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PUBLIC HEALTH ASSESSMENT

BEEDE WASTE OIL
PLAISTOW, ROCKINGHAM COUNTY
NEW HAMPSHIRE


SUMMARY

The Beede Waste Oil (CERCLIS NO. NHD018958140) site is located inPlaistow, Rockingham County, New Hampshire. The site is located in aprimarily residential area and consists of two parcels coveringapproximately 39 acres. The site has been unoccupied since August,1994 but has had prior use as a waste oil recycling and fuel oildistribution facility since the 1920s. Parcel 1 housed nearly allpast site operations and is the source of all site relatedcontamination. Two buildings exist on Parcel 1 including an abandonedbuilding and a larger main building. The abandoned building has beenthe target of vandalism and arson and is now completely enclosed bychain-link fencing. Parcel 2 has been used in the past for sand andgravel removal and is zoned for residential development. Contaminatedsoil piles generated by operations on Parcel 1 have been stored onParcel 2. There is a single residence located on the eastern borderof Parcel 2 along Old County Road. Fencing encompasses most of thesite but does not completely secure it.

More than 100 above-ground storage tanks (ASTs) are locatedon-site. Approximately 800 55-gallon drums containing regulated andnon-regulated waste are stored in a fenced area behind the mainbuilding. Eighteenundergroundstorage tanks (USTs) have been reported throughout the history ofthe site. The contents of drums and tanks located on-site includewaste oil, fuel oil, gasoline and water contaminated with varyingamounts of metals, chlorinated volatile organic chemicals andpolychlorinated biphenyls (PCBs). Also located on-site are severaluncharacterized soil piles and two surface water runoff pits.

Significant groundwater contamination has been discovered on-siteincluding high concentrations of volatile organic chemicals (VOCs)and a free product layer up to five feet thick suspended above thegroundwater table. This free product layer has been characterized asa light non-aqueous phase liquid (LNAPL) consisting of petroleumhydrocarbons contaminated with significant amounts of chlorinatedVOCs and PCBs. Five on-site source areas contributing to fivegroundwatercontaminationplumeshave been identified. Theseplumesare estimated to be moving with the overburden groundwater in aneasterly direction before discharging into Kelly Brook. Evidence ofpriorlandfillingincluding fifteen 55-gallon drums containing various VOCs was alsouncovered during excavation near one source area which is suspectedof contributing free product discharge into Kelly Brook. Pastattempts by the site owner to remove the free product layer viarecovery wells were discontinued for an undetermined reason.

On-site groundwater contaminants from at least one source areahave apparently impacted several residential drinking water wellslocated southeast of the site. The New Hampshire Department ofEnvironmental Services (NH DES) is currently monitoring severalresidential drinking water wells around the site for VOCs which havebeen detected in ten of these wells to date. Vinyl chloride iscurrently being detected in a condominium bedrock drinking water wellat or near its maximum contaminant level (MCL) of 2.0 ppb. Residentsin this complex were supplied bottled drinking water between July,1994 and May, 1995 and advised by the New Hampshire Division ofPublic Health Services (NH DPHS) to minimize showering and hot wateruse. A point-of-entry (POE) treatment device installed on this wellby NH DES on February 17, 1995 currently treats all of the waterentering the complex for VOC removal. Restrictions on the use of thistreated water were removed and the supply of bottled waterdiscontinued following two sample analyses of the treated water onMarch 9 and April 18, 1995 which detected no VOCs. Treated anduntreated water from this well continues to be monitored for VOCs byNH DES.

On-site surface soil sampling detected high levels (1,500 ppm) ofPCBs beneath a leaking AST. This AST was reportedly drained andrelocated on-site while the contaminated soil excavated from the areawas eventually moved off-site for disposal. Low level PCB soilcontamination has also been detected in 9 of 14 soil piles locatedon-site. VOCs, PCBs and elevated metal concentrations have beendetected in sediment and surface water samples collected from KellyBrook which flows along the northeast border of the site beforeemptying into the Little River.

NH DPHS has concluded that apublichealth hazard exists through ingestion and inhalation of VOCs inresidential drinking water wells.Exposurevia incidental ingestion of and dermal contact with contaminants inKelly Brook surface water and soil/sediment represent no apparentpublic health hazard. Ingestion of PCB contaminated fish taken fromKelly Brook and contact with PCB contaminated soil migrating from thesite to nearby residences represent potential exposure pathways.Exposureof trespassers to on-site soil is an indeterminate public healthhazard due to inadequate on-site soil characterization. Past exposureof former workers to on-site soil and indoor air also represents anindeterminatehealth hazard.

NH DPHS recommends that exposure to VOC contaminated drinkingwater in residential wells be reduced or eliminated. NH DES hassupplied bottled water to residents of the Howard Manor Condominiumsin the past and has installed a POE treatment system on the wellservicing these residents. NH DPHS has no current use restrictions onthis treated water since sample analyses by NH DES continue to verifythe effectiveness of the POE system.

NH DPHS recommends that access to Parcel 1 be completelyrestricted. Stored hazardous waste, inadequate on-site soilcharacterization and past evidence of trespass and vandalism indicatethe need to better secure the site in order to prevent increasedexposure to trespassers and/or further release of hazardous wasteinto the environment.

NH DPHS recommends continued monitoring of downgradientresidential drinking water wells for VOCs and a repeat analysis ofthese wells for lead and PCBs. Also, recommended is further surfacesoil testing for PCBs near abutting residences. NH DPHS is concernedwith the potential for PCB migration into nearby yard soils and isconsidering the need for off-site soil sampling.

The Health Activities Recommendation Panel (HARP) has recommendeda community health education effort to educate abutting residents asto the nature and degree of the hazards posed by the site. ATSDR willevaluate any new data as it becomes available and provide additionalrecommendations and follow-up as needed.

NH DPHS continues to evaluate drinking water analyses ofresidential wells. Letters are sent with recommendations on water useto those residents with wells showing detectable contamination.

NH DPHS will continue to evaluate new sampling data and addresscommunity health concerns as they arise. Kelly Brook fish and macroinvertebrate PCB sampling data is expected to be available from NHDES by the end of 1996 and will be evaluated by NH DPHS in order todetermine the potential exposure of residents to PCBs via theingestion of contaminated fish. A community health education effortwill be organized to provide information related to the potentialhealth effects associated with environmental contaminants in thearea.

BACKGROUND

A. Site Description and History

The Beede Waste Oil (BWO) site (CERCLIS No. NHD018958140) islocated in Plaistow, Rockingham County, New Hampshire (seeFigure 1). The site has been a concern toregulatory agencies since the early 1980's relative to environmentalissues including on-site waste oil discharges to soil, surface waterand groundwater, migration of on-site contaminants to nearby watersupply wells and Kelly Brook and storage of PCB contaminated wasteoil. The New Hampshire Division of Environmental Services (NH DES)has issued four Administrative Orders to joint operators of BeedeWaste Oil Corporation and Cash Energy Incorporated since November,1991 concerning illegal storage of hazardous waste, use of PCBcontaminated soil for cold-patch processing and the removal of freeoil product floating on on-site groundwater. Rockingham SuperiorCourt issued an Injunction Order requiring the site owner to addressissues at the site following a civil enforcement action brought bythe State of New Hampshire in December of 1992. According to the NHDES site manager, there has been only partial compliance with theseorders.

NH DES has designated BWO as an active hazardous waste site (NO.840468). The site was designated as a Federal Hazardous Waste siteand added to CERCLIS in December, 1993. NH DES issued a PreliminaryAssessment of the site in June, 1994 and a Site Investigation wasreleased in February, 1995.TheEnvironmental Protection Agency (EPA) Region I has prepared aHazard Ranking System (HRS) package which will be used to determinewhether the site is eligible for the National Priorities List (NPL).The site is expected to be proposed for inclusion on the NPL in thespring of 1996.

The site consists of two parcels. Parcel 1 has been used forvarious waste oil recycling operations and as a fuel oil distributionfacility since the 1920's. In the fall of 1992, Beede Waste Oil Corp.and Cash Energy Inc. ceased operations and Parcel 1 was leased toTri-State Resources which operated as a fuel oil storage anddistribution facility. Tri-State Resources ceased operations onAugust 10, 1994. The site owner submitted an application foroccupancy of Parcel 1 in January, 1995 which was subsequently deniedby the town. Parcel 2 has been used in the past for sand and gravelremoval and is zoned for residential development. There is a singleresidence located on the eastern border of Parcel 2 along Old CountyRoad. Potentially contaminated soil piles generated by operations onParcel 1 have been stored on Parcel 2. Both parcels totalapproximately 39 acres (see Figure 2).

There are two buildings located on Parcel 1. One structure isvacant and in disrepair and will be designated as the abandonedbuilding. Instances of trespassing and vandalism have occurred inthis building which have resulted in fires and broken windows. Theabandoned building was secured by fencing during the fall of 1994 byNH DES. The main building is in good repair and was regularlymaintained by a caretaker until the end of 1994. Approximately eighthundred 55-gallon drums and ten 275-gallon fuel oil tanks are locatedbehind the main building on a concrete pad beneath a metal canopy.This area was secured by fencing in the fall of 1994. Seven of thesedrums were found to contain waste oil, PCB contaminated soil andprotective gear generated by remedial work conducted on and off-siteby owners/operators (1). Two drumscontaining the excavated PCB contaminated soil were apparently movedoff-site for disposal. Later investigation of the drum storage areacounted 779 drums and 13 275-gallon above-ground storage tanks (AST).Composite analysis of these drums indicate that more than halfcontain RCRA regulated waste based on PCB, lead, benzene and cadmiumcontent (2).

Eighty-six ASTs of varying capacity are arranged in the three rowstowards the south end of Parcel 1. NH DPHS estimated a total liquidproduct of 821,592 gallons based on tank dimensions and measuredliquid levels with capacities ranging from 10,000 to 30,000 gallonsper tank (1). Subsequent sampling ofthese ASTs in May, 1995 by Total Waste Management Corporation (TWM)determined that 16 of these tanks contained greater than 3,000gallons of oil, 62 contained greater than 1 inch but less than 3,000gallons of oil, 3 contained oil and water and 6 contained only water.The TWM sampling also included analysis for PCBs which detected50-499 ppm in one of the 16 high volume tanks and 6 of the 62 lowvolume tanks. None of the 16 high volume tanks and one of the 62 lowvolume tanks contained oil at PCB levels greater than 500 ppm(2). Previous sampling of these ASTsdetected a maximum PCB concentration of 6,700 ppm in Tank #51 from asample taken on August 24, 1988 (3).

There are five 30,000 gallon and three larger ASTs (between215,000 and 260,000 gallons) formerly used for fuel oil distributionlocated south of the main building within an unlined containmentstructure. These larger ASTs were found to contain a total of lessthan 50,00 gallons of oil and sludge with one tank containingapproximately 180,000 gallons of water(2). Two other ASTs used as gasolineand waste oil storage tanks for on-site vehicle maintenance arelocated within the same containment. Documented petroleum spills haveoccurred within this structure. Four ASTs located near the siteentrance were reportedly used for kerosene and diesel fuel storage.Approximately 40 other miscellaneous ASTs (mostly empty) arescattered throughout the site. Seven of these were described as trucktrailer tanks located in the vehicle parts storage area near thewestern border of Parcel 1 (2).

An inventory of on-site USTs taken by Sanborn, Head Associates(SHA) recorded a total of 18 USTs as existing on-site at varioustimes. The SHA report notes that only two of these USTs are known toremain on-site. Three USTs apparently used to store waste oil,gasoline and #2 fuel oil are indicated on site sketch plan held bythe Plaistow Fire Department. Two of these are believed to have beenremoved and the third is thought to be a methanol containing tank nowstored above ground (4,5). Three other USTs, also believed to havebeen removed, were sampled and analyzed for PCBs in October, 1979.Aroclor-1016 was detected in two of these tanks at 172 and 678 ppm.The third tank was found to contain Aroclor-1260 at 950 ppm. A fourthsample reportedly taken from a tank truck used to oil the roads inSandwich, NH detected no PCBs(6).Subsequent sampling of these tanks in June, 1981 showed an increasein PCB levels with a maximum of 2100 ppm total PCBs includingAroclor-1242 (7).

Adjacent to the abandoned building is the location of a former144,000 gallon underground storage tank (UST) used for the temporarystorage of waste oil. This tank, which has been removed and replacedwith soil covered by cold-patch, is thought to have contributed tothe contaminant plume and free product layer associated withoverburden groundwater in the northeast corner of the site. Directlyadjacent to the former location of this UST is a past AST storagearea and soil pile which is also thought to have contributed to thisplume. Initial characterization of this free product revealed highconcentrations of VOCs. Two free product recovery wells wereinstalled by the site owner near the southeast side of the abandonedbuilding. Removal of the free product via these wells has beendiscontinued. Oil samples taken by EPA in December, 1994 from on-sitegroundwater monitoring wells located in the vicinity of this plumedetected PCBs at a maximum of 37.5 ppm(8). Further sampling of free productfrom monitoring wells in this area detected Aroclor-1242 andAroclor-1260 at a maximum of 20 and 60 ppm, respectively(2).

Excavation of a interceptor trench designed to intercept freeproduct migrating from this plume revealed several feet of buriedtrash and fifteen 55-gallon drums of liquid waste. Sampling of freeproduct in this trench revealed the presence of both VOCs and PCBs. Acomposite sample taken from these buried drums revealed the presenceof several VOCs including high concentrations of xylenes, acetone andmethyl ethyl ketone. Also detected were lower levels of chlorinatedVOCs including vinyl chloride, 1,1,1-trichloroethane andtrichloroethylene (see Appendix B)(1). Further sub-surface surveying ofthis area by SHA in May, 1995 using ground penetrating radar (GPR)detected metal debris and one crushed drum. Sampling of surface waterand sediment in Kelly Brook detected PCBs, VOCs and elevated metalconcentrations.

Two surface water runoff pits are located on-site. One surfacewater runoff pit (SWRP 1) is located just east of the site entranceon Kelly Road and just north of the fuel oil and diesel fuel ASTsnoted above (1). The other surfacewater runoff pit (SWRP 2) is located just northeast of the 86 ASTswhich reportedly had a history of oil discharges. According to the NHDES site manager, floating oil product was noted in this pit duringthe springs of 1993 and 1994 due to surface water runoff. PCBs weredetected in a surface soil sample taken from SWRP #2. Aerialphotographs dating back to 1962 indicates the presence of a formersurface lagoon constructed sometime between 1962 and 1971. It is nowreadily apparent that this lagoon received significant releases ofpetroleum before being filled in sometime between May, 1971 andNovember, 1975.

A total of five groundwater contaminant plumes have beenidentified that originate from source areas located on Parcel 1. Dataincluded in the SHA report indicate that the former lagoon area isthe source of a major contaminant plume moving in the overburden andimpacting off-site residential wells. Free product thicknessassociated with this plume has been measured as high as 5.4 feet.Other groundwater contaminant plumes defined in the SHA investigationinclude the plume thought to be originating from the 140,000 gallonUST and nearby ASTs. Free product has also been detected inassociation with this plume at depths of up to 5.2 feet. Contaminantplumes associated with the surface water runoff pits have also beenidentified. Free product thickness associated with the SWRP 1 andSWRP 2 plumes have been measured at depths up to 2.1 and 2.8 feet,respectively. A fifth source area located near monitoring well AE-12has been associated with a less significant plume. This plume iscause for concern, however, since the source area is towards thesouthern border of the site and proximal to off-site residentialwells (2).

Fourteen soil piles contaminated with virgin petroleum, waste oiland PCBs are scattered throughout both Parcel 1 and 2. Vehicle partsand assorted rubble are piled at the south end of Parcel 1 along thegravel road which accesses the southeast portion of the site. Asandblast grit pile is located on the western border of the site(5).

B. Site Visit

A site visit was conducted by Dennis Pinski and Robert Duff of NHDPHS and the NH DES site manager on July 26, 1994. The site wasentered through an electronic gate off Kelly Road. The gate is partof a chain link fence which extends only partially around thefacility. The gate which was reportedly in disrepair in the pastappeared to be functional at the time of the site visit. The areasurrounding the site is primarily residential including twomulti-unit complexes. Residences could be seen directly abuttingParcel 1 to northeast and to the west. Two bedrock drinking waterwells are located on-site. One provides water to the main building onParcel 1 and the other is in use by an abutting resident.

Surface water and sorbent pads were noted in the excavated trenchwhich runs along the eastern border of Parcel 1. Just beyond thetrench, separated by a chain link fence, is Kelly Brook which runsjust inside of the eastern border of Parcel 1 through a wetlands areaas it flows southeast towards the Little River. The NH DES sitemanager indicated that groundwater is moving east-northeast from thesite towards Kelly Brook.

No visible leaks were noted in any of the ASTs. The surface waterrunoff pits were dry but, according to the site manager, the pit nearthe ASTs has contained oil slicked water in the past during periodsof rain. The abandoned building located towards the northeast end ofParcel 1 was in considerable disrepair. The 55-gallon drums storedbehind the main building seemed to be fairly well protected from theelements by the concrete pad and metal roof which housed them. Tarpcoverings were noted on some but not all of the soil piles. Theadditional fencing installed around the abandoned building and thedrum containing area of the main building was not in place at thetime of the site visit.

C. Demographics, Land Use, and Natural ResourcesUse

There are approximately 1,300 people living within 0.5 miles and3,400 within 1.0 mile of the Beede Waste Oil site, respectively(1). There is no municipal watersupply available to the residents of Plaistow. Public water suppliesserve two multi-unit dwellings located within one-quarter mile of thesite. Other than these two complexes, all residents living within onemile of the site are served by either bedrock or overburden privatedrinking water wells. There are thirty-six water supply wells locatedwithin a 1,000 foot radius of the site(1).

Kelly Brook flows in a southeasterly direction along the northeastborder of Parcel 1 and through the eastern portion of Parcel 2. Thebrook empties into the Little River approximately 0.25 miles from thesite. The Little River then flows south for several miles beforeconverging with the Merrimack River in Haverhill, MA. There are nodrinking water intakes within fifteen miles downstream of the site.

Nearby land use includes an automobile junkyard and a machine shoplocated on North Main Street about 0.25 and 0.5 miles from the BWOsite, respectively. Both are listed as RCRA small quantity generators(5). Community concerns related to NHDPHS have indicated that gasoline fumes possibly originating from thejunkyard are detectable by residents living near the BWO site.Process Engineering Inc. is located on North Main Street at least 2.0miles from the BWO site and is the only Plaistow business listed inthe Toxic Release Chemical Inventory (TRI). The company has reportedreleases to the air and surface water of chromium, manganese, nickeland Freon-113 (9). The location andnature of these releases make it an unlikely contributor to anypotential adverse health effects impacting the population around theBWO site.

The former Plaistow dump is a Groundwater Protection Bureau (GPB)published site (No. 920235) located along Walton Road within 0.7miles of the BWO site. Also known as the Old Walton Road Dumpsite, itis located directly behind residential abutters to the BWO site onShady Lane. No information could be found to indicate the potentialof the former landfill to be a contributing source of contaminationin the area. The Old County Road landfill is located approximately2,500 feet to the northeast of the site.

D. Health Outcome Data

Cancer incidence data for the town of Plaistow between 1986 and1993 was obtained from the Chronic Disease Epidemiology Programwithin NH DPHS. This data was used to compare tumor specificpercentages of total cancers for the town of Plaistow to those of thestate. This comparison is included in Section B(Health Outcome Evaluation) of the Public Health Implications sectionof this document. No other health outcome data has been identified(10, 11).

COMMUNITY HEALTH CONCERNS

Several concerns were related to NH DPHS by nearby residents ofthe BWO site during a public availability session held on September15, 1994. These concerns are listed below and are addressed in thePublic Health Implications section of this document.

1. Citizens from two nearby residences not included in the currentdrinking water well sampling program were concerned about the qualityof their well water. They are both using their wells (bedrock) forwashing purposes only and have been drinking bottled water forseveral years. Each of these residents would like to have their welltested but not at their own expense.

2. Several residents expressed concern over soil which had beentrucked onto the site from an outside source. A related concern overapparent "late night" shipments onto the site and other "unknownactivities" was also voiced.

3. A resident from a nearby property (~ 200 ft. from BWO)expressed concern over the health of her daughter. She said that theyhad stopped drinking the water from her bedrock well approximatelyten years ago but have been using it for bathing and showering. Thisresident wants to know why her well water has not been tested. Shefeels her rights have been violated.

4. Several residents expressed concern over the potential forfires or explosions on the site.

5. A concern related to dermal contact during washing and bathingwith mercury contaminated well water was expressed by a resident.

6. A couple noted a "gasoline-like sheen" in a wetlands area oftheir property which borders the site. The residents wished to knowwhether this could be site related. Concern for the surroundingecology was also expressed by this couple who noticed a squirrel ontheir property which "looked as if it had mange".

7. A resident inquired as to whether the state has probed the sitewith metal detectors to determine if any undetected 55-gallon drumsremain on the site. Another resident claimed that drums have beendisposed of on the site.

8. The proprietor of a nearby multiplex which has shown drinkingwater well contamination (probably site related) wished to know if hecan be held legally liable for any adverse health effects which couldbe attributed to the contaminants.

9. Several residents expressed concern over a "documented"injection well installed by a previous owner of the site.

10. Several residents expressed concern over apparent dumping ofbattery acids on-site.

11. Several residents expressed concern related to migration ofsoil contaminants from on-site soil piles to off-site residences.PCBs (polychlorinated biphenyls) were noted as particular contaminantof concern in on-site soil. One resident noted that a "black powderysubstance" has blown into his yard from the site.

12. Several residents expressed concern related to the opening ofanother business on-site. These residents suggested that the site beclosed to any future operations. They also expressed concern that apotential new tenant on-site is affiliated with the present owner. Arelated question was raised as to whether another on-site businesswould add to the existing hazard.

13. One resident stated that on-site monitoring well data waspromised to be made available to him at 3-month intervals. He statedthat he has not seen any data in over a year.

14. One resident claimed that waste was being discharged throughhoses into surface runoff pits.

15. Concern over a leaking AST (Above-ground Storage Tank) wasexpressed.

16. One resident expressed concern about the health hazards ofantifreeze which has apparently been disposed of on-site.

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