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Fletcher’s Paint Works and Storage Facility Superfund Site February 2016
EPA Seeks Public Comment on Proposal to Remove PCBContaminated Sediments from the Souhegan River Contaminated Sediments Need to be Removed to Prevent Unacceptable Risks to Human Health and the Environment
Introduction As part of the investigations of the Fletcher’s Paint Works and Storage Facility Superfund Site (the Site) in Milford, NH, EPA has evaluated sediments in the Souhegan River that have been impacted by contamination from the Site. This evaluation is presented in a study called an Engineering Evaluation/Cost Analysis (EE/ CA), which is available for review by the public. EPA is proposing to remove approximately 2,000 cubic yards of contaminated sediments from a 1/3-acre area of the Souhegan River adjacent to the Elm Street portion of the Site. The sediment removal is currently planned to start in the Summer of 2016 and will be performed along with the ongoing Elm and Mill Street cleanup which involves excavation and off-site disposal of 30,000 cubic yards of contaminated soil.
This Fact Sheet summarizes the sediment removal action that EPA is proposing along with the other removal actions evaluated in the EE/CA.
The Problem The source of contaminants at the Site resulted from many years of storage and release of scrap pyranol, which is a mixture of polychlorinated biphenyls (PCBs) and solvents. Since the Souhegan River is immediately adjacent to the Elm Street portion of the Site, river sediments have been found to contain a variety of contaminants; however, PCBs are the primary contaminant of concern.
A risk assessment was conducted for the Souhegan River sediments in 2011. The general conclusion of the risk assessment is that there is an elevated risk to human health and ecological receptors from the ingestion of PCB contaminated fish and from exposure to PCB contaminated sediments located near the Elm Street portion of the Site.
Engineering Evaluation/Cost Analysis For a cleanup where it is determined that a six-month planning period is available before cleanup activities must begin, an EE/CA is performed. This study analyzes the Site’s contamination, identifies the objectives and goals for the removal, and evaluates alternatives that satisfy the removal action objectives and goals.
Fletcher’s Paint Works and Storage Facility Superfund Site
EPA’s Removal Action Objectives and Goals y Prevent direct contact during recreational use
with sediment having total PCB concentrations that result in excess health risks;
y Prevent consumption of fish with total PCB concentrations that result in excess risks;
y Reduce the amount or bioavailability of PCBs in sediment to ensure that PCB concentrations in fish tissue no longer result in excess health risks;
y Prevent wildlife from consuming fish that contain total PCB concentrations that result in excess risks;
y Prevent direct contact by benthic invertebrates with sediment having total PCB concentrations that result in excess risk; and
y Reduce transport of PCBs by minimizing the downstream movement of PCBs during the sediment removal activities or future storm events.
EPA has determined that a target sediment cleanup goal of 0.5 milligrams per kilogram (mg/kg) and fish tissue goal of 0.34 mg/kg will achieve these objectives.
PCB Contaminated Sediment Targeted by EE/CA
Site History Fletcher’s Paint Works manufactured and sold paints and stains for residential use at its Milford, NH plant from 1949 until 1991. The Site cleanup is being managed in two phases or operable units (OUs). OU1 consists of excavation and off-site disposal of about 30,000 cubic yards of contaminated soils from two lots: the former manufacturing plant/retail outlet on Elm Street, and a storage area 700 feet south on Mill Street. OU2 consists of the groundwater under Keyes Field and the Souhegan River sediments.
1989: Site listed on the NPL
1991 – 1993: Fence constructed around the Elm Street lot. Disposal of a storage shed and its contents.
1995: Contaminated surface soils removed from three properties adjacent to the Mill Street lot and asphalt placed over Mill Street to direct future run-off away from these three properties.
1996: Contaminated soils removed from a small piece of land adjacent to the Elm Street lot to allow for construction of the Korean War Memorial.
1998: OU1 Record of Decision (ROD) for the Mill and Elm Street soil excavation and on-site treatment.
2000: Demolition and off-site disposal of the former Fletcher’s Paint Works building on Elm Street.
2001: Administrative Order to General Electric to perform the OU1 Site cleanup.
2009: Amended OU1 ROD. Eliminated on-site treatment of the excavated soils and selected off-site disposal.
2012: OU2 Keyes Field groundwater ROD.
2015: Site preparation activities for the OU1 soil excavation started in the Fall and are ongoing.
2016: Souhegan River sediment EE/CA
Fletcher’s Paint Works and Storage Facility Superfund Site
Removal Action Alternatives Evaluated Alternative 1: No Action - No action taken to remove or limit exposure to the PCB contaminated sediments. cost: $0
Alternative 2: Limited Action - Short-Term Institutional Controls y This alternative relies on short-term institutional controls, such as fishing advisory signage, to minimize exposure to sediment and prevent fish consumption.
y Long-term institutional controls and monitoring would be addressed by a future Superfund decision document finalized after the proposed removal action is implemented.
cost: $12,000
Alternative 3: Isolation Cap with Sediment Removal (see Figure 1 - last page of fact sheet) y This alternative relies on constructing an isolation cap on top of sediments that have PCB concentrations
greater than the target cleanup concentration of 0.5 mg/kg (TCC) and some sediment removal.
y Preparation of construction staging areas and river diversion.
y Constructing an isolation cap involves placing a 12-inch layer of sand and a 6-inch armor layer on top of the contaminated sediments. For purposes of the EE/CA it was assumed that an isolation cap without prior sediment removal would be constructed only in areas with water depths four feet or greater. An area of about 13,000 square feet would be capped (Figure 1, areas 2 and 3).
y Sediment would be removed and clean backfill would be placed in areas where PCB concentrations above the TCC are contained entirely within the top foot of sediment. This would involve removing about 100 cubic yards of sediment from an area of about 3000 square feet and placement of an equal volume of backfill to restore the original grade in this area (Figure 1, area 1).
y Sediment would also be removed in areas where PCB concentrations above the TCC extend deeper than one foot and the area is too shallow to cap without excavation. This would involve removal of about 450 cubic yards of sediment (Figure 1 area 2).
y Dewatering, transportation and off-site disposal of any excavated sediment.
y Restoration activities.
y This alternative shares the long-term institutional controls and monitoring component of Alternative 2. cost: $1,979,000
ALTERNATIVE 4 IS EPA’S PREFERRED ALTERNATIVE
Alternative 4: Complete Sediment Removal (see Figure 2 - last page of fact sheet) y This alternative relies on complete removal of all sediment above the TCC.
y Preparation of construction staging areas and river diversion.
y Removal of about 2,000 cubic yards of sediments from an area of about 16,000 square feet (1/3-acre), and placement of an equal volume of clean backfill.
y Dewatering, transportation and off-site disposal of any excavated sediment.
y Restoration activities.
y This alternative also shares the institutional controls and long-term monitoring components of Alternative 2.
cost: $2,791,000
For more information contact: US EPA Project Manager US EPA Community Involvement NHDES Jim Brown Jim Murphy Andrew Hoffman (617) 918-1308 (617) 918-1028 (603) 271-6778 [email protected] [email protected] [email protected]
Fletcher’s Paint Works and Storage Facility Superfund Site
Why Does EPA Recommend This Alternative? Alternative 4 is considered the best overall solution because the PCB contaminated sediment will be removed completely and permanently as part of this alternative, and ongoing monitoring and maintenance of a sediment cap, as part of a future Superfund action, will not be required (as would be for Alternative 3). The additional incremental cost for Alternative 4, as opposed to Alternative 3, is not considered to be large enough to outweigh the long-term permanence of Alternative 4. Alternatives 1 and 2 are considered less desirable because neither is protective of human health or the environment, nor do they meet federal and state statutory and regulatory requirements.
Your Opinion is Important EPA is asking for public comment on its draft selection of a removal alternative evaluated in the EE/CA. EPA is also looking for comments on the wetland and floodplain impacts and draft TSCA determination discussed in Section 6.5 of the EE/CA. The public comment period will run until March 19, 2016. Comments can be sent by mail or email.
By mail: Jim Brown, Project Manager USEPA – New England Five Post Office Square, Suite 100 Boston, MA 02109-3912
By email: [email protected]
A public information meeting will be held on March 15, 2016 at 6:00 PM at the Ambulance Facility, 66 Elm Street, Milford, NH.
Continued Opportunities for Public Involvement beyond the EE/CA Comment Period EPA will continue to meet with and update the Milford Town Manager and Board of Selectmen over the course of the cleanup and any community concerns will be addressed to the extent possible.
An Administrative Record is Available for Review at: y Wadleigh Memorial Library, 49 Nashua Street,
Milford, NH 03055.
y EPA-New England’s Superfund Records Center, 5 Post Office Square, Boston, MA 02109-3912
• https://semspub.epa.gov/src/collection/01/AR62654
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Figure 2 Conceptual DesignAlternative 4:
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(617) 918-1028 or Toll Free (888) 372-7341
