UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION)

JF KENNEDY FEDERAL BUILDING, BOSTON, MASSACHUSETTS 022;30-2211

April 9.,9r

Mr. Harish PancnalDivision of Hazardous WasteDepartment of Environmental ProtectionOne Winter Street, Fifth FloorBoston, MA 02108

Dear Harish:

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

1have lately oiscovered, however, that this site should not havebeen entered into CERCLIS. The site was previously consiaeredfor CERCLIS listing in 1988, after Congressman Brian Donneliyexpressed an interest in the Ouincy Shipyard. An agreement wasreached at that time between the State (DEP Commissioner DanielGreenbaum) and EPA (former Regional Administrator Michael Deland)not to list the site, Instead, it was decided that the Statewould assume an active lead'at the site, and would ensure that athorough assessment and remediation of the site is undertaken byGeneral Dymanics. I have attached copies of the July 196-correspondences between the State, EPA, and Congressman Donnellyon this matter.

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

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

Sincerely,

Nancy SNithMA Site Assessment Coorcnator

UNITED STATES ENVIRONMENTAL PROTECTION AGENCYREGION I

J. F. KENNEDY FEDERAL BUILDING. BOSTON, MASSACHUSETTS

July 25, 19B8

Honorable Brian Donnelly438 Cannon House Office BuildingWashington, D.C. 20515

Dear Mr. D

This letter is in response to your inquiry regarding the status ofsite investigations at the Quincy Shipyard and the EnvironmentalProtection Agency's plans for conducting a preliminary assessmentat that location. As you are aware, the Massachusetts Water ResourcesAuthority has conducted extensive site investigations at the Shipyardand has developed a cleanup program which is now being implemented.As a result of your concerns, I did meet with Daniel Greenbaum,Commissioner of the Massachusetts Department of EnvironmentalQuality Engineering, concerning the State's ongoing and plannedoversight role in site remediation.

I have been assured by Commissioner Greenbaum that DEQE will playan active role in ensuring that a thorough cleanup of the site isundertaken by General Dynamics. By letter of July 8 (copy enclosed),the Commissioner outlined for me in detail DEQE's ongoing activitiesand plans. Because of the scope of the studies already completedand the commitment by DEQE to play a strong oversight role, I donot feel a preliminary assessment by EPA is warranted at this time.We will, however, be monitoring the situation, and if the cleanupprogram is delayed or determined to be inadequate then EPA wouldreserve its option to undertake additional studies at the site. Ibelieve this approach provides for the most expeditious cleanup ofthe Shipyard, while still allowing significant involvement by theAgency, should it become necessary. I know of the great concernthat you and your constituents have that the site be adequatelycleaned up and that environmental problems be resolved. I amconfident that the DEQE is committed to seeing that this is done.

Your office will be kept informed of any actions considered by theAgency. If you need further assistance, please contact me, or haveyour staff contact Betsy Horne or Michael Ochs of the Office ofGovernment Relations and Environmental Review at (617) 565-3414 orFTS 835-3414.

Sincerely,

MihDelandRegional Administrator

Enclosure

09

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

Daniel S. Greenbaum $qNreaw o aele 0Uau

Com""ssi""er"wOne 'aWer Jfe4e , Oaston, J a. os2odMEMORANDUMTO: Helen Wald fFROM: Pat Mullan'kDATE: March 28, 1990SUBJECT: Preliminary Assessment, Former General Dynamics

Shipyard, Quincy, MA

Attached please find a final copy of a Preliminary Assessment forthe Former General Dynamics Shipyard, Qunicy, MA, site number3-0536, to be submitted for the quarter ending March 31, 1990.

Orngi|la I'' :oted on N \T ced PKa pe

ras* ow

THEDEPATMTOrINYJRONMENTALFUOFET1IN

PRELIMINARY ASSESSMENT REPORT

FORMER GENERAL DYNAMICS97 EAST HOWARD STREET

QUINCY MA

INTRODUCTION

General Dynamics Shipyard occupies approximately 180 acres ofindustrial/commercial propery abutting the Fore River on theQuincy/Braintree town line. The former shipyard, located at 97East Howard Street, Quincy, Massachusetts, commenced activity in1901 and continued active operation until 1986. Prior to 1900this was a residential area known as Quincy Point. Lead paint,asbestos, oils, lubricants and chemicals were used in theshipbuilding process. The company notified as a large quantitygenerator (LQG) of hazardous waste in 1980. Reports indicateVOCs, metals, cyanide, pesticides, PCBs, acid and base neutralextractable compounds and petroleum hydrocarbons are present invarying concentrations contaminating the site. Preliminaryanalysis of site assessment reports indicate that elevated levelsof a diverse range of contaminants are present in localized areasof the site.

CURRENT AND PAST OWNERSHIP

The Fore River Shipyard site consists of approximately 180 acres,most of which are in Quincy, with the remainder in Braintree.The Shipyard is bordered by East Howard Street on the west, Southand Washington Streets on the north, the Weymouth Fore River tothe east, and the Clean Harbors and Citgo facilities and QuincyAvenue to the south (figure 1). The site has been used forshipbuilding since 1901. From 1901 to 1913, the Shipyard wasowned by the Fore River Ship and Engine Company. Between 1913and 1963, it was owned by the Bethlehem Steel Company. InJanuary 1964, General Dynamics Corporation purchased theShipyard. The Shipyard was formally closed in May 1986, and allindustrial operations ceased. In November 1987, theMassachusetts Water Resources Authority (MWRA) purchased theShipyard. MWRA will be using portions of the property forvarious components of the Boston Harbor Cleanup program,including as a staging area for construction of the new DeerIsland wastewater treatment facility and as a short term sludgeprocessing facility during the cleanup of Boston Harbor.Currently, the Shipyard is being considered as a location forMWRA's long term sludge processing facility. In October 1988,MWRA leased 50 acres of the southern and central portions of thesite to the Massachusetts landbank for use by the MassachusettsShipbuilders to resume shipbuilding.

-2-

SITE USE AND NATURE OF OPERATION

Shipbuilding has been the main operation at this site since 1901.Located on the site are buildings and structures which house theindustrial activity associated with shipbuilding. For the mostpart, the remainder of the site, not covered by buildings orstructures, is paved. In addition to the structures and pavedopen areas, the site also contains one wet basin, four piers andfive dry docks.

Substances that were mainly used in the shipbuilding processinclude lead paint, asbestos, oils, lubricants and chemicals.Site activity has been limited to remediation activities since1986 when active shipbuilding was halted.

RCRA STATUS

General Dynamics obtained a RCRA permit in August 1980 as a LargeQuantity Generator (LQG), under the ID # HAD003926045. There areno reports of any RCRA violations during the period of operationsfrom 1980 through 1986; RCRA Annual Reports were filed for theseyears also. Although the shipbuilding activity has ceased thecompany has retained their ID number to facilitate the disposalof hazardous wastes generated during the remedial activities.

WATER SUPPLY, ENVIRONMENTAL SETTING AND POPULATION

The city of Quincy has a population of 84,743 (1980), andencompasses approximately 17 square miles. The shipyard abuttsthe Weymouth Fore River to the east, Clean Harbors and Citgofacilities and Quincy Avenue to the south, East Howard Street onthe west and South and Washington Streets on the north. Land usein the area is a mix of residential/commercial/industrial. TheMetropolitan District Commission (MDC) supplies all of Quincy'sresidents with drinking water. The neighboring communities ofBraintree and Weymouth receive their water supply from the GreatPond Reservoir upgradient from the site. Therefore no watersupplies within a 4-mile radius are impacted by contaminationfrom the site.

TYPE AND NATURE OF CONTAMINATION AND REMEDIATION MEASURES

The Department commenced remedial activity at the site in January1986 by issuing a Notice Of Responsibility (NOR) referencing aSeptember 1985 release of approximately 190 gallons of #2 fueloil from an underground piping system which connects to a 10,000gallon above ground storage tank located within the Shipyard; andan April 1985 release of #2 fuel oil at the outfall stormdrainoriginating within the General Dynamics facility.

-3-

Upon receipt of the NOR General Dynamics hired a consultant,Goldberg-Zoino, Associates (GZA), to assess environmentalconditions at the site. GZA submitted an EnvironmentalAssessment Report to the Department in May 1986, in additionsupplements were submitted in August 1986, October 1986 and March1987. GZA's investigation included the excavation of test pits;installation of borings and the subsequent installation ofmonitoring wells; screening of soil and groundwater samples forvolatile organic compounds (VOCs); the analysis of selected soiland groundwater samples for VOCs, PCBs, metals, acid base/neutralextracts, and petroleum hydrocarbons; and screening of monitoringwells for an immiscible floating product.

Specific contaminants identified by GZA during the course of thestudy include the following:1) Tetrachloroethylene, trichloroethylene and 1,1,1-trichloroethylene solvents in the groundwater;2) Mineral spirits in the groundwater;3) Fuel oil products (i.e. gasoline, #2 fuel oil, weathered #6fuel oil, and residual oil) in the groundwater;4) PCB contamination in the surface soils;5) Plume of oil contamination extending over the central portionof the site.

The following remedial response actions were taken subsequent tothe submission of GZA's report: (1) Removal of PCB contaminatedsoil; (2) Removal of 10 subsurface tanks; and (3) installationand operation of a passive oil recovery system (upgraded to anactive recovery system 10/86).

As a part of the Purchase and Sale Agreement between GeneralDynamics and MWRA, MWRA agreed to undertake a portion of thefuture remedial activity at the site and so hired their ownconsultant, NUS. NUS conducted a review of the existing siteassessment reports and conducted sampling of their own. Theresulting report "Quincy Shipyard Site Assessment, March 1988"was also submitted to the Department.

Reports commissioined by General Dynamics and MWRA, indicate thatVocs, metals, cyanide, pesticides, PCBs, acid base/neutralextractable compounds and petroleum hydrocarbons are present invarying concentrations contaminating the site. The Department iscurrently reviewing the reports and sampling results to ensurethe design of a comprehensive remedial action strategy.

-4-

CONCLUSION AND RECOMMENDATION

Based on the investigation of the site and its documentation inthe site assessment reports as well as several other letterreports compiled by GZA and NUS, and their preliminary review, itis concluded that extensive contamination exists at the site.Petroleum products seem to have caused extensive contamination,and sampling and monitoring well results indicate the presence ofseveral other hazardous constituents. Although no drinking watersupplies are within a 4-mile radius of the site, and current andfuture use is limited to industrial activity, DEP feels that dueto the nature of the contaminants present, future FederalSuperfund Rermedial Action is appropriate to remediate andmonitor the site.

The Department, based on the above conclusion, recommends that amedium priority Screening Site Inspection (SSI), under CERCLA beconducted.

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REFERENCES

1) Environmental Site Assessment, General Dynamics/QuincyShipbuilding Division, Quincy, MassachusettsGoldberg-Zoino, Associates May 1986

2) Public Involvement Plan, Former General Dynamics ShipyardDepartment of Environmental Protection May 1989

3) Quincy Shipyard Site AssesssmentNUS March 1988

POTENTIAL HAZARDOUS WAS TE SITE L CENTIFICATION

PREUMINARY ASSESSMENT 1 ArE 0- mfh A.81 EPART 1- BITE INFORMATION AND ASSESSMENT

L JUTE NAME ANO LOCATI0Na] arTE eMe. a..----...- -.. QZ ffsrU. RouT NO.., Oft5PECJ;C'Qcanonw otrnE

Al cL )I I sCY Ar& u0.3 rM &STAFE 05PCZWE 06C-Okry 0cOoDE CESTN

os co LoOLs ITUDE LONGTUDE

10 oMCfcioS TO SrrE S. - ...

it Cl V I(t fI - l3Pct

m. RESPONSIBLE PARTIES

01 owR EA-- 02 STREET Ow,-N-

osCrr 04 ST ATE osZP cooM 06 TELLP"ONE NUMBER .

SOmRA T - -- - 5-C& 1 es ca T .-.. ....-

ov CrY io sT AFE _ PCOCE 12 TELEPHONE NUABER

3 TYPE of RHOEU~ c

* A. PWVATE C B. FEDERAL O C. STATE OD.COuNrTY C E. MUNCPAL

C F. OTHER: C CG UNKNOWN

a QW~tuIopA roP TCT Oomc n c.. oteae.v.,.

C A. RCHA 300 1 DATE RECSVED: ' ' CO B..UNCONTROEDl WASTE Srmac a - DATE RECEIVED: ' 0 C. ONEhm0r Car CIA eew oCA YVtAA

IV. CXARACTR.CATION OF POTENTAL HAZARDat On srrE SPECOC a, rse..w..

o YES DA E , , A. EPA O a. EPA CONTRACTOR C C. STATE C 0. OTHER CONTRACTOR

oacon. PA O E. LOCA EALT) OFFCAL C F. OTHER:

CONTRACTOR NAMEISl:

02 SrE STA To-s - ca YEARS OF o.tRA7On

C A. ACTVE BRAC"NE C C. LuIOwN O IL UNKNOWN

0 DESCE.mO4 OF usMTAJcES P'MY PREENT. 0fOwn, OR A.LEGED

05 oS.m OF PC TEN rw. Pt'.Ro TO EMvVem.ENT AOC PORATfno

ft ~ './'' A t(1 C'J t(C .jyr I

V. PRIORITY ASSESSMENT01 Pno0r rN "CPC7O 0-- a - . - - .-- - = C_ .c .

9A HIGH 8 WEDU C C. LOW C. MOE"- --- '-- ---. a m- ------ -. .- ... . ---.----

VL PsFORMAT1ON AVAILABLE FRO&I

01 CONTACT 02 O. 0.3 TELEP- N1mER

U4 OfFMCW4As--, SZfo o.1 *i T 0-L4Am no*- 07 TELEP"c't-e. NL~ormmiR 06 QA rE

.?, PL o 20 0. 2 ? -4 11

Site Name:CERCLIS No.:TDD No.:Reference No.:

V

NPL ELIGIBILITY CHECKLIST

YES NO COMMENTS

Are the wastes onsite considered hazardous,as defined in CERCL-A? - -------

*Sites covered by other authorities:

Are the hazardous materials at the site solelypetroleum products (gasoline, oil, naturalgas)? -- ---------

Is the contamination at the site causedsolely by pesticides that were appliedusing an accepted practice? --- --- ------

If the release is into public or privatedrinking water systems, is it due todeterioration of the system through ordinaryuse? --- --- -------

:s the release from products which are partof the structure, and result in exposurewithin residential, business, or communitystructures? - -------

Did the release result in exposure to peoplesolely within a work place? - -------

Does the facility have an UndergroundInlection Control permit under the SafeDrinking Water Act? - -------

Is the release the result of the normalazolicaticn of fertilizer? --- -- -------

Does the release involve naturally occurringsubstances in their unaltered form? --- --- -------

Does the contamination at the site consistsolely of radioactive materials generatedby Department of Energy/Atomic EnergyCommission activities? --- --- ------

Is the contamination at the site causedsolely by coal mining operations?

Does the facility have a permit from EPAor the U.S. Army Corps of Engineers (underthe Marine Protection, Research, andSanctuaries Act) to dispose of dredgedmaterials in ocean waters?

--- -

6y

c e Name:iCLIS No.:

TDD No.:Reference No.:

AK R~c &e~iPdd j &tAM C$~0

YES NO COMMENTS

*Other issues of site definition:

is the site defined solely as acontaminated well field?

Is the site currently owned or operatedby a federal agency, or has it been inthe past?

Is the site a municipal landfill?

-- Check if there is documentation ofindustri.al waste disposed of. ---

Does the waste consist of a "special waste"such as fly ash? --- ---

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

Does the facility have an NPDES permit? ---

Check if the facility has a historyof permit violations. ---

Is the facility subject to ambient airquality standards under the Clean Air Act? ---

Does the facility have a permit under theClean Air Act?

*RCRA status

Has the facility notified as a RCRAgenerator?

Has the facility ever had RCRA interimstatus or a RCRA permit?

If yes, check any that apply:

-- The facility is a boA quantitygenerator.

-- The facility is a NnonnotifierN or"protective filer" (identified as such.by EPA or the state).

c 6wett

27 55C

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U~kv N@4\PA 0~t#4

e Name:!RCLIS No.:

TDD No.:Reference No.:

*RCA status (continued)

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

-- A RCRA compliance order or noticeof violation has been issued for thefacility at some time.

The order or notice concerned:- conditions that posed a hazard (i.e.a release of contamination to theenvironment) OR

- administrative violations (i.e.recordkeeping or financialrequirements).

-- Some RCRA enforcement action iscurrently pending at the facility.

-- A RCRA permit has been denied orinterim status has been revokedfor the facility.

The permit or interim statuswas revoked:

-because ol conditions at the facilitythat nosed a hazard OR

-because the facility failed to meet anadministrative requirement (i.e.,failed to file an acceptablePart B permit application).

-- A closure plan has been requested orsubmitted for the facilityunder RCRA.

-- A closure plan has been approved forthe facility under RCRA.

-- The facility is closed and currentlymonitoring under RCRA regulations.

0

CERCLIS DATABASE FORM

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

DIRECTIONS TO SITE: ixHy fS9r5{g -C, u L y 4i U;:t i .3t 5NWj\f rAOjf~ Can\d~ ( Gua nt- I A- ay rur ort ta-ft efVerr d eytf

CERCLIS CODE(No. of positions)

DESCRIPTION

1. FOR ALL PROJECTS

C2(2) Postal code

Site ID(if available)

Site Name

Street Address

City

County

Ownership

C101(12)

C 104(40)

C 110(25)

C111(25)

*TBD

C136(2)

Years of operation

FMS Number(if assigned)

Dun & Bradstreetor GSA

9 Eqct d Ste

g t e

Noy 1L

FFSTCODIL

MlUN

*TBD"TBDOH

*TBD

Federally ownedState ownedCounty ownedDistrict ownedIndian landsMixed ownershipUnknownMunicipally owned

(Privatey ownedOther

t9Ly to /y!t

C315(4)

ELEMENT

State

ENTRY

01

CERCLIS CODE(No. of positions)

DESCRIPTION

11. ONLY FOR SITE WITH HRS

Latitude and Longitude

BCLMNFTPA

If unknown,Type of WastePresent R

J*TBD

D

If unknown,Type of ReceptorAffected V

HW

*TBD0

Coordinates

Type ofFacility ofSource

Waterways/riverHousing AreaDrinking Water WellsEcological ReceptorsOther

C201(240) Site Description

ELEMENT

0

ENTRY

*TBD

Chemical PlantCity ContaminationLandfillManufacturing PlantMilitary FacilityOther Federal Facilitymines/tailingsLagoonsAbandoned/Midnight dumping

Radioactive WasteInorganic WasteOrganic WasteOther Industrial WasteDioxin

C 137(1)

P

Abstract

ELEMENT CERCLIS CODE(No. of positions)

Recommendation C2103(1)of Most RecentProject at Site

Note C2105(20)

Reasons forIneligibility (forSites DeterminedIneligible underCERCLA)

Agency Responsiblefor Work at Site

DESCRIPTION

For PAs:H =

N =

HighMed.NFRAP =

= SSI Required= 551 RecommendedNo Further Remedial ActionPlanned

For 551s:R = Recommended for an L15D = Deferred to another authorityN = NFRAP = No Further Remedial

Action Planned

For LSls:G = Recommended for an HRS ScoringN = NFRAP = No Further Remedial

Action Planned

Abbreviated Comments

*TBD *TBD*TBD*TBD*TBD*TED

F5

SNFF

*TBD

C2117(2)

Petroleum contamination onlyActive RCRA facilityProperly applied pesticideNuclear/radioactive wasteAll other reasons

EPA, Fund financedState, Fund financedState, no fund financingFederal facilityResponsible Party

ENTRY

J6V2nwwa4§f 6T M Ae/

Daniel S. GreenbaumCommissioner

6twt /Aee. 2os/n, N at. (2/0N

MEMORANDUM

TO:

FROM:

DATE:

File

Harish Panchal

September, 9, 1988

SUBJECT: Fore River Shipyard (General Dynamics)

This memorandum provides an update on the status of theother response actions. The site is being addressed bythe N.E. Regional Office in Woburn and all the responseunder the technical directives of that office.

ongoing remedial andthe Department out ofactions are being taken

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

I. Immiscible Petroleum Plume and Associated Contaminated Groundwater andSubsurface Soil

The active product/groundwater and recovery treatment is ongoing and anadditional total product recovery of about 2000 gallons has occurred sinceMay 1988. It is expected that with this recovery the original productthickness of 8 feet may have decreased to a little less than 1 foot. Afeasibility study submitted by General Dynamics (GD) to address thesubsurface petroleum contamination of soil is still being reviewed bythe Department.

II. Surficial Petroleum Contamination Stockpiled Soil

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

)

-2-

III- Polychlorinated BIphenyls (PCBs)

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

IV. Southern Boundary

This is an extensive area where remedial response actions are ongoingand also joint assessment is conducted by GD, Clean Harbors and Cit iesService/Citgo to identify need and type/extent of future remedialactions. The area in which a free floating product was recovered inone of the wells a Petrex Soil Gas Survey was conducted as mentionedin the July '88 letter. As a result of the survey, it was concludedthat the free product in the well was due to some localized contamination in the surrounding area. It is decided to excavate the contaminatedarea and remove and dispose the contaminated soil.

V. Sampling and Long Term Monitoring

Confirmatory sampling and analyses were conducted on selected wellsthroughout the site. GD, as required by the Department has alsoundertaken long term monitoring of groundwater quality in selectedareas of site. Results of sampling analyses are being reviewedby the Department and based on this, further need of additionalsampling and future remedial response actions will be decided.

VI. Site Assessment Activities by GD and MWRA

Site Assessment and remedial actions were initiated by GD subsequentto the Department's issuance of Notice of Responsibility and anemergency approval of active recovery of immiscible petroleumplume in October 1986. Sine then, GZA, the GD's consultant hassubmitted a series of site assessment reports. MassachusettsWater Resources Authority (MWRA) pruchased the property from Glin November 1987. MWRA hired NUS Corp. as their consultant for siteassessment and remediation activities as a part of the Purchaseand Sale Agreement. As a result of their studies and review ofprevious reports, NUS presented their own report. This report isbeing reviewed by the Department. Based on this report., GZA hasprepared a 'Risk Evaluation Report' considering the highestcontaminant concentrations observed at site. This report is alsocurrently reviewed by the Department.,

-3

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

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

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

HP/sc

cc: Jim Colman, Director OIR for informationSharon Gerolamo

ac/ 6 0 wtcnnnaSa 64' n4eae

Daniel S. Ceenhar-rCorrmaisionr Q~

MEMORANDUM

TO: File

FROM: Harish Panchal

DATE: August 30, 1988

SUBJECT: Fore River Shipyard (General Dynamics)

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

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

I. Immiscible Petroleum Plume and Associated Contaminated Groundwater andSubsurface Soil

The active product/groundwater and recovery treatment is ongoing and anadditional total product recovery of about 2000 gallons has occurred sinceMay 1988. It is expected that with this recovery the original productthickness of 8 feet may have decreased to a little less than 1 foot. Afeasibility study submitted by Ceneral .ynamics (GD) to address thesubsurface petroleum contamination of soil is still being reviewed bythe Department.

II. Surficial Petroleum Contamination/Stockpiled Soil

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

-2-

III. Polychlorinated Biphenyls (PCBs)

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

IV. Southern Boundary

This is an extensive area where remedial response actions are ongoingand also joint assessment is conducted by GD, Clean Harbors and CitiesService/Citgo to identify need and type/extent of future remedialactions. The area in which a free floating product was recovered inone of the wells,a Petrex Soil Gas Survey was conducted as mentionedin the July '88 letter. As a result of the survey, it was concludedthat the free product in the well was due to some localized contamin-ation in the surrounding area. It is decidedto excavate the contaminatedarea and remove and dispose the contaminated soil.

V. Sampling and Long Term Monitoring

Confirmatory sampling and analyses were conducted on selected wellsthroughout the site. GD, as required by the Department has alsoundertaken long term monitoring of groundwater quality in selectedareas of site. Results of sampling analyses are being reviewedby the Department and based on this, further need of additionalsampling and future remedial response actions will be decided.

VI. Site Assessment Activities by GD and MWRA

Site Assessment and remedial actions were initiated by GD subsequentto the Department's issuance of Notice of Responsibility and anemergency approval of active recovery of immiscible petroleumplume in October 1986. Sine then, GZA, the GD's consultant hassubmitted a series of site assessment reports. MassachusettsWater Resources Authority (MWRA) pruchased the property from GDin November 1987. MWRA hired NUS Corp. as their consultant for siteassessment and remediation activities as a part of the Purchaseand Satt: Agreement. As a result of their studies and review ofprevious reports, NUS presented their own report. This report isbeing reviewed by the Department. Based on this report, GZA hasprepared a 'Risk Evaluation Report' considering the highestcontaminant concentrations observed at site. This report is alsocurrently reviewed by the Department.

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

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

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

HP/sc

Vt" Cc)/~.4 A

DANIEL S. GREENBAUMCommissioner

July 8, 1988

Michael Deland, Regional Administrator RE: Fore River ShipyardEnvironmental Protection Agency (General Dynamics)J.F.K. Building, 22nd Floor 21E Site Assessment andBoston, MA 02203 Remediation Activities

Dear Mr. Deland:

As we discussed at our meeting on June 24, 1988, hazardous waste siteassessment and remediation at the Fore River Shipyard has been under statedirection since 1986, and is well underway. As requested, uny staff has pre-pared this update of these assessment and remedial activities.

Formal enforcement actions by DEQE began on October 21, 1986, whenGeneral Dynamics (GD) was issued a "Notice of Responsibility" letter (NOR)(attached) indicating their liabilities/responsibilities underMassachusetts General Law Chapter 21E. Due to the urgency of thesituation, the NOR also gave GD an emergency approval to begin active reco-very of an immiscible petroleum plume located in the central portion of theshipyard. This plume was estimated to cover an area of approximately 1.8acres and was over 8 feet thick at some points. Due to the proximity ofthe Weymouth Fore River, there was serious concern that the plume might reachthat water body if some type of control was not initiated immediately.

During 1987, GD's consultant Goldberg-Zoino and Associates, Inc.,(GZA) submitted a series of site assessment reports. The Departmentdetermined that GZA's assessment was sufficient and set forth requirementsfor remediation in a letter dated September 20, 1987 (attached). Thisletter also cpntained the Department's requirements for additional infor-mation.

In November 1987, while assessment and remedial activities were beingconducted at the shipyard. GD sold the property to the Massachusetts WaterResources Authority (SRA). As part of the Purchase and Sale Agreement,MWRA engaged the services of NUS Corp. to (1) review all previousassessment and remedial activities conducted at the shipyard and (2) ini-tiate their own assessment of environmental conditions on the property.NUS provided the results of their investigation to DEQE in a report datedMarch 17, 1988.

100% Recycled Pap'

S -1-

At this time, the Department is reviewing existing requirements forcleanup and identifying next steps in light of the new information sub-mitted by GZA and NUS. The Department is also working closely with EWRAregarding their plans for development of the site.

The following is a brief surary of the major remedial activities con-ducted to date at the shipyard.

1. Immiscible Petroleum Plume and Associated Contaminated Groundwaterand Subsurface Soil

An active product/groundwater recovery and treatment system has beenoperating in the central portion of the site since October, 1986. As ofMay 27, 1988, product recovery had totaled approximately 363,640 gallons,product thickness has decreased from approximately 8 feet to I foot, andthe air stripper had been effective in reducing influent contaminant con-centrations to approved discharge limitations.

In regards to the extensive subsurface petroleum contaminated soillocated in this area, General Dynamics has submitted a feasibility studydated April, 1988 which evaluates remedial alternatives. This study iscurrently under review by the Department.

II. Surficial Petroleum Contamination/Stockpiled Soil

Several areas of surficial petroleum contamination were identified bythe Department at the site. From May 17, 1988 to June 2, 1988, wherefeasible, these soils were removed. Approximately 600 tons of con-taminated soil were removed from across the site and disposed of at theStablex facility in Canada. One area of surficial contamination wasobserved to be so extensive complete removal became infeasible and as suchwas backfilled with clean soil. This area is located adjacent to the mainplume and therefore will be considered an extension of that area and isbeing addressed in the previously mentioned feasibility study. A reportdocumenting the conditions described in the April feasibility study andrecommending potential remediation activities is expected to be submittedto DEQE this July.

III. Polycholorinated Biphenyls (PCB's)

Where feasible, PCB contaminated soil was removed to 1 mg/kg and PCBoil stained pads were cleaned to 100ug/100 sq cm. The removal of con-taminated soil/stained pads was completed on April 29, 1988. Approximately122.5 tons of contaminated soil/debris and 8 tons of concrete were removedfrom the site. Confirmatory sampling was completed on May 24, 1988. Areport summarizing these activities is expected within the next couple ofmonths.

IV. Southern Boundary

As required by the Department, General Dynamics is currently in theprocess of installing additional groundwater monitoring wells at thesouthern boundary to further define subsurface conditions. GeneralDynamics has also been holding active discussions with Clean Harbors and toa lesser extent with Cities Service/Citgo regarding joint efforts for theassessment and remediation of this area.

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During the course of continuing explorations in the southern boundaryarea, free floating product was discovered in one of the wells in December of1987. In order to define the extent of this layer, a Petrex Soil GasSurvey was conducted. The results of this survey were submitted in a reportdated May, 1988 and General Dynamics will be submitting a proposal forremediation of this area in the near future.

V. Confirmatory Sampling

As required by the Department, confirmatory sampling/analyses was con-ducted on selected wells from across the site to verify groundwaterquality. The results of this sampling were recently submitted to theDepartment in a report dated May, 1988 and is currently under review.

VI. Longterm Monitoring

As required by the Department, longterm monitoring of groundwaterquality in selected areas of the site has been initiated by GeneralDynamics. To date, two rounds have been conducted. The results of thefirst round were recently submitted in a report dated May, 1988 and theresults of the second round are pending.

VII. IWRA Site Assessment Activities

As previously indicated, NUS presented the results of their environ-mental assessment and comments on previous assessments and remedial activi-ties in a report dated March 17, 1988. Currently, this report is underreview by the Department.

Upon receipt of this report, GD asked GZA to evaluate NUS's assessmentand to conduct a risk evaluation of the shipyard based upon the highestcontaminant concentrations observed to date. The results of this eva-luation were submitted to DEQE in a report date June, 1988. GD and GZA

made a formal presentation on the contents of this report to DEQEJuly 7, 1988.

Level of Remediation

Section 3A(g) of Chapter 21E requires that feasible permanent solu-tions be implemented at all disposal sites. A permanent solution isdefined as " a measure or combination of measures that, at a minimum, willensure the attainment of a level of control of each identified substance ofconcern at a disposal site or in the surrounding environment such that nosuch substance of concern will present a significant or otherwise unaccep-table risk of damage to health, safety, public welfare, or the environmentduring any foreseeable period of time, considering existing public healthstandards and foreseeable uses of the site". Further, where feasible, per-manent solutions shall include "measures designed to reduce to the extentpossible the level that would exist in the absence of the disposal site ofconcernNu

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

-3-

that site use would be limited to activities of industrial or businessoffice nature. The Department has stated to General Dynamics and MWRA thatit reserves the right to reexamine the site investigation/remediationprogram should any change in the proposed site use warrant it. TheDepartment is working closely with WRA regarding its proposed utilizationplans for the site to ensure that the level of remediation being performedat the site will be sufficient for the anticipated site use.

As this sunmary clearly indicates, extensive assessment and remedialactivities have been conducted at the shipyard. Given both 6ZA's and NUS'senvironmental assessments, it is the Department's opinion that a completecharacterization of contaminant conditions across the majority of the siteis available. Additional investigation will, however, be required at theSouthern Boundary Area. The sufficiency of remedial actions completed willbe reevaluated based upon the most recent information submitted by GZA andNUS, however significant changes are not anticipated.

State versus Federal Program

This Agency would welcome any assistance EPA would like to offer inreviewing and cornenting on any aspect of the assessment or remediation ofthe site. The Department would not, however, recommend that the shipyardbe ranked for the National Priorities List for the reasons explained below.

The Department believes that a change in the site cleanup lead from theDEQE 21E Program to the EPA Superfund Program would cause significantdelays in the remediation work being performed without benefit to the ulti-mate goal of remediating the site. Nomination to the National ProgramList (NPL) at this time would duplicate cleanup efforts completed to dateand cause significant delays in future State enforcement and remediationactivities. Those delays could amount to several years.

The Department further believes that its actions at the site adequatelyaddress concerns with the site and that it is not a good candidate for theNPL. Requests for federal Superfund assistance on sites are normallybased on a number of factors, which include difficulties in getting respon-sible parties to complete site work; and the degree to which the sites:are of particular regional significance based on complex site conditions;involve wastes with which the Department has very little experience such asradioactive waste and explosives; or where a federal agency is involved inthe site contamination as a reponsible party.

Finally, regulations for implementing the amended MassachusettsSuperfund Law have been promulgated. The Massachusetts Contingency Plan,similar to the National Contingency Plan under CERCLA, contains the notifi-cation, requirements, and guidelines for the assessment and remediation ofreleases or threats of releases of oil or hazardous materials. It alsoincludes a comprehensive public participation process. The Department hasalso been given additional resources for its cleanup program and hasenhanced its ability to enforce compliance with environmental laws. Thesechanges have increased the Department's ability to cleanup sites similar tothe authorities and programs EPA has under CERCLA as amended by SARA.

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Public Involvement Plan

In response to a petition recently filed with DEQE by residents inBraintree and Quincy, the Department is developing a formal PublicInvolvement Plan (PIP) for the 21E activities at the shipyard. A series ofdiscussions have been held among staff from my Divisions of Water PollutionControl and Hazardous Waste and MWRA to determine the efficacy of utili-zing the MWRA's RMFP Quincy-Braintree-Weymouth Regional Task Force as avehicle for the 21E PIP. Such a procedure would also be very advantageousto EPA since the EPA is concurrently preparing an EIS for the MRA's RMFPand is directly involved in this public participation process, and therefore would have direct access to the 21E PIP.

I hope that this correspondence provides you with the information yourequire. If any portions of this correspondence need clarification orexpansion or you require additional documentation feel free to contact meor have your staff contact Mr. Lipman directly (292-5698).

As I indicated at our June 24th meeting, I would be happy to par-ticipate with EPA in a briefing for Congressman Donnelly.

Very truly yours

Daniel GreenbaumCommissioner

DG/SGL/sf(417)cc: Jeffry Fowley, EPA - Office of General Counsel

3. RUSSELL SYLVA 5fme,,n4

935-2160

- October 21, 19866

fr. G.S. Grimes

Vice President - General Manager-General Dynamics CorporationQuincy Shipbuilding Division ,97 East Howard St.Quincy , MA 0216 9

R E: QUINCY - General Dynamics/QuincyShipbuilding Division -97 East Howard Street

NOTICE OF RESPONSIBILITY PURSUANT TOO.G.L. CHAPTER 21E

DEQE CASE NO.: 3-511

Dear Mr. Grimes:

The Department of Environmental Quality Engineering is in-receipt of an engineering -report -prepared by Goldberg-Zoino &Associates, Inc. (GZA) concerning environmental conditions atthe subject site. This report is dated May 1986 and is entitled:"Environmental Site Assessment, General Dynamics/Quincy ShipbuildingDivision, Massachusetts".

Additional information regardi ng -remedial actions conductedat the site was submitted to the Department in a GZAsQreport datedAugust 1986 and entitled "Supplement to Environmental Site Assessment,Quincy Shipbuilding Facility, Quincy, Massachusetts".

Accordin to GZA the subject site has been utilized as ashipbuilding' facility since 1901. Currently the site is inactive.

The investigation conducted by GZA included the excavation oftestapits ; the installation of 61 borings and the subsequentinstallation of 4-4,groundwater -monitoring wells; the screeningof soil and groundwater samples for volatile organic compounds(VOC's)1 the analysis of selected soil and groundwater samplesfor VOC's,.PCB's, metals, acid-base neutral extractables, andpetroleum hydrocarbonsv and the screening of monitoring wellsfor an itiscible floating product.

Mr. C.S. Crimes

Page 2.

The results of OZA's investigation indicated that elevatedlevels of a diverse range of contaminants are present in localizedareas of the site, the most significant of these areas being thearea around buildings 5 and 11 where approximately 10 feet offloating product (#2 oil) was observed.

To date, remedial actions initiated at the site include:(1) the removal of PCB contaminated soil; (2) the removal of 10subsurface tanks, and (3) the installation and operation of apassive recovery system in the area of Anilding #5.

Your cooperation in this matter in voluntarily initiatingand pursuing site investigative and remedial measures is appreciated.Please excuse the legalistic tone of this letters we are compelledby regulatory policy to outline statutory provisions relative toyour potential liabilities at this site.

Statement of Conclusions/Statutory Liabilities

Based upon the aforementioned investigation, a condition ofsoil and groundwater contamination have been documented at thesubject site.

Be advised that such conditions constitute a "release" ofoil/hazardous materials at the site. The prevention and/or mitigationof such a release or threat of release is governed by MassachusettsGeneral Law, Chapter 21E, the "Massachusetts Oil and Hazardous MaterialRelease Prevention and Response Act."

Chapter 21E identifies as responsible parties the current owneror operator of a site at which there has been a release or threatof release of oil or a hazardous material; the past owner oroperator of a site where a release of anhazardous material hasoccurred; any person who ditactly or indirectly arranged forthe transport, disposal, storage or treatment of hazardousmaterials to or at such a site; and any person who caused or islegally responsible for a release or a Jreat of release ofoil or a hazardous material at such a -site. Such parties areliable without regard to fault; the nature of this liability isjoint and several. (M.G.L. Chapter 21E, Section 5 a).

This letter is to inform you in writing that:

(1) The Department has determined that a "release" of oil/hazardous materials has occurred at the subject site.

Mr. 0.S. Grimes

Page 3.

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(2) Initial remedial/cleanup measures are necessary at the -site to mitigate adverse public health/environmentalimpacts.

(3) Information available to the Department -indicates thatyou as owner are a liable and "responsible" partypursuant to Section 5(a) of Chapter 21E.

(4) Should you fail to implement those actions deemednecessary by this Office, the-Department may, pursuantto M.G.L. Chapter 21E, take or arrange for any and allnecessary actions at the site. If public funds areexpended under such conditions, Chapter 21E, Section 11stipulates that the Attorney'General of the Comonwealthof Massachusetts may initiate legal action against theresponsible party(s) to recover all costs incurredby the Department in the assessment, containment, andremoval of any release or threat of release of oil orhazardous materials.

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

a. all response costs incurred by the Departmentdue to the release/threat of release, includingall contract, administrative, and personnelcosts; and

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

This liability constitutes a debt to the Cozionwealth. Thedebt, together with interest, would constitute a lien on all yourproperty in the Commonwealth. In addition to the foreclosureremedy provided by the lien, the Attorney General of theComonwealth may recover that debt or any part of it in an actionagainst you. You may also be liable for additional penalties ordamages pursuant to other statutes or common law.

A synopsis of M.G.L. Chapter 21E is attached for furtherdelineation of the liabilities and penalties contained in this statuteA complete copy of this statute, as Ammended, is available at theState House Bookstore in Boston.

Mr. G.S. Grimes

Page 4.

Recuisite Site Actions

Based upon the information contained in GZA's report ofMay 1986, the Department hereby approves the i=ediate installationof an "active" product recovery system in. the area of Buildings 5and 11. Plans for such a system were submitted by GroundwaterTechnology, Inc. in a report entitled "Proposed GroundwaterRehabilitation Program, General Dynamics, Quincy Shipyard,97 East Howard Street, Quincy, Massachusetts, September 1986".

The approval for the installation of such a product/groundwaterrecovery and treatment system is based ;upon the plans datedSeptember 1986, and subject to the following conditions:

(I) MONITORING SCHEDULE

The following monitoring schedule, as developed bythe Department and agreed to by Groundwater Technology,must be implemented at the subject site:

(A) Initially

(1) Monitoring Wells

Piezometric head levels and floating productthicknesses must be determined in "key wells",1, 3, and 7 days following system startup.

(2) Influent/Effluent Water to/from the Air Stripper

The influent and effluent water to/from the airstripper must be analyzed for VOC's accordingto Groundwater Technology's modified EPAMethod 602. 1, 3, and 7 days following systemstartup. In lieu of the "Modified" 602, aportable GCamay be utilized for days 1 and 3.

(B) First Month

(1) Monitoring Wells

Piezometric head levels and floating product,thicknesses must be determined in "key wells",weekly for the first month.

Mr. C.S. Crives

Page 5.

(2) Influent/Effluent Water td/from the Air Stripper

The influent and effluent water to/from theair stripper must be analyzed for VOC's accordingto EPA Method 624 (GC/MS) for the first weekof the first month, to insure that onlypetroleum constituents are being drawn throughthe stripper. If the results of EPA Method624 indicate that in fact, only petroleumconstitutents are present, GroundwaterTechnology's modified EPA Method 602 may beutilized weekly for the remainder of the month.However, if the results of EPA method 624indicate that contaminants other than petroleumconstituents are pr'esent, EPA Method 624must be utilized weekly for the remainderof the month.

-(C) -Second~ Month

(1) 'Monitoring WellsPiezometric head levels and floating productthicknesses must be determined in "key wells",bimonthly for the second month.

(2) Influent/Effluent Water to/from the Air Stripper

The influent and effluent water to/from the airstripper must be analyzed for VOC's by means ofthe most appropriate testing method (EPA Method624 or Modified 602 depending upon the resultsof prior analysis), bimonthly for the secondmonth.

(D) Thereafter

(1) Monitoring wells

Piezomettic head levels and floating productthicknesses must be determined in "key wells"on a monthly basis.

(2) Influent/Effluent Water to/from the Air Stripper

The influent and effluent water to/from theair stripper must be analyzed for VOC's on amonthly basis utilizing the most appropriatetesting method (EPA Method 624 or the Modified602 depending upon the results of prior analysis).

Mr. G.S. Grimes

Page 6.

(II) REPORTING SCHEDULE

Written reports detailing system operation andmaintenance, system and site water quality data, andsite piezometric data must be submitted to the Depart-ment 21 days following system startup and monthlythereafter. Piezometric/product thickness data mustbe contoured; tabulations, charts, and sketches shall beutilized as needed to facilitate the presentation andevaluation of data.

(III) DISCARGE CRITERIA

The Department has established a discharge criteriaof 100 ug/1 total benzene, toluene, ethyl benzene,and xylenes for the effluent water from the air stripper.This concentration is the result of discussions betweenDEQE, EPA, and Groundwater Technology.

(IV) SUFFICIENCY OF RMEDIA. ACTIONS

Iterative actions will undoubtedly be needed to "fine-tune" system operations and optimize steady-state remedialefforts. Field decisions and actions in this regard shallbe documented in submitted reports.

Following startup and system stabilization, GroundwaterTechnology shall continuously assess system performanceand adequacy, and if warranted, shall propose systemmodifications and/or additions that may be needed to meetremediation objectives.

In this regard, the Department questions the adequacyof the four proposed recovery wells in recovering theentire floating product plume. Based upon calculationscontained in Groundwater Technology's report of September1986, the "capture zone" of each recovery well is estimatedat 41' + downgradient. The results of screening monitoringwells indicate that the inmiscible plume extends approximately150' downgradient of the most downgradient recovery well.Therefore, .a portion of the floating plume may not berecovered. Under such conditions, additional investigationand remedial actions must be initiated in this area.

Recovery operations may be terminated following awritten determination by the Department that remediationobjectives have been adequately fulfilled.

Mr. G.S. Grimes

Page 7.

Please be informed that start-up of the recovery systemmay not occur until approval is obtained from the Department'sDivision of Air Quality Control. Since there is a free floatinglayer present in close proximity to the Weymouth Fore River, theU.S. Coast Guard is issuing a variance from the NPDES permit atthis time, thereby allowing the effluent water from the air stripperto be discharged to an onsite storm drain.

As part of the overall review of the site, the Department iscontinuing to assess what impact the repainder of the documentedcontamination may have on public health and the environment andwill determine the need for additional investigation and/or theneed for remedial actions at the site in the near future.

A written response indicating your intentions to comply withthe provisions of this letter is required by November.1, 1986.

If you have any further questions regarding this mater, pleasecontact Sharon Gerolamo at the letterhead address or 935-2160.

Very truly yours,

Richard ,JhalpinActing RegionalEnvironmental Engineer

RJC/SG/gg

cc: DEQE/DSHW, 1 Winter St., Boston, MA 02108- ATTN: Madeline SnowQuincy.Bd. of Health, 2120 Hancock St., Quincy, NA 02169Ms. Laurie Burt,YFoley, Hoag & Elliot, One Post Office Sq.,

Boston, MA 02109Mr. Thomas J. Kern, Goldberg Zoino & Assoc., The Geo Bldg.,

320 Needham St., Newton Upper Falls, MA 02164Mr. John Grabowski, Citgo Petroleum Corp., One Warren Place

Box 3758, Tulsa, OK 74102Ms. Jeji Malek, Cities Service Oil and Gas Corp., 110 West 7th St.

Box 300, Tulsa, OK 74102Mr. Michael Hatch, Clean Harbors, Inc., 325 Wood Rd., Braintree, 1Mr. David Tordoff, US EPA, 60 Westview St., Lexington, MA 02173Commanding Officer, U.S. Coast Guard, Marine Safety Office, 447

Cocercial St., Boston, MA 02109-1096Mr. Richard Kowalski, Groundwater Technology, Inc., Suite 101

1420 Providence Highway, Norwood, MA 02062

S. RUSSELL SYLVACmamsioner

50mmmea-A. ,4dAnue0

A6~~cmazoauce atk //aacae

9

September 20, 1987

Mr. Fredrick SussuanGeneral Dynamics/QuiUcy Shipbuilding Division10 Forbes Road EastBraintree, HA 02184 -RE: QUINCY - General Dynamics/

Quincy Shipbuilding Facility97 East Howard Street -DEQE Case No. 3-536

Dear Mr. Sussman:

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

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

I. ADEQUACY OF THE SITE ASSESSMENT

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

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

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

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

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

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

2

(6) Investigation of Potential Southern Boundary Source Areas,Quincy Shipbuilding Facility, Quincy, MA, GZA, March 1987

(7) Summary Table of PCB Chemical-Screening and AnalyticalResults and Remedial Measures, July 15, 1987

(8) Tank Removal Observation Summary, April 26, 1986 and FieldSummary Sheets, April 22-25, 1986 -

(9) Report on Asbestos Abatement Activities at the GeneralDynamics Corp/Quincy Shipbuilding Division, ERT, July 1987

Based upon a review of these documents, it is the Department'sdetermination that, overall, they appear adequate in identifying allareas of the site thet may pose a significant threat to public healthand/or the environment.. The basis for this determination is addressedin Section Il below.

In reviewing these reports, the Department has several requestsfor additional confirmatory information. These requests will beaddressed in Section III of this letter.

II. DEPARTMENTAL REQUIREMENTS FOR CLEANUP

Section 3A(g) of Massachusetts General Law Chapter 21E requiresthat feasible permanent solutions be implemented at all disposalsites. A permanent solution is defined as "a measure or combinationof measures that, at a minimum, will ensure the attainment of a levelof control of each identified substance of concern at a disposal siteor in the surrounding environment such that no such substance ofconcern will present a significant or otherwise unacceptable risk ofdamage to health, safety, public welfare, or the environment duringany foreseeable period of time", considering existing public healthstandards and foreseeable uses of the site. Further, where feasible,permanent solutions shall include "measures designed to reduce to theextent possible the level of oil or hazardous materials in theenvironment to the.level that would exist in the absence of thedisposal site of concern."

The Department's requirements for the level of investigation andthe level of remediation at this site is based upon General Dynsamics'assertion that site use would be limited to activities of industrialor business office nature. Be advised that, the Department reservesthe right to reexamine the site investigation/remediation programshould any change in the proposed site use warrant it.

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

(A) Am Immiscible Petroleum Plume and Associated ContaminatedGroundwater in Area 2 of the Site,

'> (B) Subsurface Petroleum Contaminated Soil in Area 2 (associated

3

with the immiscible plume),

(C) Surficial Petroleum Contaminated Soils,

(D) Polychlorinated Biphenyl (PCB) Contaminated Soil,

(E) Mineral Spirits

(F) Chlorinated Solvents

(C) Acid/Base Neutrals

(H) Asbestos

(1) Properties Outside of the Shipyard Proper

(J) Southern Boundary

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

A. THE IMMISCIBLE PETROLEUM PLUME AND ASSOCIATED CONTAMINATEDGROUNDWATER

An immiscible plume, consisting primarily of #2 fuel oil, existsin Area II of the site, in the vicinity of building 11. This plumeextends over an area approximately 1.8 acres in size and whenoriginally discovered, was approximately 8 feet thick. Realizing theurgency of this situation, General Dynamics immediately contractedGroundwater Technology to recover this plume. In August of 1986, aproduct/groundwater recovery and treatment system was installed forthe purpose of containing and recovering the oil. This systemoriginally consisted of a few recovery wells and an air strippingtower. The system has since received several modifications. Passiverecovery of the oil began on August 19, 1986 and active recovery beganon October 22, 1986. To date, the system has recovered approximately327,000 gallons of oil and has been.effective in treating contaminatedgroundwater.

The requirements for cleanup of this area (ie. how long thissystem would have to run) was a major topic of discussion betweenDEQE, General Dynamics, and OZA. It was agreed that remedistion wouldfollow a phased approach, specifically: Phase I-Product Recovery,Phase II-Groundwater Recovery and Treatment, and Phase III-Long-termMonitoring. In a letter dated August 17, 1987, CZA submitted aproposal to implement this approach. Please be advised that, afterreviewing this submittal, the Department has established a modifiedfinal approach for General Dynamics to follow. This approach isdescribed below:

Phase I - Product Recovery

Note: The existing product/groundwater recovery and treatmentsystem is operating under this phase.

4

Obje ctive: To recover all immiscible floating product. -

Requirements:

(1) The product/groundwater recovery and treatment system austrun until all floating product has been removed (ie., nomeasurable amounts observed in impacted wells), or

(2) If General Dynamics can demonstrata that achiavingRequirement I is technically and economically infeasible, theDepartment will consider the use of a technology based limit(TBL). The Department has defined this TEL as that pointwhen product recovery (under optimal conditions) has becomeasymptotic (leveled off for a period of 6 months) and theproduct thickness in impacted wells is less than two inches.

Monitoring: The system along with "key wells" must continue to bemonitored monthly as required in the October 21, 1986 Noticeof Responsibility (NOR) letter.

Reporting: Reporting must continue on a monthly basis as required inthe October 21, 1986 NOR letter.

Phase 11 Transition: When the requirements of this phase have beenachieved, remedial actions can move into Phase 11.

Note: If applicable, groundwater monitoring data collected duringthis phase may be credited towards the jequirements of Phase 11.

PHASE 11 - GROUNDWATER RECOVERY AND TREATMENT

Objective: To determine the appropriateness of continued groundwaterrecovery and treatment and to confirm that the objective ofPhase I has been met.

Requirements:

(1) The groundwater recovery and treatment system must continueto tun through one hydrologic cycle (1 year). 'During thisyear, groundwater in key wells must be monitored to observethe effects of seasonal fluctuations on floating productthickness and dissolved contaminant concentrations.

(2) The entire product recovery system must remain in place andoperational in the event that immiscible petroleum reappearsduring this phase.

Monitoring: The influent and effluent to the treatment system alongwith "key wells" must be monitored monthly during this phasefor parameters (including floating product) to be specifiedat the end of Phase 1.

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

5

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

PHASE III - LONG-TERM MONITORING

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

Requirements:

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

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

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

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

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

General Dynamics muat submit a feasibility study to evaluateappropriate remedial/cleanup actions for petroleum contaminated soilassociated with the immiscible plume in Area 2. As indicated by GZAin a letter dated August 18, 1987, this study will be completed inapproximately 3 months.

C. SURFICIAL PETROLEUM CONTAMINATED SOIL

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

6

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

D. POLYCHLORINATED BIPHENYLS

-To date, all soil found to contain polychlorinated biphenyls(PCBs) at concentrations greater than 40 ppm has been removed from thesite. The Department has determined that soil remaining at the siteat concentrations less than 1 ppm PCBs does not require any type ofcleanup. However, soil remaining at concentrations greater than 1 ppmand less than 40 ppm must be capped with a minimum of 10 inches ofclean, compected soil as previously proposed by GZA and a deednotification must be made to prevent future disturbance of these areaswithout DEQE approval. General Dynamics has recently agreed to removesoils containing-PCBs at concentrations greater than I ppm to anapproved disposal facility.

For PCI contaminated concrete pads at the site, the Departmenthas established a cleanup requirement of 100 ug/100 aq cm. This levelwas obtained from the existing Federal Regulations which state thatfor decontaminating spills in areas with "restricted access" and wherethe contaminated surface is a "low contact outdoor surface", cleanupis required to 100 ug/100 sq ca. In the instance that this level isunachievable, the surface must be properly sealed and a deednotification must be made.

E. Mineral Spirits

Mineral spirits were observed in one area of the site where twosubsurface storage tanks were formerly located (south and east ofbuilding 26). Based upon the results of groundwater aampling/analysiaconducted in this area, the Department does not enticipate requiringany remedial/cleanup ections at this time. However, additionalgroundwater sampling/analysis vill be required to insure thatcontaminant levels are decreasing over time.

F. Solvents

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

G. Acid/Base Neutrals

Acid extractable compounds were observed in one water sample froma well located in the southern boundary area.

7S

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

Excluding the southern boundary area which will be addressed inSection II(K) of this letter, the Department does not anticipaterequiring any cleanup at this time. However, additional groundwateraampling/analyais will be required particularly in the area of theImmiscible petroleum plume.

B. Asbestos

Based upon the historical use of asbestos throughout theshipyard, several soil samples were obtained from selected locationsfor analysis. No detectable levels of asbestos were observed in anyof the samples. Therefore, the Department does not anticipaterequiring any remedial/cleanup actions at this time.

In addition, General Dynamics has submitted a July, 1987 reportby ERT regarding the location, condition, and remediation of asbestoslagging. The Department's Division of Air Quality Control/AsbestosSection will review and respond to this submittal under a separatecover.

I. Metals

Soil and groundwater samples from across the site were analyzedfor the Priority Pollutant metals. Based upon the results of thisanalysis, the Department does not anticipate requiring anyremedial/cleanup actions at this time.

J. OFFSITE PROPERTIES

There are several properties outside of the shipyard proper whereno subsurface investigation was conducted based upon the results of aPhase I assessment (including a historical literature search andvisual inspection) which indicated that these areas were neverindustrial is nature. Since there is no information to indicate thatthere has been a release of oil/hazardous materials in these areas,the Department cannot require any additional work at this time.

K. Southern Boundary

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

III-. ADDITIONAL DEPARTMENT REQUIREMENTS

a

7'

The following is a list of Department requirements.,for additionalconfirmatory information. These requirements have been numberedsequentially to facilitate your response.

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

2. Explain the alevated level of total patroleum hydrocarbons In MW1113, 1116, 1117, and 1118.

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

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

5. Identify all wall head elevations.

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

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

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

9. All stockpiled soil associated with the removal of severalunderground tanks, if contaminated, must be removed to an approvedfacility for disposal or reuse. Uncontaminated soil may be reusedonsite subject to Department approval.

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

11. Provide the Department with a report detailing site surveys orInvestigations addressing licenses from the Nuclear RegulatoryCommission, or other appropriate agencies regarding nuclearmaterials which may have been used, stored, or otherwise handledat the.site.

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

9

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

The Department's detarmination in this matter shall not limit theresponse or action we might take with respect to other sites in thearea or the response or action we might take regarding this propertyin the event that further informatiob comes to the attention of theDepartment.

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

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

ory tru yo ,0

Richard J. ChalpinDeputy gionalEnvironmental Engineer

cc:

DEQE, 1 Winter Street, Boston, MA 02108, Attn: Madeline Snow, DHW, 5thFloor

Quincy Board of Health, 1120 Hancock St., Quincy, MA 02169Ms. Laurie Burt, Foley, Boag & Elliot, Ode Post Office Square, Boston,

MA 02109 *Mr. Lawrence Feldman, Goldberg Zoino & Associates, The Geo Bldg., 320

Needham St., Newton Upper Falls, MA 02164Ms. Beji Malek, Cities Service Oil and Gas Corp., 110 West 7th St.,

Box 300, Tulsa, OK 74102Hr. John Grabowski, Citgo Petroleus Corp., One Warren Place, Box 3758,

Tulsa, OK 74102Mr. Alan McKim, Clean Harbors, Inc., 325 Wood Road, Braintree, MA

02184

Tioma; c McManor.Director

-fwa ?!Z//6////recac Cc r/~ (:rninn4a L MI

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July 6, 1988

Leigh Bridoes, DirectorDivision of Marine Fisheries100 Canbradcc S-reetBoston, MA 02203

RE: Weymouth Fore River -General Dynamics Shipyard(Fore River Shipyard)

Dear Mr. Bridges:

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

The remediation of this site is extremely important to DEQE for tworeasons: (1) the shipyard is a critical element of the Boston HarborCleanup Plan and, (2) potential impacts of site contamination on theWeymouth Fore River and its fishery resources. Since this report comes onthe heals of the EPA Quincy Bay Study and also uses flounder, shellfish andlobster as its indicator and impact species, it will be viewed by some asan aspect of tnat study.

Throughout the fishery consumption impacts portion of the report(beinning on page 26) there are numerous references to DMF reports,unpublished data and personal communications. The Department does not wantto complete its review of this document without checking with DMF to ensurethat there hasn't been any misuse or misunderstandings of the informationprovided by DMF.

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

-1-

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

Very truly yours,

Thomas C. McMahonDirector

TCM/SGL /sf(417)cc: Sharon Gerolamo, DEQE/DHW

Carol West, ORSMichael Murphy, ORSBob Bois, DEQE/DHW

V.

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October 28, 1937

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Mr. Michael R. DelandRegional AdministratorEnvironmental Protection AgencyJFK Federal BuildingBoston, Massachusetts 02203

Dear Michael:

Thank you for your recent letter concerning my request that aPreliminary Assessment of the Quincy Shipyard be completed. Iappreciate your prompt attention to my request.

I had been aware that the Massachusetts Water Resources Authorityhad retained a firm for discovery and analysis of hazardous wasteat the Quincy Shipyard. Although I certainly do not wish toimpugn the motives of any party involved, I'm sure you understandmy concern that there be no potential for conflict of interestduring the initial assessment of the site. The prospect of aconflict of interest could be raised in the eyes of the publicwhen the owner cof the site is responsible for the hazardous wasteassessment. I urge you to use great diligence in monitoring thework contracted for by MWRA.

Additionally, I am curious to know if there is precedent for thisaction. If possible, please provide me with a list of instanceswhere the owner of a suspected hazardous waste site was allowedto conduct the Preliminary Assessment. More specifically, issuch a procedure precedented.

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

With warm regards,

Sincerely,

BRIAN DONNELLY Nov; Z 1981.Member of Congress

BD/ trb

438 CANNON HOUSE OFFICE BUJLOINGWASHINGTON. D C 20S1512021 225-3215

2307 JOHN F. KENNEDY FEDERAL BUILDNGBOSTON, MA. 022031671 2234038

47 WASHINGTON STREETQUINCY MA 0216-(617 .2 18M

61 MAIN STREETBROCKTDN. MA 0240116171 W 6 0

TOLt FREE UNE TOWASHNGTONI " 4249112

b~c of tbc

33ouse of i&rpresrntatiuss

BRIAN DONNELLYMASSACHUSETTS

ELEVENTH DISTRICT

Jicin

UNITED TES ENVIRONMENTAL PROTEC@N AGENCY

REGIONI

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

October 21, 1987

Honorable Brian DonnellyHouse of RepresentativesWashington, D.C J 0515

Dear Mr. nl

Thank you for your letter of September 23, 1987 to MerrillHohman, Waste Management Division Director for Region I,requesting a Preliminary Assessment of the Quincy Shipyardproperty. As you know, a Preliminary Assessment is generallyan initial evaluation of a site based on existing informationsuch as data concerning site management practices, review ofland use data from local planning agencies and review ofgeological, hydrological and topographical data availablefrom federal, state and local institutions.

The Massachusetts Water Resources Authority has informed us thatit intends to commence an extensive study of the site todetermine the nature and extent of whatever hazardous materialsmay be present there. This study is scheduled for completionwithin the next six months.

In light of the fact that this sort of study provides preciselythe type of data EPA typically employs in conducting aPreliminary Assessment, and that the study is scheduled forcompletion in the near future, I believe it makes sense toawait the result of the study before determining what stepswould be appropriate for this office to take.

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

Sincerely,

Michael R. DelandRegional Administrator

cc: S. Russell Sylva

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5AChWWIZWZZ/YV ~

S. Russell SvlvaCommissioner(617) 292-5851

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4nrne $ nt6 men Sc/ forua0.<

MEMORANDUM

TO:

THRU:

FROM:

DATE:

James C. Colman, Director, OIR

Edmond Benoit

Madeline Snow

October 13, 1987

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

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

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

t ~

444.4

K.

-2-

In view of the fact that this site was operated under contract and even by thefederal government during (WWII) there is some thought it may be considered afederal facility. In addition, if MWRA owns the site, its status could beinterpreted as a state owned facility if it were on the NPL. We believe that,for these reasons, the legal office should get involved in this site. Thesituation is further complicated by purchase and sales agreements alluded to inthe press which supposedly say MWRA will assume responsibility for contamination6 months after they buy the property. We are trying to find out more detailsabout this.

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

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

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

HP/sc

cc: Anne Bingham

S& Russell Sylva W/9 4Commissioner

(617)292-5851 ~'~~<~~

MEMORANDUM

TO: To The Files

FROM: Harish Panchal

DATE: October 8, 1987

SUBJECT: General Dynamics/Quincy Shipyard

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

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

Cleanup Responsibilities: To what extent General Dynamics, as a previous owner,is going to accept the responsibility of cleanup after the property is sold isrelatively unclear at this time. However it seems that General Dynamics hasagreed to cleanup whatever contamination that is noticed as a result of a sixmonth study, assessment and evaluation of the site (effective September 23,1987.) to an industrial standard - a standard that our Department has to decideconsidering its future use, risk assessment level, potential threat to publichealth and the environment, weighed against the cleanup-cost. As it appearsfrom the press release, whatever contamination that may be noticed after thissix months study period, it will be the responsibility of M4WRA to cleanup suchcontamination and whatever deems acceptable to the standard set forth by ourDepartment. (Our office is awaiting a copy of the purchase agreement for a clearinterpretation.) At this time our Department does not anticipate any futuredifficulty in assigning or delineating moral, financial or legal respon-sibilities, as all the sections of MGL c. 21E as amended are very well defined.General Dynamics have already been issued two notices of responsibilities underMGL c. 21E on January 14, 1985 and October 21, 1986 by our Department and theyhave responded to both of these. It may be useful to know that our NortheastRegion Office is aware of the current development and actively working on thissite.

-2-

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

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

Congressman Donnelly's Press Statement: With respect to Rep. Donnelly's viewsregarding placing this site to the National Priority List, it is theDepartment's position that it is premature at this time to imagine any such possi-bility. As indicatd earlier in this memo, the Department is constantly workingon this site and has already defined the necessary actions pertinent to ourregulations, applicable and relevant to the type of contamination found presentuntil this time. General Dynamics has agreed and responding by taking remedialactions as per our technical direction and under MGL c. 21E. However the maincriteria, that governs any site to be nominated for NPL i.e. the HazardousRanking System is being revised. EPA has released a draft version of this modelwhich is in circulation for review and comment. After receiving comments fromenvironmental and other related agencies and public group, nationwide, EPA willpublish a semifinal draft which will be open for public comments This draftwill become a final model after incorporating the necessary comments at the endof the comment period. The Department will then be able to score the siteapplying this model to the site conditions. The site will then be eligible to

4PL be placed on MPH if it scores above 28.5. until this time, the site will con-tinue to be addressed by our Department under MGL c. 21E.

eptember 23, 1987

af ~cpesetatgs

Mr. Mel Hollman LU VSuperfund DirectorU.S. Environmental Protection AaencvRegion I2203 J.K.F. Federal Building REGION IBoston, Massachusetts 02203 WASTE MGMT. DIVII

BRIAN DONNELLYMASSACHUSETTS

ELEVENTH DISTRICT

SION

Dear Mr. Hollman:

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

Consistent with the discovery section of the regulations implementingCERCLA (40 CFR 300-63), I am writing to inform you that based onmy personal knowledge and belief, the property located at 97 EastHoward Street, Quincy, Massachusetts (commplly known as the "QuincyShipyard") is a potential hazardous waste site. Therefore, Irequest that pursuant to 40 CFR 300.63 (d) (1), a preliminaryassessment of the site be undertaken.

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

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

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

Thank you for your attention to this matter.

Sincerely,

BRIAN DONNELLYMember of Congress

AM CANNON HOUSE OFFICE BUILDING 2307 JOHN F. KENNEDY FEDERAL B LDiNG 47 wASHINGTON STREETWASHINGTON, D C. 2051 BOSTON. MA. 22 OUINCY, MA 0216E=22 225-3S (617) 223O7] 16171 4 72 1I H

61 MAIN STREETBROCKTON, MA. 02401(6171 SU C"0

TOLL FREE LINE TOWASHINGTON1-9WJ 424 9112

;eCn0m al. Iinc.

April 24. 2003

GZA File No. 11930.82-C

I \\A -1 - - l

1 i- , ' '

Nis. Sharon GobielDepartment of Environmental ProtectionNortheast Regional Office205 Lowell StreetWilmington. Mlassachusetts 01887

Re Deconmissioning ActivitiesCentral Yard Oil Plume AreaQuincy/Fore River ShipyardQuincy. MassachusettsRTN # 3-0536

Dear Ms. Gohiel:

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

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

Ver truly vours.

GZA GEOENVIRONM ENTAL, INC.

C-.K-.

Lawience Feldman. LSPSenior Principal

Cc: Kristin Fletcher, GDLaurie Burt, Esqj., FH

Stephen Pitrowski, GZA

1 IE l0 /( )Y 1% 4f 5 I\ id N 'kkl-.sPL fl) -Notki in II Systeu I tunauii Apl . tol i

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OFFICE OF THE COUNCILUINCY

D.\\itai G. Rm\ i< moiResidence: (617) 479-9044 G ,.it pF i -

Ms. Sharon Gobiel March 5, 2003MA Department of Environmental Protection205A Lowell St.Wilmington, MA 01887

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

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

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

" What are the environmental issues at the site that are within the jurisdictionof the Massachusetts Department of Environmental Protection?

" What input does the community have regarding the cleanup of the site?" What input does the community have regarding any agreement that the

Government may enter into with the new owner of the Shipyard?* What other Government agencies are involved in the cleanup of the site?

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

Sincery,

Daniel G. Raymondi fCOUNCIL PRESIDENT and CHAIRMANFORE RIVER REDEVELOPMENT COMMITTEE

jrEnclosures -QY Gt

City Hall, 1305 Hancock Street, Quincy, MA 02169-510 2 (617 376- 3

i 1w)(A It ti&Ydnflo of c Ar C 1 I calltGj *Y

IN R E WARD TW COUNCILLOR DANIEL G. RAYNWNDIINTRODUCED BY

CITY OF QUINCYIN COUNCIL

ORDER NO. 2002-011 January 22, 2002

ORDER E SOLUTION ESTABLISHING FORE RIVER REDEVELOPMENT COMMITTEE

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

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

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

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

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

State Representative Joseph Sullivan, Fifth Norfolk DistrictState Representative Ronald Mariano, Third Norfolk DistrictQuincy City Councillor Daniel Raymondi, Ward TwoQuincy Director of Planning & Development, Richard MeadeBraintree Board of Selectmen Chairman, James CaseyBraintree Director of Planning & Conservation, Peter LaPollaWeymouth Planning & Economic Development Director, James ClarkeQuincy Point Business Association President, Thomas O'BrienQuincy Ward Two Civic Association President, Zaida ShawEast Braintree Civic Association, RepresentativeSouth Shore Chamber of Commerce, RepresentativeSouth Shore Building Trades Council, RepresentativeQuincy 2000 Corporation, RepresentativeQuincy Mayor Phelan's Representative.

ADOPTED IN COUNCIL JANUARy 22, 2007APPROVED

ATTEST:

2S 2002 CLERK OF COUNCIL

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

NAYS Cahill, Connolly, Coughlin, Finn, Gutro, Hansey, McCauley, Newton, Raymondi

EXECUTIVE SECRETARYTeri S. Ackerman

TOWN OF BRAINTREEONE JFK MEMORIAL DRIVE

BRAINTREE, MASSACHUSETTS 02184TELEPHONE: 781-794-8 UD FAX. 781-794-8128

OFFICE OF SELECTMENJames M. Casey

Chairman

David M ShawVice Chair-man

Leland A. DingeeHawold J, RandolphAlfred W. Varraso

January 30, 2002

City Councilor Daniel RaymondiQuincy City HallQuincy, MA 0 2169

RE: RESOLUTION SUPPORTING THE ESTABLISHMENT OF THEFORE RIVER REDEVELOPMENT COMMITTEE

Gentlemen:

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

Very truly yours,

Tern S. Ackerman, Executive Secretary

ApLerovai BOS

(cIi\ li~llldll llc.

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

N 1

SI \\I -, V

Ms. Siarol GobielDeparmnit EInviromnental ProtectionI

Northeast Reeional Office205 Lowell StreetWilmingiton, Massachusetts 0 1887

Re: Notilication of Post- Rciiediation Contiratory MonitoringCentral Yard Oil Plume AreaQuincy/Fore River ShipyardQuiricy, Massachusetis

RTN # 3-0536

Dear Ms. Gobiel:

On behalf of General Dynamics (GD), GZA GeoEnvironiental, Inc. (GZA) is pleased toadvise you and the Massachusetts Depanrment of lnvironmental Protection (DiP) that wehave initiated confiniatory monitoing to verify that the remedial goals ti the Central YardOil Plune (CYOP) area of the Quincy/Fore River Shipyard have been achieved.Specifically, the pulse pumping and bioventing remedial system has been shut down for an

indefinite penod of time to allow GZA to conduct post-reimediatioii confiinnatoryniiitorling for separate phase hydrocarbons (SPH) in the CYOP area.

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

Notification of Post- Reimediation Confirmatory Monitoring

On October 25, 2001, the pulse pumping and biovent systems at the CYOP were turned offfor a scheduled "pulsed off' cycle. The results of the first round (taken on November 2,2001) of SPH thickness measurements taken following shutdown indicated that less than 2

inch of SPH was present in each of the surveyed wells within the CYOP. Since thisshutdown, the system has remained off and five additional rounds of gauging data understatic conditions have been collected, each indicating that the average thickness of SPH inthe CYOP area wells is below h inch. The results of these six gauging rounds arepresented in tabular form as an attachnrent to this letter for reference The first three ofthese gauging tables were presented in the latest Monitoring Report #123, submitted to theDEP in Januarv 2002.

Given the limited residual thickness of SPH in the CYOP, and the limited SPH recoveriesexperienced recently, it is GZA's opinion that substantial quantities of recoverable SPH donot exist at the Site. Moreover, conditions for a Pennanent Solution with respect to 310

I , , L ' I ri ,- \rj \ II

S5 : ME

Department of 1-onmental ProtectionRTN # 3-0536

0 March 26, 2002Pace 2

cr1't

CMR 40.0996 (i.e., less than 12 inch of SPH) have been indicated during our recent Surveys.

It thus appears that the pulse pumpiing aid bioventing remedial systm ihat wasimplemented in August 1999 by GZA to augiient the existing reniedial system' has attainedthe remedial coals for SPH in the CYOP. Accordingly, GZA reconiiids that the CYOPsvstem remain off indeintely to allow continued ninitoring for SP. In accordaicc withrecent DEP guidaice (implementation of the MADEP VPH/EPH Approach - FinalDraft, June 2001, Section 4,6), the monitornug will he perhnned lor a full hydrologicCycle (i.e., OIe yar from the October 25, 2001 shutdown) to confinrm that the SPH1 cleanup

coals (i.e., less than h inch average thickness of SPH) in the CYOP have been attained.Ie nonitoing will be conducted on a monthly basis to provide sufficieti data points with

respect to valying groundwater elevations iII support of Site closure under the MCP.

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

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

Very truly yours,

GZA GEOENVIRONMENTAL, INC.

Stephen T. Pitrowskiroject Manager

Lawrence Feldman, LSPSenior Principal

Albert Ricciardelli, PESenior Principal

Attachments: Gauging Sheets

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

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

The pulse pumping and bioventing remedial systen was implemented to augment and accelerateremedmation of the SPH. Previous remediation involved more traditional methods (i e., continuousgroundwater extraction and product recovery) and had reached asymptotic recovery levels after 13years of operation since 1986.

Project Naine General jInaincs

P'olecO Numnher 119 il 92

WELL MIONITORING FORM sHuICTle %I K licer

Ile I| D2 MryI

ASt|MI D ( (1kHIl11)

wl 1 1(I~ Illi law DI- I I MNDR(X Asill H I1- 1 ' l/H )lI -it

\\ [ ID 1 z0 l :P I T 1 1- 1 -\ R 10l1ARI111 lI~N I-. S S RA\ 1)Y HI AD

(feu I (I ((ee) IecT (tcti (ctI) 1 h n e li(et

I 23 73 96.29 13.63 ND ND ND NA 82.66

+ V' >17i 90(2 NM NM NA NA NA NA

MW-C 12.4 90.26 8.15 ND ND ND NA 82.11

\* \ I k iksuil ikniiwn VM N 1 NA NA N A NA

SMW- 22.65 100.26 17.72 N) ND ND NA 82.54\ A 9997 17 1N- NI ND N-\ H

\ Unknown Unknown 17,60 ND ND ND NA NA

\ 268 9600 NM Mi NA NA NA NA

M 9 19.40 94.54 12.98 ND ND ND NA 81.56

\1\\ Unkmn I nknown NM NM NA NA NA NA

\ 17S55 95.13 11.96 ND ND ND NA 83.17I5 3- 94 32 11 ) \D NDI) ND NA 2 '

+ MW-i 3 Unknown Unknown NM NM NA NA NA NA

+ M\ I x 20.40 92.54 1H 10 ND ND ND NA Q 44

+ MW-ISS 18.94 90.63 NM NM NA NA NA NA+ W -II 14.36 9146 74 ND ND ND NA 82 7

MW-1I 27.73 100.80 17.67 ND ND ND NA 83.13* 1 I 2S 47 100 9 17.9 17 94 001 1) 12 0I8, 82 9G

' RW-1 A, 35.25 97.32 14.92 14.90 0.02 0.24 0.85 82.42' R\* - 29'") 96 1 127 13 2i 002 D24 0 8, C29

' RW-3A\ 36.90 100.50 18.02 1798 0.04 0.48 0.85 82.51* Ri J ) w' I 9h ND ND NI) NA 12

- RW A 36.70 95.92 13.80 13.78 0,02 0.24 0 85 82 14

* R 10 33.01 98 4 l'9 179S 0 0 03 0 9X X()0SI

RW - 34,55 96,38 13 81 13 79 0.02 0.24 0.85 82.58

":\\ 2' s1 9692 14 29 ND ND NI NA K] 6

"RW- 28,60 95 96 14.65 ND ND ND NA 81.31" \ 'A 2-.3' 98,2) 1 b6 ND NI) ND NA 80 55* RW-10 20.58 98.60 16.33 ND ND ND NA 82.27" R\\- I 29.3i 98 83 1X.21 ND ND NJ) NA 8O62

' RW-12 22.05 99.93 18.40 ND ND ND NA 81.53+ GD-il) Unknown Unknown NM NM NA NA NA NA+ GD-1154 Unknown Unknown NM NM NA NA NA NA+ GD-2 2 is 90 40 7 28 ND ND ND NA $3 12

* GD-2129A 30.40 100.40 17.67 ND ND ND NA 82.73

+ GD-2133 Unknown Unknown NM NM NA NA NA NA

* GD-2152 Unknown Unknown NM NM NA NA. NA NA* GD-21' 24.34 99.71 17.14 17.33 0.01 0.12 0 85 82 58

GD-2157 13.4 99.31 0.56 ND ND D NA 88.75* 11 2158 1856 9918 17.04 ND ND ND NA 8214

* GD-9... ;2312 *40joo'j -V I.O . ND .,D 'ND - NA 82.80* 4)-2268. 26.90 10084 17.81 ND ND ND NA 83.03

* GDP2OA Unknown -n!n .0NM -A . NA NA NA+ GD-2270 Unknown Unknown NM NM NA NA NA NA+ GD,2390A Unknown :Uaknon #NM NM -NA NA NA NA+ GD-2391 Unknown Unknown NM NM NA NA NA NA

+ GD-2392 .16.32 90.51. 7.0 ND ND ND NA 82.61+ GD-2393A 15.29 S9.50 7.23 ND ND ND NA 82 27+ GD-2394 Unknown Uniown NM NM NA NA NA NA+ GD-2395A 20.0 90.67 7.45 ND ND ND NA 83 22+ GD-2396 Unknown Unknown NM NM NA NA NA NA+ GD-2397 Unknown Unknown NM NM NA NA NA NA

GD-27126 Unknown UnkopwD NmM. . -M NA NA NA NA* GD-27 2 2- Unknown Unknown 6.25 ND ND ND NA NA

GD-27128 Unknown Unrinw 4 NM JA .NA NA NAGD-2750 2785 101.70 1823 ND ND ND NA 8347OD-27tS2 Unknown UnJE* I ijla47 D 1 _..: NA

* GD-2715 Unknown Unknown 1775 ND ND ND NA NA

Total Average Hvdrocarbon Thickness (fcc) 0 Wi, 0 W, inches

Comniments

N - Not Applicable Well on General Dynanic propeny included in hydrocarbon averagc ( gaugedND None Detected + Wcll in "Bents Creek" area included in hydrocarbon average if gaugedNM = Nol Monitored

TOC Top of Casing"Average" based on those wells gauged and included on this Form where oil has been detected and/or is within the ( YOP

GA 1930 zgyI1930 52 tivrlTatles\GD - GZA Gauging Data PosiShOTdown (Monanng 11.-01]

WEL L MONIIORING FORM

W I-II T '

W i I H \ 'Ite-t) ( fe

WIlI IR l IIIcROCANPHI1)'(fe t c lIe)

'rolet Name rnridal PyTumuni

Pmjiei Niniber I 191) X2

S iilii J I t i her

Daue i W, 09001Weat dher V Slun1 4'1

IM 'M I Di (I ) I I i

JIYDR1) ARBON ',IIF(H( Il I/ l(I I R1k

lil( KNISS XI % lIY III N

fee) (iches) (teet)

\tW- I 23.73 96.29 13.62 ND1u-2 17 902 NM \M

MW-3C 12.54 90.26 8,07 ND\iu I l'kn (se kimwn I NM N\lMW-> 22.65 100.26 17.56 17.55\ln ' '#7 (.2) N I

-' Uiknoiwn Unknown 17,60 ND'e -. 9 h o NM\ N\i

"I\k. 19,40 94.54 NM NMl\ I li knm I'TkiOi NM NM

MW- 17.55 95.13 1 .75 ND.X\' Is 5 04.32 1| 29 N )

MW-13 Unknown Unknown NM NM

M -14A 20 4.) 92 54 9 1'1 9 10

MW-ISS 18.94 90.63 NM NMMW -1c 14 .u 91 4h 9 75 NDMW-I? 27.73 100.80 17.60 ND

I\\ I1 2647 l0089 '.80 17 7>

RW-IA 35.25 97.32 14.66 14.65kr ' 20.00 961" 1 19 13 lI

RW-3A 36.90 100.50 17.75 17,73S .1 2S 4') 9?8 2 1. 8O ND

RW-5A 36.70 95.92 13.65 13.63\\ '1c 13 (i 9t 4c 1I 77 17 74

RW-6 34.55 96.38 13.67 13.66N\\ \ 27 S0 9692 14.02 ND

RW-8 28.60 95.96 14.35 NDR\ Wi 27.38 98.20 17 25 N )

RW-10 20.58 98.60 17.89 NDR\\ I [ 29.3 98.83 18 10 NDRW-12 22,05 99.93 18.34 NDGD 1 10 Unknown Unknown NM NMGD-I 154 Unknown Unkndwn NM NMGD-2128 18 2 5 9040 747 745

GD-2129A 30.40 100.40 17.4 ND(D-21 1 Unknown Unknown NM NMGD-2152 Unknown Uninown N0 NMGlD-21i 2434 9971 1694 1693

GD-2157 13.44 /99.31 ..; 10.55. . ND.G1) 21 ?r 18 56 99.18 1664 ND

GD-2j59 . 23.12 ;0929 .(7 ND,GD-2268A 26.90 100.84 1762 17.61

O41%IL Uknowa$gm S4W . -KNMo-GD-2270 Unknown Unknown NM NMGD2S9O UnhjiliaJM En 241W NMGD-2391 Unknown Unknown NM NMGD.232 16,32 90751 '492 NDGD-2393A 15.29 89.50 7.45 ND

GD-2394 Unknown Unknown M NMGD-2395A 20 05 9067 760 ND

GD-2396 Unknown Unknown , , NM NMGD-2397 [Jnkncwn Unknown NM NMGD-27126 Unknown . Unknown N4 NMGD-2712 Unknown Unknown NM NM

0D-27128 Unknown . , . b . .MGD-27150 27.85 101.70 18.34 NDGD-27012; - lnuir ' .p i 5M'GD-27155i Unknown Unknown NM NM

ND ND NA 8267N\ NA N\ NAND ND NA 82.19Nl NA N. NA

0.01 0.12 (1,85 82.71Nit NID NAx1NI) ND NA NANA NA N\ N:NA NA NA NANA NA NA NAND ND NA 83.38ND ND NA 83 01NA NA NA NA

0 01 0 12 0 S5 83 44

NA NA NA NA

ND ND NA R1I 7)

ND ND NA 83,20

0.01 0.12 it) s3 I o

0.01 0.12 0,85 82.67G01 0 12 118> 82'97

0.02 0.24 0,85 82.77NI) ND NA '1 4,

0.02 0.24 0.85 82.290 03 036 C S5 8(0 7?

0.01 0.12 0.85 82.71ND ND NA 8290

ND ND NA 8L61

ND ND NA 80.9s

ND ND NA 80.71ND ND NA 80 73

ND ND NA 81.59NA NA NA NANA NA NA NA002 024 0185 8295

ND ND NA 82.76NA NA NA NANA NA NA NA001 012 085 8278

ND ND NA . 88.76ND ND NA 82.54

ND ' ND NA 83.000,01 0.12 0.85 83.23

NA .4WA NA . NANA NA NA NA

xNA NA NA iANA NA NA NA

ND ND NA 82.59ND ND NA 82,05

NA NA NA NAND ND NA 83 07NA NA NA NANA NA NA NA

'NA NA NA NANA NA NA NA

,NA NA. :,WA --- AND ND NA 83.36

: 4,lKKMSKYS ' .$MANA NA NA NA

Total Averaec Hvdrocarbon Thickness (feet 0 005 I 0 6 mches |

Comments

NA - Not AppicableND = None DetectedNM - Not Monitored

* - Well on General Dynamic property included in hydrocarbrnii average if gauged+ - Well in "Bents Creek" area included in hydrocarbon average if gauged

lOC Top of Casing"Average" based on those wells gauged and included on this Foirm where 0il ha been deiected and/or is within the NYOPi

Gl 1930 zgtu 1930-82 ov'Tables'GD -G2A Gauoog Data - Pour Shuldown (Momiong 11-09011

WElL MONITORING FORM

5 1-II

WEi I I ap Ill:7[l)1 fecii

'loyec i Name Gineral Dyimits

Piioei Number I1 J')41 2

1 nle i UINer

Weiaihe I I I 'lud h iC

A' MH i iNliXDl) 0IR ( I11 1)

W Pt IM 'Il I DI P~i j o HlfDR0(M ARi )\ Sill 111( PI11/1IN 1 RI, k

EI V WA IITR I IR0((ARI A I I( KNI: (,RA\ iY 1 Il)(fe) (lcI rt) (mnches)

MW1- 23.73 96.29 13.67 ND

MN -' 17.9% 90.02 NM NM

MW-3C 12.54 90.26 8.05 ND\ - Inknown ('rknowi NIM NM

M.- 22,65 100,26 17.43 17.425m 'A 26A 1 99.97 16 35 ND

I W-7 Unknown Unknown 17.32 Ni)

\11 26 MX 96.00 NM NMMW 9 19,40 94,54 1141 NI)'1' I inkin wn 1 inkown NM NM

MWA.-I 1 L7.55 95.13 12.36 ND11\\ 1' I )D 7 94 32 1 05 it b44

MW-13 Unknown Unknown NM NMMW -IA 20.41 92.54 991 Ni)

MW-15S 18.94 90.63 NM NMMW -16 14.3, 91 4t x 90 8 h9

MW-I 7 27.73 100.80 17.34 ND\M1 I 2S4' 10089 17 5 1 7. t

RW-1A 35.25 97.32 14.34 14.33

k% 2 29.00 9(1.1 13 26 NI)

RW-3A 36.90 100.50 17.52 17.50ISO 4 28.40 9825 1,63 NI)

RW-5A 36.70 95.92 13.15 13.14R A 33.(H '4846 [- 6R 1762

RW-t 34.55 96.38 13.33 13.321- 27.5o 96 9 9 13 73 NI)

RW-8 28.60 95.96 14,08 NDI? % 2 7.3S 98.20 17.05 NI)

RW-IO 20.58 98.60 17,80 NDMW 11 29.3S 9883 1792 Nit

RW-12 22.05 99.93 18.13 NDGD-1 110 Unknown Unknown NM NMGD-1 154 Unknown Unknown NM NMGD-2128 18.25 90.40 7.88 ND

GD-2129A - 3.40 100.40 17.10 NDGD-2131 Unknown Unknown NM NM

GD-2132 Unlikown Unknown NM . MMGID-21 24.34 99.71 16 71 ND

GD-2157 3344 '9921 . 1023 ND3D-21N8 18.56 99.18 1635 ND

Gl2159 . 3.12 100.0 37ND

GD-2264\ 26.90 10084 1750 17-41

GD-220A Unknown Unlnowy 2 fl* "ZGD-2270 Unknown Unknown NM NMGD-290A. Udkoown' tlnknoln . . i NMGD-2391 Unknown Unknown NM NM

GD23.92 .16,32 90.51 r " : MGD-2393A 1529 89.50 79 75R

GD-2394 Unknown Unknown 'NM NMGD-2395A 2005 90.67 NM NM

GD-2396 Unkiown Unknown NM. NMGD-2397 Unknown Unknown NM NM

ID-27126 Unkown Unknown INM NMGID-2712-' Unknown Unknown NM NMGD47.128 jJJnknown Unlinfrn "NM NMGD-27150 27.85 101 70 18 10 ND

GD127152 Linknown Unk4w . hmMGD-271 Unknown Unknown 17.42 ND

ND ND NA 8262NA NA NA NA

ND ND NA 82.21N A NA N A N A

0.005 0.06 085 82.83NI) Nil '\ 'i-i

ND ND NA NANA NA NA NA

ND ND NA H3.11NA NA Nx NAND ND NA 82.7700) 0 01)6 , M. :7

NA NA NA NA

N) ND NA 2 6)NA NA NA NA00i 0 12 05 2S I/ND ND NA 83.460 19 228 0 83 2o

0.01 0.12 0.85 82,99NI) ND NA M2 K-

0.02 0.24 0.85 83.00NI) ND NA X1 61

0.01 0.12 0.85 82.780D6 0.72 n)85 MI) I

0.01 0.12 0.85 83.05NI) ND NA AI 19

ND ND NA 81.88NI) ND NA 61 i5ND ND NA 80.80ND ND NA 8091ND . ,ND NA 81.80NA NA NA NANA "iNA NA 'NA'ND ND NA 82.52N 4A 83J0NA NA NA NA

; A ; . .ND ND NA 83.00

-R A 48ASND ND NA 82.83

0.09 1.08 0.85 83.42

- ~ twb A:"AiNA NA NA NA

ANA 'T NA :NANA NA NA NANA . -1 NA NA

001 0.12 065 8192'NA "NA NA NANA NA NA NA

NA -4 NA NANA NA NA NANA -.?MA-NA NANA NA NA NA

. $N . MilWA.-: AND ND NA 83 60

ND ND NA NATotal Average 11dirocarbon Thickness (fee) 01013 | 15 inches |

Comments:

NA = Not Applicable * Well on General Dynaniic properly included in hydrocarbon acrage if gaugedND - None Detected + Well in "Bents Creek" area included in hydrocarbon average if gaugedNM = Not Monitored

TOC - Top of Casing"Average" based on hose wells gauged and included on this Fomi where oil has been detected and/or is witin dir CYOP

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

Ice)I1 4I feet (left) (Inuile')(feet)(feez) o'cet) (fect)

0

WELL MONTORING FORM

0PjecIt Namic icneral lnaunis

Project Numhci I L)) J(1

[l cani Qun , ,lMs%^ helsi,

Saile. I teliciDat 0 l 0 ?];0(1

Weathie1 laith' ( ohd. 4r'

A.S.l31- 1) ( ()RRH I ll)

H I0(' DHl'IH 1,1 DI11P11 to H)YDROCARk) t P].IR P 1K( MII

ifIe)

MW-I 2373 96.29 13.05\n -2 17)6 9002 NN1MW-3C 12 54 90.26 7.45

I%\ I ljokowr I Iknain NMM" 22.65 100.26 16.70

264 )9t7 Isif

Unknown Unknown 16.642o 68 9? 00 NM

\NW 19.40 94.54 1086i 1 I ist I /nknown N M

M1 I 17.55 95.13 11 l741/ _ I5S 9432 100 1

MW-13 Unknown Unknown NMMIW- 14A 2o) 40 92 54 9 35MW-15S 18,94 90.63 NMM16 1 14 36 91 46 9 20MW-17 27.73 100.80 16.78\IS ]. 2141 I10 ( 9 17 14

RW-IA 35.25 97.32 13.87P % 29.00 9615 [2 70RW-3A 36.90 10050 17.00IN\\ . 1 41 '98 2S 16 (IS

kW-SA 36.70 95.92 13.03u Nil 33 111 9946 11996

RW-6 34.55 96,38 16.36INN -\ 27.50 96.92 1;20RW-8 28.60 95.96 13.54RN1 ) 27.38 98211 1650RW-10 20.58 98.60 17.03

W -r] 293> 983 1717RW-12 22.05 99.93 17.43G1 D-1110 Unknown Unknown NMGD-1154 Unknown Unknown NM0-2128 18.25 90.40 6.87

GD-2129A 30.40 100.40 16.51GD-2133 Unknown Unknown NMGD-2152 Unknown Unknown NM(Id) 24.34 99.71 16.57GD-2157 13.44 99.31 9.98iD-2158 8 56 99.18 1583GD-2159 .3.12a 400.0 l3(iD-2268\ 26.90 100.84 16.83GD2269A .: Unioan 'TIdi i-NMGD-2270 Unknown Unknown NMGD-2390A- tUXknbwn 6n ; N JMGD-2391 Unknown Unknown NMGD-2392 . 10 2.? .90.51' ',740GD-2393A 1529 89,50 NMGD-2394 Unknown Uinown NM(i)-2395A 20 05 90,67 7.09GD-2396 .Unknown Unkmown -NM-GD-2397 Unknown Unknown NM

0.A IFR IIYDRi(AkON(feet)

NDNMND

NM

16.69NDNDNMNDNMNDND)NMNI)NM

ND17 0o)

13.86NI)

16,97NI)

13021092

16.35NDNDNI)NDNDNDNMNMND

NDNMNM

1656NDND

I IC11 KNISS(fect) Itcnlic )ND NDNA NA

ND NDNA NA0.01 0 12NI) N

ND NDNA NAND NDNA NAND NDNI) NI)

NA NAND NI)NA NAND NI)ND ND0 58 C%0,01 0.12ND) NI)

0.03 0.36ND NI)

0.01 0. 120104 04S

0.01 012ND NI)ND NDND NI)

ND, NDN) NI)

ND 'NDNA NA

NA NAND NI)ND NDNA NA

;NA 'NA001 0.12ND *NDND NI)

~D~ t 7 AID tCNP,16.81 0.02 0.24$M, '-NA !A.

NM NA NANM NA 5.SMANM NA NAND ND ID $NM NA NA

m NA .NANID ND ND

M NA <oNANM NA NA

G-27126 Uukwn MSIR1n tMAt M -NA$1AAI)D-2' I- Unknown Unknown NM NM NA NA

GD-27128 .Undkisp 3iS0 IM& , 4AMA A-GD-27150 27.85 101.70 1747 ND ND NDGD-22152C.MUi&i Lab;. -i! 4

(ikAVI 11Y 11 AD(fce0

NANANANA

0.85N ANANANANANANANANA

NANANA

0.85NA

0.85NA0.85

0.85NANANA

NANA

NANANANANANANA0.85NANA

NA085NANA

NANANANA

NANANANANANA

NA

GID-2755 Unknown Unknown 1696 ND ND ND NA

83.24NA

821NA

8357A40

NANA

83.6sNA

83.398$ 5

NA83 1)NA

83 21

84,02$3 '7483.46X345

83.53A2 17

82.90SI 5

80.02837282.42

l 70

81.5781 6682.50

NA

NA83 5383.89

NA

NA83.1589.3383.35

.83.6784 03'NA

NA

NANA

83.11NANA

83 58NANA

NANA

.. A84 23

NATotal Average Hydrocarbon Thickness (feet) 002 0 2: inches

CommentsNA - Nol Applicable * Well on General Dyanbc property included in hydrocarbon ascrage I gaugedNJ) None Detected + Well in "Bents Creek" area included in hydrocarbon average if gaugedNM = Noi MonitoredTOC =Top of Casing"Average" based on those wells gauged and included on this Formi where oil has been detected and/or is within the CYOP

G 5 '930 zgA) 1930-82 bvti\Tables\GD GZA Gaugong DaLa .l'ost Shutdow [Monxtonng 0)-10-021

WWYl- I rD DIe

(fePI'l

et)

I-.I .V(I Lcc )

'

'

*

+

+

+

+

+

+

+

+

+

'

WVELL MONITORING FORM

Wl !1, To( D]I-PT 1,

3H I IID DEI'I I FlI A I I(Ieei (feel) (feel)

MW.I 23.73

MW-3C 12.54i . I I 1k1 n 1

MW 22.65\ 2604

Unknown

\ - 19.40

M W 1 17.55\u 1 15.7MW-13 UnknownMW 14AA 204(MW-15S 18.94MW- 14 31MW-] 7 27.73M\\- I n 28.47

RW-IA 35.2511w 2 29 00RW-3A 36.9044\ 4 28 40

RW-SA 36.70R%% \\ 33.04)RW-6 34.55R\4 - 3 27.50RW-S 28.60R\\ 0 27.38RW-10 20.58RW . II 29.35RW42 22.05GD- 110 UnknownGD-l154 UhinownGD-2128 18.25OEI:9A ,.'40

GD-2133 UnknownrD, 52 - Ab6dii(ii)-21-.o 2414

96.2990 02

90.26Unknow T

100.26999

Unknown960094.54

I nknown

95.1394,32

Unknown92 5490.6391.46100,80100.89973296 15100.5098.2595.9298 4696.3896.9295.9698,20

.98.6098 83

-993UnknownUuknowna

90.40

Unknown

99.71

12.786 847.02NIM

16.141 46

16.03N M

10.23NI11.099 88NM8 87NM7 9816.2116.7313.26120316,3815 5512.5116.3715.7412.3712.7915 9416.53166016.95NMNM6 79I5.88NM

1562

MEl 111 1,

IllY DRiAR)l

(feel)NDNDND'i Ni

16.135N )NDN NINDNM

ND9'. 5:

NMNDNMNI)ND16 1

13,24ND

16.37NI)

12.49NI)

15.71N I)NDNDNDNDNDNMNMNDNDNM1M515,60

GD-2lhS 1856 9918 15.24 ND

GD-228A 26.90 100.84 16.21 ND

GD-2270 Unknown Unknown NM NMOO A

GD-2391 Unknown Unknown NM NM

GD-2393A 15.29 89.50 5.88 NDGnI4 4id1ibwn2' 11 n .tai0D-239A 2005 9067 6.1 ND

Aw -NM,ljjabwu 2. ~.u.-4jN4

GD-2397 Unknown Unknown NM NM

06Y~o~i~,MQV"AAIW_%7.' X.ND-:W MV

GD1)-27127 Unknown Unknown NM NM

GD-27150 27.85 101.70 1701 ND

71 715$ Unknown- Us .~I3M?~

Ulnkntown 16.40

Project Namie General Dyiiarnn

Project Nuinber I 1910 521 mOnJKI Qumes. M.111,1huseCtt

Isxpr J Ilahel

Weather 1rily ( ludv. 40,

A. lsI 1II) ( )RRI ll1)I Yl)RO( ARII IN P:(l1 IP/I' OMII J(

1IlCKNl:SS (;RA\ 11Y I EAD

(feel) (iclie ) (CC) I

ND ND NAND ND NAND ND NANA N.1 NA

0.005 0,06 0.85ND NI) NA

ND ND NANA NA NA,ND ND NANA NA NA AND ND NA).01 0 12 4,05

NA NA NAND ND NANA NA NAND ND NAND ND NA0.17 2 04 0 )50.02 0.24 0.85ND NI) NA0,01 0.12 0,85ND NI) NA0.02 0.24 0.85ND ND NA

0.03 0.36 085ND ND NAND ND NANID ND NAND ND NAND ND NA

.-ND ND NANA NA NA

,NA NA NAND ND NA

-)-D ND NANA NA NA

-J4A "§NA -NA0.02 0.24 083

NDp YND AND ND NA

MAND ND NA

AA-lAA

NA NA NA.NA - NA 'NA

NA NA NAtTN 2XNeO -t2.NA

ND ND NANA )'NA NAND ND NA

IA ~&A NA NANA NA NA

NA NA NA

ND ND NA

ND ND ND NATotal Average Hydrocarbon Thickness (fect 0 01 I 0 09

NA /84.69

NAinches |

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

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

83.518 Is83.24

NA

84.1251 INAN A

84,31NA

84.0484 43NA

83b7NA

83 4K84,5984 it)

84.0884 1284.135227083.43K2 09)80.6684.3583.1782 2682.0782 2382.98NANA8361

84.52NANA84 .[89.183 94

820;.*84.63

NANANA

83.3583.62NA

83.86NANANANA

Unknown 1640 ND ND ND NA

S

WELL MONITORING FORM

W511.L (X DIIIil Dl.1111 io.

II10 DFI'III lLI.\~ s RI 1 Dki ARHiN

(feel) (fect deco (fect)

MW- 2173 96.29 12.40MW 2 17"6 9002 142MW-3C 12.54 90.26 8.71\M\ I Unknown Unknown NNIMW--' 22.65 100.26 15.83.. ' 6)h 9997 .5 190

Unknown Unknown 15.75\' ' 26(8 9600 NMMW-Q 19.40 94.54 10.04

\ I'' 1- Unknown Unknown NMNM -1) 17.55 95.13 10,8511W 1' 15.75 94 32 '177

MW-13 Unknown Unknown NMMW -14.A 20.40 92 54 S 61MW-15S 18.94 90.63 NMMW-lI, 1436 9146 '50

MW-17 27.73 100.80 15.97\l\\ 1I 28 47 100.89 I6 7

RW- IA 35.25 97.32 13,07/5 29.0' 96.I 1 1 II 7

RW-3A 36.90 100.50 16.16R ) 4 284C 98.25 1> 19

RW-5A 36.70 95.92 11.88'Wm 33.00 98.4), I, I6RW-6 34.55 96.38 15.50R,> \ 27 50 96 92 12 38

RW-8 28.60 95.96 12.54R W5 9 27.3 98.20 15.70RW-10 20.58 98.60 16.28R-ll 29.35 9883 16.40

RW-12 -,22.0$ 9$3 16.67GD l[10 Unknown Unknown NMGD-1154 UnkMown Unl&bu NMGD-2128 18.25 90.40 602GD2129A .3040 10 iGD-2133 Unknown Unknown NMGD-2152 1 Uiknown .unl : M6D-21%s 2434 9971 15 32GD-2157 13.44 - j99 3lI)-'I15 18.56 99.18 1496G3D-2159. .: 3 52. ik.'.(D-22.XA 26,90 100.84 1596

GD-2270 Unknown Unknown NMGD-2390A" D~lf' n kia M MGD-2391 Unknown Unknown NMGD-2392 .'tl&2 967GD-2393A 15.29 89.50 545GD-2394 Unknown _Unkliv - NM,GD-2395A 20.05 90.67 6.44GD2396 . -AUnkn n i UnWn NM.GD-2397 Unknown Unknown NMGD47126 Al~iw iki , - ,(iD-271I2 Unknown Unknown NMGD427128 .85 .GD-27150 27.85 101.70 16.74

0Potjeci Name (eCral

Dynamis

I'rojct| Ninnber I I 10 2[. catm Quinen %s hm)

.NAI 1 IltT J Hutcier

I Ist 031 (1 .2uii

Weair Nuim. 41)s

AH)) IMI I) ( ~RRl 1 )10

IIY R(X)AkRIIN NPEl. l( PII) I/IOMI IRI(

I IIkKNI \S , IRA\ tI) I Il-AD

I(fec 0 (im c s (feel) |

ND ND ND NAND ND ND NAND ND ND NANM NA NA NND ND ND NAND ND N NAND ND ND NANM NA NA NAND ND ND NANM NA NA NAND ND ND NA9 10 0 17 2 04 .1

NM NA NA NAN) ND ND NANM NA NA NAND ND ND NAND ND ND NA16 31 0.40 4.80 0 5 i13.06 0.01 0.12 0.85ND ND ND NA

16.16 0.00 0.06 0.8515 1 0 01 0.12 0 85

11.87 0.01 0,12 0.85ND ND ND NA

15.47 0.03 0.36 0.85ND ND ND NAND ND ND NAND ND ND NAND NflD. . ND NAND ND ND NA

'ND -- d.YA'";.tD :-NANM NA NA NANM . NAND ND ND NA

NM NA NA NA,NM kVf NNA-5.31 0,0 1.A 0.12 0.851ND rNAND ND ND NA

ND ND ND NA

NM NA NA NA

NM NA NA NA

ND ND ND NA,NM.N,2ND ND ND NA

NM NA NA NA

NM N A NA N A

ND ND ND NA

83.89HI)81.55

NA

84.43S4 7n

NANA84.50NA

84.28

94 60

NAX3 93

NA83 96

84.8384 5284.2684 40

84.3483 1; .84.05823080.9084 5483.4282.50

.82.3282.43

.. 9'26NA

NA84.38

NA

84 40e M94'+

84 22

84.88

NA

4ANA

13.84 A84,05

8423

NA eNA

NA

84,96

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

CommentsNA = Not Applicable * Well on General Dynanic property included in hydrocarbon average i gauged.ND = None Detected + - Well in "Rents Creek" area included in hydrocarbon average if gaugedNM Not MonitoredTOC= Top olCasing"Average" based on those wells gauged and included on ihis Form where oil has been detected and/or is within the C YOP

G 11930 zg19A30 82 bvtTables\GD - GZA Gaigng Data - Pos) Shuidawni [Mioon03-04-02

I

JANE SWIFTGovernor

AUG 2 8 2091

General Dynamics Corporation116 East Howard StreetQuincy, MA 02169

BOB DURANDSecretary

LAUREN LISSCommissioner

RE: Quincy97 East Howard StreetRTN 3-0536

Attention: Robert F. White

NOTICE OF AUDIT FINDINGSREMEDIAL SYSTEM COMPLIANCE INSPECTION

Dear Mr. White:

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

The inspection focused primarily on the remedial system discharges. This inspection does notpreclude future audits of past, current, or future response actions or activities at the site orinspections to confirm compliance with applicable requirements of other laws or regulationsenforced by the Department. The inspection involved:

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

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

This information is available in alternate format by calling our ADA Coordinator at (617) 574-6872.205A Lowell St. Wilmington, MA 0 1887 a Phone (978) 661-7600 * Fax (978) 661-7615 * TDD # (978) 661-7679

0 Pnnted on Recyced Paper

0 'D.-FILE COPYCOMMONWEALTH OF MASSACHUSETTS

EXECUTIVE OFFICE OF ENVIRONMENTAL AFFAIRS

DEPARTMENT OF ENVIRONMENTAL PROTECTION

Metropolitan Boston - Northeast Regional Office

INSPECTION FINDINGS

Intpyrinn of the groundwater treatment ytem

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

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

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

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

The biovent portion of the system was operational on the day of the inspection. The systemconsists of 10 extraction wells connected to a blower. The vapor collected from the wells is notconnected to off gas controls.

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

Effluent concentration: <1 ppmv

INSPECTION OUTCOME

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

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

Sincerely,

Wes PerryEnvironmental Analyst

Patricia DonahueChief, Audit SectionBureau of Waste Site Cleanup

cc: Data Entry/File PhaseV SNAUDI-07/26/01 AUDINS-NAFNVDOffice of the Mayor, 1305 Hancock Street, Quincy, MA 02169Quincy Health Department, 1585 Hancock St., Lower Level, Quincy, MA 02169

Attention: Director of Public HealthGZA, Inc., One Edgewater Drive, Norwood, MA 02062

Attention: Larry Feldman, LSP #8107

3

S1 SMassachusetts Department of Environmental Protection BWSC-102BBureau of Waste Site Cleanup

Release tracking NurnberRELEASE LOG FORM ATTACHMENT

E. LOGJRELEASE LOCATION INFORMATION: (cowle If using EVSC-1O2Bonly)

cityrrown: (mO: (run AM [] PM

-meew Ad- 1 srewaUse ofAtta t (dck one): mendment to Reles LUg Fon E Aahpt Pagos)

F. INSPECTIONS OR SITE ViSs (also Foow-up Ofice Response (check one)-

ita Cowplince Fli Repom.Announcd [ ls Conmpae nappw - Unaninounced

Comnihnce FWd ResponsM Annone [3 Compliane Fiel Wpqnq tnannounmed E Shut Notice Audit Inspection

- ield]Raeinse-DrcOweulght -- - Foo. pOrCn - Q Folloup OffeResponse

a ADDITIONAL DESCRIPTiON: -F

- .flU ..~.-L2'II

I , - . I

r1 m

PprRA e i Si gnurx:

H.DP SINMN*(crplt t sn *.VC-IMA and 102 ort~ BVSG.O 4

Prepaw~~~ of R-A(les )

Stafg Lead Assignied (if different frorn preparer):

SD chekM here ir the Releas or Threa of Release is unassignedB

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

Revised 11/22/99 Do Not Alter This Form Page 2 of 2

MASSACHUSETTS WATER RESOURCES AUTHORITY-r Charlestown Navy Yard

100 F irst AvenueBoston. Massa husetts 02 129

SA c H T elephon:q (6 1 7) 2 4 2 -6000Fasirnide: 617) 241 -6070

February 16, 2001

Ms. Sharon GobielMassachusetts Department of Environmental ProtectionBureau of Waste Site Cleanup205A Lowell StreetWilmington, MA 01887

RE: Tier II Extension SubmittalMWRA Fore River Staging AreaBuilding 9 Oil PlumeRelease Tracking Numbers 3-0536 and 3-10266

Dear Ms. Gobiel:

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

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

Sincerely,

Mark RadvilleProgram ManagerReal Property & Environmental Management Department

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

@ P r i i i It , I i ii I I ~I I I ',Ri- ( I'

cc: Leon Lataille. MWRARobert White, General Dynamics/American Overseas MarineS. David Graber, Consulting Engineer

ATTACHMENT

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

D. Tier II Extension Submittal Requirements

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

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

Following is information summarizing why a Permanent or Temporary Solution has notbeen achieved at the Building 9 Oil Plume Area:

The Building 9 Oil Plume Area is in Phase V (Operation, Maintenance, and/orMonitoring) of the Massachusetts Contingency Plan. Work already completed at the Sitehas included extensive subsurface investigations, completion feasibility studies, andremediation of the subject plume. A Permanent or Temporary Solution has not yet beenachieved at the Building 9 Oil Plume Area due to the continued presence of >0.5 inchesof free product in the subsurface. Oil recovery efforts were hampered during the year2000 due to a poorly functioning oil recovery well. To correct this, a Remedial MethodOptimization Evaluation was finalized in November 2000. Based on recommendationsmade in this evaluation, the grading of site paving around the recovery well wascorrected in November 2000 to prevent surface water runoff from entering the well andinterfering with the functioning of oil recovery equipment. The oil recovery equipmentalso underwent cleaning, maintenance, and testing.

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

* Skimming/Passive NAPL Removale Groundwater Depresssion and NAPL Recovery* Dual Phase Extraction* Bioslurping

It was detennined that due to the confined nature of the free product plume, technicalapproaches that would ordinarily be cost effective and significantly improve productrecovery are not applicable. The benefits of Groundwater Depression, Dual PhaseExtraction, and Bioslurping are negated when the free product is confined below thewater table as it is at the Building Oil Plume Area. Consequently, the recommendationwas made that the approach that remains cost effective and has the highest potential forsuccess remains skimming and passive recovery. This selected approach requiredrehabilitation of the existing recovery well and maintenance of the recovery systemequipment, which was completed in November 2000 as described above.

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

Prior Response Actions undertaken by MWRA are described in the Tier II ClassificationExtension submittals filed with DEP in February 1999 and February 2000. MWRA iscurrently in the process of reinitiating oil recovery operations after having implementedthe recommendations made in the November 2000 Remedial Method OptimizationEvaluation. Oil recovery and monitoring activities conducted in 2001 will bedocumented as required by 310 CMR 40.0892. A Response Action Outcome Statementfor the Building 9 Oil Plume Area will be submitted at the conclusion of remedialactivities.

F. Disposal Site Compliance History Summary

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

Program Description Permit # Permit Facility IDCategory

Air Quality Building 19 Boiler MBR-89-COM- BWP AQ 02 119 304113

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

Sludge Plant Odor MBR-89-INO- BWP AQ 02 119 304Control, Sludge 115AStorage Tanks, &Transport Barges

Storm Water EPA Multi-sector MAR05A676General StormWater Permit

Hazardous FRSA Sludge Plant MV6173762500 EPA Sludge PlantWaste (M.G.L Generatorc.2 1 C) ID#

Vehicle MAV000016820 EPA VehicleMaintenance Generator MaintenanceFacility ID#

0

South MaintenanceYard

Class A RecyclePermit (SludgePlant)

MAR000010793

.4 .4

Transmittal #122564, 11/20/97

0I

EPAGeneratorID#

VehicleMainter ance

BWPHW21

10

Massachu Department of Environmentalatection BWSC-107ABureau of l te Site Cleanup

TIER CLASSIFICATION, TIER II EXTENSION & Release Tracking NumberTIER 11 TRANSFER TRANSMITTAL FORM

I 3 - 536Pursuant to 310 CMR 40.0510 and 40,0560 (Subpart E)

A. DISPOSAL SITE LOCATION:

Disposal Site Name: MWRA Fore Rivei StagingArea

Street: 551 SouthStreet LocationAid: Formerly 97 East Howard Street

City/Town Quincy ZIPCode: 02169-0000

Related Release Tracking Numbers That This Submittal Will Address: 3-10266

B. THIS FORM IS BEING USED TO: (check all that apply)

Submit a new or revised Tier Classification Submittal for a Tier I Site, including a Numerical Ranking Scoresheet(complete Sections A, B, C. I, J, K and L).

I Submit a new or revised Tier Classification Submittal for a Tier Il Site, including a Numerical Ranking Scoresheet(complete Sections A, B, C, F, G, I, J, K and L).

Submit a Notice that an additional Release Tracking Number(s) is (are) being linked to this Tier Classified Site and rescoring is notrequired at this time (complete Sections A, B, J, K and L). If this submittal is for a Tier I Site, you must also submit a Minor PermitModification Transmittal Form (BWSC-109).

List Additional Release Tracking Number(s)

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

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

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

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

Submit a Tier |1 Transfer Submittal for a change in person(s) undertaking Response Actions at a Waiver Site, pursuant to310 CMR 40.0630(6) (complete Sections A, B, E, F, J, K, L, M, N and 0, and also complete Sections G and I or Section H).*

You must attach all supporting documentation required for each use of form indicated,including copies of any Legal Notices and Notices to Public Officials required by 310 CMR 40.1400.

"NOTE: The Waiver expires on the effective date of this submittal and all further Response Actions must be taken as a Tier il Site.

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

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

Groundwater is located within an interim Welihead Protection Area or a Zone 11, and there is evidence of groundwater contaminationby an Oil or Hazardous Material at the time of Tier Classification at concentrations equal to or exceeding the applicable RCGW-1Reportable Concentration set forth in 310 CMR 40.0360.

An Imminent Hazard is present at the time of Tier Classification.Check here if this Tier Classification revises a previous submittal for this Disposal Site. You must include a revised Numerical RankingScoresheel with this submittal. If a Tier I Permit has been issued, you may also need to submit a Major Permit Modification Application(BWSC 10).it incorporating additional Release(s) into the Disposal Site, list Release Tracking Number(s):

D. TIER 11 EXTENSION SUBMITTALREQUIREMENTS:Slate the expiration date of the Tier Il Classification or Waiver for the Disposal Site, whichever is applicable: 4/19/2001

Attach a statement summarizing why a Permanent or Temporary Solution has not been achieved at the Disposal Site.A Tier It Extension is effective for a period of one year beyond the current expiration date of the Tier 11 Classification or Waiver.

E. TIER || TRANSFER SUBMITTAL REQUIREMENTS:

State the proposed effective date of the change in person(s) undertaking Response Actions at the Disposal Site:

Attach a statement summarizing the reasons for the proposed change in person(s) undertaking the Response Actions.All Response Actions must be completed by the deadline applicable to the person who first filed either a Tier Classification Submittal for

the Disposal Site or received a Waiver of Approvals.

Revised 4/6/95 Supersedes Forms BWSC-010 (in part) and 014 Page 1 of 4Do Not Alter This Form

Massach tts Department of Environment rotection BWSC-107ABureau o ste Site Cleanup

TIER CLASSIFICATION, TIER 11 EXTENSION & Release Tracking NumberTIER || TRANSFER TRANSMITTAL FORMPursuant to 310 CMR 40.0510 and 40.0560 (Subpart E) 3 536

F. DISPOSAL SITE COMPLIANCE HISTORY SUMMARY:

> If providing either a Tier Classification Submittal for a Tier I Site or a Tier II Extension Submittal for a Waiver Site, the person named inSection J must provide a Compliance History.

> If providing a Tier |1 Extension Submittal for a Tier Il Site, the person named in Section J must update their Compliance History since theeffective date of the Tier || Classification.

> If providing a Tier Il Transfer Submittal for a Tier 1I or Waiver Site, the person named in Section M must provide a Compliance History

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

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

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

PROGRAM: PERMIT NUMBER: PERMIT CATEGORY: FACILITY ID.

Air Quality

Hazardous Waste (M.GL. c. 21C)

Solid Waste

Industrial Wastewater Management

Water Supply

Water Pollution Control/Surface Water

Water Pollution Control/Groundwater

Water Pollution Control/Sewer Connection

Welland & Waterways

List all other Federal, state or local permits, licenses, certifications, registrations, variances, or approvals that are relevant to this Disposal Site:

ISSUING AUTHORITY OR PROGRAM, OR DOCUMENTATION TYPE: IDENTIFICATION NUMBER: DATE ISSUED:

If needed, attach to this Transmittal Form a statement further describing the Compliance History of this Disposal Site. This statement mustdescribe the compliance history of the person named above with the following:

(1) OEP regulations, and(2) other laws for the protection of health, safety, public welfare and the environment administered or enforced by any other government

agency.

Such a stalement should identify information such as:

(1) actions relevant to the Disposal Site taken by the Department to enforce its requirements including, but not limited to, a Notice ofNoncompliance (NON), Notice of Intent to Assess Civil Administrative Penalty (PAN), Notice of Intent to Take Response Action (NORA),

andan administrative enforcement order:

(2) administrative consent orders:(3) judicial consent judgements;(4) similar administrative actions taken by other Federal, state or local agencies:(5) civil or criminal actions relevant to the Disposal Site brought on behalf of the DEP or other Federal, state, or local agencies; and(6) any additional relevant information.

For each action identified, provide the following information

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

Revised 4/6/95 Supersedes Forms BWSC-010 (in part) and 014 Page 2 of 4Do Not Alter This Form

, Massac h tts Department of Environmentn rotection BWSC-107ABureau o aste Site Cleanup

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

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

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

> If providing a Tier 11 Transfer Submittal, the person who signs this certification MUST be the person named in Section M. or that person's agent.

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

By: Title:(signature)

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

If you are submitting either a Tier I Extension Submittal for a Waiver Site or a Tier It Transfer Submittal for a Waiver Site,you may choose to sign the alternative Ability and Willingness Certification found in Section H

in place of providing the certification in Section G and the LSP Opinion in Section 1.H. ALTERNATIVE CERTIFICATION OF ABILITY AND WILLINGNESS:

> If providing a Tier 11 Extension Submittal for a Waiver Site, the person who signs this certification MUST be the person named in SectionJ, or that person's agent> If providing a Tier il Transfer Submittal for a Waiver Site, the person who signs this certification MUST be the person named in Section M.or

that person's agent.I attest under the pains and penalties of perjury that (i) I/the person(s) or entity(ies) on whose behalf this submittal is made has/have personallyexamined and am/is familiar with the requirements of M.G.L. c. 21E and 310 CMR 40.0000; (ii) based upon my inquiry of theConsultant-of-Record for the disposal site which is the subject of this Transmittal Form and of the person(s) or entity(ies) on whose behalf thissubmittal is made, and my/that person's(s') or entity's(ies') understanding as to the estimated costs of necessary response actions, that/thoseperson(s) or entity(ies) has/have the technical, financial and legal ability to proceed with response actions for such site in accordance withM.G.L. c. 21E, 310 CMR 40.0000 and other applicable requirements; and (iii) that I am fully authorized to make this attestation on behalf of theperson(s) or enfity(ies) legally responsible for this submittal, 'the person(s) or entity(ies) on whose behalf this submittal is made is aware of therequirements in 310 CMR 40.0172 for notifying the Department in the event that l/the person(s) or entity(ies) on whose behalf this submittal ismade learn(s) that it/they is/are unable to proceed with the necessary response actions.

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

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

I. LSP OPINION:

I attest under the pains and penalties of perjury that I have personally examined and am familiar with this transmittal form, including any and alldocuments accompanying this submittal. In my professional opinion and judgment based upon application of (i) the standard of care in 309 CMR4.02(1), (ii) the applicable provisions of 309 CMR 4.02(2) and (3), and (iii) the provisions of 309 CMR 4.03(5), to the best of my knowledge,information and belief.

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

> if Section 8 of this form indicates that a Phase I Completion Statement or a Tier I or Tier 11 Classification Submittal which does not relyupon a previously submitted Phase I Completion Statement is being submitted, the response action(s) that is (are) the sublect of this submittal(i) has (have) been developed and implemented in accordance with the applicable provisions of M.G.L. c. 21E and 310 CMR 40.0000, (11) is(are) appropriate and reasonable to accomplish the purposes of such response action(s) as set forth in the applicable provisions of M.G.L. c21E and 310 CMR 40.0000, and (iii) complies(y) with the identified provisions of all orders, permits. and approvals identified in this submittal;

SECTION I IS CONTINUED ON THE NEXT PAGE

Revised 4/6/95 Supersedes Forms BWSC-010 (in part) and 014 Page 3 of 4Do Not Alter This Form

Massac g tts Department of EnvironmenW rotection BWSC-107ABureau o aste Site Cleanup

TIER CLASSIFICATION, TIER 11 EXTENSION & Release Tracking NumberTIER 11 TRANSFER TRANSMITTAL FORM

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

1. LSP OPINION: (continued)

> if Section B of this form indicates that a Tier II Extension Submittaf or a Tier H Transfer Submittal is being submitted, the response action(s)that is (are) the subject of this submittal (i) is (are) being implemented in accordance with the applicable provisions of M.G.L. c. 21 E and 310 CMR40.0000, (ii) is (are) appropriate and reasonable to accomplish the purposes of such response action(s) as set forth in the applicable provisions ofM.GL. c 21E and 310 CMR 40.0000, and (iii) complies(y) with the identified provisions of all orders, permits, and approvals identified in thissubmittal.I am aware that significant penalties may result. including, but not limited to, possible fines and imprisonment. if l submit information which Iknow to be false. inaccurate or materially incomplete.

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

LSP LSP #: Stamp:Name:Telephone. Ext.:

FAX: (optional)

Signature.

Date:

J. PERSON MAKING SUBMITTAL: (For Transfer Submittals describe person currently undertaking response actions, not transferee)

NameofOrganization: Massachusett-s. Water Resources Authority

Name of Contact: Mark E . _Radville _ _ Title: Program Manager

Street: Charlestown_ Navy- Yard, 100 FirstAvenue _

City/Town: aston._ State: MA ._ ZIP Code: 02129- 0000

Telephone: 617-788:2759 _. Ext.: FAX:(optional) 617 -788-4898

K. RELATIONSHIP TO DISPOSAL SITE OF PERSON MAKING SUBMITTAL: (check one)

RP or PRP Specify: 4 Owner Operator : Generator Transporter Other RP orI- PRP:

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

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

Any Other Person Making Submittal Specify

L CERTIFICATION OF PERSON MAKING SUBMITTAL:

1 ___ Mark E-. Radville _._ , attest under the pains and penaities of perjury (i) that I have personally examined andam familiar with the information contained in this submittal, including any and all documents accompanying this transmittal form, (ii) that, based onmy inquiry of those individuals immediately responsible for obtaining the information, the material information contained in this submittal is, to thebest of my knowledge and belief, true, accurate and complete, and (iii) that I am fully authorized to make this attestation on behalf of the entitylegally responsible for this submittal. I/the person or entity on whose behalf this submittal is made am/is aware that there are significant penalties,including, but not limited to. possible fines and imprisonment, for willfully submitting false, inaccurate, or incomplete information.

By: -i___ Title: Program Manager(signature)

For Date: 2/16/2_001(print name of person or entity recorded in Section J)

Enter address of the person providing certification(s), including Ability and Willingness Certification where applicable, if different from addressrecorded in Section J:

Street:

City/Town: State: ZIP Code:

Teiephone: Ext FAX: (optional)

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

A REQUIRED DEADLINE, AND YOU MAY INCUR ADDITIONAL COMPLIANCE FEES.

Revised 416/95 Supersedes Forms BWSC-010 (in part) and 014 Page 4 of 4Do Not Alter This Form

0 & orporationi Hn iwr-ble flri

' ho kflme, t 011 0I I11ItTVl. ?~8.082. 08H

O 1. o .i/ J q

I-ebruary 14. 2001

Regional AdministratorMassachusetts Department of Environmental ProtectionBureau of Waste Site CleanupNortheast Regional Office205A Lowell Street

'ilmington,. MA 01887

Subject: LSP of Record TerminationDEP RTNs: 3-0536 and 3-19102Fore River Staging Area SiteQuincy, Massachusetts

Dear Sir or Madam:

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

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

If you have any questions, please call me.

Sincerely,

IT Corporation

Iric G Nelson. LSPBusiness Line Manager

'dI ' (c iialin %\k\ RA do,

the

MassacNsefts Department of Environmental Protection BWSC-108Bure,- of Waste Site Cleanup

COMPREHENSIVE RESPONSE ACTION TRANSMITTAL Release Tracking Number

FORM & PHASE I COMPLETION STATEMENT [ . O 36I Pursuant to 310 CMR 40 0484 (Subpart D) and 40.0800 (Subpart H)

-E LOCATION:oIte Name (optional) _Former General Dnamics/Quincy Shiovard (Central Yard Oil Plume)

Street 97 East Howard Street LocationAid: ouincy Shicvard

City/Town: Qui nc y ZIP Code 02169

Related Release Tracking Numbers that this Form Addresses:

Tier Classificaion: (check one of the following) 0 Tier JA ] Tier IB 7 Tier IC [b Tier II Not Tier ClassifiedIf a Tier I Permit has been issued, state the Permit Numoer:

B. THIS FORM IS BEING USED TO: (check all that apply)

[ Submit a Phase I Completion Statement, pursuant to 310 CMR 40.0484 (complete Sections A, B, C, G, H, I and J).

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

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

Submit a Phase IlIl Remedial Action Plan and Completion Statement, pursuant to 310 CMR 40.0862 i ,(comlete Sections A. B. C. G H I and J).

F] Submit a Phase IV Remedy Implementation Plan, pursuant to 310 CMR 40.0874 (complete Sections A. B. C. G, H, 1 and J).

F] Submit an As-Built Construction Report. pursuant to 310 CMR 40.0875 (complete Sections A, B. C. G, H. I and J).

E] Submit a Phase IV Final Inspection Report and Completion Statement, pursuant to 310 CMR 40.0878 and 40 0879(complete Sections A, B, C, E G, H, I and J).

Submit a periodic Phase V Inspection & Monitoring Report. pursuant to 310 CMR 40.0892 (complete Sections A B. C. G, H, I and J)

Submit a final Phase V Inspection & Monitoring Report and Completion Statement, pursuant to 310 CMR 40 0893(complete Sections A, B C, F, G, H, I and J),

You must attach all supporting documentation required for each use of form indicated, including copies ofany Legal Notices and Notices to Public Officials required by 310 CMR 40.1400.

C. RESPONSE ACTIONS:

F Check here if any response action(s) that serves as the basis for the Phase submittal(s) involves the use of Innovative Technologies (DEP isinterested in using this information to create an Innovative Technologies Clearinghouse.)

Descnbe Technologies.

D. PHASE |1 COMPLETION STATEMENT:

Specify the outcome of the Phase il Comprehensive Site Assessment

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

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

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

Rescoring of this Site using the Numerical Ranking System is necessary, based on the results of the final Phase I Report.

E. PHASE IV COMPLETION STATEMENT:

Specify the outcome of Phase IV activities

Phase V operation, maintenance or monitoring of the Comprehensive Response Action is necessary to achieve a Response Action Outcome(This site will be subject to a Phase V Operation, Maintenance and Monitoring Annual Compliance Fee.)

The requirements of a Class A Response Action Outcome have been met No additional operation, maintenance or nonitoring is necessary toensure the integrity of the Response Action Outcome. A completed Response Action Outcome Statement (BWSC-104) will be submitted toDEP.

The requirements of a Class C Response Action Outcome have been met. No additional operation, maintenance or monitoring is necessary toF] ensure the integrity of the Response Action Outcome. A completed Response Action Outcome Statement (BWSC-104) will be submitted to

DEP.SECTION E IS CONTINUED ON THE NEXT PAGE

Revised 3/30195 Sunorcnde Fnrms BWSC-010 tin ngrtt and 013 Paoe I o1 3

Do Not Alter This Form

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

COMPREHENSIVE RESPONSE ACTION TRANSMITTAL Release Tracking Number

i FORM & PHASE I COMPLETION STATEMENT -Pursuant to 310 CMR 40.0484 (Subpart D) and 40.0800 (Subpart H)

E. PHASE IV COMPLETION STATEMENT: (continued)

The requirements of a Class C Response Action Outcome have been met. Further operation. maintenance or rmonitonng of the remedial action isnecessary to ensure that conditions are maintained and that further progress is made toward a Permanent Solution. A completed ResponseAction Outcome Statement (BWSC-104) will be submitted to DEP

Indicate whether the operation and maintenance will be Active or Passive. (Active Operation and Maintenance is defined at 310 CMR 40.0006)

0 Active Operation and Maintenance O Passive Operation and Maintenance

(Active Operation and Maintenance makes the Site subject to a Post-RAO Class C Active Operation and Maintenance Annual Compliance Fee.)

F. PHASE V COMPLETION STATEMENT:Specify the outcome of Phase V activities:

The requirements of a Class A Response Action Outcome have been met and a completed Response Action Outcome Statement (BWSC-1104)will be submitted to DEP.

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

The requirements of a Class C Response Action Outcome have been met. Further operation, maintenance or rmonitonng of the remedial action isnecessary to ensure that conditions are maintained and that further progress is made toward a Permanent Solution A completed ResponseAction Outcome Statement (BWSC-104) will be submitted to DEP.

Indicate whether the operation and maintenance will be Active or Passive (Active Operation and Maintenance is defined at 310 CMR 40.0006

) Active Operation and Maintenance Q Passive Operation and Maintenance

(Active Operation and Maintenance makes the Site subject to a Post-RAO Class C Active Operation and Maintenance Annual Compliance Fee)

G. LSP OPINION:

I attest under the pains and penalties of perjury that I have personally exarrined and am familiar with the information contained in this transmittal form,including any and all documents accompanying this submittal. In my professional opinion and judgment based upon application of (i) the standard ofcare in 309 CMR 4.02(1), (ii) the applicable provisions of 309 CMR 4.02(2) and (3), and (iii) the provisions ot 309 CMR 4.03(5), to the best of myknowledge, information and belief,> if Section S indicates that a Phase I, Phase It, Phase Ill, Phase IV or Phase V Completion Statement is being submitted, the response action{ s)that is (are) the subject of this submittal (i) has (have) been developed and implemented in accordance with the applicable provisions of M G L c. 21 Eand 310 CMR 40.0000, (ii) is (are) appropriate and reasonable to accomplish the purposes of such response action(s) as set forth in the applicableprovisions of M.G L. c. 21 E and 310 CMR 40.0000, and (iii) complies(y) with the identified provisions of all orders, permits, and approvals identified inthis submittat> if Section S indicates that a Phase Il Scope of Work or a Phase IV Remedy Implementation Plan is being submtted, the response action(s)that is (are) the subject of this submittal (i) has (have) been developed in accordance with the applicable provisions of M G.L c. 21E and 310 CMR40 0000, (ii) is (are) appropriate and reasonable to accomplish the purposes of such response action(s) as set forth in the applicable provisions ofM G L c 21E and 310 CMR 40.0000, and (iii) complies(y) with the identified provisions of all orders, permits, and approvals identified in thissiihmittal-> if Secton 8 indicates that an As-Built Construction Report or a Phase V Inspection and Monitoring Report is being submitted. the responseaction(s) that is (are) the subject of this submittal (i) is (are) being implemented in accordance with the applicable provisions of M.G.L. c. 21 E and 310CMR 40.0000, (ii) is (are) appropriate and reasonable to accomplish the purposes of such response action(s) as set forth in the applicable provisionsof M.G L c. 21E and 310 CMR 40.0000, and (iii) complies(y) with the identified provisions of all orders, permits, and approvals identified in thissubmittal.I am aware that significant penalties may result, including, but not limited to, possible fines and imprisonment, if I submit information which I know tobe false, inaccurate or materially incomplete.

Check here if the Response Action(s) on which this opinion is based. if any, are (were) subject to any order sj m6(S) skid/or approval(s) issuedby DEP or EPA. If the box is checked, you MUST attach a statement identifying the applicable provisijrswereof.

LSPName Lawrence Feldman LSP#: -07

Telephone: 781-278-3807 Ext LStamp 4 -

FAX: (optional) N., -

Signature .J-A, L

Date: -

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

V0

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

COMPREHENSIVE RESPONSE ACTION TRANSMITTAL Release Tracking Number

FORM & PHASE I COMPLETION STATEMENT 7 _536Pursuant to 310 CMR 40.0484 (Subpart D) and 40.0800 (Subpart H)

H. PERSON UNDERTAKING RFSPONSE ACTIONISI

Name of Organization: General Dynamics Corporation

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

Street: 116 East Howard Street

City/Town: Quincy _State: ZIP Code 02169

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

[-] Check here if there has been a change in the person undertaking the Response Action.

I. RELATIONSHIP TO SITE OF PERSON UNDERTAKING RESPONSE ACTION(S): (check onel

RPorPRP Specify: Q owner Q Operator Q Generator Q Transporter Other RP or PRP: Prior Owner

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

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

[ Any Other Person Undertaking Response Action Specify Relationship:

J. CERTIFICATION OF PERSON UNDERTAKING RESPONSE ACTION(S):Danle 1 We1l ev attest under the pains and penalties of perjury (i) that I have personally exarrned and am

familiar with the information contained in this submittal, including any and all documents accompanying this transrnittal form, (ii) that based on my inquiryof those individuals immediately responsible for obtaining the information, the material information contained in this subrnittal is, to the best of myknowMledge and belief, true, accurate and complete, and (iii) that I am fully authorized to make this attestation on behalf of the entity legally responsible forthis subrnittal. I/the person or entity on whose behalf this subrrittal is made anis aware that there are significant penalties including, but not limited to,possible fines and imprisonment. for willfully submitting false, inaccurate, or incomplete information

By L.A

(signature) -

For- General Dynamics Corporation

Title-

Date(pnnt name of person or entity recorded in Section H)

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

Street:

City/Town: State: _ ZIP Code:

Telephone: Ext. _ FAX (optional)

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

A REQUIRED DEADLINE.

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

Page 3 of 3

FOLEY, HOAG & ELIOT LLP

ONE POST OFFICE SQUARE

BOSTON, MASSACHUSETTS 02109-2170

Laune Bur[ TELEPHONF 617-S32.1000 1747 PENNSYLVANIA AVE'., N\

617-S32-llli FACSIMILE 617-832-700C StI1TE I2A'

Ib-unirtr fte,com hnrp:/www fhe comI1t WASHINGTON, ID.C 200t,

Til 202-2231A

FAX. 202-785-6687

January 5, 2001

Ms. Sharon GobielDcpartment of Environmental ProtecticNortheast Regional Office205 Lowell StreetWilmington, MA 01887

Re: Quincy/Fore River ShipyardCentral Yard Oil PlumeDEP Site No. 3-0536Notification of Remedy Operating Status1-

Dear Ms. Gobiel:

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

Veryt yours,

Laurie Burt

Enclosurecc: See Attached Sheet

16/332472 I

Department of Environmental ProtectionJanuary 5, 2001Page 2

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

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

16/332472.1

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

COMPREHENSIVE RESPONSE ACTION TRANSMITTAL Release Tracking Number

FORM & PHASE I COMPLETION STATEMENT - 0s36Pursuant to 310 CMR 40.0484 (Subpart D) and 40.0800 (Subpart H)

A. SITE LOCATION:Site Name: (optional) MWRA - Fore River SLaging Area

Street: 551 SouLh St (ornerlv 97 E. Howard St) Location Aid:

CityrTown: Quincv ZIP Code: 02169-000

Related Release Tracking Numbers that this Form Addresses: 3-0536 and 3-10266

Tier Classification: (check one of the following) E Tier IA E Tier B H Tier IC Tier I Not Tier Classified

If a Tier I Permit has been issued state the Permit Number-

B. THIS FORM IS BEING USED TO: (check all that apply)

H Submit a Phase I Completion Statement, pursuant to 310 CMR 40.0484 (complete Sections A, B, C, G, H, I and J)

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

Submit a final Phase 11 Comprehensive Site Report and Completion Statement, pursuant to 310 CMR 40 0836(complete Sections A, B, C. D, G, H. I and J).

O Submit a Phase III Remedial Action Plan and Completion Statement, pursuant to 310 CMR 40.0862I'comolete Sections A. B, C. G. H. I and J1.

Submit a Phase IV Remedy Implementation Plan, pursuant to 310 CMR 40.0874 (complete Sections A, B, C. G, H, I and J).

Subrnit an As-Built Construction Report, pursuant to 310 CMR 40.0875 (complete Sections A. B, C, G, H, I and J).

Submit a Phase IV Final Inspection Report and Completion Statement, pursuant to 310 CMR 40.0878 and 40.0879(complete Sections A, B, C. E. G, H I and J).

Submit a periodic Phase V Inspection & Monitoring Report, pursuant to 310 CMR 40.0892 (complete Sections A B, C, G, H, I and J).

Subnit a final Phase V Inspection & Monitoring Report and Completion Statement, pursuant to 310 CMR 40.0893(complete Sections A, B, C, F, G, H. I and J)

You must attach all supporting documentation required for each use of form indicated, including copies ofany Legal Notices and Notices to Public Officials required by 310 CMR 40.1400.

C. RESPONSE ACTIONS:

Check here if any response action(s) that serves as the basis for the Phase submittal(s) involves the use of Innovative Technologies. (DEP isinterested in using this information to create an Innovative Technolooes Cleannohouse i

Describe Technologies:

D. PHASE || COMPLETION STATEMENT:Specify the outcome of the Phase il Comprehensive Site Assessment:

H Additional Comprehensive Response Actions are necessary at this Site based on the results of the Phase Il Comprehensive Site Assessment.

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

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

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

E. PHASE IV COMPLETION STATEMENT:

Specify the outcom of Phase IV activities: 20r7Phase V operation, maintenance or mrnoitoring of the Comprehensive Response Action is necessary to ac Response Action Outcome .)

(This site will be subject to a Phase V Operation, Maintenance and Monitonng Annual Compliance Fee.) DF h A$

H The requirements of a Class A Response Action Outcome have been met. No additional operation, maintanoe oW idF rt4 4 toensure the integrity of the Response Action Outcome. A completed Response Action Outcome Statement ( C~u4 WI1 -e 5uiMminuu LUDEP.

The requirements of a Class C Response Action Outcome have been met No additional operation, maintenance or monitonng is necessary toF ensure the integrity of the Response Action Outcome. A completed Response Action Outcome Statement (BWSC-104) will be subrnitted to

DEP.SECTION E IS CONTINUED ON THE NEXT PAGE

Revised 3/30195 Supersedes Forms BWSC-010 (in part) and 013Do Not Aller This Form

Page 1 of 3

Massachusetts Department of Environmental Protection BWSC-1 08Bureau of Waste Site Cleanup

COMPREHENSIVE RESPONSE ACTION TRANSMITTAL Release Tracking Number

FORM & PHASE I COMPLETION STATEMENTPursuant to 310 CMR 40.0484 (Subpart D) and 40.0800 (Subpart H)

H. PERSON UNDERTAKING RFSPONSF ACTION(SI:

NameofOrganization: Massachusttes Water Resources Authority

Name of Contact: Mark Radville Title: Proaram Manaer

Street: Charlestown Navv Yard, 100 First Avenue

City/Town: Bo s ton State: MA ZIP Code: 02129-000

Telephone: 617-788-2759 - Ext.: FAX (optional) 617-788-48 98

Check here if there has been a change in the person undertaking the Response Action.

I. RELATIONSHIP TO SITE OF PERSON UNDERTAKING RESPONSE ACTION(S): (check onel

RP or PRP Specify: i2 Owner Q Operator Q Generator Q Transporter Other RP or PRP:

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

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

Any Other Person Undertaking Response Action Specify Relationship:

J. CERTIFICATION OF PERSON UNDERTAKING RESPONSE ACTION(S):Ma-rk Pa dvi 1 1 e , attest under the pains and penalties of perjury (i) that I have personally examined and am

familiar with the information contained in this submittal, including any and all documents accompanying this transmittal form, (ii) that, based on my inquiryof those individuals immrnediately responsible for obtaining the information, the rnaterial information contained in this submittal is, to the best of myknowledge and belief, true, accurate and complete, and (iii) that ( am fully authorized to make this attestation on behalf of the entity legaly responsible forthis submittal, /the person or entity on whose behalf this submittal is made amlis aware that there are significant penalties, including, but not limited to.possible fines and imprisonment, for willfully submitting false, inaccurate. or incomplete information.

By: n-Title: Program Manager

(signature)

For: Massachusetts Water Resources Authority Date: I I - Z i ~ 0 _

(print name of person or entity recorded in Section H)

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

Street

City/Town: _ State: _ ZIP Code:

Telephone: Ext.: - FAX (optional)

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

A REQUIRED DEADLINE.

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

Massach tts Department of Environmen rotection BWSC-108Bureau of ste Site Cleanup W

COMPREHENSIVE RESPONSE ACTION TRANSMITTAL Release TrackingFORM & PHASE I COMPLETION STATEMENT Number

Pursuant to 310 CMR 40 0484 (Subpart D) and 40.0800 (Subpart H) 3 0536

E. PHASE IV COMPLETION STATEMENT: (continued)

The requirements of a Class C Response Action Outcome have been met Further operation. maintenance or monitoring of the remedialaction is necessary to ensure that conditions are maintained and that further progress is made toward a Permanent Solution A completedResponse Action Outcome Statement (BWSC-104) will be submitted to DEP.

Indicate whether the operation and maintenance will be Active or Passive. (Active Operation and Maintenance is defined at 310 CMR40.0006.):

Active Operation and Maintenance Passive Operation and Maintenance

(Active Operation and Maintenance makes the Site subject to a Post-RAO Class C Active Operation and Maintenance Annual Compliance Fee)

F. PHASE V COMPLETION STATEMENT:Specify the outcome of Phase V activities:

The requirements of a Class A Response Action Outcome have been met and a completed Response Action Outcome Statement(BWSC-1 04) will be submitted to DEPThe requirements of a Class C Response Action Outcome have been met. No additional operation. maintenance or monitoring is necessaryto ensure the integrity of the Response Action Outcome A completed Response Action Outcome Statement (BWSC-104) will be submittedto DEP

The requirements of a Class C Response Action Outcome have been met. Further operation, maintenance or monitoring of the remedialaction is necessary to ensure that conditions are maintained and that further progress is made toward a Permanent Solution A completedResponse Action Outcome Statement (BWSC-104) will be submitted to DEP

Indicate whether the operation and maintenance will be Active or Passive (Active Operation and Maintenance is defined at 310 CMR40 0006.):

Active Operation and Maintenance Passive Operation and Maintenance

(Active Operation and Maintenance makes the Site subject to a Post-RAO Class C Active Operation and Maintenance Annual Compliance

G. LtP8PINION:

I attest under the pains and penalties of perjury that I have personally examined and am familiar with the information contained in thistransmittal form, including any and all documents accompanying this submittal In my professional opinion and judgment based uponapplication of (i) the standard of care in 309 CMR 4 02(1), (ii) the applicable provisions of 309 CMR 4 02(2) and (3), and (iii) the provisions of309 CMR 4.03(5), to the best of my knowledge information and belief,

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

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

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

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

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

LSP Name: Eric G. Nelson LSP# 2516 Stamp

Telephone 781-245-6606 Ext : 5612 ER 1

FAX: 781-246-5060(optional)

Signature

Date: -

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

Sz7> <s, Edd7

se -u

-7/.yg ~ o

Massachusetts Department of Environmental Protection BWSC-102BBureau of Waste Site Cleanup

Release Tracking Number

RELEASE LOG FORM ATTACHMENT

E. LOG/RELEASE LOCATION INFORMATION: (complete if using BWSC-1028 only)

City/Town: C '. __ .. Date: - Time M PM

Release Address LUse of Atlachment (check one): ] Amendment to Release Log Form J Attachment Page(s): of:

F. INSPECTIONS OR SITE VISITS (also Follow-up Office Response): (check one)

I Initial Complianoe Field Response -Announced C Initial Compliance Field Response - Unannounced

[ Compliance Field Response -Announced [ Compliance Field Response - Unannounced Short Notice Audit Inspection

L Field Response - Direct Oversight C Follow-up or Other Field Response \4 Tollow-up Office Response

G. ADDITIONAL DESCRIPTION:

1/ A14- h/ /v

H. DEP ASSIGNMENT: (complete if using BWSC-102A and 1026 or BWSC-1028 only)

Preparer of RLFA (please print) . Signature

Staff Lead Assigned (if different from preparer):

- i Check here if the Release or Threat of Release is unassigned.

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

Revised 11/22/99 Do Not Alter This Form Page 2 of 2

FOLEY, HOAG & ELIOT LLPONE P3ST OF11-11 '1 SQU AR

BOSTON. MASSACHUSEIT'S 02109-2170

TELEPHONE 617-832-1000 1747 ITNNSYl.VANIA AVENULI. N W.

FACSIMILE 617-832-7000 [111 120)

Rndan E Kromm www.he com WASHINGTON, D.C. 20006

oli) 3:-1251 1l1i 202-223-1200

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

March 20, 2000

Mr. David BrownWatson Park Library85 Quincy AvenueBraintrec, MA 02184

Re: Documents to be Filed at Local Information RepositoriesQuincy ShipyardDFP Release Tracking Number 3-0536

Dear Mr. Brown:

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

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

Thank you for your assistance in making this information available.

Sincerely,

Randall E. Kromm

Enclosurescc: Sharon Gobiel, DEP

Robert F. White, GDC

0 0FOLEY, HOAG & ELIOT LLP

ONE IOST OFFICE SQU ARE

BOSTON, MASSACHUSETT S 02109-2170

TELEPI)NE 617-832-1000 1747 NNNSYLVANIA AViN U.N WFACSIMILE 617-832-7000 2ra 0K)

Rndal E Kroin www(Ihecon WASHINGTON, D.(. 20006

(tm 8 21251 ITE: 202 223 1200

rkrorn:, Ili nm FAX 202 785-6697

March 20, 2000

Ms. Judith PatTufts Library46 Broad StreetWeymouth, MA 02188

Re: Documents to be Filed at Local Information RcpositoricsQuincy ShipyardDEP Release Tracking Numbcr 3-0536

Dear Ms. Patt:

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

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

Thank you for your assistance in making this information available.

Sincerely,

Randall E. Kromm

Enclosurescc: Sharon Gobiel, DEP

Robert F. White, GDC

102945 1

FOLEY, HOAG & ELIOT LLPONE POST OFFICE SQUARE

BOSTON, MASSACHUSEFITS 02109-2170

TELEPHONE 6[7-632-1000 1747 PINNSYLVANIA AVINl , N W

FACSIMILE: 617-32.7000 S0111 1"A

lindall E. Krommn www jli.com WASHINGTON, ) C 20006

(0)2,332-1251 TEL: 202-2 3 210

rkromm 1weT e.coIm FAX: 202-785 6087

March 20, 2000

Ms. Linda BeelerThomas Crane Public Library40 Washington StreetQuincy, MA 02169

Re: Documents to be Filed at Local Information RepositoriesQuincy ShipyardDEP Release Tracking Number 3-0536

Dear Ms. Beeler:

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

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

Thank you for your assistance in making this information available.

Sincerely,

Randall E. Kromm

Enclosures

cc: Sharon Gobiel, DEPRobert F. White, GD

31) i I

FOLEY, HOAG & ELIOT LLPONE P0T OFFICE SQUARE

BOSI ON, MASSACHUSETTS 02109-2170

TELEPHONE 617-332-1000 1747 P[ENNVHL VANIA Ai I4I NAX

FACSIMILE 617-832-7000 SU IT- L

Laur Bun wwwfhe c[m WASHINGTON, D.C. 20006

ti7 82- 1ii1 TEL: 202-223-1200

lhun 11 th FAX. 202-7S5-6657

September 3, 1999

Waiver SubmittalsAttn: Sharon A. GobielMassachusetts Department of Environmental ProtectionBureau of Waste Site CleanupNortheast Regional Office205 Lowell StreetWilmington, MA 01887

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

Dear Ms. Gobiel:

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

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

Very truly yours,

Laurie Burt

f

Sharon A. GobielSeptember 3, 1999Page 2

cc: Robert F. White. General DynamicsLawrence Feldman, LSP, GZAMark Radville, MWRASteve Buttner, MHI

Harding Lawson Associates* . I-

April 1, 1999

Ms. Sharon GobielMassachusetts Department of Environmental ProtectionBureau of Waste Site Cleanup205A Lowell StreetWilmington, MA 01887

RE: Remediation System Modification PlanMWRA Fore River Staging Area, Building 9 Oil PlumeRelease Tracking Numbers 3-0536 and 3-10266

Dear Ms. Gobiel:

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

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

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

Sincerely,

HARDING L.AWSON ASSOCIATES

Herbert W. ColbySenior Project Manager

Attachment

cc: M. Radville - MWRAE. Nelson, LSP - HLA

C*

MASSACHUSETTS WATER RESOURCES AUTHORITY

MODIFICATION NO. I TO TASK ORDER NO. I

REMEDIATION SYSTEM MODIFICATION PLAN FOR THEBUILDING 9 OIL PLUME INVESTIGATION

A. GENERAL APPROACH

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

* Install eight shallow monitoring wells with screens positioned to permit determination of free-product presence and thickness.

* One week after well installation and development, perform an initial baildown of free-productfrom all wells to reduce effects of boring advancement/well construction on free-productthickness. Monitor free-product recovery.

* Measure thickness of product in all relevant monitoring wells two weeks after the initialbaildown. Product will also be removed from the wells during this measuring event.

* Prepare well logs, a plan of monitoring well locations, and tabular summary of productthickness data for review by MWRA.

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

B. PROPOSED WELL LOCATIONS

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

Harding Lawson Associates

q:\w4statemwra\proposal\Iskprop\PTSK I AWP.doc 2341.01

C. WELL CONSTRUCTION METHODS

Soil Boring Installation

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

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

Monitoring Well Installation

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

Monitoring Well Development

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

Harding Lawson Associates

q:\w4sLale\mw ra\proposal\tskprop\PTSK! AWP.doc 23-11 012

0 0

technique. The purpose of development is to reduce the amount of fine-grained material entering thewell from the surrounding formation. Monitoring well development procedures and observationswill be documented in a field logbook. Water will be evacuated with a hand-operated inertial pumpwith tubing. No water or other liquids will be introduced into the well other than formation waterfrom that location. The development apparatus will be decontaminated prior to use in the nextmonitoring well. Groundwater purged during monitoring well development will be containerized in17H drums for disposal. HLA anticipates seven drums of groundwater will be generated anddisposed of as oily liquids (MAO 1).

D. FIELD TESTING

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

Groundwater Monitoring

Groundwater monitoring will begin with the least contaminated monitoring wells and end with themost contaminated monitoring wells. HLA will check each monitoring well for properidentification and location, open the road box cover, unlock the monitoring well and remove thecap. The well will immediately be scanned with a PID meter and the reading will be recorded onthe Field Data Record. The distance between the top of the monitoring well riser and the groundsurface will also be measured and recorded on the Field Data Record. Using an electronicoil/water interface probe, HLA will measure for the presence of free-product, the static waterlevel, and the depth of the monitoring well to the nearest 0.01 foot. Between each well monitoredthe interface probe will be rinsed with an alconox and potable water solution and then rinsed withDI water.

Baildown Testing

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

E. HEALTH AND SAFETY

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

Harding Lawson Associates

q;\w4statc\nwra\proposal\tskprop\PTSK AWP.doc 2341.013

F. PROPOSED DRILLING SUBCONTRACTOR

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

Harding Lawson Associates

q:\w4state\mwra\proposal\tskprop\PTSK I AWPdoc 2341.014

Harding Lawson AssocIates FIGURE 1PROPOSED MONITORING WELL LOCATIONSBUILDING 9 OIL PLUMEMWRA-FRSAQUINCY, MA

APPENDIX A

Site: Building 9 - Fore River Staging Area ContaStreet Address: Fore River Staging Area, Quincy, MAProposed Date(s) of Investigation: March 1999 Job NPrepared by: Scott Shelton Date:Approved by: Date:Proposed Activity(s): Well Installation/Field Testing/Contractor OversightKnown or Suspected Chemicals (include PELs): #2 Fuel Oil (none)

ct: Mark Mark Radville (617) 788-2759

umber: 2341.01February 23, 1999

HAZARD EVALUATION (Check all that apply):

Overall Hazard Estimation:

Major Exposure Route(s):

Contaminant Location(s):

Health Hazard(s):

Safety Hazard(s):

Serious Moderate LALow Unknown None

Dermal Inhalation Ingestion Puncture

Surface i Underground Soil Sediment WaterTank WOther (list):

Liquid Xi Solid Sludge Corrosive IgjgnitableVolatile |% Radioactive Reactive Unknown

Height Equipment Cold Stress Noise 7 EyeNear Water Confined Space Heat Stre Machinery BurnsLifting $j Slips/Falls Other (list): Slow moving tractor/trailers.

EQUIPMENT (check all that apply):

PPE Selected:

Monitoring Equipment:

Emergency Equipment:

Initial Level of P

Cartridge RespiratorEscape RespiratorSafety Boots/ShoesChemical Resistant BootsDisposable Boot CoversOther (list):

Combustible Gas/Oxygen MeterHydrogen Sulfide MeterRadiation Alert MeterDosimeter Badge

$ First Aid KitOther (list):

ersonal Protection: Modified D

CoverallsSafety GlassesFace Shield

1 Hard HatL- Ear Protection

Explosimeterr:Draeger Tubesr List:

[Other (list):

lFire Extinguisher

Glovesinner-outer

Tyveks

> regular-coated

|OVAPID

X] Eye Wash

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

q \w4tate\nwrn\proposaltvskprop\health xis 02341.0 1

DECONTAMINATION/DISPOSAL: All personnel and/or equipment leaving contaminated sites are subject todecontamination. Under no circumstances (except emergency evacuation) will personnel be allowed to leave the siteprior to decontamination. The decontamination procedures to be used at the site are as follows:

Tyvek and disposal items will be placed in garbage bags and properly disposed of.

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

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

EMERGENCY TELEPHONE NUMBERS:

Local Police Department (617) 479-1212 or 911Local Fire Department (617) 376-1010 or 911Local Rescue Service (617) 376-1341 or 911Primary Hospitat Quincy Hospital (617) 773-6100Health Resources - (800) 350-4511

- Pager (leave area code and telephone number) (800) 455-0964National Poison Control Center (800) 492-2414Chemical Manufacturing Association-Chemical Referral Center (800) 262-8200Health and Safety Manager: Cindy Sundquist (207) 775-5401 (w)

(207) 892-4402 (h)

AUTHORIZED PERSONNEL:

'+ Garth Hirsch*+ Herbert Colby

* Current First-aid Certification

+ Current CPR Certification

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

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

Name: Date:

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

:d(omoon ishmd

Veasjel

DiMoiIdnd

MIO oI

f MooniIl-an

ROUTES TO EMERGENCY MEDICAL FACILITIES

PRIMARY HOSPITAL:

Facility Name: Quincy HospitalAddress: 114 Whitwell StreetTelephone Number: (617) 773-6100

DIRECTIONS TO PRIMARY HOSPITAL (attach map):

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

q:\w4state\mrna\proposal\tskprop\health. xis 02141.0Ot

FOLEY, HOAG & ELIOT LLP

ONE POST OFFICE SQUARE

BOSTON, MASSACHUSETrS 02109-2170

TELEPHONE 617-832-1000 1747 PENNSYLVANIA AVINUE, N.W

FACSIMILE 617-832-7000 SUi 1200

Randall E. Kromm www.fhe.com WASHINGTON, D.C. 20006

(617) 832-1251 TEL: 202-223-1200

rkrormfehe.com FAX: 202-785-6687

February 24, 1999

Ms. Linda BeelerThomas Crane Public Library40 Washington StreetQuincy, MA 02169

Re: Documents to be Filed at Local Information RepositoriesQuincy ShipyardDEP Release Tracking Number 3-0536

Dear Ms. Beeler:

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

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

Thank you for your assistance in making this information available.

Sincerely,

Randall E. Kromm

Enclosurescc: Sharon Gobiel, DE 3

Robert F. White, GDCMark Radville, MWRA

302880.1

FOLEY, HOAG & ELIOT LLP

ONE POST OFFICE SQUARE

BOSTON, MASSACHUSETTS 02109-2170

TELEPHONE 617-832-1000 1747 PENNSYLVANIA AVENUE, N W

FACSIMILE 617-832-7000 SUITE [200

Randall P. Kromm www.the.com WASHINGTON, D.C. 20006

(617) 832-1251 TEL: 202-223-1200

rkmnm@rh.com FAX: 202-785-6687

February 24, 1999

Ms. Judith PattTufts Library46 Broad StreetWeymouth, MA 02188

Re: Documents to be Filed at Local Information RepositoriesQuincy ShipyardDEP Release Tracking Number 3-0536

Dear Ms. Patt:

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

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

Thank you for your assistance in making this information available.

Sincerely,

Randall E. Kromm

Enclosurescc: Sharon Gobiel, DEP

Robert F. White, GDCMark Radville, MWRA

302945.1

I

Geolnsirollllicnt11 Inc.November 1800File No 7-400 50

Gia\ ij k i ir i

I I L I IT -

\ s I

Ms. Sharon A GobielMassachusetts Department ofEnv ironmental ProtectionNortheast Reuional Office25 Lowell StreetWilmington, Massachusetts 01887

DEP Waiver Site I D. Number 309536 and 3-10266

Re. Waiver SubmittalCompletion and Startup ofGroundwater Extraction Well - RW-5BCentral Yard Oil PlumeQuincy Shipyard, Quincy, Massachusetts

Dear Ms. Gobiel:

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

BACKGROUND

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

INSTALLATION AND STARTUP OF RW-4A

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

Copyright © 1998 GZA GeoEnvironmental, Inc.

DPr NOV 2 6

\i~ s ili le lii .. I 'a l

Massachusetts Department of Environmental Protection November 1 3. 1998File No 7400 50 Page 2

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

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

Very truly yours.

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

Principar

-tawrence Feldman. LSPSenior Principal

Encl. - Figure

Boring Log

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

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ATTACHMENT 1

EXPLORATION LOCATION PLAN

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ATTACHMENT 2

BORING LOG

Drilling LogFUOR DAME TI Recovery Well

Project General Dynamics/urncyM Owner General Dynamics

Location Quincy, MA Proi. No. 102722

Surface Elev. Total Hole Depth 34 ft, Diameter /2 In.

Top of Casing Water Level Initial /8.0 ft. Static

Screen: Dia /0 in. Length 20.0 ft. T ype/Size Stainless Stee/O.035 in.

Casing: Dia /0 in. Length /4,0 ft. Type Stainless SteelFill Material Jessie Morrie #1 Rig/CoreDrill Co. American Drlling Method Hollow Stem Auger

Driller Kenny Bylund Log By W. Holt Date 7/22/98 Permit i NAChecked By J Mitchell License No.

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1/09/19% Itbicg-June.96 Paqe: of 2

RW-5B

1l/09/199611thiog-June.96 Page: ! of 2

Drilling LogFUOR DANIEL GTE9

Project General Dynamics/QuxncvMAI ti Quinctv MA

Recovery Well

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11/09/1998Blithlog--June,96 Page: 2 of 2

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April 28, 1998File No. 7400.50

Ms. Sharon A. GobielMassachusetts DEPNortheast Regional Office10 Commerce WayWoburn, Massachusetts 01801

Re: Waiver SubmittalScope of WorkRW-5A Shutdown TestQuincy ShipyardQuincy, MassachusettsRelease Tracking No. 3-0536 and No. 10266

Dear Ms. Gobiel:

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

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

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

Very Truly YoursI - i

INC.

c'

WV

Lawrence Feldman, LSPSenior Principal

AJR:rvh

Attachments: Scope of Work

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

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SPROPOSED PLAN FOR RW-SA SHUTDOWN TEST

BACKGROUND

cia\Massachusetts Heavy Industries (MIHI), the current owner of the Building II area, has advisedGeneral Dynamics that due to safety issues associated with the roof of Building i1, and plannedreconstruction of the entire roof of Building I I and renovation of the building interior for plannedreuse, it will be necessary to make modifications to existing recovery and monitoring wells inBuilding 11. Existing monitoring wells include MW-I and MW-8. Existing recovery wells inBuilding I I include RW-2 which is currently inactive, and RW-5A which is currently active. Basedon hydrogeologic testing in 1994, RW-2 was removed from active status (with DEP notification)since oil recovery from this well was minimal and it was no longer necessary to contain the plume.Results of pump tests in the CYOP performed by GZA in 1994 indicated that RW-5A wasnecessary to contain the eastern portion of the CYOP from migrating downgradient. Since thattime, apparent oil thicknesses measured in wells in this area have continued to decrease.

Because of planned roof reconstmuction and future use in Building 11, we understand that MH[ hasindicated that it will no longer be possible to maintain the existing well casings, associated productand groundwater discharge lines and electrical lines above floor level in Building II . The plannedmodifications to Building I I provides the opportunity to evaluate the current effectiveness ofRW-5A in containing the eastern portion of the CYOP and the recovery of oil in this area. Thisevaluation can be undertaken by performing a limited shutdown test of RW-5A Because RW-5A iscurrently an active part of the CYOP recovery system, the RW-5A shutdown test is proposed toevaluate the need to either leave RW-5A in place and modify existing piping, or move RW-5A to anew location outside Building 11, and cut RW-5A to floor level, remove associated piping and leavethe recovery well in place.

PURPOSE

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

Monitoring of the eastern portion of the CYOP in the area of RW-5A indicates the productthicknesses in monitoring wells have been below 2-inches for more than 6 months. Product recoveryfrom RW-5A has been asymptotic for at least six months and therefore General Dynamics hasachieved the objectives of Phase I in the eastern portion of the CYOP. GZA proposes performing ashutdown test in the vicinity of RW-5A to assess whether substantial quantities of SPH would bereleased with the groundwater depression system at RW-5A shutdown for the eastern portion of theCYOP. If results of the shutdown test indicate that SPH does not accumulate in monitoring wells atgreater than two inches in the eastern portion of the CYOP, it may be possible to meet therequirements of the DEP 1987 letter by terminating recovery of groundwater and product from RW-5A and installing an alternate recovery well (RW-5B) either to the north or south of Building I I andpiping and operating a groundwater depression pump in that well for at least one year. Alternatively,

if the shutdown test indicales RW-5A is still necessary, it will be necessary to repipe the dischargelines from RW-5A to allow use of Building I I by MHL.

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

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

* Assess the appropriate well configuration for capture of residual SPH in this portion of the01\X CYOP.SCOPE OF WORK

Performance of Shutdown Test

Upon authorization to proceed with this scope of work, GZA will coordinate with Fluor Daniel GTIto gauge groundwater elevations and apparent fuel oil thickness measurements in all normallymonitored wells. These measurements will serve as a pre-shutdown evaluation of groundwater flowand apparent oil thickness. It is anticipated that Fluor Daniel GTI will perform most groundwaterelevation and fuel oil thickness measurements. GZA will perform limited measurements, but overseeand coordinate the shutdown test. Due to the safety issues concerned with working in Building I1, itis anticipated that Flour Daniel GTI will make arrangements with MHI to ensure that adequateprotection of safety is provided. It is further anticipated that this shutdown test will not commenceuntil GT1 agrees that an adequate level of safety is provided.

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

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

On a weekly basis for three weeks, that is, three separate measurements after the pre-shutdownreadings, measurements of apparent fuel oil thickness and groundwater elevations will be taken in themonitoring and recovery wells in the RW-5A area. At the two week time, measurements ofgroundwater elevation and apparent fuel oil thickness will be made for all normally monitored wells.Based on previous hydraulic testing at the Site, it is anticipated that this should be sufficient time toallow hydraulic equilibration in this area. Measurable quantities of oil will be removed from wells inthe RW-5A area after the one week measurements. This will allow two weeks to ascertain if SPHwill accumulate in the monitoring wells. It is possible that because RW-5A has been pumping for solong that an area of increased permeability in the highly heterogeneous subsurface (fill,construction debris, etc.) around the well will allow minor, intermittent residual oil in the area tosettle around the recovery well upon shutdown.

During this period, the monitoring wells and recovery wells located within Building I 1 will bemodified as requested by MHI to permit open use of the main floor level of the facility.

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

Evaluation of Results

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

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

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

System Modifications

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

-s 0( I liii, 10k

April 28, 1998File No, 7400.50

- (C '-<K %

Ms. Sharon A, GobielMassachusetts DEPNortheast Regional Office10 Commerce WayWobum, Massachusetts 0 180 1

Re: Waiver SubmittalScope of WorkRW-5A Shutdown TestQuincy ShipyardQuincy, MassachusettsRelease Tracking No. 3-0536 and No. 10266

Dear Ms. Gobiel:

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

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

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

Very Truly Yours

GZA GEOENV MENTAL, INC.

ibert J. Ricciardelli, LSPt Principal

AJR:rvh

Attachments: Scope of Work

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

Lawrence Feldman, LSPSenior Principal

I . , 1

0'\Th Kv+ ',s.,

-1

. . 1

SPROPOSED PLAN FOR RW-5A SHUTDOWN TEST

BACKGROUND

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

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

PURPOSE

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

Monitoring of the eastern portion of the CYOP in the area of RW-5A indicates the productthicknesses in monitoring wells have been below 2-inches for more than 6 months. Product recoveryfrom RW-5A has been asymptotic for at least six months and therefore General Dynamics hasachieved the objectives of Phase I in the eastern portion of the CYOP. GZA proposes performing ashutdown test in the vicinity of RW-5A to assess whether substantial quantities of SPH would bereleased with the groundwater depression system at RW-5A shutdown for the eastern portion of theCYOP. If results of the shutdown test indicate that SPH does not accumulate in monitoring wells atgreater than two inches in the eastern portion of the CYOP, it may be possible to meet therequirements of the DEP 1987 letter by terminating recovery of groundwater and product from RW-5A and installing an alternate recovery well (RW-5B) either to the north or south of Building I I andpiping and operating a groundwater depression pump in that well for at least one year. Alternatively,

N

if the shutdown test indicates RW-5A is still necessary, it will be necessary to repipe the dischargelines from RW-5A to allow use of Building I by M HI.

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

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

" Assess the appropriate well configuration for capture of residual SPH in this portion of the0lx CYOP.SCOPE OF WORK

Performance of Shutdown Test

Upon authorization to proceed with this scope of work, GZA will coordinate with Fluor Daniel GTIto gauge groundwater elevations and apparent fuel oil thickness measurements in all normallymonitored wells. These measurements will serve as a pre-shutdown evaluation of groundwater flowand apparent oil thickness. It is anticipated that Fluor Daniel GTi will perform most groundwaterelevation and fuel oil thickness measurements. GZA will perform limited measurements, but overseeand coordinate the shutdown test. Due to the safety issues concerned with working in Building 1 1, itis anticipated that Flour Daniel GTI will make arrangements with MHl to ensure that adequateprotection of safety is provided. It is further anticipated that this shutdown test will not commenceuntil GT1 agrees that an adequate level of safety is provided.

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

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

On a weekly basis for three weeks, that is, three separate measurements after the pre-shutdownreadings, measurements of apparent fuel oil thickness and groundwater elevations will be taken in themonitoring and recovery wells in the RW-5A area. At the two week time, measurements ofgroundwater elevation and apparent fuel oil thickness will be made for all normally monitored wells.Based on previous hydraulic testing at the Site, it is anticipated that this should be sufficient time toallow hydraulic equilibration in this area. Measurable quantities of oil will be removed from wells inthe RW-5A area after the one week measurements. This will allow two weeks to ascertain if SPHwill accumulate in the monitoring wells. It is possible that because RW-5A has been pumping for solong that an area of increased permeability in the highly heterogeneous subsurface (fill,construction debris, etc.) around the well will allow minor, intermittent residual oil in the area tosettle around the recovery well upon shutdown.

During this period, the monitoring wells and recovery wells located within Building II will bemodified as requested by MHI to permit open use of the main floor level of the facility.

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

Evaluation of Results

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

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

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

System Modifications

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

0

FOvernriwtnte, k j..- -

State environmental agencysays yard free of toxic wasteBy Eric Niler .Deer Island sewage treatment plaiThe Patriot Ledger Under an agreement with t

M ~ki state, General Dynamics assumiQUINCY - State environmental responsibility for cleaning up

officials say the Fore River shipyard sps found by 1987, when thas been scrubbed of potentially,, MWRA bought the property. TIdangerous toxic materials and is WRA has been responsible f4ready for use as an industrial site. spills discovered since then. Mass

Massachusetts Heavy Industries, chusett Heavy Industries is respothe yard's new owner, has removed aible for any new discoveries of toxnearly all of the asbestos from the chemicals.dilapidated buildings and chemical ,h bgs environmental baiwaste in the ground has either been at the yard has been asbestos,removed or does not pose a serious a fibrous insulating and fir -proofbrisk to workers. material that was widely used

"There's nothing significant outthere right now," said Sharon Go- caiprsiadilmnt a eto 1wbiel, an environmental engineer for 3, and ilme ts oaersathe state Department of Environ-mental Protection, the agency over- Many of the former workersseeing the cleanup."The site is safe." ceived financial settlements fr

Officials found contamination asbestos manufacturers. Onethroughout much of the 180-acre site them. Robert Galotti of Quinwhen General Dynamics closed the received a $2.5 million jury awardshipyard in 1986. 1994. Two months later, he died fo

The Massachusetts Water Re- mesothelioma, a lung cancer tiedsources Authority took over part of asbestos exposure, Mid his lawythe yard to build a sludge-to-fertilizer James Ferraro of Miami*plant, and as a staging area for "He'd be excited that the yardworkers and construction equipment reopening'" Ferraro Mid. "But notbarges used in the construction of the ther was asbestos thret."

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* pCOMMONWEALTH OF MASSACHUSETTSEXECUTIVE OFFICE OF ENVIRONMENTAL AFFAIRSDEPARTMENT OF ENVIRONMENTAL PROTECTIONONE WINTER STREET, BOSTON MA 02108 (617)292-5500

ARGEO PAUL CELLUCCI TRUDY COXEGovernor Secretary

DAVID B. STRUHSConuissioner

December 5, 1997BY HAND DELIVERY

Donald S. BerryMcDermott, Will & Emery75 State StreetBoston, MA 02109-1807

Re: Cuincy Shipyard, Release Tracking Number 3-0536

Dear Don:

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

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

Sincerely,

Marga t R. StolfaAc:ing Deputy General Counsel

Attachmentscc: Betsy Harper, Assistant Attorney General (with original)

Leon Lataille, Environmental Manager, MWRA (with original)James Colman, Assistant Commissioner, DEP/WSC (with original)Laurel Mackay, Deputy Regional Director, DEP/NERO (with copy)

COMMONWEALTH OF MASSACHUSETTSEXECUTIVE OFFICE OF ENVIRONMENTAL AFFAIRSDEPARTMENT OF ENVIRONMENTAL PROTECTIONONE WINTER STREET. BOSTON MA 02108 (617)292-5500

ARGEO PAUL CELLUCCI TRUDY COXEGovernor Secreary

DAVID B. STRUHSCommissioner

COMMONWEALTH OF MASSACHUSETTSEXECUTIVE OFFICE OF ENVIRONMENTAL AFFAIRS

DEPARTMENT OF ENVIRONMENTAL PROTECTION ANDTHE OFFICE OF THE ATTORNEY GENERAL

IN THE MATTER OF:

MASSACHUSETTS HEAVYINDUSTRIES, INC.

SPECIALCOVENANT NOT TO SUEAGREEMENT

I. Parties

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

II. Authority

The Department, through its Bureau of Waste Site Cleanup (the"Bureau"), implements and enforces the Massachusetts Oil andHazardous Material Release Prevention and Response Act, MGL, c. 21E("Chapter 21E"), and regulations promulgated, inter alia, underthat statute and codified at 310 CMR 40.0000, known as theMassachusetts Contingency Plan (the "MCP") . The Commonwealth,acting by and through the Department and the Attorney General,enters into this Agreement pursuant to its authority under Chapter21E, § 3A(j) .

NOW, THEREFORE, in consideration of the mutual promises andagreements set forth in this Agreement, the Commonwealth, acting byand through the Department and the Attorney General, in reliance onMHI's representations described in this Agreement, and MHI agree asset forth below.

Special Covenant Not To Sue AgreementDecember 1, 1997Page 2

III. Definitions

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

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

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

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

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

F. "Department" or "DEP" shall mean the MassachusettsDepartment of Environmental Protection, and any successordepartments or agencies of the Commonwealth of Massachusetts, itsagents, servants, and employees.

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

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

I. "Oil or hazardous material" shall mean any oil orhazardous material as each of those terms is defined in Chapter21E, §2.

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

K, "Site" shall mean the former General Dynamics QuincyShipbuilding Facility, DEP Release Tracking Number 3-0536, subject

Special Covenant Not To Sue AgreementDecember 1, 1997Page 3

to the "waiver of approvals" granted by the Department in March1994 to General Dynamics and the Massachusetts Water ResourcesAuthority.

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

IV. Parties Bound

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

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

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

V. Scope of Agreement

This Agreement represents the entire understanding andagreement among the Parties with respect to the performance ofresponse actions at the property pursuant to Chapter 21E and theMCP.

VI. Statement of Facts and Law

Solely for the purpose of this Agreement, the Partiesstipulate to the statement of facts and law set forth below.

A. Summary of Law. This Agreement is entered into pursuantto and is governed by the "Massachusetts Oil and Hazardous MaterialRelease Prevention and Response Act, " M.G.L. c. 21E and theregulations promulgated thereunder as the Massachusetts ContingencyPlan (the "MCP") at 310 C.M.R. 40.0000 et. seg.

B. Summary of Facts.

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

2. On March 2, 1994 a waiver of approvals ("waiver") was grantedto MWRA and General Dynamics pursuant to 310 CMR 40.000.

Special Covenant Not To Sue AgreementDecember 1, 1997Page 4

3. MWRA is the current owner and operator of the Site, excludingthe portion of the Site identified herein as the Property, andGeneral Dynamics is the former owner and operator.

4. As of the Acquisition Date, MHI is the current owner of theportion of the Site identified herein as the Property.

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

6. Prior to the Acquisition Date, MHI has had no ownership of orcontrol over, and has not conducted any operations at, theSite.

VII. Response Action

A. Description of the Resronse Action. Pursuant to thewaiver issued under the 1988 Massachusetts Contingency Plan ("1988MCP") , other parties are performing response actions at the QuincyShipyard to comply with the requirements of MGL c. 21E and the 1988MCP. Massachusetts Heavy Industries (MHI) will conduct certainresponse actions as specified in this Agreement on the Property.All construction activities shall comply with the requirements asapplicable of the Notice of Land Use Stipulation recorded in theNorfolk Registry of Deeds a copy of which is attached hereto andincorporated herein as Exhibit B.

The additional response actions to be performed by MHI comprise:

1. Release Abatement Measure in coniunction withconstruction of an addition to Building 3/12 (and formertransformer cage). In conducting excavation of contaminated soilsor dewatering of contaminated groundwater at the Property, MHIshall comply with the provisions of 310 CMR 40.0440 through40.0447, regarding performance of a Release Abatement Measure("RAM") . Prior to completing the RAM Plan required by 310 CMR40.0444, MHI shall review and evaluate all relevant and reasonablyavailable data compiled for the Property and shall conductadditional soil and groundwater sampling and analysis needed toensure proper management of contaminated materials that areexcavated. The RAM Plan shall provide for the reuse of excavatedsoil on site, to the extent allowed by 310 CMR 40.0442 (2) (b) , andby redevelopment plans for the Property. The RAM Plan shall alsoinclude a plan for stockpiling, testing, and arranging for off-sitedisposal of soils which cannot be reused on site. MHI shallcomplete the work as set forth in the RAM Plan.

In conducting excavation of contaminated soils ordewatering of contaminated groundwater at the Property, MHI shall

Special Covenant Not To Sue AgreementDecember 1, 1997Page 5

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

Subsequent to filing a RAM Completion Report for anyexcavation or dewatering subject to the requirements set forthabove, MHI shall submit a Class A Response Action Outcome Statementfor the areas where the aforementioned excavation or dewatering hasbeen conducted, unless such Response Action Outcome Statementcannot be achieved based upon the work required pursuant to the RAMPlan, in which case MHI shall submit an LSP Opinion addressingwhether further response actions are needed in the areas where theaforementioned excavation or dewatering has been conducted.

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

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

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

VIII. Property Access

A. From the Acquisition Date forward, MHI shall provide tothe Department and/or to its employees, agents, consultants,contractors and authorized representatives, an irrevocable right ofaccess at all reasonable times to the Property, for all purposesauthorized by Chapter 21E and the MCP. MHI shall permit suchpersons to record all field activities on its Property by means ofphotographic or other recording equipment as the Department deemsappropriate. Notwithstanding any provision of this Agreement, theDepartment retains all of its authority and rights, includingenforcement authority related thereto, under Chapter 21E and theMCP.

B. Within 30 days after the effective date of thisAgreement, MHI shall record a certified copy of this Agreement withthe Norfolk County Registry of Deeds. MHI shall provide to theDepartment a copy of the recorded Agreement, evidencing recordingdata, once it is available. After this Agreement has beenrecorded, each deed, title, or other instrument conveying aninterest in the Property shall contain a notice stating that the

Special Covenant Not To Sue AgreementDecember 1, 1997Page 6

interest is conveyed subject to this Agreement. Any partyconveying such an interest shall provide a copy of each suchinstrument to the Department.

IX. Commonwealth's Covenant Not to Sue

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

1 . The Commonwealth's covenant not to sue, set forthbelow, shall be effective only upon the signature of the Agreementby the Commonwealth.

B. Commonwealth's Covenant Not to Sue

1. Pursuant to the terms and conditions of thisAgreement and Chapter 21E, §3A(j), the Commonwealth,acting by andthrough the Department and the Attorney General, except asspecifically provided in Section XIII (Commonwealth's andDepartment's Reservation of Rights) and otherwise subject to thelimitations set forth in this Agreement;

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

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

3. These covenants shall not apply to response actioncosts arising from any of the following:

a. releases or threats of release of oil orhazardous material at the Property occurring after the AcquisitionDate, exclusive of passive leaching from Existing Contamination;

b. any release or threat of release of oil orhazardous material which MHI, their employees, officers, directors,or tenants at the Property, or any other person to whom thebenefits of this covenant inure, causes or contributes to or causesto become worse than it otherwise would have been. The covenantshall be void only against those persons who cause or contribute toa release or threat of release or cause such to become worse thanit otherwise would have been; or

Special Covenant Not To Sue AgreementDecember 1, 1997Page 7

c. any release or threat of release of oil orhazardous material not expressly covered by paragraph B. 1,preceding.

4. Notwithstanding the foregoing, these covenants:

a. shall be void as to MHI if MHI fails toperform, or fund and cause to be performed, in accordance withapplicable requirements, any obligation of MHI contained in thisAgreement with respect to the Property;

b. shall be void as to any of the personsidentified in paragraphs B. 1. and B. 2. of this section, or anyother person to whose benefit these covenants inure, if suchperson:

i. fails to comply with the release andthreat of release notification requirements of Chapter 21E and theMCP with respect to the Property; or

ii. unreasonably denies DEP, its agents,contractors or authorized representatives, access to the Propertyto investigate, sample and inspect any records conditions,equipment, practice or equipment to ensure compliance with andfulfillment of the terms of the Agreement, Chapter 21E and the MCPor for purposes of conducting necessary response actions at theProperty; provided however, that the covenant shall be void onlyagainst those persons who unreasonably deny such access, andagainst any other person to whose benefit this covenant inuressubsequent to such denial.

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

6. MHI shall ensure that a copy of this Agreement isprovided to any current lessee or sublessee on the Property at theeffective date of this Agreement and shall ensure that anysubsequent leases, subleases, assignments or transfers of theProperty are consistent with this Agreement.

X. Commonwealth's and Department's Reservation of Rights

A. The Commonwealth and the Department reserve all claimsother than those released pursuant to the above covenants,including but not limited to claims based on the following:

Special Covenant Not To Sue AgreementDecember 1, 1997Page 8

1. failure by MHI to meet a requirement of thisAgreement;

2. conditions previously unknown or undetected by theDepartment or the Commonwealth, that are discovered at the Site, orinformation previously unknown to the Department or theCommonwealth that is received by the Department or the Commonwealthif the Department or the Commonwealth determines, based upon suchpreviously unknown conditions or new information, together with anyother relevant information, that the implementation of therequirements of this Agreement is no longer protective of thepublic health, safety, welfare or the environment;

3. liability for future disposal of oil or hazardousmaterial at the Site;

4. violation of Chapter 21E or any applicable law orregulation which occurs during or after implementation of theresponse action; and

5. criminal liability.

B. Nothing in this Agreement shall preclude the Department orCommonwealth from enforcing the provisions of this Agreement in anyadministrative or judicial process.

C. If MHI fails to satisfactorily perform or fund and causeto be performed any response action that it is obligated to performunder this Agreement, the Department reserves its right pursuant toChapter 21E and the MCP, in addition to any other remedies whichare available, to undertake such response actions as it reasonablydeems necessary at the Property, in its sole and reasonablediscretion. In such event, the Commonwealth and the Departmentexpressly reserve all legal and equitable rights to take any actionto recover from MHI all response action costs incurred by theDepartment against MHI, interest thereon, and all other costsassociated with the recovery of such costs, including, withoutlimitation, all reasonable attorneys' fees.

XI. Covenant by MHI to the Commonwealth

MHI hereby covenants not to sue or assert any claims or causesof action against the Commonwealth or the Department, includingtheir respective officers, trustees, employees and agents, withrespect to Existing Contamination at the Property, providedhowever, that (i) MHI reserves all rights and remedies which it mayhave with respect to any release or threat of release of oil orhazardous material which the Commonwealth, the Department or any ofthe aforementioned persons causes or contributes to, causes tobecome worse that it otherwise would have been, or is otherwiselegally responsible for.

Special Covenant Not To Bue AgreementDecember 1, 1997Page 9

XII. Contribution Protection

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

XIII. Modification of Agreement

This Agreement may only be modified upon the written agreementof both the Department and the Attorney General, by signature oftheir authorized representatives, and by MHI by signature of theirauthorized representatives.

XIV. Separate Documents

This Agreement may be executed in two or more counterparts,each of which shall be deemed an original, but all of whichtogether shall constitute one and the same instrument.

Xv. Severability

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

IT IS SO AGREED:

MASSACHUSETTS HEAVYINDUSTRIES, IN

By Date: Qctufer L, (?47AAgent

MASSACHUSETTS DEPARTMENT OFENVIRONMENTAL PROTECTION

By. L /d 6Lki y '4)6t*W) C (dY6%Ctz Date: ~4-Y fJames C. ColmanAssistant Commissioner

special Covenant Not To Sue AgreementDecember 1, 1997Page 10

COMMONWEALTH OF MASSACHUSETTSScott Harshbarger, Attorney General

By: ENancy E. Harper, Es .Assistan Attorney General

Date: / 1 3 7~f

COMMONWEALTH OF MASSACHUSETTS

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

Notay Public eI -

My commission expires;:9-1O-

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NOTICE OF LAND USE STIPULATION

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

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

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

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

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

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

4. Any proposed change in activities and uses at the Property which mayresult in higher levels of exposure to oil and/or hazardous material than theexposures which would occur as a result of the use of the Property for the purposesset forth in Section 3 above shall be evaluated (i) by the Consultant of Record,during the term of the Waiver of Approvals, who shall make a determination(hereinafter the "Consultant's Determination") or (ii) by an LSP who shall render anLSP Opinion, in accordance with the DEP Waiver of Approvals and theMassachusetts Contingency Plan , as applicable, as to whether the proposed changeswill present a significant risk of harm to health, safety, public welfare or theenvironment. Any and all requirements set forth in the Consultant'sDetermination or LSP Opinion to ensure a condition of No Significant Risk in theimplementation 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 inwriting, signed by the Consultant of Record or the certifying LSP, as applicable, andrecorded and/or registered with the appropriate Registry of Deeds and/or LandRegistration Office. A certified copy of same shall be filed with DEP within 30 daysof recording and/or registration. Upon the recording of either the Consultant'sDetermination or the LSP Opinion, the Property shajl be conclusively presumed tobe available for use for the purposes set forth in such Determination or Opinion aswell as for the purposes set forth in Section 3 above.

5. Construction activities which may involve the disturbance ofcontamination soil and/or groundwater shall include preparation andimplementation of a hazardous materials management plan ("HMMP") tominimize migration of and exposure to hazardous materials. The HMMP shall beprepared in accordance with the requirements of the "Waiver of Approval" and theMassachusetts Contingency Plan, as applicable.

WITNESS the execution hereof under seal this 10th day of May1995.

MASSACHUSETTS WATER RESOURCESAUTHO TY

By: __

COMMONWEALTH OF MASSACHUSETTS

uffolk ss. M n 1995

Then personally appeared the above-namedDouglas B. MacDonals

Jijarj of MwRA and acknowledged the foregoinginstrument to be the free act and deed of MWRA before me.

Notary Public

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

-2-I

9EXHIBIT A

Legal Description

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

EXHIBIT A-I

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

PARCEL 1:

A CERTAIN PARCEL OF LAND IN THE COMMONWEALTH OFMASSACHUSETTS, COUNTY OF NORFOLK, CITY OF QUINCY AND TOWN OFBRAINTREE, SITUATED ON EAST HOWARD STREET, SOUTH STREET, NASHAVENUE, WASHINGTON STREET, HILL AVENUE, AND QUINCY AVENUE AS SHOWNON SAID PLAN, DATED OCTOBER 15, 1986, DRAWING 150.011M, DRAWING150.021M, DRAWING 150.031M, DRAWING 150.041M, AND DRAWING150.051M.

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

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

(1) LAND DESCRIBED AS TRACT NO. 1 IN THE INDENTURE BETWEENFORE RIVER SHIPBUIDING CORPORATION, AND FORE RIVERRAILROAD CORPORATION DATED APRIL 30, 1919, RECORDED ATBOOK 1421, PAGE 264, EXCEPT THAT PORTION THEREOFCONVEYED BY FORE RIVER RAILROAD CORPORATION TO BETHLEHEMSTEEL COMPANY BY DEED, DATED MARCH 13, 1962, RECORDED ATBOOK 3975, PAGE 742;

(2) LAND DESCRIBED AS PARCEL 2 IN THE DEED FROM THECOMMONWEALTH OF MASSACHUSETTS TO FORE RIVER RAILROADCORPORATION, DATED AUGUST 6, 1920, RECORDED ATBOOK 1466, PAGE 81;

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

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

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

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

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

FOR TITLE REFERENCE, SEE CERTIFICATE OF TITLE NO. 74465, FILED INREGISTRATION BOOK 373, PAGE 65; CERTIFICATE OF TITLE NO. 88974,

FILED IN REGISTRATION BOOK 445, PAGE 174; DEED FROM BETHLEHEMSTEEL COMPANY DATED DECEMBER 31, 1963, RECORDED AT BOOK 4132, PAGE459; AND DEED FROM THE UNITED STATES OF AMERICA, ACTING BY ANDTHROUGH THE ADMINISTRATOR OF GENERAL SERVICES, DATED APRIL 30,1970, RECORDED AT BOOK 4660, PAGE 495.

PARCEL 2:

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

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

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

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

PARCEL 3:

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

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

FOR TITLE REFERENCE, SEE DEED FROM JAMES E. DHOOGE DATED MAY 2,1967, RECORDED AT BOOK 4425, PAGE 517; DEED FROM GERALD D. DHOOGE,ALSO KNOWN AS GERALD D. DEWEY, AND MABEL DHOOGE, ALSO KNOWN ASMABEL DEWEY, DATED APRIL 10, 1967, RECORDED AT BOOK 4431, PAGE604; DEED FROM THERESA LUISI DATED JUNE 15, 1967, RECORDED AT BOOK4447, PAGE 555; AND TWO DEEDS FROM THE TOWN OF BRAINTREE DATEDDECEMBER 11, 1967, RECORDED AT BOOK 4483, PAGES 447 AND 450.

PARCEL 4:

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

- 2 -

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

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

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

PARCEL 5:

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

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

FOR TITLE REFERENCE, SEE DEED FROM BETHLEHEM STEEL COMPANY DATEDDECEMBER 31, 1963, RECORDED AT BOOK 4132, PAGE 459; DEED FROMJAMES J. FLAVIN DATED JANUARY 7, 1967, RECORDED AT BOOK 4404, PAGE639; DEED FROM JOHN F. JOHNSON AND JESSIE M. JOHNSON DATED MARCH3, 1967, RECORDED AT BOOK 4414, PAGE 552; DEED FROM CATHERINEMCQUARRIE DATED OCTOBER 5, 1967, RECORDED AT BOOK 4465, PAGE 73;AND DEED FROM WILLIAM N. MCQUARRIE AND CATHERINE MCQUARRIE DATEDOCTOBER 5, 1967, RECORDED AT BOOK 4465, PAGE 74.

PARCEL 6:

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

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

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

PARCEL 7:

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

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

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

- 3

PARCEL 8:

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

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

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

PARCEL 9:

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

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

FOR TITLE REFERENCE, SEE DEED FROM CHARLES A. SMITH DATEDMARCH 17, 1967, RECORDED AT BOOK 4416, PAGE 50; DEED FROM SIGNE E.WHITEHOUSE DATED MAY 1, 1967, RECORDED AT BOOK 4424, PAGE 327;DEED FROM GEORGE W. NOYES, JR. AND JOYCE E. NOYES DATED MAY 29,1967, RECORDED AT BOOK 4430, PAGE 659; DEED FROM RAYMOND E. ELLISDATED JUNE 13, 1967, RECORDED AT BOOK 4434, PAGE 110; DEED FROMRENE BIGANZOLI AND MARY BIGANZOLI DATED JUNE 16, 1967, RECORDED ATBOOK 4435, PAGE 531; DEED FROM HENRY SEPPALA AND VIOLET SEPPALADATED JUNE 15, 1967, RECORDED AT BOOK 4435, PAGE 533; DEED FROMWILLIAM PERRY AND JOHN S. PERRY DATED JUNE 27, 1967, RECORDED ATBOOK 4438, PAGE 395; DEED FROM RAYMOND F. BARRETT, ADMINISTRATOROF THE ESTATE OF ANNIE DRUMMOND, DATED JANUARY 31, 1968, RECORDEDAT BOOK 4491, PAGE 277; AND DEED FROM AGNES DRISCOLL DATED JANUARY4, 1969, RECORDED AT BOOK 4568, PAGE 707.

PARCEL 10:

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

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

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

- 4 -

0 SPARCEL 11:

A CERTAIN PARCEL OF LAND IN THE COMMONWEALTH OFMASSACHUSETTS, COUNTY OF NORFOLK, CITY OF QUINCY, SITUATED ONEAST HOWARD STREET, CHUBBUCK STREET, DES MOINES ROAD, AND SOUTHSTREET AND IS SHOWN ON SAID PLAN, DATED OCTOBER 15, 1986, DRAWING150.091M.

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

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

PARCEL 12:

A CERTAIN PARCEL OF LAND IN THE COMMONWEALTH OFMASSACHUSETTS, COUNTY OF NORFOLK, CITY OF QUINCY, SITUATED ONLAWRENCE STREET, CHASE STREET, CHECKER STREET, AND CLEVERLY COURTAND IS SHOWN ON SAID PLAN, DATED OCTOBER 15, 1986, DRAWING150.101M.

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

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

PARCEL 13:

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

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

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

PARCEL 14:

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

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

- 5 -

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

PARCEL 15:

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

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

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

FOR TITLE REFERENCE, SEE CERTIFICATE OF TITLE NO. 117791, FILEDIN REGISTRATION BOOK 589, PAGE 191; DEED FROM BETHLEHEM STEELCOMPANY DATED DECEMBER 31, 1963, RECORDED AT BOOK 4132, PAGE 459;DEED FROM ADELE M. FERRIS DATED APRIL 10, 1967, RECORDED AT BOOK4419, PAGE 599: DEED FROM JOHN A. MORRISON AND WINIFRED J.MORRISON DATED APRIL 10, 1967, RECORDED AT BOOK 4419, PAGE 600;DEED FROM ROBERT J. GILMORE AND ELAINE M. GILMORE DATED JUNE 9,1967, RECORDED AT OOK 4434, PAGE 109; DEED FROM MARIE NORCOTTDATED JULY 10, 1967, RECORDED AT BOOK 4441, PAGE 440; AND DEEDFROM ARMAND F. BRODEUR AS TRUSTEE OF THE RONALD BRODEUR TRUST,AND RONALD J. BRODEUR AND ANNA M. BRODEUR, DATED JULY 22, 1967,RECORDED AT BOOK 4445, PAGE 299.

- 6 -

EXHIBIT B

Parcel Four

A certain parcel of land in The Commonwealth of Massachusetts, County ofNorfolk, Town of Braintree, situated on Lancaster Road, and shown on drawing150.061M of a plan of land entitled "General Dynamics Quincy, MA. and Braintree,MA." (consisting of a Plan Index and fourteen drawings numbered 150.011M to150.151M, inclusive, but excluding 150.081M) dated October 15, 1986 and November4, 1986, as revised, by New England Survey Service, recorded November 16, 1987 inPlan Book 361 as Plan #1372 of 1987, Sheets 1-15.

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

Said parcel is identified as Parcel 4 in Exhibit A of the deed of GeneralDynamics Corporation to Massachusetts Water Resources Authority datedNovember 16, 1987 and filed with the Norfolk County Registry District of the LandCourt as Document No. 535415 and recorded with the Norfolk County Registry ofDeeds in Book 7803, Page 211. Said parcel is further described as Parcel 4 on ExhibitA-1 hereto.

0

EXHIBIT C

CERTIFICATE CF COMPLETIONSPECIAL COVENANT NOT TO SUE

AGREEMENTM.G.L. c. 21E, § 3A(j)

From: The Department of Environmental Protection

To: Massachusetts Heavy Industries ("MHI")

Date of Issuance:

DEP Release Tracking No. 3-0536

Property:

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

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

Issued by:Assistant Commissioner, Bureau of Waste Site Cleanup

MASSACHUSETTS WATER RESOURCES AUTHORITYCharlestown Navy Yard

100 First AvenueBoston, Massachusetts 02129

Telephone (617) 242-6000Facsimile. (617) 241-6070

October 17, 1997

James C. ColemanAssistant CommissionerCommonwealth of MassachusettsDepartment of Environmental ProtectionOne Winter StreetBoston, MA 02108

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

Dear Mr. Coleman:

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

Thank you for your help in this matter.

Sincerely,

Le n atailleEnvironmental Manager

Enclosure: Signed facsimile

cc: Douglas MacDonaldTom PowersMaggie DebbieTrudy ReillyPeg Stolfa-DEP

Printed on 100% Recycled Paper

10-17- 1997 14:28 6f92+5721 MASS. DEP / N LEQAL P.03/04

COMMONWEALTH OF MASSACHUSETTS

ExEcu-nvE OFFICE OF ENmIoNMENTAL AFFAIRS

DEPARTMENT OF ENVIRONMENTAL PROTECTlONONE WiTEK STAT. DWTUN, MA 0210 617.29>$500

TRUDY (XMfARGEO PAUL CELLUCC -

DAVID B. TRUHM

October 17, 1997

Leon LatailleMassachusetts WaterResource AuthorityCharlestown Navy Yard100 First AvenueBoston, MA 02129

Re: Massachusetts Water Resources Authority Confirmation ofResponsibility for Existing Contamination at the QuincyShipyard. Reasue Traeking Number 3-056

Dear Mr. Lataille:

Attached please find the latest draft of the Special CovenantNot to Sue Agreement ("Covenant") with respect to MassachuuettuHeavy Industry, Inc.'s ("MHI") purchase of that portion of theabove referenced site ("Site") that is defined in the Covenant asthe "Property." Prior to approving the final Covenant, theDepartment of Environmental Protection (the "Department") must beassured by the Massachusetts Water Resources Authority ("MWRA")that the Existing Contamination on the Site will be addressed. Asdefined in the Covenant, "Existing Contamination" means "any oilor hazardous material present or existing on or under the Site,whether known or unknown, as of the Acquisition Date." Asdiscussed, this letter serves to memorialize the agreement inprinciple between the Department and the MURA that the MWRAconfirms its responsibility for such Existing Contamination.

The Department is aware that the MWRA has executedindemnification agreements with General Dynamics and MH1 regardingthis issue. While indemnification agreements between privateparties provide specified protections among the parties, as youare no doubt aware, it does not affect any obligation to the

DEP on ftm Wr Wie Wb: MtmwAnstema.ufmlp

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10-17-1997 14:28 617 292+5721 MASS. DEP / 80 LEGAL P.04/04

Leon LatailleKMNA Confirmation of Responsibility for Existing Contamination atthe Quincy Shipyard, RTS 3-0536October 17, 1997Page 2

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

Please have the authorized representative of MWRA sign thestatement below and return the original copy of this letter to myattention. Upon receipt the Department will circulate the finalCovenant for the signatures of the authorized representatives ofMHI, the Department and the Office of Attorney General.

S' erely,

Ja eeu. ColmanAs istant Commissioner

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

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G\Ms. Sharon A. GobielDepartment of Environmental Protection10 Commerce WayWoburn, Massachusetts 01801

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

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

Dear Ms. Gobiel:

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

Fluor Daniel GTI has proposed a location for replacement recovery well RW-6A which isapproximately 15 feet north of well RW-6. This location is considered the most optimumin light of existing underground utilities and planned building demolition. Piping will be

placed in a trench from the new well vault to pre-existing piping from RW-6. The pipingthat ran to RW-6 will be capped in place. Electrical supply will be provided from theQuincy Fire Academy Building. The decommissioning of RW-6 and its associated wellvault, installation and development of RW-6A and the installation of a new well vault forRW-6A, will be performed by Fluor Daniel GTI.

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

Copyright® 1997 GZA GeoEnvironmental, Inc.

Department of Environmental ProtectionFile No. 7400.5

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

Very truly yours,

July 31. 1997Page 2

GZA GEOENVIRONMENTAL, INC.

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David J. Adilinan, P.G.Project Manager

Lawrence Feldman, LSPSenior Principal

<Albert J. RicciardelliAssociate Principal

Attachment: Figure I

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

G9.\7400.ZGN\74(X)- 17 DJA\CORIRESP\ZGN I7103 .OC

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June 17, 1997File No. 7400.5-C,PC

7400-C

Ms. Sharon A. GobielDepartment of Environmental Protection10 Commerce WayWoburn, Massachusetts 01801

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

Re: Groundwater Monitoring RequirementsCentral Yard Oil PlumeQuincy Shipyard, Quiney, Massachusetts

Dear Ms. Gobiel:

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

BACKGROUND

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

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

Copyright@ 1997 GZA GeoEnvironmental, Inc.

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Department of Environmental ProtectionFile No. 7400.5_

June 17, 1997Page 2

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

A Waiver of Approvals for the Site was issued by DEP on March 2, 1994.1994, Completion Statements were issued in conjunction with the Waiverabove mentioned reduction in monitoring wells was discussed.

In Septemberin which the

By 1994, the reported amount of oil recovered per month had decreased from 116,000gallons in November 1986 to 242 gallons in October 1994. The rate of oil rceovery hasleveled off to relatively low levels in most wells and has been essentially asymptotic since1990 to 1991. The apparent thickness of SPH had also leveled off in most monitoringwells.

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

ADDITIONAL RECONFIGURATION OF MONITORING SYSTEM

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

One of the goals of the groundwater monitoring program is to monitor the extent of theCYOP. Thus, wells which no longer exhibit detectable levels of SPH may not be necessary

01zX

Department of Environmental Protection June 17, 1997File No. 7400.5 ______ Page 3

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

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

. GD-2270 and MW-15S. SPH has not been observed in GD-2270 in the past andrecords show that GD-2270 is no longer functional, as it has been destroyed since1992. MW-15S typically shows no oil thickness or an extremely small thickness(<.03 feet). In addition, the groundwater elevation in other wells which aremonitored in the area (MW-2, MW-16, GD-2392 and GD-2395A) provide adequatedefinition of the groundwater contours (and thus system capture) in this area.

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

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

. GD-2159. This well is near the center of the plume and consistently shows either nooil or small thicknesses. Wells GD-2269A, MW-5 and RW-4 are consideredadequate to define the CYOP in this area.

To the extent practical (in light of the planned construction at the shipyard), we recommendthat the above mentioned wells not be abandoned so that they can be utilized in the futureto monitor system performance should further modifications be made to the groundwaterextraction system (e.g., further elimination of extraction wells). At this time we believe thatthe remaining wells adequately demonstrate capture of the CYOP regardless of the numberof active recovery wells.

Department of Environmental ProtectionFile No. 7400.5

June 17, 1997Page 4

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

onx Very truly yours,

GZA GEOENVIRONMENTAL, INC.

Lawrence Feldman, LSPSenior Principal

David J. Adilman, P.G.Project Manager

Alb/rt J. RicciardelliAsociate Principal

Attachment: Figure 1

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

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MASSACHUSETTS WATER RESOURCES AUTHORITYCharlestown Navy Yard

100 First AvenueBoston, Massachusetts 02129

C4 Telephone: (617) 242-6000Facsimile (617) 241-6070

May 14, 1997

Ms. Sharon GobielMassachusetts Department of Environmental ProtectionNortheast Regional OfficeBureau of Waste Site Cleanup10 Commerce WayWoburn, Massachusetts 01801

Re: Fore River Staging Area(Fmr. General Dynamics Quincy Shipbuilding Facility)Quincy, MassachusettsRTN # 3-0536 & 3-10266

Dear Ms. Gobiel:

For over seven years MWRA has operated an ambient air monitoring system at the ForeRiver Staging Area (FRSA) in Quincy, Massachusetts. MWRA established an air monitoringnetwork at the FRSA in September 1989 to ensure that fenceline air concentrations duringbuilding demolition or soil excavation did not exceed standards for total inhalable particulatematter (PM 0 ) and to assess lead concentrations in comparison to DEP's guideline 24-hour ceilingconcentration and Threshold Effects Exposure Limit (TEL). Ambient air sampling stationsconsisting of PMo Size Selective High Volume (Hi-Vol) Samplers were established at thefollowing four locations:

1. At the western edge of the roof of the Administration Building (Building 10);2. On the northern site boundary at the South Street gate;3. At the northeastern corner of the site, near Pier 4; and4. East of the FRSA, across the Fore River on the south side of the Boston Edison Edgar

Station.

From September 1989 until January 1992, PM10 Hi-Vol samples were generally collectedevery 2 days, From 1991 to the present, the PM,0 sampling frequency was decreased to every 12days Lead Hi-Vol samples were generally collected every 12 days throughout the entire studyperiod. Approximately 1,400 PMI, samples and over 800 lead samples have been collected over

Printed on 100% Recycled Paper

the study period.

From September 1989 to the present, only one PM,0 sample from the total ofapproximately 1,400 samples (0.07%) exceeded the 24-hour ambient air quality standard, and ofover 800 lead samples, only one sample (0.13%) exceeded the 24-hour TEL. The annual PM,,standard was never exceeded. Only approximately 4% of the lead concentrations were above thepractical quantitation limit; no detectable lead has been observed in samples collected since May1993.

As a result of the non-existent or negligible exceedances of applicable ambient air qualitystandards since 1989, and the expected low level of future construction activity at the FRSA,MWRA intends to terminate regular air monitoring effective immediately. Air monitoring will beimplemented for future construction or demolition projects on a project specific basis, asnecessary to meet all applicable regulatory requirements.

If you have any questions or comments regarding this decision, please call me at (617)241-2759. Thank you for your assistance.

Very truly yours,

Mark RadvilleProgram Manager,Real Property &Environmental Management

cC Maggie Debbie, MWRALeon Lataille, MWRASteve Lipman, DEP/WPCKen Menzies, PEER Consultants

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Me Ch ara~n rOnhial T1PD/NTP12(1 Me~x 1 A 1 00'7

DRAFT FINDING PURSUANT TO M.G.L. c.30 s.61

BY THE

MASSACHUSETTS WATER RESOURCES AUTHORITY

FOR THE

SLUDGE PROCESSING FACILITY EXPANSION, PHASE Il,

AND LONG TERM RESIDUALS MANAGEMENT OPERATION

EOEA # 5832

Submitted by:

The Massachusetts Water Resources Authority100 First Avenue

Charlestown Navy YardBoston, MA 02129

(617) 242-6000

July 26, 1996

ATTACHMENT A

Thomas Powers, Deputy Director, MWRADavid Standley, P.E., Consultant to the City of QuincyS. David Graber, Consultant to the City of WinthropJames Goldstein, Consultant to the Town of BraintreeJames Clark, Town of WeymouthPeter Koff, Legal Counsel for the City of QuincyAllen Johnson, Massachusetts Historical CommissionJane Mead, Office of Coastal Zone Management -

Steven Lipman, DEP Division of Water Pollution ControlMark Stein, EPA Region IVivien Li, Boston Harbor AssociationVirginia Renick, Associate General Counsel, MWRANancy Kurtz, Associate General Counsel, MWRAPatricia Laurie, Staff Counsel, MWRASusan Redlich, MWRA Advisory CommitteeRichard Mills, Director, Residuals ManagementJodi Sugerman, Save the Harbor Save the Bay

MASSACHUSETTS WATER RESOURCES AUTHORITYCharlestown Navy Yard

100 First AvenueBoston, Massachusetts 02129

Telephone: (617) 242-6000Facsimile: (617} 241-6070

July 26, 1996

Trudy Coxe, SecretaryCommonwealth of MassachusettsExecutive Office of Environmental Affairs100 Cambridge Street, 20th FloorBoston, MA 02202

Attention: MEPA Unit

Dear Secretary Coxe:

Re: MWRA, Sludge Processing Facility Expansion and Long-TermResiduals Management Operation, EOEA #5832

Pursuant to the Massachusetts Environmental Policy Act (M.G.L.C.30 s.61) the Massachusetts Water Resources Authority issubmitting the enclosed DRAFT Section 61 finding for theResiduals Management Facilities Plan, EOEA #5832, SludgePr-csinc Facility Expansion, Phase III. This submittal alsocomplies with the Secretary's Certificate regarding the FEIR(November 20, 1989) and the Notice of Project Change (March 9,1995). This finding is also being forwarded to the interestedparties and regulators listed in Attachment A.

This DRAFT finding covers the remaining elements of the Lng-I;Residuals Management Plan not covered in the previously submittedfinding submitted December 12, 1995 for elements of the SludgeProcessing Facility, Phase II Outside Work contract. Included inthis document are findings related to process improvementsnecessary for increased pelletizing capacity, installation of twoadditional pelletizing trains to meet future sludge processingdemand, revisions to building ventilation systems, revision ofair pollution control systems, addition of process safetyequipment and changes to sludge cake handling and bypassconveying equipment for emergency sludge loading.

If yo have any questions regarding the DRAFT finding, please giveme a call at (617) 242-6000 or contact Mike Rivard at (617) 242-0230 x4351.

Sincerely,

JO F. Fi Dairector, Se erage Division

cc: D. MacDonald, MWRAJ. Reitsma, MEPA UnitD. Shephardson, MEPA Unit

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DRAFT FINDING PURSUANT TO M.G.L. c.30 s.61BY THE

MASSACHUSETTS WATER RESOURCES AUTHORITYFOR THE

SLUDGE PROCESSING FACILTY EXPANSIONAND LONG TERM RESIDUALS MANAGEMENT OPERATION

PHASE III

TABLE OF CONTENTSPage

1 INTRODUCTION 1

2 PROJECT BACKGROUND 1

3 DESCRIPTION OF FACILITIES 1

3.1 Deer Island (Phase 1I) 1

32 Fore River Staging Area (FRSA) 1

3.2.1 Existing Facilities 1

322 Lcrg-terrn RFst: Facilities (Phase 1) 2Pelletizing (Heat Drying) Trains 2High Solids Centrifuges 3Product Storage Facilities (Phase 11) 3Pellet Transport to New Silos (Phase 11) 3Pier 2 (Phase 11) 3Sludge Cake Loading Facilities (Phase 11) 3Rail Storage Track (Phase 1l) 3Exhaust Gas Recirculation 3Manifolding Regenerative Thermal Oxidizers 4Air Pollution Control Devices 5Explosion Protection 5Fire Suppression 6Pellet Cooling 6Building Ventilation 6Access Road & Utility Improvements (Phase 11) 7Historic Building Demo/Rehabilltation (Phase 11) 7Braintree/Weymouth Interceptor (Phase 1l) 7Ferric Chloride 7

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3.2.3 Cogeneration (Phase 11) 8

3.3 Residuals Disposal Facilities (Phase 11) 8

3.3.1 Walpole Landfill (Phase 11) 8

3.3.2 Commercial Disposal Facilities (Phase 11) 8

Grit & Screenings 8

Sludge Cake & Pellets 8

4 SPECIFIC IMPACTS & MITIGATION - DEER ISLAND (Phase 11) 8

5 SPECIFIC IMPACTS & MITIGATION - FRSA FACILITIES 8

5.1 Construction 85.1.1 Excavated Soils and Construction and Demolition

Materials Handling (Phase 11) 85.1.2 Building/Structure Demolition (Phase 11) 851.3 Noise & Vibration 85.1.4 Traffic 85.1.5 Water Quality, Waterways & Wetlands (Phase 11) 85.1.6 Air Quality (Phase 11) 8

5.2 Long-term 95.2.1 Air Quality 9

Best Available Control Technology 9Regulatory Requirements Actual and Potential Emissions 12Air Quality Impact Analysis 13Odor Impacts 16

5.2.2 Noise 185.2.3 Historical/Archeological Resources (Phase 11) 185.2.4 Land Use & Visual Impacts (Phase 11) 185.2.5 Socioeconomic (Phase 11) 185.2.6 Transportation (Phase 11) 185.2.7 Water Quality (Phase 11) 185.2.8 Waterways (Phase 11) 185.2.9 Wetlands (Phase 11) 185.2.10 Utilities (Phase 1l) 18

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6 SPECIFIC IMPACTS & MITIGATION - RESIDUALS DISPOSAL FACILITIES 18

6.1 Walpole Landfill (Phase 11) 18

6.2 Commercial Disposal Facilities (Phase 11) 18

7 RESPONSES TO SECRETARY'S CERTIFICATES & SELECTED PUBLICCOMMENTARY [PHASE IIJ 18

7.1 Noise 18

7.2 Transportation (Phase 1l) 18

7.3 Hazardous Materials (Phase 11) 18

7.4 Land Use & Visual (Phase 11) 18

7.5 Other 187.5.1 Air Quality and Facility Emissions 187.5.2 Odor Control 1975.3 Fire Hazards 197.5.4 Visible Emissions 20

8 CONCLUSIONS & FINDINGS 20

APPEND CES

APPENDIX 1 - 8 - (See Phase 11)

APPENDIX 9 - Conditional Approval,MWRA Sludge Processing ExpansionAppl. No. MBR-95-IND-056

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INTRODUCTION

This Draft Phase III Section 61 Finding is submitted pursuant to M.G.L c30,Section 61 and the Certificates of the Secretary of Environmental Affairs as relatedto the Massachusetts Water Resources Authority (MWRA) sludge processingfacility expansion and long-term residuals management facilities operations.

As provided for in the most recent Certificate of the Secretary dated March 9,1995, this document specifically addresses the commitments to environmentalprotection to be implemented during construction and operation of facilities relatedto the "inside" construction work of the long-term residuals project, known as andreferred to hereinafter as Phase Ill. The "outside" phase of the long-term residualsproject, known as Phase 11, and the environmental protection commitments madepertaining thereto, were the subject of a separate Draft Section 61 Findingdocument, as amended, submitted to MEPA, interested parties and regulators onAugust 21, 1995. Comments on the Draft Section 61 Findings document for PhaseI have been responded to by MWRA and a Final Section 61 Findings Documentwas submitted to MEPA, interested parties and regulators on December 12,1995.In this regard, and in the interest of submitting a combined Final Section 61Finding document which covers both Phases |1 and IlIl, this Draft Phase Illdocument only includes text which addresses topics and impacts associated withPhase Ill. For a review of all topics and impacts related to Phase 1l the reader isreferred to the Phase 11 Section 61 Finding document.

Ultimately, the Authority's objective is to combine the Phase i Final and Phase IllFinal Findings, subsequent to comment responses, into a single Final Section 61Finding document for the Sludge Processing Facility Expansion and Long-TermResiduals Management Operation.

2 PROJECT BACKGROUND (See Phase || Finding)

3 DESCRIPTION OF FACIUTIES

3.1 Deer Island (See Phase Il Finding)

3.2 Fore River Staging Area (FRSA)

3.2.1 Existing Facilities (Also see Phase il Finding)

Phase I Sludge Processing Facility Expansion In 1995. In the spring of1995, dryer train #2 was modified to allow for its use in the full scale pilot testprogram, which has been called Phase I of the expansion and modification project.Modifications were made to the process air handling and air pollution controlsystems.

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Specifically, the original equipment installed under the ISP&D project was modifiedto allow testing of alternative particulate removal equipment and recirculation ofdryer air to reduce air emissions and energy use. In addition, pellet coolingequipment was installed and tested to provide control over pellet self heatingduring storage. The following modifications were made under Phase 1:

1. Dual cyclone pairs on pelletizing train No. 2 were replaced by a venturiscrubber and packed tower to demonstrate improved particulate andammonia removal. The packed tower was also operated as a condenserto allow higher rates of gas recirculation.

2. Recirculation ductwork and a larger induction fan were added on Train 2 toallow treated hot air to be returned to the head end of the pellet dryer forreuse.

3. Two pellet cooling devices were installed to provide pellet cooling for fourprocess trains. Pellet coolers of same size are intended to be used, oneper train, in the future plant expansion, Phase Ill.

3.2.2 Long-term Residuals Facilities

Pelletizing (Heat Drying) Trains. As presented in the FEIR, the Authoritywill install two (2) additional process trains to allow the thermal processing of allanticipated future sludge volumes from the new Deer Island Treatment Plant. Theinstalled capacity of the six dryer trains has been revised since the filing of the'EIR :- '989 Curent estimates of insta!led processing capacity indicate that the

six dryer trains would provide between 224 and 324 dry tons per day (dtpd)depending on the pellet quality desired. The lower processing rate has beendemonstrated over the past year of operation to be a reliable operating point andprovides a marketable pellet product providing a high market price. Higherthroughp.t., 3n the order of 43 dr, :s per day per machine (258 dtpd installedcapacity with six trains), has been achieved for short operating periods butoperational reliability at this throughput is unproven. Phase 3 improvements inwet and dry solids conveying and pre-mixing are expected to improve the reliabilityof all trains at the target processing rate of 44.8 dtpd. At this processing rate thepellet facility would be capable of providing continuous operation during highsludge production periods while allowing one dryer train to be out of service forregular or unscheduled maintenance.

The theoretical maximum processing capacity of a dryer is 54 dtpd (324 dtpdinstalled capacity with six trains). This processing rate has never been achieved,is highly dependent on sludge cake dryness and would likely produce very poorquality pellet product that would not be well accepted in the fertilizer markets. Inaddition to nutrient content, size, density and uniformity of the pellet product arecritical characteristics for marketing as fertilizer. An uncontrolled product with largevariation in these various parameters would likely draw the lowest market price,

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thus increasing the difficulty of sale as a fertilizer product.

Projected maximum month sludge volumes of 224 dry tons per day could beprocessed with 5 or 6 trains depending on the necessary product quality goals.Annual average sludge volumes of 180 dry tons per day could be processed withfour to five process trains in operation allowing some redundancy for maintenanceand repair of dryer and associated conveyance equipment.

Pug mills on the dryer inlet and pellet screens at the dry process end are beingreplaced to ensure adequate "dry-material" processing is available for higherprojected processing rates.

High Solids Centrifuges. The eight (8) belt filter presses installed forsludge dewatering in the Interim Sludge Processing and Disposal (ISP&D) projectwill be replaced under Phase Ill Sludge Processing Facility Expansion with twelve(12) centrifuges as planned in the FEIR, August 1989 ind revised in the Notice ofProject Change dated December 30, 1994. The centrifuges are necessary toprovide high solids dewatering capability for the future volumes of mixedanaerobically digested primary and secondary sludge. Twelve centrifuges willprovide the necessary sludge dewatering capability for anticipated maximummonth sludge volumes with adequate processing redundancy.

Product Storage Facilities. (See Phase Il Finding)

Pellet Transport to New Silos. (See Phase 11 Finding)

Pier 2 (See Phase Il Finding)

Sludge Cake Loading Facilities. (See Phase I Finding)

Rail Storage Track. (See Phase ii Finding)

Exhaust Gas Recirculatlon. Exhaust gas recirculation has been shown toimprove the efficiency of the heat drying process during testing of Train 2 in PhaseI of the plant expansion project. This process has been demonstrated in Canadaand Europe as an effective means of increasing the efficiency and performance ofsludge drying and reducing facility emissions. Dryer air recirculation loops will alsobe installed on each of the other three existing trains and the two new processtrains. Process air recirculation rates as high as 75 percent are possible. Theprocess air recirculation loop diverts air exiting the dryer, after a venturi scrubberand packed tower (see discussion -Air Pollution Control Devices), back to the inletof the dryer, reducing the volume of new air that must be heated to dry the sludge.Recirculation reduces the discharge of process air from the facility, which willreduce emissions from the facility. Furthermore, the reduction in air requiring

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treatment through the Regenerative Thermal Oxidizers (RTOs) decreases the fueland power consumption of the RTO operation.

New separator cans have been designed for dryer Trains 1 through 4 so that airlocks can be installed beneath the discharge cone. The inclusion of the air lockwill reduce infiltration air into the dryer air loop, thus reducing the impacts onrecirculation of dryer air and plant emissions volumes that would result from theintroduction of unwanted process air.

Manifolding Regenerative Thermal Oxidizers. The process changesdescribed above, as well as changes in the handling of dryer room ventilation air(see Building Ventilation), result in a reduction in the number of RTO's that arenecessary to treat process and building ventilation air.

The original design intent was to provide one RTO per sludge drying train witheach system in parallel. Therefore, two new RTO's would have been required forthe new dryer trains. Under this design assumption all process room air includingthe sludge dryer room air would be drawn into a common plenum and used 100%as sludge dryer air in a once through process. AM air would have passed throughsix dryers/ RTO's in parallel prior to discharge to the stack. However, with therecirculation of between 30% and 75% of the dryer air back into the sludge dryerand the direct discharge of non-process air from the dryer room, no additionalRTO's are necessary to provide volatile organics destruction and odor control.The four existing RTO's will be manifolded to allow any combination of dryers andRTO's to operate as a system.

Three RTO's are expected to adequately handle the operation of six processingtrains plus providing treatment of building ventilation air associated with sludgedewatering, conveyance and storage. Sludge weigh belts and storage bins willbe covered and vented direct to the existing plenum which continues to provideprocess air to the pellet dryers. Ventilation air from the cake bin room and thedewatering room can either be pulled to the plenum as needed or bypasseddirectly to the RTO manifold for treatment (see Building Ventilation).

One RTO is anticipated to be off-line for scheduled maintenance or serve asbackup to the three operational RTO's providing some operational flexibility. Themanifolding of RTO's allows any of the four RTO's or the six pellet drying trainsto be out of service for repairs, without losing dryer system or RTO capacityunnecessarily.

In addition, ventilation air from the dewatering room and bypass conveying/loadingareas can be directed to the RTO mnifofd for VOC and odor control duringbypass cake loading in the future garage extension. This allows operation of thesludge bypass option independently of the sludge dryer operation.

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Two existing, unused process flues that were originally intended for discharge ofadditional process air from two new process trains and RTO's will no longer beneeded. These unused flues will be used to conduct baghouse exhaust andpurge air during dryer start-up (see 'Air Pollution Control Devices " and"Explosion Protection").

Air Pollution Control Devices. Phase IlIl of the sludge processing facilityexpansion will include the replacement of dual cyclones with a wet venturiscrubber and packed tower combination for particulate removal. This equipmentwas pilot tested in Phase I of plant expansion in 1995. The wet venturi scrubberand packed tower system installed in Phase I demonstrated superior particulateremoval when compared to the existing cyclones. High ammonia removal wasalso demonstrated through condensing and sulfuric acid addition in the packedtower loop. Ammonia removal will reduce emissions otfiitrogen oxides (NOx) fromthe facility. Additional sulfuric acid storage and dosing equipment will be addedas part of the Phase 3 plant expansion. Condensing, which was previouslyachieved through the addition of clean, cold, water to the packed tower, will beachieved by the use of heat exchangers and roof mounted cooling towers on thewater return of the packed tower.

The new air pollution control devices will be installed on all six process trains andwill treat all sludge dryer air flows prior to the recirculation of process air to theinlet of the d'ye- and subsequent discharge of excess portions of the dryerexhaust.

Improved dust collection equipment will be installed on each dryer train, underPhase 3 construction, reducing fugitive dust hazard within process equipment andeliminating discharges into the dryer room enclosure. An exhaust fan will draw dustladen air from six (6) points along the dry product handling system through abaghouse. One baghouse will be provided for each process train and allbaghouse exhaust will be directed via a common manifold to one of two existingunused process flues within the stack.

Explosion Protection. Explosion suppression and venting systems havebeen expanded in the final design in response to further hazard assessment of theoverall operation of the dryer system. Explosion suppression is provided onseveral key, dry material handling systems in the form of diammonium phosphatecanisters that dispense the chemical under pressure into the storage vessels anddry material conveyors. The system automatically actuates in response to asudden increase in pressure such as a pressure wave caused by dust explosionin the equipment. Explosion suppression will be added to the separator can andthe fugitive dust collection system on each dryer train in addition to existingsystems on the recycle bins and recycle conveyor feed. In addition, the dust

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collection system on each dryer train will reduce entrained dust in enclosedvessels and conveyors, lessening the potential for dust deflagration.

A new dryer purge system will also be installed which will vent cold dryer train airdirectly to one of the two existing, unused process flues within the 213 foot stackduring start-up. This system will intentionally ventilate the dryer and burner cavitytemporarily bypassing the RTOs as a safety precaution to remove uncombustednatural gas which could accumulate in these areas during down times or start-up.Prior to adding sludge to the dryer, all air flow will be directed to the air pollutioncontrol systems, including RTOs.

Fire Suppression. To eliminate the potential for fire within the sludge dryerand separator can, both manually automated "mini-quench" and emergencysprinkler water deluge systems have been provided. The mini-quench providesnozzles at both ends of the dryer that can be activated by the operator inresponse to climbing temperatures monitored at the inlet and outlet of the dryertrain which is indicative of a potential fire. An emergency sprinkler/deluge systemis also provided at the dryer and separator can with fusible heads that activateautomatically in response to high temperatures in either vessel. These systemsare process specific and in addition to the building sprinkler system which islocated throughout the facility.

Pellet Cooling. Pellet cooling by water-cooled, bulk-flow, plate heatexchangers was tested ,der Phase I of plant expansion in 1995 The full scaletests utilizing two heat exchangers processing sludge pellets from four dryer trainswere successful in lowering the temperature of pellets in storage. Lowering thestorage temperature of pellets improves the overall safety of the pellet handlingand transportation; therefore, Phase IlIl plant expansion includes the addition ofpeiiet cooiing on each dryer train following pellet screening.

Building Ventilation. Ventilation systems for the pelletizer and dewateringrooms will be altered under the Phase Ill expansion. The dryer room ventilationsystem will be revised to allow direct venting of non-process, room air to theatmosphere. Six exhaust fans and vents will be added to vent room air directlythrough the roof as necessary to maintain acceptable working conditions in thedryer room. A smaller portion of the dryer room air will be included as dryermakeup air or dryer burner air due to the changes in building ventilation.

The change in dewatering technology from bet filter presses to high solidscentrifuges and the recirculation of dryer exhaust to be used as process feed airhas resulted in a reduction in the amount of ventilation air needed from the plenumas feed air to the dryer trains. Previously the plenum received air from the dryerroom via the wet cake room and the dewatering area. Centrifuges are enclosedin a steel frame and both the sludge discharge chute and filtrate drain line are

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contiguous to the sludge cake bins and the building drain system. Therefore,there is no mixing of sludge or filtrate with room air. This containment of sourcesof odor and VOC's allows reduction of the ventilation makeup air for thedewatering and cake bin areas. In addition, in the sludge cake bin area below,covers will be added to the weigh belt conveyors to reduce odor migration withinthe room. Each weigh belt enclosure and each cake bin will be vented to theplenum, which will continue to supply feed air to operating dryer trains.

Ventilation air for the cake storage bin/polymer pump area enters from thepelletizing room via existing louvers and exits through ceiling openings into thedewatering area above. This ventilation air is then ducted to the plenum to provideprocess air for operating dryers. During high recirculation rates (i.e. 75%recirculation) and 4 to 5 process trains running, a second "By-pass" ventilationsystem will pull dewatering room air directly to the RTO plenum for odor and VOCcontrol. The "By-pass" fan will operate at approximately half speed under normaloperation. At a recirculation rate of 33%, all ventilationair will be utilized as make-up air for the dryer systems and zero ventilation air must be bypassed to theRTOs. During periods of higher temperatures, between 60 and 80 degreesFahrenheit, additional direct ventilation of the dryer room area is needed and therooftop fans will be activated. The cake bin and dewatering areas will continue toreceive the same make-up ventilation air from the dryer room area. At ambienttemperatures above 80 degrees Fahrenheit additional cooling of the dryer roomand dewatering room air will be provided via rooftop air conditioning units.

Ventilation for the cake bypass operation including the dewatering room, cakestorage bin area, bypass conveyors on the mezzanine, lime silo room and thesludge loading areas to the north end of the building will be provided by the"Bypass' ductwork and 'Bypass' fan, operating at full speed, with directdischarge to the RTO manifold for treatment. These areas will use the "Bypass"only when sludge cake is to be conveyed to the garage area for loading. Thebypass ventilation system is intended to ensure that the garage areas operateunder negative pressure when sludge handling in these areas is necessary. Undernormal operations, i.e. - pelletizing, the garage areas will be ventilated usingrooftop exhaust fans.

Access Road & Utility Improvements. (See Phase i Finding)

Historic Building Demo/Rehabilitation. (See Phase il Finding)

BraintrelWeymouth Interceptor. (See Phase i Finding)

Ferric Chloride. Ferric Chloride (FeCQ, will be added to the sludge priorto dewatering in order to increase phosphorous capture during further processingand for struvite control. A 30 or 40 percent (%) solution of liquid ferric chloride will

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be transported to the site by secure tank trucks. The ferric chloride solution willbe stored securely in the existing 10,000 gallon tank previously used to storepotassium permanganate.

The addition of ferric chloride provides several benefits. First, it may bind someammonia prior to processing the sludge which minimizes the formation andemission of nitrogen oxides. This binding of ammonia into the sludge matrixenhances pellet fertilizer value by increasing pellet nitrogen content. Anotherbenefit is that ferric chloride precipitates phosphorous increasing nutrient valueand preventing the formation of struvite in sludge and sewer piping. Ferricchloride also provides excellent odor control as it is a strong oxidizing compound.

Ferric chloride in a 30% or 40% solution is very corrosive and must not come incontact with metal or skin. A 10,000 gallon high density cross-linked polyethylenetank with spill protection will be provided for storage of ferric chloride solutions.

3.2.3 Cogeneration. (See Phase 11 Finding)

3.3 Residuals Disposal Facilities

3.3.1 Walpole Landfill (See Phase 11 Finding)

3.3.2 Commercial Disposal Facilities (See Phase 11 Finding)

Grit & Screenings

Sludge Cake & Pellets

SPECIFIC IMPACTS & MITIGATION - DEER ISLAND (See Phase II Fcing)

5 SPECIFIC IMPACTS & MITIGATION - FRSA FACIUTIES

5.1 Construction (See Phase 11 Findings)

5.1.1 Excavated Soils and Construction and Demolition Materials Handling5.1.2 Building/Structure Demolition5.1.3 Noise & Vibration5.1.4 Traffic5.1.5 Water Quality, Waterways & Wetlands5.1.6 Air Quality

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5.2 Long-term

5.2.1 Air Quality

The impact on air quality resulting from the operation of the MWRA SludgeProcessing Expansion and Modification Project at the FRSA in Quincy,Massachusetts, has been quantified using dispersion modeling analysis.The dispersion analysis follows the most recent guidance available from theMassachusetts Department of Environmental Protection (MDEP) and isconsistent with the latest available EPA guidance and models.

Three (3) potential sources of air pollution were modeled: 1) the sludgedryers; 2) the dryer room ventilation air; and 3) the process air fugitive dustventilation system. Each of these sources were modeled as if exhaustingto the atmosphere through the process flues within the existing twohundred thirteen (213) ft. high stack. Dryer exhaust and fugitive dust air willexhaust to the atmosphere through the unused process flues within the twohundred thirteen (213) ft. stack. The dryer room ventilation system designwas subsequently changed to rooftop vents. A supplemental modelinganalysis was conducted to assess odor impacts for this design.

The dispersion modeling analysis showed that Massachusetts and NationalAmbient Air Quality Standards for criteria pollutants or MDEP ThresholdEffects Exposure Umits and Allowable Ambient Limits for air toxics wouldnot be exceeded during long-term operations with the changes proposedunder the Phase Ill plant expansion. Therefore, the project will not have anadverse impact on air quality.

Best Available Control Technology. Best available controltechnology [BACT] analyses were conducted for pollutant emissions ofPM, ; nitrogen oxides (NO) and ammonia (NH3); carbon monoxide (CO);sulfur dioxide (SO2) and total reduced sulfur (TRS); volatile organiccompounds (VOC) and metal emissions from the modified and expandedsludge processing facility. Emission controls for the new and modifiedsludge drying trains, process fugitive dust collection systems and fugitivedust collection systems of the pellet handling and storage operations wereaddressed in the BACT analysis.

Summarized, the BACT analysis provides for a "top-down" method ofranking the available control methods and technologies. These methodsand technologies are ranked in descending order [hence 'top-down"] ofcontrol effectiveness. The methods and technologies are evaluated in lightof energy use, economic and environmental impacts, and other criteria.Control technologies found inappropnate for the emission source are

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eliminated.

Particulate. The BACT analysis for PM,, considered fabricfilters, ceramic filters, dry electrostatic precipitators (ESP's), wet ESP's, wetventuri scrubbers and mechanical cyclone collectors. Of thesetechnologies, fabric filters, dry ESP's and ceramic filters were found to betechnically infeasible control alternatives for PM, control for the MWRAsludge processing facility.

The remaining control technologies were ranked [top to bottom] in orderof potential control effectiveness.

. Wet ESP's

. Wet venturi scrubbers

. Mechanical cyclone collectorsWet ESP's were deemed infeasible primarily based on space constraints ofthe site; mechanical cyclones, much like those operating for the existingfacility, have been found to provide insufficient removal efficiencies.Therefore, wet venturi scrubbers are considered BACT for PM10 emissions.

Wet venturi scrubbers are highly effective particulate control systems.Control efficiencies in excess of 98% can easily be achieved with wet venturiscrubbers. These high control efficiencies were demonstrated throughoutthe summer of 1995 in the full scale pilot testing of the wet venturi scrubberfor dryer train #2 at MWRA's sludge drying facility. Outlet particulateconcentrations from the wet venturi scrubber/packed tower systemproposed for the sludge drying facility will be less than 0.009 grains per drystandard cubic foot.

Nitrogen Oxides and Ammonia. The BACT analysis for NO,and ammonia (NH3) emissions from the sludge drying process trains wasalso conducted. NO, emissions at the stack result from

- Dryer burner, natural gas combustion- Oxidation of sludge NH3 to NO. at the elevated temperatures

in the RTO; and- RTO burner, natural gas combustion.

BACT for NO control is the use of low NO. burners, which will be used onboth the sludge dryers and the RTO burners.

Moreover, MWRA is proposing to reduce ammonia to further control NOemissions. Ammonia will be removed from the exhaust gas usingabsorption and condensing technologies. Ammonia control employingabsorption and condensing, using different agents, was tested during"Phase I". The wet venturi scrubber, packed tower system, installed on train#2, was operated in three (3) modes to determine optimal NH3 removal.

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The three (3) modes were:

1) Absorption in the packed tower by circulating water only2) Absorption in the packed tower with sulfuric acid addition3) Air recirculation in the condensing mode with no acid addition

Results from the demonstration project indicate that more than 95% NH3removal can be achieved using absorption with sulfuric acid addition. Thisammonia removal also correlated to greater than 90% NO. removal,assuming the conversion of NH, to NO, in the RTO. Therefore, BACT isproposed as the use of low NO. burners and absorption using sulfuric acid.

Carbon monoxide. Three (3) methods were evaluated todetermine BACT for carbon monoxide (CO) control: 1) thermal and/orcatalytic oxidation; 2) controlling combustion parameters, and /or 3)pollution prevention. ..

1) Thermal and/or catalytic oxidation would require increasing RTOtemperature which has shown to increase NO, emissions.

2) Combustion control can only be achieved by nozzle adjustment,adjustment of air control linkages to the fuel controls and adjustment of fuelpressure. All three (3) types of adjustments were tested in August 1995with no effect on stack CO.

Therefore, pollution prevention has been determined to be BACT for COcontrol. Pollution prevention consists of minimizing energy demand of theburners within the system. This will be accomplished by better sludgedewatering as provided by the centrifuges, process air recirculation andmaximization of sludge cake feed into the dryers, unless restricted by pelletquality or safety considerations. The RTO's will continue to provide someCO control as well.

Sulfur Dioxide and Total Reduced Sulfur. Fuel used incombustion processes are usually the major contributor to sulfur dioxide(SO2) emissions. BACT for SO2 control on combustion units is the use ofnatural gas as the combustion fuel. AM sludge drying trains use natural gasas fuel.

Anaerobically digested wastewater sludge is a source of hydrogen sulfide(H2S) and Total Reduced Sulfur (TRS). Sludge HS and TRS are by-products of the digestion process and are oxidized to form SO2 in the RTO.MWRA will continue to use the RTOs as TRS control devices, aflthough the

potential exists for a nominal increase in SO2.

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Volatile Organic Compounds. The best available control forVOC emissions is thermal oxidization. MWRA is committed to using theRegenerative Thermal Oxidizers (RTOs) for VOC control.

Metals. Control of metals is accomplished through effectiveparticulate control, with the exception of the "volatile" metals cadmium,selenium, and mercury. BACT for particulate removal was discussedpreviously and applies for non-volatile metal control. The modeling analysisperformed in support of the CPA application assumed no control for thevolatile metals of Cd, Se, and Hg. DEP's ambient air quality criteria (TEL'sand AAL's see Page 19) were well below the mandated thresholds for allmetals.

Fugitive Dust. The most effective control device for fugitivedust emissions from the pellet storage silos aJd dry product handling iscontainment, exhaust, and capture using a baghouse collection system. Assuch, BACT for dust control will be the use of baghouse systems for dryproduct transport, loading and unloading. A baghouse system will also beinstalled on each process train for control of dust during product handlingand processing.

Each fugitive collection system will use a pulse jet continuous cleaningbaghouse, with polyester, non-woven filter media. Treated (processed) air'rom dust collectors or process trains within the pelletizing room will bevented through a common ventilation duct to one of two unused exhaustflues in the plant stack.

Regulatory Requirements Actual and Potential Emissions.Regulatory requirements applicable:; ith expansion and modification of thesludge drying facility include review of emission criteria and standardsagainst the potential emissions from the modified facility. Regulatoryprograms include Prevention of Significant Deterioration (PSD);Nonattainment New Source Review (NSR); and National Emission Standardfor Hazardous Air Pollutants (NESHAP).

PSD requirements apply on a pollutant-specific basis to major modificationsand new major sources in geographic areas which are in attainment of thenational ambient air quality standards for that pollutant. These requirementsinclude ambient air quality monitoring (at the discretion of the regulatoryagency), the application of Best Available Control Technology (BACT, whichconsiders the costs of control), and compliance with ambient airrequirements and PSD increments. Nonattainment NSR requirernentsapply on a pollutant-specific basis to major modifications and new majorsources in areas which are violating the national ambient air quality

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standards for that pollutant. These requirements include the application ofair pollution control technology achieving the Lowest Achievable EmissionRate (LAER, which does not consider the control costs), and greater thanone to one emissions offsets (reductions of emissions elsewhere greaterthan the proposed increases).

Analysis is required to compare present facility emissions with estimatedfuture emissions under operating conditions which would potentially resultin the highest emissions. Stack parameters are not used in this stage ofthe analysis.

Based on existing potential emissions from the sludge processing facility,(i.e., maximum possible emissions from the facility as it is currentlyconfigured), the facility is considered a "major source" for NO, becauseemissions exceed fifty (50) tons per year (TPY). the threshold specifiedunder the Nonattainment New Source Review (NSR) program. The facilityis not a "major source" under regulations for Prevention of SignificantDeterioration (PSD) since potential emissions for each of the pollutants isless than 250 TPY.

The highest emission rates anticipated from the expanded facility wouldresult from the maximum sludge quantity processed at the facility and theuse of the lowest air recirculation rate of 33%. Net annual emissionsincreases (expanded facility emissions less existing facility emissions)under this scenario result in the proposed expansion and modificationproject being considered a minor modification of a major source becausethe net emissions increase of NO, is less than 25 TPY. Additionally, the netincrease in PM, and SO2 are each less than the PSD threshold of 250 TPY.Existing and future potential emissions of VOC's and CO are both less thanthe Nonattainment NSR threshold of 50 TPY and 100 TPY, respectively.Therefore, the project is not subject to Nonattainment NSR programapplicability and PSD regulations and the sludge processing facility remainsa minor source for all pollutants except NO.

The modified facility will also maintain its compliance with the NationalEmission Standard for Hazardous Air Pollutants (NESHAP) for mercury of3,200 gm/24 hours. Future facility-wide potential emissions of mercury areestimated to be 66.7 gm/24 hours.

Air Quality impact Analysis. Air quality impacts are determinedusing dispersion modelling. Dispersion analysis results are a function ofboth emission rates and stack parameters. The emission rates and stackparameters used in the dispersion modeling are those which will yield thegreatest impact.

13

0 0

Dispersion modelling has already been performed twice for this facility.Both analyses modelled emissions from the unmodified sludge processingtrains venting through separate flues in the 213' stack. National WeatherService (NWS) surface meteorological data from Boston's Logan Airport1983 through 1987 were used in addition to mixing height data from theNWS in Portland, Maine.

Original modelling in 1989 for the Air Plan Approval Application wasconducted using expected emissions from five (5) trains processing a totalof 13,667 dry pounds of sludge cake an hour which is equivalent to eachof the existing four (4) trains processing 3,417 dry lbs/hr. It was assumedthat facility-wide emissions for a given facility wide processing rate wereindependent of the individual dryer's sludge cake feed rates. The EPAISCST model used indicated that the maximum predicted impacts would beless than the EPA significant impact concentrations for all criteria pollutantsand that the maximum predicted concentration of all air toxics would beless than the MDEP's threshold effects exposure limits (TEL's) andallowable ambient limits (AAL's). Additionally, the analysis indicated that theworst case impacts from the facility would occur under typicalmeteorological conditions and simple terrain, as opposed to either seabreeze fumigation conditions or complex terrain. The MDEP issued aConditional Plan Approval in February 1990.

The secono cisperscrn analysis was performed ;n 1 994 as a condition ofFinal Plan Approval for the facility. Results of the original analysis werescaled to correspond with actual emissions measured during compliancetesting. Compliance with all Massachusetts and National Ambient AirQuality Standards (NAAQS) and MDEP's TEL's/AAL's for all pollutantsexcept NO2 was demonstratea. Additional modelling with ISCST2 modelusing revised stack parameters and NO, emission rates demonstratedcompliance with NAAQS for NO2.

As is described previously, the wet venturi and packed tower, with acid andthe recirculation loop (which will recirculate at least 33% of the process air),will have the effect of substantially reducing emissions of all pollutants fromeach of the existing drying trains. Even with increased hourly operating andsludge processing capacity of the facility, potential emissions of mostpollutants are expected to decrease. Nonetheless, as part of theComprehensive Plan Approval (CPA) application for the expansion andmodification project, refined dispersIon modelling was performed again forthe four existing modified and two new sludge dryers. DEP issued it'sConditional Approval for the Sludge Processing Facility Expansion onFebruary 9, 1996 (See Appendix 9).

14

Dispersion modeling was also conducted for a new emissions sourceexhausting from the 213 ft. high stack, namely the process fugitive dustventilation and control system exhausting from a spare process flue, alreadyin the stack. The dryer start-up purge air will also discharge from this spareprocess flue but was not modelled due to negligible emissions.

Process Air Fuqitive Dust Ventilation. The exhaust parametersmodeled for dust control system conservatively correspond to the lowestexpected exit temperatures from this system (80*F) and the maximum flowrate of 12,000 ACFM corresponding to all six (6) fans at full operation.

Sludge de!yrs. Recirculation of at least 33% of process air andmodifications of the air pollution devices under Phase Ill will substantiallyreduce emissions from each of the existing dryer trains. Even with theincreased operating hours and sludge processjng capacity of the facility,potential emissions of most pollutants are expected to decrease.

Subsequent to load screening and receptor screening modeling, the refinedair quality compliance modelling was conducted to determine the maximumair quality impacts from the modified facility. Differences between previousmodelling efforts and the current modelling effort are:

1) Receptor rings at 200 and 800 meters were removed andrecstcr rings 2t 150 and 400 meters were added.

2) A receptor at the proposed U. S. Naval Shipbuilding Museumnear the site was added.

3) Use of hourly meteorological data collected by Clean Harbors,Inc. between November 1, 1988 and October 31, 1989, at alocation less than %/ mile south of the facility site. Theproximity of the site to the location of the Clean Harbors, Inc.data collection site warrants the use of the data as on-sitemeteorological data'.

The results of the refined modelling for the criteria pollutants (SO2, CO, NO2,PM, 0, Pb) indicate that the maximum predicted air quality impacts from theproposed facility will be less than significant concentrations at all receptors.With the addition of conservative background concentrations, the maximumpredicted air quality impacts from the facility will be less than the NAAQSfor all criteria air pollutants. These results also indicate that the maximumpredicted air quality impacts from the proposed facility will be less than the

Comparison of the Clean Harbor's with Logan Airport data show that use of the one year dataset, with lower wind speeds, results in higher predicted pollution impacts from the facility thanif the Logan data were used.

15

PSD increments for all criteria air pollutants. Therefore, the air qualityanalysis demonstrates that the proposed facility will not have an adverseimpact on air quality.

The results of the refined modeling for the air toxics (NH3, Be, Cd, Cr, Cr-VI,Cu, H2S, Pb, Hg, Ni, Se, V) indicate that the maximum predicted air qualityimpacts from the proposed facility will be less than the TEL's and AAL's forall analyzed air toxics. Therefore, the air toxics modeling analysisdemonstrates that the proposed facility will not have an adverse impact onair quality.

Odor Impacts. Odor impacts of dryer room ventilation were thesubject of a May 1995 report by Tech Environmental, Inc. entitled "AirQuality Impacts of Room Air Ventilation from MWRA Sludae Expansion &Modification Project". The air quality evaluatioR.is made by comparing airtoxic impact concentrations to established DEP thresholds and predictingodor impacts, expressed in terms of "dilutions-to-threshold" (D/T). If airodor is detectible, "dilutions-to-threshold" refers to the degree to whichconcentrations of odorants in the air need to be reduced to be non-odorous. For example, if the only odorant present in the air is ammonia,which has an odor threshold of 6ppm and its concentration is 18ppm, theodor concentration is 3 (18/6) dilutions to threshold. Previous studies of airemissions from the dryers have identified the following contaminants as

eing of interest: the criteria/NAAOS pollutants (SO.. PM, NO2, Pb, CO),metals (Be, Cd, CR, Cr*", Cu, Pb, Hg, Ni, Se, V) and volatile and semi-volatile compounds (PCB's, Asbestos, Hydrogen Sulfide, HydrogenChloride and Ammonia).

Polutant samplng was &an :z.c ted on February 1, 1995. In addtnto chemical sampling, the City of Quincy requested evaluation of odorpotential based on use of odor panels to establish thresholds of dryer roomair versus use of chemical-specific literature values, and the use of a "puffmodel to assess probable dilutions to receptors. This modeling wasconducted by Odor Science & Engineering (OS&E) of Bloomfield,Connecticut.

OS&E collected six (6) air samples from various locations in the dryer room.The samples were analyzed within the same day of collection by dynamicdilution olfactometry using a trained and screened odor panel. The odorpanelists were chosen from OS&E's pool of panelists from the greaterHartford area who actively participated in ongoing olfactory research andrepresent an average to above average sensitivity range when comparedto a large population. The samples were quantified for odor concentrationin terms of dilution to threshold rates (D/T) in accordance with ASTM

16

Method E-679-91. Unaware of the samples origin, the panelists were alsoasked to describe the odor character of each sample at varying dilutionlevels.

Odors in the pelletizing room are likely to change subsequent to expansionand modification due to more sludge processed and changes to the air flowthrough the room as a result of the new dryer room ventilation system.Odors in the room will be a function of airflow through the operating dryers,sludge feed rate and the air flow through the rooftop vents.

Future emissions through the roof vents are also functions of these samevariables. "Worst Case" future emissions result when the recirculation rateis highest, therefore, the dryer room air needed as make-up process air isminimized. Dryer room ventilation is then augmented by roof-top fans asneeded. The maximum air recirculation rate of 75% was therefore used tocalculate "worst case" future ventilation emissions.

The future worst case emissions from the dryer room air vents weremodeled to estimate maximum air quality impacts at ground level.Maximum ground level impacts from downwash were assessed in both thecavity and near-wake regions adjacent to the building obstructions.

The SCREEN 2 model was used to estimate concentrations in the buildingcavity regions. The ISCST2 model with on-site meteorological data wasused for assessing effects in the wake regions. The dispersion modelingwas supplemented by odor dispersion modelling conducted by OS&Eusing their proprietary PUFF model. 'Worst case" meteorologicalconditions, determined as a result of screening modelling were used in thePUFF model to assess odor impacts. Receptor points for odor impactanalysis, located on and in the proximity of the site, were used to assessodor impacts.

'Worst case" odor impacts predicted using regulatory air quality models inthe budding cavity and near-wake regions were 1.8 D/T and 4.1 D/T,respectively.

Odor modelling results with the PUFF model indicated odor impacts onlyalong the north (Pier 2), east (Fore River) and south (Marine/industrial areasite) boundaries for some of the modelled meteorological conditions. The"worst case" odor conditions were predicted to be at a boundary receptorlocated along the North Platen (#16), consistent with ISCST2 modellingresults. Lesser odor impacts were identified at receptors located along thePier 2, adjacent to Building 11 and the marinelindustrial area. No odorimpacts are predicted for the designated commercial area north of Pier 1

17

or the areas west designated for a "Maritime Technology Park".

More recent modeling of odor impacts from a revised rooftop ventilationdesign of six (6) rooftop vents discharging approximately fifteen feet abovethe roof (Tech Environmental letter to Rachel Quill of DEP, April 12, 1996)showed even lower predicted odor impacts. Maximum predicted odorimpacts to all sensitive receptors were less than 2.2 Df. Although thesemodeling results would theoretically result in the detection of odor undercertain climatic conditions, the impact is thought to be very minor and maynot result in any practical detectable odor. The MWRA is committed totaking reasonable measures to eliminate detectable odors at its propertyboundary and will take the necessary steps toward this goal in the eventthat odors are found to be detectable in practice.

5.2.2 Noise .5.2.3 Historical/Archeological Resources (See Phase It Finding)5.2.4 Land Use & Visual Impacts (See Phase i Finding)5.2.5 Socioeconomic (See Phase Il Finding)5.2.6 Transportation (See Phase 11 Finding)5.2.7 Water Quality (See Phase Il Finding)5.2.8 Waterways (See Phase 11 Finding)5.2.9 Wetlands (See Phase Il Finding)5.2.10 Utilities (See Phase 11 Finding)

6 SPECIFIC IMPACTS & MITIGATION - RESIDUALS DISPOSAL FACILITIES(See Phase 11 Finding)

6.1 Walpole Landfill6.2 Commercial Disposal Facilities

7 RESPONSES TO SECRETARY'S CERTIFICATES & SELECTED PUBLICCOMMENTARY [PHASE III]

7.1 Noise (See Phase 1i Finding)7.2 Transportation (See Phase 11 Finding)7.3 Hazardous Materials (See Phase || Finding)7.4 Land Use & Visual (See Phase 11 Finding)7.5 Other (Also See Phase Il Finding)

7.5.1 Air Quality and Facility EmissionsCommentary received throughout the development of the sludgeprocessing facility has focussed on the air quality impacts associated withthe operation of the facility. Responses to the various concerns follow.

18

0 0

As described in Section 5.2.1, the expanded facility will not have an adverseimpact on air quality. Dispersion modelling conducted for the expandedfacility, using "on-site" meteorological data, has demonstrated thatMassachusetts and National Ambient Air Quality Standards (NAAQS) forcriteria pollutants will not be exceeded and that MDEP Threshold EffectsExposure Limits (TEL's) and Allowable Ambient Limits (AAL's) for air toxicswill also not be exceeded. Therefore, deposition analysis or health riskassessment were not required to be conducted.

Facility emission rates from the expanded facility have been updated. Netannual emissions increases are described more fully in Section 5.2.1,Regulatory Requirements and Potential Emissions.

7.5.2 Odor ControlAn "odor impact analysis", as requested by-the City of Quincy, wasundertaken by Odor Science & Engineering (OS&E) in early 1995. Thisimpact analysis used results from air quality modelling to quantify odorimpacts. Additionally, samples of dryer room air were collected andanalyzed by dynamic dilution olfactometry using trained personnel involvedin ongoing olfactory research. These persons represent an average toabove average sensitivity to odors when compared to a large population.Additionally, odor dispersion modelling was conducted by OS&E.

Cd-r impacts which may result su.bsequent to the expansion andmodification project at the MWRA sludge processing facility are expectedto be minor. Section 5.2.1 describes more fully the odor impacts analysisconducted by OS&E.

7.5.3 Fire HazardsA Fire Hazards Analysis has been conducted for the facility. Fire andexplosion targets associated with the processes were evaluated andrecommendations for mitigation strategies developed. To the greatestextent possible these strategies have been incorporated into the expandedfacility. They are:

- Pellet cooling;- Nitrogen inerting of silos and recycle bins;- Improved sludge feed mixing;- Addition of a deluge system to the separator discharge

conveyor;. Replacement of dry cyclones with wet venturi scrubbers for

better particulate removal;- Explosion venting of silo dust collection systems;

19

- Explosion suppression of fugitive dust collection systemsassociated with each dryer train;

- Addition of automated controls to shut down feed and burneroperations while continuing to rotate the dryer and operatefans and emission control equipment if deluge is activated;

- Explosion suppression system at four points on the separatorsystem: one on the inlet to the separator can; one on theoutlet of the separator can and two on the separator canitself. Additionally, a diammonium phosphate system will beinstalled on the recycle conveyor to the recycle bin; on therecycle bin itself; on the recycle bin outlet conveyor and oneon the inlet and outlet side of the baghouse in the fugitivedust collection system. Diammonium phosphate is anexplosion suppressant chemical that can be discharged underpressure into a enclosed vessel,-sonveyor or duct and willeliminate the migration of fire and potential for explosion.

7.5.4 Visible Emissions. The wet venturi scrubber system will significantlyimprove particulate collection. Approximately 90% more particulatewill be removed using the wet venturi scrubbers versus the dualcyclone system. The dryer system consistently operates at less than10% opacity except during start-up.

8 CONCLUSIONS & FINDINGSBased on the foregoing, the Authority finds that the environmental impactsresulting from the implementation of Phase II are those which have beendescribed in the Residuals Management Facilities Plan and Final EnvironmentalImpact Report (EOEA No. 5832) supplemented by the aforementioned NPC's in1990, 1993, 1994 and 1995 and which are summarized n tth Section 61 Finding.The Authority further finds that the mitigation measures committed to in thisFinding constitute all feasible measures to avoid or minimize any adverseenvironmental impacts described and enhance any beneficial impacts attendantthereto.

As with any major and complex project, further elaboration of and changes inspecific mitigation measures may occur during final design and construction. TheAuthority commits to inform the Executive Office of Environmental Affairs MEPAUnit of project changes which may affect this Finding, in accordance withapplicable MEPA regulations.

20

Appendix 1 - 8(See Phase 11)

APPENDIX 9Conditional Approval,

MWRA Sludge Processing ExpansionAppl. No. MBR-95-IND-056

EXEc"TVE OFrIC: OF EONMENTALS VM

DEPARTMENT OF ENVIRONMENTAL PROTECTION'---

FEB 9 1996

Ir. ohn F:tzgeraldMassachusetts WaterResources Authority M'WRA)Charlestown Navy Yard

00 First Avenue3oston. Iassachusetts 02129

,SWY COXE

DAVD B. SflUIcommmmene

RE: QUINCY - Metropolitan

Boston/ Northeast Region310 CU!R 702(2)BWP AQ 02Transmittal No. 108091AppL. No. MBR-95-IND-056SLUDGE PROCESSINGEXPANSIONCONDITIONAL APPROVAL

Dear Mr. Fitzgerald:

The Metropolitan Boston/Northeast Region of the Department ofEnvironmental Protection. Bureau of Waste Prevention. has reviewed yourrequest regarding modificatons to you existing Interim Sludge Paocessing andDisposal (ISP&D) Facility located at 97 East Howard Street. in the Fore RiverStaging Area of Quincy, Mssachusetts. Construction and operation of the existingISP&D Facility was first approved by the Department in its February 28, 1990.CONDITIONAL APPROVAL letter, and subsequently, in its October 28, 1994,INTERIM APPROVAL letter. Your request, in the form of a plan applicationsubmittal. bears the seal and signature of Mr. David G. Healey, Ma=sachusettsP.E. No. 27544. This Office's review of your application commenced on October13, 1995.

This review of the submitted information by Department engineersindicates that the MWRA plans to expand and modify its existing sludgeprocessing operations. As described in the above mentioned INTERIMAPPROVAL letter, this expansion and modification would be accomplished inthree phases:

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Fore River Staging AreaSludge Processing Expansion and ModificationPage 2

Appheation No.MBR-95-IND-056

Phase 1. which ended on September 1. 1995. involved the modification ofTram No. 2 to replace the dual cyclones with a wet venturi scrubber andpacked tower. and to install an exhaust gas recirculation loop. Collection ofemissions and performance data was also included in this phase.

Phase 2. subject of the submitted application, entails the outsideimprovements to rail loading facilities, and installamon of storage tanks andpossibly associated piping for fuel oil. The submitted application does notinciude fuel oi as a back-up fuel. However. the MWRA may later modifythe apphcation by proposng a iow sulfur fuel oil as a back-up fuel.

Phase 3, also subject of the submitted application, refers to the actualexpansion of sludge processing capacity. primarily inside the existingbuilding. This expansion will consist of modification of the four existingsludge dring prcfs train' (to improve air pollution control equipment,reduce energy consumption. and increase dry solids throughput), andinstallation of two new sludge drying process trains.

Therefore. this CONDITIONAL APPROVAL will serve both to approvemodifications under Phases 2 and 3, and to approve the continued operation of theexisting ISP&D Facility. Thus, the pertinent description and requirements statedin this CONDITIONAL APPROVAL letter will supersede the description andrequirements stated in the INTERIM APPROVAL letter (see Proviso No. 4).

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Fore River Stagng Area Application No.Sludge Processing Expansion and Modification MBR-95-IND-056Page 3

L EXISTING INTERIM SLUDGE PROCESSING AND DISPOSAL FACILITY

As it currently stands. the ISP&D Facility is primarily enclosed within onebuilding. Barges containing sludge from Deer and Nut Islands dock next to thisbuilding, and transfer sludge to holding tanks each equipped with an odor controlsystem as approved under Application No. MBR-89-IND-115A. The ISP&DFacility also includes enclosed spaces for the transfer and loading of dewateredcake to rail cars or trucks. The holding tanks are incorporated into the building,and the entire dewatering, pelletizing, and drying processes occur within thebuilding. The product pellets are then conveyed to silos which are outside andadjacent to the building, from where they can be loaded into rail cars.

1.1 Existing Sludge Processing Operation

The ISP&D Facility currently contains four sludge drying process trains.Each sludge drying process train includes two belt filter presses, one sludge cakestorage bin, one rotary drum dryer, two duai cyclones iexcept for Train No. 2,which has a venturi scrubber/packed tower system), two induced draft fans, oneregenerative thermal oxidizer (RTO), and one process exhaust gas flue. Asmentioned before, Train No. 2 is also equipped with an exhaust gas recirculationloop.

The belt filter presses produce a sludge cake with a typical concentration of25 percent solids by weight from the liquid wastewater sludge which usuallycontains 3 percent solids by weight. The odorous emissions from the belt filterpresses in the dewatering process areas, along with any odorous emissionscontained within the pelletizing plant, are controlled by the RTO associated witheach sludge drying process train. The dewatered sludge cake is blended withrecycled material from the process and fed into its associated sludge dryingprocess train.

-ore River Stagng Area Appfication No.Sludge Processing Expansion and Modification MBR-95-IND-056Page 4

Each of the four Baker Rullman Model No. 105-32 rotary drum dryers has alesign energy input rating of 25,000,000 British Thermal Units (Btu) per hour,and is equipped with a single Peabody Engineering Model No. APR-10 "low NOx":rurner. which :s capable of firing natural gas at a maximum rate of 25.000 cubicfeet per hour. The burners of the rotary drum dryers utilize natural gas as theonlv fuel. .

The product separation system for each sludge drying process trainseparates the product pellets from the process airstream by allowing the pellets todrop from the bottom of the separator while the airstream exits out the top. Thepellets are conveyed to vibratory screens which sort the produced pellets/finesaccording to their size. The first materials which are separated from the productstream are the oversized pellets. These pellets are conveyed to a crusher andthen to a recycle bin. The properly sized pellets are transported into theappropriate product storage silo or to the recycle bin depending upon processingneeds. The undersized pellets and captured fines are also conveyed to the recyclebin.

After ieaving the top of the separator, Lne airstream continues on to theparticulate removal system'. The material collected by the particulate removalsystem is conveyed to the sludge cake feed screw conveyor.

Each particulate removal system servicing Train Nos. 1, 3, and 4 consists oftwo 4XD 340-31 Fisher Klostermann dual cyclones, which provide an averageoverall particulate removal efficiency of approximately 85 percent. The air flowcapacity for both sets of cyclones is approximately 28,500 actual cubic feet perminute (acfm) at 170"F with pressure drops between 14 and 17 inches of watergauge across each parallel assembly of dual cyclones. The induced draft fan foreach rotary drum dryer is located downstream of each dual cyclone assembly, andprovides a marnum air flow of 28,500 acfIn at 170*Fand 26 inches of staticwater (gauge) pressure.

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rore River Staging Area Appucation No-Iuage Processing Expansion and Modification NEBR 95-IND-056Page 5

The particulate removai system servicing Train No. 2. consists of a VS 21Size 42 Clean Gas Systems venturi scrubber'. which provides an average overallparticulate removal efficiency of approximately 98.5 percent. The air flow capacityof this particulate removal system is approximately 32.000 acfm at 180 0 F with apressure drop of 10 inches of water gauge across the venturi scrubber. Theinduced draft fan for the rotary drum dryer is located downstream of the venturiscrubber. and provides a maximum air flow of 32.000 acfnf'at 180*Fand 30 inchesof static water igauge) pressure.

The existing ISP&D Facility also includes five product storage silos. Eachof these silos is equipped with a Dynamic Air Modu - Kleen Model No. 250 bagfilter pulse jet baghouse to control the fugitive particulate emissions which arecreated in the filling process. Each baghouse contains thirty-six polyester filterbags, which operate at pressure drops of 3 to 4 inches of water gauge whilehancihng a maxunum air flow of 42U acim at 170 F. The cleaning mechamsmcleans six (6) bags in intervals of 3 to 30 seconds.

Marketable dried sludge pellets are loaded from each of the product storagesilos into rail cars through a separate PEBCO Model No. DLS-22-4 loading system.Each loading system is equipped with a self-contained particulate control device,which holds thirty-two polyester filter tubes. Each particulate control deviceoperates at pressure drops of 3 to 5 inches of water gauge while handling amaximum air flow of 907 acfm at 70*F. The cleaning cycle for each particulatecontrol device consists of pulsed jets of air that are employed to clean filter banksof 4 to 6 elements every 5 seconds.

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Tore River Staging Area Appiicauon No.Sludge Processing Expansion and Modification MBR-95-IND-056Page 6

Each sludge drying process train is equipped with a Huntington EnergySystems Model No. 3RT095 regenerative thermal oxidizer tRTO) to control

gaseous emissions. Each RTO provides an average destruction efficiency ofapproximately 88.8 percent. The RTOs contain beds of inert ceramic materialused as a conductive heat exchange medium to store and release the availableenergy contained in the RTO exhaust gases. Each RTO, having a design energyinput rating of 7.700.000 Btu per hour, is equipped with tWo Maxon Ovenpacsburners. each capable of firing natural gas at a design rate of 3,850 cubic feet perhour. The burners of the RTOs utilize only natural gas as fuel. Each RTO isdesigned so as to provide a minimum residence time of 1.0 second at 1500*F forall gases introduced to the RTO. During stack testing of modified Train No. 2without recirculation, it was determined that at the permitted temperature of1500*Faits associated RTO no longer produced effective carbon monoxide control,and that a minimum temperature of 1600*F must be maintained any time that

r 1 aiaonL iS not on Train No. 2.

The induced draft fan for each RTO is an LAP Model No. 110-112centrifugal fan which provides a maximum air flow of 34,000 acfm at 310*Fand 32inches of static water (gauge) pressure.

The exhaust flue for each of the four sludge drying process trains is housedin a common concrete stack. Each steel flue is equipped with a Data Test ModelNo. 90AS opacity monitoring device. The opening of each 40 inch exit diameterflue is located 213 feet above ground level. The maximum flue gas exit velocityfor Tram Nos. 1, 3, and 4 is approximately 72 feet per second at 350*F.,and themaximum flue gas exit velocity for Train No. 2 is 76 feet per second at 400"F.

1.2 Existing Operation and Emissions Requirements. Modified Train No. 2Testing Resulta

Currently, each sludge drying process train is approved to process between2300 and 3500 pounds of sludge per hour on a dry weight basis (see InterimApproval No. MBR-89-IND-115).

"'ore River staging Area -Applcation No>luage Prvcessing Expansion and Modificaulon MBR-95-ND-056P3age 7

During the performance and erussions testing of modified Train No. 2, theInterim Approval and subsequent agreements between the MWRA and theDepartment allowed this tram to process between 2300 and 5000 pounds of sludgeper hour on a dry weight basis, at air recirculation rates of 0 and 50 percent (orThe maximum achievable recirculation rate).

The performance and emissions testing was conducted to evaluate theventuri scrubber. the packed tower, and the air recirculation system installed onTrain No. 2. The testing program was witnessed by Department personnel and itwas conducted from August 29 to September 1. 1995.

Testing was performed at four operational conditions. The first threeconditions tested consisted of high sludge throughput (4000 dry pounds per hour)with the recirculation loop (33 percent). low sludge throughput (2300 dry poundsper hour) with the recirculation loop (33 percent), and low sludge throughputwithout recirculation. The fourth operating condition tested involved the dopingof the process airstream with SO., to simulate fuel oil combustion in the dryerburner and to illustrate its resulting SO, stack emissions. Testing results aresummarized in Table 1, below.

0 0

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ore River Stawrng Area Applcation No.udge Processing Expansion and Modiflcation MBR-95-ND-056age 10

These test results indicate that replacing the dual cyclones system with aventuri scrubber has the effect of reducing emissions of particulate matter,egardless of which conditions are being run. Results also showed emissionseductions -or all other pollutants, with the exception of ammonia and sulfur

dioxide. These higher emission rates are believed to be a result of variability in:he sludge, :he content of which cannot be controlled. Due to this characteristic(If the sludge. and the belief that the stack testing methodblogies used forunmonia and sulfur dioxide during the compliance testing of 1994 may lack the:equisite precision. the MWRA has requested a revision of these two air pollutantsemission limits established in the Interun Approval.

The MWRA's request includes increasing the ammonia limit from 1.76pounds per hour (lbs/hr) to 2.90 lbs/hr for all sludge drying process tramis; andincreasing the sulfur dioxide limit from 0.18 lbs/hr to 1.28 lbs/hr5 for Train Nos.. 3, and 4. Due to some degree of sulfur dioxide removal by the ventur

scrubber packed tower system. the MWRA has requested that sulfur dioxideemissions from Train No. 2 be limited to 0.52 lbs/hr5. These limits were basedupon the mean of the data points plus two standard deviations.

Therefore, the sludge processing conditions summarized in Table 2, below,will govern the operation of the existing ISP&D Facility until completion of theproposed expansion and modification and the Final Sludge Processing and DisposalFacility is ready for continuous operation.

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Fore River Stagng AreaSluage Processing Expansion and ModificationPage ! I

-\ppbcauon NoMBR-95-IND-056

TABLE 2 - OPERATING CONDITIONS FOR THE EXISTING ISP&D FACILITY CONDIONS

TRAIN NUMBER I NNIMJM FEED MAXIMUM FEED TOTAL HOURSRATE RATE OF OPERATION

1i2300 3500 8760

2 2300 and 0% or 4000 and 0%' or 7640higher recirculation higher recirculation

(at least 33%) (at least 33%)

3 :300 3500 7640

4 2300 3500 8760

Cg ru rusreena Mguri W sntge per four of ooeraton. on a cry ViM io.

-he R'C on Trwn No. 2 em. be mainrenus a minimum lemmrsure ad 1600F wnnwgea is ga0 meruwiain a useSt

-h. Cormnon nan it bn iems. Mmri Tecen Erircwni. in rno oaf 19. 1 m MAr, sweiee -MI- 9u use "Mm Mmof do dry b/w,ants 0% iecglnsn ain be apprmflmfimuy Utn s e SOmt ter eme 45 Sty S/wr, mnd 3 m n'=,"..

Consequently, the existing ISP&D Facility's potential air pollutantemissions from sludge dryers, for a 365-day rolling period, are estimated to be:82.0 tons per year (tpy) of particulate matter (PM); 210.9 tpy of nitrogen oxides(NOx); 95.1 tpy of carbon monoxide (CO); 44.3 tpy of volatile organic compounds(VOC); 18.0 tpy of sulfur dioxide (SO,); 47.6 tpy of ammonia (NH,); and 1.0 tpy ofhydrogen sulfide (1.5). These annual emissions were calculated based upon theoperating conditions indicated in Table 2, above.'

6Aisum n sRom Mt esang iM FssDa y, n e, # eq d i.5 sy cr sM. dYE my r N 1.5 tp of . 10.1 yci af . 1tyier

SO 10. yci n 9'N3 nd am y - M8I

ore River Staging Area Application No.Sludge P-xessing Expansion and Modification MtBR-95-LND-056Page 12

2. SLUDGE PROCESSING EXPANSION AND MODIFICATION

The £MRA has decided that the sludge drying and pelletization processused in :he ISP&D Facilty would be the selected technology for the long termdisposal of wastewater sludge resulting from the operation of the Deer IslandWastewater Treatment Plant. Therefore, an expansion of the existing sludgeprocessing facility is required in order to accommodate th0 increased volume ofcjudge produced at the Deer Island new wastewater treatment facilities.

The sludge processing expansion and modification includes: (1) expansion ofsludge processing capacity, and (2) energy and air pollution control improvements.These proposed plant modifications, as well as the future operating conditions andresulting emissions, are described below.

2.1 Expansion of Sludge Processing Capacity

Expansion of sludge processing capacity will be accomplished by increasingthe capacity of the existing four sludge drying process trains and adding two newsludge drying process trains. It is expected that improved dewatering equipmentand new product classifiers will allow for additional sludge processing in eachexisting sludge drying process train. With the improved dewatering and screens,the maximum capacity of each train is expected to increase to at least 4500pounds of sludge per hour, on a dry weight basis. The two new sludge processingtrains are then anticipated to increase the capacity of the entire facility byanother 50 percent after the capacity of each existing sludge processing train isincreased.

Expansion of the sludge processing capacity will also require additionalproduct pellet storage, thus. four new product storage silos will be constructed.

Fore River Staging Area Appication NoSluage Processing Expansion ana Modification MBR-95-ND-056Page 13

Each of the two new sludge drying process trains will include aBaker/Rullman Model No. 105-32, or equivalent, rotary drum dryer. Each rotarydrum dryer. having a design energy input rating of 25,000,000 Btu per hour, willbe equipped with a Peabody Engineering, or equivaient, "low NOx" burner, whichwill be capable of firing natural gas at a design rate of 25,000 cubic feet per hour.The burners of each new rotary drum dryer will utilize natural gas as the onlyfuel.

Process gas from the two new sludge drying process trains will be directedto the existing RTOs. The exhaust flues of the four existing RTOs will serve thesix sludge drying process trains and are currently housed in a common concretestack. As described before, each steel flue is equipped with a 90AS Data Testopacity monitoring device, and the opening of each 40 inch exit diameter flue islocated 213 feet above ground level. The maximum flue gas exit velocity persludge drying process train will be approximately 76 feet per second at 400*F.

2.2 Energy and Air Pollution Control Improvements

During Phase 3 of the expansion and modification of its existing sludgeprocessing and disposal facility, the MWRA proposes to install an air recirculationloop in each dryer to increase the efficiency and performance of the drying systemand to reduce air emissions. With condensation of moisture in the recirculated airstream, maximum air recirculation rates of approximately 75 percent are expected.

Energy is conserved by recirculating a fraction of the hot process gas backto the rotary drum dryer furnace. Less energy is required to heat the process gasto the temperatures required for effective sludge drying and less fuel is thereforenecessary for combustion in the dryer furnaces. In addition, the fuel consumptionin the RTOs will be reduced proportionately to the reduced air flow at the inlet ofthe RTOs since the point in the process at which the air is recirculated will beupstream of the RTOs

.ore River Staging Area Application No.Sludge Processing Expansion and Modification MBR-95-IND-056Page 14

Moreover. a number of improvements to the existing air pollution controlsystems are also anticipated during Phases 2 and 3. These improvements are:

I Instaiation of the mentioned air recirculation loop, which is expected toreduce ermssions swce the recirculation point will be located downstream of theparticuiate andi ammonia control device.

2) Repiacement of the existing dual cyclones with venturi scrubbers kto controlparticulate emissions), followed by packed towers (to control ammonia emissions).The outlet particulate concentration is expected to be 0.009 grains per drystandard cubic foot or less. The outlet ammonia concentration is expected to be20 parts per milion by volume or less.

W Addition :f a new fugitive dust control system to both the new and existingsilos. Each silo complex will be equipped with two pulse jet baghouses: onebaghouse for the pellet loading ventilation system, and one baghouse for the pelletunloading ventilation system. Each loading and unloading baghouse will be a STJ-66 W. W. Sy Manufacturing Company, or equivalent, and will contain thirty-sixpolyester filter bags. Each loading baghouse will operate at pressure drops of 3 to4 inches of water gauge while handling a maximum air flow of 1750 acfm for theexisting silos and 2000 acfm for the new silos. Each unloading baghouse willoperate at pressure drops of 3 to 4 inches of water gauge while handling amaximum air flow of 1600 acfm. The maximum air to cloth ratio of eachbaghouse will be 4 to 1, and the cleaning mechanism for each baghouse will cleansix bags in intervals of 3 to 30 seconds. The overall particulate outletconcentration of each baghouse is expected to be less than or equal to 0.005 grainsper actual cubic foot.

(4) Addition of a new ventilation system for the dryer room, capable ofhandling a maximum of 150,000 acfm (from six 25,000 acfm capacity fans; oneabove each drying train). This system will only operate when dryer roomtemperatures exceed a specified temperature (approximately 80*F) and individualfans will likely only operate if the drying train to which they correspond isoperating. All six fans will exhaust through a common plenum and into two spareflues in the existing 213 foot stack.

-ore Rner Stagng Area Appbcacon NoSluage PF-tcessing ExDansion ana Mociication MIBR-95-IND-056Page -5

5) Addition of a new process fugitive dust ventilation and control system foreach sludge drving process train. This system will consist of one exhaust fan foreach drying train. which wiii draw fugitive dust-laden air from six dried productlhandling potLs for each drying train through one baghouse for each drying train.From here. the gas will exhaust through a common plenum for all six trains andinto the two spare process flues in the existing 213 foot stpck. The processfugitive dust system will consist of six identical baghouses with pulse jet cleaning,polyester ncn-woven filter media. and a collection area of 400 square feet. Each of:he six systems has a flow capacity of 1500 acfm for a total system capacity of9000 acim at 80*F.

1.6) Addition of a new RTO air plenum to be constructed along the entire wallbehind the RTOs. Process gas from each the six dryer trains will be ducted tothis single air rlenum and at the outlet of the plenum, dampers will control theflow of process gas to any required combination of RTOs. Gaseous emissions fromthe six dryer trains will be controlled by the four existing RTOs. The MWRAexpects that the existing RTOs will be capable of effectively controlling gaseousemissions from all dryer trains since at any recirculation rate. only a fraction ofthe ful process air flow will be processed in the RTOs. In addition, it is expectedthat the RTOs will destroy between 67 and 78 percent of the carbon monoxideemissions emanating from the dryers.

rare River Staging AreaSludge Processing Expansion and ModificationPage 16

Application No.MBR-95-IND-056

2.3 Final Operating Conditions

As proposed in the submItted application. the Final Sludge Processing andDisposal Facility will operate as indicated in Table 3, below.

TABLE 3 - FINAL OPERATING CONDITIONS PER SLUDGF> PROCESING TR4

SLUDGE FEED RATE PROCESS AIR HOURS OF OPERATIONtdry pounds per hour) RECIRCULATION RATE (per year)

2300 4500 33% 75%MiMum Maximum Minimum Maximum 8760

The submitted information further indicates that whenever a sludgeprocessmn train operates at a recirculation rate above approximately 40 percent,the packed tower needs to be operated in the condensing mode to remove themoisture from the airstream. This wil involve the use of a heat exchanger toremove heat from the packed tower water. This will be accomplished by acombination of rejection of heat to the incoming sludge and to the air via rooftopheat exchangers. Therefore, for example, at 75 percent air recirculation,condensing wiWl be required, whereas at 33 percent condensing will not berequired.

Lastly, the submitted information also indicates that, on an annual basis,the total maximum facility sludge processing rate will be 81,760 dry tons per year.

ore Ru.er Staging Area -ppucation Nosludge Processing Expansion and Moaification MBR-95-IND-056Page -1

2.4 Uncontrolled and Controlled Air Emissions

Operation of the Final Sludge Processing and Disposal Facility will result inair emissions of particulate matter <PM.), oxides of nitrogen. ammonia. carbonmonoxide, sulfur dioxide. total reduced sulfur (TRS)", volatile organic compounds,and metals (beryllium. copper. chromium, nickel, lead, vanadium, cadmium.selenium. and mercury). -

Uncontrolled air emissions are defined as emissions from the sludge dryersalone. and do not include emissions from control equipment (such as emissions ofcombustion pollutants from the RTOs). The uncontrolled air emissions presentedin the application were obtained during the emissions testing of modified TrainNo. 2. With the once-through system, uncontrolled emissions represented thoseemissions sampled at the control device inlets. With the recirculation loop, this isnot a the case. Although the recirculation loop has no detrimental effectupon mass emissions. concentrations of air pollutants which are not controlledwell within the loop (i.e.. by the venturi scrubber/packed tower) will increasesignificantly at the inlet as a result of these pollutants being reintroduced to theairstream -. the dryer inlet. However. this increase is compensated for by adecrease in the volumetric flow rate out the stack, to yield either identical orlower mass emissions relative to the once-through system.

The controlled air emissions presented in the application were obtainedduring emissions testing of modified Train No. 2. Modifications to this sludgedrying process train included several of the air pollution control improvementsdescribed in Section 2.2. above. Worst-case uncontrolled and controlled potentialair emissions are summarized in Table 4, below.

PM' AAn en PWni., SMajIaf MRn WC mwoe in bwen.

The aqter 1 RM I Idvf -W me brk feu afIWO esmyme h fl i i SWdI nnflt adn'o1 stew. men dfli dse.

Fore River Staging AreaSludge Processing Expansion and ModificationPage 18

Application No.MR-95-IND-056

TABLE 4 - UNCONTROLLED AND CONTROLLED AIR EMISSIONS FROM THE FINALSLUDGE PROCESSING AND DISPOSAL FACILITY (PER DRYING TRAIN)

POLLUTANT WNCONTROLLE.D EMISSIONS CONTROLLED EMISSIONSk pounds per hourj (pounds per hour

Pamicumate Matter Smader than 10 67 i1% Dcrer-s marneter

Oxioea oi Nitrogen '2

Ammowa 16.0 0.47

Carbon Monoxide 16.1 35

Sulfur Diaxide 1 3 0.52

Totai Reducea Sulfur 022 J 09

Volatde Orgamc Compounac 19.0 0 94

Bervwilium 00016 I.SE-05

S .s18 2,1E-03

Total Chronuum 024 2.8E-03

Hexavalent Chromium 0.0065 7,6E-05

Nickel 0.063 7.2E-04

Lead 0.091 1.1E-03

Vanadum 0.18 2.1E-03

Cadmium" 5.6E.04 5.6E-04

Selenim 6.2E-04 6.2E-04

Mercury 0 9.9E-04 9.9E-04

oue % e m. " pwn Sa e msfum e e&4o numeni em n m ser maOfl not fle ow a.

"ore River Starng Area Application Noluage Processing Expansion ana Modification MBR-95-IND-056

%ge 19

2.5 Future Potential Emissions

Future potential emissions have been estimated based on the operation ofthe following emission units:

'1) Six siudge drying process trains, which include four-existing (modified)trains and two new ones. Potential future emissions of PM.., NOx, CO,SO- VOC. TRS (as hydrogen sulfide), NH, and metals are estimated basedon the controlled emission rates as indicated in Table 4, above, assumingeach train will operate 8760 hours per year, at 100 percent capacity.

12) Six new space heaters with a combined maximum input capacity of1.600.000 Btu per hour. These space heaters will utilize natural gas as theonly fuel, Potential future emissions of PM, NOx. CO. SO, and VOC areestimated based on EPA's' emission factors for natural gas combustion andthe rated heat input of the units, assuming each unit will operate 8760hours per year. at 100 percent capacity.

3) One 225 kilowatt emergency generator. Potential future emissions of PM,,,NOx. CO, SO2 and VOC are estimated based on EPA's emission factors fordiesel-fired reciprocating engines, assuming a restricted operation of 300hours per year, at the maximum fuel rate of 18 gallons per hour.

(4) Four existing sludge/filtrate tanks, each having a capacity of 1,000,000gallons. Future potential emissions of VOC are based on the actualemission estimate for year 1994, scaled to reflect the proposed maximumsludge throughput for the facility.

(5) Nine pellet storage silos. Each to be equipped with a fugitive dust controlsystem. Future potential emissions of PM., from the handling of theproduct pellets are based on a controlled emissin rate of 0.005 grains peractual cubic foot from each existing silo complex baghouse, assuming 100percent annual capacity.

9EPA * wu~~lPmowan Apnay.

Fore River Staging AreaSludge Processing Expansion and ModificationPage 20

Appucation No.MB R-95- rND-056

(6) Two 10.000 gallon dust suppressant storage tanks (each bank of silos will beequipped with a storage tank for dust suppressant). Future potential VOCemissions are based on EPA's emission factors for the storage of organicliquids and an estimated maximum annual throughput of surfactant at anapplication rate of 3 gallons per ton of product pellets.

7) A new room air ventilation system, and a new process fugitive dust controlsystem for process equipment dry solids handling associated with eachexistmg and new sludge drver process train. Future potential emissions ofPM.., VOC, TRS (as hydrogen sulfide), NH,, and metals are based on dataand emission factors from previous studies, and based on a baghouse outletconcentration of 0.005 grains per actual cubic foot.

Therefore. the future potential emissions" from the Final SludgeProcessing and Disposai I acility, for a 365-day roiling period, are estimated to be:34.2 tpy of PM.; 54.7 tpy of NOx; 94.7 TPY of CO; 49.3 tpy of volatile organiccompounds NOC); 13.8 tpy of SO; 12.9 tpy of ammonia (NH,); and 2.5 tpy ofhydrogen sulfide (HS).

10%W .n. smM. ma.. *OF% me Sag. WO. a y . a sa r oe. Sge .. etn .ru mem..n qaMs .e.s S tm

15. Iay o .r S6 Isy G.O N, 732 IPy .t c0. 34.2 loy . V=, I S tp or . La Wy o.r W 3 ey 4 P2L The nagg .Pc..n %.t .1 1 mm.., a"M MW o 0. . e V We mcgee e WApt Wn u Gss a .. ma W a N w ., y.n. M m

Irm a en WW 25 UM WM

Pore River Staging Ara Apphcation No.Sludge Processmg Expansion and Modification MBR-95-IND-056Page 2:

3. CONDITIONAL APPROVAL AND PROVISOS

The Department has determined that your application is administrativelycomplete and that the described process and equipment are in conformance withcurrent air pollution control engineering practices, and hereby grantsCONDMONAL APPROVAL for the proposal. as submitteli, with the followingprovisos:

GENERAL REQUIREMENTS

Tha: Lfhe :JWEV~ E :namr.amerinucus compliance at alIuez wit

Section 3 of this CONDMONAL APPROVAL Sections 1 and 2 of thisApproval letter are descriptive and constitute enforceable requirements onlyto the extent incorporated into a proviso in Section 3.

2. That if conflicting information is found between the submitted informationregarding the Final Sludge Processing and Disposal Facility and thisCONDMONAL APPROVAL, then the requirements of thisCONDMONAL APPROVAL shall take precedence over the documentationin the application materials.

3. That if the MWRA anticipates substantial changes to the informationcontained in this CONDMONAL APPROVAL including, but not limited to,the usage of a low sulfur fuel oil as a back-up fuel, then the MWRA shallsubmit appropriate documentation which will demonstrate that saidchanges will not adversely impact the environment and will not violate therequirements of 310 CMR 7.00 - Air Pollution Control Regulations. WrittenDepartment concurrence must be obtained prior to implementation of saidchanges

rore River Staging Area Application No.Sludge Processing Expansion and Modification MBR-95-IND-056Page 22

4. That the description and requirements contained in this CONDITIONALAPPROVAL letter regarding the existing ISP&D Facility shall supersedethe description and requirements contained in the INTERIM APPROVALletter issued to the MWRA by the Department on October 28, 1994.

5. That a copy of this CONDITIONAL APPROVAL letter and any subsequentrevisions shall be maintained in the facility's controlloom.

6. That the Department may suspend, modify, or revoke this Approval if atany time the MWRA violates any applicable Regulation(s) or conditions ofthis Approval letter.

That should the construction, substantial reconstruction. or alteration atthe Final Sludge Processing and Disposal Facility violate any provisions ofo10 CMR %BV. a R MWILA -hall be subject to enorcem. pursua2: to

Massachusetts General Laws, Chapter 111, sections 142A and B andChapter 21A. section 16.

S. That the MWRA shall specify the emissions resulting from the operation ofthe equipment described in this letter on the Emission Statement Formssubmitted to the Department as required by Regulation 310 CMR 7.12.

9. That the MWRA shall comply with all applicable federal requirementspursuant to 40 CFR Part 61, Subpart E - National Emission Standard forMercury.

10. That should any nuisance condition(s) such as smoke, dust, odor, or noiseoccur as a result of the operation of equipment and processes described inthis Approval letter, then appropriate steps (including shutdown of affecteddryer trains in the event of major system upsets or major malfunctions ofthe air pollution control equipment) shall be taken by the MWRA to abatesaid nuisance condition(s).

Fore River Staging Area Applicauon No.Sludge Processing Expansion and Modification MBR-95-IND-056Page 23

11. That the MWRA shall immediately implement all necessary and appropriatemeasures to alleviate dust, noise, and odor nuisance conditions which mayoccur during and after modifications to the existing ISP&D Facility. Suchmeasures must comply with Regulations 310 CMR 7.01, 7.09. and 7.10.

12. That the MWRA shall comply with Regulation 310 CMR 7.15 to properlyremove any asbestos that may be disturbed by the modifications to theexsting ISP&D Facility.

13. That the MWRA shall allow Department personnel, health andenvironmental officials, and EPA personnel access to the plant site,buildings and all pertinent records during normal business hours for thepurpose of making inspections, surveys, collecting samples, obtaining data,and reviewing all pertinent records.

14. That the MWRA shall comply with all the requirements stated in thisCONDITIONAL APPROVAL letter regarding the operation of the existingISP&D Facility until completion of the proposed expansion andmodification, and the Final Sludge Processing and Disposal Facility is readyfor continuous operation.

NOTIFICATION AND SUBMI'"ALREQUIRKMENTS

15. That the MWRA shall notify this Office. in writing, attention Permit Chief,Bureau of Waste Prevention, when the modifications to the existing ISP&DFacility are complete, and the Final Sludge and Disposal Facility is ready foroperation.

16. That the MWRA shall notify the Department of its plans or schedule(s) torestart operation of each sludge drying process trains pursuant to 40 CFR61.09

Tare River Sagmg Area Application No.Sludge Processing Expansion and Modification MBR-95-IND-056Page 24

17. That the MWRA shall supply this Office. attention Permitting Chief,Bureau of Waste Prevention, with the final plans and specifications for thenew equipment to be installed at the facility.

18. That the MWRA shall immediately notify this Office by fax at (617) 932-7615 and subsequently in writing, of any major system upsets or majormaifunctions of the existing air pollution control eqtripment or the existingopacity momtoring equipment (see Proviso Nos. 21 and 36). The MWRAshal submit the written confirmation to this Office, attention Complianceand Enforcement Chief, Bureau of Waste Prevention, describing themalfunction, the possible reason(s) for it, and future actions to beundertaken to prevent this malfunction from recurring. The writtenconfirmation shall be received by this Office no later than 7 days from theonset of the malfunction.

19. That the MWRA shall immediately notify this Office by fax at (617) 932-7615 and subsequently in writing, attention Compliance and EnforcementChief. Bureau of Waste Prevention, of any malfunctions, operator errors,and unpermitted releases that caused or could have caused harm to publichealth. safety, or welfare, and/or to the environment while installing,testing, and operating the new equipment.

P1H0CESS/EQ&UIPM Ulq OERATON RFURMNSFOR THE EXgfISMQINTRIM= SLUDGE PRESSING AND DISPOSAL FACILIT

20. That the MWRA shall operate the existing ISP&D Facility consistent withthe pertinent parameters and conditions as established in thisCONDITIONAL APPROVAL letter.

21. That in the event of a major malfunction in the air pollution controlequipment, the MWRA shall cease operation of the affected sludge dryingprocess train(s) until the problem has been corrected.

Fore River Staging Area Application No.Sludge Processing Expansion and Modificaion MBR-95-LYD-056Page 25

22. That during normal operation. the minimum siudge feed rate to each of theexisting four sludge drying process trains shall not be lower than 2,300 drypounds per hour.

23. That the sludge feed rate of Train Nos. 1, 3, and 4 shall not exceed 3,500dry pounds per hour.

24. That the sludge feed rate of Train No. 2 shall not exceed 4,000 dry poundsper hour.

25. That the operation of Train Nos. 2 and 3 shall not exceed a maximum of7,640 hours per year, per train. The MWRA shall document theelapsed/run time of these trains on a meter and strip chart recorder.

2 That the MWRA shall operate the existing venturi scrubber servicing TrainNo. 2 in accordance with manufacturer's specifications so as to ensure amaximum outlet particulate concentration of 0.009 grains per dry standardcubic foot.

27. That the packing material in the packed tower shall be filled asrecommended by the manufacturer so as to ensure optimum controloperation of this equipment.

28. That the MWRA shall operate the existing RTOe in accordance withmanufacturer's specifications so as to ensure an average VOC destructionefficiency of approximately 88.8 percent.

29. That the MWRA shall maintain the operating temperature of the RTOservicing Train No. 2 at a minimum of 1600 *F. whenever the exhaust gasrecirculation is kept at 0 percent.

Fore kiver Staging AreaSludge Processing Expansion and ModificationPage 26

Application No.MBR-95-NI-056

30. That the air emissions from each sludge drying process train shall notexceed the limitations summarized in Table 5, below:

TABLE 5 - AIR EMISSION LIMITATIONS PER SLUDGE DRYING PROCESSTRAIN

POLLUTANT AIR EMISSION LIMITATION(pounds per hour, per train)

PM 5.00

NOx 12.86

CO 5.80

"OC 2.70

SO2 1.28 (Train Nos. 1, 3, and 4)0.52 (Train No. 2)

2.90

HS 0.064

'C

t. a 4

Fore River Staging AreaSludge Processing Expansion and ModificationPage 27

Application No..MBR-95-IND-056

31. That the annual air emissions from the existing ISP&D Facility shall notexceed the limitations summarized in Table 6, below. These limitations arebased on a 365-day roling period.

TABLE 6 - ANNUAL AIR EMTB8TON LMITATIONS FROM THE EITINGINTERIM SLUDGE PROCESSING AND DISPOSAL FACILITY

POLLUTANT ANNUAL AIR EMISSIONLIMITATION

(tn per 865 day roiling period)

PM 82.0

NOx 210.9

CO 95.1

VOC 44.3

SO2 18.0

NH, 47.6

H 25 1.0

32. That the mercury air emissions resulting from the operation of the existingISP&D Facility shall not exceed 3200 grams per 24-hour period, as requiredpursuant to 40 CFR Part 61.52.

33. That the MWRA shall conduct sludge sampling and analysis for mercury aspecified in 40 CFR Part 61.54, if and when the Department deems itnecessary. The sludge shall be sampled according to Method 105 -Determination of Mercury in Watewater Treatment Plant Sewaue Sludes.

-~ 'a.-

Fore River Stagmg Area Appilcauon No.Sludge Processing Expansion and Modification MBR-95-IND-056Page 28

34. That the visible emissions from each sludge drying process train shall notexceed fifteen (15) percent opacity.

PROCESS/EQUIPMENT OPERATION REQUIREMEN'S FOR THE FINALSLUDGE PROCESSING AND DISPOSAL FACILITY

35. That the MWRA shall operate the Final Sludge Processing and DisposalFacility consistent with the pertinent parameters and conditions aestablished in this CONDITIONAL APPROVAL letter.

36. That in the event of a major malfunction in the air pollution controlequipment. the MWRA shall cease operation of the affected sludge dryingprocess train(s) until the problem has been corrected.

37. That during normal operation, the minimum sludge feed rate to each of thesix sludge drying process trains shall not be lower than 2,300 dry poundsper hour.

38. That the sludge feed rate of each sludge process train shall not exceed4,500 dry pounds per hour.

39. That the total maximum sludge processing rate for the entire facility shallnot exceed 81,760 dry tons per year.

40. That the particulate emission rate and outlet concentration from eachventuri scrubber shall be determined during the required compliancetesting. It is expected that a maximum particulate outlet concentration of0.009 grains per dry standard cubic foot will be attained by each venturiscrubber.

41. That the packing material in each packed tower shall be filled asrecommended by the manufacturer so as to ensure optimum controloperation of this equipment.

III

Application No.MBR-95-IND-056

42. That the ammonia emission rate and outlet concentration from each packedtower shall be determined during the required compliance testing. It isexpected that a maximum outlet ammonia concentration of 20 parts permillion by volume will be attained by each packed tower.

43. That the normal pH set point range for each packed tower shall beestablished during the required compliance testing:-

44. That the air emissions from each sludge drying process train shall notexceed the limitations summarized in Table 7, below:

TABLE 7 - AIR EMISSION LIMITATIONS PER SLUDGE DRYING PROCESSTRAIN

1,*

1-. 1

Fore River Staging AreaSludge Processing Expansion and ModificationPage 29

I

I

POLLUTANT AIR EMISSION LIMITATION(pounds per hour, per train)

PM,0 1.10

NOr 1.6

CO 3.6

VOC 0.94

S0, 0.52

NH3 0.47

HS 0.09

W

ore River Staging AreaSludge Processing Expansion and ModificationPage 30

Application No.MBR-95-IND-056

45. That the annual air emissions from the Final Sludge Processing andDisposal Facility shall not exceed the limitations summarized in Table 8,below. These limitations are based on a 365-day rolling period.

TABLE 8 - ANNUAL AIR EMISSION LIMITATIONS FROM THE FINALSLUDGE PROCESSING AND DISPOSAL FACILITY

POLLUTANT ANNUAL AIR EMISSIONLIMITATION

(tons per 365 day rolling period)

PM. 0 34.2

NOx 54 7

CO 94.7

VOC 49.3

S0 13.8

NH, 12.9

HS 2.5

46. That the mercury air emissions resulting from the operation of the FinalSludge Processing and Disposal Facility shall not exceed 3200 grams per 24-hour period, as required pursuant to 40 CFR Part 61.52.

47. That the visible emissions from each sludge drying process train shall notexceed fifteen (15) percent opacity.

48. That the operation of the 225 kilowatt emergency generator shall notexceed 300 hours per year.

rore River Laging Area Applcation NoSludge Processing Expansion and Modificaton MBR-95-IND-056Page 31

49. That the MWRA shall operate the new fugitive dust control systems inaccordance with manufacturer's specifications so as to ensure a maximumparticulate outlet concentration of 0.005 grains per actual cubic foot.

50. That the MWRA shall demonstrate the ability of the new fugitive dustcontrol systems to maintain particulate emission rates at or below thestated level, when and if the Department deems such as necessary.

FOR THE FINAL SLUDGEPROCEESING AND DISPOSAL FACILIrY

51. That the MWRA shall conduct emissions compliance testing on all sixsludge drying process trains, within 90 days of initial start-up of the newand modified trains. This compliance testing shall be performed todemonstrate compliance with the requirements of this CONDITIONALAPPROVAL letter regarding the operation of the Final Sludge Processingand Disposal Facility. Final air emissions limitations and operatingrestrictions shall be contained in the FINAL APPROVAL for the subjectfacility.

52. That each of the six sludge drying process trains shall be tested forparticulate matter (at the outlet of each packed tower), oxides of nitrogen(as nitrogen dioxide), ammonia (at the outlet of each packed tower), carbonmonoxide, sulfur dioxide, total reduced sulfur (as hydrogen sulfide), volatileorganic compounds, and metals (beryllium, copper, total chromium,hexavalent chromium, nickel, lead, vanadium, cadmium, selenium, andmercury), and any other parameter(s) determined by the Departmentduring the test protocol reviewing period (see Proviso No. 53).

S

Fore River Staging Area Appucation No.Sludge Processing Expansion and Modification MBR-95-IND-056Page 32

53. That the MWRA shall submit to this Office. attention Permit Chief. Bureauof Waste Prevention, a test protocol for the required air enissions testingfor Department review. This test protocol shall be submitted at least 60days prior to commencement of said air emissions testing. The protocolshall describe sampling point locations, sampling equipment, sampling andanalytical procedures, and the operating conditions for the required testing.

54. That the MWRA shall conduct said emissions compliance testing inaccordance with test methods and procedures required pursuant to 40 CFRPart 60, Appendix A, and Part 61, Subpart E. This emissions compliancetesting must be witnessed by Department personnel. Scheduling for thistesting shall be coordinated with Department personnel and shall beconfirmed no later than 60 days prior to the target test date(s).

55. That the MWRA shall conduct sludge sampling and analysis for mercury asspecified in 40 CFR Part 61.54, if and when the Department deems itnecessary. The sludge shall be sampled according to Method 105 -Determination of Mercury in Wastewater Treatment Plant Sewage Sludges.

56. That the MWRA shall submit the emissions compliance testing resultsreport to this Office, attention Permit Chief, Bureau of Waste Prevention,within 60 days of completion of this testing for Department review.

57. That in addition to the initial emissions compliance testing, the MWRAshall periodically perform emissions compliance testing for any two of thesix sludge drying process trains, selected by DEP, to demonstratecompliance with the requirements stated in the FINAL APPROVAL letter,when issued. The first of these additional tests shall be completed withinthe fifth year after the issuance date of the FINAL APPROVAL letter.Subsequent tests shall be performed once every five years. TheDepartment may alter the time between testing by submitting a writtennotification to the MWRA to that effect.

rore River Staging Area Apphcanlon NoSludge Processang Expansion and Modification MBR-95-IND-056Page 33

58. That during the emissions compliance testing required in Proviso No. 57,above, both sludge drying process trains shall be tested for particulatematter (at the outlet of each packed tower), oxides of nitrogen (as nitrogendioxide), carbon monoxide, ammonia (at the outlet of each packed tower),and volatile organic compounds. One of these two sludge drying processtrains shall be tested at its RTO's outlet for sulfur dioxide, total reducedsulfur tas hydrogen sulfide), and metals (beryllium, cqpper, total chromium,hexavalent chromium, nickel, lead, vanadium, selenium, and mercury).

59. That within 90 days of initial start-up of the new and modified trains, theMWRA shall conduct a noise survey via a qualified consultant todemonstrate that noise impacts from the operation of the Final SludgeProcessing and Disposal Facility are within allowable levels. This noisesurvey must be witnessed by Department personnel. The Department shallbe notifed of the scheduled noise survey at least seven (7) days in advance.

STANDARD OPERATING AND MAINTENANCE PROCEDURESREQUIREMENTS FOR THE E2ISTING INTERIM SLUDGE PROCESSING ANDDISPOSAL FACILT

60. That the MWRA shall maintain on-site, at all times, an up-to-date copy ofthe existing ISP&D Facility's Standard Operating and MaintenanceProcedures (SOMP).

61. That the MWRA shall conduct daily equipment checks, including, but notlimited to, the air pollution control equipment to prevent and/or minimizemajor system upsets and malfunctions.

62. That any revision(s) made to the existing ISP&D Facility's SOMP must besubmitted to this Office, attention Permit Chief, Bureau of WastePrevention, withm 15 days of said revision(s).

Fore River Staging Area Application No.Sludge Processing Expansion and Modification MBR-95-IND-056Page 34

STANDARD OPERATING AND MAINTENANCE PROCEDURESREQUIREMENTS FOR THE FINAL SLUDGE PROCESSING AND DISPOSALFACILITY

63. That the MWRA shall conduct daily equipment checks, including, but notlimited to, the air pollution control equipment to priVent and/or minimizemaior system upsets and malfunctions.

64. That the MWRA shall submit the Final SOMP for the Final SludgeProcessing and Disposal Facility to this Office, attention Permit Chief;Bureau of Waste Prevention, within 120 days of completion of the emissionacompiance testing required in Proviso No. 51, above.

65. That the Final SOMP must contain standard operating and maintenanceprocedures for the Final Sludge Processing and Disposal Facility, includingthe rotary drum dryers, the dewatering system, the venturi scrubbers, thepacked towers, the regenerative thermal oxidizers, the silos fugitive dustcontrol equipment, the process fugitive dust control system, and the opacitymonitoring equipment. The MWRA shall also provide for abatement actionin this Final SOMP, which shall be initiated immediately should theinstalled equipment cause or contribute to a condition of air pollution.

66. That any subsequent revision(s) made to the Final SOMP must besubmitted to this Office, attention Permit Chief, Bureau of WastePrevention, within 15 days of said revision(s).

67. That the MWRA shall maintain on-site, at all times, an up-to-date copy ofthe required SOMP.

Fore River Staging Area Apphcation No.Sludge Processing Expansion and Modification MBR-95-IND-056Page 35

RECORDKEEPINQ AND REPORTING REQUIlEMENTS FOR THE EXISTINGINTERIM SLUDGE PROCESSING AND DISPOSAL FACILITY

68. That the MWRA shall maintain adequate daily records for the existingISP&D Facility. These records shall contain, at a minimum, the followinginformation:

a) Hours of operation of each sludge drying process train; and

b) Amount of sludge processed in each sludge drying process train, inpounds of dry sludge per hour; and

c) Daily cumulative emissions of PM, NOx, CO, VOC, SO,, NH,, and12S; and

d) Any other data necessary to demonstrate compliance with theemission limits set forth in Proviso Nos. 30, 31, and 34.

These records shall be maintained at the facility for three years followingthe date of the reports (see Proviso No. 71), and shall be made available toDepartment personnel upon request.

69. That the MWRA shall keep adequate on-site maintenance log books for theexisting ISP&D Facility. These log books shall contain, at a minimum, thefollowing information:

a) All relevant maintenance performed on the rotary drum dryers, thebelt filter presses, the dual cyclones, the venturi scrubber, the packedtower, the regenerative thermal- oxidizers, and the opacity monitoringequipment; and

b) All equipment malfunctions (time, date, downtime, when restored,etc.); and

c) All calibrations which were performed on the opacity monitors.

Tore River Staging Area Application No.Sludge Proemng Expansion and Modification MBR-95-IND-056Page 36

These records shall be maintained at the facility for three years and shallbe made available to Department personnel upon request.

TO. That the MWRA shall maintain an Environmental Logbook which shallrecord actions relative to environmental issues (accidental or emergencyreleases, etc.) and overall emission changes associated with the existingISP&D Facility. The MWRA shall record information such as the results offederal, state. or local environmental inspections; maintenance or correctiveactions which affect air emissions related to the operation of the pollutioncontrol equipment; and measures taken to lower emissions from the subjectequipment to the environment (air, water, etc.). This Logbook shall bemade available to Department personnel upon request.

71. That the MWRA shall submit quarterly compliance reports to this Office,attention Compliance and Enforcement Chief. Bureau of Waste Prevention.These quarterly reports shall be submitted within 21 days of the end ofeach quarter, and shall contain the following information, based on a 365-day rolling period:

a) Hours of operation of each sludge process train; and

b) Average amount of sludge processed in pounds of dry sludge per hour;and

c) Facility-wide emissions of PM, NOx, CO, VOC, SO,, NH,, and HS, intons per 365 day rolling period.

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Fore River Staging Area Application No.Sludge Processing Expansion and Modification MBR-95-IND-056Page 37

RECORDKEEPING AND REPORTING REQUIREMENTS FOR THE FINALSLUDGE PROCES&NG AND DISPOSAL FACILTY

72. That the MWRA shall maintain adequate daily records for the Final SludgeProcessing and Disposal Facility. These records shall contain, at aminimum, the following information:

a) Hours of operation of each sludge drying process train; and

b) Amount of sludge processed in each sludge drying process train, inpounds of dry sludge per hour; and

c) Daily cumulative emissions of PM,, NOx, CO, VOC, SO,, NH,, andHS; and

d) Any other data necessary to demonstrate compliance with theemission limits set forth in Proviso Nos. 44, 45, and 47.

These records shall be maintained at the facility for three years followingthe date of the reports (see Proviso No. 75), and shall be made available toDepartment personnel upon request.

73. That the MWRA shall keep adequate on-site maintenance log books for theFinal Sludge Processing and Disposal Facility. These log books shallcontain, at a minimum, the following information:

a) All relevant maintenance performed on the rotary drum dryers, thedewatering systems, the venturi scrubbers, the packed towers, theregenerative thermal oxidizers, and the opacity monitoringequipment; and

b) All equipment malfunctions (time, date, downtime, when restored,etc.); and

c) All calibrations which were performed on the opacity monitors.

Fore River Staging Area Application No.Sludge Processing Expansion and Modification MBR-95-IND-056Page 38

These records shall be maintained at the facility for three years and shallbe made available to Department personnel upon request.

74. That the MWRA shall maintain an Environmental Logbook which shallrecord actions relative to environmental issues (accidental or emergencyreleases, etc.) and overall emission changes associated with the Final SludgeProcessing and Disposal Facility. The MWRA shall record information suchas the results of federal, state. or local environmental inspections;maintenance or corrective actions which affect air emissions related to theoperation of the pollution control equipment; and measures taken to loweremissions from the subject equipment to the environment (air, water, etc.).This Logbook shall be made available to Department personnel uponrequest.

75. That the MWRA shal submit quarterly compliance reports to this Office,attention Compliance and Enforcement Chief, Bureau of Waste Prevention.These quarterly reports shall be submitted within 21 days of the end ofeach quarter, and shall contain the following information, based on a 365-day rolling period:

a) Hours of operation of each sludge process train; and

b) Average amount of sludge processed in pounds of dry sludge per hour;and

c) Facility-wide emissions of PM,, NOx, CO, VOC, SO, NH3, and 1 8, intons per 365 day rolling period.

Failure to comply with any of the above stated provisions will constitute aviolation of the "Regulations", and can result in the revocation of the approvalgranted herein. This approval may also be revoked by the Department if theconstruction work is not begun within two years from the date of issuance of thisapproval, or if the construction work is suspended for a period of one year ormore.

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Fore River Staging Area Application No.Sludge Processing Expansion and Modification MBR-95-IND-056Page 39

The Department has determined that the filing of an EnvironmentalNotification Form (ENF) with the Secretary of Environmental Affairs. for airquality control purposes. was not required prior to this action by the Department.Notwithstanding this determination, the Massachusetts Environmental Policy Act(MEPA) and Regulation 301 CMR 11.00, Section 11.03, provide certain "Tail-SafeProvisions" which allow the Secretary to require the filingof an ENF and/or anEnvironmental Impact Report at a later time.

This plan approval is an action of the Department. If you are aggrieved bythis action, you may request an adjudicatory hearing. A request for a hearingmust be made in writing and postmarked within twenty-one (21) days of the dateyou received this plan approval.

Under 310 CMR 1.01(6)(b). the request must state clearly and concisely thefacts which are the grounas for the request, and the relief sought. Additionally,the request must state why the plan approval is not consistent with applicablelaws and regulations.

The hearing request along with a valid check payable to the Commonwealthof Massachusetts in the amount of one hundred dollars ($100.00) must be mailedto:

Commonwealth of MassachusettsDepartment of Environmental ProtectionP.O. Box 4062Boston, MA 02211

The request will be dismissed if the filing fee is not paid, unless theappellant is exempt or granted a waiver as described below.

The filing fee is not required if the appellant is a city or town (or municipalagency), county, or district of the Commonwealth of Massachusetts, or a municipalhousing authority. -

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Fore River Staing Area Application No.Sludge Processing Expansion and Modification MBR-95-IND-056Page 40

The Department may waive the adjudicatory hearing filing fee for a personwho shows that paying the fee will create an undue financial hardship. A personseeking a waiver must file, together with the hearing request as provided above,an affidavt setting forth the facts believed to support the claim of undue financialhardship.

Please be advised that this approval does not negate the responsibility ofthe MWRA to comply with this or any other applicable federal, state, or localregulations now or in the future. Nor does this approval imply compliance withthis or any other applicable federal, state, or local regulations now or in thefuture.

Should you have any questions concerning this matter, please do nothesitate to contact Mrs. Rachel Quill at the Metropolitan Boston/NortheastRegion, 10 Commerce Way, Woburn, Massachusetts 01801.

Sincerely,

Icel 'ui ames E. Be

Environmental Engineer ermit ChiefBureau of Was e Prevention

cc: Board of Health, 1120 Hancock Street. Quincy, MA 02169Fire Headquarters, 26 Quincy Avenue, Quincy, MA 02169Board of Health, Town Hall, Braintree, MA 02184Fire Headquarters, 9 Union Plae, Braintree, MA 02184DEP, DAQC, One Winter Stra, Baston, MA 02108Attn: Mr. Walter SullivanDEP, DWPC, One Winter Street, Bston, MA 02108Att: Mr. Steven LipranDEP, DWPC, One Winter Stret, Baton, MA 02108Attn: Mr. Dennis DunnDEP, DAQC, NEROAttn: Mr. Thomas Parks r

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I,

Application No.MBR-95-IND-056

United States Environmental Protection Agency, J.FX Federal Building, Boston, MA 02203Attn: Mr. Jerry PotamisMaseachusetts Water Resources Authority, Charlestown Navy Yard, 100 First Avenue,Boston, MA 02129 - Attn: Mr. Leon LatailleTech Environmental. Inc., Reservoir Place, 1601 Trapelo Road, Waltham, MA 02154Attn: Mr. Keith KennedyTighe & Bond Consulting Engneers, Westfield Executive Park, 53 Southampton Road,Westfield, MA 01085 - Attn: Mr. Todd M. BrownNew England Fertilizer Company, 97 East Howard Street, Quinty, MA 02169Attn: Mr. Craig R. DolanMr. David Standley, Consultant in Environmental Management, 4 South Main Street,Ipswich, MA 01938Tellus Institute, 11 Arlington Strest, Boston, MA 02116Attn: Mr. James Goldstein

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Fore River Staging AreaSludge Processing Expansion and ModificationPage 41

II

*CRC4 MASSACHUSETTS WATER RESOURCES AUTHORITY

Charlestown Navy Yard100 First Avenue

Boston, Massachusetts 02129

Telephone: {617) 242-6000Facsimile. (617) 241-6070

September 19, 1996

PUBLIC NOTICE RE: CONSULTANTS DETERMINATION andLSP LETTER OF OPINIONMWRA Fore River Staging Area(former General Dynamics Shipyard)Release Tracking No. 3-0536 and 3-10266

Dear Interested Party:

Please be advised that GZA GeoEnvironmental, Inc. (GZA), the Consultant ofRecord for the Massachusetts Water Resources Authority (MWRA) and for WaterTransportation Alternatives, Inc. (WTA), has prepared a Licensed Site ProfessionalLetter of Opinion and a Consultant's Determination for a portion of the MWRA's ForeRiver Staging Area, Quincy, Massachusetts. These documents pertain to WTA'sproposal to develop a portion of the Fore River Staging Area as a commuter parking lotand ticketing area for a water shuttle service to be established by WTA at this locationunder a lease from the MWRA.

In accordance with the Fore River Staging Area Notice of Land Use Stipulation,this portion of the property is currently restricted to business office or industrial use.Before any other use is allowed, a Consultant's Determination is required to demonstratethat a condition of no significant risk to public health, welfare, or the environment willexist under the proposed use. In accordance with the Fore River Staging Area PublicInvolvement Plan, the Consultant's Determination and the Licensed Site ProfessionalLetter of Opinion on which the Determination is based have been made available forpublic review and comment. Copies of these documents may be reviewed at thefollowing locations:

Thayer Public Library, 798 Washington Street, Braintree

Tufts Public Library, 46 Broad Street, Weymouth

Thomas Crane Public Library, 40 Washington Street, Quincy

MWRA Library, 100 First Avenue, Charlestown Navy Yard, Boston

Printed on 100% Recycled Paper

Please forward all comments to the attention of:

Mr. Jose VincentyPublic Contact PersonMWRACharlestown Navy Yard100 First AvenueBoston, MA 02129

The 20-day public comment period for these documents will expire on October 11,1996.

DISTRIBUTION: Public Involvement Plan Mailing List

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STAFF SUMMARY

TOFROM:DATE:SUBJECT:

Board of Directors ViDouglas B. MacDonald, Executive DirectorSeptember 11, 1996Water Transportation Alternatives, Inc., United States NavalShipbuilding Museum and MWRA: Arrangements at FRSA forWater Shuttle Service to Logan Airport and Downtown Boston

COMMITTEE: Administration & Finance InformationX Vote

Maggie Debbie, Director, Real Prop./Env. Mgmt. Thomas B. PowersPreparer/Title Division Director Approval

This matter was presented to the Board at the meeting of August 14 andwithdrawn to permit the staff to gather additional information, conduct furtherdiscussions with WTAI and the City of Quincy, and answer questions raised byvarious Board members. This staff summary supersedes the staff summary ofAugust 14, 1996.

RECOMMENDATION:

To authorize the Executive Director to enter into the following arrangements forthe use of a portion of the FRSA to support a water shuttle service serving LoganAirport and Long Wharf from Quincy: (1) amend the lease with the United StatesNaval Shipyard Museum, Inc. (the Museum), to increase its leased area from11.5 acres to approximately 14.5 acres; (2) authorize a sublease from the Museumto Water Transportation Alternatives, Inc. (WTAI) for purposes of operating apassenger water shuttle service including providing parking for patrons; (3) enterinto financial arrangements whereby WTAI shall pay rent in a monthly baseamount plus (commencing in 1999) a $1 per parked car per day additional rentand providing for division of those rental receipts between the Authority and theMuseum as specified in this staff summary; and (4) to make other necessaryarrangements to achieve the service objectives outlined in this staff summary.

DISCUSSION:

Backrround

This water shuttle initiative emerges from an RFP conducted by Massport inFebruary, 1996 to attract a second passenger water shuttle service to LoganAirport. The RFP is part of the "Logan 2000" modernization plan which includessteps to reduce the airport's dependence on automobile access. Expanded watershuttle service to Logan also contributes to mitigation commitments and trafficplanning needs for the Central Artery Project. The proposed service is supported

a 7

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by all the relevant transportation agencies and the state Executive Office ofEnvironmental Affairs as well as by both the City of Boston and the City of Quincy(more detail below). The existing Logan water shuttle service, operated by one ofthe Beacon Companies, connects the airport only with Rowes Wharf.

WTAI was one of two bidders (the other was Beacon) responding to the MassportRFP. In May 1996 WTAI was designated by Massport staff1 The WTAI proposalemphasized the opportunity to expand water passenger ridership to and fromLogan by providing a new service linking the South Shore (now Quincy), LongWharf and the Airport. Selling points of the proposal included frequentdepartures matched to air traffic demand (for example, boat departures fromLogan would vary from 22 to 26 per day depending on day of week) and theprovision of a high amenity service with new vessels equipped with luggageracks, snack bars and other features appealing to commuters and air travellers.The proposed fare between Quincy and the Airport is $10.00 and between Quincyand Long Wharf is $5.00. A separate parking charge in Quincy would be set at aday rate of $2.00 and an overnight rate of $6.00. Projected one-way daily ridershipwould start at 300 passengers per day, growing to 1800 passengers per day, orapproximately 556,000 passengers per year, of which about 65% would be expectedto travel to and from the Airport. (By contrast, the current Rowes Wharf shuttlecarries an average passenger volume of 650 per day; the Hingham-Bostoncommuter ferry carried over 600,000 passengers in 1995.)

Key projections prepared by WTAI as part of its pro forma plan submitted toMassport include:

1 Arrangements at Massport are expected to be completed under delegated authority; Massportstaff expect to submit to the Massport Board the equivalent of an "information only" staffsummary after all arrangements, including the terminal arrangements, are concluded

2

1997 1999 2001

Weekday Ridership 1,142 1,700 1,800(75% to Logan)Weekend Ridership 571 800 800(25% to Logan)

Fare Revenues $2,717,000 $4,106,000 $4,318,000

Parking Revenues $673,000 $1,021,000 $1,081,000

From these projections, MWRA staff have derived a rough benchmark of car/parkdays as follows:

WTAI's principal executives are two graduates of Mass. Maritime Academy whodeveloped the proposal with support from a financial and operating company,American Overseas Marine Corporation (AMSEA), a subsidiary of the GeneralDynamics Corporation.- AMSEA now owns WTAI. Two 149-passenger water-jetcatamarans to provide the service are now being built in Somerset, Mass. at theGladding-Hearn Shipbuilding yard.

Terminal Arrangements at Logan Airport and Long Wharf

At Logan Airport the service will terminate at the float and pier already used bythe Rowes Wharf shuttle. Passengers will be inoved to and from the airlineterminals on the Massport shuttle buses that already serve the Rowes Wharf boat.Massport will make no charge to WTAI for the use of the pier, but after April 1998WTAI will pay a fee of $1.50 for each passenger to offset a portion of the cost of thebus service. (The delay in Massport's charge is intended to help WTAI defray itsapproximately $50,000 cost for necessary changes to the float to accommodate thebow-loading configuration of the WTAI vessels.) Massport has advised MWRAthat WTAI's payment will only partially cover the per passenger shuttle bus cost;the resulting subsidy to WTAI is intended to support the overall benefits toMassport of reduced automobile congestion to, from and at the Airport. Theanticipated Massport/WTAI agreement is in the form of a three year operatingagreement with two extensions for three years each exercisable by WTAI unlessits annual ridership is less than 200,000 in the year preceding the renewal. (TheFRSA arrangements will be terminable if at any time the WTAI license at LoganAirport ceases to be in effect.)

On the Boston waterfront the service will terminate at Long Wharf, a propertyowned by the BRA. BRA voted at its meeting of September 4, 1996 to approve a fiveyear lease (plus one five year extension at lessee's option) for approximately 100square feet of space on Long Wharf and a water area of approximately 9,000square feet in which to locate the service float. The rent to the BRA has been set at$18,000 per year subject to an escalation for inflation. In addition WTAI willconstruct and pay for site improvements on Long Wharf at the entry point to itsramps at an estimated cost of $50,000 - $75,000.

3

Days Spaces Use Factor Car Days

Weekdays 250 900 0.9 202,500

Weekends 110 900 0.7 69,300

Total 360 - - 271,800

Terminal Arrangements in Quincy

WTAI originally anticipated that the South Shore terminal would be at the formerBECo Edgar Station in Weymouth. However, discussions in April began toexplore the possibility of using space leased by MWRA to the United States NavalShipbuilding Museum at the Fore River Staging Area for parking and the float.MWRA staff contacted at that time advised WTAI that because of the existinglease to USNSM, any arrangements regarding that site would have to be broughtto the MWRA through and with the concurrence of USNSM.

WTAI then entered into further discussions with USNSM and Mayor Sheetsabout the terminal and parking possibilities and any attendant traffic, economicdevelopment and neighborhood impacts. The USNSM was receptive to theproposal because its own parking demand has not yet expanded to utilize theentire area it had originally leased from MWRA for parking purposes.Discussions included MWRA in June 1996 because of the need to secure MWRAapproval of this leasehold use of the USNSM area and also the. need to add alimited area not then leased to the USNSM for location of the service float. Theproposal before the Board is intended to effectuate the use of the Fore RiverStaging Area generally in accordance with this plan.

WTAI has had an expectation of additional support for the construction of thefloats at Long Wharf and FRSA from the Executive Office of Transportation andConstruction. If this support does not materialize, WTAI will bear the cost ofconstructing the floats. Therefore, the service is not dependent on EOTC'sinvolvement.

Suitability of the Proposed Use of the Fore River Staging Area

The area of the proposed use of the Fore River Staging Area is shown on thefollowing sketch, which also delineates the area now under lease to the USNSM(11.5 acres; lease expires 2003 with two five-year options) as well as the new areaproposed to be made available by MIWRA (3.0 acres, approximately 60% of which iswater surface). The use of this area to support a water shuttle service to Bostonand Logan Airport is entirely consistent with the development blueprint for FRSAproduced through the community-based planning process with which the Boardis familiar.

The FRSA Development Plan envisioned Harbor Island access from the northportion of the site, with the possibility of a public access area foreducational/cultural activities. The museum and the water shuttle dock providea strong base for this part of site development. With the synergy of the watershuttle it is expected that the Museum's visibility and its visitor count willincrease.

In addition, the adjacent lot is the proposed location of the Marine EngineeringCenter, a facility for development and manufacturing of products related tomarine transportation and structures. A recent focus group of interestedindustry leaders voiced support for a water route to Logan Airport, and saw it as abenefit and added attraction to potential users

4

USNSM LEASE AREA AND PROPOSED ADDITION FOR WTAI-

In order to use the proposed parking area, WTAI must relocate track on the sitein order to accommodate storage of back-up rail cars for the NEFCO sludge-to-fertilizer operation. This relocation will be performed by WTAI at a cost not-to-exceed $130,000, with one-half of its expense to be recouped from the $1 percar perday fee (see below) it will commence to pay in 1999.

WTAI has also undertaken to contract other site improvements to the parkingarea including fencing, lighting, grading, paving, striping, traffic control gates,and installation of water/sewer connections to the ticket facility. WTAI hasestimated its cost for these improvements to be approximately $750,000.

WTAI will provide a $5 million general liability coverage naming MWRA asadditional insured, other routine insurance, a $1 million Watercraft insurancepolicy, and certain customary lease indemnnifications.

WTAI will also bear the cost of a requirement owed MWRA in the USNSM lease toprepare and file a change in the Notice of Land 'Use stipulation at the registry ofdeeds. This will raise the stipulated land use to accommodate public access ascontrasted to the current industrial/business use classification under the DEPWaiver of Approvals issued in March 1994 pursuant to the MassachusettsContingency Plan. This and the required underlying analysis notice is beingprepared for WTAI by GZA at a cost of approximately $50,000.

5

WTAI has also filed the necessary Chapter 91 application for the docking facilityand a Notice of Intent with the Quincy Conservation Commission.

In July, WTAI filed a notice of project change with MEPA to account for theexpectation that the proposed parking arrangements at the USNSM wouldexpand from about 500 cars to about 950 cars. MEPA's decision is expected bySeptember 15th on whether further environmental analysis must be performedeither on the parking itself or on ancillary impacts on the Route 3A rotary or ForeRiver Bridge. The belief of WTAI and the City of Quincy is that no further MEPAwork will be required.

Financial Issues Regarding Rents

The other issues involve the rent and fall into two categories: (1) the overallpayment to be made by WTAI for use of the FRSA acreage, and (2) the division ofthat payment stream between USNSM and MWRA.

Payment to be made by WTAI for its use of FRSA area

When this matter was presented to the Board at the meeting on August 14, 1996,members of the Board were not in agreement that a ten-year term for WTAI's useof the FRSA should be coupled with a to-be-determined rental rate applicable toyears 6 - 10 of the lease. The staff, the Museum and WTAI have subsequentlyagreed to a rental term consisting of a base monthly rent plus additional rent df $1per car per day commencing January 1, 1999. The base rental amounts are asfollows:

Calendar Year Monthly Base Rent

1996 $1,2001997-2000 $4,0002001 $5,0002002-2006 $6,000

Overall rent levels will depend heavily on the actual level of parking use. Thefollowing projection is used for illustrative purposes only, assuming that WTAIachieves parking counts in 1999 of 258,210 (95% of the benchmark shown on p. 3),271,800 car/days in 2001 (100% of the benchmark), and 285,390 car/days in 2003(105% of the benchmark).

.4.t YeiQ__ _ __ _ '9 00 0

B~ Rn %800 4B DOC [ $2sujo 0oc srVE63Oo

* Prior to a credit allowed to WTAI in the amount of up to $65,000 representing 50% of thecost WTAI incurs in relocatinq railroad storaqe track now located on the parkin site.

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Because the service is subject to start-up risks and uncertain ridership levels, theforegoing illustrations of the rent mechanism cannot be.taken as firm projectionsof actual future rental levels. The actual revenue potential of the arrangementwill only be reliably forecast after the start-up period.

Division of the Rent Receipts Between MWRA and the USNSM

The respective positions of MWRA and USNSM might be compared to two partieseach of whom has the key to the lock on one of the two chains that keeps a gatefrom being opened. Opening the gate represents enabling WTAI's parking andshuttle service to operate from FRSA, a public interest objective agreed upon by allthe transportation and civic parties. But the gate cannot be opened until MWRAand USNSM are each satisfied that to do so is in its own interest, since eitherparty withholding its key keeps one chain locked on the gate. The chain "owned"by USNSM is its remaining 7 years (plus options) lease on most of the site. Thechain owned by MWRA is the need to approve the site use and the contribution ofa small amount of additional acreage illustrated in the plan. The City of Quincyis a highly interested observer because of its interest in the vitality of both theUSNSM and the new shuttle service as sound underpinnings for economicgrowth, tourist promotion, land use and traffic planning for the immediate areaand the surrounding neighborhood. There are interests MWRA shares becauseof their importance to the overall FRSA Development Plan. Both USNSM andMWRA are in the position that any revenue developed from implementation of theproposal is a benefit compared to non-use of the site.

The proposed division of revenue between USNSM and MWRA is based on theprincipal that the monthly base rent shall be divided between them in thefollowing percentages:

3 mos./1996 1997 1998 1999 2000 2001 2002-2006

Base Rent $3,600 $48,000 $48,000 $48,000 $48,000 $60,000 $72,000

MWRA $2,487 $18,000 $18,000 $18,000 $18,000 $30,000 $36,000

Museum $1,113 $30,000 $30,000 $30,000 $30,000 $30,000 $36,000

Museum's % . 69% 62.50% 62.50% 62.50% 62.50% 50.00% 50.00%

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01Further to the base rent, the additional rent from the receipt of $1 per car per dayshall be divided between them according to the following sliding scale:

Annual up to $50,000- $100,000 - overReceipts $50,000 $100,000 $150,000 $150,000

MWRA 60% 70% 80% 90%Museum 40% 30% 20% 10%

The result of this division will vary depending on the level of receipts for the $1 percar per day fee. Using the parking assumptions in the shaded table on page 5, theparties receipts at several yearly snapshots of the arrangement would be asfollows:

1997 1999 2001 2003MWRA

base rent $18,000 $18,000 $30,000 $36,000addil. rent - $137,389 $214,620 $226,851

Subtotal $18,000 $155,389 $244,620 $262,851Museum

base rent $30,000 $30,000 $30,000 $36,000addil. rent - $55,821 $57,180 $58,539

Subtotal $30,000 $85,821 $87,180 $94,539

Total $48,000 $241,210 $331,800 $357,390

The City of Quincy is strongly supportive of this division arrangement because ofits belief in the importance that the museum and the water shuttle service shouldbe mutually supportive.

BUDGET AND FISCAL IMPACT:

The Museum currently pays the MWRA $1,000 per month rent After October1998, MWRA is entitled to rent of 10% of the first $500,000 of the Museum's grossrevenue and 15% of revenue beyond that

8

0 0To: Iris Davis@BWSC PRR@DEP NERO

Sharon Gobiel@BWSC ASM@DEP NERONancy Fitzpatrick@BWSC ASM@DEP NERO

Cc: Alan Slater@MA@DEP BostonRonald Lyberger@MA@DEP BostonJudith Perry@BRP WW@DEP Boston

Bcc:From: Steven Lipman@BRP WPC@DEP BostonSubject: MWRA, Braintree/Weymouth-Haz. Mat. PlanDate: Friday, June 28, 1996 12:42:45 EDTAttach:Certify: NForwarded by:

Hello my favorite people. Just an update FYI regarding this MWRA Project. Ijust received for review/comment an Amendment to the Haz. Mat. Plan fromStone & Webster for site investigations for another portion of the MWRABraintree/Weymouth Project, this element being options for getting aconnection from the proposed B/W Intermediate Pump Station located on theBECo/Sprague Site across the Fore River to the Pelletizing Plant at the ForeRiver Staging Area( aka Quincy Shipyard).

15 borings will be installed at the BECo/Sprague Site; 7 of which will be forcollection of soil with 5 turned into monitoring wells. As we requested atthe meeting we had with them they will include surficial sampling at 13locations and analyze for Cyanide.

They will collect sediment samples at 8 locations in the Fore River foranalysis. I have requested that they include Reactive Sulfides in theanalysis plan.

At the Shipyard they will punch 13 borings with 5 turned into wells.

Overall the proposal looks reasonable, and since they only gave me a coupleof days to look at it I don't intend to perform a real detailed review. I didask them for an additional copy of the plan and will forward to NERO for yourinfo. and files as soon as I receive it.

JUN-27-96 THU 13:,1 MWRA B31 3rd FLR RECP

MASSACHUSETTS WATER RESOURCES AUTHORITYCharlestown Navy Yard

100 First AvenueBoston, Massachusetts 02129

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Daniel S. Greenbaum

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* Woburn, Massachusetts 01801 * FAX (617) 935-6393 * Telephone (617) 935-216010 Commerce Way

S 0COMMONWEALTH OF MASSACHUSETTSEXECUTIVE OFFICE OF ENVIRONMENTAL AFFAIRSDEPARTMENT OF ENVIRONMENTAL PROTECTIONONE WINTER STREET, BOSTON MA 02108 (617) 292-5500

6 9 b1

TRUDY COXESecretary

DAVID B. STRUHSCommissioner

May 13, 1996

Jan Reitsma, DirectorMEPA UnitExecutive Office of EnvironmentalAffairs20th Floor100 Cambridge StreetBoston, MA 02202

Re: ENF - EOEA #10692Sale of 130 Acres of theQuincy Shipyard

Dear Mr. Reitsma:

This correspondence includes the Department of EnvironmentalProtection's (DEP) consolidated comments regarding the abovereferenced Environmental Notification Form Filing. Initially, DEPwould like to indicate its full support for bringing shipbuildingactivities back to the Quincy Fore River Shipyard and views theseactivities as the best and highest use for this property as it islocated in a Designated Port Area (DPA) and is the historical usefor this site. MHI's proposal is also compatible with MWRA'sexisting and future uses at the site.

During the past ten (10) years, the MWRA and General Dynamics,in cooperation with DEP's Bureau of Waste Site Cleanup, have spentconsiderable time and money to assess and remediate the QuincyShipyard due to prior releases and spills of Oil and HazardousMaterials (OHM), most of which were related to the historicshipbuilding and repair activities at the site. It will thereforebe important that future shipbuilding activities be performed instrict compliance with all State and Federal statutes andregulations related to the handling, use and disposal of OHM andhazardous wastes at the site, so as not to undo the millions ofdollars and effort expended to remediate the site.

0 Pnnied on Recyded Paper

WILLIAM F. WELDGovernor

ARGEO PAUL CELLUCCILt. Governor

It will also be critical that all activities by MHI notinterfere with MWRA's existing and future uses at those portions ofthe site that they will be retaining, the key activities beingoperation of the Biosolids Drying/Pelletizing Plant and RO/ROFacility.

MEPA is probably aware that the neighborhoods surrounding theQuincy Shipyard site have been very active with regard tocontrolling noise and odor impacts from MWRA activities at thesite, and in this regard MWRA has taken numerous steps to ensurethat its activities do not cause off-site impacts. Shipbuildingactivities will also have the potential for off-site noise and odorimpacts and it will be incumbent upon MHI to carefully considerthese issues in development of its facilities, and operationalcontrols.

Specific Comments

Air Ouality Issues

1. MHI must implement measures to alleviate dust, noise and odornuisance conditions which may occur during and after anyconstruction in any portion of the 130 acres. Such measuresmust comply with DEP Regulations 310 CMR 7.01, 7.09 and 7.10.In addition, the Bureau of Waste Prevention (BWP) must benotified in writing ten days prior to commencement of anydemolition.

2 MHI must comply completely with Regulation 310 CMR 7.15regarding removal of any asbestos that may be disturbed duringconstruction in any portion of the site.

3. MHI must submit plan applications to DEP's Division of AirQuality Control (DAQC) for any construction, substantialreconstruction, or alteration subject to the requirements of310 CMR 7.02, and receive written approval from the Departmentprior to the commencement of said construction, substantialreconstruction, or alteration. In particular, criteriapollutants resulting from proposed painting operations, andenergy input capacities for proposed power plant (s) operationmay trigger 310 CMR 7.02 plan review requirements.

4. MHI must comply with the Requirements of 310 CMR 7.00,Appendix C, if the operation of any equipment and/or processesto be installed in any portion of the site would result in sumtotal emissions of criteria pollutants and/or Hazardous AirPollutants at "major" levels.

Waterways Regulation Program

Staff from DEP's c.91 Waterways Regulation Program attendedthe May 8th MEPA Project Site Visit and stated that MHI's proposednew building would be situated at least partially within formerlyfilled tidelands and as such will require a c.91 License. Theproject is a Water Dependent Activity and DEP does not anticipateany permitting difficulties with the proposal as described at theSite Visit.

c.21E and the Massachusetts Contingency Plan

As indicated earlier, the Quincy Shipyard (a.k.a. Fore RiverStaging Area) has been undergoing site assessment and remediationactivities by the Mass. Water Resources Authority (MWRA) andGeneral Dynamics (GD) for historic releases/spills of OHM under a21E "Waiver of Approvals" issued to MWRA and GD in 1994. Duringthe past few years extensive areas of the Site have been assessedand remediated in accordance with c.21E/MCP and the Site Waiver.The level of site cleanup has been based on the assumption that theforeseeable future use of the Site will remain "industrial orbusiness office in nature" and the MHI proposal is consistent withthat use restriction.

The proposed construction activities on the Site by MHI willneed to be carefully designed and implemented so as to minimizeexposure to construction workers and other individuals on and offthe project site to OHM which may be encountered duringconstruction and excavation activities. As part of DEP'scoordination with MWRA to allow for its ongoing constructionactivities on the Site, a detailed Construction Procedures Documentwas developed which is utilized by MWRA and any of its contractorswhenever site intrusive activities are performed. The Notice ofLand Use Stipulation for this site includes the requirement that aHazardous Materials Management Plan be developed and implementedwhen construction activities are performed by other entities on theSite, which may involve disturbance of contaminated soil and/orgroundwater. DEP recommends that MHI expeditiously develop such aplan for any work that they, or any of their contractors, intendsto perform on the Site. This will be particularly important if MHIperforms any site intrusive work within or near the "centralpetroleum plume area" on the Site.

With regard to issues of existing site contamination, DEPstaff are working with MHI, MWRA and GD to devise a mutuallyagreeable procedure to ensure compliance with c.21E/MCP whileallowing MHI to expeditiously proceed forward with its proposedconstruction and operations at the site. In this regard, attachedis a copy of May 10, 1996, correspondence from DEP which describesissues of liability and future actions relative to c.21E and theMCP.

Stormwater and Facility Ooeration Discharaes

About four years ago, as part of MWRA's construction of theFRSA Biosolids Drying/Pelletizing Plant, the Authority prepared andsubmitted to EPA and DEP a sitewide NPDES Permit for all existingand potential surface water discharges, including those related toshipyard facilities. After initial review of the application, EPAand DEP determined that a sitewide permit was not necessary toallow for proper management of stormwater from theDrying/Pelletizing Plant, and the application was placed inabeyance. Depending on the specific activities MHI intends toperform on the Site, some type of stormwater permitting may berequired. Staff from EPA and DEP will work with MHI to determineif any formal permitting will be necessary.

Feel free to contact me if you have any questions regardingthis correspondence.

Very truly yours,

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

SGL/wp9 reitsma

cc: Dave Shepardson, MEPAMaggie Debbie, MWRAMarianne Connolly, MWRASharon Gobiel, DEP/BWSCRachel Quill, DEP/DAQCDave Kennedy, DEP/WaterwaysJim Sprague, DEP/WetlandsDave Ferris, DEP/DAQCJane Downing, EPA/DEP

COMMONWEALTH OF MASSACHUSETTS

EXECUTIVE OFFICE OF ENVIRONMENTAL AFFAIRSDEPARTMENT OF ENVIRONMENTAL PROTECTIONONE WINTER STREET, BOSTON MA 02108 (617) 292-5500

WILLIAM F. WELD TRUDY COXEGovernor Secretary

ARGEO PAUL CELLUCCI DAVID B. STRUHSLt. Governor Commissioner

May 10, 1996

Mr. Greg SparkmanMaritime Administration400 7th StreetWashington, D.C. 20590

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

Dear Mr. Sparkman:

I am pleased to learn that the Massachusetts Heavy Industries Inc. (MHI) has agreed topurchase approximately 130 acres of the former Quincy Shipbuilding facility on East HowardStreet, Quincy ("the site") from MWRA. The site is currently a "non-priority, waiver-approvedsite" undergoing remediation for environmental contamination under MGL c. 21 E. I understandthe buyer, MIli, plans to re-institute a shipbuilding business on this site while remediation ofexisting contamination progresses. This arrangement would be an excellent opportunity to returnthis property to productive use, is very much in the public interest, and is in the spirit of theCommonwealth's Brownfields initiative.

I also understand that in the course of negotiations with MARAD regarding federal loanguarantees, concerns have been raised about potential liability pursuant to MGL. c. 21 E, the statestatute which establishes responsibility for responding to releases of oil and hazardous materialsto the environment. To speed conclusive negotiations, I write to indicate the Department ofEnvironmental Protection's readiness to formalize an agreement that the Department will not seekto hold MHI, its successors or its assigns, excluding currently responsible parties, responsible forcosts associated with remediation of existing contamination as of the date of execution of thedeed. The foregoing is offered on the condition that:

1. MI-1l complies with the provisions of the Notice of Land Use Stipulation recorded onMay 17, 1995 at Norfolk County Registry of Deeds, including applicable provisions ofthe Massachusetts Contingency Plan (MCP).

2. MHI agrees to assume responsibility to the extent it is liable pursuant to MGL c. 21Efor any oil or hazardous material releases that occur after the date on which the deed isexecuted.

0Pr-teit an Recyed Pape,

By way of amplification, there are several factors leading to my conclusion that theforegoing would be in the public interest. First, the site is classified as "non-priority" withrespect to the risks associated with the contamination on this site relative to other sites. Second,DEP has issued a Waiver of Approvals under the MCP (which allows response actions to proceedwithout Department oversight) and there is an agreement between the MWRA and GeneralDynamics to meet the Waiver of Approvals requirements. Third, there are clearly substantialopportunities to be provided by MHI for jobs and tax revenues for the citizens of theCommonwealth. Fourth, the anticipated uses of the site are expected to be related to maritimeactivities and are "industrial or business office in nature."

Sincerely,

David B. StruhsCommissioner

cc: Sotiris Emmanuel, MIDouglas MacDonald, MWRATrudy Coxe, EOEADavid Tibbets, EOEA

COMMONWEALTH OF MASSACHUSETTSEXECUTIVE OFFICE OF ENVIRONMENTAL AFFAIRS 6DEPARTMENT OF ENVIRONMENTAL PROTECTIONONE WINTER STREET, BOSTON MA 02108 (617) 292-5500

WILLIAM F. WELD TRUDY COXEGovernor Secretary

ARGEO PAUL CELLUCCI DAVID B. STRUHSLt. Governor Commissioner

MEMORANDUM:

TO: Willa Kuh

FROM: Steve Lipman

DATE: May 13, 1996

SUBJECT: Sale of 130 Acres of Former Quincy Fore RiverShipyard by MWRA to Mass. Heavy Industries, 21E/MCPLiability Issues

On May 9, 1996, at 2:30 this writer accompanied Jim Colman andSharon Gobiel (BWSC) to a meeting at EOEA with Henry Bell andSharon Pelosi (EOEA) , Jan Reitsma (MEPA) , MWRA, Executive Office ofEconomic Affairs, and Mass. Heavy Industries (MHI) to discuss howto deal with 21E/MCP issues relative to the sale of 130 acres ofthe former Quincy Shipyard (a.k.a. Fore River Staging Area) fromMWRA to MHI for reintroduction of full-scale shipbuilding at thesite. We first heard about this meeting on May 8th from JohnViola. We were told that MWRA and MHT were looking for a CovenantNot to Sue, or similar control of 21E liability, for historicreleases and spills at the Site.

Jim, Sharon and I me- with Peg Stolfa (OGC) at 2:00 before theEOEA meeting where we reviewed a draft letter that MWRA hadprepared and forwarded to EOEA, along with a letter which DEP sentto MWRA and a prior potential lessee (Northeast Shipbuilders, Inc.)in August 1994 to also limit 21E liability, but that deal fellthrough due to a lack of federal/state loan guarantees.

At the meting MHI representatives explained the area of thesite they intend to purchase and the facilities they plan toconstruct and operate. It appears that their facilities will notrequire extensive subsurface excavation. We reviewed the letterdrafted by MWRA for Secretary Coxe's signature (which we only heardabout and saw on May 9th even though EOEA had been in receipt ofthe draft for over a month) which was a revision to the August 1994DEP letter. After comparing and discussing the MWRA draft to the

0 Pnnted on Recyled Paper

prior DEP letter, the parties came to basic agreement on a newdraft that DEP would prepare and Commissioner Struhs would sign,before COB May 10th (to be presented on Monday May 13th to theFederal Maritime Adm. to receive approval for federal loanguarantees.

The letter was redrafted and hand delivered to EOEA and FAXedto the other key players by 10:00 on the 10th with a request forrevisions by 1:00 p.m. DEP received comments from MWRA, ExecutiveOffice of Economic Affairs and EOEA by 2:30, and a final version ofthe letter was signed by Ed Kunce, for the Commissioner, and handdelivered to EOEA and FAXed to the same players before 4:00 p.m.

Attached FYI is a copy of that letter. MEPA comments on thesale are due on May 14th, and a copy of our comment letter is alsoappended.

EOEA also agreed to assign an individual (MHI and MWRA wantsomeone from DEP) to expedite project permitting (my name wasmentioned). DEP actions will likely include: (1) 21E/MCP ongoingcoordination; (2) c.91 License; (3) stormwaterpermitting/management; and (4) air quality permitting. May alsoinclude other miscellaneous DEP permits/approvals such as: (1)cross-connection approvals; (2) industrial wastewater discharges,etc. It does seem logical that I play this role based upon my pastexperienced and knowledge about this Site. tet me know what youthink.

SGL/wp9:quincy

cc: Ed KunceJim ColmanBill GaughanSharon GobielPeg StolfaCarol WassermanBob GolledgeJohn SimpsonDave KennedyJim Sprague

CONAALTH OF MASSACHUSETTSExECUTIVE OFFICE OF ENVIRONMENTAL AFFAIRSDEPARTMENT OF ENVIRONMENTAL PROTECTION

S=ONE WINTER STREET, BOSTON MA 02108 (617) 292-5500

?CILLIAM F. WELD TRUDY COXEjovernor Secretary

A.RGEO PAUL CELLUCCI DAVID B. STRUHsLt. Governor commissioner

May 10, 1996

Mr. Greg SparkmanMaritime Administration400 7th StreetWashington, D.C. 20590

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

Dear Mr. Sparkman:

I am pleased to learn that the Massachusetts Heavy Industries Inc. (MHI) has agreed topurchase approximately 130 acres of the former Quincy Shipbuilding facility on East HowardStreet, Quincy ("the site") from MWRA. The site is currently a "non-priority, waiver-approvedsite" undergoing reniediation for environmental contamination under MGL c. 21 E. I understandthe buyer. MHl, plans to re-institute a shipbuilding business on this site while remediation ofexisting contamination progresses. This arrangement would be an excellent opportunity to returnthis property to productive use, is very much in the public interest, and is in the spirit of theCommonwealth's Brownfields initiative.

I also understand that in the course of negotiations with MARAD regarding federal loanguarantees, concerns have been raised about potential liability pursuant to MGL. c. 21E, the statestatute which establishes responsibility for responding to releases of oil and hazardous materialsto the environment. To speed conclusive negotiations, I write to indicate the Department ofEnvironmental Protection's readiness to formalize an agreement that the Department will not seekto hold MHI, its successors or its assigns, excluding currently responsible parties, responsible forcosts associated with remediation of existing contamination as of the date of execution of thedeed. The foregoing is offered on the condition that:

1. MHI complies with the provisions of the Notice of Land Use Stipulation recorded onMay 17, 1995 at Norfolk County Registry of Deeds, including applicable provisions ofthe Massachusetts Contingency Plan (MCP).

2. MHII agrees to assume responsibility to the extent it is liable pursuant to MGL c. 21Efor any oil or hazardous material releases that occur after the date on which the deed isexecuted.

06. Printed on Rrcwtled Paper

By way of amplification, there are several factors leading to my conclusion that the

foregoing would be in the public interest. First, the site is classified as "non-priority" with

respect to the risks associated with the contamination on this site relative to other sites. Second,DEP has issued a Waiver of Approvals under the MCP (which allows response actions to proceedwithout Department oversight) and there is an agreement between the MWRA and General

Dynamics to meet the Waiver of Approvals requirements. Third, there are clearly substantialopportunities to be provided by MHI for jobs and tax revenues for the citizens of theCommonwealth. Fourth, the anticipated uses of the site are expected to be related to maritimeactivities and are "industrial or business office in nature."

Sincerely,

David B. StruhsCommissioner

cc: Sotiris Emmanuel, MIDouglas MacDonald, MWRATrudy Coxe, EOEADavid Tibbets, EOEA

COMMONWEALTH OF MASSACHUSETTSEXECUTIVE OFFICE OF ENVIRONMENTAL AFFAIRSDEPARTMENT OF ENVIRONMENTAL PROTECTIONONE WINTER STREET, BOSTON MA 02108 (617) 292-5500

WILLIAM F. WELD TRUDY COXEGovernor Secretary

ARGEO PAUL CELLUCCI DAVID B. STRUHSLt. Governor Commissioner

May 13, 1996

Jan Reitsma, Director Re: ENF - EOEA #10692MEPA Unit Sale of 130 Acres of theExecutive Office of Environmental Quincy ShipyardAffairs20th Floor100 Cambridge StreetBoston, MA 02202

Dear Mr. Reitsma:

This correspondence includes the Department of EnvironmentalProtection's (DEP) consolidated comments regarding the abovereferenced Environmental Notification Form Filing. Initially, DEPwould like to indicate its full support for bringing shipbuildingactivities back to the Quincy Fore River Shipyard and views theseactivities as the best and highest use for this property as it islocated in a Designated Port Area (DPA) and is the historical usefor this site. MHI's proposal is also compatible with MWRA'sexisting and future uses at the site.

During the past ten (10) years, the MWRA and General Dynamics,in cooperation with DEP's Bureau of Waste Site Cleanup, have spentconsiderable time and money to assess and remediate the QuincyShipyard due to prior releases and spills of Oil and HazardousMaterials (OHM), most of which were related to the historicshipbuilding and repair activities at the site. It will thereforebe important that future shipbuilding activities be performed instrict compliance with all State and Federal statutes andregulations related to the handling, use and disposal of OHM andhazardous wastes at the site, so as not to undo the millions ofdollars and effort expended to remediate the site.

41Pnnted oh Recycled Pipe,

It will also be critical that all activities by MHI notinterfere with MWRA's existing and future uses at those portions ofthe site that they will be retaining, the key activities beingoperation of the Biosolids Drying/Pelletizing Plant and RO/ROFacility.

MEPA is probably aware that the neighborhoods surrounding theQuincy Shipyard site have been very active with regard tocontrolling noise and odor impacts from MWRA activities at thesite, and in this regard MWRA has taken numerous steps to ensurethat its activities do not cause off-site impacts. Shipbuildingactivities will also have the potential for off-site noise and odorimpacts and it will be incumbent upon MHI to carefully considerthese issues in development of its facilities, and operationalcontrols.

Specific Comments

Air uality Issues

1. MHI must implement measures to alleviate dust, noise and odornuisance conditions which may occur during and after anyconstruction in any portion of the 130 acres. Such measuresmust comply with DEP Regulations 310 CMR 7.01, 7.09 and 7.10.In addition, the Bureau of Waste Prevention (BWP) must benotified in writing ten days prior to commencement of anydemolition.

2 MHI must comply completely with Regulation 310 CMR 7.15regarding removal of any asbestos that may be disturbed duringconstruction in any portion of the site.

3. MHI must submit plan applications to DEP's Division of AirQuality Control (DAQC) for any construction, substantialreconstruction, or alteration subject to the requirements of310 CMR 7.02, and receive written approval from the Departmentprior to the commencement of said construction, substantialreconstruction, or alteration. In particular, criteriapollutants resulting from proposed painting operations, andenergy input capacities for proposed power plant(s) operationmay trigger 310 CMIR 7.02 plan review requirements.

4. MHI must comply with the Requirements of 310 CMR 7.00,Appendix C, if the operation of any equipment and/or processesto be installed in any portion of the site would result in sumtotal emissions of criteria pollutants and/or Hazardous AirPollutants at "major" levels.

Waterways Regulation Program

Staff from DEP's c.91 Waterways Regulation Program attendedthe May 8th MEPA Project Site Visit and stated that MHI's proposednew building would be situated at least partially within formerlyfilled tidelands and as such will require a c.91 License. Theproject is a Water Dependent Activity and DEP does not anticipateany permitting difficulties with the proposal as described at theSite Visit.

c.21E and the Massachusetts Contingenc Plan

As indicated earlier, the Quincy Shipyard (a.k.a. Fore RiverStaging Area) has been undergoing site assessment and remediationactivities by the Mass. Water Resources Authority (MWRA) andGeneral Dynamics (GD) for historic releases/spills of OHM under a21E "Waiver of Approvals" issued to MWRA and GD in 1994. Duringthe past few years extensive areas of the Site have been assessedand remediated in accordance with c.21E/MCP and the Site Waiver.The level of site cleanup has been based on the assumption that theforeseeable future use of the Site will remain "industrial orbusiness office in nature" and the MHI proposal is consistent withthat use restriction.

The proposed construction activities on the Site by MHI willneed to be carefully designed and implemented so as to minimizeexposure to construction workers and other individuals on and offthe project site to OHM which may be encountered duringconstruction and excavation activities. As part of DEP'scoordination with MWRA to allow for its ongoing constructionactivities on the Site, a detailed Construction Procedures Documentwas developed which is utilized by MWRA and any of its contractorswhenever site intrusive activities are performed. The Notice ofLand Use Stipulation for this site includes the requirement that aHazardous Materials Management Plan be developed and implementedwhen construction activities are performed by other entities on theSite, which may involve disturbance of contaminated soil and/orgroundwater. DEP recommends that MHI expeditiously develop such aplan for any work that they, or any of their contractors, intendsto perform on the Site. This will be particularly important if MHIperforms any site intrusive work within or near the "centralpetroleum plume area" on the Site.

With regard to issues of existing site contamination, DEPstaff are working with MHI, MWRA and GD to devise a mutuallyagreeable procedure to ensure compliance with c.21E/MCP whileallowing MHI to expeditiously proceed forward with its proposedconstruction and operations at the site. In this regard, attachedis a copy of May 10, 1996, correspondence from DEP which describesissues of liability and future actions relative to c.21E and theMCP.

Stormwater and Facility Operation Discharges

About four years ago, as part of MWRA's construction of theFRSA Biosolids Drying/Pelletizing Plant, the Authority prepared andsubmitted to EPA and DEP a sitewide NPDES Permit for all existingand potential surface water discharges, including those related toshipyard facilities. After initial review of the application, EPAand DEP determined that a sitewide permit was not necessary toallow for proper management of stormwater frQm theDrying/Pelletizing Plant, and the application was placed inabeyance. Depending on the specific activities MHI intends toperform on the Site, some type of stormwater permitting may berequired. Staff from EPA and DEP will work with MHI to determineif any formal permitting will be necessary.

Feel free to contact me if you have any questions regardingthis correspondence.

Very truly yours,

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

Sl L/wp9 reitsma

cc: Dave Shepardson, MEPAMaggie Debbie, MWRAMarianne Connolly, MWRASharon Gobiel, DEP/BWSCRachel Quill, DEP/DAQCDave Kennedy, DEP/WaterwaysJim Sprague, DEP/WetlandsDave Ferris, DEP/DAQCJane Downing, EPA/DEP

MAY-09-96 THU 11:22

MASSACHUSETTS WATER RESOURCES AUTHORITYCharlestown Navy Yard

100 First AvenueBoston, Massachusetts 02129

Telephone: (617) 242-6000FacsImile: (617) 241-6 200

BUILDING 34

FAX NO: 241-6200

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NUMBER OF PAGES(INCLUDING COVER SHEET)

Printed on 100% Recycled Paper

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MEMORANDUM

TO:

FROM

DATE:

RE:

the NoRegistr

Maggie Debbie, Director, Real Property & Environmental Mgmt.Mark Radville, Project Manager, Real Property & Environment Mgmt. t/

Christine E. Seward, Legal Assistant, Law Division

May 17, 1995

Notice of Land Use Stipulation - Parcels of land located in Quincyand Braintree, MA

'he attached Notice of Land Use Stipulation was recorded on May 17, 1995 atfolk County Registry of Deeds as Document #36965 and the Norfolk Countyr of the Land Court as Document #714486.

.'lease do not hesitate to contact me at ext. 1142 if you have any questions.

Enclos irecc *Irudy P. Reilly, Associate General Counsel

P.0?MWRAT334 3rd FIR REOP FAX NO. 6172416200

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NOTICE OF LAND USE STIPULATION

NOTICE is hereby given as of the 10t_ day of May 1995, byMass ichusetts Water Resources Authority, a public body corporate and politic, withan of ice at 100 First Avenue, Charlestown Navy Yard, Boston, Massachusetts("Gr ntor") that:

1. Grantor is the owner in fee simple of the land located in Quincy andBrain:ree, Norfolk County, Massachusetts, with the buildings and improvementsthere )n more particularly described on Exhibit A attached hereto and made a partherec (the "Property").

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

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

(a) activities in connection with the use of the Property forindus :xial and business office purposes; and

(b) such other activities which, in the opinion of (i) the "Consultantof Re ord" under the terms of the 'Waiver of Approvals" dated March 2, 1994 andgrant. d to Grantor; or (ii) a person licensed by the Board of Registration of WasteClean ip Professionals or any successor agency (a holder of such license hereinafterreferr d to as an "LSP'), present no greater risk of harm to health, safety, publicwelfa e or the environment than the use of the Property for industrial or businessoffice purposes. Such opinions shall be set forth in writing, signed and sealed by theConsi Itant of Record or the LSP, as applicable, and recorded and/or registered withthe al propriate Registry of Deeds and/or Land Registration Office. A certifiedRegis ry copy of the same shall be filed with DEP within 30 days of recording and/orregist -ation.

4. Any proposed change in activities and uses at the Property which mayresult in higher levels of exposure to oil and/or hazardous material than theexpos ires which would occur as a result of the use of the Property for the purposesset fo th in Section 3 above shall be evaluated (i) by the Consultant of Record,durin the term of the Waiver of Approvals, who shall make a determination(herei after the "Consultant's Determination") or (ii) by an LSP who shall render anLSP C pinion, in accordance with the DEP Waiver of Approvals and theMass chusetts Contingency Plan , as applicable, as to whether the proposed changeswill p -esent a significant risk of harm to health, safety, public welfare or theenvir< nment. Any and all requirements set forth in the Consultant'sDeter nination or LSP Opinion to ensure a condition of No Significant Risk in theimple nentation of the proposed activity or use shall be satisfied before any such

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activ ty or use is commenced, Such Determination or Opinion shall be set forth inwriti ig, signed by the Consultant of Record or the certifying LSP, as applicable, andrecor led and/or registered with the appropriate Registry of Deeds and/or LandRegi, tration Office. A certified copy of same shall be filed with DEP within 30 daysof re- ording and/or registration. Upon the recording of either the Consultant'sDete: mination or the LSP Opinion, the Property shall be conclusively presumed tobe ai ailable for use for the purposes set forth in such Determination or Opinion aswell ts for the purposes set forth in Section 3 above.

5. Construction activities which may involve the disturbance ofcont2 nination soil and/or groundwater shall include preparation andimph mentation of a hazardous materials management plan ("HMMP") tommi uze migration of and exposure to hazardous materials. The HMMP shall beprep; red in accordance with the requirements of the "Waiver of Approval" and theMass ichusetts Contingency Plan, as applicable.

WITNESS the execution hereof under seal this 10th day of iav1995.

MASSACHIJSFTTS WATER RESOURCESAUTHOITY

By:

COMMONWEALTH OF MASSACH-USETTS

Fj fftn l SS. M 3 0 . 1995

Then personally appeared the above-namedDouglas B. MacDonaii_-hh iL-* of wA and acknowledged the foregoinginstrt ment to be the free act and deed of wwRA, before me.

Notary Public

My Commission expires: /0//-/-z/

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EXHIBIT A

Legal Description

The real property in Quincy and Braintree, Norfolk County, Massachusettsconv< yed to Massachusetts Water Resources Authority by General DynamicsCorp< ration by deed dated November 16, 1987 and filed with the Norfolk CountyRegis ry District of the Land Court as Document No. 535415 shown as TransferCertil cate of Title No. 127626, filed in Registration Book 639, Page 26, and recordedwith; he Norfolk County Registry of Deeds in Book 7803, Page 211; said real propertybeing more particularly described as Parcels 1 through 15, inclusive, in Exhibit A tosaid I eed, a copy of the land description in such Deed is attached hereto as ExhibitA-1; I ut expressly excluding Parcel 4 as described in such Exhibit A to said Deed andin ExJ .ibit A-1 hereto, and in Exhibit B hereto. Said parcels are shown on a plan ofland i ntitled "General Dynamics Quincy, MA. and Braintree, MA." (consisting of aPlan I adex an d fourteen drawings numbered 150.011 M to 150.151M, inclusive, butexclui .ing 150.081M) dated October 15, 1986 and November 4, 1986, as revised, byNew England Survey service, recorded November 16, 1987 in Plan Book 361 as Plan#1372 of 1987, Sheets 1-15.

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EXHIBIT A-1

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

PARCEL 1:

A CERTAIN PARCEL OF LAND IN THE COMMONWEALTH OFMASSACHUSETTS, COUNTY OF NORFOLK, CITY OF QUINCY AND TOWN UFBRAINTREE, SITUATED ON EAST HOWARD STREET, SOUTH STREET, NASHAVENUE, WASHINGTON STREET, HILL AVENUE, AND QUINCY AVENUE AS SHOWNON SAID PLAN, DATED OCTOBER 15, 1986, DRAWING 150.011M, DRAWING150.021M, DRAWING 150.031M, DRAWING 150.041M, AND DRAWING150.0SiM.

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

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

(1) LAND DESCRIBED AS TRACT NO. 1 IN THE INDENTURE BETWEENFORE RIVER SHIPBUIDING CORPORATION, AND FORE RIVERRAILROAD CORPORATION DATED APRIL 30, 1919, RECORDED ATBOOK 1421, PAGE 264, EXCEPT THAT PORTION THEREOFCONVEYED BY FORE RIVER RAILROAD CORPORATION TO BETHLEHEMSTEEL COMPANY BY DEED, DATED MARCH 13, 1962, RECORDED ATBOOK 3975, PAGE 742;

(2) LAND DESCRIBED AS PARCEL 2 IN THE DEED FROM THECOMMONWEALTH OF MASSACHUSETTS TO FORE RIVER RAILROADCORPORATION, DATED AUGUST 6, 1920, RECORDED ATBOOK 1466, PAGE 81;

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

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

INCLUDED AS PART OF THE ABOVE-DESCRIBED PARCEL 1 ARE THEFOLLOWING LOTS OF REGISTERED LAND;

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

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

FOR TITLE REFERENCE, SEE CERTIFICATE OF TITLE NO. 74465, FILED INREGISTRATION BOOK 373, PAGE 65; CERTIFICATE OF TITLE NO. 88974,

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FILED IN REGISTRATION BOOK 445, PAGE 174; DEED FROM BETHLEHEM;TEEL COMPANY DATED DECEMBER 31, 1963. RECORDED AT BOOK 4132, PAGE;59; AND DEED FROM THE UNITED STATES OF AMERICA, ACTING BY AND

HROUGH THE ADMINISTRATOR OF GENERAL SERVICES, DATED APRIL 30,.970, RECORDED AT BOOK 4660, PAGE 495.

:ARCEL 2:

A CERTAIN PARCEL OF LAND IN THE COMMONWEALTH OF MASSA.CHU-;ETTS, COUNTY OF NORFOLK, TOWN OF BRAINTREE, SITUATED ON HILLAVENUE, LANCASTER ROAD, CLIFF STREET, AND COLUMBIA TERRACE AND ISHOWN ON SAID PLAN, DATED NOVEMBER 4, 1986, DRAWING 150.061M.

cONTAINING 9,066 SQUARE METERS, MORE OR LESS, OR 97,584 SQUAREEET, MORE OR LESS, OR 2.240 ACRES, MORE OR LESS.

NCLUDED AS PART OF THE ABOVE-DESCRIBED PARCEL 2 IS A PARCEL OFI EGISTERED LAND BEING SHOWN ON LAND COURT PLAN 23255A.

JOR TITLE REFERENCE, SEE CERTIFICATE Or TITLE NO. 82202, FILED TNI EGISTRATION BOOK 412, PAGE 2; DEED FROM BETHLEHEM STEEL COMPANYIATED DECEMBER 31, 1963, RECORDED AT BOOK 4132, PAGE 459; DEEDIROM WILLIAM N. MCQUARRIE, JR. AND JOAN MCQUARRIE DATED JUNE 1,J967, RECORDED AT BOOK 4431, PAGE 170; DEED FROM FRANCES RIVELLI,IDMINISTRATOR OF THE ESTATE OF NUNZIATO LUISI, DATED JUNE 15,1967, RECORDED AT BOOK 4447, PAGE 557; DEED FROM ARTHUR V. OLSENIND GLADYS M. OLSEN DATED JANUARY 16, 1968, RECORDED AT BOOK 4488,

INGE 42; DEED EROM RAYMOND F. BARRETT, ADMINISTRATOR OF THE ESTATECF ANNIE DRUMMOND, DATED JANUARY 31, 1968, RECORDED AT BOOK 4491,FAGE 277; AND DEED FROM JOHN J. SULLIVAN AND ANNE SULLIVAN DATEDOJNE 14, 1968, RECORDED AT BOOK 4519, PAGE 541.

PXRCEL 3:

A CERTAIN PARCEL OF LAND IN THE COMMONWEALTH OFMXSSACHUSETTS, COUNTY OF NORFOLK, TOWN OF BRAINTREE, SITUATED ONC)LUMBIA TERRACE AND CLIFF STREET AND IS SHOWN ON SAID PLAN, DATEDN)VEMBER 4, 1986, DRAWING 150.061M.

C)NTAINING 1,778 SQUARE METERS, MORE OR LESS, OR 19,138 SQUAREF:ET, MORE OR LESS.

F)R TITLE REFERENCE, SEE DEED FROM JAMES E. DHOOGE DATED MAY 2,1 67, RECORDED AT BOOK 4425, PAGE 517; DEED FROM GERALD D. DHOOGE,A .SO KNOWN AS GERALD D. DEWEY, AND MABEL DHOOGE, ALSO KNOWN ASM.BEL DEWEY, DATED APRIL 10, 1967, RECORDED AT BOOK 4431, PAGE6 4; DEED FROM THERESA LUISI DATED JUNE 15, 1967, RECORDED AT BOOK4.47, PAGE 555; AND TWO DEEDS FROM THE TOWN OF BRAINTREE DATEDD:CEMBER 11, 1967, RECORDED AT BOOK 4483, PAGES 447 AND 450.

P. RCEL 4:

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

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,ANCASTER ROAD, AND IS SHOWN ON SAID PLAN, DATED NOVEMBER 4, 1986,RAWING 150.061M.

ONTAINING 1,301 SQUARE METERS, MORE OR LESS, OR 14,000 SQUAREEET, MORE OR LESS.

OR TITLE REFERENCE, SEE DEED FROM BETTY A. DIBONA DATED JUNE 1,970, RECORDED AT BOOK 4666, PAGE 467.

1ARCEL 5:

A CERTAIN PARCEL OF LAND IN THE COMMONWEALTI OFIASSACHUSETTS, COUNTY OF NORFOLK, TOWN OF BRAINTREE, SITUATED ON!ILL AVENUE AND LANCASTER ROAD AND IS SHOWN ON SAID PLAN, DATED2DVEMBER 4, 1986, DRAWING 150.061M.

(DNTAINING 6,551 SQUARE METERS, MORE OR LESS, OR 70,509 SQUAREIEET, MORE OR LESS, OR 1.619 ACRES, MORE OR LESS.

F3R TITLE REFERENCE, SEE DEED FROM BETHLEHEM STEEL COMPANY DATEDERCEMBER 31, 1963, RECORDED AT BOOK 4132, PAGE 459; DEED FROMJ5 MES J. FLAVIN DATED JANUARY 7, 1967, RECORDED AT BOOK 4404, PAGE639; DEED FROM JOHN F. JOHNSON AND JESSIE M. JOHNSON DATED MARCH3. 1967, RECORDED AT BOOK 4414, PAGE 552; DEED FROM CATHERINEM:QUARRIE DATED OCTOBER 5, 1967, RECORDED AT BOOK 4465, PAGE 73;AID DEED FROM WILLIAM N. MCQUARRIE AND CATHERINE MCQUARRIE DATEDO:TOBER 5, 1967, RECORDED AT BOOK 4465, PAGE 74.

P RCEL 6:

A CERTAIN PARCEL OF LAND IN THE COMMONWEALTH OFMLSSACHUSETTS, COUNTY OF NORFOLK, TOWN OF BRAINTREE, SITUATED ONLLNCASTER ROAD AND IS SHOWN ON SAID PLAN, DATED NOVEMBER 4, 1986,D AWING 150.061M.

CiNTAINING 643 SQUARE METERS, MORE OR LESS, OR 6,916 SQUARE FEET,Mi RE OR LESS.

F( R TITLE REFERENCE, SEE DEED FROM BETHLEHEM STEEL COMPANY DATEDDICEMBER 31, 1963, RECORDED AT BOOK 4132, PAGE 459.

PlRCEL 7:

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

CC'TAINING 660 SQUARE METERS, MORE OR LESS, OR 7,108 SQUARE FEET,MCRE OR LESS.

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

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N RCEL 8:

A CERTAIN PARCEL OF LAND rN THE COMMONWEALTH OF%SSACHUSETTS, COUNTY OF NORFOLK, TOWN OF BRAINTREE, SITUATED ON

CXLUMBIA TERRACE, AND IS SHOWN ON SAID PLAN, DATED NOVEMBER 4,1986, DRAWING 150.061M.

CDNTAINING 391 SQUARE METERS, MORE OR LESS, OR 4,212 SQUARE FEET,N)RE OR LESS.

F)R TITLE REFERENCE, SEE DEED FROM THE TOWN OF BRAINTREE DATEDCZCEMBER 11, 1967, RECORDED AT BOOK 4483, PAGE 448.

UkRCEL 9:

A CERTAIN PARCEL OF LAND IN THE COMMONWEALTH OFM SSACHUSETTS, COUNTY OF NORFOLK, TOWN OF BRAINTREE, SITUATED ONH:LL AVENUE, PATTEN AVENUE, AND QUINCY AVENUE AND IS SHOWN ON SAIDPAN, DATED NOVEMBER 4, 1986, DRAWING 150.071M.

C)NTAINING 15,390 SQUARE METERS, MORE OR LESS, OR 165,659 SQUAREF:ET, MORE OR LESS, OR 3.803 ACRES, MORE OR LESS.

FOR TITLE REFERENCE, SEE DEED FROM CHARLES A. SMITH DATEDK RCH 17, 1967, RECORDED AT BOOK 4416, PAGE 50; DEED FROM SIGNE E.W.:ITEHOUSE DATED MAY 1, 1967. RECORDED AT BOOK 4424, PAGE 327;D ED FROM GEORGE W. NOYES, JR. AND JOYCE E. NOYES DATED MAY 29,1 67, RECORDED AT BOOK 4430, PAGE 659; DEED FROM RAYMOND E. ELLISD.TED JUNE 13, 1967, RECORDED AT BOOK 4434, PAGE 110; DEED FROMR.'NE BIGANZOLI AND MARY BIGANZOLI DATED JUNE 16, 1967, RECORDED ATBCOK 4435, PAGE 531; DEED FROM HENRY SEPPALA AND VIOLET SEPPALADi TED JUNE 15, 1967, RECORDED AT BOOK 4435, PAGE 533; DEED FROMW LLIAM PERRY AND JOHN S. PERRY DATED JUNE 27, 1967, RECORDED ATB(OK 4438, PAGE 395; DEED FROM RAYMOND F. BARRETT, ADMINISTRATOR01 THE ESTATE OF ANNIE DRUMMOND, DATED JANUARY 31, 1968, RECORDEDA BOOK 4491, PAGE 277: AND DEED FROM AGNES DRISCOLL DATED JANUARY4, 1969, RECORDED AT BOOK 4568, PAGE 707.

PJRCEL 10:

A CERTAIN PARCEL OF LAND IN THE COMMONWEALTH OFMJSSACHUSETTS, COUNTY OF NORFOLK, TOWN OF BRAINTREE, SITUATED ONC(LUMBIA TERRACE AND PATTEN AVENUE AND IS SHOWN ON SAID PLAN,DUrTED NOVEMBER 4, 1986, DRAWING 150.071M.

C(NTAINING 2,796 SQUARE METERS, MORE OR LESS, OR 30,095 SQUAREFEET, MORE OR LESS.

FCR TITLE REFERENCE, SEE DEED FROM WALTER J. LATHAM AND DORIS M.Le rHAM DATED MAY 4, 1967, RECORDED AT BOOK 4425, PAGE 516; DEEDFF)M THERESA LUISI DATED JUNE 15, 1967, RECORDED AT BOOK 4447,PP3E 555; AND DEED FROM SARAH R. FERGUSON DATED JULY 12, 1967,RE:ORDED AT BOOK 4443, PAGE 483.

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'ARCEL 11:

A CERTAIN PARCEL OF LAND IN THE COMMONWEALTH OFASSACHUSETTS, COUNTY OF NORFOLK, CITY OF QUINCY, SITUATED ON

-AST HOWARD STREET, CHUBBUCK STREET, DES MOINES ROAD, AND SOUTHTREET AND IS SHOWN ON SAID PLAN, DATED OCTOBER 15, 1986, DRAWING.50.091M.

3EING SHOWN AS LOT 2 ON A PLAN DRAWN BY ERNEST W. BRANCH, INC.,IVIL ENGINEERS, DATED DECEMBER 16, 1958, AND NUMBERED 18298-B,

;HEETS I THROUGH 6 INCLUSIVE, ALL AS MODIFIED AND APPROVED BY THEOURT, A COPY OF A PORTION OF WHICH IS FILED IN NORFOLK REGISTRYiISTRICT WITH CERTIFICATE NO. 69622, 90CK 349.

'OR TITLE REFERENCE, SEE CERTIFICATE OF TITLE NO. 74465, FILED IN.EGISTRATION BOOK 373, PAGE 65.

.ARCEL 12:

A CERTAIN PARCEL OF LAND IN THE COKMONWEALTH OF1ASSACHUSETTS, COUNTY OF NORFOLK, CITY OF QUINCY, SITUATED ONlAWRENCE STREET, CHASE STREET, CHECKER STREET, AND CLEVERLY COURTIND IS SHOWN ON SAID PLAN, DATED OCTOBER 15, 1986, DRAWING:50.101M.

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

!DR T:TLE REFERENCE, SEE DEED FROM BETHLEHEM STEEL COMPANY DATEDLECEMBER 31, 1963, RECORDED AT BOOK 4132, PAGE 459.

INRCEL 13;

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

C)NTAINING 11,485 SQUARE METERS, MORE OR LESS, OR 123,625 SQUARE FEET,Y)RE OR LESS, OR 2.838 ACRES, MORE OR LESS.

F)R TITLE REFERENCE, SEE DEED FROM BETHLEHEM STEEL COMPANY DATEDCEEMBER 31, 1963, RECORDED AT BOOK 4132, PAGE 459.

PRCEL 14:

A CERTAIN PARCEL OF LAND IN THE COMMONWEALTH OFM\SSACHUSETTS, COUNTY OP NORFOLK, CITY OF QUINCY, SITUATED ONW\SHINGTON STREET AND READ AVENUE AS SHOWN ON SAID PLAN, DATEDO:TORER 15, 1986, DRAWING 150.111M.

C)NTAINING 4,865 SQUARE METERS, MORE OR LESS, OR 52,367 SQUAREF2ET, MORE OR LESS, OR 1.202 ACRES, MORE OR LESS.

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1ER TITLE REFERENCE, SEE DEED FROM THOMAS F. DRAPER DATEDNJVEMBER 29, 1968, RECORDED AT BOOK 4560, PAGE 223; DEED FROMEECTOR A. FRAZ:ER DATED MARCH 4, 1969, RECORDED AT BOOK 4579,E\GE 87; AND DECD FROM MADELINE FRAZIER DATED MARCH 4, 1969,RWCORDED AT BOOK 4579, PAGE 88.

EkRCEL 15:

A CERTA:N PARCEL OF LAND IN THE COMMONWEALTH OFMtSSACHUSETTS, COUNTY OF NORFOLK, CITY OF QUINCY, SITUATED ONS )UTH STREET, READ AVENUE, WASHINGTON STREET, AND NASH AVENUE ANDI: SHOWN ON SAID PLAN, DATED OCTOBER 15, 1986, DRAWING 150.111M.

C'NTAINING 8,147 SQUARE METERS, MORE OR LESS, OR 87,688 SQUAREF.:ET, MORE OR LESS, OR 2.013 ACRES, MORE OR LESS.

IlICLUDED AS PART OF THE ABOVE-DESCRIBED PARCEL 15 IS A PARCEL OFRIGISTERED LAND BEING SHOWN AS LOT B ON LAND COURT PLAN 10629B, ACCPY OF A PORTION OF WHICH IS FILED WITH CERTIFICATE NO. 16150,RIGISTRATION BOOK 81.

F(R TITLE REFERENCE, SEE CERTIFICATE OF TITLE NO. 117791, FILEDIt REGISTRATION BOOK 589, PAGE 191; DEED FROM BETHLEHEM STEELCCMPANY DATED DECEMBER 31, 1963, RECORDED AT BOOK 4132, PAGE 459;DEED FROM ADELE M. FERRIS DATED APRIL 10, 1967, RECORDED AT BOOK4419, PAGE 599: DEED FPOM JOHN A. MORRISON AND WINIFRED J.MCIRISON DATED APRIL 10, 1967, RECORDED AT BOOK 4419, PAGE 600;DED FROM ROBERT J. GILMORE AND ELAINE M. GILMORE DATED JUNE 9,1957, RECORDED AT 200K 4434, PAGE 109; DEED FROM MARIE NORCOTTDArED JULY 10, 1967, RECORDED AT BOOK 4441, PAGE 440; AND DEEDFR)M ARMAND F. BRODEUR AS TRUSTEE OF THE RONALD BRODEUR TRUST,AN) RONALD J. BRODEUR AND ANNA M. BRODEUR, DATED JULY 22, 1967,RE:ORDED AT BOOK 4445, PAGE 299.

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EXI-UBIT B

Parcel Four

A certain parcel of land in The Commonwealth of Massachusetts, County ofNorfi 1k, Town of Braintree, situated on Lancaster Road, and shown on drawing150.0 .IM of a plan of land entitled "General Dynamics Quincy, MA. and Braintree,MA." (consisting of a Plan Index and fourteen drawings numbered 150.011M to150.1 1M, inclusive, but excluding 150.081M) dated October 15, 1986 and November4, 191 6, as revised, by New England Survey Service, recorded November 16, 1987 inPlan look 361 as Plan #1372 of 1987, Sheets 1-15.

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

Said parcel is identified as Parcel 4 in Exhibit A of the deed of GeneralDyna nics Corporation to Massachusetts Water Resources Authority datedNove nber 16, 1987 and filed with the Norfolk County Registry District of the LandCour as Document No. 535415 and recorded with the Norfolk County Registry ofDeed; in Book 7803, Page 211. Said parcel is further described as Parcel 4 on ExhibitA-1 I ereto.

MASSACHUSETTS WATER RESOURCES AUTHORITYCharlestown Navy Yard

100 First Avenuei Massachusetts 02129

S>L,

Telephone: (61 ~1 242-6000Facstmile: 617 241-6070

April 9, 1996

Subject: The sale of 130 acres at the Quincy Ship Yard from theMassachusetts Water Resources Authority (MWRA) toMassachusetts Heavy Industries (MHI)

Dear Environmental Reviewer:

Enclosed please find one (1) copy of the Environmental NotificationForm (ENF) for the MWRA's sale of 130 acres at the Quincy Ship Yardto Massachusetts Heavy Industries. The ENF was submitted to theMassachusetts Environmental Policy Act (MEPA) Unit on April 10, 1996and will be noticed in the next issue of the the Environmental Monitor.

Please review this document and forward any comments to the Secretaryof Environmental Affairs , 100 Cambridge Street, 20th Floor, Boston, MA02202, Attention: MEPA Unit. If you have any questions or requireadditional information, please call me at (617) 241-2765.

Sincerely,

Marianne ConnollyProgram Manager,Regulatory Compliance

MassachusettsHeavy Industries Inc.

e-,hipo I I

SoTiKIS (. EXINIANI T.President

PMPus radhe Rd . Suie I 2sMA) ?X) 2001 M I aiIpScoI. MA 01907- (901)

ri-I (0bI ') .17!1 24(9 1:j, ((!) 1-) 1J 2475

NVA' -todsus

r~~Viijx QMv on *Wvbon

enc.

EN VIKUNMtN I AL 1* 1 ik-iCA I lON 1-OM

Massachusetts Water ResourcesAuthority (MWRA) sale of a

SUMMARY portion of the Quincy Shipyardto Massachusetts Heavy

A. Project Identification Industries (MHI)1. Project Name - Ouincy Fore River ShipyardAddress/Location East Howard Street

City/Town __ Ouiney and Braintree2. Project Proponent. MHI and MWRA

Address 1

3. Est. Commencement June 1996 . Est. CompletionApprox. Cost $ 145M _.. Status of Project Design % Complete.

4. Amount (if any) of bordering vegetated wetlands, salt marsh, or tidelands to be dredged,filled, removed, or altered (other than by receipt of runoff) as a result of the project.

acres square feet.5. This project is categorically included and therefore requires preparation of an EIR.

Yes - No X ?

B. Narrative Project DescriptionDescribe project and site.

Massachusetts Heavy Industries (MH1) proposes to buy approimately 130 acres at the formerGeneral Dynamics Shipyard in Quincy and Braintree, now referred to as the Fore RiverStaging Area (FLSA) (see Figure 1). The entire 130 acre shipyard is owned by theMassachusetts Water Resources Authoritj (MWRA). HI is in the process of applying forfederal loan guarantee from MARAD (the Maritime Administration in Washington, D.C.)Federal loan guarantees are available for site impravements (S30 million) and shipconstruction (S200 milion). The 130 acres includes the fve dry docks, the wet basin,approximately 42 buildings and numerous cranes including the Goliath (see Figure 2).

A purchase and sale agreement has to be executed by both parties and a dosing date on ornear June 30, 1996 is anticipated. MHI intends to spend the first year renovating the site andthen constructing double hulled tankers for a foreign entity.(Continued on next page)

Copies of the complete ENF may be obtained from (proponent or agent):Name: Marianne Connolly Firm/Agency: Mass. Water Resources AuthorityAddress: 100 First Ave., .Charlestown Phone No. (617) 241-2765

MA 02129

1987 THIS IS AN IMPORTANT NOTICE. COMMENT PERIOD IS UMITED.For Information, call (617) 727-5830

(continued from previous page)

This intended use is compatible with the master plan that was completed in 1994 for the site.The planning process was carried out over two years through the joint efforts of Quincy,Braintree, Weymouth, CZM and MWRA. The shipyard is part of a Designated Port Area(DPA) and has had marine industrial uses at the site since the late 1800's. The shipyardemployed 4200 workers in July 1985 when the shutdown of the yard was announced by theprevious owner, General Dynamics.

The current owner, MWRA, uses approximately 40 acres of the overall site for the BostonHarbor Project (BHP). MWRA purchased the site in November 1987, and in 1988 completedthe facilities planning and environmental impact review for the construction and stagingfacilities as part of the BHP. MWRA expects passage of recently filed state legislation whichwould allow the purchase of 130 acres at this site.

Ia.

C. Ust the State or Federal agencies from which permits or other actions have been/will be sought:Agency Name Permit Date filed; file no.

MHI will be responsible for obtaining all applicable local, state and federal environmentalpermits, which may Include but not be limited to Notices of Intent, Water QualityCertifications, hazardous materials handling approvals, Section 404, etc. as a term of thesale.

D. List any government agencies or programs from which the proponent will seek financial assistancefor this project:

Agency Name Funding Amount

Maritime Administration,Washington D.C. -

$230 M in federal loan guarantees forsite upgrade & construction of ships.

ConstructionImpacts

Port Area

Long TermImpacts

xx

x

XX

X (positie)

E. Areas of potential impact (complete Sections H and II rst, before completing this section).1. Check all areas in which, in the proponent's judgment, an impart of this project may occur. Positive

impacts, as well as adverse impacts, may be indicated.

Iniand W etlands...................................Coastal Wetlands/Beaches ........................ridelands.....(fU111*)...........................T raffic ..............................................Open Space/Recreation ...........................Historical/Archaeological ........................Fisheries/W ildlife ..................................Vegetation/Trees ..................................Agricultural Lands .................................W ater Pollution....................................Water Supply/Use ........ ...............Solid W aste...................... .................Hazardous Materials...........................A ir Pollution .......................................Noise .................. .......................W ind/Shadow ............. ,.......................Aesthetics ......................................Growth Impacts................................Community/Housing and the

Built Environment ...............................Other (Specify) Revitalization of Designated

2. List the alternatives which have been considered.

The No Action alternative was considered, which would result in the continuedunderutilization of a unique shipyard resource which had been a source of skilled jobs andregional investment for the past century. Source: MWRA.

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F. Has this project been filed with EOEA before? No I Yes EOEA No.ENF 7280 was riled in August of 1988. At that time, the MWRA intended to sign a lease with theMassachusetts Land Bank who would then sublease to the MSala Sipbuilder Corp. to restor andoperate a shipbuilding and repair facility on approximately 50 acres. The lease was never executed.Sourc MWRA.

G. WETLANDS AND WATERWAYS

1. Will an Order of Conditions under the Wetlands Protection Act (c.131s.40) or a License underthe Waterways Act (c.91) be required? Estin Ch. 91 Ucenses allowYes - oNo X g

2. Has a local Order of Conditions been: for shipbuilding and related uses.

a. issued? Date of issuance ; DEQE File No. . Source: DEP.b. appealed? Yes _ ; No X .

3. Will a variance from the Wetlands or Waterways Regulations be required? Yes :No X

II. PROJECT DESCRIPTION

A. Map; site plan. Include an original 8% x 11 inch or larger section of the most recent U.S.G.S.7.5 minute series scale topographic map with the project area location and boundaries clearlyshown. If available, attach a site plan of the proposed project.

See Figures 1 and 2

B. State total area of project: . 130 acres.Estimate the number of acres (to the nearest 1/10 acre) directly affected that are currently:1. Developed ............. 130 acres 6. Tidelands ............ 6. acres2. Open Space/ 7. Productive Resources

Woodlands/Recreation - acres Agriculture ............. acres3. W etlands ............... acres Forestry ................ acres4. Floodplain ............ 60 acres 8. Other ................... acres5. Coastal Area ............ A; acres

C. Provide the following dimensions, if applicable:Exisring Increase Total

Length in miles ................................. N/A N/2.LA N/ANumber of Housing Units ............................ NIA N/A N/AN um ber of Stories ..... ,.......................... .... - - 1-3Gross Floor Area in square feet ..................Number of parking spaces ....................Total of Daily vehicle trips to and from site(Total Trip Ends) ........................... ... 100-200 100-2000 200-2200Estimated Average Daily Traffic on road(s)serving site .......... ........................................

1.

2.

3.

C. * Actual trip generation will depend on MH's final pla. Start-up (estimated for June 96) will involveapproximately 50 employees. Eventually, 1000 employees are expected in May 97. Source: MI

D, TRAFFIC PLAN. If the proposed project will require any permit for access to local roads orstate highways. attach a sketch showing the location and layout of the proposed driveway(s)

i1l. ASSESSMENT OF POTENTIAL ADVERSE ENVIRONMENTAL IMPACTS

Instructions: Explain direct and indirect adverse impacts, including those arising from generalconstruction and operations. For every answer explain why significant adverse impact isconsidered likely or unlikely to result. Positive impact may also be listed and explained.

Also, state the source of information or other basis for the answers supplied. Suchenvironmental information should be acquired at least in part by field inspection.

A. Open Space and RecreationI. Might the project affect the condition, use, or access to any open space and/or recreation

area?No. The site is located within a Designated Port Area. There are noopen space and/or recreation areas that would be affected.Source: Massachusetts Coastal Zone Management Atlas, 1977.

2. Is the project site within 500 feet of any public open space, recreation, or conservation land?

No. The site is not located within 500 feet of any public open space or conservationarea. However, a Shipbuilding Museum located within the Shipyard is approximately1500' outside the MHI boundary. Source: MWRA.

B. Historic and Archaeological Resources1. Might any site or structure of historic. significance be affected by the project? (Prior

consultation with Massachusetts Historical Commission is advised.)Yes. The FRSA meets the criteris of eligibilty for hling in the Natiosma Register of Istor Places ass historicdistrict. The proposed use of the mite (ehIpbuildIng)l's -mtt wit the previous historic - at the site. MIproposes demoldon of som buidings at the it. A complete lstori Survey w completed Is I99. TheMWRA and MHC cmde to work closely n mater Mted to this sle. The MWIA ha. submitted the listof buildings for demoetuon to the MHC to begI, the review pros Senreem MWRA, MHC.

2. Might any archaeological site be affected by the project? (Prior consultation withMassachusetts Historical Commission is advised.)

There is a known trilobite quarry under the wet basin. Since no excavation is proposed, noimpacts are expected.Source: MWRA, MHC.

C. Ecological Effects1. Might the project significantly affect fisheries or wildlife, especially any rare or endangered

species? (Prior consultation with the Massachusetts Natural Heritage Program is advised).

No. There are no known rare or endangered species at the site.Source: Massacbusetts Natural Heritage Atlas, 1995 Edition.

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2. Might the project significantly affect vegetation, especially any rare or endangered speciesof plant? (Prior consultation with the Massachusetts Natural Heritage Program is advised.)(Estimate approximate number of mature trees to be removed. )

No. There are no known rare or endangered species of plant at the site.Source: Massachusetts Natural Heritage Atlas, 1995 Edition.

3. Agricultural Land. Has any portion of the site been in agricultural use within the last 15 years?If yes, specify use and acreage.

No. The site had been used for maritime industrial uses associated withshipbuilding for over 100 years. More recently, the MWRA acquired the site tohost activities (construction staging and RO/RO) related to the BostonHarbor Project. Source: MWRA.

D. Water Quality and Quantity1. Might the project result in significant changes in drainage patterns?

No. Shipbuilding will occur at existing facilties (dry docks, basins, buildings) atthe site, therefore, no significant changes to the drainage patterns are proposed.

2. Might the project result in the introduction of any pollutants, including sediments, into marinewaters, surface fresh waters or ground water?

No. Ther wil be no introduction of pollutants into marine waters or ground water. Source:MH I.

3. Does the project involve any dredging? No X Yes -Volume - . If 10,000cy or more, attach completed Standard Application Form for Water Quality Certification,Part 1(314 CMR 9.02(3), 9.90, DEQE Division of Water Pollution Control).

0 P.6 04. Will any part of the project be located in flowed or filled tidelands, Great Ponds, or other

waterways? (Prior consultation with the DEQE and CZM is advised.)

Yes. Approximately 50% of the site is located In filled tidelands. The siteis located within the Weymouth Fore River Designated Port Area intended to reserve deepwater port areas for maritime uses. Source: DPA map.

5. Will the project generate or convey sanitary sewage? No - Yes IIf Yes, Quantity: gallons per day -Disposal by: (a) Onsite septic systems .......................... Yes - No .

(b) Public sewerage systems (location; average and peak daily flows totreatment works) ................................... Yes . No -

Explanation and Source:

Yes. At start-up, approximately 50 employees are likely to generate 1000 gallons per day(gpd). At peak (1000 employees) the amount could increase to 20,000 gpd.Source: DEP Sewage Flow factors, 310 CMR 15.00 State Env. Code, TitleS.Source: MH[ and MWRA.

6. Might the project result in an increase in paved or impervious surface over a sole sourceaquifer or an aquifer recognized as an important present or future source of water supply?Explanation and Source:

No. The site is not located over a sole source aquifer.Source: MWRA.

7. Is the project in the watershed of any surface water body used as a drinking water supply?Explanation and Source:

No. The site Is not in the watershed of any surface water body usedas a drinking water supply.Souirce: MWRA.

8. Are there any public or private drinking water wells within a 1/2-mile radius of the proposedproject?Explanation and Source:

No. The site is located in an area served by the MWRA. No drinking waterwells are within a 1/2 - mile radius of the project site.Source: MWRA. -

0 P.7

9. Does the operation of the project result in any increased consumption of water?

Approximate consumption gallons per day. Likely water source(s)Explanation and Source:

Yes. Start-up (50 employees) will result in approximately1000 gpd.It is estimated that each employee win use 20 gpd. At peak, (1000 employees)it is estimated to be 20,000 gpd. Source: MHI and MWRA.

E. Solid Waste and Hazardous Materials1. Estimate types and approximate amounts of waste materials generated, e.g., industrial,

domestic, hospital, sewage sludge, construction debris from demolished structures. How/where will such waste be disposed of?

Demolition debris, if any, may include asbestos-containing building materials, Such debris would consist primarilyof non-friable asbestos siding. Potential sources of friable asbestos wase may include electrical manholes andunderground electrical conduits. All asbestos would be abated and disposed of in full accordance with alapplicable Federal, state and local regulations.Source: MWRA and MHL

2. Might the project involve the generation, use, transportation, storage, release, or disposalof potentially hazardous materials?Explanation and Source:

On-site excavation activities may generate contaminated surplus soils. Such soils will be

managed in accordance with MCP.

Source: MWRA.

3. Has the site previously been used for the use, generation, transportation, storaqe. release.or disposal of potentially hazardous materials? The FRSA has been used a a maritime industrial site for over 100. - - - - - - years.Several investgative and remedial actions have been taken atArange of containants were discovered in locized areas of the usdre 130 acres including low levels of chlorinated solvents,

eral spirits, metals and pesticide constituents in groundwater samples at Isolated areas of the site, PCB contaminated soils adacent toing former transformers, and a plume of 12 hal oil in soils adjacent to Bll. Ra=dial cleanup acdons completed under DEPew included the removal of hael tanks, PCB contaninated soils above 40 ppm, and htiltatimo of an oi recovery system. Under thea of the salt of the shipyard to MWRA, General Dynamics (G.D.)agreed to complete sme bazardous waste remediation that left the

ean to an industrial standard. Under the terms-of a Waiver of Approvals isued to G.D.and MWRA in March 94, Waiver Conpletionanents pertaining to the above areas of contamination will be submitted to DEP. Source: MWRA.

F. Energy Use and Air Quality1. Will space heating be provided for the project? If so, describe the type, energy source, and

approximate energy consumption.

Explanation and Source:

Natural gas service is available and will likely be the source of energy. Source: MHL

0 P.8

2. Will the project require process heat or steam? If so, describe the proposed system, the fueltype, and approximate fuel usage.

Explanation and Source:

Natural gas service is available and will likely be the source of energy. Source: MHL

3. Does the project include industrial processes that will release air contaminants to theatmosphere? If so, describe the process (type, material released, and quantity released).Explanation and Source

Industrial processes that might release air contaminants on a localized basis Includepainting with lead-bee paints and steel cutting and fabrication activities Involvingcombustion of oxy-acetylene gases. Good shipguiding practices will be utilized to minimizeadverse impacts on air quality in the immediate work environment, in compliance with DEPand/or OSHA requirements.Source: MHI

4. Are there any other sources of air contamination associated with the project (e.g. automobiletraffic, aircraft traffic, volatile organic compound storage, construction dust)?Explanation and Source

No. There are no know sources of air contamination associated with this project. Anypotentially contaminated dust associated with excavation of contaminated soils wil bemonitored and managed in accordance with existing environmental regulations.Source: MWRA and MHI

S. Are there any sensitive receptors (e.g. hospitals, schools, residential areas) which would beaffected by air contamination caused by the project?

Explanation and Source:

No. There are no sensitive receptors that would be affected by air contamination

caused by the project. Source: MWRA.

G. Noise1. Might the project result in the generation of noise?

(Include any source of noise during construction or operation, e.g., engine exhaust, piledriving, traffic.)Explanation and Source:

Noise associated with routine shipbuilding activities can be expected.

Source: MI

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2. Are there any sensitive receptors (e.g., hospitals, schools, residential areas) which would beaffected by any noise caused by the project?

Explanation and Source:

No. There are no sensitive receptors that would be affected by noise generated frn thesite. Source: MWRA.

3. Is the project a sensitive receptor, sited in an area of significant ambient noise?Explanation and Source:

No. The project Is not-a sensitive receptor.

Source: MWRA

H. Wind and Shadow1. Might the project cause wind and shadow impacts on adjacent properties?

Explanation and Source:

No. The former shipyard site is 180 acres. MHI proposes to buy 130 acres. There will

not be any wind and shadow impacts on adjacent properties.

Source: MWRA.

1. Aesthetics1. Are there any proposed structures which might be considered incompatible with existing

adjacent structures in the vicinity in terms of size, physical proportion and scale, orsignificant differences in land use?

Explanation and Source:

No. Some new construction may be proposed but it will be compatible with shipbuildingrelated activities.Source: MHI and MWRA.

2. Might the project impair visual access to waterfront or other scenic areas?Explanation and Source:

Nu. No new major contruction (tall buildings) is proposed for the site.

P.100

IV. CONSISTENCY WITH PRESENT PLANNING

Discuss consistency with current federal, state and local land use, transportation, open space,recreation and environmental plans and policies. Consult with local or regional planningauthorities where appropriate.

This project is consistent with federal, state and local environmental policies.In particular, it is consistent with state Waterways and Coastal Zone ManagementPolicy Number 7 which encourages the location of maritime commerce and development insegments of urban waterfronts Designated as Port Areas (DPA).

The sale is consistent with the master plan for the long term use of the site. The masterplan was developed in a cooperative manner with the City of Quincy, Town of Braintreeand Weymouth, the MWRA and CZM. Since the site is a DPA, it is appropriate to achieveoptimum utilization of the industrial port facilities. The reopening of the shipyard willrestore at least 1,000 jobs and associated investment in the regional maritime economy.

V. FINDINGS AND CERTIFICATION

A. The public notice of environmental review has been/will be published in the followingnewspaper(s):

Patriot Ledger(Date)

submitted week of April 8, 1996

B. This form has been circulated to all agencies and persons as required by 301 CMR 11.24.

Sv wt sponsible Officeror Project Proponent

Sotirios EmmanouilPresident

Date Signature of person preparingENF (if different from above)

Douglas B. MacDonaldExecutive Director

Mass. Water Resourtes Audh.100 First AvenueCharlestown, MA 02129(617) 242-6000

(NAME)

Mass. Heavy Industries. Inc.505 Paradise Road, Suite 123Swappscott, MA 01970-0901{6171 471-2409

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CIRCULATION LIST

Greg SpakmanMaritime Administration400 7th StreetWashington, D.C. 20590

Environmental ReviewerDivision of Marine Fisheries100 Cambridge Street, 19th HoorBoston, MA 02202

Ms. Jane MeudProject Review CoordinatorCoastal Zone Management100 Cambridge Street, 20th FloorBoston, MA 02202

Ms. Trudy CoreSecretary of Environmental Affairs100 Cambridge Street, 20th HoorBoston, MA 02202Attention: MEPA Unit

Environmental ReviewerMassachusetts Bay Transit Authority10 Park Plaza, 6th HoorBoston, MA 02216-3966

Mr. Richard MeadQuincy Planning OfficeCity Hall1305 Hancock StreetQuincy, MA 02169

Ms Judith McDonoughMass Historical Commission220 Morriusey Blvd.Boston, MA 02125

Executive Office of Communitiesand Development

State Clearinghouse100 Cambridge Street, Rm 1803

Boston, MA 02202

Mr. Steve LipmanDept of Environmental ProtectionOne Winter StreetBoston, MA 02108

Mr. Dave KennedyDept. of Environmental ProtectionDivision of WaterwaysOne Winter StreetBoston, MA 02018

Environmental ReviewerMED - District #4519 Appleton StreetArington, MA 02174

Mr. Jim SpragueDEP/NE Regional Office10 Commerce WayWoburn, MA 01801

0Ms. Heather SargentQuincy Conservation CommissionCity Hall1305 Hancock StreetQuincy, MA 02169

Mr. Alen WeinbergBraintree Conservation CommissionBraintree Town HaiJFK Memorial PkwyBraintree, MA 02184

01Metropolitan Area Planning Council60 Temple PlaceBoston, MA 02111