed whether certain groundwater monitoring wells can be eliminated from the ongoing monthly monitoring program being conducted by Fluor Daniel GTL (formerly Groundwater Technology, Inc.) for groundwater elevation and separate phase hydrocarbon (SPH) thickness.

BACKGROUND

GZA's May 1986 "Environmental Site Assessment" for the QSY indicated the presence of separate phase hydrocarbon (SPH) in the vicinity of Buildings 5 and 11. At that time, the '.1 *. thickness of the SPH observed in monitoring wells in this area ranged up to 8 feet. GD, through its contractor Fluor Daniel GTI, began performing passive oil recovery in this area in August 1986 and active oil recovery, including groundwater extraction and treatment, in October 1986 in accordance with the October 21, 1986 approval letter from the Department of Environmental Protection (DEP). This approval letter required continuous assessment of system performance and adequacy and, if warranted, recommendations for system modifications to meet the remediation objectives.

In February 1988, SPH was discovered in monitoring well GD- 1154 located in the Bents Creek Area (located north of the CYOP, but in the area monitored for SPH as part of the ongoing CYOP recovery system monitoring program). In June 1989, GZA completed a

study of this area and determincd that SPH in the Bents Creek Area was minor and intermittent. Based on this work, in a letter dated April 17, 1991 DEP approved discontinuing the monitoring of a number of wells (GD-1154, GD-I 110, GD-2390, GD- 2391, GD-2393A, GD-2394. GD-2396, GD-1297) in the CYOP recovery system monitoring program.

01zX A Waiver of Approvals for the Site was issued by DEP on March 2, 1994. In September 1994, Completion Statements were issued in conjunction with the Waiver in which the above mentioned reduction in monitoring wells was discussed.

By 1994, the reported amount of oil recovered per month had decreased from 116,000 gallons in November 1986 to 242 gallons in October 1994. The rate of oil rceovery has leveled off to relatively low levels in most wells and has been essentially asymptotic since 1990 to 1991. The apparent thickness of SPH had also leveled off in most monitoring wells.

These changes in site conditions warranted an examination of the possibility of reconfiguring the number of active recovery wells to a more cfficient operating regime, Therefore, in June, 1994, GZA conducted pump tests and groundwater flow modeling in order to assess options for the possible reconfiguration of the existing groundwater extraction system. Based on this work, GZA recommended reducing the number of groundwater depression wells and product recovery wells. In addition, GZA submitted a "Modifications to Monitoring Program" letter dated December 5, 1994 which included a recommendation to reduce monitoring report production to a quarterly basis, with each quarterly report containing monthly monitoring data for the previous three months. The reduced level of monitoring was reflective of the stable conditions that had been observed during the previous several years. Since system startup in 1986 Fluor Daniel GTI has submitted 97 monthly monitoring reports and nine quarterly monitoring reports to DEP.

ADDITIONAL RECONFIGURATION OF MONITORING SYSTEM

GZA has reevaluated the existing monitoring program in light of data contained in the Fluor Daniel GTI quarterly groundwater monitoring reports prepared since late 1994. Based on this evaluation, and our commitment to continued system modifications based on observed conditions, we recommend eliminating additional wells from the recovery system monitoring network at this time. Our assessment is based on whether the wells are needed to either monitor the extent of the CYOP plume, or to demonstrate the capture and containment of the plume.

One of the goals of the groundwater monitoring program is to monitor the extent of the CYOP. Thus, wells which no longer exhibit detectable levels of SPH may not be necessary Department of Environmental Protection June 17, 1997 File No. 7400.5 ______Page 3

to monitor the extent of the plume. In addition, groundwater elevations within and around the plume are needed to demonstrate that the groundwater and product recovery system is effectively controlling the migration of SPH. Where there is redundancy in groundwater elevation data, wells can be eliminated.

Monitoring wells no longer required to perform either of these functions can be eliminated from the program. Based on our evaluation, we recommend that wells GD-2270, MW-15S, GD-2152, MW-13 and GD-2159 be eliminated from the monitoring program for the reasons outlined below. The locations of these wells are highlighted on the attached figure.

. GD-2270 and MW-15S. SPH has not been observed in GD-2270 in the past and records show that GD-2270 is no longer functional, as it has been destroyed since 1992. MW-15S typically shows no oil thickness or an extremely small thickness (<.03 feet). In addition, the groundwater elevation in other wells which are monitored in the area (MW-2, MW-16, GD-2392 and GD-2395A) provide adequate definition of the groundwater contours (and thus system capture) in this area.

. GD-2152. This well has been reported as destroyed since August, [995.

. MW-13. At least one well from the northern portion of the plume could be eliminated from the program. SPH has not been detected in well MW- 13 for over a year, and GD-2157 and MW-l are sufficient to monitor the CYOP and its capture in this area.

. GD-2159. This well is near the center of the plume and consistently shows either no oil or small thicknesses. Wells GD-2269A, MW-5 and RW-4 are considered adequate to define the CYOP in this area.

To the extent practical (in light of the planned construction at the shipyard), we recommend that the above mentioned wells not be abandoned so that they can be utilized in the future to monitor system performance should further modifications be made to the groundwater extraction system (e.g., further elimination of extraction wells). At this time we believe that the remaining wells adequately demonstrate capture of the CYOP regardless of the number of active recovery wells. Department of Environmental Protection June 17, 1997 File No. 7400.5 Page 4

We feel these recommendations are in keeping with our efforts to efficiently contain the Central Yard Oil Plume and monitor SPH in monitoring wells. Please do not hesitate to call if you have any questions or concerns.

Very truly yours, onx GZA GEOENVIRONMENTAL, INC.

David J. Adilman, P.G. Lawrence Feldman, LSP Project Manager Senior Principal

Alb/rt J. Ricciardelli Asociate Principal

Attachment: Figure 1

cc: L. Burt, Esq. (FH&E) Robert F. White (General Dynamics) John Mitchell, Fluor Daniel GTI

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CENTRAL YARID OiL PLLME I GENERAL DYNAMICS QUINCY SHIPYARD IREv. N.1 t seR1PflON QUINCY, MA PROJ MGR £'A 1" = 80 DESIGNED BY DJA REVIE'ED HY: AJR WELLS TO REMOVE FROM GROUNDWATER 0 40' so 160, I-- ~- ", MONITORING REQUIREMENTS GZA 11-1 nviro'in3 i ntal In , MASSACHUSETTS WATER RESOURCES AUTHORITY Charlestown Navy Yard 100 First Avenue Boston, Massachusetts 02129 C4 Telephone: (617) 242-6000 Facsimile (617) 241-6070

May 14, 1997

Ms. Sharon Gobiel Massachusetts Department of Environmental Protection Northeast Regional Office Bureau of Waste Site Cleanup 10 Commerce Way Woburn, Massachusetts 01801

Re: Fore River Staging Area (Fmr. General Dynamics Quincy Shipbuilding Facility) Quincy, Massachusetts RTN # 3-0536 & 3-10266

Dear Ms. Gobiel:

For over seven years MWRA has operated an ambient air monitoring system at the Fore River Staging Area (FRSA) in Quincy, Massachusetts. MWRA established an air monitoring network at the FRSA in September 1989 to ensure that fenceline air concentrations during building demolition or soil excavation did not exceed standards for total inhalable particulate matter (PM 0 ) and to assess lead concentrations in comparison to DEP's guideline 24-hour ceiling concentration and Threshold Effects Exposure Limit (TEL). Ambient air sampling stations consisting of PMo Size Selective High Volume (Hi-Vol) Samplers were established at the following four locations:

1. At the western edge of the roof of the Administration Building (Building 10); 2. On the northern site boundary at the South Street gate; 3. At the northeastern corner of the site, near Pier 4; and 4. East of the FRSA, across the Fore River on the south side of the Boston Edison Edgar Station.

From September 1989 until January 1992, PM10 Hi-Vol samples were generally collected every 2 days, From 1991 to the present, the PM,0 sampling frequency was decreased to every 12 days Lead Hi-Vol samples were generally collected every 12 days throughout the entire study period. Approximately 1,400 PMI, samples and over 800 lead samples have been collected over

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From September 1989 to the present, only one PM,0 sample from the total of approximately 1,400 samples (0.07%) exceeded the 24-hour ambient air quality standard, and of over 800 lead samples, only one sample (0.13%) exceeded the 24-hour TEL. The annual PM,, standard was never exceeded. Only approximately 4% of the lead concentrations were above the practical quantitation limit; no detectable lead has been observed in samples collected since May 1993.

As a result of the non-existent or negligible exceedances of applicable ambient air quality standards since 1989, and the expected low level of future construction activity at the FRSA, MWRA intends to terminate regular air monitoring effective immediately. Air monitoring will be implemented for future construction or demolition projects on a project specific basis, as necessary to meet all applicable regulatory requirements.

If you have any questions or comments regarding this decision, please call me at (617) 241-2759. Thank you for your assistance.

Very truly yours,

Mark Radville Program Manager, Real Property & Environmental Management cC Maggie Debbie, MWRA Leon Lataille, MWRA Steve Lipman, DEP/WPC Ken Menzies, PEER Consultants

2 DRAFT FINDING PURSUANT TO M.G.L. c.30 s.61

BY THE

MASSACHUSETTS WATER RESOURCES AUTHORITY

FOR THE

SLUDGE PROCESSING FACILITY EXPANSION, PHASE Il,

AND LONG TERM RESIDUALS MANAGEMENT OPERATION

EOEA # 5832

Submitted by:

The Massachusetts Water Resources Authority 100 First Avenue Charlestown Navy Yard Boston, MA 02129 (617) 242-6000

July 26, 1996 ATTACHMENT A

Thomas Powers, Deputy Director, MWRA David Standley, P.E., Consultant to the City of Quincy S. David Graber, Consultant to the City of Winthrop James Goldstein, Consultant to the Town of Braintree James Clark, Town of Weymouth Peter Koff, Legal Counsel for the City of Quincy Allen Johnson, Massachusetts Historical Commission

Jane Mead, Office of Coastal Zone Management - Steven Lipman, DEP Division of Water Pollution Control Mark Stein, EPA Region I Vivien Li, Boston Harbor Association Virginia Renick, Associate General Counsel, MWRA Nancy Kurtz, Associate General Counsel, MWRA Patricia Laurie, Staff Counsel, MWRA Susan Redlich, MWRA Advisory Committee Richard Mills, Director, Residuals Management Jodi Sugerman, Save the Harbor Save the Bay MASSACHUSETTS WATER RESOURCES AUTHORITY Charlestown Navy Yard 100 First Avenue Boston, Massachusetts 02129 Telephone: (617)242-6000 Facsimile: (617} 241-6070 July 26, 1996

Trudy Coxe, Secretary Commonwealth of Massachusetts Executive Office of Environmental Affairs 100 Cambridge Street, 20th Floor Boston, MA 02202

Attention: MEPA Unit

Dear Secretary Coxe:

Re: MWRA, Sludge Processing Facility Expansion and Long-Term Residuals Management Operation, EOEA #5832

Pursuant to the Massachusetts Environmental Policy Act (M.G.L. C.30 s.61) the Massachusetts Water Resources Authority is submitting the enclosed DRAFT Section 61 finding for the Residuals Management Facilities Plan, EOEA #5832, Sludge Pr-csinc Facility Expansion, Phase III. This submittal also complies with the Secretary's Certificate regarding the FEIR (November 20, 1989) and the Notice of Project Change (March 9, 1995). This finding is also being forwarded to the interested parties and regulators listed in Attachment A.

This DRAFT finding covers the remaining elements of the Lng-I; Residuals Management Plan not covered in the previously submitted finding submitted December 12, 1995 for elements of the Sludge Processing Facility, Phase II Outside Work contract. Included in this document are findings related to process improvements necessary for increased pelletizing capacity, installation of two additional pelletizing trains to meet future sludge processing demand, revisions to building ventilation systems, revision of air pollution control systems, addition of process safety equipment and changes to sludge cake handling and bypass conveying equipment for emergency sludge loading.

If yo have any questions regarding the DRAFT finding, please give me a call at (617) 242-6000 or contact Mike Rivard at (617) 242- 0230 x4351.

Sincerely,

JO F. Fi D airector, Se erage Division cc: D. MacDonald, MWRA J. Reitsma, MEPA Unit D. Shephardson, MEPA Unit %T 9efc wn a; / n50 &ot ,M 17 &/a ~~# , J o-r K g?c F5esA %Anad /zC- b//&

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7 '7'7 #2- AL19K' As;5 7, DRAFT FINDING PURSUANT TO M.G.L. c.30 s.61 BY THE MASSACHUSETTS WATER RESOURCES AUTHORITY FOR THE SLUDGE PROCESSING FACILTY EXPANSION AND LONG TERM RESIDUALS MANAGEMENT OPERATION

PHASE III

TABLE OF CONTENTS Page 1 INTRODUCTION 1

2 PROJECT BACKGROUND 1

3 DESCRIPTION OF FACILITIES 1

3.1 Deer Island (Phase 1I) 1

32 Fore River Staging Area (FRSA) 1

3.2.1 Existing Facilities 1

322 Lcrg-terrn RFst: Facilities (Phase 1) 2 Pelletizing (Heat Drying) Trains 2 High Solids Centrifuges 3 Product Storage Facilities (Phase 11) 3 Pellet Transport to New Silos (Phase 11) 3 Pier 2 (Phase 11) 3 Sludge Cake Loading Facilities (Phase 11) 3 Rail Storage Track (Phase 1l) 3 Exhaust Gas Recirculation 3 Manifolding Regenerative Thermal Oxidizers 4 Air Pollution Control Devices 5 Explosion Protection 5 Fire Suppression 6 Pellet Cooling 6 Building Ventilation 6 Access Road & Utility Improvements (Phase 11) 7 Historic Building Demo/Rehabilltation (Phase 11) 7 Braintree/Weymouth Interceptor (Phase 1l) 7 Ferric Chloride 7

i Page

3.2.3 Cogeneration (Phase 11) 8

3.3 Residuals Disposal Facilities (Phase 11) 8 3.3.1 Walpole Landfill (Phase 11) 8

3.3.2 Commercial Disposal Facilities (Phase 11) 8

Grit & Screenings 8 Sludge Cake & Pellets 8

4 SPECIFIC IMPACTS & MITIGATION - DEER ISLAND (Phase 11) 8

5 SPECIFIC IMPACTS & MITIGATION - FRSA FACILITIES 8

5.1 Construction 8 5.1.1 Excavated Soils and Construction and Demolition Materials Handling (Phase 11) 8 5.1.2 Building/Structure Demolition (Phase 11) 8 51.3 Noise & Vibration 8 5.1.4 Traffic 8 5.1.5 Water Quality, Waterways & Wetlands (Phase 11) 8 5.1.6 Air Quality (Phase 11) 8

5.2 Long-term 9 5.2.1 Air Quality 9 Best Available Control Technology 9 Regulatory Requirements Actual and Potential Emissions 12 Air Quality Impact Analysis 13 Odor Impacts 16 5.2.2 Noise 18 5.2.3 Historical/Archeological Resources (Phase 11) 18 5.2.4 Land Use & Visual Impacts (Phase 11) 18 5.2.5 Socioeconomic (Phase 11) 18 5.2.6 Transportation (Phase 11) 18 5.2.7 Water Quality (Phase 11) 18 5.2.8 Waterways (Phase 11) 18 5.2.9 Wetlands (Phase 11) 18 5.2.10 Utilities (Phase 1l) 18

1i Page

6 SPECIFIC IMPACTS & MITIGATION - RESIDUALS DISPOSAL FACILITIES 18

6.1 Walpole Landfill (Phase 11) 18

6.2 Commercial Disposal Facilities (Phase 11) 18

7 RESPONSES TO SECRETARY'S CERTIFICATES & SELECTED PUBLIC COMMENTARY [PHASE IIJ 18 7.1 Noise 18

7.2 Transportation (Phase 1l) 18

7.3 Hazardous Materials (Phase 11) 18

7.4 Land Use & Visual (Phase 11) 18

7.5 Other 18 7.5.1 Air Quality and Facility Emissions 18 7.5.2 Odor Control 19 75.3 Fire Hazards 19 7.5.4 Visible Emissions 20

8 CONCLUSIONS & FINDINGS 20

APPEND CES

APPENDIX 1 - 8 - (See Phase 11)

APPENDIX 9 - Conditional Approval, MWRA Sludge Processing Expansion Appl. No. MBR-95-IND-056

iii 0

INTRODUCTION

This Draft Phase III Section 61 Finding is submitted pursuant to M.G.L c30, Section 61 and the Certificates of the Secretary of Environmental Affairs as related to the Massachusetts Water Resources Authority (MWRA) sludge processing facility expansion and long-term residuals management facilities operations. As provided for in the most recent Certificate of the Secretary dated March 9, 1995, this document specifically addresses the commitments to environmental protection to be implemented during construction and operation of facilities related to the "inside" construction work of the long-term residuals project, known as and referred to hereinafter as Phase Ill. The "outside" phase of the long-term residuals project, known as Phase 11,and the environmental protection commitments made pertaining thereto, were the subject of a separate Draft Section 61 Finding document, as amended, submitted to MEPA, interested parties and regulators on August 21, 1995. Comments on the Draft Section 61 Findings document for Phase I have been responded to by MWRA and a Final Section 61 Findings Document was submitted to MEPA, interested parties and regulators on December 12,1995. In this regard, and in the interest of submitting a combined Final Section 61 Finding document which covers both Phases |1 and IlIl, this Draft Phase Ill document only includes text which addresses topics and impacts associated with Phase Ill. For a review of all topics and impacts related to Phase 1lthe reader is referred to the Phase 11Section 61 Finding document. Ultimately, the Authority's objective is to combine the Phase i Final and Phase Ill Final Findings, subsequent to comment responses, into a single Final Section 61 Finding document for the Sludge Processing Facility Expansion and Long-Term Residuals Management Operation.

2 PROJECT BACKGROUND (See Phase || Finding)

3 DESCRIPTION OF FACIUTIES 3.1 Deer Island (See Phase Il Finding) 3.2 Fore River Staging Area (FRSA) 3.2.1 Existing Facilities (Also see Phase il Finding) Phase I Sludge Processing Facility Expansion In 1995. In the spring of 1995, dryer train #2 was modified to allow for its use in the full scale pilot test program, which has been called Phase I of the expansion and modification project. Modifications were made to the process air handling and air pollution control systems.

1 Specifically, the original equipment installed under the ISP&D project was modified to allow testing of alternative particulate removal equipment and recirculation of dryer air to reduce air emissions and energy use. In addition, pellet cooling equipment was installed and tested to provide control over pellet self heating during storage. The following modifications were made under Phase 1:

1. Dual cyclone pairs on pelletizing train No. 2 were replaced by a venturi scrubber and packed tower to demonstrate improved particulate and ammonia removal. The packed tower was also operated as a condenser to allow higher rates of gas recirculation. 2. Recirculation ductwork and a larger induction fan were added on Train 2 to allow treated hot air to be returned to the head end of the pellet dryer for reuse. 3. Two pellet cooling devices were installed to provide pellet cooling for four process trains. Pellet coolers of same size are intended to be used, one per train, in the future plant expansion, Phase Ill.

3.2.2 Long-term Residuals Facilities

Pelletizing (Heat Drying) Trains. As presented in the FEIR, the Authority will install two (2) additional process trains to allow the thermal processing of all anticipated future sludge volumes from the new Deer Island Treatment Plant. The installed capacity of the six dryer trains has been revised since the filing of the 'EIR :- '989 Curent estimates of insta!led processing capacity indicate that the six dryer trains would provide between 224 and 324 dry tons per day (dtpd) depending on the pellet quality desired. The lower processing rate has been demonstrated over the past year of operation to be a reliable operating point and provides a marketable pellet product providing a high market price. Higher throughp.t., 3n the order of 43 dr, :s per day per machine (258 dtpd installed capacity with six trains), has been achieved for short operating periods but operational reliability at this throughput is unproven. Phase 3 improvements in wet and dry solids conveying and pre-mixing are expected to improve the reliability of all trains at the target processing rate of 44.8 dtpd. At this processing rate the pellet facility would be capable of providing continuous operation during high sludge production periods while allowing one dryer train to be out of service for regular or unscheduled maintenance.

The theoretical maximum processing capacity of a dryer is 54 dtpd (324 dtpd installed capacity with six trains). This processing rate has never been achieved, is highly dependent on sludge cake dryness and would likely produce very poor quality pellet product that would not be well accepted in the fertilizer markets. In addition to nutrient content, size, density and uniformity of the pellet product are critical characteristics for marketing as fertilizer. An uncontrolled product with large variation in these various parameters would likely draw the lowest market price,

2 0 thus increasing the difficulty of sale as a fertilizer product.

Projected maximum month sludge volumes of 224 dry tons per day could be processed with 5 or 6 trains depending on the necessary product quality goals. Annual average sludge volumes of 180 dry tons per day could be processed with four to five process trains in operation allowing some redundancy for maintenance and repair of dryer and associated conveyance equipment. Pug mills on the dryer inlet and pellet screens at the dry process end are being replaced to ensure adequate "dry-material" processing is available for higher projected processing rates. High Solids Centrifuges. The eight (8) belt filter presses installed for sludge dewatering in the Interim Sludge Processing and Disposal (ISP&D) project will be replaced under Phase Ill Sludge Processing Facility Expansion with twelve (12) centrifuges as planned in the FEIR, August 1989 ind revised in the Notice of Project Change dated December 30, 1994. The centrifuges are necessary to provide high solids dewatering capability for the future volumes of mixed anaerobically digested primary and secondary sludge. Twelve centrifuges will provide the necessary sludge dewatering capability for anticipated maximum month sludge volumes with adequate processing redundancy.

Product Storage Facilities. (See Phase Il Finding) Pellet Transport to New Silos. (See Phase 11Finding)

Pier 2 (See Phase Il Finding)

Sludge Cake Loading Facilities. (See Phase I Finding)

Rail Storage Track. (See Phase ii Finding) Exhaust Gas Recirculatlon. Exhaust gas recirculation has been shown to improve the efficiency of the heat drying process during testing of Train 2 in Phase I of the plant expansion project. This process has been demonstrated in Canada and Europe as an effective means of increasing the efficiency and performance of sludge drying and reducing facility emissions. Dryer air recirculation loops will also be installed on each of the other three existing trains and the two new process trains. Process air recirculation rates as high as 75 percent are possible. The process air recirculation loop diverts air exiting the dryer, after a venturi scrubber and packed tower (see discussion -Air Pollution Control Devices), back to the inlet of the dryer, reducing the volume of new air that must be heated to dry the sludge. Recirculation reduces the discharge of process air from the facility, which will reduce emissions from the facility. Furthermore, the reduction in air requiring

3 treatment through the Regenerative Thermal Oxidizers (RTOs) decreases the fuel and power consumption of the RTO operation.

New separator cans have been designed for dryer Trains 1 through 4 so that air locks can be installed beneath the discharge cone. The inclusion of the air lock will reduce infiltration air into the dryer air loop, thus reducing the impacts on recirculation of dryer air and plant emissions volumes that would result from the introduction of unwanted process air. Manifolding Regenerative Thermal Oxidizers. The process changes described above, as well as changes in the handling of dryer room ventilation air (see Building Ventilation), result in a reduction in the number of RTO's that are necessary to treat process and building ventilation air. The original design intent was to provide one RTO per sludge drying train with each system in parallel. Therefore, two new RTO's would have been required for the new dryer trains. Under this design assumption all process room air including the sludge dryer room air would be drawn into a common plenum and used 100% as sludge dryer air in a once through process. AM air would have passed through six dryers/ RTO's in parallel prior to discharge to the stack. However, with the recirculation of between 30% and 75% of the dryer air back into the sludge dryer and the direct discharge of non-process air from the dryer room, no additional RTO's are necessary to provide volatile organics destruction and odor control. The four existing RTO's will be manifolded to allow any combination of dryers and RTO's to operate as a system. Three RTO's are expected to adequately handle the operation of six processing trains plus providing treatment of building ventilation air associated with sludge dewatering, conveyance and storage. Sludge weigh belts and storage bins will be covered and vented direct to the existing plenum which continues to provide process air to the pellet dryers. Ventilation air from the cake bin room and the dewatering room can either be pulled to the plenum as needed or bypassed directly to the RTO manifold for treatment (see Building Ventilation). One RTO is anticipated to be off-line for scheduled maintenance or serve as backup to the three operational RTO's providing some operational flexibility. The manifolding of RTO's allows any of the four RTO's or the six pellet drying trains to be out of service for repairs, without losing dryer system or RTO capacity unnecessarily.

In addition, ventilation air from the dewatering room and bypass conveying/loading areas can be directed to the RTO mnifofd for VOC and odor control during bypass cake loading in the future garage extension. This allows operation of the sludge bypass option independently of the sludge dryer operation.

4 Two existing, unused process flues that were originally intended for discharge of additional process air from two new process trains and RTO's will no longer be needed. These unused flues will be used to conduct baghouse exhaust and purge air during dryer start-up (see 'Air Pollution Control Devices " and "Explosion Protection"). Air Pollution Control Devices. Phase IlIl of the sludge processing facility expansion will include the replacement of dual cyclones with a wet venturi scrubber and packed tower combination for particulate removal. This equipment was pilot tested in Phase I of plant expansion in 1995. The wet venturi scrubber and packed tower system installed in Phase I demonstrated superior particulate removal when compared to the existing cyclones. High ammonia removal was also demonstrated through condensing and sulfuric acid addition in the packed tower loop. Ammonia removal will reduce emissions otfiitrogen oxides (NOx) from the facility. Additional sulfuric acid storage and dosing equipment will be added as part of the Phase 3 plant expansion. Condensing, which was previously achieved through the addition of clean, cold, water to the packed tower, will be achieved by the use of heat exchangers and roof mounted cooling towers on the water return of the packed tower. The new air pollution control devices will be installed on all six process trains and will treat all sludge dryer air flows prior to the recirculation of process air to the inlet of the d'ye- and subsequent discharge of excess portions of the dryer exhaust.

Improved dust collection equipment will be installed on each dryer train, under Phase 3 construction, reducing fugitive dust hazard within process equipment and eliminating discharges into the dryer room enclosure. An exhaust fan will draw dust laden air from six (6) points along the dry product handling system through a baghouse. One baghouse will be provided for each process train and all baghouse exhaust will be directed via a common manifold to one of two existing unused process flues within the stack.

Explosion Protection. Explosion suppression and venting systems have been expanded in the final design in response to further hazard assessment of the overall operation of the dryer system. Explosion suppression is provided on several key, dry material handling systems in the form of diammonium phosphate canisters that dispense the chemical under pressure into the storage vessels and dry material conveyors. The system automatically actuates in response to a sudden increase in pressure such as a pressure wave caused by dust explosion in the equipment. Explosion suppression will be added to the separator can and the fugitive dust collection system on each dryer train in addition to existing systems on the recycle bins and recycle conveyor feed. In addition, the dust

5 collection system on each dryer train will reduce entrained dust in enclosed vessels and conveyors, lessening the potential for dust deflagration.

A new dryer purge system will also be installed which will vent cold dryer train air directly to one of the two existing, unused process flues within the 213 foot stack during start-up. This system will intentionally ventilate the dryer and burner cavity temporarily bypassing the RTOs as a safety precaution to remove uncombusted natural gas which could accumulate in these areas during down times or start-up. Prior to adding sludge to the dryer, all air flow will be directed to the air pollution control systems, including RTOs.

Fire Suppression. To eliminate the potential for fire within the sludge dryer and separator can, both manually automated "mini-quench" and emergency sprinkler water deluge systems have been provided. The mini-quench provides nozzles at both ends of the dryer that can be activated by the operator in response to climbing temperatures monitored at the inlet and outlet of the dryer train which is indicative of a potential fire. An emergency sprinkler/deluge system is also provided at the dryer and separator can with fusible heads that activate automatically in response to high temperatures in either vessel. These systems are process specific and in addition to the building sprinkler system which is located throughout the facility.

Pellet Cooling. Pellet cooling by water-cooled, bulk-flow, plate heat exchangers was tested ,der Phase I of plant expansion in 1995 The full scale tests utilizing two heat exchangers processing sludge pellets from four dryer trains were successful in lowering the temperature of pellets in storage. Lowering the storage temperature of pellets improves the overall safety of the pellet handling and transportation; therefore, Phase IlIl plant expansion includes the addition of peiiet cooiing on each dryer train following pellet screening. Building Ventilation. Ventilation systems for the pelletizer and dewatering rooms will be altered under the Phase Ill expansion. The dryer room ventilation system will be revised to allow direct venting of non-process, room air to the atmosphere. Six exhaust fans and vents will be added to vent room air directly through the roof as necessary to maintain acceptable working conditions in the dryer room. A smaller portion of the dryer room air will be included as dryer makeup air or dryer burner air due to the changes in building ventilation.

The change in dewatering technology from bet filter presses to high solids centrifuges and the recirculation of dryer exhaust to be used as process feed air has resulted in a reduction in the amount of ventilation air needed from the plenum as feed air to the dryer trains. Previously the plenum received air from the dryer room via the wet cake room and the dewatering area. Centrifuges are enclosed in a steel frame and both the sludge discharge chute and filtrate drain line are

6 contiguous to the sludge cake bins and the building drain system. Therefore, there is no mixing of sludge or filtrate with room air. This containment of sources of odor and VOC's allows reduction of the ventilation makeup air for the dewatering and cake bin areas. In addition, in the sludge cake bin area below, covers will be added to the weigh belt conveyors to reduce odor migration within the room. Each weigh belt enclosure and each cake bin will be vented to the plenum, which will continue to supply feed air to operating dryer trains. Ventilation air for the cake storage bin/polymer pump area enters from the pelletizing room via existing louvers and exits through ceiling openings into the dewatering area above. This ventilation air isthen ducted to the plenum to provide process air for operating dryers. During high recirculation rates (i.e. 75% recirculation) and 4 to 5 process trains running, a second "By-pass" ventilation system will pull dewatering room air directly to the RTO plenum for odor and VOC control. The "By-pass" fan will operate at approximately half speed under normal operation. At a recirculation rate of 33%, all ventilationair will be utilized as makeup air for the dryer systems and zero ventilation air must be bypassed to the RTOs. During periods of higher temperatures, between 60 and 80 degrees Fahrenheit, additional direct ventilation of the dryer room area is needed and the rooftop fans will be activated. The cake bin and dewatering areas will continue to receive the same make-up ventilation air from the dryer room area. At ambient temperatures above 80 degrees Fahrenheit additional cooling of the dryer room and dewatering room air will be provided via rooftop air conditioning units. Ventilation for the cake bypass operation including the dewatering room, cake storage bin area, bypass conveyors on the mezzanine, lime silo room and the sludge loading areas to the north end of the building will be provided by the "Bypass' ductwork and 'Bypass' fan, operating at full speed, with direct discharge to the RTO manifold for treatment. These areas will use the "Bypass" only when sludge cake is to be conveyed to the garage area for loading. The bypass ventilation system is intended to ensure that the garage areas operate under negative pressure when sludge handling in these areas is necessary. Under normal operations, i.e. - pelletizing, the garage areas will be ventilated using rooftop exhaust fans. Access Road & Utility Improvements. (See Phase i Finding)

Historic Building Demo/Rehabilitation. (See Phase il Finding)

BraintrelWeymouth Interceptor. (See Phase i Finding)

Ferric Chloride. Ferric Chloride (FeCQ, will be added to the sludge prior to dewatering in order to increase phosphorous capture during further processing and for struvite control. A 30 or 40 percent (%)solution of liquid ferric chloride will

7 be transported to the site by secure tank trucks. The ferric chloride solution will be stored securely in the existing 10,000 gallon tank previously used to store potassium permanganate.

The addition of ferric chloride provides several benefits. First, it may bind some ammonia prior to processing the sludge which minimizes the formation and emission of nitrogen oxides. This binding of ammonia into the sludge matrix enhances pellet fertilizer value by increasing pellet nitrogen content. Another benefit is that ferric chloride precipitates phosphorous increasing nutrient value and preventing the formation of struvite in sludge and sewer piping. Ferric chloride also provides excellent odor control as it is a strong oxidizing compound. Ferric chloride in a 30% or 40% solution is very corrosive and must not come in contact with metal or skin. A 10,000 gallon high density cross-linked polyethylene tank with spill protection will be provided for storage of ferric chloride solutions.

3.2.3 Cogeneration. (See Phase 11Finding)

3.3 Residuals Disposal Facilities 3.3.1 Walpole Landfill (See Phase 11Finding) 3.3.2 Commercial Disposal Facilities (See Phase 11Finding)

Grit & Screenings

Sludge Cake & Pellets

SPECIFIC IMPACTS & MITIGATION - DEER ISLAND (See Phase II Fcing)

5 SPECIFIC IMPACTS & MITIGATION - FRSA FACIUTIES

5.1 Construction (See Phase 11Findings) 5.1.1 Excavated Soils and Construction and Demolition Materials Handling 5.1.2 Building/Structure Demolition 5.1.3 Noise & Vibration 5.1.4 Traffic 5.1.5 Water Quality, Waterways & Wetlands 5.1.6 Air Quality

8 5.2 Long-term 5.2.1 Air Quality

The impact on air quality resulting from the operation of the MWRA Sludge Processing Expansion and Modification Project at the FRSA in Quincy, Massachusetts, has been quantified using dispersion modeling analysis. The dispersion analysis follows the most recent guidance available from the Massachusetts Department of Environmental Protection (MDEP) and is consistent with the latest available EPA guidance and models.

Three (3) potential sources of air pollution were modeled: 1) the sludge dryers; 2) the dryer room ventilation air; and 3) the process air fugitive dust ventilation system. Each of these sources were modeled as if exhausting to the atmosphere through the process flues within the existing two hundred thirteen (213) ft. high stack. Dryer exhaust and fugitive dust air will exhaust to the atmosphere through the unused process flues within the two hundred thirteen (213) ft. stack. The dryer room ventilation system design was subsequently changed to rooftop vents. A supplemental modeling analysis was conducted to assess odor impacts for this design. The dispersion modeling analysis showed that Massachusetts and National Ambient Air Quality Standards for criteria pollutants or MDEP Threshold Effects Exposure Umits and Allowable Ambient Limits for air toxics would not be exceeded during long-term operations with the changes proposed under the Phase Ill plant expansion. Therefore, the project will not have an adverse impact on air quality. Best Available Control Technology. Best available control technology [BACT] analyses were conducted for pollutant emissions of PM, ; nitrogen oxides (NO) and ammonia (NH3); carbon monoxide (CO); sulfur dioxide (SO2) and total reduced sulfur (TRS); volatile organic compounds (VOC) and metal emissions from the modified and expanded sludge processing facility. Emission controls for the new and modified sludge drying trains, process fugitive dust collection systems and fugitive dust collection systems of the pellet handling and storage operations were addressed in the BACT analysis.

Summarized, the BACT analysis provides for a "top-down" method of ranking the available control methods and technologies. These methods and technologies are ranked in descending order [hence 'top-down"] of control effectiveness. The methods and technologies are evaluated in light of energy use, economic and environmental impacts, and other criteria. Control technologies found inappropnate for the emission source are

9 eliminated.

Particulate. The BACT analysis for PM,, considered fabric filters, ceramic filters, dry electrostatic precipitators (ESP's), wet ESP's, wet venturi scrubbers and mechanical cyclone collectors. Of these technologies, fabric filters, dry ESP's and ceramic filters were found to be technically infeasible control alternatives for PM, control for the MWRA sludge processing facility. The remaining control technologies were ranked [top to bottom] in order of potential control effectiveness. . Wet ESP's . Wet venturi scrubbers . Mechanical cyclone collectors Wet ESP's were deemed infeasible primarily based on space constraints of the site; mechanical cyclones, much like those operating for the existing facility, have been found to provide insufficient removal efficiencies. Therefore, wet venturi scrubbers are considered BACT for PM10 emissions. Wet venturi scrubbers are highly effective particulate control systems. Control efficiencies in excess of 98% can easily be achieved with wet venturi scrubbers. These high control efficiencies were demonstrated throughout the summer of 1995 in the full scale pilot testing of the wet venturi scrubber for dryer train #2 at MWRA's sludge drying facility. Outlet particulate concentrations from the wet venturi scrubber/packed tower system proposed for the sludge drying facility will be less than 0.009 grains per dry standard cubic foot.

Nitrogen Oxides and Ammonia. The BACT analysis for NO, and ammonia (NH3) emissions from the sludge drying process trains was also conducted. NO, emissions at the stack result from - Dryer burner, natural gas combustion - Oxidation of sludge NH3 to NO. at the elevated temperatures in the RTO; and - RTO burner, natural gas combustion. BACT for NO control is the use of low NO. burners, which will be used on both the sludge dryers and the RTO burners.

Moreover, MWRA is proposing to reduce ammonia to further control NO emissions. Ammonia will be removed from the exhaust gas using absorption and condensing technologies. Ammonia control employing absorption and condensing, using different agents, was tested during "Phase I".The wet venturi scrubber, packed tower system, installed on train #2, was operated in three (3) modes to determine optimal NH3 removal.

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The three (3) modes were:

1) Absorption in the packed tower by circulating water only 2) Absorption in the packed tower with sulfuric acid addition 3) Air recirculation in the condensing mode with no acid addition Results from the demonstration project indicate that more than 95% NH3 removal can be achieved using absorption with sulfuric acid addition. This ammonia removal also correlated to greater than 90% NO. removal, assuming the conversion of NH, to NO, in the RTO. Therefore, BACT is proposed as the use of low NO. burners and absorption using sulfuric acid.

Carbon monoxide. Three (3) methods were evaluated to determine BACT for carbon monoxide (CO) control: 1) thermal and/or catalytic oxidation; 2) controlling combustion parameters, and /or 3) pollution prevention. ..

1) Thermal and/or catalytic oxidation would require increasing RTO temperature which has shown to increase NO, emissions.

2) Combustion control can only be achieved by nozzle adjustment, adjustment of air control linkages to the fuel controls and adjustment of fuel pressure. All three (3) types of adjustments were tested in August 1995 with no effect on stack CO. Therefore, pollution prevention has been determined to be BACT for CO control. Pollution prevention consists of minimizing energy demand of the burners within the system. This will be accomplished by better sludge dewatering as provided by the centrifuges, process air recirculation and maximization of sludge cake feed into the dryers, unless restricted by pellet quality or safety considerations. The RTO's will continue to provide some CO control as well. Sulfur Dioxide and Total Reduced Sulfur. Fuel used in combustion processes are usually the major contributor to sulfur dioxide (SO2) emissions. BACT for SO2 control on combustion units is the use of natural gas as the combustion fuel. AM sludge drying trains use natural gas as fuel.

Anaerobically digested wastewater sludge is a source of hydrogen sulfide (H2S) and Total Reduced Sulfur (TRS). Sludge HS and TRS are by- products of the digestion process and are oxidized to form SO2 in the RTO. MWRA will continue to use the RTOs as TRS control devices, aflthough the potential exists for a nominal increase in SO2.

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Volatile Organic Compounds. The best available control for VOC emissions is thermal oxidization. MWRA is committed to using the Regenerative Thermal Oxidizers (RTOs) for VOC control. Metals. Control of metals is accomplished through effective particulate control, with the exception of the "volatile" metals cadmium, selenium, and mercury. BACT for particulate removal was discussed previously and applies for non-volatile metal control. The modeling analysis performed in support of the CPA application assumed no control for the volatile metals of Cd, Se, and Hg. DEP's ambient air quality criteria (TEL's and AAL's see Page 19) were well below the mandated thresholds for all metals. Fugitive Dust. The most effective control device for fugitive dust emissions from the pellet storage silos aJd dry product handling is containment, exhaust, and capture using a baghouse collection system. As such, BACT for dust control will be the use of baghouse systems for dry product transport, loading and unloading. A baghouse system will also be installed on each process train for control of dust during product handling and processing. Each fugitive collection system will use a pulse jet continuous cleaning baghouse, with polyester, non-woven filter media. Treated (processed) air 'rom dust collectors or process trains within the pelletizing room will be vented through a common ventilation duct to one of two unused exhaust flues in the plant stack. Regulatory Requirements Actual and Potential Emissions. Regulatory requirements applicable:;ith expansion and modification of the sludge drying facility include review of emission criteria and standards against the potential emissions from the modified facility. Regulatory programs include Prevention of Significant Deterioration (PSD); Nonattainment New Source Review (NSR); and National Emission Standard for Hazardous Air Pollutants (NESHAP). PSD requirements apply on a pollutant-specific basis to major modifications and new major sources in geographic areas which are in attainment of the national ambient air quality standards for that pollutant. These requirements include ambient air quality monitoring (at the discretion of the regulatory agency), the application of Best Available Control Technology (BACT, which considers the costs of control), and compliance with ambient air requirements and PSD increments. Nonattainment NSR requirernents apply on a pollutant-specific basis to major modifications and new major sources in areas which are violating the national ambient air quality

12 standards for that pollutant. These requirements include the application of air pollution control technology achieving the Lowest Achievable Emission Rate (LAER, which does not consider the control costs), and greater than one to one emissions offsets (reductions of emissions elsewhere greater than the proposed increases).

Analysis is required to compare present facility emissions with estimated future emissions under operating conditions which would potentially result in the highest emissions. Stack parameters are not used in this stage of the analysis. Based on existing potential emissions from the sludge processing facility, (i.e., maximum possible emissions from the facility as it is currently configured), the facility is considered a "major source" for NO, because emissions exceed fifty (50) tons per year (TPY). the threshold specified under the Nonattainment New Source Review (NSR) program. The facility is not a "major source" under regulations for Prevention of Significant Deterioration (PSD) since potential emissions for each of the pollutants is less than 250 TPY. The highest emission rates anticipated from the expanded facility would result from the maximum sludge quantity processed at the facility and the use of the lowest air recirculation rate of 33%. Net annual emissions increases (expanded facility emissions less existing facility emissions) under this scenario result in the proposed expansion and modification project being considered a minor modification of a major source because the net emissions increase of NO, is less than 25 TPY. Additionally, the net increase in PM, and SO2 are each less than the PSD threshold of 250 TPY. Existing and future potential emissions of VOC's and CO are both less than the Nonattainment NSR threshold of 50 TPY and 100 TPY, respectively. Therefore, the project is not subject to Nonattainment NSR program applicability and PSD regulations and the sludge processing facility remains a minor source for all pollutants except NO. The modified facility will also maintain its compliance with the National Emission Standard for Hazardous Air Pollutants (NESHAP) for mercury of 3,200 gm/24 hours. Future facility-wide potential emissions of mercury are estimated to be 66.7 gm/24 hours.

Air Quality impact Analysis. Air quality impacts are determined using dispersion modelling. Dispersion analysis results are a function of both emission rates and stack parameters. The emission rates and stack parameters used in the dispersion modeling are those which will yield the greatest impact.

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Dispersion modelling has already been performed twice for this facility. Both analyses modelled emissions from the unmodified sludge processing trains venting through separate flues in the 213' stack. National Weather Service (NWS) surface meteorological data from Boston's Logan Airport 1983 through 1987 were used in addition to mixing height data from the NWS in Portland, Maine.

Original modelling in 1989 for the Air Plan Approval Application was conducted using expected emissions from five (5)trains processing a total of 13,667 dry pounds of sludge cake an hour which is equivalent to each of the existing four (4) trains processing 3,417 dry lbs/hr. It was assumed that facility-wide emissions for a given facility wide processing rate were independent of the individual dryer's sludge cake feed rates. The EPA ISCST model used indicated that the maximum predicted impacts would be less than the EPA significant impact concentrations for all criteria pollutants and that the maximum predicted concentration of all air toxics would be less than the MDEP's threshold effects exposure limits (TEL's) and allowable ambient limits (AAL's). Additionally, the analysis indicated that the worst case impacts from the facility would occur under typical meteorological conditions and simple terrain, as opposed to either sea breeze fumigation conditions or complex terrain. The MDEP issued a Conditional Plan Approval in February 1990.

The secono cisperscrn analysis was performed ;n 1994 as a condition of Final Plan Approval for the facility. Results of the original analysis were scaled to correspond with actual emissions measured during compliance testing. Compliance with all Massachusetts and National Ambient Air Quality Standards (NAAQS) and MDEP's TEL's/AAL's for all pollutants except NO2 was demonstratea. Additional modelling with ISCST2 model using revised stack parameters and NO, emission rates demonstrated compliance with NAAQS for NO2. As is described previously, the wet venturi and packed tower, with acid and the recirculation loop (which will recirculate at least 33% of the process air), will have the effect of substantially reducing emissions of all pollutants from each of the existing drying trains. Even with increased hourly operating and sludge processing capacity of the facility, potential emissions of most pollutants are expected to decrease. Nonetheless, as part of the Comprehensive Plan Approval (CPA) application for the expansion and modification project, refined dispersIon modelling was performed again for the four existing modified and two new sludge dryers. DEP issued it's Conditional Approval for the Sludge Processing Facility Expansion on February 9, 1996 (See Appendix 9).

14 Dispersion modeling was also conducted for a new emissions source exhausting from the 213 ft. high stack, namely the process fugitive dust ventilation and control system exhausting from a spare process flue, already in the stack. The dryer start-up purge air will also discharge from this spare process flue but was not modelled due to negligible emissions.

Process Air Fuqitive Dust Ventilation. The exhaust parameters modeled for dust control system conservatively correspond to the lowest expected exit temperatures from this system (80*F) and the maximum flow rate of 12,000 ACFM corresponding to all six (6) fans at full operation.

Sludge de!yrs. Recirculation of at least 33% of process air and modifications of the air pollution devices under Phase Ill will substantially reduce emissions from each of the existing dryer trains. Even with the increased operating hours and sludge processjng capacity of the facility, potential emissions of most pollutants are expected to decrease. Subsequent to load screening and receptor screening modeling, the refined air quality compliance modelling was conducted to determine the maximum air quality impacts from the modified facility. Differences between previous modelling efforts and the current modelling effort are:

1) Receptor rings at 200 and 800 meters were removed and recstcr rings 2t 150 and 400 meters were added. 2) A receptor at the proposed U. S. Naval Shipbuilding Museum near the site was added. 3) Use of hourly meteorological data collected by Clean Harbors, Inc. between November 1, 1988 and October 31, 1989, at a location less than %/ mile south of the facility site. The proximity of the site to the location of the Clean Harbors, Inc. data collection site warrants the use of the data as on-site meteorological data'.

The results of the refined modelling for the criteria pollutants (SO2, CO, NO2 , PM, 0, Pb) indicate that the maximum predicted air quality impacts from the proposed facility will be less than significant concentrations at all receptors. With the addition of conservative background concentrations, the maximum predicted air quality impacts from the facility will be less than the NAAQS for all criteria air pollutants. These results also indicate that the maximum predicted air quality impacts from the proposed facility will be less than the

Comparison of the Clean Harbor's with Logan Airport data show that use of the one year data set, with lower wind speeds, results in higher predicted pollution impacts from the facility than if the Logan data were used. 15 PSD increments for all criteria air pollutants. Therefore, the air quality analysis demonstrates that the proposed facility will not have an adverse impact on air quality.

The results of the refined modeling for the air toxics (NH3, Be, Cd, Cr, Cr-VI, Cu, H2S, Pb, Hg, Ni, Se, V) indicate that the maximum predicted air quality impacts from the proposed facility will be less than the TEL's and AAL's for all analyzed air toxics. Therefore, the air toxics modeling analysis demonstrates that the proposed facility will not have an adverse impact on air quality. Odor Impacts. Odor impacts of dryer room ventilation were the subject of a May 1995 report by Tech Environmental, Inc. entitled "Air Quality Impacts of Room Air Ventilation from MWRA Sludae Expansion & Modification Project". The air quality evaluatioR.is made by comparing air toxic impact concentrations to established DEP thresholds and predicting odor impacts, expressed in terms of "dilutions-to-threshold" (D/T). If air odor is detectible, "dilutions-to-threshold" refers to the degree to which concentrations of odorants in the air need to be reduced to be non- odorous. For example, if the only odorant present in the air is ammonia, which has an odor threshold of 6ppm and its concentration is 18ppm, the odor concentration is 3 (18/6) dilutions to threshold. Previous studies of air emissions from the dryers have identified the following contaminants as eing of interest: the criteria/NAAOS pollutants (SO.. PM, NO2, Pb, CO), metals (Be, Cd, CR, Cr*", Cu, Pb, Hg, Ni, Se, V) and volatile and semi- volatile compounds (PCB's, Asbestos, Hydrogen Sulfide, Hydrogen Chloride and Ammonia). Polutant samplng was &an:z.c ted on February 1, 1995. In addtn to chemical sampling, the City of Quincy requested evaluation of odor potential based on use of odor panels to establish thresholds of dryer room air versus use of chemical-specific literature values, and the use of a "puff model to assess probable dilutions to receptors. This modeling was conducted by Odor Science & Engineering (OS&E) of Bloomfield, Connecticut.

OS&E collected six (6)air samples from various locations in the dryer room. The samples were analyzed within the same day of collection by dynamic dilution olfactometry using a trained and screened odor panel. The odor panelists were chosen from OS&E's pool of panelists from the greater Hartford area who actively participated in ongoing olfactory research and represent an average to above average sensitivity range when compared to a large population. The samples were quantified for odor concentration in terms of dilution to threshold rates (D/T) in accordance with ASTM

16 Method E-679-91. Unaware of the samples origin, the panelists were also asked to describe the odor character of each sample at varying dilution levels.

Odors in the pelletizing room are likely to change subsequent to expansion and modification due to more sludge processed and changes to the air flow through the room as a result of the new dryer room ventilation system. Odors in the room will be a function of airflow through the operating dryers, sludge feed rate and the air flow through the rooftop vents.

Future emissions through the roof vents are also functions of these same variables. "Worst Case" future emissions result when the recirculation rate is highest, therefore, the dryer room air needed as make-up process air is minimized. Dryer room ventilation is then augmented by roof-top fans as needed. The maximum air recirculation rate of 75% was therefore used to calculate "worst case" future ventilation emissions. The future worst case emissions from the dryer room air vents were modeled to estimate maximum air quality impacts at ground level. Maximum ground level impacts from downwash were assessed in both the cavity and near-wake regions adjacent to the building obstructions.

The SCREEN 2 model was used to estimate concentrations in the building cavity regions. The ISCST2 model with on-site meteorological data was used for assessing effects in the wake regions. The dispersion modeling was supplemented by odor dispersion modelling conducted by OS&E using their proprietary PUFF model. 'Worst case" meteorological conditions, determined as a result of screening modelling were used in the PUFF model to assess odor impacts. Receptor points for odor impact analysis, located on and in the proximity of the site, were used to assess odor impacts.

'Worst case" odor impacts predicted using regulatory air quality models in the budding cavity and near-wake regions were 1.8 D/T and 4.1 D/T, respectively.

Odor modelling results with the PUFF model indicated odor impacts only along the north (Pier 2), east (Fore River) and south (Marine/industrial area site) boundaries for some of the modelled meteorological conditions. The "worst case" odor conditions were predicted to be at a boundary receptor located along the North Platen (#16), consistent with ISCST2 modelling results. Lesser odor impacts were identified at receptors located along the Pier 2, adjacent to Building 11 and the marinelindustrial area. No odor impacts are predicted for the designated commercial area north of Pier 1

17 or the areas west designated for a "Maritime Technology Park". More recent modeling of odor impacts from a revised rooftop ventilation design of six (6)rooftop vents discharging approximately fifteen feet above the roof (Tech Environmental letter to Rachel Quill of DEP, April 12, 1996) showed even lower predicted odor impacts. Maximum predicted odor impacts to all sensitive receptors were less than 2.2 Df. Although these modeling results would theoretically result in the detection of odor under certain climatic conditions, the impact is thought to be very minor and may not result in any practical detectable odor. The MWRA is committed to taking reasonable measures to eliminate detectable odors at its property boundary and will take the necessary steps toward this goal in the event that odors are found to be detectable in practice.

5.2.2 Noise . 5.2.3 Historical/Archeological Resources (See Phase It Finding) 5.2.4 Land Use & Visual Impacts (See Phase i Finding) 5.2.5 Socioeconomic (See Phase Il Finding) 5.2.6 Transportation (See Phase 11Finding) 5.2.7 Water Quality (See Phase Il Finding) 5.2.8 Waterways (See Phase 11Finding) 5.2.9 Wetlands (See Phase Il Finding) 5.2.10 Utilities (See Phase 11Finding)

6 SPECIFIC IMPACTS & MITIGATION - RESIDUALS DISPOSAL FACILITIES (See Phase 11Finding) 6.1 Walpole Landfill 6.2 Commercial Disposal Facilities

7 RESPONSES TO SECRETARY'S CERTIFICATES & SELECTED PUBLIC COMMENTARY [PHASE III]

7.1 Noise (See Phase 1iFinding) 7.2 Transportation (See Phase 11Finding) 7.3 Hazardous Materials (See Phase || Finding) 7.4 Land Use & Visual (See Phase 11Finding) 7.5 Other (Also See Phase Il Finding)

7.5.1 Air Quality and Facility Emissions Commentary received throughout the development of the sludge processing facility has focussed on the air quality impacts associated with the operation of the facility. Responses to the various concerns follow.

18 0 0

As described in Section 5.2.1, the expanded facility will not have an adverse impact on air quality. Dispersion modelling conducted for the expanded facility, using "on-site" meteorological data, has demonstrated that Massachusetts and National Ambient Air Quality Standards (NAAQS) for criteria pollutants will not be exceeded and that MDEP Threshold Effects Exposure Limits (TEL's) and Allowable Ambient Limits (AAL's) for air toxics will also not be exceeded. Therefore, deposition analysis or health risk assessment were not required to be conducted. Facility emission rates from the expanded facility have been updated. Net annual emissions increases are described more fully in Section 5.2.1, Regulatory Requirements and Potential Emissions. 7.5.2 Odor Control An "odor impact analysis", as requested by-the City of Quincy, was undertaken by Odor Science & Engineering (OS&E) in early 1995. This impact analysis used results from air quality modelling to quantify odor impacts. Additionally, samples of dryer room air were collected and analyzed by dynamic dilution olfactometry using trained personnel involved in ongoing olfactory research. These persons represent an average to above average sensitivity to odors when compared to a large population. Additionally, odor dispersion modelling was conducted by OS&E.

Cd-r impacts which may result su.bsequent to the expansion and modification project at the MWRA sludge processing facility are expected to be minor. Section 5.2.1 describes more fully the odor impacts analysis conducted by OS&E.

7.5.3 Fire Hazards A Fire Hazards Analysis has been conducted for the facility. Fire and explosion targets associated with the processes were evaluated and recommendations for mitigation strategies developed. To the greatest extent possible these strategies have been incorporated into the expanded facility. They are: - Pellet cooling; - Nitrogen inerting of silos and recycle bins; - Improved sludge feed mixing; - Addition of a deluge system to the separator discharge conveyor; . Replacement of dry cyclones with wet venturi scrubbers for better particulate removal; - Explosion venting of silo dust collection systems;

19 - Explosion suppression of fugitive dust collection systems associated with each dryer train; - Addition of automated controls to shut down feed and burner operations while continuing to rotate the dryer and operate fans and emission control equipment if deluge is activated; - Explosion suppression system at four points on the separator system: one on the inlet to the separator can; one on the outlet of the separator can and two on the separator can itself. Additionally, a diammonium phosphate system will be installed on the recycle conveyor to the recycle bin; on the recycle bin itself; on the recycle bin outlet conveyor and one on the inlet and outlet side of the baghouse in the fugitive dust collection system. Diammonium phosphate is an explosion suppressant chemical that can be discharged under pressure into a enclosed vessel,-sonveyor or duct and will eliminate the migration of fire and potential for explosion. 7.5.4 Visible Emissions. The wet venturi scrubber system will significantly improve particulate collection. Approximately 90% more particulate will be removed using the wet venturi scrubbers versus the dual cyclone system. The dryer system consistently operates at less than 10% opacity except during start-up.

8 CONCLUSIONS & FINDINGS Based on the foregoing, the Authority finds that the environmental impacts resulting from the implementation of Phase II are those which have been described in the Residuals Management Facilities Plan and Final Environmental Impact Report (EOEA No. 5832) supplemented by the aforementioned NPC's in 1990, 1993, 1994 and 1995 and which are summarized n tth Section 61 Finding. The Authority further finds that the mitigation measures committed to in this Finding constitute all feasible measures to avoid or minimize any adverse environmental impacts described and enhance any beneficial impacts attendant thereto.

As with any major and complex project, further elaboration of and changes in specific mitigation measures may occur during final design and construction. The Authority commits to inform the Executive Office of Environmental Affairs MEPA Unit of project changes which may affect this Finding, in accordance with applicable MEPA regulations.

20 Appendix 1 - 8 (See Phase 11) APPENDIX 9 Conditional Approval, MWRA Sludge Processing Expansion Appl. No. MBR-95-IND-056 EXEc"TVE OFrIC: OF EONMENTALS VM --- DEPARTMENT OF ENVIRONMENTAL PROTECTION'

,SWY COXE FEB 9 1996 DAVD B. SflUI commmmene

Ir. ohn F:tzgerald RE: QUINCY - Metropolitan Massachusetts Water Boston/ Northeast Region Resources Authority M'WRA) 310 CU!R 702(2) Charlestown Navy Yard BWP AQ 02 00 First Avenue Transmittal No. 108091 3oston. Iassachusetts 02129 AppL. No. MBR-95-IND-056 SLUDGE PROCESSING EXPANSION CONDITIONAL APPROVAL

Dear Mr. Fitzgerald:

The Metropolitan Boston/Northeast Region of the Department of Environmental Protection. Bureau of Waste Prevention. has reviewed your request regarding modificatons to you existing Interim Sludge Paocessing and Disposal (ISP&D) Facility located at 97 East Howard Street. in the Fore River Staging Area of Quincy, Mssachusetts. Construction and operation of the existing ISP&D Facility was first approved by the Department in its February 28, 1990. CONDITIONAL APPROVAL letter, and subsequently, in its October 28, 1994, INTERIM APPROVAL letter. Your request, in the form of a plan application submittal. bears the seal and signature of Mr. David G. Healey, Ma=sachusetts P.E. No. 27544. This Office's review of your application commenced on October 13, 1995.

This review of the submitted information by Department engineers indicates that the MWRA plans to expand and modify its existing sludge processing operations. As described in the above mentioned INTERIM APPROVAL letter, this expansion and modification would be accomplished in three phases:

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Phase 1. which ended on September 1. 1995. involved the modification of Tram No. 2 to replace the dual cyclones with a wet venturi scrubber and packed tower. and to install an exhaust gas recirculation loop. Collection of emissions and performance data was also included in this phase.

Phase 2. subject of the submitted application, entails the outside improvements to rail loading facilities, and installamon of storage tanks and possibly associated piping for fuel oil. The submitted application does not inciude fuel oi as a back-up fuel. However. the MWRA may later modify the apphcation by proposng a iow sulfur fuel oil as a back-up fuel.

Phase 3, also subject of the submitted application, refers to the actual expansion of sludge processing capacity. primarily inside the existing building. This expansion will consist of modification of the four existing sludge dring prcfs train' (to improve air pollution control equipment, reduce energy consumption. and increase dry solids throughput), and installation of two new sludge drying process trains.

Therefore. this CONDITIONAL APPROVAL will serve both to approve modifications under Phases 2 and 3, and to approve the continued operation of the existing ISP&D Facility. Thus, the pertinent description and requirements stated in this CONDITIONAL APPROVAL letter will supersede the description and requirements stated in the INTERIM APPROVAL letter (see Proviso No. 4).

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L EXISTING INTERIM SLUDGE PROCESSING AND DISPOSAL FACILITY

As it currently stands. the ISP&D Facility is primarily enclosed within one building. Barges containing sludge from Deer and Nut Islands dock next to this building, and transfer sludge to holding tanks each equipped with an odor control system as approved under Application No. MBR-89-IND-115A. The ISP&D Facility also includes enclosed spaces for the transfer and loading of dewatered cake to rail cars or trucks. The holding tanks are incorporated into the building, and the entire dewatering, pelletizing, and drying processes occur within the building. The product pellets are then conveyed to silos which are outside and adjacent to the building, from where they can be loaded into rail cars.

1.1 Existing Sludge Processing Operation

The ISP&D Facility currently contains four sludge drying process trains. Each sludge drying process train includes two belt filter presses, one sludge cake storage bin, one rotary drum dryer, two duai cyclones iexcept for Train No. 2, which has a venturi scrubber/packed tower system), two induced draft fans, one regenerative thermal oxidizer (RTO), and one process exhaust gas flue. As mentioned before, Train No. 2 is also equipped with an exhaust gas recirculation loop.

The belt filter presses produce a sludge cake with a typical concentration of 25 percent solids by weight from the liquid wastewater sludge which usually contains 3 percent solids by weight. The odorous emissions from the belt filter presses in the dewatering process areas, along with any odorous emissions contained within the pelletizing plant, are controlled by the RTO associated with each sludge drying process train. The dewatered sludge cake is blended with recycled material from the process and fed into its associated sludge drying process train. -ore River Stagng Area Appfication No. Sludge Processing Expansion and Modification MBR-95-IND-056 Page 4

Each of the four Baker Rullman Model No. 105-32 rotary drum dryers has a lesign energy input rating of 25,000,000 British Thermal Units (Btu) per hour, and is equipped with a single Peabody Engineering Model No. APR-10 "low NOx" :rurner. which :s capable of firing natural gas at a maximum rate of 25.000 cubic feet per hour. The burners of the rotary drum dryers utilize natural gas as the onlv fuel. .

The product separation system for each sludge drying process train separates the product pellets from the process airstream by allowing the pellets to drop from the bottom of the separator while the airstream exits out the top. The pellets are conveyed to vibratory screens which sort the produced pellets/fines according to their size. The first materials which are separated from the product stream are the oversized pellets. These pellets are conveyed to a crusher and then to a recycle bin. The properly sized pellets are transported into the appropriate product storage silo or to the recycle bin depending upon processing needs. The undersized pellets and captured fines are also conveyed to the recycle bin.

After ieaving the top of the separator, Lne airstream continues on to the particulate removal system'. The material collected by the particulate removal system is conveyed to the sludge cake feed screw conveyor.

Each particulate removal system servicing Train Nos. 1, 3, and 4 consists of two 4XD 340-31 Fisher Klostermann dual cyclones, which provide an average overall particulate removal efficiency of approximately 85 percent. The air flow capacity for both sets of cyclones is approximately 28,500 actual cubic feet per minute (acfm) at 170"F with pressure drops between 14 and 17 inches of water gauge across each parallel assembly of dual cyclones. The induced draft fan for each rotary drum dryer is located downstream of each dual cyclone assembly, and provides a marnum air flow of 28,500 acfIn at 170*Fand 26 inches of static water (gauge) pressure.

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The particulate removai system servicing Train No. 2. consists of a VS 21 Size 42 Clean Gas Systems venturi scrubber'. which provides an average overall particulate removal efficiency of approximately 98.5 percent. The air flow capacity of this particulate removal system is approximately 32.000 acfm at 180 0 F with a pressure drop of 10 inches of water gauge across the venturi scrubber. The induced draft fan for the rotary drum dryer is located downstream of the venturi scrubber. and provides a maximum air flow of 32.000 acfnf'at 180*Fand 30 inches of static water igauge) pressure.

The existing ISP&D Facility also includes five product storage silos. Each of these silos is equipped with a Dynamic Air Modu - Kleen Model No. 250 bag filter pulse jet baghouse to control the fugitive particulate emissions which are created in the filling process. Each baghouse contains thirty-six polyester filter bags, which operate at pressure drops of 3 to 4 inches of water gauge while hancihng a maxunum air flow of 42U acim at 170 F. The cleaning mechamsm cleans six (6) bags in intervals of 3 to 30 seconds.

Marketable dried sludge pellets are loaded from each of the product storage silos into rail cars through a separate PEBCO Model No. DLS-22-4 loading system. Each loading system is equipped with a self-contained particulate control device, which holds thirty-two polyester filter tubes. Each particulate control device operates at pressure drops of 3 to 5 inches of water gauge while handling a maximum air flow of 907 acfm at 70*F. The cleaning cycle for each particulate control device consists of pulsed jets of air that are employed to clean filter banks of 4 to 6 elements every 5 seconds.

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Each sludge drying process train is equipped with a Huntington Energy Systems Model No. 3RT095 regenerative thermal oxidizer tRTO) to control gaseous emissions. Each RTO provides an average destruction efficiency of approximately 88.8 percent. The RTOs contain beds of inert ceramic material used as a conductive heat exchange medium to store and release the available energy contained in the RTO exhaust gases. Each RTO, having a design energy input rating of 7.700.000 Btu per hour, is equipped with tWo Maxon Ovenpacs burners. each capable of firing natural gas at a design rate of 3,850 cubic feet per hour. The burners of the RTOs utilize only natural gas as fuel. Each RTO is designed so as to provide a minimum residence time of 1.0 second at 1500*F for all gases introduced to the RTO. During stack testing of modified Train No. 2 without recirculation, it was determined that at the permitted temperature of 1500*Faits associated RTO no longer produced effective carbon monoxide control, and that a minimum temperature of 1600*F must be maintained any time that

r 1 aiaonL iS not on Train No. 2.

The induced draft fan for each RTO is an LAP Model No. 110-112 centrifugal fan which provides a maximum air flow of 34,000 acfm at 310*Fand 32 inches of static water (gauge) pressure.

The exhaust flue for each of the four sludge drying process trains is housed in a common concrete stack. Each steel flue is equipped with a Data Test Model No. 90AS opacity monitoring device. The opening of each 40 inch exit diameter flue is located 213 feet above ground level. The maximum flue gas exit velocity for Tram Nos. 1, 3, and 4 is approximately 72 feet per second at 350*F.,and the maximum flue gas exit velocity for Train No. 2 is 76 feet per second at 400"F.

1.2 Existing Operation and Emissions Requirements. Modified Train No. 2 Testing Resulta

Currently, each sludge drying process train is approved to process between 2300 and 3500 pounds of sludge per hour on a dry weight basis (see Interim Approval No. MBR-89-IND-115). "'ore River staging Area -Applcation No >luage Prvcessing Expansion and Modificaulon MBR-95-ND-056 P3age 7

During the performance and erussions testing of modified Train No. 2, the Interim Approval and subsequent agreements between the MWRA and the Department allowed this tram to process between 2300 and 5000 pounds of sludge per hour on a dry weight basis, at air recirculation rates of 0 and 50 percent (or The maximum achievable recirculation rate).

The performance and emissions testing was conducted to evaluate the venturi scrubber. the packed tower, and the air recirculation system installed on Train No. 2. The testing program was witnessed by Department personnel and it was conducted from August 29 to September 1. 1995.

Testing was performed at four operational conditions. The first three conditions tested consisted of high sludge throughput (4000 dry pounds per hour) with the recirculation loop (33 percent). low sludge throughput (2300 dry pounds per hour) with the recirculation loop (33 percent), and low sludge throughput without recirculation. The fourth operating condition tested involved the doping of the process airstream with SO., to simulate fuel oil combustion in the dryer burner and to illustrate its resulting SO, stack emissions. Testing results are summarized in Table 1, below. 0 0 S

Eat-s

1-:ja jl- ~ z :' 1 a.I

zHl z P I dA E iR

jejf Eq I Eq S C.. w S N - a It z z

- .5 is a - * I- 9- ore River Stawrng Area Applcation No. udge Processing Expansion and Modiflcation MBR-95-ND-056 age 10

These test results indicate that replacing the dual cyclones system with a venturi scrubber has the effect of reducing emissions of particulate matter, egardless of which conditions are being run. Results also showed emissions eductions -or all other pollutants, with the exception of ammonia and sulfur dioxide. These higher emission rates are believed to be a result of variability in :he sludge, :he content of which cannot be controlled. Due to this characteristic (If the sludge. and the belief that the stack testing methodblogies used for unmonia and sulfur dioxide during the compliance testing of 1994 may lack the :equisite precision. the MWRA has requested a revision of these two air pollutants emission limits established in the Interun Approval.

The MWRA's request includes increasing the ammonia limit from 1.76 pounds per hour (lbs/hr) to 2.90 lbs/hr for all sludge drying process tramis; and increasing the sulfur dioxide limit from 0.18 lbs/hr to 1.28 lbs/hr5 for Train Nos. . 3, and 4. Due to some degree of sulfur dioxide removal by the ventur scrubber packed tower system. the MWRA has requested that sulfur dioxide emissions from Train No. 2 be limited to 0.52 lbs/hr5. These limits were based upon the mean of the data points plus two standard deviations.

Therefore, the sludge processing conditions summarized in Table 2, below, will govern the operation of the existing ISP&D Facility until completion of the proposed expansion and modification and the Final Sludge Processing and Disposal Facility is ready for continuous operation.

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TABLE 2 - OPERATING CONDITIONS FOR THE EXISTING ISP&D FACILITY CONDIONS

TRAIN NUMBER I NNIMJM FEED MAXIMUM FEED TOTAL HOURS RATE RATE OF OPERATION

1i2300 3500 8760

2 2300 and 0% or 4000 and 0%' or 7640 higher recirculation higher recirculation (at least 33%) (at least 33%)

3 :300 3500 7640

4 2300 3500 8760

Cg ru rusreena Mguri W sntge per four of ooeraton. on a cry ViM io.

-he R'C on Trwn No. 2 em.be mainrenus a minimum lemmrsure ad 1600F wnnwgeais ga0 meruwiain a useSt

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Consequently, the existing ISP&D Facility's potential air pollutant emissions from sludge dryers, for a 365-day rolling period, are estimated to be: 82.0 tons per year (tpy) of particulate matter (PM); 210.9 tpy of nitrogen oxides (NOx); 95.1 tpy of carbon monoxide (CO); 44.3 tpy of volatile organic compounds (VOC); 18.0 tpy of sulfur dioxide (SO,); 47.6 tpy of ammonia (NH,); and 1.0 tpy of hydrogen sulfide (1.5). These annual emissions were calculated based upon the operating conditions indicated in Table 2, above.'

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2. SLUDGE PROCESSING EXPANSION AND MODIFICATION

The £MRA has decided that the sludge drying and pelletization process used in :he ISP&D Facilty would be the selected technology for the long term disposal of wastewater sludge resulting from the operation of the Deer Island Wastewater Treatment Plant. Therefore, an expansion of the existing sludge processing facility is required in order to accommodate th0 increased volume of cjudge produced at the Deer Island new wastewater treatment facilities.

The sludge processing expansion and modification includes: (1) expansion of sludge processing capacity, and (2) energy and air pollution control improvements. These proposed plant modifications, as well as the future operating conditions and resulting emissions, are described below.

2.1 Expansion of Sludge Processing Capacity

Expansion of sludge processing capacity will be accomplished by increasing the capacity of the existing four sludge drying process trains and adding two new sludge drying process trains. It is expected that improved dewatering equipment and new product classifiers will allow for additional sludge processing in each existing sludge drying process train. With the improved dewatering and screens, the maximum capacity of each train is expected to increase to at least 4500 pounds of sludge per hour, on a dry weight basis. The two new sludge processing trains are then anticipated to increase the capacity of the entire facility by another 50 percent after the capacity of each existing sludge processing train is increased.

Expansion of the sludge processing capacity will also require additional product pellet storage, thus. four new product storage silos will be constructed. Fore River Staging Area Appication No Sluage Processing Expansion ana Modification MBR-95-ND-056 Page 13

Each of the two new sludge drying process trains will include a Baker/Rullman Model No. 105-32, or equivalent, rotary drum dryer. Each rotary drum dryer. having a design energy input rating of 25,000,000 Btu per hour, will be equipped with a Peabody Engineering, or equivaient, "low NOx" burner, which will be capable of firing natural gas at a design rate of 25,000 cubic feet per hour. The burners of each new rotary drum dryer will utilize natural gas as the only fuel.

Process gas from the two new sludge drying process trains will be directed to the existing RTOs. The exhaust flues of the four existing RTOs will serve the six sludge drying process trains and are currently housed in a common concrete stack. As described before, each steel flue is equipped with a 90AS Data Test opacity monitoring device, and the opening of each 40 inch exit diameter flue is located 213 feet above ground level. The maximum flue gas exit velocity per sludge drying process train will be approximately 76 feet per second at 400*F.

2.2 Energy and Air Pollution Control Improvements

During Phase 3 of the expansion and modification of its existing sludge processing and disposal facility, the MWRA proposes to install an air recirculation loop in each dryer to increase the efficiency and performance of the drying system and to reduce air emissions. With condensation of moisture in the recirculated air stream, maximum air recirculation rates of approximately 75 percent are expected.

Energy is conserved by recirculating a fraction of the hot process gas back to the rotary drum dryer furnace. Less energy is required to heat the process gas to the temperatures required for effective sludge drying and less fuel is therefore necessary for combustion in the dryer furnaces. In addition, the fuel consumption in the RTOs will be reduced proportionately to the reduced air flow at the inlet of the RTOs since the point in the process at which the air is recirculated will be upstream of the RTOs .ore River Staging Area Application No. Sludge Processing Expansion and Modification MBR-95-IND-056 Page 14

Moreover. a number of improvements to the existing air pollution control systems are also anticipated during Phases 2 and 3. These improvements are:

I Instaiation of the mentioned air recirculation loop, which is expected to reduce ermssions swce the recirculation point will be located downstream of the particuiate andi ammonia control device.

2) Repiacement of the existing dual cyclones with venturi scrubbers kto control particulate emissions), followed by packed towers (to control ammonia emissions). The outlet particulate concentration is expected to be 0.009 grains per dry standard cubic foot or less. The outlet ammonia concentration is expected to be 20 parts per milion by volume or less.

W Addition :f a new fugitive dust control system to both the new and existing silos. Each silo complex will be equipped with two pulse jet baghouses: one baghouse for the pellet loading ventilation system, and one baghouse for the pellet unloading ventilation system. Each loading and unloading baghouse will be a STJ- 66 W. W. Sy Manufacturing Company, or equivalent, and will contain thirty-six polyester filter bags. Each loading baghouse will operate at pressure drops of 3 to 4 inches of water gauge while handling a maximum air flow of 1750 acfm for the existing silos and 2000 acfm for the new silos. Each unloading baghouse will operate at pressure drops of 3 to 4 inches of water gauge while handling a maximum air flow of 1600 acfm. The maximum air to cloth ratio of each baghouse will be 4 to 1, and the cleaning mechanism for each baghouse will clean six bags in intervals of 3 to 30 seconds. The overall particulate outlet concentration of each baghouse is expected to be less than or equal to 0.005 grains per actual cubic foot.

(4) Addition of a new ventilation system for the dryer room, capable of handling a maximum of 150,000 acfm (from six 25,000 acfm capacity fans; one above each drying train). This system will only operate when dryer room temperatures exceed a specified temperature (approximately 80*F) and individual fans will likely only operate if the drying train to which they correspond is operating. All six fans will exhaust through a common plenum and into two spare flues in the existing 213 foot stack. -ore Rner Stagng Area Appbcacon No Sluage PF-tcessing ExDansion ana Mociication MIBR-95-IND-056 Page -5

5) Addition of a new process fugitive dust ventilation and control system for each sludge drving process train. This system will consist of one exhaust fan for each drying train. which wiii draw fugitive dust-laden air from six dried product lhandling potLs for each drying train through one baghouse for each drying train. From here. the gas will exhaust through a common plenum for all six trains and into the two spare process flues in the existing 213 foot stpck. The process fugitive dust system will consist of six identical baghouses with pulse jet cleaning, polyester ncn-woven filter media. and a collection area of 400 square feet. Each of :he six systems has a flow capacity of 1500 acfm for a total system capacity of 9000 acim at 80*F.

1.6) Addition of a new RTO air plenum to be constructed along the entire wall behind the RTOs. Process gas from each the six dryer trains will be ducted to this single air rlenum and at the outlet of the plenum, dampers will control the flow of process gas to any required combination of RTOs. Gaseous emissions from the six dryer trains will be controlled by the four existing RTOs. The MWRA expects that the existing RTOs will be capable of effectively controlling gaseous emissions from all dryer trains since at any recirculation rate. only a fraction of the ful process air flow will be processed in the RTOs. In addition, it is expected that the RTOs will destroy between 67 and 78 percent of the carbon monoxide emissions emanating from the dryers. rare River Staging Area Application No. Sludge Processing Expansion and Modification MBR-95-IND-056 Page 16

2.3 Final Operating Conditions

As proposed in the submItted application. the Final Sludge Processing and Disposal Facility will operate as indicated in Table 3, below.

TABLE 3 - FINAL OPERATING CONDITIONS PER SLUDGF> PROCESING TR4

SLUDGE FEED RATE PROCESS AIR HOURS OF OPERATION tdry pounds per hour) RECIRCULATION RATE (per year)

2300 4500 33% 75% MiMum Maximum Minimum Maximum 8760

The submitted information further indicates that whenever a sludge processmn train operates at a recirculation rate above approximately 40 percent, the packed tower needs to be operated in the condensing mode to remove the moisture from the airstream. This wil involve the use of a heat exchanger to remove heat from the packed tower water. This will be accomplished by a combination of rejection of heat to the incoming sludge and to the air via rooftop heat exchangers. Therefore, for example, at 75 percent air recirculation, condensing wiWl be required, whereas at 33 percent condensing will not be required.

Lastly, the submitted information also indicates that, on an annual basis, the total maximum facility sludge processing rate will be 81,760 dry tons per year. ore Ru.er Staging Area -ppucation No sludge Processing Expansion and Moaification MBR-95-IND-056 Page -1

2.4 Uncontrolled and Controlled Air Emissions

Operation of the Final Sludge Processing and Disposal Facility will result in air emissions of particulate matter

Uncontrolled air emissions are defined as emissions from the sludge dryers alone. and do not include emissions from control equipment (such as emissions of combustion pollutants from the RTOs). The uncontrolled air emissions presented in the application were obtained during the emissions testing of modified Train No. 2. With the once-through system, uncontrolled emissions represented those emissions sampled at the control device inlets. With the recirculation loop, this is not a the case. Although the recirculation loop has no detrimental effect upon mass emissions. concentrations of air pollutants which are not controlled well within the loop (i.e.. by the venturi scrubber/packed tower) will increase significantly at the inlet as a result of these pollutants being reintroduced to the airstream -. the dryer inlet. However. this increase is compensated for by a decrease in the volumetric flow rate out the stack, to yield either identical or lower mass emissions relative to the once-through system.

The controlled air emissions presented in the application were obtained during emissions testing of modified Train No. 2. Modifications to this sludge drying process train included several of the air pollution control improvements described in Section 2.2. above. Worst-case uncontrolled and controlled potential air emissions are summarized in Table 4, below.

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TABLE 4 - UNCONTROLLED AND CONTROLLED AIR EMISSIONS FROM THE FINAL SLUDGE PROCESSING AND DISPOSAL FACILITY (PER DRYING TRAIN)

POLLUTANT WNCONTROLLE.D EMISSIONS CONTROLLED EMISSIONS kpounds per hourj (pounds per hour

Pamicumate Matter Smader than 10 67 i1 % marneter Dcrer-s

Oxioea oi Nitrogen '2

Ammowa 16.0 0.47

Carbon Monoxide 16.1 35

Sulfur Diaxide 1 3 0.52

Totai Reducea Sulfur 022 J 09

Volatde Orgamc Compounac 19.0 0 94

Bervwilium 00016 I.SE-05

S .s18 2,1E-03

Total Chronuum 024 2.8E-03

Hexavalent Chromium 0.0065 7,6E-05

Nickel 0.063 7.2E-04

Lead 0.091 1.1E-03

Vanadum 0.18 2.1E-03

Cadmium" 5.6E.04 5.6E-04

Selenim 6.2E-04 6.2E-04

Mercury 0 9.9E-04 9.9E-04

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2.5 Future Potential Emissions

Future potential emissions have been estimated based on the operation of the following emission units:

'1) Six siudge drying process trains, which include four-existing (modified) trains and two new ones. Potential future emissions of PM.., NOx, CO, SO- VOC. TRS (as hydrogen sulfide), NH, and metals are estimated based on the controlled emission rates as indicated in Table 4, above, assuming each train will operate 8760 hours per year, at 100 percent capacity.

12) Six new space heaters with a combined maximum input capacity of 1.600.000 Btu per hour. These space heaters will utilize natural gas as the only fuel, Potential future emissions of PM, NOx. CO. SO, and VOC are estimated based on EPA's' emission factors for natural gas combustion and the rated heat input of the units, assuming each unit will operate 8760 hours per year. at 100 percent capacity.

3) One 225 kilowatt emergency generator. Potential future emissions of PM,,, NOx. CO, SO2 and VOC are estimated based on EPA's emission factors for diesel-fired reciprocating engines, assuming a restricted operation of 300 hours per year, at the maximum fuel rate of 18 gallons per hour.

(4) Four existing sludge/filtrate tanks, each having a capacity of 1,000,000 gallons. Future potential emissions of VOC are based on the actual emission estimate for year 1994, scaled to reflect the proposed maximum sludge throughput for the facility.

(5) Nine pellet storage silos. Each to be equipped with a fugitive dust control system. Future potential emissions of PM., from the handling of the product pellets are based on a controlled emissin rate of 0.005 grains per actual cubic foot from each existing silo complex baghouse, assuming 100 percent annual capacity.

9 EPA * wu~~lPmowan Apnay. Fore River Staging Area Appucation No. Sludge Processing Expansion and Modification MB R-95- rND-056 Page 20

(6) Two 10.000 gallon dust suppressant storage tanks (each bank of silos will be equipped with a storage tank for dust suppressant). Future potential VOC emissions are based on EPA's emission factors for the storage of organic liquids and an estimated maximum annual throughput of surfactant at an application rate of 3 gallons per ton of product pellets.

7) A new room air ventilation system, and a new process fugitive dust control system for process equipment dry solids handling associated with each existmg and new sludge drver process train. Future potential emissions of PM.., VOC, TRS (as hydrogen sulfide), NH,, and metals are based on data and emission factors from previous studies, and based on a baghouse outlet concentration of 0.005 grains per actual cubic foot.

Therefore. the future potential emissions" from the Final Sludge Processing and Disposai I acility, for a 365-day roiling period, are estimated to be: 34.2 tpy of PM.; 54.7 tpy of NOx; 94.7 TPY of CO; 49.3 tpy of volatile organic compounds NOC); 13.8 tpy of SO; 12.9 tpy of ammonia (NH,); and 2.5 tpy of hydrogen sulfide (HS).

10 %W .n. smM. ma.. *OF% me Sag. WO. a y . a sa oe.r Sge .. etn .ru mem..n qaMs.e.s tm S 15. Iay o S6.r Isy G.O N, 732 IPy.t c0. 34.2 loy . V=, I S tp or . La Wy o.r W 3 ey 4 P2L The nagg .Pc..n %.t .11 mm.., a "Mo MW.. 0. . e ., V y.n.We mcgee e WApt Wn u Gss a ma W a N w Mm Irm a en WW 25UM WM Pore River Staging Ara Apphcation No. Sludge Processmg Expansion and Modification MBR-95-IND-056 Page 2:

3. CONDITIONAL APPROVAL AND PROVISOS

The Department has determined that your application is administratively complete and that the described process and equipment are in conformance with current air pollution control engineering practices, and hereby grants CONDMONAL APPROVAL for the proposal. as submitteli, with the following provisos:

GENERAL REQUIREMENTS

Tha:Lfhe :JWEV~ E :namr.amerinucus compliance at alIuez wit Section 3 of this CONDMONAL APPROVAL Sections 1 and 2 of this Approval letter are descriptive and constitute enforceable requirements only to the extent incorporated into a proviso in Section 3.

2. That if conflicting information is found between the submitted information regarding the Final Sludge Processing and Disposal Facility and this CONDMONAL APPROVAL, then the requirements of this CONDMONAL APPROVAL shall take precedence over the documentation in the application materials.

3. That if the MWRA anticipates substantial changes to the information contained in this CONDMONAL APPROVAL including, but not limited to, the usage of a low sulfur fuel oil as a back-up fuel, then the MWRA shall submit appropriate documentation which will demonstrate that said changes will not adversely impact the environment and will not violate the requirements of 310 CMR 7.00 - Air Pollution Control Regulations. Written Department concurrence must be obtained prior to implementation of said changes rore River Staging Area Application No. Sludge Processing Expansion and Modification MBR-95-IND-056 Page 22

4. That the description and requirements contained in this CONDITIONAL APPROVAL letter regarding the existing ISP&D Facility shall supersede the description and requirements contained in the INTERIM APPROVAL letter issued to the MWRA by the Department on October 28, 1994.

5. That a copy of this CONDITIONAL APPROVAL letter and any subsequent revisions shall be maintained in the facility's controlloom.

6. That the Department may suspend, modify, or revoke this Approval if at any time the MWRA violates any applicable Regulation(s) or conditions of this Approval letter.

That should the construction, substantial reconstruction. or alteration at the Final Sludge Processing and Disposal Facility violate any provisions of o10 CMR a MWILA%BV.R -hall be subject to enorcem. pursua2: to Massachusetts General Laws, Chapter 111, sections 142A and B and Chapter 21A. section 16.

S. That the MWRA shall specify the emissions resulting from the operation of the equipment described in this letter on the Emission Statement Forms submitted to the Department as required by Regulation 310 CMR 7.12.

9. That the MWRA shall comply with all applicable federal requirements pursuant to 40 CFR Part 61, Subpart E - National Emission Standard for Mercury.

10. That should any nuisance condition(s) such as smoke, dust, odor, or noise occur as a result of the operation of equipment and processes described in this Approval letter, then appropriate steps (including shutdown of affected dryer trains in the event of major system upsets or major malfunctions of the air pollution control equipment) shall be taken by the MWRA to abate said nuisance condition(s). Fore River Staging Area Applicauon No. Sludge Processing Expansion and Modification MBR-95-IND-056 Page 23

11. That the MWRA shall immediately implement all necessary and appropriate measures to alleviate dust, noise, and odor nuisance conditions which may occur during and after modifications to the existing ISP&D Facility. Such measures must comply with Regulations 310 CMR 7.01, 7.09. and 7.10.

12. That the MWRA shall comply with Regulation 310 CMR 7.15 to properly remove any asbestos that may be disturbed by the modifications to the exsting ISP&D Facility.

13. That the MWRA shall allow Department personnel, health and environmental officials, and EPA personnel access to the plant site, buildings and all pertinent records during normal business hours for the purpose of making inspections, surveys, collecting samples, obtaining data, and reviewing all pertinent records.

14. That the MWRA shall comply with all the requirements stated in this CONDITIONAL APPROVAL letter regarding the operation of the existing ISP&D Facility until completion of the proposed expansion and modification, and the Final Sludge Processing and Disposal Facility is ready for continuous operation.

NOTIFICATION AND SUBMI'"ALREQUIRKMENTS

15. That the MWRA shall notify this Office. in writing, attention Permit Chief, Bureau of Waste Prevention, when the modifications to the existing ISP&D Facility are complete, and the Final Sludge and Disposal Facility is ready for operation.

16. That the MWRA shall notify the Department of its plans or schedule(s) to restart operation of each sludge drying process trains pursuant to 40 CFR 61.09 Tare River Sagmg Area Application No. Sludge Processing Expansion and Modification MBR-95-IND-056 Page 24

17. That the MWRA shall supply this Office. attention Permitting Chief, Bureau of Waste Prevention, with the final plans and specifications for the new equipment to be installed at the facility.

18. That the MWRA shall immediately notify this Office by fax at (617) 932- 7615 and subsequently in writing, of any major system upsets or major maifunctions of the existing air pollution control eqtripment or the existing opacity momtoring equipment (see Proviso Nos. 21 and 36). The MWRA shal submit the written confirmation to this Office, attention Compliance and Enforcement Chief, Bureau of Waste Prevention, describing the malfunction, the possible reason(s) for it, and future actions to be undertaken to prevent this malfunction from recurring. The written confirmation shall be received by this Office no later than 7 days from the onset of the malfunction.

19. That the MWRA shall immediately notify this Office by fax at (617) 932- 7615 and subsequently in writing, attention Compliance and Enforcement Chief. Bureau of Waste Prevention, of any malfunctions, operator errors, and unpermitted releases that caused or could have caused harm to public health. safety, or welfare, and/or to the environment while installing, testing, and operating the new equipment.

P1H0CESS/EQ&UIPM UlqOERATON RFURMNSFOR THE EXgfISMQ INTRIM= SLUDGE PRESSING AND DISPOSAL FACILIT

20. That the MWRA shall operate the existing ISP&D Facility consistent with the pertinent parameters and conditions as established in this CONDITIONAL APPROVAL letter.

21. That in the event of a major malfunction in the air pollution control equipment, the MWRA shall cease operation of the affected sludge drying process train(s) until the problem has been corrected. Fore River Staging Area Application No. Sludge Processing Expansion and Modificaion MBR-95-LYD-056 Page 25

22. That during normal operation. the minimum siudge feed rate to each of the existing four sludge drying process trains shall not be lower than 2,300 dry pounds per hour.

23. That the sludge feed rate of Train Nos. 1, 3, and 4 shall not exceed 3,500 dry pounds per hour.

24. That the sludge feed rate of Train No. 2 shall not exceed 4,000 dry pounds per hour.

25. That the operation of Train Nos. 2 and 3 shall not exceed a maximum of 7,640 hours per year, per train. The MWRA shall document the elapsed/run time of these trains on a meter and strip chart recorder.

2 That the MWRA shall operate the existing venturi scrubber servicing Train No. 2 in accordance with manufacturer's specifications so as to ensure a maximum outlet particulate concentration of 0.009 grains per dry standard cubic foot.

27. That the packing material in the packed tower shall be filled as recommended by the manufacturer so as to ensure optimum control operation of this equipment.

28. That the MWRA shall operate the existing RTOe in accordance with manufacturer's specifications so as to ensure an average VOC destruction efficiency of approximately 88.8 percent.

29. That the MWRA shall maintain the operating temperature of the RTO servicing Train No. 2 at a minimum of 1600 *F. whenever the exhaust gas recirculation is kept at 0 percent. Fore kiver Staging Area Application No. Sludge Processing Expansion and Modification MBR-95-NI-056 Page 26

30. That the air emissions from each sludge drying process train shall not exceed the limitations summarized in Table 5, below:

TABLE 5 - AIR EMISSION LIMITATIONS PER SLUDGE DRYING PROCESS 'C TRAIN

POLLUTANT AIR EMISSION LIMITATION (pounds per hour, per train)

PM 5.00 NOx 12.86 CO 5.80

"OC 2.70

SO2 1.28 (Train Nos. 1, 3, and 4) 0.52 (Train No. 2)

2.90

HS 0.064

t. a4 Fore River Staging Area Application No. Sludge Processing Expansion and Modification .MBR-95-IND-056 Page 27

31. That the annual air emissions from the existing ISP&D Facility shall not exceed the limitations summarized in Table 6, below. These limitations are based on a 365-day roling period.

TABLE 6 - ANNUAL AIR EMTB8TON LMITATIONS FROM THE EITING INTERIM SLUDGE PROCESSING AND DISPOSAL FACILITY

POLLUTANT ANNUAL AIR EMISSION LIMITATION (tn per 865 day roiling period)

PM 82.0 NOx 210.9 CO 95.1 VOC 44.3

SO2 18.0

NH, 47.6

H 25 1.0

32. That the mercury air emissions resulting from the operation of the existing ISP&D Facility shall not exceed 3200 grams per 24-hour period, as required pursuant to 40 CFR Part 61.52.

33. That the MWRA shall conduct sludge sampling and analysis for mercury a specified in 40 CFR Part 61.54, if and when the Department deems it necessary. The sludge shall be sampled according to Method 105 - Determination of Mercury in Watewater Treatment Plant Sewaue Sludes.

-~ 'a.- Fore River Stagmg Area Appilcauon No. Sludge Processing Expansion and Modification MBR-95-IND-056 Page 28

34. That the visible emissions from each sludge drying process train shall not exceed fifteen (15) percent opacity.

PROCESS/EQUIPMENT OPERATION REQUIREMEN'S FOR THE FINAL SLUDGE PROCESSING AND DISPOSAL FACILITY

35. That the MWRA shall operate the Final Sludge Processing and Disposal Facility consistent with the pertinent parameters and conditions a established in this CONDITIONAL APPROVAL letter.

36. That in the event of a major malfunction in the air pollution control equipment. the MWRA shall cease operation of the affected sludge drying process train(s) until the problem has been corrected.

37. That during normal operation, the minimum sludge feed rate to each of the six sludge drying process trains shall not be lower than 2,300 dry pounds per hour.

38. That the sludge feed rate of each sludge process train shall not exceed 4,500 dry pounds per hour.

39. That the total maximum sludge processing rate for the entire facility shall not exceed 81,760 dry tons per year.

40. That the particulate emission rate and outlet concentration from each venturi scrubber shall be determined during the required compliance testing. It is expected that a maximum particulate outlet concentration of 0.009 grains per dry standard cubic foot will be attained by each venturi scrubber.

41. That the packing material in each packed tower shall be filled as recommended by the manufacturer so as to ensure optimum control operation of this equipment. I I Fore River Staging Area Application No. Sludge Processing Expansion and Modification MBR-95-IND-056 I Page 29 I

42. That the ammonia emission rate and outlet concentration from each packed tower shall be determined during the required compliance testing. It is expected that a maximum outlet ammonia concentration of 20 parts per million by volume will be attained by each packed tower.

43. That the normal pH set point range for each packed tower shall be established during the required compliance testing:-

44. That the air emissions from each sludge drying process train shall not exceed the limitations summarized in Table 7, below: I W TABLE 7 - AIR EMISSION LIMITATIONS PER SLUDGE DRYING PROCESS TRAIN

POLLUTANT AIR EMISSION LIMITATION (pounds per hour, per train)

PM,0 1.10 NOr 1.6 CO 3.6 VOC 0.94

S0, 0.52

NH3 0.47

HS 0.09

1,*

1-. 1 ore River Staging Area Application No. Sludge Processing Expansion and Modification MBR-95-IND-056 Page 30

45. That the annual air emissions from the Final Sludge Processing and Disposal Facility shall not exceed the limitations summarized in Table 8, below. These limitations are based on a 365-day rolling period.

TABLE 8 - ANNUAL AIR EMISSION LIMITATIONS FROM THE FINAL SLUDGE PROCESSING AND DISPOSAL FACILITY

POLLUTANT ANNUAL AIR EMISSION LIMITATION (tons per 365 day rolling period)

PM. 0 34.2

NOx 54 7

CO 94.7

VOC 49.3

S0 13.8

NH, 12.9

HS 2.5

46. That the mercury air emissions resulting from the operation of the Final Sludge Processing and Disposal Facility shall not exceed 3200 grams per 24- hour period, as required pursuant to 40 CFR Part 61.52.

47. That the visible emissions from each sludge drying process train shall not exceed fifteen (15) percent opacity.

48. That the operation of the 225 kilowatt emergency generator shall not exceed 300 hours per year. rore River Laging Area Applcation No Sludge Processing Expansion and Modificaton MBR-95-IND-056 Page 31

49. That the MWRA shall operate the new fugitive dust control systems in accordance with manufacturer's specifications so as to ensure a maximum particulate outlet concentration of 0.005 grains per actual cubic foot.

50. That the MWRA shall demonstrate the ability of the new fugitive dust control systems to maintain particulate emission rates at or below the stated level, when and if the Department deems such as necessary.

S FOR THE FINAL SLUDGE PROCEESING AND DISPOSAL FACILIrY

51. That the MWRA shall conduct emissions compliance testing on all six sludge drying process trains, within 90 days of initial start-up of the new and modified trains. This compliance testing shall be performed to demonstrate compliance with the requirements of this CONDITIONAL APPROVAL letter regarding the operation of the Final Sludge Processing and Disposal Facility. Final air emissions limitations and operating restrictions shall be contained in the FINAL APPROVAL for the subject facility.

52. That each of the six sludge drying process trains shall be tested for particulate matter (at the outlet of each packed tower), oxides of nitrogen (as nitrogen dioxide), ammonia (at the outlet of each packed tower), carbon monoxide, sulfur dioxide, total reduced sulfur (as hydrogen sulfide), volatile organic compounds, and metals (beryllium, copper, total chromium, hexavalent chromium, nickel, lead, vanadium, cadmium, selenium, and mercury), and any other parameter(s) determined by the Department during the test protocol reviewing period (see Proviso No. 53). Fore River Staging Area Appucation No. Sludge Processing Expansion and Modification MBR-95-IND-056 Page 32

53. That the MWRA shall submit to this Office. attention Permit Chief. Bureau of Waste Prevention, a test protocol for the required air enissions testing for Department review. This test protocol shall be submitted at least 60 days prior to commencement of said air emissions testing. The protocol shall describe sampling point locations, sampling equipment, sampling and analytical procedures, and the operating conditions for the required testing.

54. That the MWRA shall conduct said emissions compliance testing in accordance with test methods and procedures required pursuant to 40 CFR Part 60, Appendix A, and Part 61, Subpart E. This emissions compliance testing must be witnessed by Department personnel. Scheduling for this testing shall be coordinated with Department personnel and shall be confirmed no later than 60 days prior to the target test date(s).

55. That the MWRA shall conduct sludge sampling and analysis for mercury as specified in 40 CFR Part 61.54, if and when the Department deems it necessary. The sludge shall be sampled according to Method 105 - Determination of Mercury in Wastewater Treatment Plant Sewage Sludges.

56. That the MWRA shall submit the emissions compliance testing results report to this Office, attention Permit Chief, Bureau of Waste Prevention, within 60 days of completion of this testing for Department review.

57. That in addition to the initial emissions compliance testing, the MWRA shall periodically perform emissions compliance testing for any two of the six sludge drying process trains, selected by DEP, to demonstrate compliance with the requirements stated in the FINAL APPROVAL letter, when issued. The first of these additional tests shall be completed within the fifth year after the issuance date of the FINAL APPROVAL letter. Subsequent tests shall be performed once every five years. The Department may alter the time between testing by submitting a written notification to the MWRA to that effect. rore River Staging Area Apphcanlon No Sludge Processang Expansion and Modification MBR-95-IND-056 Page 33

58. That during the emissions compliance testing required in Proviso No. 57, above, both sludge drying process trains shall be tested for particulate matter (at the outlet of each packed tower), oxides of nitrogen (as nitrogen dioxide), carbon monoxide, ammonia (at the outlet of each packed tower), and volatile organic compounds. One of these two sludge drying process trains shall be tested at its RTO's outlet for sulfur dioxide, total reduced sulfur tas hydrogen sulfide), and metals (beryllium, cqpper, total chromium, hexavalent chromium, nickel, lead, vanadium, selenium, and mercury).

59. That within 90 days of initial start-up of the new and modified trains, the MWRA shall conduct a noise survey via a qualified consultant to demonstrate that noise impacts from the operation of the Final Sludge Processing and Disposal Facility are within allowable levels. This noise survey must be witnessed by Department personnel. The Department shall be notifed of the scheduled noise survey at least seven (7) days in advance.

STANDARD OPERATING AND MAINTENANCE PROCEDURES REQUIREMENTS FOR THE E2ISTING INTERIM SLUDGE PROCESSING AND DISPOSAL FACILT

60. That the MWRA shall maintain on-site, at all times, an up-to-date copy of the existing ISP&D Facility's Standard Operating and Maintenance Procedures (SOMP).

61. That the MWRA shall conduct daily equipment checks, including, but not limited to, the air pollution control equipment to prevent and/or minimize major system upsets and malfunctions.

62. That any revision(s) made to the existing ISP&D Facility's SOMP must be submitted to this Office, attention Permit Chief, Bureau of Waste Prevention, withm 15 days of said revision(s). Fore River Staging Area Application No. Sludge Processing Expansion and Modification MBR-95-IND-056 Page 34

STANDARD OPERATING AND MAINTENANCE PROCEDURES REQUIREMENTS FOR THE FINAL SLUDGE PROCESSING AND DISPOSAL FACILITY

63. That the MWRA shall conduct daily equipment checks, including, but not limited to, the air pollution control equipment to priVent and/or minimize maior system upsets and malfunctions.

64. That the MWRA shall submit the Final SOMP for the Final Sludge Processing and Disposal Facility to this Office, attention Permit Chief; Bureau of Waste Prevention, within 120 days of completion of the emissiona compiance testing required in Proviso No. 51, above.

65. That the Final SOMP must contain standard operating and maintenance procedures for the Final Sludge Processing and Disposal Facility, including the rotary drum dryers, the dewatering system, the venturi scrubbers, the packed towers, the regenerative thermal oxidizers, the silos fugitive dust control equipment, the process fugitive dust control system, and the opacity monitoring equipment. The MWRA shall also provide for abatement action in this Final SOMP, which shall be initiated immediately should the installed equipment cause or contribute to a condition of air pollution.

66. That any subsequent revision(s) made to the Final SOMP must be submitted to this Office, attention Permit Chief, Bureau of Waste Prevention, within 15 days of said revision(s).

67. That the MWRA shall maintain on-site, at all times, an up-to-date copy of the required SOMP. Fore River Staging Area Apphcation No. Sludge Processing Expansion and Modification MBR-95-IND-056 Page 35

RECORDKEEPINQ AND REPORTING REQUIlEMENTS FOR THE EXISTING INTERIM SLUDGE PROCESSING AND DISPOSAL FACILITY

68. That the MWRA shall maintain adequate daily records for the existing ISP&D Facility. These records shall contain, at a minimum, the following information:

a) Hours of operation of each sludge drying process train; and

b) Amount of sludge processed in each sludge drying process train, in pounds of dry sludge per hour; and

c) Daily cumulative emissions of PM, NOx, CO, VOC, SO,, NH,, and 12S; and

d) Any other data necessary to demonstrate compliance with the emission limits set forth in Proviso Nos. 30, 31, and 34.

These records shall be maintained at the facility for three years following the date of the reports (see Proviso No. 71), and shall be made available to Department personnel upon request.

69. That the MWRA shall keep adequate on-site maintenance log books for the existing ISP&D Facility. These log books shall contain, at a minimum, the following information:

a) All relevant maintenance performed on the rotary drum dryers, the belt filter presses, the dual cyclones, the venturi scrubber, the packed tower, the regenerative thermal- oxidizers, and the opacity monitoring equipment; and

b) All equipment malfunctions (time, date, downtime, when restored, etc.); and

c) All calibrations which were performed on the opacity monitors. Tore River Staging Area Application No. Sludge Proemng Expansion and Modification MBR-95-IND-056 Page 36

These records shall be maintained at the facility for three years and shall be made available to Department personnel upon request.

TO. That the MWRA shall maintain an Environmental Logbook which shall record actions relative to environmental issues (accidental or emergency releases, etc.) and overall emission changes associated with the existing ISP&D Facility. The MWRA shall record information such as the results of federal, state. or local environmental inspections; maintenance or corrective actions which affect air emissions related to the operation of the pollution control equipment; and measures taken to lower emissions from the subject equipment to the environment (air, water, etc.). This Logbook shall be made available to Department personnel upon request.

71. That the MWRA shall submit quarterly compliance reports to this Office, attention Compliance and Enforcement Chief. Bureau of Waste Prevention. These quarterly reports shall be submitted within 21 days of the end of each quarter, and shall contain the following information, based on a 365- day rolling period:

a) Hours of operation of each sludge process train; and

b) Average amount of sludge processed in pounds of dry sludge per hour; and

c) Facility-wide emissions of PM, NOx, CO, VOC, SO,, NH,, and HS, in tons per 365 day rolling period.

-4 Fore River Staging Area Application No. Sludge Processing Expansion and Modification MBR-95-IND-056 Page 37

RECORDKEEPING AND REPORTING REQUIREMENTS FOR THE FINAL SLUDGE PROCES&NG AND DISPOSAL FACILTY

72. That the MWRA shall maintain adequate daily records for the Final Sludge Processing and Disposal Facility. These records shall contain, at a minimum, the following information:

a) Hours of operation of each sludge drying process train; and

b) Amount of sludge processed in each sludge drying process train, in pounds of dry sludge per hour; and

c) Daily cumulative emissions of PM,, NOx, CO, VOC, SO,, NH,, and HS; and

d) Any other data necessary to demonstrate compliance with the emission limits set forth in Proviso Nos. 44, 45, and 47.

These records shall be maintained at the facility for three years following the date of the reports (see Proviso No. 75), and shall be made available to Department personnel upon request.

73. That the MWRA shall keep adequate on-site maintenance log books for the Final Sludge Processing and Disposal Facility. These log books shall contain, at a minimum, the following information:

a) All relevant maintenance performed on the rotary drum dryers, the dewatering systems, the venturi scrubbers, the packed towers, the regenerative thermal oxidizers, and the opacity monitoring equipment; and

b) All equipment malfunctions (time, date, downtime, when restored, etc.); and c) All calibrations which were performed on the opacity monitors. Fore River Staging Area Application No. Sludge Processing Expansion and Modification MBR-95-IND-056 Page 38

These records shall be maintained at the facility for three years and shall be made available to Department personnel upon request.

74. That the MWRA shall maintain an Environmental Logbook which shall record actions relative to environmental issues (accidental or emergency releases, etc.) and overall emission changes associated with the Final Sludge Processing and Disposal Facility. The MWRA shall record information such as the results of federal, state. or local environmental inspections; maintenance or corrective actions which affect air emissions related to the operation of the pollution control equipment; and measures taken to lower emissions from the subject equipment to the environment (air, water, etc.). This Logbook shall be made available to Department personnel upon request.

75. That the MWRA shal submit quarterly compliance reports to this Office, attention Compliance and Enforcement Chief, Bureau of Waste Prevention. These quarterly reports shall be submitted within 21 days of the end of each quarter, and shall contain the following information, based on a 365- day rolling period:

a) Hours of operation of each sludge process train; and

b) Average amount of sludge processed in pounds of dry sludge per hour; and

c) Facility-wide emissions of PM,, NOx, CO, VOC, SO, NH3, and 1 8, in tons per 365 day rolling period.

Failure to comply with any of the above stated provisions will constitute a violation of the "Regulations", and can result in the revocation of the approval granted herein. This approval may also be revoked by the Department if the construction work is not begun within two years from the date of issuance of this approval, or if the construction work is suspended for a period of one year or more.

r Fore River Staging Area Application No. Sludge Processing Expansion and Modification MBR-95-IND-056 Page 39

The Department has determined that the filing of an Environmental Notification Form (ENF) with the Secretary of Environmental Affairs. for air quality control purposes. was not required prior to this action by the Department. Notwithstanding this determination, the Massachusetts Environmental Policy Act (MEPA) and Regulation 301 CMR 11.00, Section 11.03, provide certain "Tail-Safe Provisions" which allow the Secretary to require the filingof an ENF and/or an Environmental Impact Report at a later time.

This plan approval is an action of the Department. If you are aggrieved by this action, you may request an adjudicatory hearing. A request for a hearing must be made in writing and postmarked within twenty-one (21) days of the date you received this plan approval.

Under 310 CMR 1.01(6)(b). the request must state clearly and concisely the facts which are the grounas for the request, and the relief sought. Additionally, the request must state why the plan approval is not consistent with applicable laws and regulations.

The hearing request along with a valid check payable to the Commonwealth of Massachusetts in the amount of one hundred dollars ($100.00) must be mailed to:

Commonwealth of Massachusetts Department of Environmental Protection P.O. Box 4062 Boston, MA 02211

The request will be dismissed if the filing fee is not paid, unless the appellant is exempt or granted a waiver as described below.

The filing fee is not required if the appellant is a city or town (or municipal agency), county, or district of the Commonwealth of Massachusetts, or a municipal housing authority. - 0 0

Fore River Staing Area Application No. Sludge Processing Expansion and Modification MBR-95-IND-056 Page 40

The Department may waive the adjudicatory hearing filing fee for a person who shows that paying the fee will create an undue financial hardship. A person seeking a waiver must file, together with the hearing request as provided above, an affidavt setting forth the facts believed to support the claim of undue financial hardship.

Please be advised that this approval does not negate the responsibility of the MWRA to comply with this or any other applicable federal, state, or local regulations now or in the future. Nor does this approval imply compliance with this or any other applicable federal, state, or local regulations now or in the future.

Should you have any questions concerning this matter, please do not hesitate to contact Mrs. Rachel Quill at the Metropolitan Boston/Northeast Region, 10 Commerce Way, Woburn, Massachusetts 01801.

Sincerely,

Icel 'ui ames E. Be Environmental Engineer ermit Chief Bureau of Was e Prevention

cc: Board of Health, 1120 Hancock Street. Quincy, MA 02169 Fire Headquarters, 26 Quincy Avenue, Quincy, MA 02169 Board of Health, Town Hall, Braintree, MA 02184 Fire Headquarters, 9 Union Plae, Braintree, MA 02184 DEP, DAQC, One Winter Stra, Baston, MA 02108 Attn: Mr. Walter Sullivan DEP, DWPC, One Winter Street, Bston, MA 02108 Att: Mr. Steven Lipran DEP, DWPC, One Winter Stret, Baton, MA 02108 Attn: Mr. Dennis Dunn DEP, DAQC, NERO Attn: Mr. Thomas Parks r I

4 Fore River Staging Area Application No. Sludge Processing Expansion and Modification MBR-95-IND-056 I, Page 41

United States Environmental Protection Agency, J.FX Federal Building, Boston, MA 02203 Attn: Mr. Jerry Potamis Maseachusetts Water Resources Authority, Charlestown Navy Yard, 100 First Avenue, Boston, MA 02129 - Attn: Mr. Leon Lataille Tech Environmental. Inc., Reservoir Place, 1601 Trapelo Road, Waltham, MA 02154 Attn: Mr. Keith Kennedy Tighe & Bond Consulting Engneers, Westfield Executive Park, 53 Southampton Road, Westfield, MA 01085 - Attn: Mr. Todd M. Brown New England Fertilizer Company, 97 East Howard Street, Quinty, MA 02169 Attn: Mr. Craig R. Dolan Mr. David Standley, Consultant in Environmental Management, 4 South Main Street, I Ipswich, MA 01938 Tellus Institute, 11 Arlington Strest, Boston, MA 02116 I Attn: Mr. James Goldstein

ip4 *C

RC4 MASSACHUSETTS WATER RESOURCES AUTHORITY Charlestown Navy Yard 100 First Avenue Boston, Massachusetts 02129 Telephone: {617) 242-6000 Facsimile. (617) 241-6070

September 19, 1996

PUBLIC NOTICE RE: CONSULTANTS DETERMINATION and LSP LETTER OF OPINION MWRA Fore River Staging Area (former General Dynamics Shipyard) Release Tracking No. 3-0536 and 3-10266

Dear Interested Party:

Please be advised that GZA GeoEnvironmental, Inc. (GZA), the Consultant of Record for the Massachusetts Water Resources Authority (MWRA) and for Water Transportation Alternatives, Inc. (WTA), has prepared a Licensed Site Professional Letter of Opinion and a Consultant's Determination for a portion of the MWRA's Fore River Staging Area, Quincy, Massachusetts. These documents pertain to WTA's proposal to develop a portion of the Fore River Staging Area as a commuter parking lot and ticketing area for a water shuttle service to be established by WTA at this location under a lease from the MWRA.

In accordance with the Fore River Staging Area Notice of Land Use Stipulation, this portion of the property is currently restricted to business office or industrial use. Before any other use is allowed, a Consultant's Determination is required to demonstrate that a condition of no significant risk to public health, welfare, or the environment will exist under the proposed use. In accordance with the Fore River Staging Area Public Involvement Plan, the Consultant's Determination and the Licensed Site Professional Letter of Opinion on which the Determination is based have been made available for public review and comment. Copies of these documents may be reviewed at the following locations:

Thayer Public Library, 798 Washington Street, Braintree

Tufts Public Library, 46 Broad Street, Weymouth

Thomas Crane Public Library, 40 Washington Street, Quincy

MWRA Library, 100 First Avenue, Charlestown Navy Yard, Boston

Printed on 100% Recycled Paper Please forward all comments to the attention of:

Mr. Jose Vincenty Public Contact Person MWRA Charlestown Navy Yard 100 First Avenue Boston, MA 02129

The 20-day public comment period for these documents will expire on October 11, 1996.

DISTRIBUTION: Public Involvement Plan Mailing List 0

a 7 -5- S.3 STAFF SUMMARY

TO Board of Directors Vi FROM: Douglas B. MacDonald, Executive Director DATE: September 11, 1996 SUBJECT: Water Transportation Alternatives, Inc., United States Naval Shipbuilding Museum and MWRA: Arrangements at FRSA for Water Shuttle Service to Logan Airport and Downtown Boston

COMMITTEE: Administration & Finance Information X Vote

Maggie Debbie, Director, Real Prop./Env. Mgmt. Thomas B. Powers Preparer/Title Division Director Approval

This matter was presented to the Board at the meeting of August 14 and withdrawn to permit the staff to gather additional information, conduct further discussions with WTAI and the City of Quincy, and answer questions raised by various Board members. This staff summary supersedes the staff summary of August 14, 1996.

RECOMMENDATION: To authorize the Executive Director to enter into the following arrangements for the use of a portion of the FRSA to support a water shuttle service serving Logan Airport and Long Wharf from Quincy: (1) amend the lease with the United States Naval Shipyard Museum, Inc. (the Museum), to increase its leased area from 11.5 acres to approximately 14.5 acres; (2) authorize a sublease from the Museum to Water Transportation Alternatives, Inc. (WTAI) for purposes of operating a passenger water shuttle service including providing parking for patrons; (3) enter into financial arrangements whereby WTAI shall pay rent in a monthly base amount plus (commencing in 1999) a $1 per parked car per day additional rent and providing for division of those rental receipts between the Authority and the Museum as specified in this staff summary; and (4) to make other necessary arrangements to achieve the service objectives outlined in this staff summary. DISCUSSION: Backrround This water shuttle initiative emerges from an RFP conducted by Massport in February, 1996 to attract a second passenger water shuttle service to Logan Airport. The RFP is part of the "Logan 2000" modernization plan which includes steps to reduce the airport's dependence on automobile access. Expanded water shuttle service to Logan also contributes to mitigation commitments and traffic planning needs for the Central Artery Project. The proposed service is supported by all the relevant transportation agencies and the state Executive Office of Environmental Affairs as well as by both the City of Boston and the City of Quincy (more detail below). The existing Logan water shuttle service, operated by one of the Beacon Companies, connects the airport only with Rowes Wharf.

WTAI was one of two bidders (the other was Beacon) responding to the Massport RFP. In May 1996 WTAI was designated by Massport staff1 The WTAI proposal emphasized the opportunity to expand water passenger ridership to and from Logan by providing a new service linking the South Shore (now Quincy), Long Wharf and the Airport. Selling points of the proposal included frequent departures matched to air traffic demand (for example, boat departures from Logan would vary from 22 to 26 per day depending on day of week) and the provision of a high amenity service with new vessels equipped with luggage racks, snack bars and other features appealing to commuters and air travellers. The proposed fare between Quincy and the Airport is $10.00 and between Quincy and Long Wharf is $5.00. A separate parking charge in Quincy would be set at a day rate of $2.00 and an overnight rate of $6.00. Projected one-way daily ridership would start at 300 passengers per day, growing to 1800 passengers per day, or approximately 556,000 passengers per year, of which about 65% would be expected to travel to and from the Airport. (By contrast, the current Rowes Wharf shuttle carries an average passenger volume of 650 per day; the Hingham-Boston commuter ferry carried over 600,000 passengers in 1995.) Key projections prepared by WTAI as part of its pro forma plan submitted to Massport include:

1997 1999 2001

Weekday Ridership 1,142 1,700 (75% to Logan) 1,800 Weekend Ridership 571 (25% to Logan) 800 800 Fare Revenues $2,717,000 $4,106,000 $4,318,000

Parking Revenues $673,000 $1,021,000 $1,081,000

1 Arrangements at Massport are expected to be completed under delegated authority; Massport staff expect to submit to the Massport Board the equivalent of an "information only" staff summary after all arrangements, including the terminal arrangements, are concluded

2 From these projections, MWRA staff have derived a rough benchmark of car/park days as follows:

Days Spaces Use Factor Car Days

Weekdays 250 900 0.9 202,500

Weekends 110 900 0.7 69,300

Total 360 - - 271,800

WTAI's principal executives are two graduates of Mass. Maritime Academy who developed the proposal with support from a financial and operating company, American Overseas Marine Corporation (AMSEA), a subsidiary of the General Dynamics Corporation.- AMSEA now owns WTAI. Two 149-passenger water-jet catamarans to provide the service are now being built in Somerset, Mass. at the Gladding-Hearn Shipbuilding yard. Terminal Arrangements at Logan Airport and Long Wharf At Logan Airport the service will terminate at the float and pier already used by the Rowes Wharf shuttle. Passengers will be inoved to and from the airline terminals on the Massport shuttle buses that already serve the Rowes Wharf boat. Massport will make no charge to WTAI for the use of the pier, but after April 1998 WTAI will pay a fee of $1.50 for each passenger to offset a portion of the cost of the bus service. (The delay in Massport's charge is intended to help WTAI defray its approximately $50,000 cost for necessary changes to the float to accommodate the bow-loading configuration of the WTAI vessels.) Massport has advised MWRA that WTAI's payment will only partially cover the per passenger shuttle bus cost; the resulting subsidy to WTAI is intended to support the overall benefits to Massport of reduced automobile congestion to, from and at the Airport. The anticipated Massport/WTAI agreement is in the form of a three year operating agreement with two extensions for three years each exercisable by WTAI unless its annual ridership is less than 200,000 in the year preceding the renewal. (The FRSA arrangements will be terminable if at any time the WTAI license at Logan Airport ceases to be in effect.)

On the Boston waterfront the service will terminate at Long Wharf, a property owned by the BRA. BRA voted at its meeting of September 4, 1996 to approve a five year lease (plus one five year extension at lessee's option) for approximately 100 square feet of space on Long Wharf and a water area of approximately 9,000 square feet in which to locate the service float. The rent to the BRA has been set at $18,000 per year subject to an escalation for inflation. In addition WTAI will construct and pay for site improvements on Long Wharf at the entry point to its ramps at an estimated cost of $50,000 - $75,000.

3 Terminal Arrangements in Quincy WTAI originally anticipated that the South Shore terminal would be at the former BECo Edgar Station in Weymouth. However, discussions in April began to explore the possibility of using space leased by MWRA to the United States Naval Shipbuilding Museum at the Fore River Staging Area for parking and the float. MWRA staff contacted at that time advised WTAI that because of the existing lease to USNSM, any arrangements regarding that site would have to be brought to the MWRA through and with the concurrence of USNSM. WTAI then entered into further discussions with USNSM and Mayor Sheets about the terminal and parking possibilities and any attendant traffic, economic development and neighborhood impacts. The USNSM was receptive to the proposal because its own parking demand has not yet expanded to utilize the entire area it had originally leased from MWRA for parking purposes. Discussions included MWRA in June 1996 because of the need to secure MWRA approval of this leasehold use of the USNSM area and also the. need to add a limited area not then leased to the USNSM for location of the service float. The proposal before the Board is intended to effectuate the use of the Fore River Staging Area generally in accordance with this plan. WTAI has had an expectation of additional support for the construction of the floats at Long Wharf and FRSA from the Executive Office of Transportation and Construction. If this support does not materialize, WTAI will bear the cost of constructing the floats. Therefore, the service is not dependent on EOTC's involvement.

Suitability of the Proposed Use of the Fore River Staging Area The area of the proposed use of the Fore River Staging Area is shown on the following sketch, which also delineates the area now under lease to the USNSM (11.5 acres; lease expires 2003 with two five-year options) as well as the new area proposed to be made available by MIWRA (3.0 acres, approximately 60% of which is water surface). The use of this area to support a water shuttle service to Boston and Logan Airport is entirely consistent with the development blueprint for FRSA produced through the community-based planning process with which the Board is familiar.

The FRSA Development Plan envisioned Harbor Island access from the north portion of the site, with the possibility of a public access area for educational/cultural activities. The museum and the water shuttle dock provide a strong base for this part of site development. With the synergy of the water shuttle it is expected that the Museum's visibility and its visitor count will increase. In addition, the adjacent lot is the proposed location of the Marine Engineering Center, a facility for development and manufacturing of products related to marine transportation and structures. A recent focus group of interested industry leaders voiced support for a water route to Logan Airport, and saw it as a benefit and added attraction to potential users

4 USNSM LEASE AREA AND PROPOSED ADDITION FOR WTAI-

In order to use the proposed parking area, WTAI must relocate track on the site in order to accommodate storage of back-up rail cars for the NEFCO sludge-to- fertilizer operation. This relocation will be performed by WTAI at a cost not-to- exceed $130,000, with one-half of its expense to be recouped from the $1 percar per day fee (see below) it will commence to pay in 1999. WTAI has also undertaken to contract other site improvements to the parking area including fencing, lighting, grading, paving, striping, traffic control gates, and installation of water/sewer connections to the ticket facility. WTAI has estimated its cost for these improvements to be approximately $750,000. WTAI will provide a $5 million general liability coverage naming MWRA as additional insured, other routine insurance, a $1 million Watercraft insurance policy, and certain customary lease indemnnifications. WTAI will also bear the cost of a requirement owed MWRA in the USNSM lease to prepare and file a change in the Notice of Land 'Use stipulation at the registry of deeds. This will raise the stipulated land use to accommodate public access as contrasted to the current industrial/business use classification under the DEP Waiver of Approvals issued in March 1994 pursuant to the Massachusetts Contingency Plan. This and the required underlying analysis notice is being prepared for WTAI by GZA at a cost of approximately $50,000.

5 WTAI has also filed the necessary Chapter 91 application for the docking facility and a Notice of Intent with the Quincy Conservation Commission. In July, WTAI filed a notice of project change with MEPA to account for the expectation that the proposed parking arrangements at the USNSM would expand from about 500 cars to about 950 cars. MEPA's decision is expected by September 15th on whether further environmental analysis must be performed either on the parking itself or on ancillary impacts on the Route 3A rotary or Fore River Bridge. The belief of WTAI and the City of Quincy is that no further MEPA work will be required.

Financial Issues Regarding Rents The other issues involve the rent and fall into two categories: (1) the overall payment to be made by WTAI for use of the FRSA acreage, and (2) the division of that payment stream between USNSM and MWRA.

Payment to be made by WTAI for its use of FRSA area When this matter was presented to the Board at the meeting on August 14, 1996, members of the Board were not in agreement that a ten-year term for WTAI's use of the FRSA should be coupled with a to-be-determined rental rate applicable to years 6 - 10 of the lease. The staff, the Museum and WTAI have subsequently agreed to a rental term consisting of a base monthly rent plus additional rent df $1 per car per day commencing January 1, 1999. The base rental amounts are as follows: Calendar Year Monthly Base Rent 1996 $1,200 1997-2000 $4,000 2001 $5,000 2002-2006 $6,000 Overall rent levels will depend heavily on the actual level of parking use. The following projection is used for illustrative purposes only, assuming that WTAI achieves parking counts in 1999 of 258,210 (95% of the benchmark shown on p. 3), 271,800 car/days in 2001 (100% of the benchmark), and 285,390 car/days in 2003 (105% of the benchmark).

YeiQ__ _ .4.t__ _ '9 00 0 B~ Rn %800 4B DOC [ $2sujo 0oc srVE63Oo

* Prior to a credit allowed to WTAI in the amount of up to $65,000 representing 50% of the cost WTAI incurs in relocatinq railroad storaqe track now located on the parkin site.

. I Because the service is subject to start-up risks and uncertain ridership levels, the foregoing illustrations of the rent mechanism cannot be.taken as firm projections of actual future rental levels. The actual revenue potential of the arrangement will only be reliably forecast after the start-up period.

Division of the Rent Receipts Between MWRA and the USNSM The respective positions of MWRA and USNSM might be compared to two parties each of whom has the key to the lock on one of the two chains that keeps a gate from being opened. Opening the gate represents enabling WTAI's parking and shuttle service to operate from FRSA, a public interest objective agreed upon by all the transportation and civic parties. But the gate cannot be opened until MWRA and USNSM are each satisfied that to do so is in its own interest, since either party withholding its key keeps one chain locked on the gate. The chain "owned" by USNSM is its remaining 7 years (plus options) lease on most of the site. The chain owned by MWRA is the need to approve the site use and the contribution of a small amount of additional acreage illustrated in the plan. The City of Quincy is a highly interested observer because of its interest in the vitality of both the USNSM and the new shuttle service as sound underpinnings for economic growth, tourist promotion, land use and traffic planning for the immediate area and the surrounding neighborhood. There are interests MWRA shares because of their importance to the overall FRSA Development Plan. Both USNSM and MWRA are in the position that any revenue developed from implementation of the proposal is a benefit compared to non-use of the site.

The proposed division of revenue between USNSM and MWRA is based on the principal that the monthly base rent shall be divided between them in the following percentages:

3 mos./1996 1997 1998 1999 2000 2001 2002-2006 Base Rent $3,600 $48,000 $48,000 $48,000 $48,000 $60,000 $72,000 MWRA $2,487 $18,000 $18,000 $18,000 $18,000 $30,000 $36,000 Museum $1,113 $30,000 $30,000 $30,000 $30,000 $30,000 $36,000 Museum's % . 69% 62.50% 62.50% 62.50% 62.50% 50.00% 50.00%

7 01

Further to the base rent, the additional rent from the receipt of $1 per car per day shall be divided between them according to the following sliding scale:

Annual up to $50,000- $100,000 - over Receipts $50,000 $100,000 $150,000 $150,000 MWRA 60% 70% 80% 90% Museum 40% 30% 20% 10%

The result of this division will vary depending on the level of receipts for the $1 per car per day fee. Using the parking assumptions in the shaded table on page 5, the parties receipts at several yearly snapshots of the arrangement would be as follows:

1997 1999 2001 2003 MWRA base rent $18,000 $18,000 $30,000 $36,000 addil. rent - $137,389 $214,620 $226,851 Subtotal $18,000 $155,389 $244,620 $262,851 Museum base rent $30,000 $30,000 $30,000 $36,000 addil. rent - $55,821 $57,180 $58,539 Subtotal $30,000 $85,821 $87,180 $94,539 Total $48,000 $241,210 $331,800 $357,390

The City of Quincy is strongly supportive of this division arrangement because of its belief in the importance that the museum and the water shuttle service should be mutually supportive.

BUDGET AND FISCAL IMPACT:

The Museum currently pays the MWRA $1,000 per month rent After October 1998, MWRA is entitled to rent of 10% of the first $500,000 of the Museum's gross revenue and 15% of revenue beyond that

8 0 0 To: Iris Davis@BWSC PRR@DEP NERO Sharon Gobiel@BWSC ASM@DEP NERO Nancy Fitzpatrick@BWSC ASM@DEP NERO Cc: Alan Slater@MA@DEP Boston Ronald Lyberger@MA@DEP Boston Judith Perry@BRP WW@DEP Boston Bcc: From: Steven Lipman@BRP WPC@DEP Boston Subject: MWRA, Braintree/Weymouth-Haz. Mat. Plan Date: Friday, June 28, 1996 12:42:45 EDT Attach: Certify: N Forwarded by:

Hello my favorite people. Just an update FYI regarding this MWRA Project. I just received for review/comment an Amendment to the Haz. Mat. Plan from Stone & Webster for site investigations for another portion of the MWRA Braintree/Weymouth Project, this element being options for getting a connection from the proposed B/W Intermediate Pump Station located on the BECo/Sprague Site across the Fore River to the Pelletizing Plant at the Fore River Staging Area( aka Quincy Shipyard).

15 borings will be installed at the BECo/Sprague Site; 7 of which will be for collection of soil with 5 turned into monitoring wells. As we requested at the meeting we had with them they will include surficial sampling at 13 locations and analyze for Cyanide.

They will collect sediment samples at 8 locations in the Fore River for analysis. I have requested that they include Reactive Sulfides in the analysis plan.

At the Shipyard they will punch 13 borings with 5 turned into wells.

Overall the proposal looks reasonable, and since they only gave me a couple of days to look at it I don't intend to perform a real detailed review. I did ask them for an additional copy of the plan and will forward to NERO for your info. and files as soon as I receive it. JUN-27-96 THU 13:,1 MWRA B31 3rd FLR RECP FAX NO. ' 7216200 P.01

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10 Commerce Way * Woburn, Massachusetts 01801 * FAX (617) 935-6393 * Telephone (617) 935-2160 S 0 COMMONWEALTH OF MASSACHUSETTS b1 EXECUTIVE OFFICE OF ENVIRONMENTAL AFFAIRS 6 9 DEPARTMENT OF ENVIRONMENTAL PROTECTION ONE WINTER STREET, BOSTON MA 02108 (617) 292-5500

WILLIAM F. WELD TRUDY COXE Governor Secretary

ARGEO PAUL CELLUCCI DAVID B. STRUHS Lt. Governor Commissioner

May 13, 1996

Jan Reitsma, Director Re: ENF - EOEA #10692 MEPA Unit Sale of 130 Acres of the Executive Office of Environmental Quincy Shipyard Affairs 20th Floor 100 Cambridge Street Boston, MA 02202

Dear Mr. Reitsma:

This correspondence includes the Department of Environmental Protection's (DEP) consolidated comments regarding the above referenced Environmental Notification Form Filing. Initially, DEP would like to indicate its full support for bringing shipbuilding activities back to the Quincy Fore River Shipyard and views these activities as the best and highest use for this property as it is located in a Designated Port Area (DPA) and is the historical use for this site. MHI's proposal is also compatible with MWRA's existing and future uses at the site.

During the past ten (10) years, the MWRA and General Dynamics, in cooperation with DEP's Bureau of Waste Site Cleanup, have spent considerable time and money to assess and remediate the Quincy Shipyard due to prior releases and spills of Oil and Hazardous Materials (OHM), most of which were related to the historic shipbuilding and repair activities at the site. It will therefore be important that future shipbuilding activities be performed in strict compliance with all State and Federal statutes and regulations related to the handling, use and disposal of OHM and hazardous wastes at the site, so as not to undo the millions of dollars and effort expended to remediate the site.

0 Pnnied on Recyded Paper It will also be critical that all activities by MHI not interfere with MWRA's existing and future uses at those portions of the site that they will be retaining, the key activities being operation of the Biosolids Drying/Pelletizing Plant and RO/RO Facility.

MEPA is probably aware that the neighborhoods surrounding the Quincy Shipyard site have been very active with regard to controlling noise and odor impacts from MWRA activities at the site, and in this regard MWRA has taken numerous steps to ensure that its activities do not cause off-site impacts. Shipbuilding activities will also have the potential for off-site noise and odor impacts and it will be incumbent upon MHI to carefully consider these issues in development of its facilities, and operational controls.

Specific Comments

Air Ouality Issues

2 MHI must comply completely with Regulation 310 CMR 7.15 regarding removal of any asbestos that may be disturbed during construction in any portion of the site.

3. MHI must submit plan applications to DEP's Division of Air Quality Control (DAQC) for any construction, substantial reconstruction, or alteration subject to the requirements of 310 CMR 7.02, and receive written approval from the Department prior to the commencement of said construction, substantial reconstruction, or alteration. In particular, criteria pollutants resulting from proposed painting operations, and energy input capacities for proposed power plant (s) operation may trigger 310 CMR 7.02 plan review requirements.

4. MHI must comply with the Requirements of 310 CMR 7.00, Appendix C, if the operation of any equipment and/or processes to be installed in any portion of the site would result in sum total emissions of criteria pollutants and/or Hazardous Air Pollutants at "major" levels. Waterways Regulation Program

Staff from DEP's c.91 Waterways Regulation Program attended the May 8th MEPA Project Site Visit and stated that MHI's proposed new building would be situated at least partially within formerly filled tidelands and as such will require a c.91 License. The project is a Water Dependent Activity and DEP does not anticipate any permitting difficulties with the proposal as described at the Site Visit. c.21E and the Massachusetts Contingency Plan

As indicated earlier, the Quincy Shipyard (a.k.a. Fore River Staging Area) has been undergoing site assessment and remediation activities by the Mass. Water Resources Authority (MWRA) and General Dynamics (GD) for historic releases/spills of OHM under a 21E "Waiver of Approvals" issued to MWRA and GD in 1994. During the past few years extensive areas of the Site have been assessed and remediated in accordance with c.21E/MCP and the Site Waiver. The level of site cleanup has been based on the assumption that the foreseeable future use of the Site will remain "industrial or business office in nature" and the MHI proposal is consistent with that use restriction.

The proposed construction activities on the Site by MHI will need to be carefully designed and implemented so as to minimize exposure to construction workers and other individuals on and off the project site to OHM which may be encountered during construction and excavation activities. As part of DEP's coordination with MWRA to allow for its ongoing construction activities on the Site, a detailed Construction Procedures Document was developed which is utilized by MWRA and any of its contractors whenever site intrusive activities are performed. The Notice of Land Use Stipulation for this site includes the requirement that a Hazardous Materials Management Plan be developed and implemented when construction activities are performed by other entities on the Site, which may involve disturbance of contaminated soil and/or groundwater. DEP recommends that MHI expeditiously develop such a plan for any work that they, or any of their contractors, intends to perform on the Site. This will be particularly important if MHI performs any site intrusive work within or near the "central petroleum plume area" on the Site.

With regard to issues of existing site contamination, DEP staff are working with MHI, MWRA and GD to devise a mutually agreeable procedure to ensure compliance with c.21E/MCP while allowing MHI to expeditiously proceed forward with its proposed construction and operations at the site. In this regard, attached is a copy of May 10, 1996, correspondence from DEP which describes issues of liability and future actions relative to c.21E and the MCP. Stormwater and Facility Ooeration Discharaes

About four years ago, as part of MWRA's construction of the FRSA Biosolids Drying/Pelletizing Plant, the Authority prepared and submitted to EPA and DEP a sitewide NPDES Permit for all existing and potential surface water discharges, including those related to shipyard facilities. After initial review of the application, EPA and DEP determined that a sitewide permit was not necessary to allow for proper management of stormwater from the Drying/Pelletizing Plant, and the application was placed in abeyance. Depending on the specific activities MHI intends to perform on the Site, some type of stormwater permitting may be required. Staff from EPA and DEP will work with MHI to determine if any formal permitting will be necessary. Feel free to contact me if you have any questions regarding this correspondence. Very truly yours,

Steven G. ipman, P.E. Boston Harbor Coordinator SGL/wp 9 reitsma cc: Dave Shepardson, MEPA Maggie Debbie, MWRA Marianne Connolly, MWRA Sharon Gobiel, DEP/BWSC Rachel Quill, DEP/DAQC Dave Kennedy, DEP/Waterways Jim Sprague, DEP/Wetlands Dave Ferris, DEP/DAQC Jane Downing, EPA/DEP COMMONWEALTH OF MASSACHUSETTS EXECUTIVE OFFICE OF ENVIRONMENTAL AFFAIRS DEPARTMENT OF ENVIRONMENTAL PROTECTION ONE WINTER STREET, BOSTON MA 02108 (617) 292-5500

WILLIAM F. WELD TRUDY COXE Governor Secretary

ARGEO PAUL CELLUCCI DAVID B. STRUHS Lt. Governor Commissioner

May 10, 1996

Mr. Greg Sparkman Maritime Administration 400 7th Street Washington, D.C. 20590

RE: Release Tracking #3-0536/Quincy Shipbuilding Facility

Dear Mr. Sparkman:

I am pleased to learn that the Massachusetts Heavy Industries Inc. (MHI) has agreed to purchase approximately 130 acres of the former Quincy Shipbuilding facility on East Howard Street, Quincy ("the site") from MWRA. The site is currently a "non-priority, waiver-approved site" undergoing remediation for environmental contamination under MGL c. 21 E. I understand the buyer, MIli, plans to re-institute a shipbuilding business on this site while remediation of existing contamination progresses. This arrangement would be an excellent opportunity to return this property to productive use, is very much in the public interest, and is in the spirit of the Commonwealth's Brownfields initiative.

I also understand that in the course of negotiations with MARAD regarding federal loan guarantees, concerns have been raised about potential liability pursuant to MGL. c. 21 E, the state statute which establishes responsibility for responding to releases of oil and hazardous materials to the environment. To speed conclusive negotiations, I write to indicate the Department of Environmental Protection's readiness to formalize an agreement that the Department will not seek to hold MHI, its successors or its assigns, excluding currently responsible parties, responsible for costs associated with remediation of existing contamination as of the date of execution of the deed. The foregoing is offered on the condition that:

1. MI-1l complies with the provisions of the Notice of Land Use Stipulation recorded on May 17, 1995 at Norfolk County Registry of Deeds, including applicable provisions of the Massachusetts Contingency Plan (MCP).

2. MHI agrees to assume responsibility to the extent it is liable pursuant to MGL c. 21E for any oil or hazardous material releases that occur after the date on which the deed is executed.

0Pr-teit an Recyed Pape, By way of amplification, there are several factors leading to my conclusion that the foregoing would be in the public interest. First, the site is classified as "non-priority" with respect to the risks associated with the contamination on this site relative to other sites. Second, DEP has issued a Waiver of Approvals under the MCP (which allows response actions to proceed without Department oversight) and there is an agreement between the MWRA and General Dynamics to meet the Waiver of Approvals requirements. Third, there are clearly substantial opportunities to be provided by MHI for jobs and tax revenues for the citizens of the Commonwealth. Fourth, the anticipated uses of the site are expected to be related to maritime activities and are "industrial or business office in nature."

Sincerely,

David B. Struhs Commissioner cc: Sotiris Emmanuel, MI Douglas MacDonald, MWRA Trudy Coxe, EOEA David Tibbets, EOEA COMMONWEALTH OF MASSACHUSETTS EXECUTIVE OFFICE OF ENVIRONMENTAL AFFAIRS 6 DEPARTMENT OF ENVIRONMENTAL PROTECTION ONE WINTER STREET, BOSTON MA 02108 (617) 292-5500

WILLIAM F. WELD TRUDY COXE Governor Secretary ARGEO PAUL CELLUCCI DAVID B. STRUHS Lt. Governor Commissioner

MEMORANDUM:

TO: Willa Kuh FROM: Steve Lipman

DATE: May 13, 1996

SUBJECT: Sale of 130 Acres of Former Quincy Fore River Shipyard by MWRA to Mass. Heavy Industries, 21E/MCP Liability Issues

On May 9, 1996, at 2:30 this writer accompanied Jim Colman and Sharon Gobiel (BWSC) to a meeting at EOEA with Henry Bell and Sharon Pelosi (EOEA) , Jan Reitsma (MEPA) , MWRA, Executive Office of Economic Affairs, and Mass. Heavy Industries (MHI) to discuss how to deal with 21E/MCP issues relative to the sale of 130 acres of the former Quincy Shipyard (a.k.a. Fore River Staging Area) from MWRA to MHI for reintroduction of full-scale shipbuilding at the site. We first heard about this meeting on May 8th from John Viola. We were told that MWRA and MHT were looking for a Covenant Not to Sue, or similar control of 21E liability, for historic releases and spills at the Site.

Jim, Sharon and I me- with Peg Stolfa (OGC) at 2:00 before the EOEA meeting where we reviewed a draft letter that MWRA had prepared and forwarded to EOEA, along with a letter which DEP sent to MWRA and a prior potential lessee (Northeast Shipbuilders, Inc.) in August 1994 to also limit 21E liability, but that deal fell through due to a lack of federal/state loan guarantees.

At the meting MHI representatives explained the area of the site they intend to purchase and the facilities they plan to construct and operate. It appears that their facilities will not require extensive subsurface excavation. We reviewed the letter drafted by MWRA for Secretary Coxe's signature (which we only heard about and saw on May 9th even though EOEA had been in receipt of the draft for over a month) which was a revision to the August 1994 DEP letter. After comparing and discussing the MWRA draft to the

0 Pnnted on Recyled Paper prior DEP letter, the parties came to basic agreement on a new draft that DEP would prepare and Commissioner Struhs would sign, before COB May 10th (to be presented on Monday May 13th to the Federal Maritime Adm. to receive approval for federal loan guarantees.

The letter was redrafted and hand delivered to EOEA and FAXed to the other key players by 10:00 on the 10th with a request for revisions by 1:00 p.m. DEP received comments from MWRA, Executive Office of Economic Affairs and EOEA by 2:30, and a final version of the letter was signed by Ed Kunce, for the Commissioner, and hand delivered to EOEA and FAXed to the same players before 4:00 p.m.

Attached FYI is a copy of that letter. MEPA comments on the sale are due on May 14th, and a copy of our comment letter is also appended.

EOEA also agreed to assign an individual (MHI and MWRA want someone from DEP) to expedite project permitting (my name was mentioned). DEP actions will likely include: (1) 21E/MCP ongoing coordination; (2) c.91 License; (3) stormwater permitting/management; and (4) air quality permitting. May also include other miscellaneous DEP permits/approvals such as: (1) cross-connection approvals; (2) industrial wastewater discharges, etc. It does seem logical that I play this role based upon my past experienced and knowledge about this Site. tet me know what you think. SGL/wp 9:quincy cc: Ed Kunce Jim Colman Bill Gaughan Sharon Gobiel Peg Stolfa Carol Wasserman Bob Golledge John Simpson Dave Kennedy Jim Sprague CONAALTH OF MASSACHUSETTS ExECUTIVE OFFICE OF ENVIRONMENTAL AFFAIRS DEPARTMENT OF ENVIRONMENTAL PROTECTION S=ONE WINTER STREET, BOSTON MA 02108 (617) 292-5500

?CILLIAM F. WELD TRUDY COXE jovernor Secretary

A.RGEO PAUL CELLUCCI DAVID B. STRUHs Lt. Governor commissioner

May 10, 1996

Mr. Greg Sparkman Maritime Administration 400 7th Street Washington, D.C. 20590

RE: Release Tracking #3-0536/Quincy Shipbuilding Facility

Dear Mr. Sparkman:

I am pleased to learn that the Massachusetts Heavy Industries Inc. (MHI) has agreed to purchase approximately 130 acres of the former Quincy Shipbuilding facility on East Howard Street, Quincy ("the site") from MWRA. The site is currently a "non-priority, waiver-approved site" undergoing reniediation for environmental contamination under MGL c. 21 E. I understand the buyer. MHl, plans to re-institute a shipbuilding business on this site while remediation of existing contamination progresses. This arrangement would be an excellent opportunity to return this property to productive use, is very much in the public interest, and is in the spirit of the Commonwealth's Brownfields initiative.

I also understand that in the course of negotiations with MARAD regarding federal loan guarantees, concerns have been raised about potential liability pursuant to MGL. c. 21E, the state statute which establishes responsibility for responding to releases of oil and hazardous materials to the environment. To speed conclusive negotiations, I write to indicate the Department of Environmental Protection's readiness to formalize an agreement that the Department will not seek to hold MHI, its successors or its assigns, excluding currently responsible parties, responsible for costs associated with remediation of existing contamination as of the date of execution of the deed. The foregoing is offered on the condition that:

1. MHI complies with the provisions of the Notice of Land Use Stipulation recorded on May 17, 1995 at Norfolk County Registry of Deeds, including applicable provisions of the Massachusetts Contingency Plan (MCP).

2. MHII agrees to assume responsibility to the extent it is liable pursuant to MGL c. 21E for any oil or hazardous material releases that occur after the date on which the deed is executed.

06. Printed on Rrcwtled Paper By way of amplification, there are several factors leading to my conclusion that the foregoing would be in the public interest. First, the site is classified as "non-priority" with respect to the risks associated with the contamination on this site relative to other sites. Second, DEP has issued a Waiver of Approvals under the MCP (which allows response actions to proceed without Department oversight) and there is an agreement between the MWRA and General Dynamics to meet the Waiver of Approvals requirements. Third, there are clearly substantial opportunities to be provided by MHI for jobs and tax revenues for the citizens of the Commonwealth. Fourth, the anticipated uses of the site are expected to be related to maritime activities and are "industrial or business office in nature."

Sincerely,

David B. Struhs Commissioner cc: Sotiris Emmanuel, MI Douglas MacDonald, MWRA Trudy Coxe, EOEA David Tibbets, EOEA COMMONWEALTH OF MASSACHUSETTS EXECUTIVE OFFICE OF ENVIRONMENTAL AFFAIRS DEPARTMENT OF ENVIRONMENTAL PROTECTION ONE WINTER STREET, BOSTON MA 02108 (617) 292-5500

WILLIAM F. WELD TRUDY COXE Governor Secretary

ARGEO PAUL CELLUCCI DAVID B. STRUHS Lt. Governor Commissioner

May 13, 1996

Jan Reitsma, Director Re: ENF - EOEA #10692 MEPA Unit Sale of 130 Acres of the Executive Office of Environmental Quincy Shipyard Affairs 20th Floor 100 Cambridge Street Boston, MA 02202

Dear Mr. Reitsma:

41Pnnted oh RecycledPipe, It will also be critical that all activities by MHI not interfere with MWRA's existing and future uses at those portions of the site that they will be retaining, the key activities being operation of the Biosolids Drying/Pelletizing Plant and RO/RO Facility.

Specific Comments

Air uality Issues

1. MHI must implement measures to alleviate dust, noise and odor nuisance conditions which may occur during and after any construction in any portion of the 130 acres. Such measures must comply with DEP Regulations 310 CMR 7.01, 7.09 and 7.10. In addition, the Bureau of Waste Prevention (BWP) must be notified in writing ten days prior to commencement of any demolition. 2 MHI must comply completely with Regulation 310 CMR 7.15 regarding removal of any asbestos that may be disturbed during construction in any portion of the site.

3. MHI must submit plan applications to DEP's Division of Air Quality Control (DAQC) for any construction, substantial reconstruction, or alteration subject to the requirements of 310 CMR 7.02, and receive written approval from the Department prior to the commencement of said construction, substantial reconstruction, or alteration. In particular, criteria pollutants resulting from proposed painting operations, and energy input capacities for proposed power plant(s) operation may trigger 310 CMIR 7.02 plan review requirements.

c.21E and the Massachusetts Contingenc Plan

About four years ago, as part of MWRA's construction of the FRSA Biosolids Drying/Pelletizing Plant, the Authority prepared and submitted to EPA and DEP a sitewide NPDES Permit for all existing and potential surface water discharges, including those related to shipyard facilities. After initial review of the application, EPA and DEP determined that a sitewide permit was not necessary to allow for proper management of stormwater frQm the Drying/Pelletizing Plant, and the application was placed in abeyance. Depending on the specific activities MHI intends to perform on the Site, some type of stormwater permitting may be required. Staff from EPA and DEP will work with MHI to determine if any formal permitting will be necessary. Feel free to contact me if you have any questions regarding this correspondence.

Very truly yours,

Steven G. ipman, P.E. Boston Harbor Coordinator

Sl L/wp 9 reitsma cc: Dave Shepardson, MEPA Maggie Debbie, MWRA Marianne Connolly, MWRA Sharon Gobiel, DEP/BWSC Rachel Quill, DEP/DAQC Dave Kennedy, DEP/Waterways Jim Sprague, DEP/Wetlands Dave Ferris, DEP/DAQC Jane Downing, EPA/DEP MAY-09-96 THU 11:22 MWRAj34 3rd FLR RECP FAX NO. 6172416200 P.01

MASSACHUSETTS WATER RESOURCES AUTHORITY Charlestown Navy Yard 100 First Avenue Boston, Massachusetts 02129 Telephone: (617) 242-6000 FacsImile: (617) 241-6 200

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FAX NO: 241-6200

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Printed on 100% Recycled Paper MAY-09-96 THUJ 11:22 MWRAT334 3rd FIR REOP FAX NO. 6172416200 P.0?

MEMORANDUM

TO: Maggie Debbie, Director, Real Property & Environmental Mgmt. Mark Radville, Project Manager, Real Property & Environment Mgmt. t/

FROM Christine E. Seward, Legal Assistant, Law Division

DATE: May 17, 1995

RE: Notice of Land Use Stipulation - Parcels of land located in Quincy and Braintree, MA

'he attached Notice of Land Use Stipulation was recorded on May 17, 1995 at the No folk County Registry of Deeds as Document #36965 and the Norfolk County Registr r of the Land Court as Document #714486.

.'lease do not hesitate to contact me at ext. 1142 if you have any questions.

Enclos ire cc *Irudy P. Reilly, Associate General Counsel MAY-09-96 THU 11:23 MWRA 4 3rd FLR RECP FAX NO. 6172416200 P,03

NOTICE OF LAND USE STIPULATION

NOTICE is hereby given as of the 10t_ day of May 1995, by Mass ichusetts Water Resources Authority, a public body corporate and politic, with an of ice at 100 First Avenue, Charlestown Navy Yard, Boston, Massachusetts ("Gr ntor") that:

1. Grantor is the owner in fee simple of the land located in Quincy and Brain:ree, Norfolk County, Massachusetts, with the buildings and improvements there )n more particularly described on Exhibit A attached hereto and made a part herec (the "Property").

2. The Property is a disposal site as the result of a release of oil and/or hazai lous material.

3. The response actions for the Property have been approved by the Mass .chusetts Department of Environmental Protection ("DEP") based upon the Grani :r's assertion that use of the Property would be limited to:

(a) activities in connection with the use of the Property for indus :xial and business office purposes; and

(b) such other activities which, in the opinion of (i) the "Consultant of Re ord" under the terms of the 'Waiver of Approvals" dated March 2, 1994 and grant. d to Grantor; or (ii) a person licensed by the Board of Registration of Waste Clean ip Professionals or any successor agency (a holder of such license hereinafter referr d to as an "LSP'), present no greater risk of harm to health, safety, public welfa e or the environment than the use of the Property for industrial or business office purposes. Such opinions shall be set forth in writing, signed and sealed by the Consi Itant of Record or the LSP, as applicable, and recorded and/or registered with the al propriate Registry of Deeds and/or Land Registration Office. A certified Regis ry copy of the same shall be filed with DEP within 30 days of recording and/or regist -ation.

4. Any proposed change in activities and uses at the Property which may result in higher levels of exposure to oil and/or hazardous material than the expos ires which would occur as a result of the use of the Property for the purposes set fo th in Section 3 above shall be evaluated (i) by the Consultant of Record, durin the term of the Waiver of Approvals, who shall make a determination (herei after the "Consultant's Determination") or (ii) by an LSP who shall render an LSP C pinion, in accordance with the DEP Waiver of Approvals and the Mass chusetts Contingency Plan , as applicable, as to whether the proposed changes will p -esent a significant risk of harm to health, safety, public welfare or the envir< nment. Any and all requirements set forth in the Consultant's Deter nination or LSP Opinion to ensure a condition of No Significant Risk in the imple nentation of the proposed activity or use shall be satisfied before any such MAY-09-96 THU 11:23 4R34 3rd FLR RECP FAX NO. 6172416200 P.04

activ ty or use is commenced, Such Determination or Opinion shall be set forth in writi ig, signed by the Consultant of Record or the certifying LSP, as applicable, and recor led and/or registered with the appropriate Registry of Deeds and/or Land Regi, tration Office. A certified copy of same shall be filed with DEP within 30 days of re- ording and/or registration. Upon the recording of either the Consultant's Dete: mination or the LSP Opinion, the Property shall be conclusively presumed to be ai ailable for use for the purposes set forth in such Determination or Opinion as well ts for the purposes set forth in Section 3 above.

5. Construction activities which may involve the disturbance of cont2 nination soil and/or groundwater shall include preparation and imph mentation of a hazardous materials management plan ("HMMP") to mmi uze migration of and exposure to hazardous materials. The HMMP shall be prep; red in accordance with the requirements of the "Waiver of Approval" and the Mass ichusetts Contingency Plan, as applicable.

WITNESS the execution hereof under seal this 10th day of iav 1995.

MASSACHIJSFTTS WATER RESOURCES AUTHOITY

By:

COMMONWEALTH OF MASSACH-USETTS

Fjfftn l SS. M 30 . 1995

Then personally appeared the above-namedDouglas B. MacDonaii _-hh iL-* of wA and acknowledged the foregoing instrt ment to be the free act and deed of wwRA, before me.

Notary Public

My Commission expires: /0//-/-z/ MAY-09-96 THU 11:24 MWR 34 3rd FLR RECP FAX NO. 6172416200 P.05

EXHIBIT A

Legal Description

The real property in Quincy and Braintree, Norfolk County, Massachusetts conv< yed to Massachusetts Water Resources Authority by General Dynamics Corp< ration by deed dated November 16, 1987 and filed with the Norfolk County Regis ry District of the Land Court as Document No. 535415 shown as Transfer Certil cate of Title No. 127626, filed in Registration Book 639, Page 26, and recorded with; he Norfolk County Registry of Deeds in Book 7803, Page 211; said real property being more particularly described as Parcels 1 through 15, inclusive, in Exhibit A to said I eed, a copy of the land description in such Deed is attached hereto as Exhibit A-1; I ut expressly excluding Parcel 4 as described in such Exhibit A to said Deed and in ExJ .ibit A-1 hereto, and in Exhibit B hereto. Said parcels are shown on a plan of land i ntitled "General Dynamics Quincy, MA. and Braintree, MA." (consisting of a Plan I adex an d fourteen drawings numbered 150.011 M to 150.151M, inclusive, but exclui .ing 150.081M) dated October 15, 1986 and November 4, 1986, as revised, by New England Survey service, recorded November 16, 1987 in Plan Book 361 as Plan #1372 of 1987, Sheets 1-15. MAY-09-96 THU 11:24 MWRf34 3rd FLR RECP FAX NO. 6172416200 P.06

EXHIBIT A-1

All those fifteen (15) certain parcels of land in Quincy and Braintree, Norfolk County, Massachusetts, bounded and described as follows:

PARCEL 1:

A CERTAIN PARCEL OF LAND IN THE COMMONWEALTH OF MASSACHUSETTS, COUNTY OF NORFOLK, CITY OF QUINCY AND TOWN UF BRAINTREE, SITUATED ON EAST HOWARD STREET, SOUTH STREET, NASH AVENUE, WASHINGTON STREET, HILL AVENUE, AND QUINCY AVENUE AS SHOWN ON SAID PLAN, DATED OCTOBER 15, 1986, DRAWING 150.011M, DRAWING 150.021M, DRAWING 150.031M, DRAWING 150.041M, AND DRAWING 150.0SiM.

CCNTAINING 647,688 SQUARE METERS, MORE OR LESS, OR 6,971,625 SQUARE FEET, MORE OR LESS, OR 160.046 ACRES, MORE OR LESS.

EXCLUDING FOUR PARCELS OF LAND NOW OR FORMERLY OF FORE RIVER RAILROAD CORPORATION DESCRIBED AS FOLLOWS:

(2) LAND DESCRIBED AS PARCEL 2 IN THE DEED FROM THE COMMONWEALTH OF MASSACHUSETTS TO FORE RIVER RAILROAD CORPORATION, DATED AUGUST 6, 1920, RECORDED AT BOOK 1466, PAGE 81;

INCLUDED AS PART OF THE ABOVE-DESCRIBED PARCEL 1 ARE THE FOLLOWING LOTS OF REGISTERED LAND;

LOT 5 ON LAND COURT PLAN 18298D WHICH PLAN IS DATED JULY 17, 1987, AND WAS PREPARED BY NEW ENGLAND SURVEY SERVICE AND IS FILED WITH CERTIFICATE OF TITLE NO. 74465.

LOTS D, F AND G ON LAND COURT PLAN 531H.

FOR TITLE REFERENCE, SEE CERTIFICATE OF TITLE NO. 74465, FILED IN REGISTRATION BOOK 373, PAGE 65; CERTIFICATE OF TITLE NO. 88974, P.07 MAY-09-96 THU 11:25 MWR j4 3rd FLR RECP FAX NO. 6 1 200

FILED IN REGISTRATION BOOK 445, PAGE 174; DEED FROM BETHLEHEM ;TEEL COMPANY DATED DECEMBER 31, 1963. RECORDED AT BOOK 4132, PAGE ;59; AND DEED FROM THE UNITED STATES OF AMERICA, ACTING BY AND HROUGH THE ADMINISTRATOR OF GENERAL SERVICES, DATED APRIL 30, .970, RECORDED AT BOOK 4660, PAGE 495.

:ARCEL 2:

A CERTAIN PARCEL OF LAND IN THE COMMONWEALTH OF MASSA.CHU- ;ETTS, COUNTY OF NORFOLK, TOWN OF BRAINTREE, SITUATED ON HILL AVENUE, LANCASTER ROAD, CLIFF STREET, AND COLUMBIA TERRACE AND IS HOWN ON SAID PLAN, DATED NOVEMBER 4, 1986, DRAWING 150.061M.

cONTAINING 9,066 SQUARE METERS, MORE OR LESS, OR 97,584 SQUARE EET, MORE OR LESS, OR 2.240 ACRES, MORE OR LESS.

NCLUDED AS PART OF THE ABOVE-DESCRIBED PARCEL 2 IS A PARCEL OF I EGISTERED LAND BEING SHOWN ON LAND COURT PLAN 23255A.

JOR TITLE REFERENCE, SEE CERTIFICATE Or TITLE NO. 82202, FILED TN I EGISTRATION BOOK 412, PAGE 2; DEED FROM BETHLEHEM STEEL COMPANY IATED DECEMBER 31, 1963, RECORDED AT BOOK 4132, PAGE 459; DEED IROM WILLIAM N. MCQUARRIE, JR. AND JOAN MCQUARRIE DATED JUNE 1, J967, RECORDED AT BOOK 4431, PAGE 170; DEED FROM FRANCES RIVELLI, IDMINISTRATOR OF THE ESTATE OF NUNZIATO LUISI, DATED JUNE 15, 1967, RECORDED AT BOOK 4447, PAGE 557; DEED FROM ARTHUR V. OLSEN IND GLADYS M. OLSEN DATED JANUARY 16, 1968, RECORDED AT BOOK 4488, INGE 42; DEED EROM RAYMOND F. BARRETT, ADMINISTRATOR OF THE ESTATE CF ANNIE DRUMMOND, DATED JANUARY 31, 1968, RECORDED AT BOOK 4491, FAGE 277; AND DEED FROM JOHN J. SULLIVAN AND ANNE SULLIVAN DATED OJNE 14, 1968, RECORDED AT BOOK 4519, PAGE 541.

PXRCEL 3:

A CERTAIN PARCEL OF LAND IN THE COMMONWEALTH OF MXSSACHUSETTS, COUNTY OF NORFOLK, TOWN OF BRAINTREE, SITUATED ON C)LUMBIA TERRACE AND CLIFF STREET AND IS SHOWN ON SAID PLAN, DATED N)VEMBER 4, 1986, DRAWING 150.061M.

C)NTAINING 1,778 SQUARE METERS, MORE OR LESS, OR 19,138 SQUARE F:ET, MORE OR LESS.

F)R TITLE REFERENCE, SEE DEED FROM JAMES E. DHOOGE DATED MAY 2, 1 67, RECORDED AT BOOK 4425, PAGE 517; DEED FROM GERALD D. DHOOGE, A .SO KNOWN AS GERALD D. DEWEY, AND MABEL DHOOGE, ALSO KNOWN AS M.BEL DEWEY, DATED APRIL 10, 1967, RECORDED AT BOOK 4431, PAGE 6 4; DEED FROM THERESA LUISI DATED JUNE 15, 1967, RECORDED AT BOOK 4.47, PAGE 555; AND TWO DEEDS FROM THE TOWN OF BRAINTREE DATED D:CEMBER 11, 1967, RECORDED AT BOOK 4483, PAGES 447 AND 450.

P. RCEL 4:

A CERTAIN PARCEL OF LAND IN THE COMMONWEALTH OF MJSSACHUSETTS, COUNTY OF NORFOLK, TOWN OF BRAINTREE, SITUATED ON

- 2 - NO. 6 j16200 P.08 MAY-09-98 THU 11:25 MWRj34 3rd FLR RECP FAX

,ANCASTER ROAD, AND IS SHOWN ON SAID PLAN, DATED NOVEMBER 4, 1986, RAWING 150.061M.

ONTAINING 1,301 SQUARE METERS, MORE OR LESS, OR 14,000 SQUARE EET, MORE OR LESS.

OR TITLE REFERENCE, SEE DEED FROM BETTY A. DIBONA DATED JUNE 1, 970, RECORDED AT BOOK 4666, PAGE 467.

1ARCEL 5:

A CERTAIN PARCEL OF LAND IN THE COMMONWEALTI OF IASSACHUSETTS, COUNTY OF NORFOLK, TOWN OF BRAINTREE, SITUATED ON !ILL AVENUE AND LANCASTER ROAD AND IS SHOWN ON SAID PLAN, DATED 2DVEMBER 4, 1986, DRAWING 150.061M.

(DNTAINING 6,551 SQUARE METERS, MORE OR LESS, OR 70,509 SQUARE IEET, MORE OR LESS, OR 1.619 ACRES, MORE OR LESS.

F3R TITLE REFERENCE, SEE DEED FROM BETHLEHEM STEEL COMPANY DATED ERCEMBER 31, 1963, RECORDED AT BOOK 4132, PAGE 459; DEED FROM J5 MES J. FLAVIN DATED JANUARY 7, 1967, RECORDED AT BOOK 4404, PAGE 639; DEED FROM JOHN F. JOHNSON AND JESSIE M. JOHNSON DATED MARCH 3. 1967, RECORDED AT BOOK 4414, PAGE 552; DEED FROM CATHERINE M:QUARRIE DATED OCTOBER 5, 1967, RECORDED AT BOOK 4465, PAGE 73; AID DEED FROM WILLIAM N. MCQUARRIE AND CATHERINE MCQUARRIE DATED O:TOBER 5, 1967, RECORDED AT BOOK 4465, PAGE 74.

P RCEL 6:

A CERTAIN PARCEL OF LAND IN THE COMMONWEALTH OF MLSSACHUSETTS, COUNTY OF NORFOLK, TOWN OF BRAINTREE, SITUATED ON LLNCASTER ROAD AND IS SHOWN ON SAID PLAN, DATED NOVEMBER 4, 1986, D AWING 150.061M.

CiNTAINING 643 SQUARE METERS, MORE OR LESS, OR 6,916 SQUARE FEET, Mi RE OR LESS.

F( R TITLE REFERENCE, SEE DEED FROM BETHLEHEM STEEL COMPANY DATED DICEMBER 31, 1963, RECORDED AT BOOK 4132, PAGE 459.

PlRCEL 7:

A CERTAIN PARCEL OF LAND IN THE COMMONWEALTH OF MISSACHUSETTS, COUNTY OF NORFOLK, TOWN OF BRAINTREE, SITUATED ON LNCASTER ROAD AND COLUMBIA TERRACE AND IS SHOWN ON SAID PLAN, DITED NOVEMBER 4, 1986, DRAWING 150.061M.

CC'TAINING 660 SQUARE METERS, MORE OR LESS, OR 7,108 SQUARE FEET, MCRE OR LESS.

FCl TITLE REFERENCE, SEE TWO DEEDS FROM THE TOWN OF BRAINTREE DAED DECEMBER 11, 1967, RECORDED AT BOOK 4483, PAGES 446 and 449.

- 3 6 6200 P.09 MAY-09-96 THU 11:26 MWRj4 3rd FLR REOP FAX NO. 1

NRCEL 8:

A CERTAIN PARCEL OF LAND rN THE COMMONWEALTH OF %SSACHUSETTS, COUNTY OF NORFOLK, TOWN OF BRAINTREE, SITUATED ON CXLUMBIA TERRACE, AND IS SHOWN ON SAID PLAN, DATED NOVEMBER 4, 1986, DRAWING 150.061M.

CDNTAINING 391 SQUARE METERS, MORE OR LESS, OR 4,212 SQUARE FEET, N)RE OR LESS.

F)R TITLE REFERENCE, SEE DEED FROM THE TOWN OF BRAINTREE DATED CZCEMBER 11, 1967, RECORDED AT BOOK 4483, PAGE 448.

UkRCEL 9:

A CERTAIN PARCEL OF LAND IN THE COMMONWEALTH OF M SSACHUSETTS, COUNTY OF NORFOLK, TOWN OF BRAINTREE, SITUATED ON H:LL AVENUE, PATTEN AVENUE, AND QUINCY AVENUE AND IS SHOWN ON SAID PAN, DATED NOVEMBER 4, 1986, DRAWING 150.071M.

C)NTAINING 15,390 SQUARE METERS, MORE OR LESS, OR 165,659 SQUARE F:ET, MORE OR LESS, OR 3.803 ACRES, MORE OR LESS.

FOR TITLE REFERENCE, SEE DEED FROM CHARLES A. SMITH DATED K RCH 17, 1967, RECORDED AT BOOK 4416, PAGE 50; DEED FROM SIGNE E. W.:ITEHOUSE DATED MAY 1, 1967. RECORDED AT BOOK 4424, PAGE 327; D ED FROM GEORGE W. NOYES, JR. AND JOYCE E. NOYES DATED MAY 29, 1 67, RECORDED AT BOOK 4430, PAGE 659; DEED FROM RAYMOND E. ELLIS D.TED JUNE 13, 1967, RECORDED AT BOOK 4434, PAGE 110; DEED FROM R.'NE BIGANZOLI AND MARY BIGANZOLI DATED JUNE 16, 1967, RECORDED AT BCOK 4435, PAGE 531; DEED FROM HENRY SEPPALA AND VIOLET SEPPALA Di TED JUNE 15, 1967, RECORDED AT BOOK 4435, PAGE 533; DEED FROM W LLIAM PERRY AND JOHN S. PERRY DATED JUNE 27, 1967, RECORDED AT B(OK 4438, PAGE 395; DEED FROM RAYMOND F. BARRETT, ADMINISTRATOR 01 THE ESTATE OF ANNIE DRUMMOND, DATED JANUARY 31, 1968, RECORDED A BOOK 4491, PAGE 277: AND DEED FROM AGNES DRISCOLL DATED JANUARY 4, 1969, RECORDED AT BOOK 4568, PAGE 707.

PJRCEL 10:

A CERTAIN PARCEL OF LAND IN THE COMMONWEALTH OF MJSSACHUSETTS, COUNTY OF NORFOLK, TOWN OF BRAINTREE, SITUATED ON C(LUMBIA TERRACE AND PATTEN AVENUE AND IS SHOWN ON SAID PLAN, DUrTED NOVEMBER 4, 1986, DRAWING 150.071M.

C(NTAINING 2,796 SQUARE METERS, MORE OR LESS, OR 30,095 SQUARE FEET, MORE OR LESS.

FCR TITLE REFERENCE, SEE DEED FROM WALTER J. LATHAM AND DORIS M. Le rHAM DATED MAY 4, 1967, RECORDED AT BOOK 4425, PAGE 516; DEED FF)M THERESA LUISI DATED JUNE 15, 1967, RECORDED AT BOOK 4447, PP3E 555; AND DEED FROM SARAH R. FERGUSON DATED JULY 12, 1967, RE:ORDED AT BOOK 4443, PAGE 483.

- 4 - MAY-09-96 THU 11:26 MWR 34 3rd FLR RECP FAX NO. 6172416200 P.10

'ARCEL 11:

A CERTAIN PARCEL OF LAND IN THE COMMONWEALTH OF ASSACHUSETTS, COUNTY OF NORFOLK, CITY OF QUINCY, SITUATED ON -AST HOWARD STREET, CHUBBUCK STREET, DES MOINES ROAD, AND SOUTH TREET AND IS SHOWN ON SAID PLAN, DATED OCTOBER 15, 1986, DRAWING .50.091M.

3EING SHOWN AS LOT 2 ON A PLAN DRAWN BY ERNEST W. BRANCH, INC., IVIL ENGINEERS, DATED DECEMBER 16, 1958, AND NUMBERED 18298-B, ;HEETS I THROUGH 6 INCLUSIVE, ALL AS MODIFIED AND APPROVED BY THE OURT, A COPY OF A PORTION OF WHICH IS FILED IN NORFOLK REGISTRY iISTRICT WITH CERTIFICATE NO. 69622, 90CK 349.

'OR TITLE REFERENCE, SEE CERTIFICATE OF TITLE NO. 74465, FILED IN .EGISTRATION BOOK 373, PAGE 65.

.ARCEL 12:

A CERTAIN PARCEL OF LAND IN THE COKMONWEALTH OF 1ASSACHUSETTS, COUNTY OF NORFOLK, CITY OF QUINCY, SITUATED ON lAWRENCE STREET, CHASE STREET, CHECKER STREET, AND CLEVERLY COURT IND IS SHOWN ON SAID PLAN, DATED OCTOBER 15, 1986, DRAWING :50.101M.

CONTAINING 7,381 SOUARE METERS, MORE OR LESS, OR 79,448 SQUARE FEET, I DRE OR LESS, OR 1.824 ACRES, MORE OR LESS.

!DR T:TLE REFERENCE, SEE DEED FROM BETHLEHEM STEEL COMPANY DATED LECEMBER 31, 1963, RECORDED AT BOOK 4132, PAGE 459.

INRCEL 13;

A CERTAIN PARCEL OF LAND IN THE COMMONWEALTH OF MASSACHUSETTS, CDUNTY OF NORFOLK, CITY OF QUINCY, SITUATED ON SOUTH STREET AND CLEVERLY COURT AND IS SHOWN ON SAID PLAN, DATED OCTOBER 15, 1986, [RAWING 150.101M.

C)NTAINING 11,485 SQUARE METERS, MORE OR LESS, OR 123,625 SQUARE FEET, Y)RE OR LESS, OR 2.838 ACRES, MORE OR LESS.

F)R TITLE REFERENCE, SEE DEED FROM BETHLEHEM STEEL COMPANY DATED CEEMBER 31, 1963, RECORDED AT BOOK 4132, PAGE 459.

PRCEL 14:

A CERTAIN PARCEL OF LAND IN THE COMMONWEALTH OF M\SSACHUSETTS, COUNTY OP NORFOLK, CITY OF QUINCY, SITUATED ON W\SHINGTON STREET AND READ AVENUE AS SHOWN ON SAID PLAN, DATED O:TORER 15, 1986, DRAWING 150.111M.

C)NTAINING 4,865 SQUARE METERS, MORE OR LESS, OR 52,367 SQUARE F2ET, MORE OR LESS, OR 1.202 ACRES, MORE OR LESS.

- 5 FAX NO. 61 16200 P.11 MAY-09-96 THU 11:27 WRj34 3rd FLR RECP

1ER TITLE REFERENCE, SEE DEED FROM THOMAS F. DRAPER DATED NJVEMBER 29, 1968, RECORDED AT BOOK 4560, PAGE 223; DEED FROM EECTOR A. FRAZ:ER DATED MARCH 4, 1969, RECORDED AT BOOK 4579, E\GE 87; AND DECD FROM MADELINE FRAZIER DATED MARCH 4, 1969, RWCORDED AT BOOK 4579, PAGE 88.

EkRCEL 15:

A CERTA:N PARCEL OF LAND IN THE COMMONWEALTH OF MtSSACHUSETTS, COUNTY OF NORFOLK, CITY OF QUINCY, SITUATED ON S )UTH STREET, READ AVENUE, WASHINGTON STREET, AND NASH AVENUE AND I: SHOWN ON SAID PLAN, DATED OCTOBER 15, 1986, DRAWING 150.111M.

C'NTAINING 8,147 SQUARE METERS, MORE OR LESS, OR 87,688 SQUARE F.:ET, MORE OR LESS, OR 2.013 ACRES, MORE OR LESS.

IlICLUDED AS PART OF THE ABOVE-DESCRIBED PARCEL 15 IS A PARCEL OF RIGISTERED LAND BEING SHOWN AS LOT B ON LAND COURT PLAN 10629B, A CCPY OF A PORTION OF WHICH IS FILED WITH CERTIFICATE NO. 16150, RIGISTRATION BOOK 81.

F(R TITLE REFERENCE, SEE CERTIFICATE OF TITLE NO. 117791, FILED It REGISTRATION BOOK 589, PAGE 191; DEED FROM BETHLEHEM STEEL CCMPANY DATED DECEMBER 31, 1963, RECORDED AT BOOK 4132, PAGE 459; DEED FROM ADELE M. FERRIS DATED APRIL 10, 1967, RECORDED AT BOOK 4419, PAGE 599: DEED FPOM JOHN A. MORRISON AND WINIFRED J. MCIRISON DATED APRIL 10, 1967, RECORDED AT BOOK 4419, PAGE 600; DED FROM ROBERT J. GILMORE AND ELAINE M. GILMORE DATED JUNE 9, 1957, RECORDED AT 200K 4434, PAGE 109; DEED FROM MARIE NORCOTT DArED JULY 10, 1967, RECORDED AT BOOK 4441, PAGE 440; AND DEED FR)M ARMAND F. BRODEUR AS TRUSTEE OF THE RONALD BRODEUR TRUST, AN) RONALD J. BRODEUR AND ANNA M. BRODEUR, DATED JULY 22, 1967, RE:ORDED AT BOOK 4445, PAGE 299.

- 6 - MAY-09-96 THU 11:27 MWRj4 3rd FLR RECP FAX NO. 6172416200 P.12

EXI-UBIT B

Parcel Four

A certain parcel of land in The Commonwealth of Massachusetts, County of Norfi 1k, Town of Braintree, situated on Lancaster Road, and shown on drawing 150.0 .IM of a plan of land entitled "General Dynamics Quincy, MA. and Braintree, MA." (consisting of a Plan Index and fourteen drawings numbered 150.011M to 150.1 1M, inclusive, but excluding 150.081M) dated October 15, 1986 and November 4, 191 6, as revised, by New England Survey Service, recorded November 16, 1987 in Plan look 361 as Plan #1372 of 1987, Sheets 1-15.

Containing 1,301 square meters, more or less, or 14, 000 square feet, more or less.

Said parcel is identified as Parcel 4 in Exhibit A of the deed of General Dyna nics Corporation to Massachusetts Water Resources Authority dated Nove nber 16, 1987 and filed with the Norfolk County Registry District of the Land Cour as Document No. 535415 and recorded with the Norfolk County Registry of Deed; in Book 7803, Page 211. Said parcel is further described as Parcel 4 on Exhibit A-1 I ereto. MASSACHUSETTS WATER RESOURCES AUTHORITY S>L, Charlestown Navy Yard 100 First Avenue i Massachusetts 02129 Telephone: (61 ~1 242-6000 Facstmile: 617 241-6070 April 9, 1996

Subject: The sale of 130 acres at the Quincy Ship Yard from the Massachusetts Water Resources Authority (MWRA) to Massachusetts Heavy Industries (MHI)

Dear Environmental Reviewer:

Enclosed please find one (1) copy of the Environmental Notification Form (ENF) for the MWRA's sale of 130 acres at the Quincy Ship Yard to Massachusetts Heavy Industries. The ENF was submitted to the Massachusetts Environmental Policy Act (MEPA) Unit on April 10, 1996 and will be noticed in the next issue of the the Environmental Monitor.

Please review this document and forward any comments to the Secretary of Environmental Affairs , 100 Cambridge Street, 20th Floor, Boston, MA 02202, Attention: MEPA Unit. If you have any questions or require additional information, please call me at (617) 241-2765.

Sincerely,

Marianne Connolly Program Manager, Regulatory Compliance

Massachusetts e-,hipo I I Heavy Industries Inc. enc. SoTiKIS (. EXINIANI T. NVA' -todsus President

PMPusradhe Rd . Suie I 2s on *Wvbon MA)?X) 2001 MaiIpScoI. I MA 01907- (901) r~~Viijx QMv ri-I (0bI ') .17!1 24(9 1:j, ((!)1-) 1J 2475 EN VIKUNMtN I AL 1* 1 ik-iCA I lON 1-OM

Massachusetts Water Resources Authority (MWRA) sale of a SUMMARY portion of the Quincy Shipyard to Massachusetts Heavy A. Project Identification Industries (MHI) 1. Project Name - Ouincy Fore River Shipyard Address/Location East Howard Street

City/Town __ Ouiney and Braintree 2. Project Proponent. MHI and MWRA Address 1 3. Est. Commencement June 1996 . Est. Completion Approx. Cost $ 145M _.. Status of Project Design %Complete. 4. Amount (if any) of bordering vegetated wetlands, salt marsh, or tidelands to be dredged, filled, removed, or altered (other than by receipt of runoff) as a result of the project. acres square feet. 5. This project is categorically included and therefore requires preparation of an EIR. Yes - No X ? B. Narrative Project Description Describe project and site.

Massachusetts Heavy Industries (MH1) proposes to buy approimately 130 acres at the former General Dynamics Shipyard in Quincy and Braintree, now referred to as the Fore River Staging Area (FLSA) (see Figure 1). The entire 130 acre shipyard is owned by the Massachusetts Water Resources Authoritj (MWRA). HI is in the process of applying for federal loan guarantee from MARAD (the Maritime Administration in Washington, D.C.) Federal loan guarantees are available for site impravements (S30 million) and ship construction (S200 milion). The 130 acres includes the fve dry docks, the wet basin, approximately 42 buildings and numerous cranes including the Goliath (see Figure 2).

A purchase and sale agreement has to be executed by both parties and a dosing date on or near June 30, 1996 is anticipated. MHI intends to spend the first year renovating the site and then constructing double hulled tankers for a foreign entity. (Continued on next page)

Copies of the complete ENF may be obtained from (proponent or agent): Name: Marianne Connolly Firm/Agency: Mass. Water Resources Authority Address: 100 First Ave., .Charlestown Phone No. (617) 241-2765 MA 02129

1987 THIS IS AN IMPORTANT NOTICE. COMMENT PERIOD IS UMITED. For Information, call (617) 727-5830 (continued from previous page)

This intended use is compatible with the master plan that was completed in 1994 for the site. The planning process was carried out over two years through the joint efforts of Quincy, Braintree, Weymouth, CZM and MWRA. The shipyard is part of a Designated Port Area (DPA) and has had marine industrial uses at the site since the late 1800's. The shipyard employed 4200 workers in July 1985 when the shutdown of the yard was announced by the previous owner, General Dynamics.

The current owner, MWRA, uses approximately 40 acres of the overall site for the Boston Harbor Project (BHP). MWRA purchased the site in November 1987, and in 1988 completed the facilities planning and environmental impact review for the construction and staging facilities as part of the BHP. MWRA expects passage of recently filed state legislation which would allow the purchase of 130 acres at this site.

Ia. C. Ust the State or Federal agencies from which permits or other actions have been/will be sought: Agency Name Permit Date filed; file no. MHI will be responsible for obtaining all applicable local, state and federal environmental permits, which may Include but not be limited to Notices of Intent, Water Quality Certifications, hazardous materials handling approvals, Section 404, etc. as a term of the sale.

D. List any government agencies or programs from which the proponent will seek financial assistance for this project: Agency Name Funding Amount

Maritime Administration, $230 M in federal loan guarantees for Washington D.C. - site upgrade & construction of ships.

E. Areas of potential impact (complete Sections H and II rst, before completing this section). 1. Check all areas in which, in the proponent's judgment, an impart of this project may occur. Positive impacts, as well as adverse impacts, may be indicated.

Construction Long Term Impacts Impacts Iniand Wetlands...... Coastal Wetlands/Beaches ...... ridelands.....(fU111*)...... x T raffic ...... x Open Space/Recreation ...... Historical/Archaeological ...... Fisheries/W ildlife ...... Vegetation/Trees ...... Agricultural Lands ...... x W ater Pollution...... Water Supply/Use ...... Solid W aste...... X Hazardous Materials...... X A ir Pollution ...... Noise ...... W ind/Shadow ...... ,...... Aesthetics ...... Growth Impacts...... Community/Housing and the Built Environment ...... Other (Specify) Revitalization of Designated Port Area X (positie)

2. List the alternatives which have been considered.

The No Action alternative was considered, which would result in the continued underutilization of a unique shipyard resource which had been a source of skilled jobs and regional investment for the past century. Source: MWRA. P.3

F. Has this project been filed with EOEA before? No I Yes EOEA No. ENF 7280 was riled in August of 1988. At that time, the MWRA intended to sign a lease with the Massachusetts Land Bank who would then sublease to the MSala Sipbuilder Corp. to restor and operate a shipbuilding and repair facility on approximately 50 acres. The lease was never executed. Sourc MWRA. G. WETLANDS AND WATERWAYS

1. Will an Order of Conditions under the Wetlands Protection Act (c.131s.40) or a License under the Waterways Act (c.91) be required? Estin Ch. 91 Ucenses allow Yes - oNoX g 2. Has a local Order of Conditions been: for shipbuilding and related uses. a. issued? Date of issuance ; DEQE File No. . Source: DEP. b. appealed? Yes _ ; No X . 3. Will a variance from the Wetlands or Waterways Regulations be required? Yes : No X

II. PROJECT DESCRIPTION

A. Map; site plan. Include an original 8% x 11 inch or larger section of the most recent U.S.G.S. 7.5 minute series scale topographic map with the project area location and boundaries clearly shown. If available, attach a site plan of the proposed project.

See Figures 1 and 2

B. State total area of project: . 130 acres. Estimate the number of acres (to the nearest 1/10 acre) directly affected that are currently: 1. Developed ...... 130 acres 6. Tidelands ...... 6. acres 2. Open Space/ 7. Productive Resources Woodlands/Recreation - acres Agriculture ...... acres 3. W etlands ...... acres Forestry ...... acres 4. Floodplain ...... 60 acres 8. Other ...... acres 5. Coastal Area ...... A; acres

C. Provide the following dimensions, if applicable: Exisring Increase Total Length in miles ...... N/A N/2.LA N/A Number of Housing Units ...... NIA N/A N/A N um ber of Stories ..... ,...... - - 1-3 Gross Floor Area in square feet ...... Number of parking spaces ...... Total of Daily vehicle trips to and from site (Total Trip Ends) ...... 100-200 100-2000 200-2200 Estimated Average Daily Traffic on road(s) serving site ......

2. 3.

C. * Actual trip generation will depend on MH's final pla. Start-up (estimated for June 96) will involve approximately 50 employees. Eventually, 1000 employees are expected in May 97. Source: MI D, TRAFFIC PLAN. If the proposed project will require any permit for access to local roads or state highways. attach a sketch showing the location and layout of the proposed driveway(s) i1l. ASSESSMENT OF POTENTIAL ADVERSE ENVIRONMENTAL IMPACTS

Instructions: Explain direct and indirect adverse impacts, including those arising from general construction and operations. For every answer explain why significant adverse impact is considered likely or unlikely to result. Positive impact may also be listed and explained. Also, state the source of information or other basis for the answers supplied. Such environmental information should be acquired at least in part by field inspection.

A. Open Space and Recreation I. Might the project affect the condition, use, or access to any open space and/or recreation area? No. The site is located within a Designated Port Area. There are no open space and/or recreation areas that would be affected. Source: Massachusetts Coastal Zone Management Atlas, 1977. 2. Is the project site within 500 feet of any public open space, recreation, or conservation land?

No. The site is not located within 500 feet of any public open space or conservation area. However, a Shipbuilding Museum located within the Shipyard is approximately 1500' outside the MHI boundary. Source: MWRA. B. Historic and Archaeological Resources 1. Might any site or structure of historic. significance be affected by the project? (Prior consultation with Massachusetts Historical Commission is advised.) Yes. The FRSA meets the criteris of eligibilty for hling in the Natiosma Register of Istor Places ass historic district. The proposed use of the mite (ehIpbuildIng)l's -mtt wit the previous historic - at the site. MI proposes demoldon of som buidings at the it. A complete lstori Survey w completed Is I99. The MWRA and MHC cmde to work closely n mater Mted to this sle. The MWIA ha. submitted the list of buildings for demoetuon to the MHC to begI, the review pros Senreem MWRA, MHC. 2. Might any archaeological site be affected by the project? (Prior consultation with Massachusetts Historical Commission is advised.) There is a known trilobite quarry under the wet basin. Since no excavation is proposed, no impacts are expected. Source: MWRA, MHC.

C. Ecological Effects 1. Might the project significantly affect fisheries or wildlife, especially any rare or endangered species? (Prior consultation with the Massachusetts Natural Heritage Program is advised). No. There are no known rare or endangered species at the site. Source: Massacbusetts Natural Heritage Atlas, 1995 Edition. P.5

2. Might the project significantly affect vegetation, especially any rare or endangered species of plant? (Prior consultation with the Massachusetts Natural Heritage Program is advised.) (Estimate approximate number of mature trees to be removed. ) No. There are no known rare or endangered species of plant at the site. Source: Massachusetts Natural Heritage Atlas, 1995 Edition.

3. Agricultural Land. Has any portion of the site been in agricultural use within the last 15 years? If yes, specify use and acreage. No. The site had been used for maritime industrial uses associated with shipbuilding for over 100 years. More recently, the MWRA acquired the site to host activities (construction staging and RO/RO) related to the Boston Harbor Project. Source: MWRA.

D. Water Quality and Quantity 1. Might the project result in significant changes in drainage patterns? No. Shipbuilding will occur at existing facilties (dry docks, basins, buildings) at the site, therefore, no significant changes to the drainage patterns are proposed.

2. Might the project result in the introduction of any pollutants, including sediments, into marine waters, surface fresh waters or ground water?

No. Ther wil be no introduction of pollutants into marine waters or ground water. Source: MH I.

3. Does the project involve any dredging? No X Yes -Volume -. If 10,000 cy or more, attach completed Standard Application Form for Water Quality Certification, Part 1(314 CMR 9.02(3), 9.90, DEQE Division of Water Pollution Control). 0 P.6 0

4. Will any part of the project be located in flowed or filled tidelands, Great Ponds, or other waterways? (Prior consultation with the DEQE and CZM is advised.) Yes. Approximately 50% of the site is located In filled tidelands. The site is located within the Weymouth Fore River Designated Port Area intended to reserve deep water port areas for maritime uses. Source: DPA map.

5. Will the project generate or convey sanitary sewage? No - Yes I If Yes, Quantity: gallons per day - Disposal by: (a) Onsite septic systems ...... Yes - No . (b) Public sewerage systems (location; average and peak daily flows to treatment works) ...... Yes . No - Explanation and Source: Yes. At start-up, approximately 50 employees are likely to generate 1000 gallons per day (gpd). At peak (1000 employees) the amount could increase to 20,000 gpd. Source: DEP Sewage Flow factors, 310 CMR 15.00 State Env. Code, TitleS. Source: MH[ and MWRA.

6. Might the project result in an increase in paved or impervious surface over a sole source aquifer or an aquifer recognized as an important present or future source of water supply? Explanation and Source:

No. The site is not located over a sole source aquifer. Source: MWRA.

7. Is the project in the watershed of any surface water body used as a drinking water supply? Explanation and Source: No. The site Is not in the watershed of any surface water body used as a drinking water supply. Souirce: MWRA.

8. Are there any public or private drinking water wells within a 1/2-mile radius of the proposed project? Explanation and Source: No. The site is located in an area served by the MWRA. No drinking water wells are within a 1/2 - mile radius of the project site. Source: MWRA. - 0 P.7

9. Does the operation of the project result in any increased consumption of water? Approximate consumption gallons per day. Likely water source(s) Explanationand Source:

Yes. Start-up (50 employees) will result in approximately1000 gpd. It is estimated that each employee win use 20 gpd. At peak, (1000 employees) it is estimated to be 20,000 gpd. Source: MHI and MWRA.

E. Solid Waste and Hazardous Materials 1. Estimate types and approximate amounts of waste materials generated, e.g., industrial, domestic, hospital, sewage sludge, construction debris from demolished structures. How/ where will such waste be disposed of?

Demolition debris, if any, may include asbestos-containing building materials, Such debris would consist primarily of non-friable asbestos siding. Potential sources of friable asbestos wase may include electrical manholes and underground electrical conduits. All asbestos would be abated and disposed of in full accordance with al applicable Federal, state and local regulations. Source: MWRA and MHL

2. Might the project involve the generation, use, transportation, storage, release, or disposal of potentially hazardous materials? Explanationand Source:

On-site excavation activities may generate contaminated surplus soils. Such soils will be managed in accordance with MCP.

Source: MWRA.

3. Has the site previously been used for the use, generation, transportation, storaqe. release. or disposal of potentially hazardous materials? The FRSA has been used a a maritime industrial site for over 100

. ------years.Several investgative and remedial actions have been taken at Arange of containants were discovered in locized areas of the usdre 130 acres including low levels of chlorinated solvents, eral spirits, metals and pesticide constituents in groundwater samples at Isolated areas of the site, PCB contaminated soils adacent to ing former transformers, and a plume of 12 hal oil in soils adjacent to Bll. Ra=dial cleanup acdons completed under DEP ew included the removal of hael tanks, PCB contaninated soils above 40 ppm, and htiltatimo of an oi recovery system. Under the a of the salt of the shipyard to MWRA, General Dynamics (G.D.)agreed to complete sme bazardous waste remediation that left the ean to an industrial standard. Under the terms-of a Waiver of Approvals isued to G.D.and MWRA in March 94, Waiver Conpletion anents pertaining to the above areas of contamination will be submitted to DEP. Source: MWRA. F. Energy Use and Air Quality 1. Will space heating be provided for the project? If so, describe the type, energy source, and approximate energy consumption. Explanation and Source:

Natural gas service is available and will likely be the source of energy. Source: MHL 0 P.8

2. Will the project require process heat or steam? If so, describe the proposed system, the fuel type, and approximate fuel usage. Explanation and Source:

Natural gas service is available and will likely be the source of energy. Source: MHL

3. Does the project include industrial processes that will release air contaminants to the atmosphere? Ifso, describe the process (type, material released, and quantity released). Explanation and Source Industrial processes that might release air contaminants on a localized basis Include painting with lead-bee paints and steel cutting and fabrication activities Involving combustion of oxy-acetylene gases. Good shipguiding practices will be utilized to minimize adverse impacts on air quality in the immediate work environment, in compliance with DEP and/or OSHA requirements. Source: MHI 4. Are there any other sources of air contamination associated with the project (e.g. automobile traffic, aircraft traffic, volatile organic compound storage, construction dust)? Explanation and Source

No. There are no know sources of air contamination associated with this project. Any potentially contaminated dust associated with excavation of contaminated soils wil be monitored and managed in accordance with existing environmental regulations. Source: MWRA and MHI S. Are there any sensitive receptors (e.g. hospitals, schools, residential areas) which would be affected by air contamination caused by the project? Explanation and Source:

No. There are no sensitive receptors that would be affected by air contamination caused by the project. Source: MWRA.

G. Noise 1. Might the project result in the generation of noise? (Include any source of noise during construction or operation, e.g., engine exhaust, pile driving, traffic.) Explanation and Source: Noise associated with routine shipbuilding activities can be expected. Source: MI P.9

2. Are there any sensitive receptors (e.g., hospitals, schools, residential areas) which would be affected by any noise caused by the project? Explanation and Source:

No. There are no sensitive receptors that would be affected by noise generated frn the site. Source: MWRA.

3. Is the project a sensitive receptor, sited in an area of significant ambient noise? Explanation and Source:

No. The project Is not-a sensitive receptor. Source: MWRA

H. Wind and Shadow 1. Might the project cause wind and shadow impacts on adjacent properties? Explanation and Source: acres. There will No. The former shipyard site is 180 acres. MHI proposes to buy 130 not be any wind and shadow impacts on adjacent properties. Source: MWRA.

1. Aesthetics 1. Are there any proposed structures which might be considered incompatible with existing adjacent structures in the vicinity in terms of size, physical proportion and scale, or significant differences in land use? Explanation and Source: No. Some new construction may be proposed but it will be compatible with shipbuilding related activities. Source: MHI and MWRA.

2. Might the project impair visual access to waterfront or other scenic areas? Explanation and Source: Nu. No new major contruction (tall buildings) is proposed for the site. P.10 0

IV. CONSISTENCY WITH PRESENT PLANNING

Discuss consistency with current federal, state and local land use, transportation, open space, recreation and environmental plans and policies. Consult with local or regional planning authorities where appropriate.

This project is consistent with federal, state and local environmental policies. In particular, it is consistent with state Waterways and Coastal Zone Management Policy Number 7 which encourages the location of maritime commerce and development in segments of urban waterfronts Designated as Port Areas (DPA).

The sale is consistent with the master plan for the long term use of the site. The master plan was developed in a cooperative manner with the City of Quincy, Town of Braintree and Weymouth, the MWRA and CZM. Since the site is a DPA, it is appropriate to achieve optimum utilization of the industrial port facilities. The reopening of the shipyard will restore at least 1,000 jobs and associated investment in the regional maritime economy.

V. FINDINGS AND CERTIFICATION

A. The public notice of environmental review has been/will be published in the following newspaper(s):

Patriot Ledger submitted week of April 8, 1996 (NAME) (Date)

B. This form has been circulated to all agencies and persons as required by 301 CMR 11.24.

Sv wt sponsible Officer Date Signature of person preparing or Project Proponent ENF (if different from above) Sotirios Emmanouil Douglas B. MacDonald President Executive Director

Mass. Heavy Industries. Inc. Mass. Water Resourtes Audh. 505 Paradise Road, Suite 123 100 First Avenue Swappscott, MA 01970-0901 Charlestown, MA 02129 {6171 471-2409 (617) 242-6000 AMOUTH, MASSACHUSESR 7 G 736 xE ( wKgvrowunFsrA TFP or - Town River 67 oo -st Shipyard

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0, CIRCULATION LIST

Greg Spakman Ms Judith McDonough Maritime Administration Mass Historical Commission 400 7th Street 220 Morriusey Blvd. Washington, D.C. 20590 Boston, MA 02125

Environmental Reviewer Executive Office of Communities Division of Marine Fisheries and Development 100 Cambridge Street, 19th Hoor State Clearinghouse Boston, MA 02202 100 Cambridge Street, Rm 1803

Boston, MA 02202 Ms. Jane Meud Project Review Coordinator Mr. Steve Lipman Coastal Zone Management Dept of Environmental Protection 100 Cambridge Street, 20th Floor One Winter Street Boston, MA 02202 Boston, MA 02108

Ms. Trudy Core Mr. Dave Kennedy Secretary of Environmental Affairs Dept. of Environmental Protection 100 Cambridge Street, 20th Hoor Division of Waterways Boston, MA 02202 One Winter Street Attention: MEPA Unit Boston, MA 02018

Environmental Reviewer Environmental Reviewer Massachusetts Bay Transit Authority MED - District #4 10 Park Plaza, 6th Hoor 519 Appleton Street Boston, MA 02216-3966 Arington, MA 02174

Mr. Richard Mead Mr. Jim Sprague Quincy Planning Office DEP/NE Regional Office City Hall 10 Commerce Way 1305 Hancock Street Woburn, MA 01801 Quincy, MA 02169 0 01 Ms. Heather Sargent Quincy Conservation Commission Metropolitan Area Planning Council City Hall 60 Temple Place 1305 Hancock Street Boston, MA 02111 Quincy, MA 02169

Mr. Alen Weinberg Braintree Conservation Commission Braintree Town Hai JFK Memorial Pkwy Braintree, MA 02184