From 1949 until 1990, Fletchers Paint Works manufactured oil-base and latex paints and stains, and engaged in other chemical processing activities. The Fletchers Paint Works site (site) consists of three areas: 1) the former Paint Works Plant on Elm Street, located about one-quarter mile west of the center of town along the southern bank of the Souhegan River; 2) a former storage facility on Mill Street, located about 700 feet south of the Paint Works Plant next to the Boston and Maine Railroad tracks; and, 3) a drainage ditch that runs from the Mill Street facility through the Paint Works and into the Souhegan River.
Land-use next to the site includes a cemetery, a town park with a closed municipal well field, and mixed residential, commercial and light industrial establishments.
In 1984, contamination was discovered in the Keyes well, a municipal water supply for Milford in the northwest corner of the adjacent Keyes Park. The well was subsequently taken out of service and an investigation began to determine the contaminant source. In 1985, EPA discovered volatile organic compounds (VOCs), polychlorinated biphenyls (PCBs) and heavy metals in the soils near the plant and in Souhegan River sediments. High levels of PCBs were also found in the soils around the paint storage building.
In 1988, EPA removed 863 drums from the site and shipped them to an authorized hazardous waste disposal facility. The site was listed on the National Priorities List in March of 1989. EPA’s contractor began the remedial investigation in late 1991, and the report was completed in 1994. Higher than expected levels of PCBs and paint waste material were detected in the subsurface.
In 1993, the wooden storage shed building at the Mill Street property was demolished and hundreds of drums and boxes were removed. A soil removal was completed in 1995 at three residential properties beside the Mill Street property due to excessive PCB contamination detected in surface soils. An additional PCB-soil removal was completed in 1996 at the cemetery next to the Elm Street facility (site of the Korean War Memorial).
The feasibility study was completed in May 1996. EPA issued a Proposed Plan in January 1997 that called for ex-situ treatment of PCB-contaminated soils by thermal desorption. EPA signed a Record of Decision (ROD) outlining the selected remedy for the Mill Street property and the Elm Street property in October 1998. The ROD called for the soil to be excavated and thoroughly treated at the Elm Street property and replaced in the ground; clean soil and asphalt placed over the soils at the Mill Street property; and the contaminated groundwater plume managed by monitored natural attenuation.
On December 4, 2000, EPA’s contractor mobilized all necessary personnel, equipment, materials, and subcontractors to the site in order to implement building demolition activities at the Elm Street portion of the site. The primary objectives of the building demolition project were to remove any regulated asbestos containing materials, remove the existing building structures and dispose of the building debris in a secure hazardous waste disposal facility. The asbestos abatement subcontractor completed asbestos removal on December 27, 2000. The demolition of the building was completed on January 17, 2001.
EPA issued a Unilateral Administrative Order (UAO) to the General Electric Company (GE) on July 16, 2001. The UAO directs GE to perform a remedial design for the remedy described in the ROD, and to implement the design by performing a remedial action.
GE initiated Phase I pre-design investigation activities in May 2003 at the site. These included preliminary site-related activities to survey certain baseline information to be used in the remedial design. Phase I activities were completed August 2003. Prior to these activities, several drums present on the Elm Street site were inventoried, sampled for waste characterization and consolidated for off-site disposal. The drums contained investigation-derived waste from previous activities performed on the site, including EPA’s RI and demolition of the former building on the Elm Street site.
GE initiated Phase 2 pre-design investigation activities in November 2003. These activities were implemented between November 2003 and August 2004. Activities included soil sampling, test pit excavations, and thermal and groundwater treatability testing. GE completed the Pre-Design Investigation Report in January 2005.
A Draft Preliminary (30%) Design Report was completed by GE in late winter 2005. The 30% design document describes implementation of the Low-Temperature Thermal Desorption (LTTD) remedy for the Fletcher’s site.
The Intermediate (60%) Design Report describes implementation of a LTTD remedy and a parallel design effort of an Off-site Disposal (OSD) remedy for the site. EPA and DES proposed a fundamental change in the remedy outlined in the subsequent Final (100%) Design Report. The proposed change is only for that portion of the ROD remedy which requires the cleanup of PCB contaminated soils at the site through excavation and on-site treatment by LTTD.
EPA released a Proposed Plan in June 2008 to amend a portion of the OU1 remedy (site soils). Specifically, a change in the remedy to OSD allows for the excavation and disposal of site contaminated soils at a licensed off-site landfill. An Amended ROD was issued June 2009. The rest of the OU1 remedy is proposed to remain unchanged
In December 2009, GE’s contractor submitted a letter report to document the supplemental geophysical investigation and survey activities performed at the site in September and October 2009.
In September 2011 EPA approved with modification GE’s 100% Design Report. In December 2011 GE’s contractor submitted a work plan to complete additional field activities to address constructability issues, including hydraulic testing, pre-construction verification sampling and soil characterization for off-site treatment and disposal. These activities are planned for early 2012.
GE continues to perform quarterly groundwater monitoring of the contaminated groundwater at the site. This will continue until the remedy has been constructed and a long term monitoring program can be implemented.
The site was divided in to two Operable Units, OU-2 is comprised of the Keyes Memorial Field and the Souhegan River in the vicinity of the Elm Street area of the site. Between 2004 and 2007, sediment and fish tissue sampling occurred in the Souhegan River to determine the status of the PCB contamination in those sediments adjacent to the site. Sediment and fish tissue data were collected from the areas immediately upstream, adjacent to and downstream of the site. This effort included sediment sample collection at the Goldman Dam (located downstream of the site).The data collected was used to complete a baseline human health and ecological risk assessment(BHHERA) in 2010. The BHHERA indicated that there is elevated risk to human and ecological receptors from exposure to PCB’s in Souhegan River sediments. An abbreviated remedial investigation for OU-2 was completed in September 2011 and a focused Feasibility Study is currently underway for OU-2.