Environmental Protection Northeast Regional Office Waiver Unit 10 Commerce Way Woburn, Massachusetts 01801

O 3-0 3 7I L< Nc~v'snSt MASSACHUSETTS WATER RESOURCES AUTHORITY

100 First Avenue

02 B n M a s ach use11ns 1,

October 20, 1995

Massachusetts Department of Environmental Protection Northeast Regional Office Waiver Unit 10 Commerce Way Woburn, Massachusetts 01801

Re: Waiver Submittals OCT 2 319% MWRA Fore River Staging Area (former General Dynamics Shipyard) DEP/ORTHEAST REGION RIN 3-0536 and 3-10266 WOBURN, MASS.

To whom it may concern.

Enclosed please find the following documents, which are submitted in accordance with the March 1994 Waiver of Approvals issued by the Department of Environmental Protection to the Massachusetts Water Resources Authority for the above-referenced site:

1. PEER Consultants, P.C., Phase I Site Investigation, 166 East Howard Street, Quincy, MA, October 14, 1994.

2. PEER Consultants, P.C., Phase I Site Investigation, 661 Washington Street, Quincy, MA, September 23, 1994.

3. PEER Consultants, P.C., Phase I Site Investigation, 12 - 34 Cleverly Court, Quincy, MA, January 13, 1995.

4. PEER Consultants, P.C., Phase I Site Investigation, 5 - 49 Cleverly Court. Quincy, MA, September 15, 1994.

5. PEER Consultants, P.C., Consultant's Determination for Premises Located at MWRA Fore River Staging Area, September 15, 1995.

6. Remedial Response Action Completion Statement, Former General Dynamics October 20, 1995 Page 2

Quincy Shipbuilding Facility: Off-site parcels, October 2, 1995.

In accordance with the Fore River Staging Area Public Involvement Plan, these documents were made available for public comment. Subsequent to the public comment period, the Consultant's Determination amending the Fore River Staging Area Notice of Land Use Stipulation was recorded in the Norfolk County Registry of Deeds as Document No. 81172 and in the Norfolk County Registry of the Land Court as Document No. 722351.

Thank you for your attention to this matter. If you have any questions regarding these submittals, please contact me at (617) 241-2759.

Very truly yours,

Mark Radville Program Manager, Real Property & Environmental Management cc: Maggie Debbie, MWRA, w/o enclosure Leon Lataille, MWRA, Sharon Gobiel, DEP/NERO, REMEDIAL RESPONSE ACTION COMPLETION STATEMENT

Do not send this form in with the application form. Detach this page and reserve it until the remedial response action Is completed. At that time, submit this statement to the Department. A. SITE INFORMATION:

Name of Disposal Site: Fomer General Dynamics - Quincy Shipbuilding Facility: Off-site parcels.

DEQE Site ID Number: 3-0536 and 3-10266

Address: 97 East Howard Street (STREET) Quincy MA 02169 (CITY/TOWN) (STATE) (ZIP CODE)

C. STATEMENT OF CONFORMANCE: Parcels 11, 12, 13, and 14 of MWRA . Fore River Staging Area (formerly I certify that the remedial action for General Dynamics Shipyard) has been (SITE NAME) completed in accordance with the approved waiver application dated November 23, 1993 (MONTH/DAYNEAR) M.G.L c. 21E, and the Massachusetts Contingen Plan.

(SIG ATURE OF APPLICANT/DATE)

D. STATEMENT OF COMPLETION:

Provide an opinion as to whether the remedial response action constitutes a permanent solution under M.G.L. c.21E and provide a basis for that opinion. This opinion must be signed by the applicant and the applicant's consultant. Additional site investigations determined that a level of No Significant Risk exists at each of the four off-site parcels, thus no remedial action was required. For this reason, it is our opinion a permanent solution has been attained.

(617) 242-6000 (SIGNAURE OF APPLICANT/DAT8) (PHONE NUMBER)

PEER Consultants, P.C. (NAME OF CONSULTANT FIRM) (SIGNATURE OF WPLICANT'S REMEDIAL RESPONSE Please Print ACTION CONSULTANT/ DATE) o-J 12. ISfrt

CONSULTANTS DETERMIN i 2 3 For Premises Located A E R DEP/NORTHEAST REGION MWRA Fore River Staging WOBURN, MASS. (Former General Dynamics 97 East Howard Street, Quincy, Massachusetts

DEP Release Tracking Nos. 3-0536 and 3-10266

Reference is hereby made to a Notice of Land Use Stipulation dated May 10, 1995, signed by the Massachusetts Water Resources Authority, and recorded on May 17, 1995 in the Norfolk County Registry Distric of Deeds as Document #36965 and in the Norfolk County Registry of the Land Court as Document #714486. 15&rX- I0C9R/ PAtE +4 PEER Consultants, P.C. ("PEER") the Consultant of Record for the Massachusetts Water Resources Authority (MWR A) has conducted Phase Site Investigations for parcels 11, 12, 13, and 14 of the "Property" as desc-ibed on Exhibit A of the Notice of Land Use Stipulation. The MWRA has, in accordance with the Waiier of Approvals granted by the Massachusetts Department of Environmental Protection ("DEP") in March, 1994 submitted the Phase I Site Investigations and Waiver Completion Statements to DEP. These documents were submitted for a 20-day public comment period and have been placed on record at the following FRSA Public Involvement Plan Information Repositories:

Thayer Public Library, 798 Washington Street, Braintree

Tufts Library, 46 Broad Street, Weymouth

Thomas Crane Public Library, 40 Washington Street, Quincy

Massachusetts Water Resources Authority Library, 100 First Avenue, Charlestown

In accordance with the Waiver of Approvals, 310 CMR 40.000 (the Massachusetts Contingency Plan, "MCP"). and M.G.L. c21E, PEER has determined that environmental conditions at parcels 11, 12, 13, and 14 of the Property do not pose a significant risk of harm to health, safety, public welfare, or the environment, and that no further remedial actions are necessary. Therefore, PEER has determined that from and after the date hereof, parcels 11, 12, 13, and 14 of the Property shall no longer remain subject to any of the restrictions imposed on the remainder of the Property by the above referenced Notice of Land Use Stipulation, including their being limited to industrial or business office use. Use of the parcels may include but need not be limited to residential development. Subsurface construction activities thereon may be completed without the requirement for a hazardous materials management plan. Executed on this F , day of September, 1995.

PEER Consultants, P.C.

BY: Elissa J. Brown, Senior Environmental Scientist

COMMONWEALTH OF MASSACHUSETTS

MIDDLESEX COUNTY September\ S , 1995

Then personally appeared the above-named Elissa J. Brown, Senior Environmental Scientist of PEER Consultants, P.C. and acknowledged the foregoing to be the free act and deed of PEER Consultants, P.C.

\Y' \'L~, Notary Public

My Commission Expires: ro \i> I 0

CERTIFICATION OF VOTE OF AUTHORIZATION

Date:

I hereby certify that a meeting of the Board of Directors of PEER Consultants, P.C., duly called and held at Rockville, Maryland, at which time a quorum was present and acting, it was voted that Elissa J. Brown, a duly qualified and acting Senior Environmental Scientist of the Corporation, be and hereby is authorized to execute and deliver for in behalf of the

Corporation, a so-called "Consultant's Determination" for the Massachusetts Water

Resources Authority which was presented to and made a part of the records of said meeting.

I further certify that said vote has not been repealed, rescinded, or amended. A true copy of the record,

ATTEST:

C fhe Corporation

(Corporate Seal) MASSACHUSETTS WATER RESOURCES AUTHORITY AI- Charlestown Navy Yard 100 First Avenue Boston, Massachusetts 02129 -6000 H ~Telephone: (617) 242-60 N'J Facsimile: (617) 241-6070

July 21, 1995

PUBLIC NOTICE RE: WAIVER SUBMITTAIS; SUPPLEMENTAL SITE ASSESSMENT and RISK CHARACTERIZATION MWRA Fore River Staging Area (former General Dynamics Shipyard) Release Tracking Numbers 3-0536 and 3-10266

Dear Interested Party:

Please be advised that Green Environmental, Inc., the Consultant of Record for the Massachusetts Water Resources Authority (MWRA) through the U.S. Naval & Shipbuilding Museum (USNSM), has, in accordance with the Waiver of Approvals granted by the Massachusetts Department of Environmental Protection ("DEP") in March, 1994, prepared a Supplemental Site Assessment and Risk Characterization, a Remedial Response Action Completion Statement, and Consultant's Determination pertaining to one portion of the parcel leased by the USNSM from the MWRA at the MWRA's Fore River Staging Area (FRSA), 97 East Howard Street, Quincy, Massachusetts.

The Supplemental Site Assessment and Risk Characterization, Remedial Response Action Completion Statement, and Consultant's Determination are available for public review and comment 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

Massachusetts Water Resources Authority Library, 100 First Avenue, Charlestown

Prited 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 publi' WuHCHL period will expire on August 11, 1995.

DISTRIBUTION: FRSA PIP Mailing List

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W- Commonweath of Massachusetts Execulive Office of Envronmental Affairs Department of Environmental Protection William F. Weld Trudy Coxe scray. EOEA David B. Struhs Commi~ssIoner

MEMORANDUM

To: John viola, Co

From: Steve Lipman

Date: May 26, 1995 Subject: Fore River Staging Area, Maritime Museum and U.S.S. Salem ------

Museum) On May 25th this writer met with Bill McMullen (Director of Maritime and MWRA staff to and a representative from his 21E consultant, Green Environmental, U.S.S. Salem docked at discuss opening of the Museum with its public access to the

extensive discussions of pier 4 of MWRA's FRSA (see figures 2, 3 and 6). After allow for various options the following plan was agreed to which will hopefully

Saturday May 27th for the opening of the Museum and public access to the ship on

Memorial Day Weekend.

May by overnight express (by close of business (1) Green Environmental will mail

25th) copies of their supplemental Site Assessment/Risk characterization the conclusion report (MWRA staff have reviewed the document and concur with

including; David of no significant risk) to the six key local players,

Standley (consultant to Quincy), June Gallahue (Quincy Health Department),

Mayor James Sheets (Quincy) and officials from Weymouth and Braintree;

each of the six (2) MWRA staff will call (by close of business May 25th) the Green individuals above and explain the plan and let them know that review; Environmental documents are on their way and to request expedited

for inclusion with their (3) MWRA will prepare and FAX to Green Environmental the documents and contact report a brief letter requesting expedited review of agreement to to staff MWRA ASAP if reviewers have any problems with MWRA's that a allow Saturday opening of the Museum/ship. Letter would also explain

place mass mailing from MWRA to the full PIP mailing list is proposed to take

next Tuesday concurrent with Green's submission of their report and for the full 20- supplemental information to the local repositories, providing

day PIP comment period;

players in (1) (4) Green Environmental will FAX on Friday May 26th to the six key the above copies of the EPA approval letter allowing for the public to board final U.S.S. Salem (assumption is that EPA will issue the letter on May 26th),

which had been mailed site sampling lab results, and a summary of the report

on Thursday;

May 26 (to MWRA's (5) McMullen will have the site fencing completed on Friday

satisfaction);

292-5500 One Winter Street * Boston, Massachusetts 02108 e FAX (617) 556-1049 * Telephone (617)

%0 qt) 1kr-kdar 2.

(6) If (1) through (5) are completed, by close of business May 26th, MWRA will send a letter to the six key players stating that MWRA is satisfied that all required actions have been satisfactorily completed (fencing, EPA approval, and report finalization) and that they are authorizing opening of Museum on May 27th concurrent with the 20-day PIP public review process, kgl that if any comments are filed with MWRA which are deemed to be significant, MWRA will require immediate closure of the Museum (Bill McMullen agreed to this condition) at least until the full 20-day comment period expires and MWRA (and/or) Green responds to issue raised during that process.

I indicated that this action is MWRA's call, in that the FRSA is a Waiver Site, but that I concurred with this process. All documents/correspondence will also be sent to me and I will keep relevant DEP players informed of any further actions in this regard.

I believe this plan is reasonable and complies with the spirit and intent of the 21E Waiver and PIP requirements, while allowing the Museum to open for the Memorial Day Weekend.

cc: Ed Kunce Dick Chalpin and Sharon Gobiel (BWSC)

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4 ze 0d Commonwealth of Massachusetts DepartmentExecutive Office of Environmental of Affairs Environmental Protection William F. Weld Govermor Trudy Coxe Secretary, EOEA David B. Struhs Commissioner May 19, 1995

Mr. Robert White General Dynamics 116 East Howard Street Quincy, MA 02169 RTN: 3-10266 RO CITY: Quincy RO ADDR: 97 East Howard Street RE: M.G.L. c.21E, 310 CMR 40.0000 Annual Compliance Assurance Fee

Dear Mr. White:

This letter regards the Annual Compliance and Assurance Fee associated with the above-referenced release (or threat of release) which was reported to the Department of Environmental Protection (Department).

As you are aware, a letter and invoice requesting payment of the $2600 Annual Compliance and Assurance Fee was issued to you, or your representative, in the past weeks. Upon further review of the file, the Department has determined that the Fee is inapplicable and will therefore be waived in this specific instance.

The regional office which handles your subject release has been informed of this decision. Please be advised that this letter in no way releases you from responsibility for the release or any other submissions which may be required by the Department. Please be sure to retain this letter for your records.

Should you have any further questions pertaining to billing of Annual Compliance Fees, please contact my office at (617)292-5545. Specific questions concerning remediation should be addressed to the appropriate regional office. Thank you.

Sincerely

Robert P. lagha , Acting Director Division o Fi al Management, Cost Recovery and Administration Bureau of Waste Site Cleanup cc: Regional Office

One Winter Street * Boston, Massachusetts 02108 * FAX (617) 556-1049 * Telephone (617) 292-5500

Printed on Re, ychd Paper MASSACHUSETTS WATER RESOURCES AUTHORITY Charlestown Navy Yard 100 First Avenue Boston, Massachusetts 02129 Telephone t617) 242-6000 Facsimile. (617) 241-6070

May 10, 1995 PUBLIC NOTICE RE: WAIVER SUBMITTALS PHASE I SITE INVESTIGATIONS MWRA Fore River Staging Area (former General Dynamics Shipyard) Release Tracking Number 3-0536 and 3-10266

Dear Inteiested Party.

Please be advised that PEER Consultants, P.C. (PEER), the Consultant of Record for the Massachusetts Water Resources Authority (MWRA), has, in accordance with the Waiver of Approvals granted by the Massachusetts Department of Environmental Protection ("DEP") in March, 1994, prepared four Phase I Site Investigations, a Waiver Completion Statement, and a Consultant's Determination pertaining to certain parcels of the MWRA's Fore River Staging Area (FRSA), 97 East Howard Street, Quincy, Massachusetts. These Waiver Submittals address the following parcels, located in the City of Quincy outside the fenceline of the FRSA proper:

Parcel 11: 166 East Howard Street, Quincy, Massachusetts

Parcel 12: 12 - 34 Cleverly Court, Quincy, Massachusetts

Parcel 13: 5 - 39 Cleverly Court, Quincy, Massachusetts

Parcel 14: 661 Washington Street, Quincy, Massachusetts

The Phase I Site Investigations, Waiver Cnmpletion Statement, and Consultant's Determination are available for public review and comment 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

Massachusetts Water Resources Authority Library, 100 First Avenue, Charlestown

Printed on 100 Recycled Pape, 3-0516

Commonweath of Massachusetts Executive Office of Environmental Affairs Department of - Environmental Protection William F. Weld Governor Trudy CoeO David B. Strutis Conrrssborer May 1, 1995

Dear Interested Party:

The Massachusetts Department of Environmental Protection (DEP) will soon make available the Final Addendum to the 1993 Transition List of Confirmed Disposal Sites and Locations To Be Investigated. The Final Addendum completes the Transition List, which shows the status of each suspected or confirmed disposal site which was reported to DEP before October 1, 1993. Transition provisions in the Massachusetts Contingency Plan (310 CMR 40.0600) require certain actions to be taken at sites included in the Transition List, depending on the category in which they are listed.

Included in this publication is the location shown below (also noted is the category to which this site or location is assigned):

Our information indicates that you have a connection to this site or location as a landowner, facility owner or operator, generator or transporter of oil or hazardous material, or another type of connection. The MCP may be consulted for detailed information about specific requirements and deadlines for sites and locations in each category on the Transition List.

Copies of the Final Addendum will be available at the State Bookstore by May 8, 1995. To obtain a copy of the Final Addendum to the Transition List or the MCP, contact the State Bookstore at (617) 727-2834 or (413) 784-1378. Please direct questions about the Waste Site Cleanup Program to the MCP Hotline, part of DEP's InfoLine: from area code 617 and from outside of Massachusetts, call (617) 338-2255; from area codes 508 and 413, call 1-800-462-0444.

Sincerely,

jam s C Co an Assi tant Commissioner Bureau of Waste Site Cleanup

Enc.

one Winter Street * Boston, Massachusetts 02108 * FAX ('17) 556-1049 * Teephone (617) 292-5500 009 FOLEY, HOAG & ELIOT

ONE POST OFFICE SQUARE

BOSTON. MASSACHUSETTS 02109-2170 IN WASHINGTON DC TELEPHONE (617)32--1000

CABLE ADDRESS "FOLEYHOAG 161S L STREET, NW SUITE 850 032 700 1-ACSIMILE (617) WASHINGTON 0 C 20036 (202) 775 0600 TELEX 940693 TELEPHONE

April 28, 1995 VIA FEDERAL EXPRESS

Waiver Submittals Commonwealth of Massachusetts Department of Environmental Protection Northeast Regional Office Bureau of Waste Site Cleanup 10 Commerce Way Woburn, MA 01801 Re: MWRA Fore River Staging Area (former General Dynamics Shipyard) -- Central Yard Oil Plume DEP Waiver Site ID Numbers #3-0536 and #3-10266 Dear Madame or Sir: On behalf of General Dynamics Corporation, I am pleased to submit the following documents prepared by GZA GeoEnvironmental, Inc. ("GZA"), General Dynamics' Consultant of Record, regarding the above-referenced waiver site:

(1) A report entitled "Status Report of System Reconfiguration," dated April 25, 1995, for the Central Yard Oil Plume ("CYOP") area of the site; and (2) A report entitled "Building 66 Area Investigation," dated April 21, 1995, to further define the extent of separate phase hydrocarbons observed in the Building 66 area near the Central Yard Oil Plume (CYOP).

These submittals were prepared by GZA in accordance with the October 21, 1986 and September 20, 1987 DEP approvals of the Fuel Oil Recovery System for the CYOP. The DEP approvals require continuous assessment of system performance and adequacy and, if warranted, the recommendation of system modifications. The primary purpose of these submittals is to improve the understanding of existing site conditions after eight years of recovery system operations, as well as the efficiency of the CYOP recovery system.

The first report summarizes the results of the reconfiguration test of the existing recovery system with operation of 3 to 5 recovery wells on a trial basis. This test was conducted pursuant to GZA's recommendations in its December es e0 Waiver Submittal Department of Environmental Protection DEP Waiver Site ID Nos. #3-0536 and #3-10266 April 28 1995 Page 2

1994 Pump Testing Hydrogeologic Results Report previously submitted to DEP. The purpose of the reconfiguration was to improve the efficiency of the system while still recovering oil and maintaining containment of the plume. The monitoring results confirm that groundwater extraction from 3 particular recovery wells (RW-5A, RW-6 and RW-7A) was effectively containing the plume. However, because RW-3 and RW-4 produce oil, the product pumps and groundwater depression pumps in these wells were reactivated, for at least the near term, to maintain oil recovery capacity. In addition, GZA recommended adding a new well (GD-27150), which was installed as part of the Building 66 investigation, to be added to the list of CYOP monitoring wells. No separate phase hydrocarbons ("SPH") were not detected in this well, thus confirming that the plume does not extend east of this location. This well provides a monitoring point to the east of the CYOP where no such well previously existed.

The second report summarizes the results of work conducted by GZA to further define separate phase hydrocarbons observed around the Building 66 area near the southern portion of the CYOP. This was conducted pursuant to a Scope of Work entitled "Building 66 Area Investigation" prepared by GZA and submitted to DEP on December 12, 1994. The results of this investigation confirm that there is not an extended plume area south of the CYOP which would warrant and expansion of the current product recovery system. Although no SPH was detected in any of the newly installed wells, GZA recommends additional gaugings for SPH at these wells in June and September of 1995.

By copy of this letter, General Dynamics is also providing copies of these Waiver Submittals to the information repositories specified in the updated Public Involvement Plan, dated September, 1994.

Very truly yours,

Laurie Burt

KF Enclosures cc: Sharon G. Gobiel, DEP Robert F. White, GDC [w/o enclosures] Lawrence Feldman, GZA [w/o enclosures] s *9 Waiver Submittal Department of Environmental Protection DEP Waiver Site ID Nos. #3-0536 and #3-10266 April 28 1995 Page 3

Rhonda Russian, Esq., MWRA Jose Vincenty, MWRA Public Contact Person Thayer Public Library, Braintree Tufts Library, Weymouth Thomas Crane Public Library, Quincy C( 11%IT I )* A ,

April 25, 1995 File No. 11930.5

Mr. Robert F. White General Dynamics Corporation Gift 116 Howard Street Quincy, Massachusetts 02169

DEP WAIVER SITE ID NUMBER: 3-0536 and 3-10266 SnI Re: Status Report of System Reconfiguration Central Yard Oil Plume Former General Dynamics/Quincy Shipyard Quincy, Massachusetts

Dear Mr. White:

This letter report summarizes the current status of the oil recovery system at the Central Yard Oil Plume (CYOP) area of the former General Dynamics (GD) Corporation Shipyard (QSY) in Quincy, Massachusetts. As described in our December 1994 Pump Testing Hydrogeologic Results Report submitted to DEP, certain recommendations were made concerning the reconfiguration of the current recovery system. The purpose of the reconfiguration was to improve the efficiency of the system while still recovering oil and maintaining containment of the plume. The system reconfiguration was based on pump testing of varying configurations of the existing system; results were confirmed using a groundwater flow model.

As described in the December 1994 report, both field testing and groundwater modeling indicated that extraction from a combination of RW-5A, RW-6 and RW-7A would create a large enough capture area to contain the plume of SPH and continue to provide recovery of oil. However, because RW-3 and RW-4 produce oil (RW-3 produces the most oil at the CYOP), the recommendations considered utilizing the RW-3 and RW-4 product pumps only to recover more oil. This was considered prudent for at least the near term. The recommendations called for continued monitoring of oil recovery rates at RW-3 and RW-4; if oil recovery rates at these wells were significantly lower than with the groundwater pumps operating, then it was recommended to re-activate those groundwater pumps to develop better oil flow to those wells.

\ n% 1,.. k i - 1i 1. , r \ \ i General Dynamics Corporation April 25, 1995 File No. 11930.5 Page 2

Based on GZA's recommendations, the system was reconfigured by Groundwater Technology Incorporated (GTI). The following steps were taken: O nz January 9, 1995 All wells were monitored for SPH and groundwater level with all recovery wells active.

RW-1A, RW-2, RW-3A and RW-4 water pumps were deactivated. RW-IA and RW-2 product recovery pumps were deactivated.

January 9-20, 1995 Took daily groundwater elevation and SPH thickness measurements across site to estimate drawdowns and oil recovery at active wells.

January 23-February 3, 1995 Monitoring of system drawdowns and oil recovery continued at one-week intervals to assess whether system was working as anticipated.

February 3 to Present Monthly monitoring of SPH thickness and groundwater elevations.

The data developed from January 9th through February 2nd, indicated that groundwater extraction from RW-5A, RW-6 and RW-7A with all other recovery wells inactive, was effectively containing the plume. Groundwater elevation contours from January 17, 1995 illustrating this capture area are presented on Figure 1.

Because oil recovery in RW-3 had dropped off significantly, the groundwater depression pump at that well was reactivated on February 3, 1995. In addition, the groundwater depression pump at RW-4 was reactivated on March 31, 1995 to increase oil production. The system currently in operation thus includes groundwater and product pumps active in RW-3A, RW-4, RW-5A, RW-6 and RW-7A. Groundwater pumps in RW-3A and RW-4 are only active to recover more oil; as noted above, their operation is not necessary to contain the CYOP plume. Groundwater elevation contours from April 7, 1995 illustrating capture with five groundwater pumps active, are presented on Figure 2. Both groundwater and product pumps in RW- 1A and RW-2 are inactive.

Monthly monitoring, as required by DEP, continues as before, however, reporting will continue on a quarterly basis as specified in the December 5, 1994 Modification to Monitoring Program submittal to DEP. The selected wells for gauging of SPH 00 0

General Dynamics Corporation April 25, 1995 File No. 11930.5 Page 3

thickness and groundwater elevations will continue as before, however, we recommend adding a new well (GD-27150), which was drilled as part of the Building 66 Investigation, to be added to the list. This well provides a monitoring point to the east of the CYOP where such did not previously exist. SPH was not detected in this well, and thus continued monitoring confirms that the CYOP plume does not extend east of or' this location. Should you have any questions, please feel free to contact one of the undersigned.

Very truly yours

GZA GEOENVIRONMENTAL, INC. '7 V avid J. d1man Project Manager

Albert J. Ricciardelli Lawrence Feldm an Associate Principal Senior Principal

DJA/LF/AJR:idm/crp

cc: Laurie Burt, Esquire; Foley, Hoag & Eliot 0 0

FIGURES ATN 1 0

ATTACHMENT 1

LIMITATIONS g0 0

GEOHYDROLOGICAL LIMITATIONS

1. The conclusions and recommendations submitted in this report are based in part upon the data obtained from a limited number of soil samples from widely spaced subsurface explorations. The nature and extent of variations between these explorations may not become evident until further investigation. If variations or other latent conditions then appear evident, it will be necessary to reevaluate the recommendations of this report.

2. Water level readings have been made in the observation wells at times and under conditions stated on the exploration logs. These data have been reviewed and interpretations have been made in the text of this report. However, it must be noted that fluctuations in the level of the groundwater may occur due to variations in rainfall and other factors different from those prevailing at the time measurements were made.

3. Except as noted within the text of the report, no quantitative laboratory testing was performed as part of the site assessment. Where such analyses have been conducted by an outside laboratory, GZA GeoEnvironmental, Inc. (GZA) has relied upon the ata provided, and has not conducted an independent evaluation of the reliability of these data.

4. The conclusions and recommendations contained in this report are based in part upon various types of chemical data and are contingent upon their validity. These data have been reviewed and interpretations made in the report. As indicated within the report, some of these data are preliminary "screening" level data, and should be confirmed with quantitative analyses if more specific information is necessary. Moreover, it should be noted that variations in the types and concentrations of contaminants and variations in their flow paths may occur due to seasonal water table fluctuations, past disposal practices, the passage of time, and other factors. Should additional chemical data become available in the future, these data should be reviewed by GZA. and the conclusions and recommendations presented therein modified accordingly.

5. It is recommended that this firm be retained to provide further engineering services during design, implementation, and/or construction of any remedial measures, if necessary, This is to observe compliance with the concepts and recommendations contained herein and to allow design changes in the event that subsurface conditions differ from those anticipated.

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SPH RECOVERY SYSTEM RECONFIGLRATION

GENERAL DYNAMICS QUINCY SHIPYARD DESCRIPTION QUINCY, MASSACHUSETTS PROJ MGR DJA 1 = 80' DESIGNED8 BY: DJA/RET REVIEWED BBY: AJR GROUNDWATER ELEVATION 0 40' 80, 160' CONTOURS (APRIL 7, 1995) RS MASSACHUSETTS WATER RESOURCES AUTHORITY Charlestown Navy Yard 100 First Avenue Boston, Massachusetts 02129 Telephone (617) 242-6000 Facsimiie: (617) 241-6070

March 14, 1995

Quincy Department of Health J.F.K. Health Center 1120 Hancock Street Quincy, MA 02189-4313

Attention: M. Jane Gallahue, M.P.H., C.H.O. Commissioner of Public Health David Standley, P.E. Consultant to the City of Quincy Sanitarian

RE: MWRA Fore River Staging Area (former General Dynamics Shipyard) - RESPONSE TO REVIEW COMMENTS ON WAIVER SUBMITTALS: Notice of Land Use Stipulation and GZA Completion Statements and Opinion Release Tracking # 3-0536 and # 3-10266 Dear Ms. Gallahue and Mr. Standley: We are in receipt of the City of Quincy's November 21, 1994 comments pertaining to the Completion Statements and Opinion submitted by General Dynamics and prepared by GZA GeoEnvironmental, Inc. ("GZA"), the Consultant of Record under the DEP Waiver of Approvals for the above-referenced site. This response to comments is provided in accordance with the updated Public Involvement Plan ("PIP"), dated September 1994, the joint Waiver of Approvals for the site, which was granted by DEP in March 1994, and the 1993 Massachusetts Contingency Plan (MCP). Under these requirements, public involvement activities formerly undertaken by DEP under the PIP must be undertaken and implemented by the waiver applicants, MWRA and/or General Dynamics. Our response to the City of Quincy's other November 21, 1994 letter, which comments on the Notice of Land Use Stipulation proposed by MWRA and General Dynamics (the Notice"), is also provided below.

@ Panted on 100% Recycled Paper Quincy Department of Health March 14, 1995 Page 2

The Notice and GZA Completion Statements and Opinion were made available for public review and comment from November 1, 1994 through November 21, 1994. The only comments received were those on behalf of the City of Quincy and its Department of Health (collectively, the "City").

Each of the City's comments, as contained in the November 21 letters, are summarized below and followed by MWRA's and General Dynamics' response.

GENERAL COMMENTS Joint and Several Liability/Responsibility. The City notes in its comments that the application for a Waiver of Approvals was jointly submitted by General Dynamics and MWRA and that DEP's Waiver of Approvals was issued on March 2, 1994 to the joint applicants. The City correctly points out that in Part IV of the Waiver of Approvals, DEP stated that it will continue to hold both parties "jointly and severally liable for the response actions at the Site." However, DEP also acknowledged in the Waiver of Approvals that the parties were "free to decide on an apportionment of Waiver response action duties" (See Waiver of Approvals, Section IV, p. 9).

DEP's statement in the Waiver of Approvals confirms the Department's previous position with respect to MWRA's and General Dynamics' performance of allocated cleanup tasks at the shipyard since 1987. When MWRA purchased the site, General Dynamics had already completed a comprehensive site assessment and was performing a number of response actions. As the new site owner, MWRA took on responsibilities for different environmental measures related to its redevelopment plans for the shipyard. While DEP has looked to both parties to ensure overall Chapter 21E compliance, it has explicitly allowed one or the other party to perform specific tasks allocated between them. That same apportionment of response action duties was described in the joint application for the Waiver of Approvals and the updated PIP. Thus, the GZA Completion Statements and Opinion submitted this past fall are entirely consistent with DEP's Approval which permits such allocated submissions. The City suggests in its comments that because the Waiver of Approvals was issued "jointly" to MWRA and General Dynamics, the MWRA's Consultant of Record should submit parallel Completion Statements on the same subjects covered by GZA's Completion Statements. In the alternative, the City suggests some type of formal concurrence by both Consultants on every submission. This is not required under the Waiver, and would result in a duplicative and unnecessary expenditure of substantial resources. Quincy Department of Health March 14, 1995 Page 3

By virtue of their contractual agreement and the PIP process, MWRA and General Dynamics are each aware of DEP submissions made by the other regarding allocated response actions.

To further clarity the concept, the legal term "joint and several liability" connotes not only a common and shared liability, but also an individual responsibility for the same obligation without the other party. In other words, MWRA and General Dynamics share the obligation of Chapter 21E compliance at the shipyard, but each bears individual responsibility for performance of specific response action duties which may be performed without the other party. Accordingly, General Dynamics has submitted Completion Statements for certain Waiver response actions for which it assumed primary responsibility. While MWRA shares responsibility for the sufficiency of such actions vis a vis the DEP, MWRA may rely on General Dynamics' submission to meet its joint and several obligation.

Validity of Completion Statements and Opinion. With respect to the validity of the GZA Completion Statements and Opinion, DEP has determined, under its Waiver of Approvals, that the recording of "some type of 'Land Use Restriction' must be put in place" to insure that the "industrial or business office nature" use of the site is maintained. In addition, the DEP required the Applicants "to set in place a procedure for potential land use changes." The City highlights this requirement in its letter commenting on the Notice of Land Use Restriction proposed by MWRA and General Dynamics. This Notice satisfies DEP's requirement for a Land Use Restriction and establishes a straightforward procedure for changing activities limited to an "industrial or business office nature" to higher uses such as museum or residential. Once recorded, this Land Use Stipulation will validate the GZA Completion Statements and Opinion. A proposed change in use can be accomplished by recording and/or registering with the appropriate Registry of Deeds and/or Land Registration Office a written Consultant Determination or LSP Opinion that the proposed activity or use poses No Significant Risk. This Consultant Determination or LSP Opinion must be signed by the Consultant of Record or the LSP. If the changes of use would present such a risk, the Consultant of Record or LSP would need to specify the additional response action necessary to reduce or eliminate the risk to a level appropriate for the new use.

Notice of Land Use Stipulation. The City questions the appropriateness of a generic format for this specific property and states that the blanks in the Notice should be filled in. Specifically, the City recommends that proposed Item #2 be revised so as to detail the actual releases affecting a Quincy Department of Health March 14, 1995 Page 4 particular portion of the shipyard property. The City also recommends that the Notice include a comprehensive listing of the studies and reports in the public record concerning releases on or affecting the FRSA, which listing should be updated annually so that interested persons can give proper consideration of all aspects of any proposals for changes in activities and uses of the parcel(s).

The format of the Notice used by MWRA, while distinct from an AUL, is based in part on the DEP-approved form contained in the 1993 MCP at 310 CMR 40.1099 (Form 1075). The Notice contains all the information requirements specified by DEP. A deed notice of this kind, or indeed an Activity and Use Limitation or Grant of Environmental Restriction under the new MCP, is intended to put a person investigating the property in the Registry or Land Court on notice of the general environmental conditions of the property and any limitations on land use activities consistent with those conditions. Such a notice is intended to alert the reviewer to look at the full DEP technical record for more detail as may be appropriate for the purposes of his or her research. The Registry and the Land Court are not the proper repository of extensive technical documents. Accordingly, the proposed Notice alerts the reader that the property is a disposal site as a result of a release of oil and/or hazardous materials and that response actions for the property have been approved by DEP. Specific information about particular contaminated areas of the FRSA is already provided in great detail in the DEP record and public repositories. The GZA Completion Statements also contain a listing of studies and reports in the public record relating to the areas covered by the respective statements.

The information left blank on the draft Notice is simply the location of the MWRA offices at the Charlestown Navy Yard and the location of the Fore River Staging Area property -- "Quincy and Braintree, Norfolk County." A more detailed description of the property is provided in Exhibit A attached to the Notice. This information will appear in the final recorded Notice.

The City suggests that MWRA stipulate in the Notice what uses are included in the term "industrial and business office purposes," as well as performance of yet another risk analysis. The term was first used by DEP in connection with its 1987 approval of proposed and completed remedial actions for the Shipyard site, and for reasons of consistency, this term has been carried forward in the Waiver of Approvals and the PIP. As indicated in the Waiver of Approvals, the potential risks associated with this use have been factored into DEP's previous approvals of response actions at the Property. Moreover, an evaluation of risk to public health and the environment was performed by GZA in June 1988 for the Shipyard. See pages 3 and 0

Quincy Department of Health March 14, 1995 Page 5

4 of the revised PIP, dated September 1994. This evaluation, which was approved by DEP, assumed continued industrial/business office uses and was based on existing environmental conditions, including the highest contaminant concentrations reported by both MWRA's and General Dynamics' Consultants of Record.

As stated above, section 4 of the Notice establishes a simple, straightforward procedure for land use changes. Any proposed change in activities and uses which may result in higher levels of exposure to oil and/or hazardous material than would occur as a result of industrial/business office use should be evaluated by the Consultant of Record or an LSP as to whether the proposed changes will present a significant risk of harm to health, safety, public welfare or the environment. If the Consultant of Record determines that a condition of No Significant Risk has been met for the proposed conditions under the Waiver of Approvals and the MCP, the procedure simply calls for the filing and recording of the required documentation to that effect (see discussion above). In some cases, achieving the No Significant Risk standard may require additional response actions and, in other cases, the standard may have already been met and no further response actions would be required other than filing the required supporting documentation.

With respect to the City's concern about the risks posed by construction activities for future uses of the Property, the proposed Notice's requirement for the preparation and implementation of a site-specific or project-specific hazardous materials management plan ("HMMP") was intended to address this very concern. This requirement is consistent with DEP's new draft MCP guidance for "Construction Activities in Contaminated Areas," expected to be finalized in Spring 1995. The draft MCP guidance, dated April 28, 1994, is designed for site-specific application by competent professionals for the development of project-specific hazardous materials management plans.

The City states that specific references to the MCP regarding HMMPs should be cited, and that it would prefer that the MWRA revise its Construction Procedures Document to make that document applicable to construction activities by third parties on the Property. According to DEP's draft guidance on construction activities in contaminated areas, there currently is no comprehensive set of environmental regulations that specifically govern construction activities in contaminated areas. Thus, MWRA is unable to provide a specific MCP reference in the Notice. MWRA's Construction Procedures Document, approved by DEP, is designed specifically for activities conducted within the area bounded by the security fence and while owned by MWRA. The Construction Procedures Document does not speak to undefined, future project-specific activities by others. However, the draft Quincy Department of Health March 14, 1995 Page 6

MCP guidance on this subject, when finalized and published, should apply to construction activities by others under the MCP. Other owners or operators will need to prepare HMMPs tailored to their planned activities in accordance with the Waiver of Approvals, the MCP, as applicable at that time, and best management practices. This will ensure that there is no gap in the proper precautions needed for specific, future construction projects at the site.

The Construction Procedures Document is in the process of being revised and will be made available for public comment and DEP approval in accordance with the Waiver of Approvals.

With respect to the City's comment regarding Item #3(b) and #4 of the Notice, this language is similar to DEP's approved notice Form 1075 in the MCP. The two standards serve distinct functions in evaluating both similar and wholly new use changes relative to current industrial/business uses. The "no greater risk of harm" language in Item #3(b) refers only to existing permitted activities and uses; specifically, response actions previously approved by DEP based on the property owner's assertion that such activities would present no greater risk of harm than that posed by the existing industrial and business office use. Item #4's "no significant risk" is the standard established in Chapter 21E and the MCP; it speaks to proposed changes in activities and use. Thus, the standard in Item #4 is defined by any new uses proposed for the Property that are not otherwise "industrial or business office use" in nature. These new uses would, of course, be subject to applicable zoning laws.

With respect to the City's comment that the filing of an Opinion by either "Consultant of Record" means that "both GZA and PEER Consultants must file the Opinion," we respectfully disagree and refer the City to our response to comments on joint and several liability, above. Similarly, the Opinion of an LSP does not require concurrence by both MWRA and General Dynamics. The joint and several responsibility and liability of General Dynamics and MWRA permits the allocation of response action duties to one party, as is appropriate for the subject opinion.

Recorded Notice. The City indicated that it does not have the "notice regarding environmental conditions and remedial actions at the shipyard" as recorded on 11/17/87 (GZA Completion Statement, Section 1, Part VI). Although not stated in its letter, the City must be referring to the Completion Statement for PCB-Contaminated Soil, which is the only Completion Statement containing reference to the 11/17/87 deed notice. A copy of such notice was recorded by the MWRA at the Norfolk Registry of Deeds as Instrument No. 132776, Document No. 535417 at the time of e 9

Quincy Department of Health March 14, 1995 Page 7 purchase of the shipyard, in accordance with the law at that time. In addition, at DEP's request, General Dynamics prepared and submitted to the Department in August, 1988 a detailed site plan indicating the post-remedial locations of residual PCBs. The GZA Completion Statement for PCB-Contaminated Soil provides much more detail than the notice. The Completion Statement contains full descriptions of the completed PCB response actions, lists of related reports previously submitted to DEP, with reference to the recorded deed notice.

OTHER COMM(ENTS 1. PCB-CONTAMINATED SOIL

Comment: The City made reference to its general comment concerning industrial and business usage with respect to future use of portions of the FRSA which may be affected by PCBs.

Response: The City's concern for future uses of the property which may be affected by PCBs are addressed by MWRA's Construction Procedures, as well as the change- in-use procedures and the requirement for a hazardous material management plan set forth in the Land Use Stipulation proposed by MWRA and General Dynamics. See response to General Comments, above.

2. OUTSIDE PROPERTIES; AREA 4

Comment: The City states that the parcels in Area 4 were never industrial in nature, and thus the "industrial and business office use" criterion should never have been applied to these parcels. The City also suggests, based on the September/October 1994 Phase I investigations conducted by MWRA's Consultant of Record (PEER Consultants), that residential use would be permitted for these parcels without further remediation. In addition, the City recommends that the Area 4 properties be excluded from the definition of "Property" in the Notice. The City also recommends that a Joint Completion Statement be issued.

Response: The Area 4 parcels were owned and used by General Dynamics as part of its former industrial operation of the Shipyard. These parcels have always been considered part of the Shipyard "Site" designated by DEP and later acquired by MWRA. Given this prior use and proximity of Area 4 to the Shipyard, activities of an industrial or business office nature in Area 4 are 9p 0

Quincy Department of Health March 14, 1995 Page 8 clearly appropriate. However, other uses would not necessarily be precluded in the future. Based on MWRA's Phase I reports, residential use might be a permitted future activity for these properties without further remediation. The procedures for land use changes contained in the Notice of Land Use Restriction (LUR) proposed by MWRA and General Dynamics would allow MWRA to submit to DEP and the public (including the City) documentation demonstrating the appropriateness of such a change in use for review and comment. According to DEP, "the purpose of the Land Use Restriction would be to insure that this 'industrial or business office nature' use is maintained and, if so chosen, to set in place a procedure for potential land use changes" (emphasis added; See Waiver of Approvals, p. 4). The fact that DEP previously has approved cleanup plans submitted by General Dynamics based on the "industrial or business office nature" use standard does not prevent MWRA, or other future owners/operators, from changing that use. As DEP stated in its March 2, 1994 Response to the City comments on the Waiver of Approvals, "[t]his approval must be honored by the Department. However, nothing would preclude the applicants from using the methods and standards for risk characterization and cleanup set forth in 310 aMR 40.0900, and remediating the site to a level which would support a less restrictive land use." (See DEP's March 2, 1994 Response to City Comment, p. 5).

With respect to the City's recommendation for a Joint Completion Statement, we reference our response to the City's General Comments, above. As indicated in the GZA Completion Statement, MWRA has taken responsibility for conducting an update of the Area 4 environmental assessment and conditions of the study area since November 1987 through to the present. As you know, in September/October 1994 MWRA completed and submitted its updated Phase I Site Investigation reports for the Area 4 parcels. MWRA plans to file Completion Statements for these parcels in Spring 1995.

3. OUTSIDE PROPERTIES - AREA 5, EXCEPTION SECTION 5E

Comment: The City notes that since these properties are in the Town of Braintree, comments on behalf of the City of Quincy are not appropriate. The City adds that a Completion Statement by the MWRA Consultant of Record should be submitted. Quincy Department of Health March 14, 1995 Page 9

Response: Please refer to our response to the City's General Comments, above.

4. CHLORINATED SOLVENTS, MINERAL SPIRITS, AND LONG-TERM MONITORING

Comment: Completion Statement by the MWRA's Consultant of Record should be submitted.

Response: Please refer to our response to the City's General Comments, above.

5. BENT'S CREEK AREA

Comment: The City states that it has no record of DEP's acknowledgement of the separation of responsibility for the "oil pocket" in the vicinity of Building 9 from the remainder of the Bent's Creek area. The City references its General Comments regarding the joint responsibilities of the parties under the Waiver of Approvals. The City further states that, because of its concern about potential migration of petroleum hydrocarbons ("PHC") into the major storm drain traversing the area, which discharges into the Fore River, continued routine monitoring of the drain's discharge for PHCs for a period of several years would seem appropriate prior to accepting a Completion Statement for this area. Finally, the City recommends that the Completion Statements for the "oil plume area," "Building 9 oil pocket," and "Bent's Creek area" incorporate the MWRA's revisions to the Construction Procedures Document, made available to non-MWRA construction activity.

Response: In response to a request by General Dynamics' counsel in late 1994 for clarification of the Waiver of Approvals, DEP provided oral confirmation that, as a procedural matter, the Bent's Creek area and the Building 9 oil pocket can be addressed separately under the Waiver of Approvals. DEP confirmed that the Bent's Creek area was the subject of Item 2 of DEP's September 1987 approval letter. The Building 9 oil pocket, on the other hand, was expressly covered by a separate DEP letter, dated October 4, 1989. The Building 9 oil pocket, which was first discovered by MWRA in May of 1989, is being addressed by MWRA in accordance with the MCP and the Waiver of Approvals. Long-term monitoring was conducted by MWRA during the late 1980's and was discontinued when it was determined that there was no further oil seepage discharge into the River. With 9 0

Quincy Department of Health March 14, 1995 Page 10 respect to the City's comments on joint responsibilities, please refer to our response to the City's General Comments, above.

The City's concerns about the potential migration of PHCs has been addressed by the Completion Statement. General Dynamics' consultants (GZA and Groundwater Technology, Inc./"GTI") have monitored groundwater monitoring wells in the Bent's Creek area for at least eight (8) years (since May 1986). GZA's June, 1989 study of the Bent's Creek area concluded that the dissolved PHCs in groundwater in the area were most likely the result of historical northward migration from the central yard oil plume prior to the startup of General Dynamics' oil recovery system in 1986, rather than the result of a new, uncontrolled source. GZA further concluded that ongoing remediation and monitoring of the central yard oil plume is expected to continue to prevent the migration of separate phase product towards the Bent's Creek area. See page 7 of GZA Completion Statement.

In a letter dated April 17, 1991, DEP approved the discontinuance of several monitoring wells in the Bent's Creek Area (GD-1154, GD-1110, GD-2390, GD-2391, GD-2393A, GD-2394, GD-2396 and GD-1297). Between DEP's 1991 approval and the issuance of GZA's Completion Statement, more than three additional years of monitoring data has been collected by GTI from monitoring wells in the Bent's Creek area. GTI's data supports GZA's Completion Statement for the Bent's Creek area.

The City's recommendation that the Completion Statements for the "oil plume area," "Building 9 oil pocket," and "Bent's Creek area" incorporate the MWRA's revisions to its Construction Procedures has already been addressed. Any construction activity in this area by the MWRA will be subject to the MWRA's Construction Procedures. Future construction in this area would be subject to the proposed Land Use Stipulation. Section 5 of the Land Use Stipulation, which provides for location-specific protective procedures rather than a general procedure for the entire FRSA, provides:

"Construction activities which may involve the disturbance of contaminated soil and/or groundwater shall include preparation and implementation of a hazardous materials management plan ("HMMP") to minimize the migration of and Quincy Department of Health March 14, 1995 Page 11

exposure to hazardous materials. The HMMP shall be prepared in accordance with the requirements of the Waiver of Approvals and the Massachusetts Contingency Plan, as applicable."

Thus, the Construction Procedures for MWRA and the HMMP for future projects will protect against interference with ongoing remediation and ensure that proper precautions are taken for any subsurface excavation in this area.

6. SOUTHERN BOUNDARY AREA Comment: The City defers to the Town of Braintree with respect to GZA's Completion Statement for the Southern Boundary Area. The City acknowledges Clean Harbors has primary cleanup responsibility under its settlement with General Dynamics; but requests assurances that General Dynamics enforce that settlement. The City believes that EPA and DEP as responsible regulators, and the MWRA as the affected property owner, should perform an aggressive oversight of remediation activities required of any and all parties in the area and require monitoring to prevent the discharge of contamination to the Fore River. The City also recommends that a Completion Statement by the MWRA's Consultant of Record be submitted.

Response: As stated in the Completion Statement, Clean Harbors is conducting this remediation under a Corrective Action Consent Order issued by the U.S. EPA in accordance with the 1984 Hazardous and Solid Waste Amendments ("HSWA"), as well as a settlement with General Dynamics. In addition, DEP has determined, pursuant to Chapter 21E and the 1993 MCP, that response actions subject to HSWA Corrective Action Orders, such as at the Clean Harbors site, are considered to be "otherwise adequately regulated", provided that certain provisions of the MCP are followed. The terms and conditions of that consent order are being monitored and enforced by EPA.

We wish to assure the City that General Dynamics and MWRA intend to track Clean Harbors' compliance with the HSWA Order and the terms of the litigation settlement agreement requiring remediation of the Southern Boundary groundwater contamination. However, with respect to the HSWA Order, neither General Dynamics nor MWRA have any control over U.S. EPA's or DEP's Quincy Department of Health March 14, 1995 Page 12

allocation of resources to the oversight or enforcement of the response actions required of Clean Harbors under the Order or the MCP. The vigilance of all parties, including Clean Harbors, is the best insurance that the remediation will be completed.

With respect to the City's recommendation that MWRA submit a Completion Statement by its Consultant of Record, please refer to our response to the City's General Comments, above.

7. OPINION REGARDING RESPONSE ACTION OUTCOME RTN 3-102G6

Comment: Opinion of MWRA's Consultant of Record should be submitted.

Response: Please refer to our response to the City's General Comments, above.

We thank you for your comments and trust the above response adequately clarifies the submissions and addresses your concerns. We believe that the Notice of Land Use Stipulation and GZA Completion Statements and Opinion are consistent with the intent and requirements of the MCP and DEP's Waiver of Approvals for this site.

If you have any questions regarding the contents of this letter, please contact me at (617) 241-6057.

Very truly yours,

Jose Vincnty, PIP Contact Person cc: Sharon A. Gobiel, DEP John J. Fitzgerald, P.E., DEP Douglas B. MacDonald, MWRA Edward C. Bruntrager, Esq., General Dynamics Corporation Maggie Debbie, MWRA Robert White/Dan Kelley, General Dynamics Laurie Burt, Esq. Addressees on attached PIP Mailing List Commonwealth of Massachusetts Executive Office of Environmental Affairs Department of Environmental Protection

William F. Weld Goserno' Trudy Coxe Secretary, EOEA Thomas B. Powers Acing Commissioner January 27, 1995

Jan Reitsma, Director Re: MWRA, FRSA Expansion and MEPA Unit Upgrading of Drying/ EOEA, 20th Floor Pelletizing Plant 100 Cambridge Street NPC, EOEA #5832 Boston, MA 02202

Dear Mr. Reit-sma:

The Massachusetts Department of Environmental Protection (DEP) has reviewed MWRA's Notice of Project Change (NPC) for the Expansion and Upgrading of its Drying/Pelletizing Plant located at the Fore River Staging Area (FRSA). The recommended plan includes the following major elements:

* rail car storage tracks, access road relocation, and 8 new pellet storage silos to be constructed north of building 11;

* relatively minor extension of the existing garage building (28 by 97 feet) onto Pier #2; and

* upgrading of the air handling and treatment systems.

The Authority has determined that in order to attempt to comply with its obligations to meet the current Federal Court Order schedule for completion of the expansion project at FRSA, it is advantageous to divide the activities at the sludge process and pelletizing plant into two (2) separate design and construction phases. in addition, the Authority has determined that a "fast- track" pilot project on a single dryer drain (No. 2) should be conducted. This full scale, fast-track, pilot test program has been designated Phase I of the expansion project, and is currently being implemented with DEP/DAQC review and approval.

The NPC Project will require that DEP process a number of cermits, licenses, certifications and plan approvals for the expansion, but DEP does not believe that the proposal will result in any substantial DEP permitting issues and project processing should be straight-forward. The key project elements for which DEP has jurisdiction are as follows:

One Winter Street e Boston, Massachusetts 02 106 O FAX (617) 556-1049 e Telephone (617) 292-5500 0 0

(1) Upgrading of the air pollution control systems;

(2) Replacement of the existing belt filter presses with twelve (12) centrifuges;

(3) Underpinning of Pier No. 2; and

(4) Intrusive excavation on the site.

DEP staff have been, and will continue to, work with MWRA and its consultants to expeditiously permit these activities. MWRA has committed to performing all intrusive excavation in accordance with the Construction Procedure Document jointly developed by MWRA and DEP to ensure that work on the FRSA site (a confirmed 21E Site) will be performed in such a way to ensure protection of the public health and welfare and the environment.

Information included in the NPC appears to indicate that noise levels might exceed DEP's Policy of maintaining noise levels at no greater than 10dBA above background. :t will therefore be incumbent upon MWRA to incorporate noise mitigation measures, to the extent necessary and feasible, into the construction documents and to carefully monitor noise during the project.

As part of the permitting for the existing Drying/Pelletizing Facility, DEP performed a c.83 s.6 Siting Procedure and at that time, and most recently at a January 5, 1995, meeting among representatives from EPA, MWRA and DEP, this writer stated that once DEP has had an opportunity to review the expansion and upgrading proposal, it would make a formal determination whether an amendment to the prior Siting Determination would be required. Based upon DEP's review of the proposed facilities to be constructed and operated as part of this NPC, DEP has determined that an amendment to the prior c.83 s.6 Siting Determination will not be necessary, in that impacts are not expected to be significantly different or greater than the currently authorized facility.

DEP recommends that the NPC be approved by MEPA and MWRA be authorized to proceed with project permitting.

Feel free to contact me (292-5698) if you have any questions regarding this correspondence.

Very truly ours,

Steven G. Lipman, P.E. Boston Harbor Coordinator

SGL/wp a:3 reitsma2 0 cc: Dave Shepardson, MEPA Rick Mills, MWRA Mark Stein, EPA John Simpson, Dave Kenney, Judy Perry, Jim Sprague, Rick Dunn, Sharon Gobiel, Alan Slater, Ron Lyberger, Dave Ferris, Jim Belsky, John Felix 0 0

Commonwealth of Massachusetts Executive Office of Environmental Affairs Department of Environmental Protection William F. Weld Govemor Trudy Coxe S.cr.ty, EOEA Thomas B. Powers ActingCoomiss~jiner January 26, 1995

Michael Hornbrook Re: MWRA Mass Water Resources Authority Braintree-Weymouth Tunnel charlestown Navy Yard Hazardous Materials Program Plan 100 First Avenue for Design Boston, MA 02129

Dear Mr. Hornbrook:

In response to a January 17, 1995, request from Gregory Sankey (Stone & Webster, Inc.), this writer has reviewed a report titled; Braintree-Weymouth Tunnel and Intermediate Pump Station, Hazardous Materials Program, Plan for Design dated January 18, 1995. As part of this review on January 25th I met with Mr. Sankey and Lisa Brandon (S&W) to discuss my comments and questions on the document. The following is a summary of DEP's comments, and whether or not they were addressed at the 25th meeting.

(1) I asked whether S&W had received relevant information from MWRA regarding 21E work at FRSA and Nut Island to assist them in locating the drop shafts and environmental borings. I was informed that such documentation was recently received and Ms. Brandon would be reviewing it to determine whether the information might affect shaft location and/or nature and extent of borings and analysis proposed to be performed (Issue resolved).

(2) We discussed the information available regarding site contamination at the BECO/Sprague Site, particularly on, or in proximity to, the area proposed to be obtained by MWRA for the pump station. Little information is available regarding this portion of the site but it appears that extensive amounts of coal waste ash has been placed on the site. An existing boring in the area did not indicate significant contamination (Issue addressed).

(3) I asked whether or not the S&W field representative overseeing installation of the borings would have the flexibility to determine that more than one soil sample be analyzed, my concern being that it is possible that multiple strata of potential contamination might be encountered, and if this were to occur, samples of each strata should be analyzed. I was told that there will be a limited amount of flexibility. I responded that it is important for field representative to have this flexibility, and request that MWRA specifically authorize multiple sample analyses.

(4) I requested that the specified length of well screens be increased from 10 to 15 feet and that the field representative consider the tidal influence on groundwater elevations in the wells when placing the screens to ensure that the groundwater elevation variation does not go outside the screened area (Issue resolved).

One Winter Street e Boston, Massachusetts 02108 O FAX (617) 556-1049 * Telephone (617) 292-5500 '-

(5) I stated that using the highest headspace reading as the main basis for picking the samples to be analyzed may not be appropriate for these sites in that any petroleum products on the sites is likely to be weathered. I recommended that headspace be just one of the items considered when choosing samples for analysis (Issue resolved). (6) I requested that all samples be analyzed for total RCRA metals, but that TCLP is only necessary for those metals where total metal results exceed the theoretical TCLP exceedance (Issue resolved).

(7) S&W provided me with better copies of figure 2 through 4 (Issue resolved).

Assuming the issues discussed above are addressed by MWRA and S&W, DEP concurs with the proposed program.

Feel free to contact me (292-5698) if you have any questions regarding this correspondence.

Very truly yours,

Steven G. Lipman, P.E. Boston Harbor Coordinator

cc: Gregory Sankey and Lisa Brandon, S&W Alan Slater, DEP/BWSC Stephen Johnson and Sharon Gobiel, DEP/BWSC

SGL/yg/53: hazmatpr.ltr Commonwealth of Massachusetts Executive Office of Environmental Affairs Department of Environmental Protection William F. Weld Tnudy Coxe 8.cn . EOEA Thomas B. Powers Acting Co.m.oner MEMORANDUM

To: John Simpson, Dave Kennedy, Judy Perry, Jim Sprague, Rick Dunn, Sharon Gobiel, Alan Slater, Ron Lyberger, Dave Ferris, Jim Belsky, John Felix

From: Steve Lipman Date: January 9, 1995

subject: MWRA, FRSA Expansion and upgrading of Drying/Pelletizing Plant, Notice of Project Change - EOEA # 5832

On Januarj 5, 1995, Dick Keith (BMF), Rachel Quill (DAQC/NERO) and I met with Staff from EPA & MWRA to allow MWRA to update EPA and DEP on the Authority's activities related to expansion/upgrading of the FRSA Drying/Pelletizing Facility. This memorandum includes a brief summary of that meeting and a review of the MEPA Notice of Project Change (NPC) for this project, filed with MEPA on December 30, 1994. copies of the full NPC are available from Dick, Rachel and this writer if you wish to borrow the filing. I also assume that copies of the NPC were sent to the typical DEP offices per MEPA requirements. It is my understanding that MEPA will be holding a scoping session at 10:00 a.m. on January 24th at the FRSA facility (Dave Shepardson is the MEPA project manager). MWRA describes this NPC in the following way:

"Through implementation of the RMFP for long-term facilities at FRSA, to serve the Boston Metropolitan area through the year 2020, several changes to the original Long-term Residuals Management Facilities Plan have been recommended for improved processing of residuals from the secondary treatment facility being constructed on Deer Island. These changes are expected to reduce the overall environmental impact of the facility and to minimize construction of new facilities while satisfying the court ordered mandates for expansion. The schedule for expansion of sludge processing capacity more than keeps pace with the start-up of new primary and secondary facilities.

The first goal of the Authority with the plant expansion design is to provide full treatment of sludge to be generated by the new primary and secondary wastewater treatment facilities while improving process redundancy of the recommended equipment within the existing building. Second, the Authority must provide rail staging to allow for the transportation of sludge cake under emergency disposal scenarios consistent with the commercial disposal contact with ECDC Environmental. The Notice of Project change also contains details on additional pellet storage silos which were presented in the RMFP, but whose number and configuration were not fully developed at the time."

At the January 5th meeting, and in the following excerpt from the NPC, MWRA staff described the project schedule.

"The Authority has determined that in order to attempt to comply with iti obligations to meet Court-ordered schedules for completion of the expansion project at FRSA it is advantageous to divide the activities at the sludge processing and

One Winter Street e Boston, Massachusetts 02108 e FAX (617) 556-1049 * Telephone (617) 292-5500 page 2. pelletizing plant into two (2) separate design and construction phases. In addition, the Authority has determined that a "fast-track" pilot project on a single dryer drain (No.2) should be conducted. This full scale, fast-track, pilot test has been designated Phase I of the expansion project. These Phase I activities are currently being implemented (with DEP/DAQC approval]".

The appended Table G.1 taken from the NPC describes the activities for Phase I, Phase II - outside changes, and Phase III - Inside Changes. This schedule will require tha MWRA amend the current Court Schedule in that MWRA will not be able to meet the current court milestone of, Completion of Facility Expansion by october 1996. According to MWRA, there will be a 10± month period of time (October 1996 to March 1997) when sludge production will theoretically exceed the firm capacity of the plant, but MWRA states that this apparent shortfall will not result in any sludge bypass or adverse impacts to operations at the Deer Island Plant. According to the NPC, DEP will be required to process a number of permits, licenses, certifications and plan approvals for the expansion (see appended Table F.1).

After quickly reviewing the NPC, it does not appear to me that the proposal will result in any substantial DEP permitting issues and project processing should be straight forward, but I would like to hear your opinion.

The recommended plan includes the following elements (please refer to appended figure D-9). * rail car storage tracks, access road relocation; and 8 new pellet storage silos to be constructed north of building 11; * relatively minor extension of the existing garage building (28 by 97 feet) onto Pier 4 2;

* upgrading of the air handling and treatment systems.

The following are various excerpts from the NPC which may be of interest to various DEP staff. "...all alternatives require demolition of Buildings 95, 84, A, 22, and the Wellman-Seaver Gantry Crane" (According to MWRA, MHC has agreed to allow this demolition to occur).

"Under all alternatives, rail car storage tracks, along with pellet storage facilities, were proposed north of Building 11. Physically this area was the only space available to the MWRA for construction of these facilities while maintaining the availability of other areas of the yard for re-development." (see figure D-9)

"The rail line on Pier 2 and the garage extension will require demolition of a portion of the pier and construction adjacent to a tidal area. some work is required to protect adjacent pile cribbing to reduce soil erosion which could expose the support piles for the pedestal foundation". W "It has been determined that 30-days of storage capacity under maximum month conditions is necessary. This storage will provide flexibility in the distribution of pellets to fertilizer markets by allowing a buffer to the seasonal and demand-side fluctuations in the marketplace. Some additional rail trackage is necessary in conjunction with these new silos to allow unloading and transportation of pellets." page 3.

"The access to the existing pellet storage facility will be modified to accommodate the new rail trackage and silo configuration. Along with these improvements, certain site utilities will be abandoned or moved to allow for the new construction. These changes will take place only between Building 11 and Buildings 19 and 48. sewer, water, fire supply, electrical, and storm drainage will be moved and or modified to service the new facilities in the area. other unused utilities related to past shipbuilding activities will be removed. This work will result in relatively minor construction activities to realign the approach to the MWRA zone and the approach to the existing pellet facility from the new rail and silo storage area as well as relocating utilities. All work in these areas will be performed under the guidelines of the "[DEP-approved] Construction Procedures" document which details control of soil migration due to construction and potential erosion."

W "The Authority is also considering the construction of fuel storage facilities in the vicinity of Building 22 located at the northwest corner of the North Platen. These fuel storage facilities would serve as a backup fuel source for sludge processing in the event of primary fuel (natural gas) interruption. The necessity for development of the fuel storage facility is still under review. Alternative fuel supply options still under review include a dedicated fuel oil pipeline and an alternative gas supply connection."

"... due to the critical nature of dewatering in the overall process, twelve (12) centrifuges are recommended instead of the eight (8) recommended in the RMFP. Even though this effectively increases the capacity of sludge cake processing at the facility, this provides 83% redundancy in a segment of the operation that cannot tolerate a failure." b "No filling or dredging of water or wetland resources is anticipated as part of the expansion project. water resources which may be impacted by the project are those waters of the Fore River adjacent to Pier 2." "Pier 2 reconstruction/ rehabilitation requirements relative to support structures are still under investigation. Depending on the condition of the existing wood piles beneath the pedestal foundation it is the Authority's intent to reuse the existing pedestal with minor improvements. "As protection against erosion of soils around existing wood pile 'cribbing' and wood borer destruction of piles, the MWRA plans to install a grout filled HDPE mattress along 370 feet of the outside pier foundation. Although this mattress would cover bottom sediments, it is not likely to create significant impacts on water quality." W "Bottom sediments, which could be disturbed during this process of a piling replacement/repair, are likely to be contaminated by organic compounds or heavy metals similar to those found by the NUS Corporation (November 1987) when one sediment sample was taken off of the end of Pier 1 and another off of the end of the North Platen. Because of the suspect nature of the bottom sediments beneath Pier 2 it is recommended that silt curtains be employed around the Pier 2 work area to trap and control the dispersion of any sediment disturbed during the replacement/repair of the Pier 2 wooden and steel piles. This technique was used during the reconstruction of Pier 3 and proved to be successful in preventing any adverse impacts to the class SB waters of the weymouth Fore River." W "Physical and time constraints are factors in the expansion of the project, as related to the handling of soil [being] excavated. Remote stockpiling, additional soil handling and construction site limitations and schedule have necessitated the development of an in-situ soil sampling and analysis program. page 4.

Removal of existing foundations for Building 84 and 95 will require excavations approximately 4'-5' deep. Installation of new foundations for the proposed silos will include pile driving and excavation for a pile cap approximately 5'-10' below the proposed silos' grade. New tracks to be laid directly north of Building 11 will require at least 2' and in some areas as much as 4' of excavation. Minimal excavation for Pier 2 is anticipated, although approximately 2' is required to be excavated at both the east (waterside) and west (landside) ends. Excavated soils will be handled in accordance with the Construction Procedures document. New piles will also be driven beneath the existing pier; however no excavation is required." At the January 5th meeting I indicated that DEP will need to make a determination whether a new or amended C.83 s.6 site Hearing will be required and that DEP will make this determination once it has had an opportunity to review the NPC and discuss issues internally. It is my initial thinking that the project change is not a "significant" revision to the original facility or its operations (as relates to abuttor impacts), and potential impacts are not substantially different from those addressed in the original c.83 s.6 Hearing (issued on November 28, 1989); therefore based upon the information currently available to me I do not believe a new or amended c.83 s.6 site Hearing is required or necessary. This issue will need to be reviewed and assessed by Rick Dunn and David Ferris (DWPC). Since this NPC is related to a revision to the Federal Court schedule, I would like to have DEP comments funneled through me for preparation and submission of a consolidated DEP comment letter. It is my understanding that comments will be due at MEPA on or about February 6, therefore please provide any comments to me on or before January 30th.

cc: Ed Kunce Bill Gaughan Elizabeth Dorsey Tom Bean

a2: NPC-5832.mem TABLE G.1

ISP&D EXPAISION PROJECT - ANTICIPATED SCHEDULE

EVENT PHASE I PHASE II PHASE III Notice to Proceed 8/6/93 8/6/93 8/6/93 Submit Design N/A 5/27/94 8/3/94

Report MWRA Approval N/A 8/1/94 10/5/94 Initiate Final 2/1/94 8/1/94 10/5/94

Design Submit Bid 4/6/94 4/1/95 8/1/95 Documents Advertise for 6/15/94 8/15/95 12/15/95 Bids Award Construction 10/26/94 11/1/95 3/1/96 Contracts Complete 4/24/95 5/1/97 11/1/97 Construction Compliance 8/1/95 N/A 2/1/98

Testing OUTSIDE PERMIT REOUIREKENTS AGENCY PERMIT U.S. Army Corps of Engineers Section 10 Permit Massachusetts Office of Coastal Consistency Zone Mgmt. Certificate Division of Water Pollution Water Quality Cert. Control - MDEP & NPDES Division of Waterways - MDEP Waterways License Division of Air Quality Control Air Plan Approval

- MDEP Massachusetts Department of Building and Public Safety Utility Permits City of Quincy Conservation Notice of Commission Intent/Order of Conditions J ~1

I I,

I . I / -

I I I 4

-I C 1~

*44 I ------Is. i

0~j I I r / / / I / i~ji i V U I' S t~ November 21, 1994

Mr. Jose Vincenty Public Contact Person MWRA Charlestown Navy Yard 100 First Ave. Boston, MA 02129

Re: MWRA Fore River Staging Area: Proposed Notice of Land Use Stipulation

Ref MWRA Public Notice of 11/1/94

Dear Mr- Vincenty:

Theses comments are jointly submitted by the undersigned on behalf of the City of Quincy concerning the subject Notice of Land Use Stipulation proposed by the MWRA for future disposition of property at the Fore River Staging Area in Quincy and Braintree ("the FRSA"). The purpose of the aforesaid Stipulation is to conform in part to the Waiver of Approvals granted by MADEP to the MWRA and General Dynamics pursuant to MGL Ch. 21E and the former Massachusetts Contingency Plan, under date of March 2, 1994.

This document was presented simultaneously with the six Completion Statements and Opinion prepared by GZA as consultant of record to General Dynamics and dated 9/14/94. In view of the statement in Para. A.(2) of the MA DEP Waiver of Approvals, "Therefore, in order for the approvals/determinations made by the Department in the September 1987 letter to be valid, some type of 'Land Use Restriction' must be put in place.", it is our view that the Notice of Land Use Stipulation must be finalized and established before any Completion Statements or Opinions relying on that letter or on a limitation of use can be accepted.

The blanks in the form should be filled in, except for the date. There is no reason for proposing a "generic format" for this specific and critical property, and the proposal thereby suggests a cavalier level of treatment of the issue by the Authority, which we assume is not intended. We note the inclusion, in the March 2, 1994 MADEP Waiver of Approvals for the site, of Appendices A and B, describing the property. We also note the recent (September/October 1994) reports of PEER Consultants to the Authority of Phase 0 -

I Site Investigations for "outside parcels" in Quincy, namely 166 East Howard Street, 5-49 Cleverly Court, 661 Washington Street, and 12-34 Cleverly Court. Based on these reports, it is proposed that at least the first three listed and probably all be excluded from the definition of "the Property". The uses of these parcels should not be limited based on contamination of soils or groundwater, with the possible exception of 12-34 Cleverly Court. For that property, a decision should be deferred pending further consultation with MADEP and the Quincy Department of Health.

Proposed Item #2 in the Notice should be structured to be expanded for the particular parcel or parcels that is/are involved in a specific land transfer action, so as to detail the actual releases affecting that specific property. The purpose would be to give the public and public agencies a clear perception of the risks and concerns associated with the parcel(s).

The Form of Notice should include a comprehensive listing of the studies and reports in the public record concerning releases of oil and hazardous materials on or affecting the FRSA, which listing should be updated annually so that the proposer, the Consultant of Record, any LSP involved, other agencies, and the public are ensured of proper consideration of all aspects of the issue of proposals for changes in activities and uses of the parcel(s).

It is incumbent upon the MWRA to clearly stipulate what uses are included in the term "industrial and business office purposes". As you are aware, the City of Quincy and the Town of Braintree have since 1987 expressed serious concerns about the statement in the September 20, 1987 letter of the MADEQE to General Dynamics (Section H, paragraph 2, page 2) "The Department's requirements for the level of investigation and the level of remediation at this site are based upon General Dynamics' assertion that site use would be limited to activities of industrialor business office nature." (italics supplied). GD's Waiver Application (1/31/94, as supplemented) avers that the present and continued use of the property is industrial in nature. The MWRA's Supplemental Information submittal to the 8/24/93 Waiver Application, dated 11/23/93, states as follows: "However, the MWRA is currently investigating redevelopment of this property, and is evaluating a wide variety of potential industrial and non-industrial uses. The MWRA does not intend to develop this property for residential use, or to include high-intensity uses by children, such as on-site day care." We note, also, the MWRA letter of 11/22/89 to Anne Bingham of MADEP proposing, in part, a definition of "industrial and commercial use". In Item #3 (b) of the proposed Notice, the MWRA states that other use of the property would be limited to "such other activities which ... present no greater risk of harm to health, safety, public welfare or the environment than the use of the Property for industrial and business office purposes." In order that the comparative risk of harm may be properly evaluated, it is essential that all concerned clearly understand what the base case and its risk of harm are. This requires definition, followed by risk analysis. 0 0

In addition to the filing of an Opinion of either the "Consultant of Record", which in this case includes both GZA and PEER Consultants, or of an LSP there should be filing and recording of concurrence thereto by the MWRA, General Dynamics, and any other party proposing a less-restrictive land use for a parcel; in order that responsibility and liability be clearly established.

There exists in the proposed Notice an incongruity between the terms of Items #3(b) and #4. Item #3(b) establishes a limitation of "no greater risk of harm", an acceptable standard, while #4 suggests a less-restrictive standard of "significant risk of harm". The use of both of these two terms in this document is acceptable only so long as it is clearly specified and understood that both and the more restrictive apply in each case; i.e., that changing the use of and public access to a parcel (a) will not create a greater risk of harm and (b) does not represent a significant risk of harm as defined in the current MCP (310 CMR 40.00) and as determined following the procedures of 310 CMR 40.0900 et. seq.

Item #5 of the proposed Notice refers to a "hazardous materials management plan (HMMP)" for future construction activities, presumably those activities carried out by subsequent owners of parcels and not by the MWRA. It should be clear that the MWRA's activities will be governed by the Construction Procedures Document. Since the Waiver of Approval does not speak to construction activities by others, the specific references to the MCP for the HfMMP should be set forth. It would be preferable were the MWRA to proceed to propose a revision to the Construction Procedures Document as called for by the City and envisioned by the Waiver of Approval, and to make that document applicable to all construction activities on the Property, regardless of by whom carried out.

The FRSA remains a Public Involvement Site under the MCP/Waiver of Approval. As such, all findings, Determinations, Opinions, and the like should be required to be publicly noticed, be available for public inspection and comment, and should also be required to be filed with the appropriate municipal agencies which will assume regulatory and public health protection jurisdiction over parcels of the Property when disposed of by the Authority.

Sincerely,

M. Jane Gallahue, Commissioner David, P.ey., Quincy Department of Health Consultant to the City of Quincy cc Mayor James A. Sheets Mr. Steven McGrath, City Solicitor Mr. J. A. MacRitchie, Legal Counsel Mr. Peter Koff 0 4

Mr. Peter Lapolla, Town of Braintree James Goldstein, TELLUS Institute Mr. John J. Fitzgerald, DRE/BWSC, DEP/NERO DEPARTMENT OF HEALTH

(617) 376-1270 M. JANE GALLAHUE, M.P.H., C.H.O. COMMISSIONER OF PUBLIC HEALTH

November 21, 1994

Mr. Jose Vincenty Public Contact Person MWRA Charlestown Navy Yard 100 First Ave. Boston, MA 02129 Re: MWRA FRSA Waiver Submittals: GZA Completion Statements and Opinion Dear Mr. Vincenty:

These comments are submitted on behalf of the City of Quincy with respect to hazardous waste matters affecting the MWRA properties in Quincy and Braintree, formerly the Fore River Shipyard of General Dynamics and now referred to as the Fore River Staging Area (FRSA). They are in response to the Public Notice of November 1, 1994 concerning WAIVER SUBMITTALS consisting of COMPLETION STATEMENTS and OPINION of GZA GeoEnvironmental, Inc. on behalf of General Dynamics Corporation and of a FORM OF NOTICE OF LAND USE STIPULATION proposed by the MWRA; all in the context of the MA DEP Waiver of Approvals granted MWRA and General Dynamics jointly, pursuant to MGL Ch.21E and the MCP.

The interests and concerns of the City of Quincy with these and other matters affecting the FRSA are numerous, and include concern for the protection of the health of its citizens who may live or work in the vicinity and for the environment of the Quincy Point area and the Fore River region. The City also recognizes that ultimate disposition of those portions of the property not needed by the MWRA will require its agencies and employees to exercise duties and responsibilities with respect to the properties and activities thereon. The City is also actively supportive of efforts to return so much of the property as possible to productive utilization by the private sector, consistent with good stewardship of the resource.

J.F.K. Health Center, 1120 Hancock Street. Quincy MA 02169-4313

PRINTED ON RECYCLED PAPER -2-

GENERAL COMMENTS: The subject Completion Statements and Opinion are those of GZA GeoEnvironmental,Inc., the Consultant of Record to General Dynamics, and are submitted to General Dynamics. It is noted that the Application for Waiver of Approvals was jointly submitted by the MWRA and General Dynamics. The DEP approval thereof was issued on 3/2/94 to the joint applicants, and in Part IV thereof states "...the Department continues to hold both parties jointly and severally liable for necessary response actions at this site... "and".. .both parties are jointly and severally responsibile for meeting the requirements of 310 CMR 40...". Therefore, the City withholds final comment on these matters until the Consultant of Record to the MWRA also submits Completion Statements addressing the subject properties and concerns, or until there is a formal joining by the MWRA and its Consultant in the GZA/General Dynamics submittals. This position applies to each of the GZA Completion Statements discussed below, and to the GZA Opinion. It is also noted with concern (as has been done separately in comments on the proposed Notice of Land Use Stipulation) that the Completion Statements rest on the assumption of present and future land usage being limited to "industrial and business office nature" as proposed by the responsible parties. Until the finalization of that Notice and its entry with respect to appropriate properties, it does not appear to the City that the Completion Statements can be considered to be other than proposals subject to yet-to-be-completed actions by the MWRA. The City does not have the "notice regarding environmental conditions and remedial actions at the shipyard" as recorded on 11/17/87 (GZA Completion Statement, Section 1, Part VI); and requests that this "deed notification" be included in Completion Statements, where applicable. The substance of such notifications is of more concern to the public than is the mere recitation of compliance with a DEP administrative requirement, and may be important to the assessment of the Completion Statement. There is a generic concern with both the MCP process as it is currently established and with the terms of this specific Waiver of Approvals, which the City has expressed on several occasions in the past. The substance of the concern is that the judgment of consultants has replaced the judgment of DEP as to the adequacy of site evaluation and remediation measures. - 3 -

We understand the circumstances which forced DEP to adopt the innovative procedures of the MCP, but expressed the strong opinion that for the FRSA, DEP direct oversight should have been retained. Its absence forces the City to choose between "trusting the consultant" and investing its own resources in technical review. In this situation we both have a high regard for Dr. Feldman and GZA, and have readily available most of the essential documentation should we choose to undertake detailed review. Nevertheless, it must be recognized that successful consultants perceive and are sensitive to the agendas of their clients, creating potentially awkward situations. SECTION 1:-PCB-CONTAMINATED SOIL Please be referred to our comment above concerning industrial and business usage as it may apply to future use of portions of this property which may be affected by PCB's. SECTION 2:- OUTSIDE PROPERTIES;AREA 4 This section unfortunately illustrates the complexity and the problems induced by: (A) the MA DEP acceptance in 1987 of the "industrial and business office use" "standard", particularly as applicable to the entire "site" (apparently defined for these purposes as the entirety of the General Dynamics holdings acquired by the MWRA); and (B) both the conditions of that transfer of title and the MA DEP Waiver of Approvals granted jointly to the responsible parties. The parcels in questions were "never industrial in nature" (MA DEP, based on GZA site investigations), and thus the "industrial and business office use" criterion should not then or now be applied to them; nor should the Completion Statement be based on that criterion. The MWRA's Consultant of Record has submitted detailed Phase I site investigations of four of these properties, finding in three of the four cases no contamination and in the fourth case a minimal level of PAH contamination likely typical of urban soils. It appears from those reports that residential use would be permitted without further remediation. It is therefore recommended that a Joint Completion Statement be issued to that effect. SECTION 3: OUTSIDE PROPERTIES-AREA 5, EXCEPTION SECTION 5E These properties are in the Town of Braintree, and comments on behalf of the City of Quincy are not appropriate. (Nevertheless, the City would hold that a Completion Statement by the MWRA Consultant of Record should be submitted.) -4-

SECTION 4: CHLORINATED SOLVENTS, MINERAL SPIRITS, AND LONG-TERM MONITORING (Completion Statement by the MWRA's Consultant of Record should be submitted.)

SECTION 5: BENT'S CREEK AREA The matter of the separation of responsibility for the "oil pocket" in the vicinity of Building 9 from that for the remainder of the Bent's Creek area is of concern. First, the City has no record of the DEP action reported by GZA on page 1, nor do we find it set forth in the March 2, 1994 DEP letter. Second, please be referred to our initial GENERAL COMMENT, above, discussing the joint responsibilities of the parties under the Waiver of Approvals. We have yet to be fully satisfied with explanations provided for the presence underground of free petroleum product or dissolved PHCs in the Bent's Creek area, outside of the Building 11 oil plume. We remain concerned about potential migration of PHC into the major storm drain traversing the area, which discharges into the Fore River between Piers 1 and 2, as the most likely route for possible contamination of that water body. Continuing routine monitoring of discharge from this drain for PHC for a period of several years would seem appropriate, prior to accepting a "completion statement" in regard to the Bent's Creek area. It appears from the record that the most critical on-going concern with the portion of the FRSA lying generally between Buildings 8 and 11 and to the west of that area is the likelihood of encountering oil-contaminated soil during excavation. Obviously the "oil plume" area and the "Building 9 oil pocket" require careful delineation and special construction procedures to avoid interference with on-going remediation measures and mobilization of remaining contamination. It appears that the remainder of the "Bent's Creek area" should receive comparable attention. Thus Completion Statements for these areas should incorporate the MWRA's revisions to the Construction Procedures Document, made applicable to non-MWRA construction activity. (In this regard, please see also our comments of November 21 on the proposed Notice of Land Use Stipulation.) SECTION 6: SOUTHERN BOUNDARY AREA (This area is presumed to be bounded on the north by the storm drain/Hayward Creek conduit which traverses the area and likely would intercept any contamination migrating north with groundwater from areas to its south. Therefore, the City concludes the Southern Boundary Area lies almost entirely within the Town of Braintree and assumes that Town will address this Completion Statement and Opinion, as well.) -5-

This Section is the most comprehensive and well-documented of the several Completion Statements submitted for comment at this time. This level of attention is appropriate given the nature of the problems in the Southern Boundary area, reported contaminant migration from off-site, and commitments to remedial action by others. These were precisely the factors that led us to urge DEP to exclude the Southern Boundary area from Waiver of Approvals, and to continue active oversight of remediation actions affecting the area. General Dynamics may properly be "off the hook" with respect to continuing remediation in this area, but should be required to enforce the terms of its settlement of litigation with Clean Harbors to the extent those terms require or affect cleanup of the Southern Boundary area. It behooves EPA and DEP as responsible regulators, and the MWRA as the affected property owner, to maintain an aggressive oversight of remediation activities required of any and all parties in the area; and to require monitoring as feasible to ensure the absence of discharge of contamination to the Fore River. (Completion Statement by the MWRA's Consultant of Record should be submitted.) SECTION 7: OPINION REGARDING RESPONSE ACTION OUTCOME RTN 3-10266 (Opinion by the MWRA's Consultant of Record should be submitted.) We appreciate the opportunity for the City of Quincy to comment on these matters at this time, and assure all parties of the City's continuing strong concerns for the protection of health and the environment and for the effective redevelopment of the FRSA.

Sincerely,

M.Jane Gallahue,MPH, Commissioner David Standley,P.E. Quincy Department of Health Consultant to the City of Quincy cc: Mayor James A. Sheets Steven J. McGrath J.A. MacRitchie Peter Koff, Davis, Malm, D'Agostine James Goldstein, TELLUS Inst. John J. Fitzgerald, MA DEP/NERO Robert White, General Dynamics Larry Feldman, GZA Maggie Debbie,MWRA .1

FOLEY, HOAG & ELIOT

ONE POST OFFICE SQUARE

BOSTON. MASSACHUSETTS 02109-2170

TELEPCONE (fi7) 832-1000 IN 'NASHINGVON. D C

CABLE ADDRESS FOLEZ'OAG" 65SLSTREEZ N'

FACSIMILE 617) 832 7000 SUITE 850 WASHINGTON 0 C 20036 -ELEX 94093 TELEPHONE (202) 775-060

LAURIE BURT (617) 832-1 1 11

November 1, 1994

VIA FEDERAL EXPRESS

Waiver Submittal Commonwealth of Massachusetts Department of Environmental Protection Northeast Regional Office Bureau of Waste Site Cleanup 10 Commerce Way Woburn, MA 01801

RE: MWRA Fore River Staging Area (former General Dynamics Shipyard) Waiver Submittals: Completion Statements, Opinion and Form of Notice of Land Use Stipulation Release Tracking #3-0536 and # 3-10266

Dear Madam or Sir:

Enclosed please find two (2) sets of a Waiver Submittal, entitled "Completion Statements in Conjunction with Waiver Approval, Former General Dynamics/Quincy Shipyard, Quincy, Massachusetts", prepared by GZA GeoEnvironmental, Inc. ("GZA"), the Consultant of Record for General Dynamics Corporation, for the above-referenced site. This document includes six (6) Completion Statements and an opinion as required by the Waiver of Approvals, granted by the Department of Environmental Protection ("DEP") on March 2, 1994. The submittal addresses the following outstanding issues identified by DEP: (1) Polychlorinated Biphenyl (PCB) Contaminated Soil; (2) Mineral Spirits. Chlorinated Solvents and Long-Term Monitoring; (3) Bent's Creek Area; (4) Outside Properties - Area 5, Except Section 5E; (5) Outside Properties - Area 4 for the period through 1987 (MWRA's purchase of the Shipyard); (6) Southern Boundary Area: and (7) DEP Release Tracking Number 3-10266 for overspill from the oil recovery system. Waiver Submittal Commonwealth of Massachusetts Department of Environmental Protection November 1, 1994 Page Two

Also included with this Waiver Submittal are two (2) copies of a form of Notice of Land Use Stipulation, prepared by the Massachusetts Water Resources Authority ("MWRA") and General Dynamics, as required by DEP's Waiver of Approval to ensure site use for activities of an "industrial and business office nature" and to establish a procedure for potential land use changes.

Public Notice of these Waiver Submittals has been given today pursuant to the updated Public Involvement Plan ("PIP") for this site. A copy of this Notice is enclosed for your reference. By copies of this letter, MWRA and General Dynamics are providing copies of these Waiver Submittals to the information repositories in Braintree, Quincy and Weymouth. MWRA has already been provided copies of these documents. The Waiver Submittals will be available for public review and comment at these three repositories and the DEP Northeast Regional Office through November 21, 1994 in accordance with the PIP and the MCP. Would you please place one set of the enclosed Waiver Submittals in your public review file for this purpose.

Thank you for your cooperation.

Sincerely,

aurie Burt

LB:tab Enclosures cc: Thayer Public Library, Braintree [Enclosures via Federal Express] Thomas Crane Library, Quincy [Enclosures via Federal Express] T fts Public Library, Weymouth [Enclosures via Federal Express] haron A. Gobiel, DEP John J. Fitzgerald, P.E., DEP Douglas B. MacDonald, MWRA Nicholas D. Chabraja, Esq.. General Dynamics Corporation Rhonda Russian, Esquire, MWRA Maggie Debbie, MWRA Leon Lataille. MWRA Robert White/Dan Kelley, General Dynamics MASSACHUSETTS WATER RESOURCES AUTHORITY (ha rlestown Nivy Yard 100 First Avenue I|sson, Massat husetts 0212 -42 60() C -I U V lt,110 011,11UClt 02 19Jelephont (61. Fa' sim ile: l, 2I - ~41

November 1, 1994

PUBLIC NOTICE RE: WAIVER SUBMITTALS COMPLETION STATEMENTS, OPINION, and FORM OF NOTICE OF LAND USE STIPULATION MWRA Fore River Staging Area (former General Dynamics Shipyard) Release Tracking #3-0536 and #3-10266

Dear Interested Party:

Please be advised that GZA GeoEnvironmental, Inc. ("GZA"), the Consultant of Record for General Dynamics Corporation has prepared six (6) Completion Statements and an opinion as required by the Waiver of Approvals, granted by the Massachusetts Department of Environmental Protection ("DEP") in March, 1994. DEP's Waiver of Approvals requires that "[o]utstanding issues [as identified by DEP in the Waiver of Approvals] must be addressed by the Consultant of Record as part of the Waiver response actions." In accordance with the Waiver Approval, these Waiver Submittals address the following outstanding issues identified by DEP: (1) Polychlorinated Biphenyl (PCB) contaminated Soil; (2) Mineral Spirits, Chlorinated Solvents and Long-Term Monitoring; (3) Bent's Creek Area; (4) Outside Properties - Area 5, Except Section 5E; (5) Outside Properties - Area 4 for the period through 1987 (MWRA's purchase of the Snipyard); (6) Southern Boundary Area; and (7) DEP Release Tracking Number 3-10266 for overspill from the oil recovery system.

Also included is a form of Notice of Land Use Stipulation prepared by the Massachusetts Water Resources Authority, as required by DEP's Waiver of Approvals to ensure site use for activities of an "industrial or business office nature" and to establish a procedure for potential land use changes.

The Waiver Submittals listed above are also described in the Updated Public Involvement Plan, dated September, 1994, for the subject site. These Waiver Submittals are 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 Library, 46 Broad Street, Weymouth

Thomas Crane Public Library, 40 Washington Street, Quincy

DEP Northeast Regional Office, 10 Commerce Way, Woburn, MA 01801 (Please call DEP File Review Contact Person at (617) 935-2160 to make an appointment to review the document.)

Please forward all comments to the attention of:

Jose Vincenty Public contact Person MWRA Charlestown Navy Yard 100 First Avenue Boston, MA 02129

The 20-day public comment period for these Waiver Submittals will expire on November 21, 1994.

DISTRIBUTION: FRSA PIP Mailing List NOTICE OF LAND USE STIPULATION

NOTICE is hereby given as of the day of , 1994, by Massachusetts Water Resource Authority, a public body corporate and politic, with an office at Boston, Massachusetts ("Grantor") that:

1. Grantor is the owner in fee simple of the land located in ,_ 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 has been approved by the Massachusetts Department of Environmental Protection 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 0 0 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 shall 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 contaminated 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 day of

, 1994.

MASSACHUSETTS WATER RESOURCE AUTHORITY

By:

-2- COMMONWEALTH OF MASSACHUSETTS

ss. , 1994

Then personally appeared the above-named

of and acknowledged the foregoing instrument to be the free act and deed of before me

Notary Public

My Commission expires:

- 3 - EXHIBIT A

DESCRIPTION OF PROPERTY

[Including title reference]

LIB 3 /0094745.02 -4- STAFF SUMMARY

TO: Board of Directors FROM: Douglas B. MacDonald, Executive Directc DATE: September 30, 1994 SUBJECT: FRSA Development - Lane, Frenchman 5 Amendment #2

COMMITTEE: Administr & Finance

Maerie Debbie. Dir Real Prop/Env. Mnvt Preparer/Title Division Dired Approval

RECOMMENDATION: To authorize the Executive Director to execute an amendment to the contract with Lane Frenchman to extend the term on the 18-month contract for another six months, until April 1995.

DISCUSSION:

Backgyround: Lane Frenchman & Associates was chosen by the Fore River Staging Area Development Committee in April 1993 to assist the committee, comprised of community representatives from Quincy, Braintree, and Weymouth and staff from Coastal Zone Management and the MWRA, in developing a long term reuse plan for the FRSA.

This plan was completed in July 1994 and is currently being printed. The final report recommends the pursuit of catalyst uses at the FRSA immediately. To this end the Development Committee, with MWRA staff acting as Project Director, awarded a $24,000 amendment to LFA in July to actively pursue these concepts. As a result of these efforts, the National Park Service has included the FRSA in its draft plan for a Harbor Islands National Recreation Area as a site for a ferry. That amendment was funded by CZM, Quincy, Braintree and the MWRA.

The consultant is also actively working with various groups to review the Marine Technology Center concept, as defined in the National Shipbuilding and Conversion Act, and interpreted by the Defense Advanced Research Projects Agency (DARPA), US DOT, the Office of Congressman Studds (sponsor of the legislation). The consultant is also reviewing other preliminary proposals for Maritime Technology Centers, investigating budgets for existing programs and identifying maritime industries in the region that may be candidates for our site.

1 This amendment is for time only, as the existing contract terminates in October 1994. BUDGET/FISCAL IMPACT: None

MBE/WBE: Same as original amendment

ATTACHMENTS: Lane Frenchman update on progress of the Marine Technology Center.

2 0

To: Fore River Staging Area Development Committee From: Dennis Frenchman LFA; Joanne Crowe, C&C Subj: Progress on Center for Marine Engineering and Industry Date: September 27, 1994

Work has continued on Task I of the Amendment, including further research on precedents and outreach to potential institutional and industry partners in MEC. Work was iitiated on Task 4 with development of a Draft Prospectus for the Center for Marine Engineering and Industry at the FRSA.

Discussions to date have been held with: Institutions/Agencies NT Dr. Chrys Chryssostomidis, Head, De patent of Ocean Engineering and Director, Grant Program UMass. Dartmouth Dr. Barry Colt, Center for Marine Science and Technology Captain Renato Miele W.H.O.I. Quisset Development Corporation Hartley Hoskins, Director, Quisset Development Corporation, Secre rMTS/NE Comm. on Merchant Marine and Fisheries Carl Bentzel, Congressman Studds ce Advanced Research Projects Agency Robert Schaffern, Maritech Program Manager Mass Marine Technology Network Jack McCann, President, Bay State Skills U. Maryland, Columbus Center Mary Moynihan Scripps Institution of Oceanography Industry Marine Technology News Maggie Linsky Merrill, Principal, Marine Marketing Services Marine Technology Society/NE Peter Tebeau, President Rateon Stanley Chamberlain B-Sa Systems Nick Emord Cordage Institute Gale Foster Economic Innovation Center Winder Snodgrass Signus Technologies John Irza Drafts of interview notes with the above individuals are included with this report. 0 0

MEC, page 2

Additional contacts planned to complete outreach effort include: MIT Follow-up meetin with Department of Ocean Engineering and Department of Civil Enrieng Mass Maritime Academy Peter Mitchell, President; Thomas Bushy, Dean of Students UMass Dartmouth Center for Marine Meeting in Dartmouth with Dr. Barry Colt and Science and Technology selected faculty associated with the Center Bay State Skills Jack McCann, to further discuss potentials for integration of MA Marine Technology Network with MEC Congressman Studds Office Coordination to discuss meeting of potential sponsors.

Other key activities undertaken during this period include: o Completion of a Draft Prospectus for MEC. The Prospectus outlines the key proposed features of the Center and will be expanded and developed as the project continues. The Prospectus was distributed to a short list of institutional and industry contact to obtain some initial feedback on the concept. o A meeting of key industry players was convened to review the Draft Prospectus and provide input on industry needs and potential avenues for development of MEC. Attending the meeting were Maggie insky Merrill of Marine Marketing (also representing Jack McCann of Bay State Skills), Nick Emord of Bell-Sea Marine Systems, and Hartley Hoskins of W.H.O.I. (also representing the MTS/NE. . o Continued research on precedents, including the Columbus Center and Scripps Institution of Oceanography, focusing on program components, management and operations. o Costs were developed for base building renovation for MEC (and FRSA infrastructure elements) for submission to the.Mass Ports Commission for potential inclusion in a state bond issue. Key issues and directions for MEC were summarized in the August Progress Report Further contacts and meetings have confirmed many of the preliminary conclusions. Several points have been stressed in subsequent outreach and feedback on the Draft Prospecwut o MEC needs to be market driven. Strategic research is needed as the Center is being planned, to determine the national and international market for goods and services that would emerge from MEC The results of such a study could shape the operation and concept of the Center. MEC, page 3 o A Marine Technology Industry Council is being proposed by Bay State Skills, the Maritime Technology Society/NE, and UMASS Dartmouth as the basis for a Network of marine industries that will facilitate oint development ventures, purchas' marketing, and information sharing by companies in Massachusetts. The uncil, if established, could provide the focal point for industry involvement in the formation and operation of MEC. Timing is good since both efforts are in their formative stages. o Marine technology industries in the region share a common link in that they are all focused on technology related to ships, including navigation, communications, and safety at sea. A key contribution which could be made by MEC would be to bring these individual technologies together so that they could be marketed as systems to end users. This would bring unit cohesion to what are now individual scattered companies. The initial focus of the Center's program should possibly be on vessels; structures will evolve with the market. o The potential relationship with a shipbuilder on site could be a powerful motivation for smaller companies to move to the shipyard if the shipbuilder were willing to use local technology wherever practical A kind of desipn/build relationship could be worked out to keep prices competitive and develop integrated systems tailored to the need. Discussions with the shipbuilder and local marine technology companies should be a high priority if and when the lease is finali d. o Access to the water and decent staging space is important to the research and development component of MEC, and potentially critical to MI's involvement. The MWRA has identified Pier 1 as the site for research vessel docking in negotiations with the shipbuilder. If a portion of Building 11 is not available for staging as ested in the Plan, replacement space will need to be found. Opportuities may available in Building 48, 8, or on a temporary basis in Building 52 (until needed by USNS Musuem). This needs further study. o Sources of financing for MEC need careful study. Current efforts are aimed at a proposal to ARPA to obtain start up funds for development of the Center. A proposed bond issue by the state for port facilities would be a good source of match. other funding sources may be available. For example, ARPA is currently solici proposals directly from industries to develop new technologies and consortia are sccally encouraged. The FRSA may rovide a venue for such development, even in advance of establishing MEC. The NCR! proposal submitted on behalf of the Development Committee, if funded, will provide resources for funding research and additional proposals.

Next steps include: 1. Completion of contacts identified above. 2. Meeting of potential sponsors to discuss formation of MEC consortium 3. Refinement of Prospectus as a basis for proposal to ARPA to be prepared by the sponsors. Ate- wif

Commonwealth of Massachusetts Executive Office of Environmental Affairs Department of Environmental Protection WimLam F. Weld Govemrn~ Trudy Coxe Secretry, EOEA Thomas B. Powers Actng Cormmoner

October 3, 1994

Mr. Douglas B. MacDonald Massachusetts Water Resources Authority Charlestown Navy Yard 100 First Avenue Boston, MA 02129 RE: Release Tracking #3-0536/Quincy Shipbuilding Facility

Dear Mr. d

I understand the Massachusetts Water Resources Authority ("MWRA") has progressed in itsnegotiations regarding the leasing of approximately 107 acres of the former Quincy Shipbuilding facility on East Howard Street, Quincy ("the site") . The site is currently a "non-priority waiver site" undergoing remediation for environmental contamination by the MWRA and General Dynamics. As you know from our several discussions and our letter of August 22, 1994, the Massachusetts Department of Environmental Protection applauds your plans to reinstitute an extensive shipbuilding business on this site. The public interest is extremely well- served by this unusual opportunity to return contaminated property to productive use, create substantial jobs and tax revenues for the citizens of the Commonwealth, and to use this site for maritime activities of an industrial/business nature.

In addition to the concerns addressed about the new lessee's liability under MGL. c. 21E (outlined below) in my letter of August 22, 1994, I understand that the MWRA is concerned about expectations DEP might have concerning future investigations at the site.

one Winter Street 0 Boston, Massachusetts 02106 O FAX (617) 556-1049 * Telephone (617) 292-5500 Douglas B. MacDonald October 3, 1994 page -2-

To recap my earlier letter, concerns had been raised about potential liability pursuant to MGL. c. 21E for the proposed new lessee. On August 22, 1994, I wrote you and the proposed lessee to indicate DEP would not seek to hold the proposed new lessee responsible for costs associated with remediation of existing contamination as of the date of execution of the lease. Please see my August 22, 1994 letter for details.

With respect to concerns about future investigations, please be advised that DEP does not expect the MWRA to go out of its way to look for additional contamination. Further, since the Department believes that extensive investigation and assessment have already been conducted at this site, and that the MWRA and General Dynamics caA meet the Waiver of Approvals requirements, the Department will not require the MWRA to do anything more than it has already committed to do at this site, so long as obvious signs of imminent hazards or gross contamination are not ignored and that any waste from construction projects are handled appropriately.

We remain available to representatives of MWRA and Northeast Shipbuilders to work out details as needed. Please contact James Colman, Assistant Commissioner, DEP Bureau of Waste Site Cleanup, should you or your staff wish to arrange a meeting. Mr. Colman can be reached by telephone at (617)292-5648.

Sinerely,

Thomas B. Powers Acting Commissioner

TBP/JCC/pg PUBLIC INVOLVEMENT PLAN

FORE RIVER SHIPYARD (FORMERLY GENERAL DYNAMICS) DISPOSAL SITE 97 East Howard Street, Quincy, Massachusetts

Prepared by:

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

Updated by:

Massachusetts Water Resources Authority (MWRA) and General Dynamics Corporation September, 1994

Contact for more information:

Jose Vincenty, MWRA (617) 241-6057 PUBLIC INVOLVEMENT PLAN

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

I. INTRODUCTION

This document is the Public Involvement Plan ("PIP" or the "Plan") for the Fore River Shipyard, now owned by the Massachusetts Water Resources Authority ("MWRA") and formerly owned by General Dynamics Corporation. As explained in more detail below, this Plan was originally prepared in 1989 by the Department of Environmental Protection ("DEP", formerly the Department of Environmental Quality Engineering, or "DEQE"). The Plan was updated in May 1994 by MWRA and General Dynamics as required by the DEP and the 1993 revisions to the Massachusetts Contingency Plan ("MCP"). Under the DEP's recent Waiver of Approvals for the site, granted in March 1994, public involvement activities formerly undertaken by DEP under the Plan must be undertaken and implemented throughout the remainder of the response action process by MWRA and/or General Dynamics. This revised Plan incorporates these modifications and updates the status of remedial response actions at the site.

In May 1988, the DEP (then DEQE) received a petition from the East Braintree Civic Association. The petition expressed the group's concerns about the General Dynamics site (now known as the Fore River Shipyard site) and requested that the site be designated a "Public Involvement Plan Site" (PIP) in accordance with the 1988 Massachusetts Contingency Plan (MCP), 310 CMR 40.203(1).

Prior to the 1992 amendments to the Massachusetts "Superfund" Law (M.G.L. c. 21E), DEP was responsible for overseeing remedial response actions at sites where oil or hazardous materials have been released to the environment. Under the 1992 amendments and the 1993 revisions to the MCP (310 CMR 40.0000), response actions at most sites may be handled by private parties. Response actions include: determining the nature, source and extent of the contamination; identifying risks posed by the site; determining whether cleanup actions are necessary, and if necessary, determining and implementing the most appropriate actions. In addition, the remedial response action process provides opportunities for public involvement throughout the process. The remedial response action process is established by the Massachusetts Contingency Plan (310 CMR 40.00).

Public involvement during the remedial response action process is undertaken to ensure that the public is both informed of and involved in planning for remedial response actions. For disposal sites at which the public indicates interest in becoming involved in this process, DEP designates the site as a PIP site, and prepares a plan which identifies specific activities that will be undertaken to address public concerns to the extent possible. The draft Plan is reviewed by the public and revised, where appropriate, based on comments submitted to DEP. The final Plan is then implemented in conjunction with the development and implementation of remedial response actions for the disposal site. DEP has designated the Fore River Shipyard site a PIP site, in accordance with the Massachusetts Contingency Plan; DEP presented the draft Plan for review at a public meeting held on January 26, 1989. An update on the remedial response action planning process for this site was also provided. Anyone who wished to comment on the draft Public Involvement Plan was encouraged to do so. Comments were submitted between January 26 and February 16, 1989. DEP finalized the Public Involvement Plan in May, 1989. Since then DEP has conducted periodic public information meetings and status reports have been regularly submitted to the DEP and the designated Information Repositories. An updated Public Involvement Plan was made available for public review and comment from June 29, 1994 through July 19, 1994. Comments were submitted by the Quincy Department of Public Health, to which MWRA and General Dynamics responded in a letter dated August 25, 1994. This updated Public Involvement Plan was finalized in September, 1994 and is organized as follows. Section II contains background information on the site, the history of remedial response actions and public involvement. Section III explains how the remedial response action process can address community concerns which have been raised during the development of the Public Involvement Plan. Section IV describes the public involvement activities chosen for this site. Section V outlines the roles and responsibilities of those involved in implementing the Public Involvement Plan. Section VI explains how the Plan can be revised in the future.

II. BACKGROUND INFORMATION

A. Site History

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

-2- the Shipyard. The Shipyard was formally closed in May 1986, and all industrial operations ceased.

In February 1986, in anticipation of the sale of the property, General Dynamics hired Goldberg-Zoino & Associates (GZA) to begin a comprehensive environmental assessment. General Dynamics submitted the results of this investigation and proposed remedial actions to DEP in May 1986. This site assessment revealed certain areas of soil and groundwater contaminated with fuel oil, gasoline, chlorinated solvents, acid extractable/base neutral compounds, metals and PCBs. On October 21, 1986, DEP formally notified General Dynamics of its responsibilities and liabilities under M.G.L. c. 21E by issuing a Notice of Responsibility (NOR) letter. During 1987, General Dynamics submitted several supplemental assessment reports. After reviewing this information and performing a number of site inspections, DEP determined that overall, the assessment was sufficient to identify all areas of the site that may pose a significant threat to public health or the environment. Based on that determination, DEP, in a letter dated September 20, 1987, established remediation requirements for the contaminants identified. This letter also contained the Department's requirements for additional information. In November 1987, the Massachusetts Water Resources Authority (MWRA) purchased the Shipyard. MWRA uses portions of the property for various components of the Boston Harbor Project (BHP), including as a laydown and staging area for contractors and location of the roll-on/roll-off facilities. The Shipyard is also used as the location for the MWRA residuals processing facility.

As part of the Purchase and Sales Agreement between General Dynamics and MWRA, MWRA hired NUS Corporation to conduct an independent review of all previous assessment and cleanup activities at the site, and conduct its own assessment of environmental conditions on the property. In March 1988, MWRA provided the results of NUS's investigation to DEP. At General Dynamics' request, GZA evaluated the NUS study and conducted an evaluation of the risk to public health and the environment posed by the Shipyard. This evaluation was based on the highest contaminant concentrations reported by both NUS and GZA. After reviewing both these reports, DEP determined that no new significant areas of contamination have been identified by these reports. DEP's decisions about the adequacy of remedial actions at the Shipyard have been based on the understanding that the property will continue to be used for industrial purposes in the future. To ensure that future construction at the Shipyard does not pose a threat to workers at the site, site neighbors or the environment, MWRA hired a consulting firm (Haley and Aldrich) to prepare a construction procedures document (CPD), dated June,

-3- 1989, which provides: (1) criteria to be used to determine the extent of contamination, if any, in the specific area being developed, (2) procedures to be used to classify, handle, reuse or dispose of excavated soils and groundwater generated during dewatering, and (3) procedures to be followed by contractors to prevent any potential exposure of workers to contaminants and prevent the contaminants from leaving the construction area, either in the air, water, or inadvertently on vehicles. This document was approved by DEP and will be revised by MWRA as part of work to be conducted under the approved waiver. Under the Waiver of Approvals, MWRA may revise its construction procedures document with DEP approval.

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

Floating Oil Plume and Associated Contaminated Groundwater and Subsurface Soil: During the initial site assessment, a large release of oil from a leaking underground pipeline was identified in the central portion of the Shipyard. In October 1986, DEP approved General Dynamics' proposal to recover this oil. A system which recovers and treats oil and groundwater has been operating since October 1986. Several years of remedial monitoring data have demonstrated the effectiveness of the system to recover floating product and contain the plume.

As of May 20, 1994, approximately 415,157 gallons of oil have been recovered. The thickness of oil in the area has decreased from approximately 8 feet in some areas to 1.5 feet or less. Over 200 million gallons of recovered groundwater has been treated to levels below the discharge limits specified by DEP and the U.S. Environmental Protection Agency.

As required by DEP, in April 1988, General Dynamics submitted a feasibility study which evaluated remedial alternatives for the subsurface contaminated soil associated with the oil plume. By letter dated June 5, 1989, DEP agreed with the study conclusions that no feasible or practical remedial solutions currently exist to significantly reduce the residual oil contamination in soils above the water table. DEP further concluded that the current product recovery and treatment system is a temporary, rather than permanent solution with respect to these subsurface soils.

General Dynamics continues to review with its consultants the efficiency of the oil recovery system and to modify the system as appropriate, in accordance with DEP's approval letters dated October 21, 1986 and September 20,

-4- 1987 and applicable standards and requirements pursuant to Chapter 21E and the MCP.

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

One of the areas of oil stained surface soils, located next to the Central Yard Oil Plume, was too extensive to completely remove all the oil-contaminated soil. The contaminated soil was excavated to the extent feasible and replaced with clean soil under DEP approval and will be addressed as part of the residual contamination of subsurface soils in the Central Yard Oil Plume, described above, and the Waiver Approval.

Another extensive area of oil/gasoline-contaminated soil was identified on a parcel outside the main Shipyard site, near its southwest boundary. This area is referred to as "Area 5E" and is not covered by the Waiver Approval issued by DEP to MWRA and General Dynamics. Area 5E is being addressed by the off-site source of the contamination -- Flibotte's Auto Salvage under a separate Waiver approved by DEP (Application #93-3-1605-1) and as part of a litigation settlement agreement with General Dynamics.

Polychlorinated Biphenyls (PCBs): Prior to closing the Shipyard, General Dynamics began a program of decommissioning and retrofilling its electrical equipment containing PCBs. General Dynamics removed soil and cleaned up foundation pads at locations of equipment which formerly contained PCBs. Where feasible, PCB contaminated soil was removed until PCB concentrations were lower than 1 milligram/kilogram and pads stained with PCB oil were cleaned until PCB concentrations were lower than 100 micrograms/100 square centimeters. General Dynamics subsequently capped and sealed those areas where remediation to these levels was infeasible. The removal of PCB-contaminated soil and oil-stained pads was completed in April 1988, and sampling to verify the initial sampling results was completed in May 1988. Approximately 115 tons of contaminated soil and debris were removed from the site. A report summarizing these

-5- activities was submitted to DEP in August 1988. DEP conditionally approved these response actions in a letter dated December 7, 1988 to General Dynamics, indicating that the Department's requirements for remediation of these areas have been met and that no further actions were required with the exception that confirmatory information be provided. General Dynamics provided this information to DEP in March 1989. In its March 2, 1994 Waiver Approval letter, DEP indicated that the Consultant of Record must review and confirm this information as part of the Waiver response actions.

Asbestos: General Dynamics removed or repaired damaged or exposed material containing asbestos in exterior locations to prevent potential asbestos releases to the environment. No asbestos was detected in any soil samples taken across the site. By letter dated September 20, 1987, DEP indicated that no additional remedial response actions were required in this regard. However, any future asbestos removal may require notice to DEP's Division of Air Quality Control's Asbestos Program.

Southeastern Boundary: Since 1988, General Dynamics has conducted further investigations of the southern boundary area. As part of a litigation settlement agreement with General Dynamics, remediation of contaminated groundwater in the southeast boundary area of the property is being implemented by Clean Harbors, Inc., one of the upgradient neighbors of the former Shipyard. The dissolved contamination in this area will most likely require some groundwater treatment and/or monitoring. Clean Harbors' response actions are being performed pursuant to a RCRA Consent Order under the Federal RCRA Corrective Action Program in consultation with EPA and DEP. Under the 1993 MCP, DEP has conditionally determined that the Clean Harbors site is "Otherwise Adequately Regulated" by the RCRA Corrective Action Program. CITGO, another upgradient neighbor, is addressing its portion of the southeast boundary contamination under Chapter 21E and the MCP (DEP Case #3-0260). General Dynamics will review the adequacy of assessments and response actions for the southern boundary as part of the waiver process.

In December 1987, #2 fuel oil was discovered in one of the groundwater monitoring wells located next to the southeastern area. The source appears to have been an above-ground fuel oil tank and associated piping, which are now empty. Remediation of this area has been completed and a final report was submitted to DEP in December 1988. By letter dated February 20, 1990, DEP indicated that no additional remedial response actions are required for this area at this time; if, however, future development of the site requires that excavations

-6- be conducted underneath Building 54 and in the area of several underground utility lines south/southeast of monitoring well GD-3145C, additional remedial response actions may be required.

Confirmatory Sampling: As required by DEP in its January 8, 1988 letter, samples were taken and analyzed from 21 groundwater monitoring wells across the site to verify the results of previous sampling which identified the locations of groundwater contamination. General Dynamics submitted the results of this sampling to DEP in reports dated May and July, 1988. By letter dated October 12, 1990, DEP determined that DEP's "Confirmatory Sampling" requirements have been satisfied and, additional response actions are not anticipated. Long Term Monitoring: As required by DEP, quarterly monitoring of contaminated groundwater in selected areas of the site was performed by General Dynamics. These locations include three areas where groundwater has been contaminated with chlorinated solvents or mineral spirits. Monitoring was done to insure that contaminant sources had been terminated and that contaminant concentrations were decreasing over time. The results were submitted to DEP in reports dated May, July and October 1988, and January 1989. Based on these results, DEP determined that additional investigation was required in one of the areas of chlorinated solvent contamination. General Dynamics submitted additional information in a report dated April 12, 1989. In its Waiver Approval Letter, DEP indicated that review of this information must be conducted by the Consultant of Record as part of Waiver response actions.

Risk Assessment: MWRA presented the results of NUS's environmental assessment and comments on previous assessments and remedial activities to DEP in a report dated March 17, 1988. At General Dynamics' request, GZA reviewed the NUS study and conducted an assessment of the risks posed by the Shipyard. The GZA risk assessment focused on groundwater contamination from the site and its impact on the Fore River. It was based on the highest contaminant concentrations reported by either NUS or GZA. The risk assessment examined potential impacts to human health from eating seafood from the river. Other routes of exposure (such as ingestion of soil and groundwater, inhalation of vapors and particulate, and direct contact with soil) were evaluated, but not examined in detail because the site is paved and fenced, the saline (salt) groundwater in this area is not a potential drinking water source, and therefore there is no access to the contaminants on the site.

-7- The GZA risk assessment was submitted to DEP in a report dated June, 1988. DEP's Office of Research and Standards reviewed the risk assessment and agreed with the report's conclusion that the site, under its current use and present state, presents minimal risk to human health.

DEP has overseen the above response actions to ensure that they meet the requirements of M.G.L. c 21E. In 1986 and again in 1992, the law was amended to add a number of requirements for site cleanup. DEP's regulations detailing the remedial response action process, the MCP, took effect in October, 1988. This MCP was revised in 1993 to conform to the 1992 statutory amendments. Most of the response actions described above were performed before the 1988 MCP and 1993 MCP took effect and DEP's approvals were based on agency policies in effect at the time. Remedial response actions performed after October 1988, must comply with the applicable MCP regulations.

In summary, many decisions regarding the adequacy of assessment and remedial response actions have been made. Implementation of remedial response actions for some areas have not yet been completed and remedial response action plans for other areas are still being considered by KWRA and/or General Dynamics under the Waiver. Issues remaining for MWRA and/or General Dynamics include: reviews of information previously submitted to, but not yet approved by the DEP; floating oil in the central yard and subsurface soil contamination associated with this floating oil; the "Southeastern Boundary"; areas of elevated levels of chlorinated solvents and/or mineral spirits in groundwater; possible revision of MWRA's construction procedures document for future work in contaminated areas of the site; floating oil in the Building 9 area; and a land-use restriction. (See Exhibit III) Pursuant to DEP's Waiver Approvals, these outstanding issues will be addressed by General Dynamics and/or MWRA with the professional assistance of their Consultants of Record or Licensed Site Professionals (LSP).

PIP Status Reports have been periodically updated and provided to the public at Plan meetings, the DEP file and PIP Information Repositories. These Status Reports and the DEP approval letters issued prior to the date of the updated Plan, dated September 1994, are incorporated by reference in this Plan. Waiver of ADprovals

In 1993, MWRA and General Dynamics filed a joint Application for Waiver of Approvals for the Site pursuant to the MCP. Notice of the joint waiver application and opportunity for public comment on the application was provided from December 29, 1993 through January 31, 1994. The waiver application was also discussed at a meeting of the Fore River Staging Area Task Force and Fore River Development Committee on January 19, 1994; to which all persons on the Plan's mailing list and the public were invited. Comments from the City of Quincy were submitted to DEP,

-8- to which the Department responded in a letter dated March 2, 1994. On March 2, 1994, DEP approved the joint application for Waiver of Approvals, subject to conditions specified in the Department's "Waiver Approval Letter." As required by DEP's Waiver Approval Letter and the MCP, the MWRA and General Dynamics have signed and submitted to DEP the Waiver Application Disposition form, accepting the conditions and responsibilities of the Waiver Approval Letter. The joint waiver application, DEP's Waiver Approval Letter, DEP's Response to Public Comments, and the Waiver Application Disposition form are on file in the designated Information repositories.

B. Public Involvement History

East Braintree is the location of several large industries. In the winter of 1987, the East Braintree Civic Association was formed by neighborhood residents to "improve and maintain the quality of life in Braintree, specifically East Braintree". At the time of the group's formation there were several specific issues facing the community. Clean Harbors, Inc. was proposing to site a hazardous waste incinerator on its property, and the MWRA was proposing that the General Dynamics Quincy Shipyard be used as the location for one of its Piers and Staging facilities during the cleanup of Boston Harbor. Shortly afterwards, the MWRA purchased the Shipyard from General Dynamics, and used the site for the MWRA's long term residuals processing facility and staging area for Deer Island construction. As a result of the East Braintree Civic Association's concern about the oil and hazardous materials on the General Dynamics property and MWRA's proposals for use of the Shipyard, the Association submitted a petition to DEP [under M.G.L. c. 21E, Section 14 (b)] on May 5, 1988, requesting that: a public meeting be held (at a time and location convenient to them) involving Braintree residents in decisions regarding response actions at the General Dynamics site, and that DEP's "proposed Public Involvement Plan" ensure that interested members of the public will have sufficient notice for the public meeting, access to documents, and the opportunity to comment and affect the decisions regarding response actions at the General Dynamics disposal site.

-9- and abutting sites contaminated with chlorinated solvents, PCBs, mercury, cyanide and other metals". They also asked that "DEQE" [now, DEP] take immediate action to stop environmental harm, and control the potential for human exposure and health damage".

In developing the original Public Involvement Plan in 1989, DEP took several steps to identify community concerns that the Plan must address. Documents in DEP's files relating to the agency's past involvement with the site and the community were reviewed, and interviews were conducted by DEP with local officials, groups and individuals in Braintree, Quincy and Weymouth. Concerns identified at that time are listed in Exhibit I. As part of the public review process for the Waiver Application filed by MWRA and General Dynamics, additional concerns were identified and summarized by DEP in its "Response to Review Comments on Waiver Application," dated March 2, 1994. Copies of DEP's summary are on file at DEP and the PIP respositories. See, also, the "Waiver of Approvals" summary in Section II.A., above.

At a meeting of MWRA's Fore River Advisory Task Force on September 27, 1988, DEP and General Dynamics briefed the Task Force on the status of the cleanup work done on the site and discussed the Public Involvement requirements of M.G.L. 21E, Section 14 and the Massachusetts Contingency Plan (310 CMR 40.00). Since 1988, DEP has conducted periodic briefings on the status of work at the site, most recently at a publicly noticed meeting of the Task Force and Fore River Development Committee on January 19, 1994.

The Fore River Task Force provides general review of current issues on the site and ongoing monitoring operations. In addition, the Fore River Development Committee, which was formed in 1989 and includes three representatives from the communities of Braintree, Quincy and Weymouth, reviews and considers development and alternative long term uses for the site. The Task Force and Fore River Development Committee serve as vehicles for communication between MWRA and the communities, and are not voting bodies.

III. ADDRESSING PUBLIC CONCERNS

The process of assessing and cleaning up disposal sites (as set forth in the 1988 MCP and 1993 MCP), is designed to address the effects of the site on health, safety, public welfare, and the environment. Once a release of oil or hazardous materials has been confirmed at a disposal site (e.g., Phase I of the remedial response action process), the process may involve a preliminary or interim response action to quickly reduce risks or it may proceed to:

- a comprehensive field investigation of the nature and extent of the contamination, and an evaluation of any

-10- risks posed to the public and the environment from the site (Phase II),

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

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

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

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

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

Other concerns about the availability of information and opportunities for the public to comment on documents, and the accuracy of documents produced by consultants, are related to the process that DEP has established to ensure that the public is involved in planning for the remaining remedial response actions. To address these concerns, DEP outlines several public involvement activities in this Plan to provide information to Braintree, Quincy and Weymouth residents and officials, and to

-11- provide opportunities for the public to comment on documents describing specific remedial response actions. These activities are described in Section IV of this Plan.

IV. PUBLIC INVOLVEMENT ACTIVITIES

In accordance with the 1988 MCP and the 1993 MCP, activities undertaken to involve the public in response actions serve two purposes:

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

for Public Involvement Plan Sites, public involvement activities solicit the concerns of the public about the disposal site and remedial response actions, so that to the extent possible, these concerns can be addressed and incorporated in planning remedial response actions. To meet each of these objectives, MWRA and/or General Dynamics are undertaking specific activities for the Fore River Shipyard site. The activities in this Public Involvement Plan were selected to address the concerns about information and opportunities for involvement described in Exhibit I. These public involvement activities are described below.

Activities for Providing Information 1. Information Repositories

Publicly Accessible Site File: A file on the Fore River Shipyard (formerly General Dynamics) disposal site is maintained at the DEP Northeast Regional Office. The file contains all documents pertaining to the site, with the exception of enforcement sensitive material, if any. Appointments to view the file can be made by contacting the File Review Contact Person at DEP/Northeast Regional Office, Site Assessment and Cleanup Section, 10 Commerce Way, Woburn, MA 01801 (telephone: 617-935- 2160).

Local Information Repositories: To provide Braintree, Quincy and Weymouth residents with easy access to information relevant to the site cleanup process, local Information Repositories have been established as specific branches of the town libraries. These repositories contain information such as: official key correspondence relative to the site; technical reports and documents regarding proposed remedial response actions; the Public Involvement Plan; public meeting summaries; and summaries of responses to comments received.

-12- Information is sent to the Repositories as it becomes available. The libraries and their hours are as follows:

Library Address Hours

Thayer Public 798 Washington St. Monday-Thursday Library Braintree 9:00am-9:00pm Friday, Saturday 9:00am-5:00pm Thomas Crane 40 Washington St. Monday-Thursday Public Library Quincy 9:00am-9:00pm Friday, Saturday 9:00am-5:00pm Tufts Public 46 Broad Street Monday, Tuesday, Thursday Library Weymouth 9:00am-9:OOpm Wenesday, Friday, Saturday 9:00am-5:00pm

Site information is also available in MWRA's library located at their offices at the Charlestown Navy Yard, 100 First Avenue, Boston. The MWRA library hours are Monday-Friday, 9:00 a.m.-4:00 p.m. Please contact Mary Lydon, at (617) 242-6000, ext. 4175, if you wish to use the MWRA library.

In addition, Boards of Health are routinely provided with copies of DEP correspondence regarding the site. 2. Site Mailing List

The original mailing list for the Fore River Shipyard site has been updated from time to time by DEP and MWRA. The site mailing list includes: petitioners, interested residents, site abutters, local and regional news media, municipal officials (specifically the Chief Municipal Officer and the Chairperson of the Board of Health), state legislators, DEP site file, and other concerned citizens. The mailing list is used to announce upcoming public meetings, distribute fact sheets, notices of public comment periods on and the availability of documents in the information repositories, and other information about the Fore River Shipyard. MWRA will maintain the mailing list and update it as necessary. MWRA has provided DEP with a copy of the site mailing list. Anyone who wants to be added to the site mailing list may contact Jose Vincenty, (617) 242-6057, ext. 1192 at MWRA.

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

The Massachusetts Contingency Plan requires community notification of major planning and implementation milestones at disposal sites. Major milestones include: (1) the start of field work, related to response actions, involving heavy equipment or protective clothing (level A or B protection),

-13- (2) the completion of a phase of the remediation process, and (3) the start of any Short Term Measures.

Notification of subject field work includes information on the type of work, its approximate duration, and any expected off- site shipments of contaminated material. Notification will be made by General Dynamics or MWRA (depending upon who is performing the work) to the people on the Notification List by telephoning the day before the activity will begin. Notification at the end of a remedial phase includes a summary of the Phase report and information on where the report can be reviewed. Those to be notified include:

Affiliation Name Address Phone

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

Mayor James A. Sheets 1305 Hancock Street 376-1990 Quincy, MA 02169

Board of Selectmen Joseph Piper 75 Middle Street 335-2000 Weymouth, MA 02189

Board of Health Steve Ward 1 JFK Memorial Drive 848-1870 Braintree, MA 02184

Board of Health M. Jane Gallahue 1120 Hancock Street 376-1270 Quincy, MA 02169 ext. 1273

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

State Representative Joseph Sullivan State House, Room 443 722-2460 Boston, MA 02133

State Representative Ronald Mariano State House, Room 167 722-2692 Boston, MA 02133

State Senator Michael Morrissey State House, Room 507 722-1494 Boston, MA 02133

East Braintree civic Geri Hughes 185 Pleasantview Avenue 843-2574 Association Braintree, MA 02184

See updated Notification List, attached hereto.

In addition, local Police and Fire Departments will also be notified in situations where public safety is a concern. The Chief Municipal Officer and Board of Health in the communities of the Site or portions thereof, as applicable, shall be notified of the response actions and of field work related to response actions specified at 310 C.M.R. 40.1403(3) of the 1993 MCP.

-14- Oportunities for Public Involvement

1. Briefings of the Fore River Advisory Task Force Subcommittee When the PIP was originally developed in 1989, a subcommittee of the MWRA Fore River Advisory Task Force had been formed to deal specifically with the site issues raised during the remediation process. The Subcommittee was comprised of nine members, three each from Braintree, Quincy and Weymouth. The members were appointed by the Chief Municipal Officials in each of the three communities. Currently, the Fore River Staging Area Task Force is the primary vehicle for dealing with site issues raised throughout the rest of the remediation process. Regularly scheduled meetings of the Task Force are held in the Administration Building at the Shipyard and the general public is encouraged to attend.

At these meetings, General Dynamics and/or MWRA will: (1) give local officials, their representatives and the general public regular status reports on progress toward planning and implementing remedial response actions at the site; and (2) provide an opportunity to comment on the remedial response actions.

MWRA will notify the cited mailing list of these meetings and participate, along with General Dynamics, at each briefing. MWRA will also prepare summaries of the meetings, and place copies of these summaries in the local Information Repositories. 2. Public Comment Periods for Documents

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

Documents usually available for comment include scopes of work for comprehensive site investigations and their subsequent results (Phase II), evaluations of the feasibility of alternative remedial response actions and the final remedial response plan (Phase III), design plans for the selected remedial response actions (Phase IV), and plans for short term measures.

Exhibit II is a generalized schedule of public involvement activities during the remedial action process. Exhibit III

-15- indicates outstanding site-related issues currently being considered by the Department. Documents prepared for response actions concerning these issues will be available to the public as they are developed. MWRA and/or General Dynamics will respond to public comments received on each document available for comment during the remedial response action process.

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

In accordance with 310 C.M.R. 40.0630(2)(d) of the 1993 MCP and DEP's Waiver of Approval Letter, public involvement activities shall be conducted in accordance with 310 C.M.R. 40.1400 through 310 C.M.R. 40.1406 of the 1993 MCP where applicable. A copy of this portion of the MCP is attached hereto as Exhibit IV.

V. RESPONSIBILITIES FOR IMPLEMENTING PUBLIC INVOLVEMENT ACTIVITIES

In accordance with DEP's Waiver of Approval Letter and the 1993 MCP, DEP has assigned responsibility for conducting both remedial and public involvement activities at this site to General Dynamics and/or MWRA. These activities are generally those designed to provide the public with information regarding remedial response actions. They include providing copies of reports to local officials and information repositories, mailing notices of meetings and the availability of site reports, notifying local officials and residents of major field work on the site, providing an update on the status of the site to local officials and residents, and drafting fact sheets or report summaries. Prior to granting the Waiver of Approvals and the 1993 MCP, DEP usually conducted public involvement activities related to obtaining and respbnding to public comments on proposed remedial response actions at this site. Under the Waiver Approval, MWRA and/or General Dynamics will be performing these tasks.

-16- VI. FUTURE PLAN REVIEW AND AMENDMENTS

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

-17- Exhibit I

Community Concerns About the Fore River Shipyard Disposal Site

A. Concerns about the nature and extent of contamination:

- What contaminants are on-site, where, and at what levels? - Is groundwater contaminated and in what direction does it move?

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

- What contamination is coming from the Citgo and/or Clean Harbors property/ies (Southern boundary issue)? - There should be an assessment of what hazardous and nonhazardous materials exist along the Fore River rail system.

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

- Is there any ongoing exposure to any contaminants? - Will there be airborne contamination during construction or removal activities?

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

C. Concerns about the site remediation process:

- Nothing should be constructed on the property until all the hazardous waste there has been cleaned up. - What are "industrial cleanup levels" and how will they affect future development on this site?

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

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

. The final cleanup should get an approval letter from DEQE. 0 0

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

- The comments made by NUS about previous response actions at the Shipyard in their March 1988 site assessment report should be addressed.

- What assessment/remediation work has been done on the site to date, by whom, when?

- What assessment/remediation work is left to do, by whom, when?

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

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

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

- Where are hazardous materials being removed to?

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

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

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

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

Copies of documents should be placed in local libraries and/or town halls.

. There should be simplified summaries of reports.

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

- Public meetings should be held in the evenings. - Meeting notices should advertise the specific topics of the meeting, in clear language so that people do not have unrealistic expectations of what will be discussed.

- Use existing groups and organizations to inform their members of site activities.

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

- The MWRA's Braintree/Quincy/Weymouth Fore River Task Force would be an appropriate group for the focus of the public involvement process during site cleanup. E. Concerns about the Waiver of Approvals: The Waiver of Approvals summary in Section II.A. above regarding the public notice and comments period provided on the joint application for a Waiver of Approvals, the Waiver Approval, and DEP's Response to Public Review Comments are incorporated by reference. 0

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e C0 0 C a, L i ' m O -4 Li . 0 - -.u4 --0 4 0 3 -Ht -H 0 a O 'a1 4 04 - >,o ' i i eartE .Q M a) a E- C A.a 'U , C U c C 4.0 4 4 0 C -'00 C o -a 6- a,. -41 040 a...-- a -4 - 2 W a) -- > Lit aC) I E E Q- Exhibit III

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

Outstanding Site-Related Issues Response Action Status

Central Yard floating oil plume IV - Implementation of approved cleanup plan Subsurface soil contamination III - Development of associated with the floating oil Remedial Action Alter- plume natives and the Final Remedial Response Plan, if appropriate Oil contaminated soil on an off- Being handled by off-site site piece of property ("Area 5E") source (Flibotte's Auto Salvage) under a separate Waiver and as part of litigation settlement agreement with General Dynamics "Southeastern Boundary" Remediation of contaminated groundwater in Southeastern boundary is being handled by off- site sources -- Clean Harbors under RCRA Corrective Action Order with the U.S. EPA, and as part of litigation settlement agreement with General Dynamics. Consultant of Record will review southern boundary area for adequacy of assessments and response actions as part of the Waiver. I

Outstanding Site-Related Issues Response Action Status

Areas where long term monitoring of Consultant of Record must groundwater contaminated with review information chlorinated solvents or mineral submitted to DEP to ensure spirits was being conducted that contaminant sources have been terminated and contaminant levels are decreasing over time.

Document describing MWRA's Not in a Phase; document construction procedures for future relates to the site as a work in any areas of the site whole; may be revised by MWRA as a task under the Waiver.

Building 9 floating oil plume IV - Implementation of Remedial Action Plan

Land-use restriction Not in a Phase; document relates to the Site as a whole; a condition of Waiver Approval.

LIB 2 /0136024.02 MAS#0 HUSETTS WATER RESOUR#a AUTHORITY Charlestown Navy Yard 100 First Avenue Boston, Massachusetts 02129 Telephone (617) 242-6000 Facsimdie. (617) 241-6070

September 9, 1994

Waiver Submittal Commonwealth of Massachusetts Department of Environmental Protection Northeast Regional Office Bureau of Waste Site Cleanup 10 Commerce Way Woburn, MA 01801

RE: MWRA Fore River Staging Area (former General Dynamics Shipyard) -- Updated Public Involvement Plan Release Tracking #3-0536 and #3-10266

Dear Madam or Sir:

Enclosed please find the final updated Public Involvement Plan (PIP), dated September 1994, for the above-referenced Waiver site. The updated PIP was made available for public review and comment from June 29, 1994 through July 19, 1994. Comments were submitted by the Quincy Department of Public Health, to which MWRA and General Dynamics responded in a letter dated August 25, 1994. By copy of this letter, MWRA and General Dynamics are also providing copies of the finalized updated PIP to the information respositories specified in the PIP.

Very truly yours,

Jose Vi RA

Enclosures

cc: Thayer Public Library, Braintree Thomas Crane Library, Quincy Tufts Public Library, Weymouth Sharon A. Gobiel, DEP John J. Fitzgerald, P.E., DEP Douglas B. MacDonald, MWRA Nicholas D. Chabraja, Esq., General Dynamics Corporation Maggie Debbie, MWRA Leon Lataille, MWRA Robert White/Dan Kelley, General Dynamics -- - - .2

* Printed on 100% Recycled Paper - MAS#HUSETTS WATER RESOURCES APIORITY harletoun \,% Yrd 100) Firs \VueL Rmlon M >( huJsIIL129 fS~u~tV I I

August 25, 1994

Quincy Department of Health J.F.K. Health Center 1120 Hancock Street Quincy, MA 02189-4313

Attention: M. Jane Galiahue, M.P.H., C.H.O. Commissioner of Public Health

Cynthia P. DeCristofaro, R.S. Environmental Sanitarian

RE: MWRA Fore River Staging Area (former General Dynamics Shipyard) - RESPONSE TO REVIEW COMMENTS ON UPDATED PUBLIC INVOLVEMENT PLAN/WAIVER SITE Release Tracking # 3-0536 and # 3-10266

Dear Ms. Gallahue and Ms. DeCristofaro:

We are in receipt of the Quincy Department of Public Health's July 14, 1994 comments pertaining to MWRA's and General Dynamics' updated Public Involvement Plan (PIP), initially prepared by the Massachusetts Department of Environmental Protection (DEP) in May 1989, for the above-referenced site. This updated PIP was submitted in accordance with the joint Waiver of Approvals for the site, which was granted by DEP in March 1994, and the 1993 Massachusetts Contingency Plan (MCP). Under these requirements, public involvement activities formerly undertaken by the DEP under the PIP must be undertaken and implemented by the waiver applicants, MWRA and/or General Dynamics. The updated PIP incorporates these changes.

This updated PIP was made available for public review and comment from June 29, 1994 through July 19, 1994. The only comments received were those from the Quincy Department of Public Health.

Each of the Department of Health's comments, as contained in the July 14 letter, are summarized below and immediately followed by MWRA's and General Dynamics' response. Quincy Department of Health August 25, 1994 Page Two

L C: Overall, the revisions to the PIP appear adequate. The Quincy Department of Health emphasized the importance of insuring public involvement (review and comment) for the following two items that are listed in Exhibit III of the PIP: (1) any revision of the Construction Procedures and (2) the development of any land-use restriction document for this site.

R: The DEP-granted Waiver of Approvals (page 8) and the PIP (page 8 and Exhibit III) provide that MWRA may revise its Construction Procedures with DEP approval. The MWRA is in the process of making such revisions and will make them available to the public for comment before being finalized.

As required by DEP's Waiver of Approvals, MWRA will soon be recording a form of Land Use Restriction at this property. Advance copies of the Land Use Restriction required by the Waiver of Approvals will be made available in the Information Repositories and DEP files, and notices of availability will be sent to the PIP mailing list. Advance copies of any amendments to that Land Use Restriction (which may be required to accommodate future redevelopment of all or portions of the site) will be made available to the public in the same manner.

2. C: It is the Department of Health's understanding that all future asbestos removal projects require notice to DEP, and that the MWRA's enabling legislation would not exempt them from this requirement. [However, it is the responsibility of the asbestos abatement contractor to submit the appropriate notification to both DEP and the Department of Labor and Industries (DLI) ].

R: The DEP, DLI, and EPA regulations applicable to asbestos removal projects set forth specific thresholds that, if exceeded, trigger governmental notification requirements. Future asbestos removal projects at the site must comply with these requirements, and may require notification to certain governmental agencies depending upon whether an agency's notification threshold has been exceeded.

3. C: According to the Waiver approval letter from DEP, the current version of the MCP, 310 CMR 40.1400 governs the PIP for this location. Therefore, page 12 of the updated PIP, under Section IV, PUBLIC INVOLVEMENT ACTIVITIES, the language should directly and fully quote the current provisions of 40.1400. The provision requires that Quincy Department of Health August 25, 1994 Page Three

the Potentially Responsible Party (PRP) "shall consider, address and, where relevant and material to the response action, incorporate these concerns in planning response actions." (emphasis added).

R: We appreciate your highlighting the new MCP's public involvement requirements. We wish to assure the Department of Health that MWRA and General Dynamics are very much aware of these new requirements and that we have already incorporated by reference in the PIP, and attached to the PIP, the entire text of the new public involvement requirements, including specifically the phrase cited in the Department of Health's comment. See Section IV, "Activities for Providing Information," page 14 of the PIP and "Opportunities for Public Comment," page 16 of the PIP where specific mention of the new MCP public involvement requirements is made.

Thank you for your comments. We trust the above response adequately addresses your comments or concerns. We believe that finalizing the updated PIP, as published in June, 1994 is consistent with the intent and requirements of the MCP and DEP's Waiver of Approvals for this site.

If you have any questions regarding the contents of this letter, please do not hesitate to contact me at (617) 241-6057.

Very truly yours,

Jose Vincenty, M RA PIP Contact Person cc: Sharon A. Gobiel, DEP John J. Fitzgerald, P.E., DEP Douglas B. MacDonald, MWRA Nicholas D. Chabraja, Esq., General Dynamics Corporation Maggie Debbie, MWRA Leon Lataille, MWRA Mark Radville, MWRA Robert White/Dan Kelley, General Dynamics Addresses on attached PIP Mailing List 0 Amy 3arad, Mike Thayer Maggie Debbie Residuals Management Residuals Management Development

Gary Webster Lisa Grollman Elisa Speranza Public Affairs Real Property - Development Executive Office

Norman Jacques Walter Armstrong Mari Sullivan Board of Directors PMD Public Affairs

Paul DiNatale Doug MacDonald John Fitzgerald Public Affairs OED Sewerage

Rick Mills Michael Hornbrook Leon Lataille Residuals Sewerage Wastewater Engineering

Glenn Harkness Mark Radville Robert Keagy ENSR Wastewater Engineering Fore River 35 Wagog Park Acton MA 01720

Laurel Rafferty Dennis Frenchman Brona Simon Mass. CZM Lane, Frenchman & Associates Mass. Historical Society 100 Cambridge St. - Rm. 2006 38 Chauncey Street 80 Boylston Street Boston MA 02202 Boston MA 02111 Boston MA 02116

Matt Wilson Mass. Campaign to Clean Up Paul Schofield Sarah Weinstein Hazardous Waste Schofield & Company DEP - BWSC 37 Temple Place 131 State Street 1 Winter St. - 5th Floor Boston MA 02111 Boston MA 02109 Boston MA 02108 Peter Kolson - S Steve Lipman " James Goldstein Murphy, DeMarco & O'Neil DEP - Commissioner's Office Tellus Institute 20 Custom House Street 1 Winter St. - 3rd Floor 11 Arlington Street Boston MA 02110 Boston MA 02108 Boston MA 02116

Government Office of Joseph Sullivan Michael Morrissey Economic Development State Representative State Senator State House - Room 109 State House - Room 443 State House - Room 413C Boston MA 02133 Boston MA 02133 Boston MA 02133

Lee Bishop Laurie Burt Mary Kelly Warner & Stackpole Foley, Hoag & Elliot Regina Villa Associates 75 State Street 1 Post Office Square 145 Tremont St.-7th Floor Boston MA 02139 Boston MA 02109 Boston MA 02111

Paul White Brian McDonald William Galvin Senator Senator Representative State House - Room 309 State House - Room 416B State House - Room 540 Boston MA 02133 Boston MA 02133 Boston MA 02133

Paul Healey M. Joseph Manning Mary Jeannette Murray Representative Representative Representative State House - Room 540 State House - Room 167E State House - Room 134 Boston MA 02133 Boston MA 02133 Boston MA 02133

Michael Sullivan Ronald Mariano Michael Bellotti Representative Representative Representative State House - Room 443 State House - Room 473F State House - R oom 473F Boston MA 02133 Boston MA 02133 Buston MA 02133

Stephen Tobin Douglas E. Franklin Jackie McLeod Representative Braintree Ind. Div. Comm. 19 Ferncroft Road State House - Room 138 14 Willard Street Braintree MA 02184 Boston MA 02133 Braintree MA 02184

Davi d Oliva Rita & John Ricca Virginia Rubino 172 Edgehill Road 49 Sterling Street 73 Argyle Road Brai ntree MA 02184 Braintree MA 02184 Braintree MA 02184 Jules Seldon - Board of Selectmen Ann & Francis Toland Clean Harbors 1 JFK Memorial Drive 158 Edgehill Road 325 Wood Road Braintree MA 02184 Braintree MA 02184 Braintree MA 02184

Mark Hobis Geraldine Hughes Robert Jabaily Citgo Petroleum Corp. 185 Pleasantview Drive 93 Liberty Street 385 Quincy Avenue Braintree MA 02184 Braintree MA 02184 Bra'ntree MA 02184

Miriam Kelleher Michael Lang Cheryl Lee 90 Trefton Drive 74 Cotton Avenue Clean Harbors Braintree MA 02184 Braintree MA 02184 325 Wood Avenue Braintree MA 02184

Mary Littlejohn James Lucid Leland Dingee 92 Trefton Drive 18 Quincy Avenue 211 Glenrose Braintree MA 02184 Braintree MA 02184 Braintree MA 02184

Jane Donovan Anne & Kaer Durgin Lu Dwyer 93 Peach Street 50 Arborway Drive 211 Glenrose Avenue Braintree MA 02184 Braintree MA 02184 Braintree MA 02184

Christine Farhat Elaine Garrity Thomas Gecewicz Braintree Forum 110 Park Street Board of Health P. 0. Box K Braintree MA 02184 1 JFK Memorial Drive Braintree MA 02169 Braintree MA 02184

James Sullivan Sara Gillies Chairman Steve Ward 65 Angela Road Board of Selectmen Board of Health Braintree MA 02184 1 JFK Memorial Drive 1 JFK Memorial Dr ive Braintree MA 02184 Braintree MA 02184

Town Clerk Paul Ahlijanian Arthur & Marilyn Armstrong 1 JFK Memorial Drive Clean Harbors 40 Ardmore Street Braintree MA 02184 325 Wood Road Braintree MA 02184 Braintree MA 02184 Gerry Studds Fred E. 2ussarian Beji Malek Congressman V 170-Zabrosky Avenue OXY USA Inc. 1334 Longworth House Stoughton MA 02072 Tulsa OK 74102 Office Building Washington DC 20515

John Morse Paul Shinney Richard Marino Water & Sewer Division N. Weymouth Civic Assn. Board of Health 120 Winter Street 286 River Street 75 Middle Street Weymouth MA 02188 Weymouth MA 02191 Weymouth MA 02189

Town Clerk James F. Clarke, Jr. Edward Foley 75 Middle Street Town Hall 54 Harding Avenue Weymouth MA 02189 75 Middle Street Weymouth MA 02188 Weymouth MA 02189

Russell Connor John Buckley Town Administrator Joseph R. Piper Superintendent Town Hall Town Hall Water and Sewer Department 75 Middle Street 75 Middle Street 120 Winter Street Weymouth MA 02189 Weymouth MA 02188 Weymouth MA 02188

Karen Stromberg Sharon Gobiel DEP DEP Northeast Regional Office Northeast Regional Office 10 Commerce Way 10 Commerce Way Woburn MA 01801 Woburn MA 01801 Commonwealth of Massachusetts Executive Office of Environmental Affairs Department of Environmental Protection William F. Weld Gowmor Trudy Coxe Scretary, EOEA Thomas B. Powers Actng Commion e

August 22, 1994

Northeast Shipbuilders, Inc. c/o Donald Quinn, Esq. Goodwin, Procter & Hoar Exchange Place Boston, MA 02109

Mr. Douglas B. MacDonald Massachusetts Water Resources Authority Charlestown Navy Yard 100 First Avenue Boston, MA 02129

RE: Release Tracking #3-0536/Quincy Shipbuilding Facility

Dear Mssrs. Quinn and MacDonald:

I am pleased to learn that the Massachusetts Water Resources Authority ("MWRA") is negotiating a lease with an option to purchase for approximately 107 acres of the former Quincy Shipbuilding facility on East Howard Street, Quincy ("the site"), which is currently a "non-priority, waiver-approved site" undergoing remediation for environmental contamination. I understand the new tenant, Northeast Shipbuilders, Inc., plans to reinstitute an extensive shipbuilding business on this site while remediation of existing contamination progresses. This arrangement would be an excellent opportunity to return contaminated property to productive use and is very much in the public interest.

I also understand that in the course of negotiations, concerns have been raised about potential liability pursuant to MGL. c. 21E, the state statute which establishes responsibility for responding

One Winter Street 0 Boston, Massachusetts 02108 O FAX (617) 556-1049 e Telephone (617) 292-5500 Mssrs. Quinn & MacDonald August 22, 1994 page -2- 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 Northeast Shipbuilders, Inc., its successors or its assigns, excluding currently responsible parties ("Northeast Shipbuilders"), responsible for costs associated with remediation of existing contamination as of the date of execution of the lease. The foregoing is offered on the condition that:

1. Northeast Shipbuilders agrees to abide by a condition to be in the proposed lease that it comply with the provisions of the construction procedures document ("Procedures Associated With Construction-Related Activities At the Fore River Staging Area" by Haley & Aldrich, Inc. [June 19, 1989, as amended]) to manage any contaminated soil excavated as part of construction in support of its shipbuilding operations. Should Northeast Shipbuilders purchase the property, the foregoing Department agreement would still apply to Northeast Shipbuilders and to subsequent owners of the property, as well, on the condition that the requirements of the "Construction Procedures Document" are incorporated into a land use stipulation (such as a deed restriction or deed notice) that establishes the same obligations and conditions with respect to management of contaminated soil.

2. Northeast Shipbuilders 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 lease is executed.

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 (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 Northeast Shipbuilders 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."

We will be happy to meet with representatives of MWRA and Northeast Shipbuilders to work out details of this agreement. Please contact James Colman, Assistant Commissioner, DEP Bureau of Waste Site Cleanup to arrange a meeting. Mr. Colman can be reached by telephone at 292-5648. 0 6 Mssrs. Quinn & MacDonald August 22, 1994 page -3-

S erely,

Thomas B. Powers Acting Commissioner

TBP/JCC/pg boc: Secretary Gloria Larson, Economic Affairs Michael Hogan, Mass Office of Business Development Kevin Smith, Chief of Staff, Governor's Office Secretary Trudy Coxe - I I

Commonwealth of Mossachusetts Executive Off Ice of Environmental Affairs Department of Environmental Protection William F. Weld Trudy Cox* S-aa, EOEA Thomas B. Powers Acting Com ner fEMORANDUM

To: Ed Kunce, Jim Colman, Bill Gaughan, Dick Chalpin, Sharon Gobiel, Laurel MacKay From: Steve Lipman // Date: August 8, 1994 Subject: MWRA, 21E Issues/Redevelopment of Fore River Staging Area (FRSA)

On July 28, 1994, Sarah Weinstein, Bob Brown and I met with staff from MWRA to discuss 21E issues/MCP Compliance relative to development of the FRSA. This memorandum is a very brief summary of the discussions. - It appears that the shipbuilding plan is in trouble, but there is still a chance it will occur. Supposedly, a Greek firm, Regency Holdings Inc., is continuing to discuss taking over 120 acres of the 192 acre site,-but site contamination issues are still outstanding.

- MWRA has plans for other developmentactivities on the FRSA so the discussions on this issue are still important to MWRA, whether or not the shipbuilding proposal goes forward.

- MWRA's Board would eventually like to sell the majority of the site, but will lease if it is the only way to get potential buyers interested.

- There is quite a bit of pressure from the locals for MWRA to develop the majority of the site to allow for an expanded job base and tax revenues.

- MWRA/GD expect to issue a series, of Waiver Completion Statements to DEP for specific portions of the site as areas are completely remediated.

On. Winter Street a Boston, Massachusetts 02106 a FAX (617) 556-1049 e Telephone (617) 292-S 2.

MWRA is really hoping that there is some way they will be able to get rid of the site and any future liability. Since any new site owners will almost certainly want MWRA to indemnify them for past contamination, MWRA sees themselves tied to this site for many years. We responded that DEP has no magic wand we can waive and eliminate their ongoing liability. There is no "3rd Party" to accept responsibility. It appears that the MWRA was hoping that the Administration would be under such pressure to reinitiate shipbuilding at the Site that the Commonwealth would somehow either take over all or some of the Authority's ongoing responsibility or find a way to limit future MWRA liability.

. We discussed the Covenant Not to Sue and everyone agreed it does not provide any resolution to the current situation, particularly relative to the Pilot Program. If the Pilot Program works well and this Covenant procedure is eventually determined to be utilized on a full-time basis, it might have limited useability for situations where a new owner wants to upgrade the use of a portion of the site being developed with additional remediation.

I did take the opportunity of having these MWRA players in one room to ask if anything has been resolved regarding the indemnity requirements from the MBTA to allow MWRA to obtain an easement and construct a portions of its New Neponset Valley Relief Sewer across MBTA property. The response was the the situation is still not resolved and is a real mess and that the MBTA is looking at some type of insurance that MWRA can buy. I stated that I thought the MBTA position represented terrible public policy and I was hoping Tom Powers could convince the Administration of this, particularly since Secretary Kerasiotes (oversees both MBTA and MHD) is getting hit on the CA/T Project by the U.S. Postal Service (against MHD) on this same issue and MHD is trying to fight the Postal Service position.

MWRA staff thanked us for meeting with them to discuss the issue and we agreed to keep in contact.

cc: Sarah Weinstein, Pat Donahue, John Fitzgerald, Liz Callahan

SGL/yg/50: MWRA-21E.mem MIA 1m ACHUSETTS( hah(w WATER RESOURCES 0rAUTHORITY

1l0 HNhi nAueILi

PUBLIC NOTICE

SOIL SAMPLING PROGRAM WORK PLAN

MWRA FORE RIVER STAGING AREA (FORMER GENERAL DYNAMICS SHIPYARD) QUINCY, MASSACHUSETTS

DEP Case No. 3-0536

The Massachusetts Water Resources Authority has prepared a work plan entitled "MWRA Sludge Processing and Disposal Plant Expansion Project, Proposed FRSA Construction Phase, Soil Sampling Program, July 1994". This document describes a soil sampling program to support the MWRA's Interim Sludge Processing and Disposal Plant (ISP&D) Expansion Project, to be conducted at the Fore River Staging Area, 97 East Howard Street, Quincy, Massachusetts. Soil sampling and analysis will be conducted in advance of the ISP&D construction project.

Public comment is invited regarding the proposed work plan, which is available for viewing at the following public libraries:

Thomas Crane Public Library 40 Washington Street Quincy, Massachusetts Hours: Monday-Thursday 9:00am-9:00pm Friday, Saturday 9:00am-5:00pm

Thayer Public Library 798 Washington Street Braintree, Massachusetts Hours: Monday-Thursday 9:00am-9:00pm Friday, Saturday 9:00am-5:00pm

Tufts Public Library 46 Broad Street Weymouth, Massachusetts Hours: Monday, Tuesday, Thursday 9:00am-9:00pm Wednesday, Friday, Saturday 9:00am-5:00pm ell9

Please forward all comments regarding the work plan to the attention of:

Mr. Jose Vincenty Public Contact Person Massachusetts Water Resources Authority Charlestown Navy Yard 100 First Avenue Boston, Massachusetts 02129

The 20-day public comment period for this work plan will expire at close of business on September 13, 1994.

DISTRIBUTION: FRSA PIP Mailing List

Printed on 100% Recycled Paper S Amy Barad Mike Thayer Maggie Debbie Residuals Management Residuals Management Development

Gary Webster Lisa Grollman Elisa Speranza Public Affairs Real Property - Development Executive Office

Norman Jacques Walter Armstrong Mari Sullivan Board of Directors PMD Public Affairs

Paul DiNatale Doug MacDonald John Fitzgerald Public Affairs OED Sewerage

Rick Mills Michael Hornbrook Leon Lataille Residuals Sewerage Wastewater Engineering

Glenn Harkness Mark Radville Robert Keagy ENSR Wastewater Engineering Fore River 35 Wagog Park Acton MA 01720

Matt Wilson Mass. Campaign to Clean Up Paul Schofield Sarah Weinstein Hazardous Waste Schofield & Company DEP - BWSC 37 Temple Place 131 State Street 1 Winter St. - 5th Floor Boston MA 02111 Boston MA 02109 Boston MA 02108 Peter Kolson Steve Lipman James Goldstein Murphy, DeMarco & O'Neil DEP - Commissioner's Office Tellus Institute 20 Custom House Street 1 Winter St. - 3rd Floor 11 Arlington Street Boston MA 02110 Boston MA 02108 Boston MA 02116

Lee Bishop Laurie Burt Mary Kelly Warner & Stackpole Foley, Hoag & Elliot Regina Villa Associates 75 State Street 1 Post Office Square 145 Tremont St.-7th Floor Boston MA 02109 Boston MA 02109 Boston MA 02111

Paul White Brian McDonald William Galvin Senator Senator Representative State House - Room 309 State House - Room 416B State House - Room 540 Boston MA 02133 Boston MA 02133 Boston MA 02133

David Oliva Rita & John Ricca Virginia Rubino 172 Edgehill Road 49 Sterling Street 73 Argyle Road Braintree MA 02184 Braintree MA 02184 Braintree MA 021B4 *Mary Ann -Lencki Cobservation Commission Darrin McAuliffe John McGlynn City Hall 62 Grogan Avenue 10 Fowler Street 1305 Hancock Street Quincy MA 02169 Quincy MA 02169 Quincy MA 02169

Jeff Kelly David Colton Cindy DeCristofaro Ellie Chan DPW JFK Health Center Patriot Ledger 55 Sea Street 1120 Hancock Street 400 Crown Colony Drive Quincy MA 02169 Quincy MA 02169 Quincy MA 02169

Sal Gallinaro Toufic Hajjar Mayor James Sheets 24 Bowes Avenue 267 South Street City Hall Quincy MA 02169 Quincy MA 02169 1305 Hancock Street Quincy MA 02169

M. Jane Gallahue President City Clerk Board of Health Mass. Shipbuilders 1120 Hancock Street 1120 Hancock Street 97 E. Howard Street Quincy MA 02169 Quincy MA 02169 Quincy MA 02169

David Aristide Paul Donnelly Stephen Lush American Waste Systems 24 Bayview Street 17 E. Howard Street 350 Hancock Street Quincy MA 02169 Quincy MA 02169 Quincy MA 02171

Theodore P. DeCristofaro Michael Cheney Gerry Studds Councillor Councillor Congressman City Council City Council 1212 Hancock Street 1305 Hancock Street 1305 Hancock Street Quincy MA 02169 Quincy MA 02169 Quincy MA 02169

Peter Kolson Kathleen Yager Councillor Personnel Director James Bove City Council City Hall Proctor & Gamble Mfg. Co. 1305 Hancock Street 1305 Hancock Street 780 Washington Street Quincy MA 02169 Quincy MA 02169 Quincy MA 02169

Michael Wheelwright Robert Mood Principal Planner President Gilbert Starkey, Jr. Public Works Department Ward II Civic Association 74 Circuit Road 55 Sea Street 42 Presidents Avenue S. Weymouth MA 02190 Quincy MA 02169 Quincy MA 02169 Gerry Studds Fred E. Sussanan 0 Beji Malek Congressman 170 Zabrosky Avenue OXY USA Inc. 1334 Longworth House Stoughton MA 02072 Tulsa OK 74102 Office Building Washington DC 20515

Town Clerk James F. Clarke, Jr. Edward Foley 75 Middle Street Town Hall 54 Harding Avenue Weymouth MA 02189 75 Middle Street Weymouth MA 02188 Weymouth MA 02189

Karen Stromberg Sharon Gobiel DEP DEP Northeast Regional Office Northeast Regional Office 10 Commerce Way 10 Commerce Way Woburn MA 01801 Woburn MA 01801 Commonwealth of Massachusetts Executive Office of Environmental Affairs Department of Environmental Protection William F. Weld Governor Trudy Coxe Secretary, EOEA Thomas B. Powers Acting Conrnssionr MEMORANDUM

To: Ed Kunce, Jim Colman, Bill Gaughan, Dick Chaplin, Sharon Gobiel, Laurel McKay

From: Steve Lipman - -

Date: July 5, 1994 Subject: MWRA, 21E Issues/Redevelopment of Fore River Staging Area

Approximately two weeks ago I received a call from Leon Lataille, who is MWRA's in-house 21E expert, regarding DEP's attendance at a meeting at EOCD with MWRA and EOCD, to discuss options for obtaining some type of "commitment" from DEP not to take any 21E action against a shipbuilding firm which is negotiating with MWRA for purchase and/or lease of space at MWRA's Fore River Staging Area (FRSA) previously known as the General Dynamics Shipyard. As you probably remember, MWRA purchased the entire shipyard from GD a number of years ago to be utilized as a staging area and RO/RO ba qing facility to construct the Deer Island Plant, and was even ually chosen as the Interim and then Permanent Site for MWRA's wistewater residuals pelletizing plant. MWRA has been actively participating with area communities to devise a long-term Development Plan for those portions of the FRSA not required by MWRA for its wastewater facilities, a focal point being reinitiating shipbuilding and/or repair activities on the site. For the past couple of years a limited amount of shiprepair work has taken place on a portion of the site leased to a local firm and recently MWRA has been actively negotiating for lease/sale of a substantial portion of the site for reinitiation of major shipbuilding/repair activities, and it appears that one of the pivotal issues to "making-the-project-happen" is 21E liability. The shipbuilding/repair company does not want to end up being drawn into 21E liability for existing site contamination (DEP/BWSC recently gave MWRA/GD a Waiver for 21E cleanup at the site) and apparently is looking for somebody to provide a formal document limiting their liability.

One Winter Street e Boston, Massachusetts 02108 O FAX (617) 556-1049 e Telephone (617) 292-5500 2.

Leon had heard about the "Covenant Not to Sue" proposal and wanted to find out the status of the proposal and whether it might be an appropriate vehicle for resolution of the FRSA issue. I subsequently discussed this issue with John Fitzgerald, Liz Callahan and Sarah Weinstein (BWSC) and on July 1st was provided with a copy of the recently released Proposal for a Pilot Program to Provide Covenants Not to Sue Pursuant to MGL c.21E, 43A(). Sarah Weinstein stated that a copy had also been forwarded to Leon Lataille for review.

We can certainly expect to hear back from MWRA in the near future with a request to meet with MWRA and/or other players to the shipbuilding plan to discuss the Covenant and the proposed one-year pilot program. It is my understanding that this document is currently, or soon to be, under a 2-week comment period by the Waste Site Cleanup Program Advisory Committee and that if things proceed forward as expected the pilot program could begin in September 1994 and would run for a one-year period. Reinitiating shipbuilding/repair at FRSA is a maior political issue in the Quincy, Braintree and Weymouth area and has the potential for very extensive economic benefits to the area, and therefore we can anticipate very intense pressure to allow this project to be one of the pilot program test cases, or for DEP to come up with an alternative plan. In this regard I recommend that in the near future we meet to discuss this situation so we will be ready to respond to the Administration's request (and there will be one) to make the shipbuilding/repair proposal happen. Please let me know if you agree that an initial sit-down is a good use of our time or whether you would rather just wait until a request is received.

cc: Sarah Weinstein, Pat Donahue, John Fitzgerald, Liz Callahan

SGL/yg/49: GD-ship.mem AA i .

4- 0 "1/i2*

STAFF SUMMARY TO: Board of Directors FROM: Douglas B. MacDonald, Executive Director DATE: June 29, 1994 SUBJECT: Further Review of Draft Development Plan for the FRSA

COMMITTEE:Administration & Finance X INFORMATION VOTE Maggie Debbie. Director. Real Property 7/U /d Preparer/Title Division Director~A roval '

RECOMMENDATION:

For information only. It would be helpful for the staff to obtain the sense of the Board that the draft report, expected to be presented to the Board in substantially its current form after incorporation of final comments from community reviewers, will then be adopted by the Board at a forthcoming meeting.

DISCUSSION:

The staff summary dated June 9, 1994 and the draft report are attached.

Members of the Board asked at their June 15th meeting for the Executive Director's assessment of the draft report and the significance of the Board's proposed adoption of the Plan as soon to be completed in final form.

The draft Plan, in our view, is a thoughtful document to which much worthy effort has been dedicated by the consultants and staff, as well as by the many contributors who have participated in the community-based planning process to prepare and review the Plan. Its purpose is to serve as a guide to steps for MWRA and others in order to move ahead to develop suitable re-use options for the FRSA. Obviously, the future of the FRSA may well be affected by events not foreseen in the Plan, so the Plan cannot be a rigid or prescriptive roadmap. Indeed, the current negotiations with the Regency interests (for a shipyard use which is explicitly compatible with the overall direction of the Plan) illustrates the need to be open and flexible to unexpected opportunity.

I STAFF SUMMARY

TO: Board of Directors FROM: Douglas B. MacDonald, Executive Director DATE: June 9, 1994 SUBJECT: Review of Draft Development Plan for the FRSA ------COMMITTEE: Administration & Finance _X_ INFORMATION VOTE Maggie Debbie. Director, Real Property ,-vfl/ Preparer/Title t tvZQ Division Director App'roval A------

RECOMMENDATION:

For information only.

DISCUSSION:

The DRAFT Development Plan for the FRSA is attached. This is the final piece in the year long process which we have funded and accomplished with the support of the communities. The draft plan has been distributed to the Development Committee as well as community leaders and elected officials. Comments and suggestions are due back to the consultants by June 17. The goal is to have the plan finalized within the next month or so. After the consultants have incorporated the changes and additions requested by the various entities, they will return to the Board for final acceptance of the plan. Dennis Frenchman and Peter Roth will be at the Board meeting on June 15 at 2 pm to discuss the draft plan with the Board.

The overall site concept is one of mixed use, combining the traditional marine industry with future oriented technology and tourism activities of a marine nature. Development will be implemented by using public incentives to attract anchor uses to the site in the near term, which will catalyze further private investment and development as the project matures. There are several sections of the plan that the Board may find of particular interest and have suggestions or questions about. One of these is the infrastructure improvement plan. The plan proposes that a coordinated set of infrastructure improvements be done in order to prepare the site for development overall and to service the particular requirements of each zone of use. There are baseline improvements suggested to arrest deterioration and improve the site infrastructure and appearance of the FRSA, and therefore its marketability. These improvements include exterior upgrade of buildings and site areas along the most visible edges of the yard, demolition of extraneous structures with little potential reuse value, development of new site access and road-associated utility upgrade between East The draft Plan is substantially final subject only to incorporation of a few last comments from the public review process.

The Board's adoption of the Plan as soon as it can be presented in final form will trigger the orderly pursuit of a number of practical steps outlined in the Plan. Some of the specific steps the Board can expect following adoption of the Plan include:

1. Proceed to detailed discussion with the Land Bank regarding it serving as MWRA's agent for dealing with development opportunities for the site, including negotiations for its possible sale.

2. Develop targeted strategies for pursuing the kinds of "catalyst uses" recommended in the Plan, such as the possible Marine Technology Center and the National Park Service harbor gateway proposal.

3. Prepare for inclusion in forthcoming versions of the CIP some of the specific "baseline" infrastructure improvements that will be necessary to support reuse opportunities at the FRSA, provided that the spending will be carefully gauged so as not to unnecessarily expend ratepayer funds except in anticipation of realistic payoffs in the development process with the description of appropriate triggers for that investment in order to protect ratepayer interests.

4. Collaborate in the future with the Executive Office of Economic Affairs and its State Office of Business Development to develop additional sale or lease opportunities should current negotiations with the Regency group not be successful.

The Plan will also be helpful to MWRA in approaching its own and others' site use and development proposals in the setting of a coherent overall plan for physical layout of various activities at the FRSA.

Of course, if the Regency negotiations are successful, a large step forward will be taken toward the ultimate reuse goal in a manner wholly consistent with the basic direction of the Plan.

BUDGET/FISCAL IMPACT:

There are no direct fiscal impacts at this time. Expenditures for maintenance and improvements in connection with reuse opportunities for the FRSA will be separately considered through the CIP process. MBE/WBE:

Not applicable.

2 STAFF SUMMARY

TO: Board of Directors FROM: Douglas B. MacDonald, Executive Director DATE: June 9, 1994 SUBJECT: Review of Draft Development Plan for the FRSA

COMMITTEE: Administration & Finance _X_ INFORMATION VOTE Maggie Debbie, Director, Real Property Preparer/Title t n Division Director Aplroval ------

RECOMMENDATION:

For information only.

DISCUSSION:

The DRAFT Development Plan for the FRSA is attached. This is the final piece in the year long process which we have funded and accomplished with the support of the communities. The draft plan has been distributed to the Development Committee as well as community leaders and elected officials. Comments and suggestions are due back to the consultants by June 17. The goal is to have the plan finalized within the next month or so. After the consultants have incorporated the changes and additions requested by the various entities. they will return to the Board for final acceptance of the plan. Dennis Frenchman and Peter Roth will be at the Board meeting on June 15 at 2 pm to discuss the draft plan with the Board.

The overall site concept is one of mixed use, combining the traditional marine industry with future oriented technology and tourism activities of a marine nature. Development will be implemented by using public incentives to attract anchor uses to the site in the near term, which will catalyze further private investment and development as the project matures. There are several sections of the plan that the Board may find of particular interest and have suggestions or questions about. One of these is the infrastructure improvement plan. The plan proposes that a coordinated set of infrastructure improvements be done in order to prepare the site for development overall and to service the particular requirements of each zone of use. There are baseline improvements suggested to arrest deterioration and improve the site infrastructure and appearance of the FRSA, and therefore its marketability. These improvements include exterior upgrade of buildings and site areas along the most visible edges of the yard, demolition of extraneous structures with little potential reuse value, development of new site access and road-associated utility upgrade between East Howard and South Street gates, and creation of new site-wide utility corridor. Other site improvements associated with individual zones of use are also suggested.

The plan recommends that the cost of such improvements be shared by entities responsible for various aspects of the redevelopment, including the Authority, tenants, and private developers, while some improvements may be eligible for funding from alternative state and federal sources. The costs are estimated to be $1.8 million for the baseline improvements, $1.5 million for other infrastructure elements, and $1.6 million if a cross-site connector is developed.

Another area which has been of particular interest to the Board is the proposed disposition plan, outlined on pages 17-20. The consultants recommend that development be carried out as a partnership among the MWRA, the Massachusetts Government Land Bank, and Quincy 2000, with the continued involvement of the Development Committee. The consultants suggest that the MWRA cofitinue to own the property with the Land Bank acting as development agent for the Authority. The site would ultimately be sold, once it has been fully developed and value has been added.

The last section of the report discusses the benefits of the proposed plan to the communities, the Commonwealth and the MWRA. Based on the key assumptions, the plan can generate $29.9 million in total returns to the Authority's ratepayers over an eight year period. Total proceeds to the Authority as projected would have a Net Present Value of approximately $16.8 million, assuming a discount rate of 7% (approximately the cost of long term Authority bonds).

BUDGET/FISCAL IMPACT:

NA 0

MASSACHUSETTS WATER RESOURCES AUTHORITY Charlestown Navy Yard 100 First Avenue 1' Boston, Massachusetts 021 29

Telephone. 16171 242-h000 Facsimile: 61 7 241-60 (

June 23, 1994 /

PUBLIC NOTICE RE! UPDATED 'PUBLIC INOLVEMENT PLAN MWRA Fare River staging Area (foinr General iynamics Shipyard) Releasc Trackin*,_#3-0536 and #3-10206

Dear Interested Party: I am writing to inform you that public tomments on the revised Public Involvement Plan (PIP) document must now be received by July 19, 1994. As stated in the last notice, the PIP document may be reviewed at the following locations:

Thayer Public Library, 798 Washington Street, Quincy Tufts Library, 46 Broad Street, Weymouth Watson Park Library, 398 Quincy Avenue, Braintree

Department of Environmental Protection Office, 10 Commerce Way, Woburn. (Please call (617) 935-2160 to make an appointment.) Please forward comments to my attention at the MWRA, Charlestown Navy Yard, 100 First Avenue, Boston, MA 02129. Sincerely,

Jose Vin Community Coordinator

JV7/cl It

@ MASSXCRIIET TS WATER RESOURCES AUTHORITY Charlestown Navy Yard 100 First Avenue Boston, Massachusetts,021 29 Telephone: (617) 242-6000 Facsimile: (617) 241-6070 June 16, 1994

PUBLIC NOTICE RE: UPDATED PUBLIC INVOLVEMENT PLAN MWRA Fore River Staging Area (former General Dynamics Shipyard) Release Tracking #3-0536 and #3-10266

Dear Interested Party: Please be advised that the Massachusetts Water Resources Authority (MWRA) and General Dynamics Corporation have updated the original Public Involvement Plan, prepared by the Massachusetts Department of Environmental Protection (DEP) in May 1989, for the above-referenced site. The DEP Plan has been revised in accordance with the joint Waiver of Approvals for the subject site, which was granted by DEP in March 1994, and the 1993 Massachusetts Contingency Plan. Under these requirements, public involvement activities formerly undertaken by DEP under the Plan, must be undertaken and implemented during the remainder of the response action process by MWRA and/or General Dynamics. The updated Plan incorporates these required changes. The revised PIP document is available for public review and comment. Copies of this document and a red-lined version of the original 1989 Plan (highlighting the revisions) may be reviewed at the following locations:

Thayer Public Library, 798 Washington Street, Quincy

Tufts Library, 46 Broad Street, Weymouth

Watson Park Library, 398 Quincy Avenue, Braintree

DEP Northeast Regional Office, 10 Commerce Way, Woburn, MA 01801 (Please call DEP File Review Contact Person at (617) 935-2160 to make an appointment to review the document.)

Please forward all comments to the attention of Jose Vincenty, Fore River Staging Area Task Force, at the following address:

MWRA Charlestown Navy Yard 100 First Avenue Boston, MA 02129

Comments must be received by July 6, 1994 (20 days after notice).

Sincerely,

Jose ViZt Community ations Coordinator f... o- 1m % Recycled Paer MASSACHUSETTS WATER RESOURCESAUTHORITY Charlestown Navy Yard 100 First Avenue Boston, Massachusetts 02129 Telephone: (617) 242-6000 Facsimile: (617) 241-6070

June 23, 1994

PUBLIC NOTICE RE: UPDATED PUBLIC INVOLVEMENT PLAN MWRA Fore River Staging Area (former General Dynamics Shipyard) Release Tracking #3-0536 and #3-10266

Dear Interested Party:

I am writing to inform you that public comments on the revised Public Involvement Plan (PIP) document must now be received by July 19, 1994. As stated in the last notice, the PIP document may be reviewed at the following locations:

Thayer Public Library, 798 Washington Street, Quincy

Tufts Library, 46 Broad Street, Weymouth

Watson Park Library, 398 Quincy Avenue, Braintree

Department of Environmental Protection Office, 10 Commerce Way, Woburn. (Please call (617) 935-2160 to make an appointment.)

Please forward comments to my attention at the MWRA, Charlestown Navy Yard, 100 First Avenue, Boston, MA 02129.

Sincerely,

Jose Vin Community Rela Coordinator

JV7/cl

0 ® Prinit-d on 1t0) . Recycled Pane, MASSACHUSETTS WATER RESOURCES AUTHORITY Charlesiown Navy Yard 100 First Avenue Boston, Massachusetts 02129 Telephone: (617) 242-6000 Facsimile: (617) 241-6070 June 16, 1994

PUBLIC NOTICE RE: UPDATED PUBLIC INVOLVEMENT PLAN MWRA Fore River Staging Area (former General Dynamics Shipyard) Release Tracking #3-0536 and #3-10266 Dear Interested Party:

Please be advised that the Massachusetts Water Resources Authority (MWRA) and General Dynamics Corporation have updated the original Public Involvement Plan, prepared by the Massachusetts Department of Environmental Protection (DEP) in May 1989, for the above-referenced site. The DEP Plan has been revised in accordance with the joint Waiver of Approvals for the subject site, which was granted by DEP in March 1994, and the 1993 Massachusetts Contingency Plan. Under these requirements, public involvement activities formerly undertaken by DEP under the Plan, must be undertaken and implemented during the remainder of the response action process by MWRA and/or General Dynamics. The updated Plan incorporates these required changes. The revised PIP document is available for public review and comment. Copies of this document and a red-lined version of the original 1989 Plan (highlighting the revisions) may be reviewed at the following locations:

Thayer Public Library, 798 Washington Street, Quincy Tufts Library, 46 Broad Street, Weymouth

Watson Park Library, 398 Quincy Avenue, Braintree

DEP Northeast Regional Office, 10 Commerce Way, Woburn, MA 01801 (Please call DEP File Review Contact Person at (617) 935-2160 to make an appointment to review the document.)

Please forward all comments to the attention of Jose Vincenty, Fore River Staging Area Task Force, at the following address: MWRA Charlestown Navy Yard 100 First Avenue Boston, MA 02129

Comments must be received by July 6, 1994 (20 days after notice). Sincerely,

Jose V Communit ations Coordinator PUBLIC INVOLVEMENT PLAN

FORE RIVER SHIPYARD (FORMERLY GENERAL DYNAMICS) DISPOSAL SITE 97 East Howard Street, Quincy, Massachusetts

Prepared by:

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

Updated by:

Massachusetts Water Resources Authority (MWRA) and General Dynamics Corporation June, 1994

Contact for more information:

Jose Vincenty, MWRA (617) 241-6057 PUBLIC INVOLVEMENT PLAN

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

I. INTRODUCTION

DEP presented the draft Plan for review at a public meeting held on January 26, 1989. An update on the remedial response action planning process for this site was also provided. Anyone who wished to comment on the draft Public Involvement Plan was encouraged to do so. Comments were submitted between January 26 and February 16, 1989. DEP finalized the Public Involvement Plan in May, 1989. Since then DEP has conducted periodic public information meetings and status reports have been regularly submitted to the DEP and the designated Information Repositories.

This updated Public Involvement Plan is organized as follows. Section II contains background information on the site, the history of remedial response actions and public involvement. Section III explains how the remedial response action process can address community concerns which have been raised during the development of the Public Involvement Plan. Section IV describes the public involvement activities chosen for this site. Section V outlines the roles and responsibilities of those involved in implementing the Public Involvement Plan. Section VI explains how the Plan can be revised in the future.

II. BACKGROUND INFORMATION

A. Site History

In February 1986, in anticipation of the sale of the property, General Dynamics hired Goldberg-Zoino & Associates (GZA) to begin a comprehensive environmental assessment. General

-2- Dynamics submitte the results of this invesoation and proposed remedial actions to DEP in May 1986. This site assessment revealed certain areas of soil and-groundwater contaminated with fuel oil, gasoline, chlorinated solvents, acid extractable/base neutral compounds, metals and PCBs. On October 21, 1986, DEP formally notified General Dynamics of its responsibilities and liabilities under M.G.L. c. 21E by issuing a Notice of Responsibility (NOR) letter.

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

In November 1987, the Massachusetts Water Resources Authority (MWRA) purchased the Shipyard. MWRA uses portions of the property for various components of the Boston Harbor Project (BHP), including as a laydown and staging area for contractors and location of the roll-on/roll-off facilities. The Shipyard is also used as the location for the MWRA residuals processing facility.

DEP's decisions about the adequacy of remedial actions at the Shipyard have been based on the understanding that the property will continue to be used for industrial purposes in the future. To ensure that future construction at the Shipyard does not pose a threat to workers at the site, site neighbors or the environment, MWRA hired a consulting firm (Haley and Aldrich) to prepare a construction procedures document (CPD), dated June, 1989, which provides: (1) criteria to be used to determine the extent of contamination, if any, in the specific area being developed, (2) procedures to be used to classify, handle, reuse or dispose of excavated soils and groundwater generated during dewatering, and (3) procedures to be followed by contractors to prevent any potential exposure of workers to contaminants and

-3- prevent the contaminants from leaving the construction area, either in the air, water, or inadvertently on vehicles. This document was approved by DEP and will be revised by MWRA as part of work to be conducted under the approved waiver. Under the Waiver of Approvals, MWRA may revise its construction procedures document with DEP approval.

Surficial Oil Contamination/Stockpiled Soil: During a site inspection, DEP identified several areas of oil stained surface soils requiring removal. During May and

-4- June 1988*pproximately 760 cubic y s of contaminated soil were removed from these areas and disposed of at out-of-state facilities approved to accept such materials. Reports documenting the soil removal were submitted to DEP in July and November 1988. Based on these reports, DEP determined in a letter to General Dynamics dated December 7, 1988, that the Department's requirements for remediation of these areas have been met.

The removal of PCB-contaminated soil and oil-stained pads was completed in April 1988, and sampling to verify the initial sampling results was completed in May 1988. Approximately 115 tons of contaminated soil and debris were removed from the site. A report summarizing these activities was submitted to DEP in August 1988. DEP conditionally approved these response actions in a letter dated December 7, 1988 to General Dynamics, indicating that the Department's requirements for remediation of these areas have been met and that no further actions were required with the exception that confirmatory

-5- information be provided. General Dynamics provided this information to DEP in March 1989. In its March 2, 1994 Waiver Approval letter, DEP indicated that the Consultant of Record must review and confirm this information as part of the Waiver response actions.

Confirmatory Sampling: As required by DEP in its

-6- January 891988 letter, samples weretken and analyzed from 21 groundwater monitoring wells across the site to verify the results of previous sampling which identified the locations of groundwater contamination. General Dynamics submitted the results of this sampling to DEP in reports dated May and July, 1988. By letter dated October 12, 1990, DEP determined that DEP's "Confirmatory Sampling" requirements have been satisfied and, additional response actions are not anticipated.

Long Term Monitoring: As required by DEP, quarterly monitoring of contaminated groundwater in selected areas of the site was performed by General Dynamics. These locations include three areas where groundwater has been contaminated with chlorinated solvents or mineral spirits. Monitoring was done to insure that contaminant sources had been terminated and that contaminant concentrations were decreasing over time. The results were submitted to DEP in reports dated May, July and October 1988, and January 1989. Based on these results, DEP determined that additional investigation was required in one of the areas of chlorinated solvent contamination. General Dynamics submitted additional information in a report dated April 12, 1989. In its Waiver Approval Letter, DEP indicated that review of this information must be conducted by the Consultant of Record as part of Waiver response actions.

The GZA risk assessment was submitted to DEP in a report dated June, 1988. DEP's Office of Research and Standards reviewed the risk assessment and agreed with the report's conclusion that the site, under its current use and present state, presents minimal risk to human health.

-7- DEP has overseen the above response actions to ensure that they meet the requirements of M.G.L. c 21E. In 1986 and again in 1992, the law was amended to add a number of requirements for site cleanup. DEP's regulations detailing the remedial response action process, the MCP, took effect in October, 1988. This MCP was revised in 1993 to conform to the 1992 statutory amendments. Most of the response actions described above were performed before the 1988 MCP and 1993 MCP took effect and DEP's approvals were based on agency policies in effect at the time. Remedial response actions performed after October 1988, must comply with the applicable MCP regulations.

In summary, many decisions regarding the adequacy of assessment and remedial response actions have been made. Implementation of remedial response actions for some areas have not yet been completed and remedial response action plans for other areas are still being considered by MWRA and/or General Dynamics under the Waiver. Issues remaining for MWRA and/or General Dynamics include: reviews of information previously submitted to, but not yet approved by the DEP; floating oil in the central yard and subsurface soil contamination associated with this floating oil; the "Southeastern Boundary"; areas of elevated levels of chlorinated solvents and/or mineral spirits in groundwater; possible revision of MWRA's construction procedures document for future work in contaminated areas of the site; floating oil in the Building 9 area; and a land-use restriction. (See Exhibit III) Pursuant to DEP's Waiver Approvals,these outstanding issues will be addressed by General Dynamics and/or MWRA with the professional assistance of their Consultants of Record or Licensed Site Professionals (LSP).

PIP Status Reports have been periodically updated and provided to the public at Plan meetings, the DEP file and PIP Information Repositories. These Status Reports and the DEP approval letters issued prior to the date of the updated Plan, dated June 1994, are incorporated by reference in this Plan.

Waiver of Approvals

On March 2, 1994, DEP approved the joint application for Waiver of Approvals, subject to conditions specified in the Department's "Waiver Approval Letter." As required by DEP's

-8- Waiver Approval LAer and the MCP, the MWRA d General Dynamics have signed and submitted to DEP the Waiver Application Disposition form, accepting the conditions and responsibilities of the Waiver Approval Letter. The joint waiver application, DEP's Waiver Approval Letter, DEP's Response to Public Comments, and the Waiver Application Disposition form are on file in the designated Information repositories.

B. Public Involvement History

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

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

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

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

-9- In developing the original Public Involvement Plan in 1989, DEP took several steps to identify community concerns that the Plan must address. Documents in DEP's files relating to the agency's past involvement with the site and the community were reviewed, and interviews were conducted by DEP with local officials, groups and individuals in Braintree, Quincy and Weymouth. Concerns identified at that time are listed in Exhibit I. As part of the public review process for the Waiver Application filed by MWRA and General Dynamics, additional concerns were identified and summarized by DEP in its "Response to Review Comments on Waiver Application," dated March 2, 1994. Copies of DEP's summary are on file at DEP and the PIP respositories. See, also, the "Waiver of Approvals" summary in Section II.A., above.

III. ADDRESSING PUBLIC CONCERNS

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

identification and evaluation of remedial response action alternatives and selection of feasible measures that will

-10- achieve aqermanent cleanup at the so (Phase III), and/or

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

-11- 0 0 IV. PUBLIC INVOLVEMENT ACTIVITIES

In accordance with the 1988 MCP and the 1993 MCP, activities undertaken to involve the public in response actions serve two purposes:

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

- for Public Involvement Plan Sites, public involvement activities solicit the concerns of the public about the disposal site and remedial response actions, so that to the extent possible, these concerns can be addressed and incorporated in planning remedial response actions. To meet each of these objectives, MWRA and/or General Dynamics are undertaking specific activities for the Fore River Shipyard site. The activities in this Public Involvement Plan were selected to address the concerns about information and opportunities for involvement described in Exhibit I. These public involvement activities are described below.

Activities for Providing Information

1. Information Repositories

Information is sent to the Repositories as it becomes available. The libraries and their hours are as follows:

-12- Library ress Hours 0 Thayer Public 798 Washington St. Monday-Thursday Library Braintree 9:00am-9:00pm Friday, Saturday 9:00am-5:00pm

Thomas Crane 40 Washington St. Monday-Thursday Public Library Quincy 9:00am-9:00pm Friday, Saturday 9:00am-5:00pm

Tufts Public 46 Broad Street Monday, Tuesday, Thursday Library Weymouth 9:00am-9:00pm Wenesday, Friday, Saturday 9:00am-5:00pm

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

2. Site Mailing List

The original mailing list for the Fore River Shipyard site has been updated from time to time by DEP and MWRA. The site mailing list includes: petitioners, interested residents, site abutters, local and regional news media, municipal officials (specifically the chief Municipal officer and the Chairperson of the Board of Health), state legislators, DEP site file, and other concerned citizens. The mailing list is used to announce upcoming public meetings, distribute fact sheets, notices of public comment periods on and the availability of documents in the information repositories, and other information about the Fore River Shipyard. MWRA will maintain the mailing list and update it as necessary. MWRA has provided DEP with a copy of the site mailing list. Anyone who wants to be added to the site mailing list may contact Jose Vincenty, (617) 242-6057, ext. 1192 at MWRA.

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

-13- 0 Notification of subject field work includes information on the type of work, its approximate duration, and any expected off- site shipments of contaminated material. Notification will be. made by General Dynamics or MWRA (depending upon who is performing the work) to the people on the Notification List by telephoning the day before the activity will begin. Notification at the end of a remedial phase includes a summary of the Phase report and information on where the report can be reviewed. Those to be notified include:

Affiliation Name Address Phone Board of Selectmen James Sullivan 1 JFK Memorial Drive 848-1870 Braintree, MA 02184