PB99-963101
EPA 541-R99-001
1999
EPA Superfund
Record of Decision Amendment:
New Bedford Harbor Site
Hotspot OU
New Bedford, MD
4/27/1999
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NEW BEDFORD HARBOR SUPERFUND SITE
HOT SPOT OPERABLE UNIT
FINAL DRAFT AMENDED RECORD OF DECISION
April 1999
U.S. Environmental Protection Agency - Region I
New England
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DECLARATION FOR THE AMENDED RECORD OF DECISION
NEW BEDFORD HARBOR SUPERFUND SITE
HOT SPOT OPERABLE UNIT
STATEMENT OF PURPOSR
This decision document amends the selected remedial action for the New Bedford Harbor
Superfund Site, Hot Spot Operable Unit located in New Bedford, Massachusetts, as outlined in
toe April 6, 1990 Record of Decision, and is developed in accordance with the Comprehensive
Environmental Response, Compensation and Liability Act of 1980 (CERCLA) 42 USC Part
9601 et_seg., as amended, and to the extent practicable, the National Oil and Hazardous
Substances Contingency Plan (NCP), 40 CFR Part 300 eLsetj., as amended. The Director of the
Office of Site Remediation and Restoration has been delegated the authority to approve the
Amended Record Of Decision (ROD).
The Commonwealth of Massachusetts concurs with the selected remedy.
STATEMENT OF BASTS -
This decision is based on the Administrative Record which has been developed in accordance
withSection 113(k) of CERCLA and which is available for public review at the Wilks Branch
Library in New Bedford, Massachusetts and at the USEPA - Region I Office of Site Remediation
and Restoration Records Center in Boston, Massachusetts. The Administrative Record Index
(Appendix B to the Amended ROD) identifies each of the items comprising the Administrative
Record upon which the selection of the remedial action is based.
ASSESSMENT OF THR STTR
Actual or threatened releases of hazardous substances from this Site, if not addressed by
implementing the response action selected in this Amended ROD, may present an imminent and
substantial endangerment to the public health or welfare or to the environment.
DESCRIPTION OF THE SELECTED REMFJW
This decision document amends portions of EPA's 1990 ROD for the Hot Spot Operable Unit
The 1990 ROD called for dredging contaminated sediments from the identified hot spot areas
with PCB concentrations of 4,000 ppm or greater, transporting the dredged sediments to a
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shoreline Confined Disposal Facility (CDF), treatment of the supernatant, dewatering the
sediments and destruction of the PCBs in an on-site incinerator. The ash generated from the
incineration process was to be solidified/stabilized if necessary and permanently contained in the
on-site CDF. A more detailed description of the 1990 remedy is provided in Section V of this
decision document. The activities associated with dredging the hot spot areas and treating the
supernatant have been completed. This decision document selects off-site landfilling instead of
on-site incineration. The modified remedy consists of the following activities:
! • UP^ade Existing Site Facilities As Needed To accommodate sediment handling and
dewatenng activities it may be necessary to construct or improve access to the CDF and other
areas of the site. Treatment pads, temporary buildings and upgrades to site utilities may also be
needed.
2- Sediment Dewatering and Water Treatment The hot spot sediments currently stored
in the Sawyer Street CDF are approximately 50% water, which is too wet to be accepted by a
TSCA permitted hazardous waste landfill. The sediments will be dewatered to that level which
is in compliance with the permits and other requirements for the selected off-site TSCA
permitted landfill. Options for dewatering the sediments will be evaluated during the design
process. The sediment may be dewatered in-situ by extracting water via installed well points or
by removing the sediment from the CDF and mechanically dewatering it ex-situ, or a
combination of in-situ and ex-situ dewatering.
3- Transportation to an Off-Site TSCA Perniitted Landfill Following dewatering the
sediments will be loaded into sealed containers for transport to a TSCA permitted off-site'
hazardous waste landfill.
4- Air Monitoring Program There is a potential for an* emissions of PCBs during the
sediment removal and dewatering activities. A comprehensive ambient air monitoring program
will be designed, documented and implemented during the sediment removal and dewatering
operations to ensure that engineering controls are effective at protecting site workers and the
local community.
SPECIAL FINDINGS
Issuance of this ROD Amendment embodies specific determinations made by the Regional
Administrator pursuant to CERCLA. Under section 121(d)(4)(B) of CERCLA, the Regional
Administrator hereby waives 40 CFR 122.4© of the Clean Water Act (a regulation regarding
discharges to polluted water bodies). Due to the nature of the New Bedford Harbor site, full
compliance with this requirement would result in greater risk to human health and the
environment thqp non-compliance.
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DECLARATION
The selected remedy is protective of human health and the environment, attains federal and state
requirements that are applicable or relevant and appropriate for this remedial action, and is cost
effective. The selected remedy provides a permanent solution for the hot spot sediments. While
it does not satisfy the statutory preference for remedies that utilize treatment as a principal
element to reduce the toxicity, mobility or volume of hazardous substances, it does permanently
isolate these sediments from human and environmental receptors by containing them in an off-
site TSCA permitted chemical waste landfill in perpetuity in a safe and protective fashion. In
addition, water removed from the hot spot sediments prior to off-site transportation to a TSCA
landfill will be treated to meet stringent discharge standards.
As the remedy for this operable unit will not result in hazardous substances remaining on site
above health-based levels, site reviews for this operable unit will not be needed every five years.
The remedy selected in the September 1998 ROD for the Upper and Lower Operable Unit of this
Site will result hi hazardous substances remaining on site above health-based levels and,
therefore, site reviews will be conducted every five years after commencement of the upper and
lower harbor remedial action to ensure that the upper and lower harbor remedy continues to
provide adequate protection of human health and the environment.
Date Patricia L. Meaney, Director
Office of Site Remediation and Restoration
EPA - New England
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Table of Contents
I. SITE NAME, LOCATION, DESCRIPTION AND RATIONALE FOR
s AMENDMENT 1
II. SITE HISTORY AND ENFORCEMENT ACTIVITY 3
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III. COMMUNITY PARTICIPATION 4
IV. SCOPE AND ROLE OF OPERABLE UNIT 8
V. DESCRIPTION OF CHANGES TO THE 1990 REMEDY 8
DESCRIPTION OF THE 1990 REMEDY... 8
1990 REMEDY ACTIVITIES COMPLETED TO DATE 9
CHANGES TO THE 1990 REMEDY 10
VI. SUMMARY OF SITE CHARACTERISTICS 11
EXISTING SITE CONDITIONS 11
• Overall Site Layout 12
Existing CDF Conditions 12
HOT SPOT SEDIMENT CHARACTERIZATION 13
Chemical Characterization .15
Physical Characteristics 18
VH. SUMMARY OF SITE RISKS 18
VHI. DESCRIPTION OF AMENDMENT ALTERNATIVES EVALUATED 19
DC COMPARATIVE ANALYSIS OF THE ORIGINAL REMEDY AND
AMENDED REMEDY 20
X. THE SELECTED REMEDY • 26
XI. STATUTORY DETERMINATIONS 27
XH. DOCUMENTATION OF NO SIGNIFICANT CHANGES 31
I. STATEROLE 32
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Figures
1. Study areas
2. Fishing Closure Areas
3. Aerial Photograph of the Sawyer Street site and the surrounding area
4. Site Layout Plan
Tables
1. Summary of PCB and Oil and Grease Data for the Hot Spot Sediments
2. PCB and Oil and Grease Results for the USAGE Samples Collected in June 1995
3. Summary of Chlorinated Benzene Data for the Hot Spot Sediment (Third Pilot Study)
4. Summary of PAH Concentrations for the Hot Spot Sediment (Third Pilot Study)
5. Summary of (2,3,7,8 Substituted Isomers} Data for the Hot Spot Sediment (Third Pilot Study)
6. Summary of Dioxb and Furan Data (Totals) for the Hot Spot Sediment (Third Pilot Study)
7. Summary of Metals Data for the Hot Spot Sediment (Third Pilot Study)
8. TCLP Results for Hot Spot Sediment (Third Pilot Study)
9. Chemical Specific ARARs and TBCs
10. Location Specific ARARs and TBCs
11. Action Specific ARARs and TBCs
Appendices
Appendix A - Responsiveness Summary
Appendix B - Administrative Record Index
Appendix C - State Concurrence Letter
Appendix D - References Cited
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NEW BEDFORD HARBOR SUPERFUND SITE
HOT SPOT OPERABLE UNIT
AMENDED RECORD OF DECISION
APRIL, 1999
I. SITE NAME, LOCATION, DESCRIPTION AND RATIONALE FOR
AMENDMENT
SITE NAME: The New Bedford Harbor Superfund Site.
SITE LOCATION: The New Bedford Harbor Superfund Site (the Site), located in Bristol County,
Massachusetts, extends from the shallow northern reaches of the Acushnet River estuary south
through the commercial harbor of New Bedford and into 17,000 adjacent acres of Buzzards Bay
(Figure 1).
SITE DESCRIPTION: Industrial and urban development surrounding the harbor has resulted in
sediments becoming contaminated with high concentrations of many pollutants, notably
polychlorinated biphenyls (PCBs) and heavy metals, with contaminant gradients decreasing from
north to south. From the 1940s into the 1970s two electrical capacitor manufacturing facilities, one
located near the northern boundary of the site (the Aerovox facility) and one located just south of
the New Bedford Harbor hurricane barrier (the Cornell-Dublier facility), discharged PCB-wastes
either directly into the harbor or indirectly via discharges to the City's sewerage system. The Site
has been divided into three geographical areas: upper harbor (including the hot spot area), lower
harbor and outer harbor (Figure 1). The hot spot is an area of approximately five acres with sediment
PCB levels in excess of 4,000 ppm located along the western bank of the upper harbor, directly
adjacent to the Aerovox facility (Figure 1). The Site is also defined by three state-sanctioned fishing
closure areas extending approximately 6.8 miles north to south and encompassing approximately
18,000 acres hi total (Figure 2).
The City of New Bedford, located along the western shore of the Site, is approximately 55
miles south of Boston. During most of the 1800s, New Bedford was a world renown center of the
whaling industry. More recently New Bedford has attracted large community of immigrants from
Portugal and the Cape Verde islands. As of 1990, approximately 27% of New Bedford's 99,922
residents spoke Portuguese in their homes (US Census Bureau, 1997). Including the neighboring
towns of Acushnet, Fairhaven and Dartmouth, the combined 1990 population of the New Bedford
area was approximately 153,000. New Bedford is currently home port to a large offshore fishing
fleet and is a densely populated manufacturing and commercial center. By comparison, hi Fairhaven
and Acushnet, the eastern shore of the Acushnet River is predominantly residential or undeveloped.
Some of Fairhaven's shore is utilized by small boating related industries. A large (approximately
70 acre) salt marsh system has formed along almost the entire eastern shore of the upper harbor.
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The Acushnet River's 16.5 square mile (43 km2) drainage basin (VHB, 1996) discharges to
New Bedford Harbor in the northern reaches of the Site, contributing relatively minor volumes of
fresh water to the tidally influenced harbor. Its estimated mean annual flow of 30 cubic feet per
second is only about 1% of the average tidal prism (the volume of water which flows into and out
of the Harbor during the course of a complete flood/ebb tide cycle) (NUS, 1984). Numerous storm
drains, combined sewer overflows (CSOs) and industrial discharges, as well as smaller brooks and
creeks, also discharge directly to the Site. The upper and lower harbors are believed to be areas of
net groundwater discharge and are generally described as a shallow, well-mixed estuary.
The upper harbor comprises approximately 187 acres, with current sediment PCB levels
ranging from below detection to approximately 4,000 ppm. Prior to the removal of the Hot Spot
sediments from the upper harbor in 1994 and 1995 as part of EPA's original Hot Spot cleanup plan
(see Section V. below), sediment PCB levels were reported higher than 100,000 ppm in the upper
harbor. The boundary between the upper and lower harbor is the Coggeshall Street bridge where the
width of the harbor narrows to approximately 100 feet. The lower harbor comprises approximately
750 acres, with sediment PCB levels ranging from below detection to over 100 ppm. The boundary
between the lower and outer harbor is the 150 foot wide opening of the New Bedford hurricane
barrier. (The hurricane barrier was constructed in the mid- 1960s). Sediment PCB levels in the outer
harbor are generally low, with only localized areas of PCBs hi the 50-100 ppm range near the
Cornell-Dubilier facility and the City's sewage treatment plant's outfall pipes. However, this area
is still being characterized by EPA. The southern extent of the outer harbor and the Site is an
imaginary line drawn from Rock Point (the southern tip of West Island hi Fairhaven) southwesterly
to Negro Ledge and then southwesterly to Mishaum Point hi Dartmouth (Figure 2).
RATIONALE FOR AMENDMENT: In 1990, EPA issued the Record of Decision (1990
Hot Spot ROD) for the Hot Spot Operable Unit of the Site (USEPA, 1990), hi accordance with the
Comprehensive Environmental Response, Compensation and Liability Act (CERCLA), 42 USC §§
9601 etseq., and the National Oil and Hazardous Substances Pollution Consistency Plan (NCP), 40
CFR Part 300. Based on a vehement and Congressionally supported reversal in community
acceptance of the 1990 Hot Spot ROD's on-site incineration component of the remedy, EPA
suspended plans to incinerate the Hot Spot sediments hi New Bedford. Working with the local
community, EPA agreed to study other options for treating the Hot Spot sediments and to amend
the 1990 Hot Spot ROD with a consensus based cleanup plan. Refer to the Community Participation
section of this Amendment for additional details regarding community opposition to incineration and
the consensus building process. This ROD Amendment addresses the changes to the original 1990
Hot Spot ROD which resulted from both community input and additional research into treatment and
disposal alternatives for the Hot Spot sediments.
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II. SITE HISTORY AND ENFORCEMENT ACTIVITIES
Details of the earlier Site History and Enforcement Activities are presented in the 1990 Hot
Spot ROD and the December 1997 Hot Spot Feasibility Study Addendum (Foster Wheeler, 1997a).
The following is an update to the Site History and Enforcement Activities which have occurred since
issuing the 1990 Hot Spot ROD.
InApril 1990, EPA issued the Hot SpotROD. The original cleanup plan set forth in the 1990
Hot Spot ROD called for dredging of the Site's most highly PCB-contaminated sediments from the
upper harbor, incinerating the sediments in an on-site treatment facility to destroy the PCBs, and
storage of the treated sediments in a shoreline disposal facility. This ROD specified a 4,000 ppm
PCB level to define the area of Hot Spot sediments to be dredged.
In 1991 and 1992, the Unites States, the Commonwealth and five defendants in litigation
filed by the EPA and Commonwealth of Massachusetts regarding this site - Aerovox Incorporated,
Belleville Industries, Inc., AVX Corporation, Cornell-Dubilier Electronics, Inc., and Federal Pacific
Electric Company (FPE) - reached settlement regarding the governments' claims. The governments'
claims against the sixth defendant, RTE Corporation, were dismissed on jurisdictional grounds. The
federal and state governments recovered a total of $99.6 million, plus interest, from the five settling
defendants.
The terms of the settlements are set forth in three separate consent decrees. Under the first
consent decree, Aerovox Incorporated and Belleville Industries, Inc. were required to pay a total of
$12.6 million, plus interest, to the United States and the Commonwealth for damages to natural
resources and for past and future Site response costs. The court approved and entered this consent
decree in July 1991. Under the second consent decree, AVX Corporation was required to pay $66
million, plus interest, to the governments for natural resource damages and for past and future Site
response costs. This decree was approved and entered by the court in February 1992. Under the
third consent decree, CDE and FPE paid $21 million, plus interest, to the governments for natural
resource damages and for past and future Site response costs. This decree was approved and entered
by the Court in November 1992.
In April 1992, EPA issued an Explanation of Significant Differences (USEPA, 1992) to
change the storage of ash generated from the incineration of Hot Spot sediments from temporary
storage in an on-site Confined Disposal Facility (CDF) to permanent storage in an on-site CDF.
In 1993, due to a vehement and Congressionally supported reversal in public support for the
incineration component of the cleanup plan at about the time the incinerator was being mobilized,
EPA agreed to terminate the incineration contract and begin studies of other possible options for
treating the Hot Spot sediments. The New Bedford Harbor Superfund Site Community Forum (see
Section ffl. below) was created in late 1993 to develop a consensus based cleanup plan to replace
the on-site incineration component of the original cleanup plan.
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During the 1994-95 construction seasons the dredging component of the 1990 Hot Spot
remedy decision, was implemented. Dredging of about 14,000 cubic-yards in volume and 5 acres
in area began in April 1994 and was completed in September 1995. The dredged sediments are
currently stored in a shoreline confined disposal facility (CDF) located at the eastern end of Sawyer
Street in New Bedford.
In October 1995, the EPA issued an Explanation of Significant Differences (USEPA 1995)
to document the need for interim storage of the dredged Hot Spot sediments in the Sawyer Street
CDF while studies of treatment options not involving on-site incineration were conducted.
In December 1997, EPA issued a Hot Spot Feasibility Study Addendum Report (Foster
Wheeler, 1997a) which presented the evaluation of the non-incineration treatment options
investigated. InAugust 1998, EPA issued a Proposed Plan (USEPA, 1998a) to amend the 1990 Hot
Spot cleanup plan. The 1998 Proposed Plan called for dewatering the Hot Spot sediments and
transporting them to a permitted off-site hazardous waste landfill.
In September 1998, EPA issued the ROD for the Upper and Lower Harbor Operable Unit
(USEPA, 1998b). This ROD involves the dredging and containment of approximately 450,000
cubic-yards of PCB-contaminated sediments spread over about 170 acres. The dredged sediments
will be placed in four shoreline confined disposal facilities (CDFs). Seawater decanted from these
sediments will be treated before discharge back to the harbor. Refer to the September 1998 Upper
and Lower Harbor ROD for a more detailed description of the remedy.
III. COMMUNITY PARTICIPATION
Community Participation in the decision-making process has always been and continues to
be at a high level for this Site. EPA went far beyond the regulatory requirements for public
involvement while developing the 1989 Proposed Plan and 1990 Hot Spot ROD (refer to the 1990
Hot Spot ROD for details). Even though EPA sought to ensure that the public was well informed
and accepted the proposed cleanup plan, public opposition to the incineration component of the Hot
Spot cleanup plan formed soon after issuing the ROD. In late 1990, a New Bedford citizen's group,
Hands Across the River (later renamed the Hands Across the River Coalition), formed in part to
oppose on-site incineration of the Hot Spot sediments. Another group, Concerned Parents of
Fairhaven, also organized to oppose on-site incineration. Finally, in the spring of 1993, a third
citizen's group, the Downwind Coalition, was formed to oppose on-site incineratioa Later that year
the New Bedford City Council passed an ordinance (City of New Bedford, 1993) which required
City approval to transport the proposed incinerator through the City streets (however the ordinance
was not signed by the Mayor).
In December 1993, EPA and other site stakeholders initiated a professionally mediated
Communrty Forum process as an effort to build a lasting consensus for the Site's cleanup, including
the upper and lower harbor. Created to address public concerns raised by the incineration component
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of the 1990 Hot Spot cleanup plan, the Forum is made up of a wide variety of Site stakeholders,
including citizen group leaders, local and state elected officials, business representatives, EPA, the
MA DEP and other relevant state and federal agencies. The Forum continues to meet regularly and
has expanded its scope to include virtually all Site related cleanup issues. The Forum meetings are
taped and televised on local cable-access TV to reach as broad an audience as possible. All of the
Forum's proceedings have been documented in the Administrative Record for mis Hot Spot ROD
Amendment and the Administrative Record for the September 1998 Upper and Lower Harbor ROD.
The Forum adopted, as part of its mission, the identification of viable innovative technologies
which could be used as an alternative to on-site incineration. During a six month period in 1994,
the Forum engaged hi an extensive technology review consisting of company presentations and
literature reviews of alternative technologies for the on-site destruction of the PCB contaminated Hot
Spot sediments. Three general types of PCB treatment methods were selected by the Forum for
treatability studies: (1) solidification/stabilization; (2) contaminant destruction; and (3) contaminant
separation and destruction. In the summer of 1994, Forum members signed an agreement which
states that "the Forum favors a remedy for the Hot Sot sediments that permanently destroys the
PCBs". The agreement also outlined the Forum's continued involvement in the on-site treatability
studies.
The treatability study program was initiated in early 1995 with the field testing occurring in
late fall 1995 through 1996. Forum members agreed that the sediment dredging component of the
1990 Hot Spot cleanup plan should be implemented while the treatability studies were being
completed. Dredging of the Hot Spot Sediments was completed m September 1995. As stated
previously, the sediments are currently being stored in a shoreline confined disposal facility at the
eastern end of Sawyer Street in New Bedford.
A series of frequent Forum meetings were held throughout 1997 and into the early summer
of 1998 to publicly discuss and debate the results of the treatability studies and work toward a
consensus on the best cleanup option for the Hot Spot sediments. The results of the treatability
studies are documented hi the December 1997 Hot Spot Feasibility Study Addendum Report (Foster
Wheeler, 1997a). The Feasibility Study Addendum evaluated eleven cleanup alternatives. Refer
to Section Vin of this Addendum for a description of the eleven Alternatives evaluated. The eleven
alternatives were evaluated against the NCP criteria (except for State and Community Acceptance).
All the alternatives except No Further Action were found to satisfy the seven criteria evaluated
although some ranked better than others (see Section 6.3, Foster Wheeler, 1997a). The Community
Forum reviewed the findings of the Feasibility Study Addendum and provided feedback to EPA and
the State.
In addition to these Community Forum efforts, an independent panel session was assembled
by a local non-profit organization, Sea Change, Inc. Sea Change, an outgrowth of the Forum's work,
is a non-profit organization, which draws hi outside independent experts to perform technical
evaluations of waste issues for local communities and the Government. Sea Change held this public
panel session on October 30, 1997.
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After extensive discussion of the treatability studies and the evaluations which used the nine
NCP criteria, the Forum developed an initial recommendation which narrowed the range of
alternatives to two cleanup options. One option was for the on-site dewatering of the sediments and
transportation of the dewatered sediments to an off-site permitted hazardous waste landfill. The
other option was for the on-site separation of the PCB 's from the sediment by one of two innovative
technologies demonstrated during the treatability studies, thermal desorption or solvent extraction.
The resulting reduced volume of material containing the concentrated PCBs would be transported
off-site to a permitted hazardous waste incinerator. The remaining treated sediment, which would
contain small concentrations of heavy metals (but not at sufficient levels to be regulated as hazardous
waste) would be placed in one of the confined disposal facilities to be constructed as part of the
Upper and Lower Harbor ROD remedy to contain the less PCB-contaminated sediments to be
dredged from the upper and lower harbor (USEPA, 1998b).
The Forum sponsored two open public meetings, on June 4, 1998, and June 10, 1998, to
discuss the two options presented above. Over 800 invitations, along with a public Forum statement
and informational materials describing the two options, were sent out prior to these meetings. In
addition, the first meeting was broadcast over the local cable television station. The meetings were
attended largely by residents of the neighborhoods in close proximity to the Sawyer Street CDF and
the site where the proposed treatment and/or dewatering facility would be built. The comments
received at these meetings strongly urged the Forum members to recommend off-site landfilling of
the Hot Spot sediments. The key reasons stated were concerns about the possibility of air emissions
or other problems occurring during the implementation of the separation technologies as well as
concerns about noise, lights and dust caused by the 24-hour per day operations. In addition,
residents pointed out that the landfilling option is significantly faster and less expensive than the
separation/destruction option.
After consideration of the public input received at the two Forum sponsored meetings and
after further discussion, the Forum made the following recommendations on June 17, 1998. For
reasons similar to those expressed at the open meetings by members of the public, a majority of the
Forum members recommend that the Hot Spot sediments be dewatered on-site and transported in
sealed containers to an off-site hazardous waste landfill permitted to accept PCB waste under the
Toxic Substances Control Act (TSCA), 15 USC §§ 2601 et seq. The reasons for this
recommendation are that the landfilling option presents fewer possibilities for operational problems
resulting in emissions or other impacts to the New Bedford community that the other options
presents. Some members of the Forum are particularly concerned about the possibility for problems
arising at the site, which is close to local businesses and residences, and thus feel that the Sawyer
Street site is a problematic location for the implementation of an innovative technology. In addition,
landfilling option can be done faster and at a lower cost than the other option. The Forum members
urge the EPA to select a landfill that is the most environmentally sound and impacts surrounding
community the least.
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A minority of the Forum members conscientiously recommend on-site separation by solvent
extraction and off-site destruction of the PCBs. The remaining treated sediment would be deposited
in one of the CDFs that are planned for the rest of the Harbor sediments. In making this
recommendation, the Forum minority's believes that EPA should choose an alternative that results
in the permanent destruction of the PCBs at an approved facility, as opposed to simply sending a
problem created in New Bedford to another community. The minority noted that this has been the
Forum's objective since it's inception. The Forum minority recommends solvent extraction because
it presents fewer possibilities for emissions than does thermal desorption. Further, the Forum
minority urges that the sediments be destroyed by an off-site method other than incineration. The
Forum minority is aware that all currently approved facilities for destruction of concentrated PCBs
are incinerators. However, the Forum minority is also aware that at least one non-incineration
technology (solvated electron technology) is under development and may be close to approval, and
others may emerge hi the near future. The Forum minority urges that the possibilities for using non-
incineration technologies be maximized during the bid selection process.
Even though there were majority and minority recommendations, all Forum members
reached consensus on the off-site landfilling option. The Forum recommendation for the landfilling
option was officially confirmed as of the date of their signatures to a June 1998 document entitled
New Bedford Harbor Superfund Site Community Forum Recommendation (Forum, 1998). The
EPA and MA DEP also signed this document as members of the Forum. However, the EPA
indicated that by concurring with the Forum consensus, EPA was not issuing a determination as to
the remedy to be selected for this Site and that the remedy selection will not be determined until after
completion of the requirements established under CERCLA and the NCP. The MA DEP also
indicated that their final decision on which remedy to support will be made after consideration of
comments received during the formal public comment period for the Proposed Plan, in accordance
with CERCLA and the NCP.
EPA published a Proposed Plan to Amend the 1990 Cleanup Plan in August 1998. The
proposed change calls for transporting the dewatered sediments to a TSCA permitted hazardous
waste landfill. The cleanup plan was recommended because EPA believed it offered the best
balance among the nine NCP criteria, including the protection of human health and the environment.
EPA held a public informational meeting on August 26, 1998 and a formal public hearing on
September 16, 1998. An informal poster board presentation was provided prior to starting the
informational meeting and hearing. The public comment period ran from August 27-September 25,
1998. All formal comments received on the August 1998 Proposed Plan are summarized and
responded to hi the Responsiveness Summary, Appendix A. All original comments to the August
1998 Proposed Plan are included hi the Administrative Record.
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IV. SCOPE AND ROLE OF OPERABLE UNIT
The New Bedford Harbor Site has been divided into three operable units, or phases of site
cleanup: The Hot Spot Operable Unit (which the April 1990 Hot Spot ROD and this Amendment
encompasses), the Upper and Lower Harbor Operable Unit, and the Buzzards Bay or Outer Harbor
Operable Unit. The ROD for the Upper and Lower Harbor Operable Unit was issued on September
25,1998. The ROD for the Outer Harbor Operable Unit is currently unscheduled pending additional
investigation in the outer harbor.
The hot spot areas are defined as those areas in the upper harbor with sediments contaminated
above 4,000 ppmPCBs. Most of the hot spot areas were dredged from the harbor in 1994 and 1995.
However, one of the hot spot areas (Area B, see USAGE, 1991) was not dredged during the hot spot
dredging operations due to its proximity to submerged high voltage power lines serving the City of
New Bedford. The remedy for the Upper and Lower Harbor Operable Unit includes the relocation
of the power lines and dredging of this last remaining hot spot area. See section XII of the
September 1998 Upper and Lower Harbor ROD (USEP A 1998b) for additional discussion regarding
the cleanup approach for the submerged power line area.
V. DESCRIPTION OF CHANGES TO THE 1990 ROD
DESCRIPTION OF 1990 REMEDY
The remedy selected by the 1990 Hot Spot ROD was developed to satisfy the following
remedial objectives:
• Significantly reduce PCB migration from the Hot Spot area sediment, which acts as
a PCB source to the water column and to the remainder of the sediments in the
harbor.
• Significantly reduce the amount of remaining PCB contamination that would need
to be remediated in order to achieve overall harbor cleanup.
• Protect public health by preventing direct contact with Hot Spot sediments.
• Protect marine life by preventing direct contact with Hot Spot sediments.
The design and specifications for the remedy selected hi the 1990 Hot Spot ROD to meet
the above remedial objectives were completed in December 1991 (USAGE, 1991b,c) and called for
the following major activities:
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1. Dredging. Dredging approximately 10,000 cubic yards of PCB-contaminated (from 4,000
to over 100,000 ppm) sediments and pumping this material to on-shore CDF (Sawyer Street Facility)
for subsequent treatment.
2. Treating Supernatant. A large volume of water co-dredged along with the sediments
requires treatment. As the dredged sediments settle in the CDF, the clarified surface layer, or
supernatant will be removed or decanted and treated on-site using the following unit processes:
• equalization
• coagulation and fiocculation
• settling
• filtration
• UV/oxidation
3. Sediment Removal Dewatering and Water Treatment After the sediments are decanted
and the wastewater treated, the sediments will be removed from the CDF for dewatering prior to
incineration. Water from the dewatering operation will be treated on-site prior to discharge to the
harbor.
4. On-site Incineration. The dewatered sediments will be incinerated in a transportable
incinerator that will be sited at the Sawyer Street location. The extremely high temperatures
achieved by the incinerator will result in 99.9999% destruction of PCBs. Exhaust gases will be
passed through air pollution control devices before being released into the atmosphere to ensure that
appropriate health and safety and air quality requirements are met.
5. Stabilization (if determined to be necessaryt. Following incineration, the Toxicity
Characteristic Leaching Procedure (TCLP), a leaching test, will be performed on the ash to
determine if it exhibits the characteristic of toxicity and is, therefore, considered a hazardous waste
under the Resource Conservation and Recovery Act (RCRA), 42 USC §§ 6901 et seq. If the TCLP
test reveals that the ash is a RCRA hazardous waste, the ash will be solidified such that the metals
no longer leach from the ash at concentrations that exceed the standards set forth for determining the
toxicity of a material.
6. On-site Disposal of Incinerator Ash. The ash from the incinerator will be permanently
disposed of in the Sawyer Street CDF. To ensure protectiveness, the CDF will be closed in
accordance with RCRA hazardous waste regulations for landfills.
1990 REMEDY ACTIVITIES COMPLETED TO DATE
Activities associated with the first two major components of the 1990 remedy, dredging and
treating the supernatant, have been completed. The CDF was upgraded in 1993 to include a double
high density polyethylene liner system. The CDF was originally constructed in 1988 as part of a
pilot dredging and disposal study conducted by the EPA and the U.S. Army Corps of Engineers
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(USAGE). Construction of a wastewater treatment facility consisting of the unit processes described
above was completed in June 1994. Dredging and treatment of the supernatant was completed in
September 1995. It was estimated that about 10,000 cubic yards of sediments needed to be dredged.
About 14,000 cubic yards of Hot Spot sediments were actually removed from the upper harbor via
hydraulic dredging and placed for interim storage in the Sawyer Street CDF. In October 1995, EPA
prepared an Explanation of Significant Difference to the 1990 Hot Spot ROD to address the need
for temporary storage of the Hot Spot sediment in the CDF while studies of alternatives to
incineration (the fourth component of the 1990 remedy) were being completed.
A concrete decontamination pad equipped with a steam cleaner and sump pump is also
located on the site. Six trailers are currently located on the site and are used as
shower/decontamuiation, laboratory, and office trailers. Six air monitoring stations are located on
platforms around the site. Electric power, potable water, and sewage facilities are also available on
the site. USAGE staff are present at the site during the day and a guard provides security at night.
Overall site security is provided by a six foot tall chain link fence. An aerial photograph of the
Sawyer Street Facility is provided as Figure 3.
CHANGES TO THE 1990 REMEDY
As discussed previously, EPA terminated the incineration component of the 1990 remedy
and worked with the New Bedford Harbor Community Forum to find an alternative to on-site
incineration of the Hot Spot sediments. This ROD Amendment selects off-site landfilling instead
of on-site incineration. This ROD Amendment satisfies the original remedial action objectives
presented above. The amended remedy replaces major activities three through six of the 1990
remedy described above with the following major activities:
1- Sediment Dewatering and Water Treatment. The sediments stored in the CDF are
approximately 50% water, which is too wet to be accepted by a TSCA permitted hazardous waste
landfill. The sediments will be dewatered to at least that level which is hi compliance with the
permits for the selected off-site TSCA permitted landfill. Options for dewatering the sediments will
be evaluated during the design process. The amount of dewatering required for the landfilling option
will be less than the amount of dewatering that would have been required prior to on-site incineration
of the sediments.
2. Transportation to an Off-Site TSCA Permitted Landfill. Following dewatering, the
sediments will be loaded into sealed containers for transport to a TSCA permitted off-site hazardous
waste landfill.
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A comparison of the original 1990 remedy and the modified remedy is provided below.
Original Remedy
Dredge the Hot Spot sediments from the
harbor and pump to Sawyer Street CDF
(completed in September 1995)
Decant supernatant, treat supernatant on-site
and discharge to the harbor (completed in
September 1995)
Dewater sediments prior to incineration, on-
site treatment of the water from dewatering
process and discharge of treated water to the
harbor
On-site incineration
sediments
of the dewatered
Perform TCLP testing of the incinerator ash
and stabilize as necessary
Place incinerator ash in Sawyer Street CDF
and close in accordance with RCRA
regulations for hazardous waste landfills.
Modified Remedy
Dredge the Hot Spot sediments from the
harbor and pump to Sawyer Street CDF
(completed in September 1995)
Decant supernatant, treat supernatant on-site
and discharge to the harbor (completed in
September 1995)
Dewater sediments prior to off-site landfilling.
on-site treatment of the water from dewatering
process and discharge of treated water to the
harbor
Load dewatered sediments into sealed
containers and transport to a TSCA permitted
landfill
VL SUMMARY OF SITE CHARACTERISTICS
This section of the report provides a description of the existing Sawyer Street Confined
Disposal Facility (CDF) that is currently being used to store the Hot Spot sediments and a chemical
and physical description of these sediments.
EXISTING SITE CONDITIONS
The Hot Spot sediments are currently stored in a double-lined CDF constructed along the
New Bedford Harbor shoreline. This CDF is adjacent to facilities at the Sawyer Street site remaining
from the Hot Spot dredging activities that were conducted by EPA and the USAGE during 1994 and
1995. The Sawyer Street site was also the location where the treatability studies were conducted.
The following subsections describe the overall site layout and the existing CDF conditions.
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Overall Site Layout:
The Sawyer Street location of the New Bedford Harbor Site is approximately eight acres in
size, including approximately three acres occupied by the CDF. The site is located at the eastern end
of Sawyer Street, on its north side, and abuts the Acushnet River to the east and vacant land to the
north and west. Land use in the vicinity of the site is a mixture of urban industrial and residential.
An aerial photograph of the site and surrounding area is included as Figure 3. A Site Layout Plan
is included as Figure 4.
An 80 foot x 120 foot bermed asphalt pad is located on the western side of the site. The pad
was constructed for the treatability study program. During the testing, the pad was covered with an
impermeable liner to prevent an inadvertent release of sediment or treatment reagents to the soil on
the site. Sump drainage from this pad was routed to the on-site water treatment facility. Following
completion of the treatability studies in 1996, this liner was appropriately decontaminated.
The site also includes a 350 gallon per minute (gpm) water treatment system enclosed within
a building. A concrete decontamination pad equipped with a steam cleaner and sump pump is also
located on the site. Several trailers are currently located on the site, these are used as
shower/decontamination, laboratory, and office trailers. Six air monitoring stations are located on
platforms around the site. Electric power, potable water, and sewage facilities are currently available
on the site. Overall site security is provided by a six foot tall chain link fence.
Existing CDF Conditions:
The CDF is illustrated on Figure 4 and can be seen in the aerial photograph included as
Figures. As shown in Figure 2, the CDF has three individual cells. Cell #1 was used as the initial
settling basin where the Hot Spot sediments were pumped following dredging. The cell has a double
HOPE liner and is approximately 200 feet by 400 feet wide and approximately nine feet deep. The
Hot Spot sediment in this cell is approximately six to seven feet deep.
The contaminated sediments in the CDF are currently covered with a 10-mil permalon cover.
This relatively thin cover was placed over the sediments as a temporary measure to minimize
volatilization and potential direct contact by human and/or ecological receptors. The cover is
weighted down with sand bags to prevent wind-damage. A layer of water is often maintained over
the cover during the summer months to assist in controlling PCB emissions.
As the dredged material settled hi Cell #1, the clarified surface layer, or supernatant was
routed to Cell #2 for temporary storage/flow equalization before receiving additional water
treatment. The supernatant was then pumped into the treatment building where a polymer was added
to enhance additional settling of solids hi Cell #3, which acted as a secondary clarifier. Subsequent
water treatment steps included sand filtration and treatment of the PCBs through Ultra Violet
Oxidation (UV/Ox) prior to discharge to the Acushnet River.
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As mentioned previously, during 1994 and 1995, the Hot Spot sediments were dredged from
the northern portion of the Acushnet River and placed in the Sawyer Street CDF. The dredging was
continued until analysis of post-dredging samples indicated that the Hot Spot sediments had been
removed and the cleanup goal of 4,000 ppm was achieved. In total, approximately 14,000 cubic
yards of sediment, weighing approximately 18,000 tons, were removed from the harbor and placed
in CDF Cell #1. Additional description of the Hot Spot sediments and their chemical and physical
composition are presented in the following section.
HOT SPOT SEDIMENT CHARACTERIZATION
The chemical and physical characteristics of the Hot Spot sediments are described in this
section. These descriptions are based largely on recent pilot study data, with reference to historical
data, as appropriate. The source of the data points and the results used to characterize the material
are discussed below.
Hot Spot sediments were initially defined in-situ as having total PCB concentrations greater
than 4,000 ppm and averaging approximately 20,000 ppm to 30,000 ppm. Removal of this Hot Spot
sediment was estimated to result in a total reduction of PCBs in the upper harbor by approximately
50 percent.
i
Sediment PCB concentrations determined during recent sampling of sediments from the CDF
ranged from 1,600 to 7,700 ppm. Based on results for samples collected from the CDF, in
conjunction with available historical data on the physical and chemical nature of the sediment,
average PCB concentrations in the CDF are estimated to be approximately 6,000 ppm.
This is lower than the historical in situ average of approximately 20,000 to 30,000 ppm. The
reason for this difference may be due to a variety of reasons including a biased CDF sampling
approach due to the limited number of sampling points, the heterogeneous nature of the dredged
material, treatment of PCBs that were transferred to the aqueous and colloidal phases during
sediment dredging and disposal within the CDF, dredging more sediments than originally planned,
and changes in analytical methodology.
In addition to PCBs, the Hot Spot sediment contains several other organic and inorganic
contaminants. Extractable oil and grease, as measured gravimetrically, comprise approximately two
to three percent of the sediment matrix. The sediment contains concentrations of other organic
compounds including chlorinated benzenes, polynuclear aromatic hydrocarbons (PAHs),
polychlorinated dibenzo-p-dioxins (dioxins) and polychlorinated dibenzofurans (furans). Several
heavy metals including arsenic, cadmium, chromium, copper, lead and zinc, were also detected at
elevated concentrations in the samples collected from the CDF. None of these contaminants have
been measured at sufficient levels so that the sediments would be regulated as hazardous waste.
Each of these contaminant groups are described in more detail below.
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Samples were collected from the CDF during several recent sampling events. The analytical
findings from these events are summarized in this section and, where appropriate, compared with
available historical data. The analytical methodologies and associated measures of quality control
and quality assurance are discussed in more detail in Section 4.3 of the December 1997 Hot Spot
Feasibiliy Study Addendum Report. Laboratory data reporting forms for the samples collected
during the pilot study program are included in the Data Compendium (Foster Wheeler 1997b).
Hot Spot sediment contained in the CDF was sampled on four occasions. These events
include a sampling event conducted by the USAGE in June 1995 and sampling conducted for each
of the three pilot study treatment processes tested in 1996. These three pilot scale studies (Ionics
RCC, Geosafe and SAIC/Eco Logic) are hereafter referred to as the first, second and third pilot
studies. The results from these four sampling events provide the basis for the Hot Spot sediment
characterization described in this section.
Samples collected by the USAGE in June 1995 were collected directly from six locations in
the CDF. Sediment for the first two pilot studies was removed from the CDF in the spring of 1996
and placed into oversized drums. Samples of this material were collected from the drums prior to
its use as feed material for the first and second pilot studies. Sediment for the third study was
removed from the CDF, transferred to drums, and sampled from the drums in the fall of 1996. This
sediment was removed from a similar location within the CDF. However, the material was retrieved
from a greater depth.
Chemical and physical data from the various sampling events are detailed in the following
subsections. In summary, the results for samples collected during the third pilot study were chosen
as the representative profile of the Hot Spot sediment. These results were generally consistent with
the historical Hot Spot data, although the PCB results were lower than the historical average of
approximately 20,000 ppm to 30,000 ppm. Results for oil and grease and four heavy metals of
concern were essentially the same for the third pilot study and the historical data. Based on the
available data, the results from the third pilot study appear to represent a reasonable average
concentration of contaminants in the CDF.
Initial in-situ sampling of the Hot Spot sediments was conducted from 1982 through 1988.
These data sets provide the basis for the historical information on the Hot Spot sediment. The
following five sediment sampling data sets were used to determine the nature and extent of PCB
contamination in sediment of the Acushnet River Estuary:
• U.S. Coast Guard Sediment Sampling Program (1982)
• USAGE FIT Sampling Program (1986)
• Battelle Hot Spot Sediment Sampling Program (1987)
• USAGE Wetlands and Benthic Sediment Sampling Program (1988)
• USAGE Hot Spot Sediment Sampling Program (1988)
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The data sets listed above were used by EPA to support the 1990 Hot Spot ROD. Other
relevant data sets that were included by EPA in the Administrative Record:
• DEQE sampling (1981)
• EPA sampling (November 1981)
• Aerovox sampling (March 1982)
• Aerovox/GE sampling (June 1986)
In summary, these four data sets are consistent with the magnitude and location of PCB
identified within the five data sets used to support the 1990 Hot Spot ROD.
Chemical Characterization:
PCB, oil and grease, selected semi-volatile, and Toxicity Characteristic Leaching Procedure
(TCLP) results for the sediment samples collected during the pilot study program are discussed in
this section. Where appropriate, the data are compared with the USAGE sampling conducted in June
1995. PCB data from the third pilot study and the USAGE 1995 samples 4 through 6 appear to be
most representative of the sediment contained within the CDF, based on historical data for the
sediment. Samples collected during the first and second pilot study and 1995 samples 1 through 3
appear to represent uncharacteristically low concentrations of contaminants due to settling at the end
of the dredge pipe. These results are further summarized and discussed below.
PCB and oil and grease data for the pilot study feed sediment samples are summarized in
Table 1. The results are presented as averages for tile first and second studies, and averages for the
third pilot scale study. This reflects the manner in which the sediment was collected and
homogenized for each study. During the spring of 1996, approximately five cubic yards of Hot Spot
sediment was removed from the CDF and homogenized. A similar procedure was performed in the
summer of 1996 to gather and homogenize feed sediment for the third pilot scale study. As shown
in the table, the average results for the first and second pilot studies were lower than for the third
pilot study.
The difference in average PCB concentrations between these two sediment removal exercises
is not surprising given the variability that is likely to exist throughout the CDF. However, it would
appear that sediment removed to support the third treatability study may be more representative of
the CDF as a whole. This judgment is in part, based on the PCB results obtained by the USACE
during the June 1995 sampling event and the historical in-situ measurements. These results of the
USAGE'S sampling of the CDF are summarized in Table 2.
In addition to the chemical analyses, the USACE evaluated the physical and chemical
composition of these samples. The results of this evaluation identified two distinctly different types
of sediment along the eastern wall of Cell #1 of the CDF. These included, the coarser material
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which had settled out at the end of the dredge discharge pipe (samples 1 through 3), and the samples
that were beyond the initial settling zone (samples 4 through 6). Given the hydrodynamic profile
of the CDF as a settling lagoon and based on a comparison with historical data, samples 4 through
6 appeared more likely to be representative of the CDF material than samples 1 through 3.
Sediment Semivolatile Concentrations:
Feed sample results from the third pilot study for chlorinated benzenes are summarized in
Table 3. Similar to the PCB and oil and grease results, chlorinated benzene results were slightly
lower in the samples collected during the first and second studies that those collected during the third
study, indicating that the chlorinated benzene concentrations may be somewhat proportional to the
PCB concentrations.
PAH results from the third pilot study are summarized in Table 4. In contrast to the
chlorinated benzenes, the results for PAHs were actually slightly higher in the samples for the first
and second study than in those collected during the third study. The average total PAHs were
reported to be 65 ppm in the first and second study, almost twice the 37 ppm average reported for
the third study. The pattern of PAH contamination does not correlate with the PCB observations.
This is likely due to historical point and non-point sources of PAHs along the harbor's edge. These
sources likely contributed PAHs to the harbor in a manner different from that of PCB. To maintain
consistency, the data from the third pilot study was used hi Table 4 to categorize the sediment.
CDF sample results are consistent with previous in-situ sampling, where total PAH concentrations
averaged approximately 70 ppm (the highest PAH concentration of 93 0 ppm was detected hi the Hot
Spot area). No discrete areas of elevated levels of PAH compounds were observed in the in-situ
sampling, suggesting that the PAH contamination is from non-point sources such as urban runoff.
PAH concentrations detected in the upper estuary sediment were similar to PAH concentrations
detected in other urban and industrialized areas (EPA, 1992).
Overall, concentrations of the semivolatile compounds, including the PAHs and the
chlorinated benzenes, total less than three percent of the PCB concentratioa This, in addition to the
relatively lower toxicity of most of these semivolatile compounds with respect to PCBs, indicates
that the majority of risk associated with the Hot Spot is attributable to PCBs.
Sediment Dioxin and Furan Concentrations:
Data for 2,3,7,8-substituted dioxins and furans from the third pilot study and the 2,3,7,8
tetrachlorodibenzo (2,3,7,8-TCDD) toxicity equivalents (TEQs) are summarized in table 5. TEQs
were calculated by multiplying the concentration of the specific 2,3,7,8- substituted congener by its
specific toxicity equivalent factor (TEFs). Further discussion of TEFs and a table summarizing the
TEF values are included in Section 4.3 of the December 1997 Hot Spot Feasibility Study Addendum
Report. The TEF calculation adjusts the concentration of the less toxic 2,3,7,8- substituted
congeners to the equivalent concentration (based on toxicity) of the most toxic dioxuVfuran congener
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(2,3,7,8-TCDD). Note that, by definition, the TEQ is related to the concentration of 2, 3, 7, 8-
substituted congeners but is not necessarily related to the total dioxin/furan concentration'
As was the case for the PCBs, dioxin and furan results from the first and second pilot studies
were slightly lower than for the third pilot study. The total 2,3,7,8-substituted isomer concentration
was 16.8 (ng/gm) (parts per billion or ppb) for the first and second studies, with a total TEQ
concentration of 1.3 ng/gm.
Table 6 summarizes the total dioxin and furan results from the third pilot study. Total
dioxins and furans total approximately 30 to 40 parts per billion (ppb). The total 2,3,7,8-TCDD
toxicity equivalent averages were approximately one to two ppb, over one million times less than
the total PCB concentration.
Sediment Metals Concentrations:
Metals results from the third pilot study are summarized in Table 7. Arsenic, cadmium,
chromium, copper, lead and zinc were identified as metals of concern for the site during the initial
phases of Rl/FS studies conducted during the early 1980's. In addition to potential risks associated
with these contaminants, metals contamination in the sediment is a concern from an engineering
perspective.
There are some public health risks associated with exposure to these metals; however, this
exposure is expected to comprise a small component of the total risk when compared to risks
associated with exposure to PCB-contaminated sediment. The interim storage of the Hot Spot
Sediment in the Sawyer Street CDF is currently preventing exposure.
TCLP Concentrations:
TCLP results for key contaminants are summarized in Table 8. The complete data set of
TCLP analysis results, including the raw data sheets for the three pilot studies, is included in the
Data Compendium (Foster Wheeler 1997b). The key contaminants summarized hi Table 8 were
chosen based on their presence in the Hot Spot sediment and/or because there is a TCLP regulatory
criteria for the contaminant. Some organic contaminants which have a regulatory criteria were not
included in this summary table, as they were reported as non-detect by the laboratory. As discussed
above, results from the third pilot study were chosen as representative of the Hot Spot sediment,
although the results from the first and second studies were similar. TCLP results for the sediment
do not exceed regulatory criteria for being regulated as hazardous waste for any of the listed
contaminants
No regulatory criteria are available for TCLP PCBs. Because PCBs are the primary
contaminant of concern in the Hot Spot sediment, the teachability (TCLP) data for PCBs are of
interest. The average TCLP PCB result was approximately 28 ug/L (ppb). In comparison with the
sediment concentration of 5,700 ppm, very little of the PCBs in the Hot Spot sediment leached into
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the TCLP aqueous solution. This is presumably because the PCBs are preferentially entrained in
the high organic matrix of the sediments.
Physical Characteristics
The Hot Spot sediments are generally a fine-sandy silt with some clay sized particles present.
The sediments are roughly 50 percent solids and 50 percent water with a wet unit weight of
approximately 1.2 tons per cubic yard. The specific gravity of the solid particles within the sediment
matrix is on the order of 2.4 to 2.5. The sediments also contain some shell fragments. However,
the majority of these fragments, passed a one-inch sieve that was used to pre-screen feed material
for two of the three pilot scale treatability studies.
Sediment from the third pilot study was evaluated for grain size distribution and found to be
similar in nature to the sediments from stations 4 through 6 of the 1995 USAGE CDF sampling
program. The results of a comparison of PCB concentrations from these samples have shown similar
consistency.
For potential full-scale treatment operations, the sediment would likely be a fine sandy silt,
with approximately 50% to 70% of the sediment passing the number 200 sieve. The sediment is also
approximately 50 percent moisture by weight. A small volume of larger sized particles is located
in the northeastern corner of the CDF, adjacent to the dredge disposal pipe terminus. In addition,
the contaminant levels associated with these larger particles are generally lower than the average Hot
Spot concentrations.
VII. SUMMARY OF SITE RISKS
Risks associated with exposure to the contaminants of concern (PCBs, cadmium, copper and
lead) in the Hot Spot sediments prior to their removal from the harbor were evaluated and discussed
in the 1990 Hot Spot ROD. As discussed previously, dredging of hot spot areas was completed in
1995 and the dredged sediments are currently stored in the Sawyer Street CDF.
The interim storage of the Hot Spot sediments in the Sawyer Street CDF has been protective
of human health and the environment but provides limited long-term protection. The limitation hi
long-term protection is due, primarily, to the limitations of the existing cover in containing the Hot
Spot sediments for a long period of time. The Sawyer Street CDF is currently operated as a
temporary storage facility and does not include a cover system which would provide long-term
isolation of contaminants within the CDF.
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VIII. DESCRIPTION OF AMENDMENT ALTERNATIVES EVALUATED
The New Bedford Harbor Hot Spot FeasMity Study Addendum Report (Foster Wheeler,
1997a) presents and analyzes all of the options EPA considered to replace the on-site incineration
component of the original remedy. EPA developed eleven options for the Hot Spot sediments
currently stored in the Sawyer Street CDF. These options are summarized below. More detailed
information on each option and a comparative analysis of the options can be found in the Feasibility
Study Addendum Report.
A. Limited or No Further Action (HS-1)
1 • No Further Action (HS-1 V The Sawyer Street facility would be operated and maintained
as it is today. This includes maintenance of the CDF cover, the current institutional controls of
fencing and site security, and continuation of the air and groundwater monitoring programs
B. Treat Contaminants On-site
2- Solvent Extraction and Solid Phase Chemical Destruction (HS-2AV Removal of the Hot
Spot sediments from the Sawyer Street CDF and separation of the PCBs and other organics through
solvent extraction. The concentrated oily extract would subsequently be treated on-site with solid
phase chemical dechlorination to destroy the PCBs. The final step involves placement of the
treatment residuals within a shoreline CDF.
3- Solvent Extraction and Gas Phase Chemical Destruction fHS-2BV Separation of the PP.Rg
and other organics through solvent extraction as described for HS-2A. The concentrated oily extract
would then be heated such that the waste would be transformed into a vapor and subsequently treated
with an on-site gas phase reduction reactor to destroy the PCBs. The final step involves placement
of the treatment residuals within a shoreline CDF.
4- Solvent Extraction and Off-Site IncinerationfHS-2C): Separation of the PCBs and other
organics through solvent extraction as described for HS-2A. The concentrated oily extract would
then be transported off-site for incineration at a permitted TSCA facility to destroy the PCBs. The
final step involves placement of the treatment residuals within a shoreline CDF.
5. Thermal Desorption and Solid Phase Chemical Destruction (YHS-3 AV Removal of the Hot
Spot sediments from the CDF followed by a mechanical dewatering step. The PCBs and other
organics would be separated through thermal desorption. The concentrated oily extract generated
by the thermal desorption process would subsequently be treated on-site with a solid phase chemical
dechlorination agent to destroy the PCBs. The final step involves placement of the treatment
residuals within a shoreline CDF.
6. Thermal Desorption and Gas Phase Chemical Destruction (HS-3BV Separation of the
PCBs and other organics via thermal desorption as described for HS-3A. The separated
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contaminants would subsequently be destroyed on-site in a gas phase reduction unit. The final step
involves placement of the treatment residuals within a shoreline CDF.
7. Thermal Desorption and Off-Site Incineration (HS-3C1: Separation of the PCBs and
other organics via thermal desorption as described for HS-3 A. The concentrated oily extract would
be transported off-site for incineration at a permitted TSCA facility to destroy the PCBs. The final
step involves placement of the treatment residuals within a shoreline CDF.
8. Staged Vitrification (HS-4): Removal of the Hot Spot sediments from the Sawyer Street
CDF followed by a thermal dewatering step to significantly reduce the moisture content. The dried
sediments would be placed within a portion of the CDF and treated through electrically generated
high temperatures (pyrolisis). The resulting product is an inert glass-like solid in which the PCBs
and other organics are thermally destroyed and any metals or other inorganics are immobilized into
a non-leachable form.
C. Contain Contaminants
9. In-Place Capping (HS-5V Following in place dewatering of the sediments with wick
drains, the sediments would be capped in-place using a multiple layer impermeable cap. This
alternative includes a significant long-term monitoring program for groundwater quality hi the
vicinity of the CDF and potential ah- releases.
E. Move Contaminants Off-site
10. Off-Site Landfilling (HS-6): This alternative involves dewatering the sediments either
in-situ or removing them from the Sawyer Street CDF and mechanically dewatering them.
Following dewatering, the sediments are transported off-site to a TSCA permitted hazardous waste
landfill.
11. Off-Site Incineration (HS-7): This alternative involves dewatering and removal of the
sediments from the CDF as described in alternative HS-6. The dewatered sediments would then be
transported off-site to a TSCA permitted incinerator to destroy the PCBs.
IX. COMPARATIVE ANALYSIS OF THE ORIGINAL REMEDY AND
AMENDED REMEDY
Section 121(b)(l) of CERCLA presents several factors that EPA is required to consider in
its assessment of alternatives. Building upon these specific statutory mandates, the NCP articulates
nine evaluation criteria to be used in assessing remedial alternatives. These criteria are as follows:
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Threshold Criteria
In accordance with the NCP, two threshold criteria must be met in order for the alternative
to be eligible for selection:
1. Overall protection of human health and the environment addresses whether or
not a remedy provides adequate protection, and describes how risks posed through
each exposure pathway are eliminated, reduced or controlled through treatment,
engineering controls or institutional controls.
2. Compliance with applicable or relevant and appropriate requirements (ARARs)
addresses whether or not a remedy will meet all of the ARARs of promulgated state
and federal environmental and facility-siting requirements, and if not, provides the
grounds for invoking a CERCLA waiver(s) for those requirements.
Primary Balancing Criteria
The following five criteria are used to compare and evaluate those alternatives which fulfill
the two threshold criteria.
3. Long-term effectiveness and permanence assesses alternatives for the long-term
effectiveness and permanence they afford, along with the degree of certainty that they
will be successful.
4. Reduction of toxicity, mobility or volume through treatment addresses the degree
to which alternatives employ recycling or treatment to reduce toxicity, mobility or
volume, and how treatment is used to address the principle threats posed by the site.
5. Short term effectiveness addresses the period of time needed to achieve protection
and any adverse impacts on human health and the environment that may be posed
during the construction and implementation of the alternative until cleanup goals are
achieved.
6. Implementability addresses the technical and administrative feasibility of an
alternative, including the availability of materials and services needed to implement
a particular option.
7. Cost includes estimated capital as well as operation and maintenance costs, on a net
present-worth basis.
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Modifying Criteria
The two modifying criteria discussed below are used in the final evaluation of remedial
alternatives generally after EPA has received public comment on the RI/FS and Proposed
Plan. .
8. State acceptance addresses the State's position and key concerns related to the
preferred alternative and other alternatives, and the State's comments on ARARs or
the proposed use of waivers.
9. Community acceptance addresses the public's general response to the alternatives
described in the remedial investigation, feasibility study and Proposed Plan.
The following is a comparison of the 1990 Hot Spot ROD remedy and the Amended ROD
remedy, contrasting each remedy's strength and weaknesses with respect to the nine evaluation
criteria.
1. Overall Protection of Human Health and the Environment
This criterion considers whether the remedy, as a whole, will protect human health and the
environment. This includes an assessment of how public health and environmental risks are properly
eliminated, reduced, or controlled through treatment, engineering controls, or institutional controls.
The original remedy and amended remedy are both protective of human health and the
environment. The original remedy called for dredging the Hot Spot sediments from the harbor,
dewatering the sediments, and destroying the PCBs in an on-site incinerator. Incineration is a
proven technology for the destruction of PCBs, and ah- pollution control devices are routinely used
to meet allowable levels of air emissions. The residual ash from the incineration process was to be
permanently stored in the Sawyer Street CDF. To ensure protectiveness of human health and the
environment, the CDF was to be closed in accordance with the RCRA Hazardous Waste Regulations
for landfills. •
The amended remedy calls for transporting the dredged Hot Spot sediments, after dewatering
on-site, to a TSCA permitted off-site hazardous waste landfill instead of on-site incineration.
Therefore, no risks to the health of the community or harbor due to potential exposure to the Hot
Spot sediments will remain at the Site. As with the original remedy, removing the sediments from
the Sawyer Street CDF may pose some risk of exposure to PCB emissions during the removal and
dewatering operations. These short-term risks can be easily minimised using engineering controls
and are relatively minor in comparison with the long-term risks associated with leaving the
sediments in place.
22
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2. Compliance with Applicable and Relevant and Appropriate Requirements
This criterion addresses whether or not a remedy complies with all promulgated state and
federal environmental and facility siting requirements that apply or are relevant and appropriate to
the conditions and remedy at a specific site. If an Applicable or Relevant and Appropriate
Requirement (ARAR) cannot be met, the analysis of a remedy must provide the grounds for
invoking a statutory waiver.
The original and amended remedy comply with all Federal and State ARARs with only one
waiver. The sediment dewatering component of the original and amended remedy requires
discharging treated water into the upper harbor. Water discharges are regulated under state and
federal water quality ARARs. Operation of the Sawyer Street treatment plants requires a waiver
of a provision of the National Pollutant Discharge Elimination System requirements of the federal
Clean Water Act (CWA), Section 402. The provision can be interpreted to prohibit new discharges
into waters that do not meet applicable water quality criteria, unless certain conditions are met (40
CFR 122.4(i)). Harbor waters are presently degraded; they neither meet AWQCs for copper and
PCBs nor are conditions concerning pollutant load allocations and compliance schedules for the
upper harbor waters likely to be accomplished within a reasonable time before the remedy is
implemented. A CERCLA waiver under Section 121(d)(4)(B) was invoked in the Proposed Plan
to Amend the Original Remedy and public comment specifically requested. The waiver was invoked
since compliance would essentially prevent the cleanup of this Site, resulting in greater risk to
human health and the environment. No comments were received on this particular waiver. Issuance
of the ROD enacts the waiver.
Further, since New Bedford Harbor water quality is so degraded as to preclude dilution of
any proposed discharge of PCBs and copper, Section 402 of the CWA requires that discharges of
PCBs and copper meet the respective AWQCs at the discharge point. Consistent with Section 303
of the CWA and its Total Maximum Daily Load (TMDL) approach, however, discharge limits for
copper and PCBs will be below current background levels but above AWQCs. This approach allows
for attainment of the water quality standards for copper and PCBs throughout the water body in a
phased or step-wise approach. The amount of copper and PCBs that will be discharged from the
treatment plants will be more than offset by the permanent removal of copper and PCB contaminated
Hot Spot sediments from the Harbor. It is expected that the treatment facilities can attain the
AWQCs for cadmium, chromium and lead, the other contaminants of concern from a wastewater
discharge standpoint.
3. Long-term Effectiveness and Permanence
This criterion refers to the ability of a remedy to maintain reliable protection of human health
and the environment over time once the remedial action is complete.
The original incineration remedy would have provided long-term protection and permanence
since the PCBs would have been destroyed during the incineration process. The residual ash, which
23
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could have been considered a hazardous waste, would have been safely contained and monitored in
a facility built to comply with RCRA Hazardous Waste Regulations for landfills.
The amended remedy will provides long-term protection and permanence since the Hot Spot
sediments will be transported from the Sawyer Street site to an off-site TSCA permitted hazardous
waste landfill.
4. Reduction of Toxicitv. Mobility, and Volume through Treatment
This criterion contains three measures of the overall performance of a remedy. The 1986
amendments to the Superfund statute emphasize that, whenever possible, EPA should select a
remedy that uses a treatment process to permanently reduce the level of toxicity of contaminants at
the Site, inhibit or eliminate the spread of contaminants away from the source of contamination, and
reduce the volume, or amount of contamination at the Site.
The original remedy uses a proven treatment technology, incineration, to reduce the toxicity,
mobility and volume of contaminants. Incineration would remove 99.9999% of the PCBs from the
sediments.
The amended remedy does not use treatment to reduce the mobility or toxicity of
contaminants. Although the 1986 amendments to CERCLA and the NCP states a preference for
treatment, an evaluation of site conditions, such as proximity to urban communities^ concluded that
there were sufficient negative effects from operating innovative treatment technologies at the site
to warrant selecting off-site landfilling over on-site treatment. The Hot Spot sediment dewatering
process will reduce the volume of contaminated sediments by 20% to 30%.
5. Short-term Effectiveness
This criterion refers to the likelihood of adverse impacts on human health or the environment
that may be posed during the construction and implementation of a remedy.
EPA does not believe that the original remedy or amended remedy pose significant short-
term effectiveness concerns. The potential exposure of site workers and area residents to
contaminated sediments or air emissions during implementation of the on-site incineration remedy
or off-site landfilling would be minimized by using safety plans that include air emissions controls
and a network of ambient air monitors to assess potential releases to the air during cleanup
operations. Off-site transportation of the Hot Spot sediments will result hi a small increase in truck
traffic through the community. The trucks will be routed to minimize the impact to local traffic.
The time to complete either the original or amended remedy is the same, about one year.
24
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6. Imolementabilitv
This criterion refers to the technical and administrative feasibility of a remedy, including the
availability of materials and services needed to implement the remedy.
EPA considers both the original and amended remedy to be implementable. The amended
remedy is routine in comparison to the original remedy. While incineration is known to be a proven
technology for the destruction of PCBs, testing in the form of a test burn would have been required
to determine optimum equipment configuration and operating parameters. The technology to
implement the amended remedy is routinely available and there are currently several off-site TSCA
permitted hazardous waste landfills available for disposal of the Hot Spot sediments.
7. Cost
This criterion includes the capital (up-front) cost of implementing each remedy. The costs
described below do not include previous costs which are substantial. The cost estimates only reflect
those costs that would be incurred henceforth to implement either the unfinished components of the
original on-site incineration remedy or the amended remedy.
Original On-Site Incineration Remedy: Total capital cost = $18,200,000
Amended Remedy (Off-Site Landfilling): Total capital cost = $14,800,000
Note: The original on-site incineration remedy included disposing the incinerator ash in an
on-site CDF and capping the CDF. The long-term O&M costs for this component of the original
remedy is not included in the capital cost of $18,200,000. The amended remedy does not require
any long-term O&M.
8. State Acceptance
This criterion addresses whether, based on its review of the data derived from the Site and
the Proposed Plan, the State concurs with, opposes, or has no comment on the Amendment EPA has
selected for the Site.
The Massachusetts Department ofEnvironmental Protection (DEP) has reviewed the August
1998 Proposed Plan to Amend the 1990 Cleanup Plan and a draft of this Amendment. The DEP
concurs with the remedy change. The DEP has provided a letter of concurrence which is provided
hi Appendix C.
9. Community Acceptance
This criterion addresses whether the public concurs with EPA's proposed Amendment.
Community acceptance of this Amendment to the 1990 Hot Spot ROD was evaluated based on
25
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comments received at the public hearing and a recommendation from the New Bedford Harbor
Community Forum discussed in Section III of this Amendment.
As discussed in Section III, EPA's proposed Amendment is also the consensus
recommendation of the New Bedford Harbor Superfund Site Community Forum. Based on the
Public Hearing and comments received during the public comment period, it appears that the
proposed Amendment has broad community support. The proposed Amendment is also supported
by the Mayor of New Bedford and Congressman Barney Frank.
X. THE SELECTED REMEDY
After an extensive process of evaluating alternatives to the on-site incineration component
of the original remedy and developing a consensus among Site stakeholders, EPA has selected the
remedy described below as the best balance between the nine criteria. The selected remedy is a
removal and disposal alternative using a permitted off-site facility. The cleanup operations will
include the following activities:
1. Upgrade Existing Site Facilities As Needed. To accommodate sediment handling and
dewatering activities is may be necessary to construct or improve access to the CDF and other areas
of the site. Treatment pads, temporary buildings and upgrades to site utilities may also be needed.
2. Sediment Dewatering and Water Treatment. The Hot Spot sediments currently stored
in the Sawyer Street CDF are approximately 50% water, which is too wet to be accepted by a TSCA
permitted hazardous waste landfill. The sediments will be dewatered to that level which is in
compliance with the permits and other requirements for the selected off-site TSCA permitted
landfill. Options for dewatering the sediments will be evaluated during the design process. The
sediment may be dewatered in-situ by extracting water via installed well points, or by removing the
sediment from the CDF and mechanically dewatering it ex-situ, or a combination of in-situ and ex-
situ dewatering. Water extracted from the Hot Spot sediment during the dewatering operations will
be treated in the existing Sawyer Street wastewater treatment plant prior to discharge into the harbor.
3. Transportation to an Off-Site TSCA Permitted Landfill. Following dewatering, the
sediments will be loaded into sealed containers for transport to a TSCA permitted off-site hazardous
waste landfill. Trucks leaving the Sawyer Street Site will be routed to minimize their impact to local
traffic
4. Air Monitoring Program. There is a potential for ah" emissions of PCBs during the
sediment removal and dewatering activities. A comprehensive ambient air monitoring program will
be implemented during the sediment removal and dewatering operations to ensure that engineering
controls are effective at protecting site workers and the local community.
The time to complete the activities describe above has been estimated at no more than two years, and
26
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a cost of $ 14,800,000. EPA may use the Sawyer Street site, including the three cells of the CDF and
the water treatment plant to support Phase H of the harbor cleanup. The Upper and Lower Harbor
ROD for Phase n was released in September 1998 and calls for dredging an additional 450,000 cubic
yards of PCB-contaminated sediments from the harbor and containing the dredged sediments in
shoreline CDFs. The future use of the Sawyer Street site and facilities will be determined during
implementation of the Phase II remedy.
XL STATUTORY DETERMINATIONS
The remedial action selected herein for implementation at the New Bedford Harbor Site is
consistent with CERCLA and, to the extent practicable, the NCP.
A. The Selected Remedy is Protective of Human Health and the Environment
The selected remedy will be protective of human health and the environment. There will be
no Hot Spot sediments remaining at the Site after the cleanup is completed. Therefore, no risks to
the health of the community or the environment due to potential exposure to the Hot Spot sediments
will remain. There are no significant short-term risks to human health or the environment during
implementation of the selected remedy. The potential exposure of site workers and area residents
to contaminated sediments will be minimized by using safety plans that include air emission controls
and a network of ambient air monitors to assess potential releases to the air during cleanup
operations. Tables 9, 10 and 11 summarize the various chemical, location and action specific
ARARs discussed below, as well as their impact on remedial activities.
B. The Selected Remedy Attains or Appropriately Waives ARARs
This section briefly summarizes the most significant chemical, location and action specific
ARARs for the remedy.
Chemical-specific ARARs govern the extent of site cleanup and provide either actual clean-
up levels or a basis for calculating such levels. These requirements are usually health- or risk-based
numerical values or methodologies which, when applied to site-specific conditions, result hi
numerical values which help define the degree of cleanup.
There are no "applicable" or "relevant and appropriate" federal or state chemical-specific
ARARs for the selected remedy. All of the Hot Spot sediments currently contained hi the Sawyer
Street CDF will be removed and transported to a TSCA permitted chemical waste landfill.
27
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Location-Specific ARARs
Location-specific ARARs are restrictions relating more directly to the geographical or
physical setting of the site. These locations include natural site features such as wetlands and flood
plains, as well as manmade features including existing landfills, disposal areas, and local historic
buildings. Location-specific ARARs are generally restrictions on the concentration of hazardous
substances or the conduct of activities solely because of the site's particular characteristics or
location. These ARARs provide a basis for assessing existing site conditions and subsequently aid
in assessing potential remedial alternatives.
Location-specific ARARs pertain to the site's location within a coastal flood plain, adjacent
to the Harbor. Federal ARARs address flood plain management, protection of fish and wildlife
resources, and coastal zone management. Alternatives located in a flood plain may not be selected
unless a determination is made that no practicable alternative exists outside the flood plain. Under
such circumstances the potential harm must be minimised and action taken to restore and preserve
natural and beneficial values. The U.S. Fish and Wildlife Service must be consulted regarding
preventing and mitigating any potential losses to fish and wildlife resources.
State ARARs address coastal zone management, work within flowed and filled tidelands, and
wetlands protection. The state wetlands protection statute identifies the following protected resource
areas that occur on or adjacent to the site: Land Subject to Coastal Storm Flowage, Land Under
Ocean, Designated Port Area, Coastal Beaches (including tidal flats), Coastal Bank (including a 100-
foot buffer zone inland from the edge of the bank), and Land Containing Shellfish.
Action-Specific ARARs
Action-specific ARARs are usually technology or activity-based limitations or requirements
that control actions at CERCLA sites. After remedial alternatives are developed, action-specific
ARARs pertaining to proposed site remedies provide a basis for assessing the feasibility and
effectiveness of the remedies. These requirements generally define acceptable treatment, storage,
and disposal procedures for PCB-contaminated and hazardous substances during the response actioa
The primary action-specific ARARs are requirements regarding waste management and
treatment. These ARARs include PCB storage, treatment and disposal requirements under TSCA
and identification and regulation of characteristic hazardous waste under Massachusetts Hazardous
Waste Management standards.
TSCA requires that any PCB contaminated dredge spoil with a concentration of 50 ppm or
greater be disposed of either in an approved incinerator, an approved chemical waste landfill, or by
using a disposal method to be approved by the Regional Administrator. Approval must be based on
a finding that, based on technical, environmental, and economic considerations, disposal in an
incinerator or chemical waste landfill is not reasonable and appropriate, and that the alternative
disposal method will provide adequate protection to health and the environment.
28
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The selected remedy complies with one of the TSCA approved disposal methods, i e
disposal in an approved chemical waste landfill. The selected remedy requires temporary storage
of the PCB sediment for greater than one year. TSCA regulations, 40 CFR 761.65(2), allow for a
one-year extension of TSCA's one-year storage limitation upon the written notice to the Regional
Administrator of the reasons for the delay in disposing of the material.
Massachusetts Hazardous Waste ARAR's apply to all non-PCB contaminants that meet
characteristic hazardous waste standards. Recent toxicity characteristic leaching procedure (TCLP)
data on the dredged sediment samples show the sediment does not meet the definition of a RCRA
characteristic waste. Toxicity characteristic (TC) constituent concentrations are below TC regulatory
hmitsforhazardous waste. Sediments, process wastes, and discharges from monitoring, operations
and/or maintenance will be tested for hazardous constituents. Any characteristic wastes identified
will be stored, treated, and/or disposed of in compliance with state hazardous waste requirements.
Other federal and state action-specific ARARs include ah- quality and air pollution
requirements, which preclude the release of PCBs and other contaminants. Air emissions from the
proposed alternatives may result from Hot Spot sediment handling/dewatering operations before
off-site transportation and disposal. Air emissions will be addressed by using safety plans that
include air emission controls and a network of ambient air monitors to assess potential releases to
the air during handling/dewatering
Water discharges are regulated under state and federal water quality ARARs. Water
treatment at the facility's on-site water treatment plant will be required to treat the water derived
from theHot Spot sediment dewatering operation. Operation of the treatment plant requires a waiver
of a provision of the National Pollutant Discharge Elimination System requirements of the federal
Clean Water Act (CWA), Section 402. The provision prohibits new discharges into waters that do
not meet applicable water quality criteria, unless certain conditions are met (40 CFR 122.4(i)) The
plan proposed that a protectiveness waiver under Section 121(d)(4)(B) ofCERCLAbeusedforthis
ARAR since compliance would essentially prevent the cleanup of this Site and result in greater risk
to human health and the environment than other alternatives. The issue is the result of the degraded
water quality in the Harbor, where permitting any new discharge is not possible unless the Harbor's
waters reach water quality standards or until the other conditions of the reguktions are met. Neither
of these conditions are likely to be accomplished in a reasonable time. Therefore, this ARAR is
waived.
Furthermore, since New Bedford Harbor water quality is so degraded as to preclude diluting
any proposed discharge, Section 402 of the CWA requires that discharges meet ambient water
quality criteria (WQC) at the discharge point. Except for copper and PCBs, it is expected that the
treatment facility can attain compliance with WQC during the remedial activities. Consistent with
Section 303 of the CWA and its Total Maximum Daily Load (TMDL) approach, it is proposed that
discharge limits for the water treatment plant be implemented that are below current background
levels of copper and PCBs, but above WQC. This approach helps achieve attainment of ambient
WQC throughout the waterbody in a phased or step-wise approach, consistent with EPA's
29
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September 1998 Record of Decision for the Upper and Lower Harbor Unit (USEPA, 1998b). The
copper and PCBs that will be discharged from the treatment plant will be offset by the copper and
PCB contaminated sediments which have been permanently removed from the Harbor as part of the
1994/1995 Hot Spot dredging operation..
Federal PCB policies and guidance regarding PCB air releases and treatment technologies
for CERCLA remedial actions will be considered. Massachusetts guidelines to be considered
include ambient air limits and noise levels. The Allowable Ambient Limits and Threshold Exposure
Limits will be considered for air emissions. Revised TEF and the air dioxin guideline will be
considered for evaluation of air emissions. Noise levels will be minimized to the extent practicable.
C. The Selected Remedial Action is Cost-Effective
The selected remedy is cost-effective since it provides overall effectiveness proportional to
its cost. The costs for the eleven cleanup plans evaluated range from $5.4 million to $48.5 million.
The two cleanup alternatives at the low end of the range (HS-1 at $5.4 million and HS-5 at $10.3
million), are alternatives that do not treat or remove the Hot Spot sediments from the Site. The
selected remedy, at an estimated cost of $14.8 milling does not treat the sediments but does remove
them from the site providing a higher level of protection than alternatives HS-1 and HS-5. The
remaining eight cleanup plans evaluated are treatment alternatives ranging in cost from $19 million
to $48.5 million. Since the selected remedy removes all of the Hot Spot sediments from the Sawyer
Street CDF and transports them off-site, there will be no remaining risks at the Site. Therefore, a
more costly treatment alternative will not provide more protection to the community or the harbor.
D. The Selected Remedy Utilizes Permanent Solutions and Alternative Treatment or
Resource Recovery Technologies to the Maximum Extent Practicable
The selected remedy provides a permanent solution for the Hot Spot sediments currently
stored on the Sawyer Street CDF. It permanently isolates these sediments from human and
environmental receptors by containing them in a TSCA permitted off-site chemical waste landfill.
Alternatives involving on-site treatment of the Hot Spot sediment were considered, but lack the
community support that would make them a practicable option at this Site. Although the Hot Spot
sediments will not be treated, a large volume of PCBs and metals contaminated water which was
decanted during the dredging operation has been treated to meet stringent discharge standards.
Furthermore, the contaminated water from the dewatering operations will also be treated to meet
stringent discharge standards.
E. The Selected Remedy Does Not Satisfy the Preference for Treatment as a Principle
Element
The selected remedy does not use treatment of the PCB-contaminated sediments as a
principle element of the remedy, although as described above, decanted water from the Hot Spot
dredging operations was treated. In addition, the Hot Spot sediment dewatering to be performed as
30
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a part of the selected remedy-will involve extensive treatment prior to discharging to the harbor.
Protection against the future ecological and human health risks posed by the Hot Spot sediments
is provided by removing them from the Sawyer Street CDF and permanently isolating them in a
TSCA permitted off-site chemical waste landfill.
XII. DOCUMENTATION OF NO SIGNIFICANT CHANGES
The Proposed Plan to Amend the 1990 Cleanup Plan was released for public comment in
August 1998. The proposed change calls for transporting the Hot Spot sediments off-site to a TSCA
permitted chemical waste landfill rather than on-site incineration as called for in the 1990 cleanup
plan. The amended cleanup plan includes:
1. Upgrade Existing Site Facilities As Needed. To accommodate sediment handling
and dewatering activities it may be necessary to construct or improve access to the
CDF and other areas of the site. Treatment pads, temporary buildings and upgrades
to site utilities may also be needed.
2- Sediment Dewatering and Water Treatment. The Hot Spot sediments currently
stored in the Sawyer Street CDF are approximately 50% water, which is too wet to
be accepted by a TSCA permitted hazardous waste landfill. The sediments will be
dewatered to that level which is in compliance with the permits and other
requirements for the selected off-site TSCA permitted landfill. Options for
dewatering the sediments will be evaluated during the design process. The sediment
may be dewatered in-situ by extracting water via installed well points, or by
removing the sediment from the CDF and mechanically dewatering it ex-situ, or a
combination of in-situ and ex-situ dewatering. Water extracted from the Hot Spot
sediment during the dewatering operations will be treated in the existing Sawyer
Street wastewater treatment plant prior to discharge into the harbor.
3. Transportation to an Off-Site TSCA Permitted Landfill. Following dewatering, the
sediments will be loaded into sealed containers for transport to a TSCA permitted
off-site hazardous waste landfill. Trucks leaving the Sawyer Street Site will be
routed to minimize their impact to local traffic.
4. Air Monitoring. There is a potential for air emissions of PCBs during the sediment
removal and dewatering activities. A comprehensive ambient air monitoring
program will be implemented during the sediment removal and dewatering
operations to ensure that engineering controls are effective at protecting site workers
and the local community.
31
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EPA determined that, based on public comment, no significant change is needed to the
proposed amended cleanup plan. EPA will evaluate potential dewatenng strategies further during
the design phase. Based on the results of these further evaluations, EPA may decide to dewater the
sediments before removing them from the CDF by extracting water from well points or mechanically
dewatering the sediments ex-situ as discussed above or a combination of in-situ and ex-situ
dewatenng.
XIII. STATE ROLE
The Massachusetts Department ofEnvironmental Protection has reviewed the remedy change
and concurs with the selected remedy described in Section X of this Amendment. A copy of the
State concurrence letter is attached as Appendix C.
32
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Hew. Bedford Harbor
Y
Hot Spot Areas
(ROD 1)
upper Harbor
Hot Spot COF
CoggeshallSL Bridge
1-195 Bridge
Lower Harbor
NEW
M BEDFORD
NASKETUCKET BAY
Outer Harbor
NEW BEDFORD HARBOR
STUDY AREAS
-------
AEROVOX
DESCRIPTION
CLOSEO T0
COGGESHALL
STREET BRIDGE FAIRHAVEN
AREA
AREA U WATERS CLOSED TO THE
TAKING OF LOBSTER, EEL,
FLOUNDER, SCUP, AND TAUTOG
AREA III WATERS CLOSED TO
LO8STERING
NEW BEDFORD
SCONTICUT
DARTMOUTH
V/ASTEWATER
TREATMENT
OCK
POINT
.RICKETSON-S
POINT
NEGRO LEDGE '
NEW BEDFORD HARBOR
FISHING CLOSURE AREAS
M:SHAUM POINT
APPflOXIMATE SCALE W FtET
-------
Figure 3: Sawyer Street Facility
Sawyer Street
Water Treatment Building
CDF where Hot Spot sediments
are currently stored
Upper New Bedford Harbor
(Acushnet River and Estuary)
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AIR MONITORING
STATION
(MOBILE LOCATION)
CONFWE0 DISPOSAL FACflJtY
COX II
NEW BEDFORD HARBOR
HOT SPOT FEA8OUTY STUDY ADDBOUM
EXISTING SFTE CONDITIONS
SAWYER STREET LOCATION
NEW BEDFORD HARBOR
SUPERFUND SITE
FOSTER WHSStER ENVROtMENTAL CORPORATION
US EPA ARCS I PROGRAM
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Table 1
Summary of PCS and Oil and Grease Data for the Hot Spot Sediment
^''&V'v*5 . ,' "" ' ,&- ''T<
3,800 7,700
28,100 36,900
Table!
PCB and Oil and Grease Results for the USAGE Samples
CoUected in June 1995
-."• f f"' •
"• %& f f\
^'W^ii.'3&'
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Table 4
Summary of PAH Concentrations for the
Hot Spot Sediment
(Third Pilot Study)
Naphthalene
2-Methyinaphthalene
Acenaphthylene
Acenaphthene
Fluorene
Phenanthrene
Anthracene
Fluoranthene
Pyrene
Benzo(a)anthracene
Chrysene
Benzo(b)fluoranthene
Bcnzo{k)fluoranthene
Benzo(a)pyieiie
Indeno(l,2,3-cd)pyrene
Dibenz(a,h)anthracene
Benzo(g,h,i)perylene
0.31
0.50
0.16
0.45
0.44
1.1
0.3
1.8
2.6
1.9
2.1
2.0
1.5
1.8
0.13
0.07
0.08
0.78
1.3
8.2
1.9
1.7
6.4
1.7
12
8.2
6.4
7.3
10
8.5
6.6
0.72
3.3
0.4
0.50
0.84
1.4
0.91
0.88
2.3
0.62
3.9
4.8
3.7
4.1
4.2
3.9
3.7
0.28
1.1
0.22
Total PAH:
37
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Table 5
Summary of {2,3, 7,8 Substituted Isomers} Data
for the Hot Spot Sediment
(Third Pilot Study)
^^W >)}J3fiaxuMt^ \y'v^**
....'..^V'^S "'""-'' V V '?*£.* ' \/r
2,3,7,8-TCDD
1,2,3,7,8-PeCDD
1,2,3,4,7,8-HxCDD
1,2,3,6,7,8-HxCDD
1,2,3,7,8,9-HxCDD
1,2,3,4,6,7,8-HpCDD
OCDD
2,3,7,8-TCDF
1,2,3,7,8-PeCDF
2,3,4,7,8-PeCDF
1,2,3,4,7,8-HxCDF
1,2,3,6,7,8-HxCDF
2,3,4,6,7,8-HxCDF
1,2,3,7,8,9-HxCDF
1,2,3,4,6,7,8-I^>CDF
1,2,3,4,7,8,9-I^)CDF
OCDF
Total:
$t ;:3n|1^(ffltSttB^ ; %
W^'l^tnf^mpjge
3.6
9.1
7.9
31
20
386
3,000
690
276
1,520
4,440
1,920
844
986
1680
1,260
1,860
18,933
^IStetSWHf5fiE^ '-'
3.6
4.5
0.79
3.1
20
3.9
3
69
14
760
444
192
84
99
13
1.9
1,714
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Table 6
Summary of Dioxin and Furan Data (Totals)
for the Hot Spot Sediment
(Third Pilot Study)
Total TCDD
Total PeCDD
Total-HxCDD
Total-HpCDD
OCDD
Total TCDF
Total PeCDF
Total-HxCDF
Total-HpCDF
OCDF
17
50
284
770
3,000
5,080
3,920
10,520
4,580
1,860
Total PCDD/PCDF
30,081
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Table 7
Summary of Metals Data for the Hot Spot Sediment
(Third Pilot Study)
*',<£m%Vftoe:?\\
"^..l.-V/"' ** ,L"
Aluminum
Antimony
Arsenic
Barium
Beryllium
Cadmium
Calcium
Chromium
Cobalt
Copper
Iron
Lead
Magnesium
Manganese
Mercury
Nickel
Potassium
Selenium
Silver
Sodium
Thallium
Vanadium
Zinc
:t^:Wtiauim*»'
&"?£0B&t&f$iQli ;#
13,300
2.9
10.2
145
0.49
13.4
5,910
295
7.3
656
21,200
550
6,980
200
0.87
56.7
3,040
2.4
2.5
12,200
ND
48.6
1,720
,l% moig&flfc^
f'; C$j*e*ii^&i&B^ ;N
17,200
8.7
14.4
221
0.55
17.0
8,960
366
9.3
861
28,000
632
9,210
243
3.6
73.7
3,950
3.6
4.4
16,900
0
69.2
2,130
:'i " h$*«*Be<"|
:; C^a<:eatr4tiOrt <"
15,658
5.1
11.9
159
0.51
15.1
7,275
330
8.3
762
25,533
600
8,278
223
1.3
64.6
3,458
3.0
3.2
14,083
ND
56.8
1,924
Results are reported in mg/kg
ND= Not Detected
-------
Table 8
TCLP Results for Hot Spot Sediment
(Third Pilot Study)
PCB
1,3-Dichlorobenzene
1,4-Dichlorobenzene
1,2,4-Trichlorobenzene
Phenanthrene
Fluoranthene
Pyrene
Arsenic
Barium
Cadmium
Chromium
Copper
Lead
Mercury
Selenium
Silver
Zinc
NC
NC
7,500
NC
NC
NC
NC
5,000
100,000
1,000
5,000
NC
5,000
200
1,000
5,000
NC
26.85
22
85
20
ND
ND
ND
22.4
352
18.0
21.2
50.8
472
ND
12.7
ND
8,260
NC No Criterion
-------
Table 9
Chemical Specific ARARs and TBCs
Federal
Cancer Slope Factors (CSFs)
Reference Doses (RfDs)
Massachusetts
•
J5fiB^froMulffli!iiipBi
To Be
Considered
To Be
Considered
P-f©'.Vv3^
h&&^£&4&U*>£«A^^^^
These are guidance values used to evaluate the potential
carcinogenic hazard caused by exposure to
contaminants.
These are guidance values used to evaluate the potential
non-carcinogenic hazard caused by exposure to
contaminants.
There are no state chemical-specific ARARs. J
UrMdLi^^ wM&.
Operation and maintenance of the facility will minimize
exposure to potential receptors.
Operation and maintenance of the facility will minimize
exposure to potential receptors.
-------
Table 10
Location Specific ARARs and TBCs
i. , ;
^•Trtv^riTW* '•"-""••"
If. . ....-., .Tf^fe'^tS^-rtini-rtl----!
Federal
Floodplain Management - Executive
Order 11 988
Fish and Wildlife Coordination Act
Coastal Zone Management Act
Massachusetts
Wetlands Protection Act
Coastal Zone Management
irHMtoii
^..Jzs; ,:,;;?,, -,.,•
40CFRPart6.
Appendix A
16 USC Part 661
et seq.; 40 CFR
6.302
16 USC Parts
1451 etseq.
131 MGL40;310
CMR 10.00
301CMR21.00
1 '•#?:!{!>•:
———g^^^^g^^
Applicable
Applicable
Applicable
Applicable
Applicable
I 'vt^niJ^-y-wit'^'AittiiVi'l.-;
f^^^^^^^^^^^^^^^^^^m^AkflMi^BMBliaMBAMK^BMMMr^aM^^^^^^^^^HI^^^^^RHH
Federal agencies are required to reduce the risk of flood
loss, minimize impact of floods, and restore and preserve
the natural and beneficial values of floodplains.
Requires consultation with appropriate agencies to protect
fish and wildlife when federal actions may alter waterways.
Must develop measures to prevent and mitigate potential
loss.
Requires that any actions must be conducted in a manner
consistent with state approved management programs.
These standards regulate the dredging, filling, altering, or
polluting of coastal and inland wetland resource areas.
Protected resource areas within and adjacent to the site
include: Land Subject to Coastal Storm Flowage (Sec.
10.02(l)(d)), Land Under Ocean (Sec. 10.25), Designated
Port Area (Sec. 10.26), Coastal Beaches (including tidal
flats)(Sec. 10.27), Coastal Bank (Sec. 10.30), and Land
Containing Shellfish (Sec. 10.34). There is a 100-foot
buffer zone landward of the Coastal Bank.
Requires that any actions must be conducted in a manner
consistent with state approved management programs.
1 /rt^iXVjfelJjrsjf'tl'Wisl^rViJ*:!!! ilt- :";'„• '
The facility lies within the 100-year coastal
floodplain. The potential effects of any action must
be evaluated to ensure that the planning and decision
making reflect consideration of flood hazards and
floodplain management, including restoration and
preservation of natural and beneficial values,
wherever feasible.
Appropriate agencies will be consulted prior to
implementation to find ways to minimize adverse
effects to fish and wildlife from facility operation
and maintenance.
The entire site is located in a coastal zone
management area, therefore applicable coastal zone
management requirements will be met
Operation and maintenance of the facility within the
100-year floodplain and the 100-foot buffer zone to
the coastal bank will comply with the substantive
requirements of the standards. Dewatering and
loading facilities will be protected from flooding.
The entire site is located in a coastal zone
management area, therefore substantive coastal zone
management requirements will be met
-------
Table 10, Continued
Location Specific ARARs and TBCs
Waterways
310 CMR 9.00
Applicable
i
Sets forth criteria for work within flowed and filled
tidelands. Waterways concerns focus on the long term
viability of marine uses and protecting public rights in
tidelands, including fishing and access.
Actions within filled and flowed tidelands at the site
will comply with the regulation's environmental
standards.
-------
Table II
Action Specific ARARs and TBCs
Federal
Toxic Substances Control
Act (TSCA), Disposal
Requirements- PCBs
Contaminated Dredged Spoil
TSCA PCB Storage
Regulations
ISCA PCB Storage
Regulations
TSCA PCB Storage
Regulations
15 USC 2601-
2692; 40 CFR
761.60(a)(5)
40 CFR
76l.65(a)
40 CFR
761.65(b)(l)
(i)
40 CFR
761.65(b)(l)
(H)
Applicable
r
Applicable
Applicable
Applicable
Dredged materials with PCBs at concentrations
greater than 50 ppm must be disposed of either
in an incinerator, or in a chemical waste landfill,
or, when the first 2 options are not reasonable
and appropriate, by a disposal method which
will protect health and the environment.
PCBs stored for disposal must be properly
disposed of within one-year of being placed in
storage. A one-year extension is granted upon
notification to the Regional Administrator.
Storage facilities must have adequate roof and
walls to prevent rainwater from reaching the
stored PCBs,
Storage facilities cannot have floor drains or
openings that would allow liquids to flow from
the storage area.
Sediments will be disposed of in a permitted II
TSCA facility.
If the remedy requires on-site storage of PCB
.contaminated material for more than one-vear
an extension will be required.
Present cover, if properly maintained, does
prevent rainwater from reaching the stored PCBs.
Rainwater that falls directly on Cell #1 may
require treatment if contamination occurs.
Cell #1 has two continuous, impermeable bottom
liners.
-------
SCA PCB Storage
Regulations
rSCA PCB Storage
((Regulations
TSCA PCB Commercial
Storage Regulations
TSCA PCB Commercial
Storage Regulations
TSCA PCB Spill Cleanup
:iean Water Act (CWA),
Section 402, National
([Pollutant Discharge
Elimination System
li(NPDES)
A, Section 402, NPDES,
tohibitions
40CFR
761.65{b)(l)
(iv)
40CFR
761.65(b)(l)
(v)
40CFR
761.65(d)(2)
(ii)
40CFR
761.65(d)(2)
(vi)
40CFR
761.120-.135
33 USC 1342;
40CFR 122-
125.131
40CFR
122.4(i)
Applicable
Applicable
Relevant and
Appropriate
Relevant and
Appropriate
Relevant and
Appropriate
Table 11, Continued
Action Specific ARARs and TBCs
Storage facilities must have floors and curbs
made of smooth impervious material to prevent
PCB penetration.
Storage facilities must not be located below the
100-year floodwater elevation.
^mn«»B«™—
CDF facilities must possess the capacity to
handle the maximum quantity of PCB waste tha
will be handled at any one time.
The operation of a commercial storage facility
must not pose an unreasonable risk of injury to
health or the environment.
Applicable
Establishes criteria to determine adequacy of the
cleanup of spills (occurring after 5/4/87) from
the release of materials with > 50 ppm PCBs.
Applicable
These standards govern discharge of water into
surface waters. Due to the degraded nature of
New Bedford Harbor waters, regulated
discharges into the waterway must meet ambient
water quality criteria (WQC) at the discharge
point.
Prohibition on new discharges into waters that
do not meet applicable water quality criteria
(WQC) gnless certain conditions are met.
^VK"IMMIMMMMM«i^^MM«MfcMU«itfififii£ifi^HSlXti^E^^^^^^^^^^^^E
Cell #1 has two liners made of HOPE which is
smooth and impermeable.
The CDF's top-of-berm elevation is two feet higher
than the 100-ycar flood elevation. If a dewatering
Utility is needed it will constructed so that it is
above the 100-year Hood elevation.
The CDF has the capacity to contain all of the
dredged hot spot sediments.
The cover for Cell #1 would have to be extended
o overlap the cell walls to prevent persons from
falling in. Air, groundwater, and surface water
monitoring in the vicinity of the CDF will be
continued to verify protectivencss of controls until
all of the sediments are removed off-site. >
Although this policy is directed at electrical
quipment-type spills, it will be considered to
ddress any PCB leakage or spillage from the
Any drainage off the site which becomes
ontaminated by the stored sediments and any
>rocess or dewatering discharge will be treated by
lie on-site treatment plant and discharged to the
arbor. Ambient water quality criteria, particularly
for copper and PCBs, will be addressed through a
phased Total Maximum Daily Load (TMDL)
pproach
waiver will be sought for this provision since
ompliance would prevent cleanup of the site until
arbor waters either reach water quality standards
r until the other conditions in the regulation are
let. Neither of which can be accomplished in a
asonable time frame.
-------
Table 11, Continued
Action Specific ARARs and TBCs
II . — ,
1 'MW&Mi? jl <£flfifitoi»
aeanAirAct(CAA),
National Emissions
Standards for Hazardous Air
Pollutants (NESHAPS)
Guidance on Remedial
Actions for Superfund Sites
with PCB Contamination
(OSWER Directive)
42 USC 7401
et seq.; 40 CFR
Part 61
I SiisluS» f !«*Li«<*«UM-%:iWj)&Ji | /&4lJ^Jy)jfc1j^ «
Applicable
To Be
Considered
NESHAPS are a set of emissions standards for
specific chemicals, including PCBs, from
specific production activities.
Describes the recommended approach for
evaluating and remediating CERCLA sites with
PCB contamination.
Monitoring of air emissions from the facility,
including from the dcwatcring process, wifl be
used to assess compliance with these standards.
Operation and maintenance activities will be
carried out in a manner which will minimize
This guidance will be considered when evaluating
PCB issues associated with removal, dewatering,
and offsite disposal of contaminated sediment.
s
Massachusetts
Hazardous Waste
Management - Identification
and Listing
Hazardous Waste
Management • Requirements
'or Generators of Hazardous
Waste
Hazardous Waste
Management - Management
Standards for all Hazardous
Waste Facilities
Supplemental Requirements
or Hazardous Waste
Management Facilities
21CMGL 4
and 6; 310
CMR 30.100
21CMGL4
and 6; 3 10
CMR 30.300
21CMGL4
and 6, 310
CMR 30.500
21MGL
27(1 2), 34 and
43; 3 14 CMR
8.00
Relevant and
Appropriate
Relevant and
Appropriate
Relevant and
Appropriate
Relevant and
Appropriate
Establishes standards for identifying and listing
hazardous waste.
Establishes standards for various classes of
generators.
Establishes standards for treatment, storage, and
disposal of hazardous waste, and establishes
standards for closure, post closure and ground
water monitoring. Sec. 30.501 (3)(a) exempts
facilities which treat, dispose or store hazardous
waste containing 50 ppm or more PCBs if they
are adequately regulated under TSCA, 40 CFR
761.
This regulation outlines the additional
requirements that must be satisfied in order for a
RCRA facility to comply with the NPDES
regulation.
Monitoring will assess whether hazardous wastes
are present in discharges or dewatering wastes
from the facility.
Any hazardous waste generated from the facility
will be managed in accordance with the
substantive requirements of these regulations.
Any non-PCB hazardous waste which is treated,
stored or disposed of at this facility as part of the
remedy will be managed in accordance with the
substantive requirements of this section.
The substantive requirements of these provisions
will be met.
-------
Table 11, Continued
Action Specific ARARs and TBCs
Surface Water Discharge
21 MGL
23(12) and 34;
314 CMR 1.00
7.00
Applicable
((Surface Water Quality
Standards
27 MOL 27;
314 CMR 4.00
Rules for the Prevention and
Control of Oil Pollution in
Ithe Waters of the
ICommonwealth
Massachusetts Water Quality
((Standards Implementation
([Polity of Toxic Pollutants in
Surface Waters (2/23/90)
21 MGL 26-
53; 314 CMR
15.000
([Ambient Air Quality
Standards
Ur Pollution Control
- Recommended
hreshold Effect Exposure
JlLimits (TELs) and Allowable
Ambient Limits (AALs)
111 MGL
142D;310
CMR 6.00
111 MGL
I42A-J.3IO
CMR 7.00
Applicable
Applicable
To Be
Considered
Applicable
Applicable
To Be
Considered
This section outlines the requirements for
obtaining a National Pollutant Discharge
Elimination System (NPDES) permit in
Massachusetts. The waters of New Bedford
Harbor adjacent to the site are classified as SB.
Any drainage off the site which becomes
{contaminated by the stored sediments and the
water from dewatering will be treated by the on-
site treatment plant and discharged in accordance
with the substantive provisions of the regulations.
vf ADEP surface water quality standards
incorporate the federal AWQC as standards for
surface waters of the state. Standards establish
acute and chronic effects on aquatic life for
contaminants including PCBs, cadmium, copper,
and lead.
I Ambient water quality criteria, particularly for
copper, will be addressed through a phased Total
Maximum Daily Load (TMDL) approach.
Regulates the discharge of oil or sewage, The remedy will comply with the substantive'
industrial waste or other material containing oil requirements of the provisions.
into waters of the Commonwealth.
Recommends surface water quality standards for
I en*i*iftjtsl SIAM »»*«!_.*_*._ •*..• . i
specified contaminants and implementation to
achieve standards.
—^•^•^^^^^^••^
Establishes ambient air level for contaminants
including PCBs and particulates.
Standards for sources of emissions. Pollution
abatement controls may be required.
----{••"••""•••Mtivii i/wiivjr oiiu auurupnHic
standards will be considered for alternatives which
impact surface water quality
Emissions from the CDF and the dewatering
facility will comply with these standards. Dust
suppression will be used to reduce paniculate
emissions.
Operation and maintenance of the CDF and the
dewatering facility will comply with the
.ubstantive requirements of these provisions.
Establishes exposure concentrations for air
contaminants developed and recommended by
the Office of Research and Standards to protect
public health.
On-site containment and dewatering technologies
having air emissions will consider the TELs and
AALs.
-------
Table 11, Continued
Action Specific ARARs and TBCs
•. M^tHfi«a^!M%: J ;;®teftb.tf •
,„'*.*>- ,x.,xV1**w^v^vi>^;V,,1':, -^;«i£#&tt iftwrfsttM^**^-'1'.^
DAQC Policy (90.001):
Allowable Sound Emissions
(2/1/90)
MA DEP - Assessment and
Control of Dioxin in
Massachusetts (10/31/91)
| •SUsBifr-
To Be
Considered
To Be
Considered
, : — j, , _______
j ii%iU^uMf%iu|&iy . r &aiM» ]
Establishes guidelines where the source of new
noise should not emit more than 10 decibels '
above the existing (background) level.
Recommends revisions to Toxicity Equivalence
Factors (TEFs) for polychlorinated
dibenzodioxins (PCDDs) and dibenzofurans
(PCDFs) in air/emissions.
Site operations noise level will be niirnmJT^i md
will follow the suggested noise limit to the extent
practicable.
Alternatives with on-site sediment dewatering
technologies that potentially include air emissions
of PCDDs and PCDFs will consider the revised
TEFs for evaluating the toxicity of these air
emissions.
-------
Appendix A - Responsiveness Summary
New Bedford Harbor Superfund Site
Amended Record of Decision for the Hot Spot Sediments
-------
-------
1.0 INTRODUCTION
This responsiveness summary summarizes and provides EPA's responses to formal
comments regarding the Proposed Plan to amend the 1990 cleanup plan for the New Bedford
Harbor Hot Spot Sediments. These comments were received during the period August 27-
September 25, 1998. The comments and responses are organized into the following categories.
Section Type of Comment
Page
2.1 Citizen A-l
2-2 Local Government A-7
2-3 State Government A-8
2-4 Congressional A-9
2.5 AVX Corporation A-10
2.0 SUMMARY OF COMMENTS RECEIVED DURING THE AUGUST 27-
SEPTEMBER 25,1998 PUBLIC COMMENT PERIOD
2.1 Citizen Comments
2.1.1 Mr. Barrett:
Mr. Barrett supports the Proposed Plan. He commented that in his opinion off-site
landfllling would be the fastest, the safest and the most economical way to dispose of the
Hot Spot sediments. However, he commented further that the off-site landfill chosen
should not necessarily be the least expensive, but, the most secluded site and the least likely
to cause any damage to the environment He also commented that he believes transport by
rail will be the safest and less likeliness for accidents that endanger public safety.
EPA Response:
The selection of an off-site landfill will be based on a competitive bidding process which
involves an evaluation of the off-site transportation and disposal proposals received from various
Offerers during that competitive bidding process. Price is one of five criteria which will be used
to evaluate the various proposals. The other four criteria are: technical approach; relevant
experience; management approach; and available resources. Lowest price does not guarantee
award of the off-site disposal contract.
A-l
-------
The selection of the off-site landfill must be done in accordance with EPA Off-site Rule
which became effective on October 22, 1993. The purpose of the Off-site Rule is to ensure that
wastes shipped off-site from Superfund clean-ups are sent to environmentally sound waste
management facilities. The rule describes the criteria that off-site waste management facilities
must meet when taking waste from Superfund sites and the procedures that EPA must follow
when making determinations on the acceptability of these facilities. Any facility which meets
the requirements of the Off-site rule is acceptable to EPA. A requirement that the site be the
most secluded site is not a criteria under the Off-site Rule.
EPA appreciates your concern over the possibility of an accident occurring while
transporting the hot spot sediments to a landfill. EPA believes that both trucking and rail are safe
means of transporting the dewatered Hot Spot sediments to a landfill. Traffic accidents
involving hazardous waste transportation are very rare events.
2.1.2 Ms. Jacobsen:
Ms. Jacobsen supports the Proposed Plan. She commented that she is very happy
that the situation is finally being addressed and resolved.
EPA Response:
The EPA appreciates your support for the Proposed Plan.
2.1.3 Ms. Kirk
Ms Kirk commented that as a member of Concerned Parents of Fairhaven and the
New Bedford Harbor Superfund Site Community Forum (Forum) she is disappointed and
opposes the Proposed Plan. She commented further that in 1993, community groups
wanted EPA to find an innovative, non-incineration PCB destruction technology that could
be used on-site and that landfilling was not an alternative favored by the community
groups. She discussed the creation of the Forum and the results of innovative technology
pilot scale testing performed by EPA at the New Bedford Harbor site which concluded that
there were innovative technologies that could be safely used on-site at full scale. Ms Kirk
concluded her comments with the following:
"In conclusion, I am disappointed in the decision of the majority of the Forum
members to off-site landfill. In my mind, landfill does not treat or destroy. The hot
spot sediments will be buried forever. To send it an off-site facility adds insult to
injury. It simply sends a problem created in New Bedford to another community.
Off-site landfill goes against our mission since the beginning and we demonstrated
that there are alternative, innovative technologies that could have been chosen that
could have destroyed PCB's and been safe for human health and the environment.
It was a rushed decision, with a lot of misinformation and fear fed to a community
A-2
-------
about health and safety issues that were resolved long before. The neighborhood
that came to these last meetings was not involved from the beginning and was not
part of our learning process. Off-site landfilling will move the problem but does not
solve the problem."
EPA Response
EPA agrees that the results of pilot scale studies of innovative treatment technologies did
show that there are non-incineration destruction technologies which EPA believes could be
safely implemented on-site to destroy the PCB-contaminated hot spot sediments. Although EPA
is also disappointed that a treatment alternative which is acceptable to the community could not
be found, we do believe that the off-site landfilling alternative does provide the beast balance
among the nine NCP remedy selection criteria. EPA's rationale for selecting the off-site
landfilling alternative, using the NCP criteria, is provided on page 6 of the August 1998
Proposed Plan.
2.1.4 Mr. Kopcych
Mr. Kopcych commented at the public hearing that he is in favor of dewatering the
sediments, placing them in sealed containers and transporting them off-site. He
commented further that he would like to see the dewatered sediments taken over to the
New Bedford rail yard which he said the city owns and which is also contaminated with
PCB's. He would like the sediment to be shipped out of the city by rail from the New
Bedford rail yard. He believes the city is allowed to charge a tipping fee, which would
assists them in cleaning up the PCB contamination at the rail yard.
EPA Response
As discussed in EPA's response to Mr. Barrett's comments above, the transportation
component of the Proposed Plan will be determined as part of a competitive bidding process.
EPA has no objection to bidders including the use of the New Bedford rail yard in their proposals
provided that it can be demonstrated that the rail yard is an approved facility in compliance with
all appropriate local and state regulations.
2.1.5 Mr. Lapointe
Mr. Lapointe provided verbal comments at the public hearing. Mr Lapointe's
comments appear to support the proposed plan. He stated:
"I wish they would just take it out of the site, bring it to wherever they bring it. Just
don't burn it Dioxin scares me."
EPA Response
A-3
-------
EPA appreciates your support for the Proposed Plan. The Proposed Plan does not include
burning the Hot Spot sediments. The sediments will be transported to a TSCA permitted
chemical waste landfill.
2.1.6 Mr.Nadeau
Mr. Nadeau provided verbal comments at the public hearing. Mr. Nadeau's
supports the proposed plan. However, he did not believe that the hearing was adequately
publicized. He stated that his name is on the mailing list, but, he never received a letter
notifying him of the public hearing.
EPA Response
EPA is disappointed to hear that you did not receive notice of the public informational
meeting and hearing. EPA sent out notices to over 800 people, advertised the meeting in the
local paper and sent out press releases to local radio stations. We will make sure that you are on
our mailing list and receive all future planned mailings and notices of any future public hearings.
2.1.7 Mr. Rusinoski
Mr. Rusinoski provided oral comments at the public hearing and written comments
in a letter dated September 14,1998. Mr. Rusinoski does not agree with EPA's Proposed
Plan. Mr. Rusinoski believes a better approach is to deposit the Hot Spot sediments in a
lined cofferdam which could be used in the construction of a pier or wharf north and east
of Fairhaven Hardware, on the New Bedford and Fairhaven bridge.
EPA Response
EPA believes that transporting the Hot Spot sediments to an off-site landfill provides
greater long-term protection of human health and the environment than the approach suggested
by Mr. Rusinoski. Although the construction of a pier or a wharf was not discussed with the
Forum and the community, on-site containment was discussed and is one of the alternatives that
EPA evaluated hi the December 1997 Hot Spot Feasibility Study Addendum Report. On-site
containment is not acceptable to the Forum and the majority of public comments received
support off-site landfilling.
2.1.8 Ms. Sanz
Ms. Sanz submitted written comments in a letter to EPA dated September 23,1998.
She stated:
"As a citizen member of the New Bedford Harbor Superfund Community Forum, I
A-4
-------
am extremely disappointed in the Forum's recommendation to the EPA The
Forum followed the process we all agreed upon to find a technology, alternative to
on-site incineration, which would clean up the hot spot material stored in a CDF
Viable alternatives were found after lengthy and costly treatability studies. But at
the very last moment and after no study of landfill, the majority decision was to
recommend landfill, a decision, I believe, that was forced by the political motives of
some members of the Forum.
The Forum process worked in general, and my hope now is that what was learned
from both the process and the technology studies will be applied to other Superfund
sites across the country."
EPA Response
As stated above in EPA's response to Ms. Kirk's comments, we are also disappointed
that we could not find a on-site treatment technology that is acceptable to the community EPA
does not agree wtth the comment that landfilling received no study. The Proposed Plan off-site
landfiUing, was evaluated in the December 1997 Feasibility Study Addendum Report and
discussed and compared against the other alternatives at several of the Forum meetings.
2.1.9 Mr. Simmons
Mr. Simmons provided oral comments and submitted written comments at the
public hearing. He read a comment letter-submitted by a Mr. Barret A summary of Mr
Barret s comments and EPA's response is provided above in section 2.1.1. Mr. Simmons'
also read a comment letter sobmitted by a Ms. And Mr. Sylvia. A summary of Ms. And
Mr. Sylvia s comments and EPA's response is provided below in section 2.1.11 Mr
Simons provided comments on behalf of Hands Across the River Coalition. Hands Across
the River is generally supportive of the Proposed Plan. But, they request that the
sediments be transported out of New Bedford via rail utilizing the New Bedford rail yard
and that the sediments be transported to a landfill in the state of Nevada. He also stated
that:
"I think in my opinion, aside from Hands Across the River, that everything that
we've looked at, the safest, fastest, cheapest, best way to go would be by rail to a
desert facility to get this stuff out of here as fast as possible. And I also think in my
opinion if that is done that Phase H would move a lot faster and we might find
something out from this endeavor that might help us in Phase H."
EPA Response
r+u JPA^aPPreciatesyoursuPP°rtfor the Proposed Plan. Your comments regarding the use
of the New Bedford rail yard and the location of the off-site landfill are addressed in EPA's
A-5
-------
response to Mr. Barrett's and Mr. Kopcych's comments. In summary, the means of
transportation and the location of the off-site landfill will be decided during the competitive
bidding process.
2.1.10 Ms. Sousa
Ms. Sousa provided oral comments at the public hearing. Ms. Souza expressed no
objections to the Proposed Plan. Ms. Sousa's congratulated the EPA and the Forum for
their efforts. She stated:
"There are many years and much to do ahead of us, but we as a community of
Southeastern Massachusetts have spoken to the government and the government
has listened to us. Thank you."
EPA Response
EPA appreciates your support for the Proposed Plan.
2.1.11 Mr. Sylvia
Mr. Sylvia provided oral comments and a comment letter (presented by Mr.
Simmons) at the public hearing. Mr. Sylvia's oral comments support the Proposed Plan.
He prefers that the sediments be transported by rail to Nevada. Mr. Sylvia's written
comments also support the Proposed Plan and his letter included a petition signed by over
400 people. The petition reads:
"The undersigned respectfully asks that the New Bedford Harbor-Superfund
Forum members recommend that the contaminated soils at the Sawyer St. site be
dewatered and the remaining sediment be transported by rail to a permitted landfill
as far from New Bedford as possible, and that the clean-up of the railroad terminal
in New Bedford proceed in conjunction with this remedy."
EPA Response
The EPA appreciates your support for the Proposed Plan. Your comment regarding
transportation by rail is addressed in EPA's response to Mr. Barrett's, Mr. Kopcych's, and Mr.
Simmons' comments. The New Bedford railroad terminal is not part of the New Bedford Harbor
Superfund Site and is being addressed by the Massachusetts Department of Environmental
Protection under State cleanup standards.
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2.2 Local Government Comments
2.2.1 Mayor Kalisz, Mayor of New Bedford
Mayor Kalisz submitted a letter dated September 22,19998 which supports the
Proposed Plan. In his letter he also stated that EPA should carefully consider the
feasibility of shipping these sediments via rail from the City to the off-site disposal location.
He also asks that the EPA, through all means possible, make every effort to employ local
businesses and residents on this, and all future cleanup efforts in New Bedford. There is a
skilled workforce in New Bedford, and there are local businesses that could aid in this
process.
EPA Response
EPA appreciates Mayor Kalisz's support for the Proposed Plan. Your comments
regarding the use of the New Bedford rail yard is addressed in EPA's response to Mr. Barrett's
and Mr. Kopcych's comments. In summary, the means of transportation and the location of the
off-site landfill will be decided during the competitive bidding process.
EPA supports the goal of using local labor to the maximum extent practicable. EPA will
not be directly responsible for hiring during the cleanup. However, we will continue to work with
the U.S. Army Corps of Engineers, their contractors and the City toward the goal of using local
labor. EPA has asked the City council to provide us with a list of local contractors that could
possibly be used during the harbor cleanup. Contractors on this list may be notified by the Corps
of Engineers and their contractors of job opportunities during the harbor cleanup.
2.2.2 Councilman Rogers, New Bedford
Councilman Rogers provided oral comments at the public hearing. Councilman
Rogers "wholeheartedly" endorses the Proposed Plan. Councilman Rogers encourage
EPA to use local labor and if possible ship the material out of New Bedford by rail.
Councilman Rogers also recommends that a location remote to any community be chosen
as the off-site disposal location and suggests that a Nevada landfill be selected.
EPA Response
EPA appreciates Councilman Roger's support for the Proposed Plan. EPA supports the
goal of using local labor to the maximum extent practicable. EPA will not be directly
responsible for hiring during the cleanup. However, we will continue to work with the U.S.
Army Corps of Engineers, their contractors and the City toward the goal of using local labor.
EPA has asked the City council to provide us with a list of local contractors that could possibly
be used during the harbor cleanup. Contractors on this list may be notified by the Corps of
A-7
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Engineers and their contractors of job opportunities during the harbor cleanup.
Your comments regarding the use of the New Bedford rail yard is addressed in EPA's
response to Mr. Barrett's and Mr. Kopcych's comments. In summary, the means of
transportation and the location of the off-site landfill will be decided during the competitive
bidding process.
2.3 State Government Comments
2.3.1 Commonwealth of Massachusetts, Executive Office of Environmental Affairs,
Department of Environmental Protection
The Commonwealth submitted written comments on the Proposed Plan in a letter
dated September 24,1998. The Commonwealth reserves its concurrence of the amended
Record of Decision until all public comments have been received and reviewed. However,
the DEP has the following comments on the Proposed Plan.
1. The DEP appreciates the EPA's efforts in participating in the New Bedford
Harbor Community Forum in an attempt to gain a consensus on the final resolution for the
Hot Spot sediments. Both the DEP and EPA reached basically the same conclusion
regarding a preference for treatment of the Hot Spot material. However, the Forum's
consensus was the off-site landfilling alternative in the Proposed Plan. The DEP will accept
this alternative pending review of the comments received during the comment period.
2. While the DEP will support the off-site landfilling option, if supported by the
public, it is disappointing that a treatment option was not selected. Both conventional and
innovative destruction technologies are readily available and were reviewed by the Forum.
While the difficulties in treatment of all the contamination at the Site are insurmountable,
the original intent of having the Hot Spot Operable unit was to treat the most highly
contaminated material. The Hot Spot contains about 45% of the total PCBs at the Site in
about 15,000 cubic yards of highly contaminated sediment It is the DEP's opinion that
there are on-site and off-site treatment options that can be implemented in a manner
protective of both human health and the environment which would result in destruction of
the PCBs and therefore a better long term outcome.
EPA Response
The EPA appreciates and agrees with DEP's comments. We also believe that an on-site
treatment option could have been safely implemented.
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2.4 Congressional Comments
2.4.1 Congressman Frank
Congressman Frank prepared written comments dated September 16,1998 which
were read by Ms. Elsie Sousa at the public hearing. Congressman Frank's comments are
as follows:
First:
Concerning the clean up alternatives for the Hot Spot sediments, I support the
proposed changes to the 1990 clean up plan which were generated by discussions in the
Forum.
EPA Response:
EPA appreciates Congressman Frank"s support for the Proposed Plan.
Second:
It is my very strong belief that it is in the best interests of the harbor, and of the
community as a whole, for the Record of Decision on Phase H of the Clean Up be expedited,
so that it is published as quickly as is allowable.
EPA Response
The Record of Decision on Phase II was signed on September 25, 1998.
Third:
I want to take this opportunity to state that I support the linkage of navigational
dredging with Superfund dredging wherever possible.
EPA Response:
EPA also supports the linkage of navigational dredging with Superfund dredging
wherever possible. EPA will cooperate with the Commonwealth of Massachusetts and the City
of New Bedford in its efforts to implement an effective and timely navigational dredging
program. It should be noted that the opportunities for linkage exists with the Phase II cleanup,
not the Hot Spot cleanup.
Finally:
I strongly support the development of a more comprehensive process for ensuring
that local residents receive hiring preference over non local residents for jobs created as a
result of the dean up.
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EPA Response
EPA supports the goal of using local labor to the maximum extent practicable. EPA will
not be directly responsible for hiring during the cleanup. However, we will continue to work with
the U.S. Army Corps of Engineers, their contractors and the City toward the goal of using local
labor. EPA has asked the City council to provide us with a list of local contractors that could
possibly be used during the harbor cleanup. Contractors on this list may be notified by the Corps
of Engineers and their contractors of job opportunities during the harbor cleanup
2.5 AVX Corporation's Comments
AVX Corporation, one of the settling parties involved in Site-related litigation, submitted
written comments in a letter to EPA dated September 25, 1998. The AVX comments consisted
of four parts: Part I is titled "Consent Decree Reopeners Are Not Available"; Part II is titled "The
Proposed ROD Amendment's Cleanup Plan Is Likely to Cost More and Take Longer Than Now
Estimated"; Part III is titled "The Proposed ROD Amendment Fails to Evaluate Comparative
Risk"; and Part IV is titled "Now Is the Time for EPA to Learn From the OU1 Experience and
Reconsider the Plan for the Rest of the New Bedford Harbor."
AVX requested that their comments be included in the Administrative Record for both
OU1 and OU2. EPA will include these comments in the Administrative Record for the Hot Spot
Operable Unit (OU2). However, since these comments were received long after the public
comment period for OU1 ended, they will not be added to the OU1 Administrative Record.
2.5.1 Part I (Consent Decree Reopeners Are Not Available)
AVX Comment #1
The definition of "Remedial Costs" in the Consent Decree entered by the United
States District Court for the District of Massachusetts in Civil Action No. 83-3882-Y
excludes "any increase in costs resulting from any amendments to the RODS" for the first
and second operable units at the New Bedford Harbor Site. AVX believes that they should
not be subject to any future efforts to seek additional reimbursement of costs for this
Amended ROD.
EPA Response
While EPA understands AVX's concern about future government demands for
reimbursement for costs associated with this Amendment to the Hot Spot Rod, this document is
not the forum for interpreting the provisions of the Consent Decree. The remedy selection
process is based on the nine criteria of the NCP, one of which is a consideration of the cost of the
remedy. However, the source of funding for the remedy is not part of the cost criteria.
A-10
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2.5.2 Part II (The Proposed ROD Amendment's Cleanup Plan Is likely to Cost More and Take
Longer Than Now Estimated)
AVX Comment #1
EPA has consistently underestimated the costs and time required to implement the
work at the New Bedford Harbor Superfund Site.
EPA Response
AVX claims that EPA spent $33,700,000 on dredging. The costs which EPA incurred
were for much more than dredging the Hot Spot sediments. EPA incurred costs associated with
the design of the entire remedy including dredging and incineration of the sediments, all site
upgrades in preparation of dredging and incineration, award and subsequent cancellation of the
remedial action contract for incineration, construction and operation of the waste water treatment
plant, modifications to the CDF for interim storage of the Hot Spot sediments, dredging of the
sediments, environmental monitoring during dredging, and continued operations and
maintenance of the Sawyer Street CDF since 1995. EPA admits that the number of days to
dredge the sediments were significantly greater than originally estimated and the total project
costs were also significantly greater than originally estimated. As AVX pointed out, the
intended accuracy of EPA's original estimate was +50%/-30%, which means that the'original
estimate could be low by as much as 50%. A significant portion of the total project delays and
increased costs were due to delays associated with the pos^RODf congressionally supported
public opposition to the incineration component of the original remedy. This public opposition
could not have been predicted at the time the ROD was released in 1990.
AVX Comment #2
EPA's present selection of a comparatively low cost remedial option for OU1
suggests an effort to avoid unnecessary costs and to limit the grossly protracted schedule,
but AVX's and the public's confidence in EPA was long ago lost due to the indefensible
escalation of costs, extension of time and erratic remedy selection process. AVX believes
that EPA's track record at the New Bedford Harbor Superfund Site strongly suggests the
great likelihood of further cost increases and scheduling extensions, which EPA should
consider now, rather than later.
EPA Response
EPA's selection of off-site landfilling was based on a comparative analysis of eleven
remedial options using the nine NCP criteria. Cost was only one of the nine NCP criteria.
EPA's rationale for selecting the off-ste landfilling option was presented in the August 1998
Proposed Plan. Off-site landfilling was also the consensus decision of the Community Forum
which was established in late 1993 to help regain the public's trust. The EPA is confident in the
A-ll
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public's support for the Proposed Plan and EPA is confident that off-site landfilling can be
completed in the two year estimate and that the cost estimate is within the +50%/-30% range.
2.5.3 Part III (The Proposed ROD Amendment Fails to Evaluate Comparative Risk)
AVX commented that it appears that EPA's Hot Spot Feasibility Study Addendum
(December 1997) does not include an evaluation of the risk associated with implementation
of the Proposed ROD Amendment, i.e., transporting the Hot Spot sediments off site and
placing them in a landfill. AVX commented further that since trucks will be operating in
an urban environment for at least two years and driving collectively thousands of miles
over public highways, and since large volumes of contaminated sediments will be placed in
a landfill, it is extremely important to evaluate the incremental risk to the public. It could
be that the risk to the public from these relatively risky operations would exceed the risks
associated with leaving the Hot Spot sediments in place.
EPA Response
EPA discussed the risks associated with the Proposed ROD Amendment in Section 6.2.10
of the December 1997 Hot Spot Feasibility Study Addendum and in the August 1998 Proposed
Plan.
The off-site transportation of dewatered sediments may be accomplished using trucks or a
combination of trucks and rail. It has been approximated that seven trucks per day, five days per
week will enter and leave the site for a period of six months to a year, not two years. EPA does
not consider of transportation of the dewatered Hot Spot sediment via truck or rail and disposal
in a TSCA permitted chemical waste landfill to be relatively risky operations. These activities
are routine. EPA believes that the continued storage of the Hot Spot sediments in the Sawyer
Street CDF will pose a greater potential future risk to the public health and the environment than
any risk associated with off-site transportation and disposal.
2.5.4 Part IV (Now Is the Time for EPA to Learn From the OU1 Experience and Reconsider
the Plan for the Rest of the New Bedford Harbor)
AVX's comments in this section appear to be primarily focused on EPA's cleanup
plan for the Upper and Lower Harbor Operable Unit, not the Hot Spot Operable Unit.
AVX refers to the plan for the rest of the harbor as OU2. For the record, the Hot Spot
Operable Unit is OU2 and the Upper and Lower Harbor Operable Unit is OU1. AVX
commented that in its selection of the OU2 remedy (actually OU1, see preceding sentence)
should not repeat the errors made patent by the Hot Spot remedy and its selection
(including its modification and amendment).
A-12
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EPA Response
AVX had ample opportunity to comment on the Upper and Lower Harbor cleanup plan
during the formal public comment period for that operable unit and, in fact, did submit many
comments to EPA during the Upper and Lower Harbor comment period. EPA will not respond
to these comments to the OU1 cleanup plan in this OU2 Responsiveness Summary.
A-13
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Appendix B - Administrative Record Index
New Bedford Harbor Superfund Site
Amended Record of Decision for the Hot Spot Sediments
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New Bedford Harbor
Hot Spot Operable Unit
NPL Site
Administrative Record
for the Amended Record of Decision
Index
Compiled: April 22, 1999
Prepared by
EPA New England
Office of Site Remediation & Restoration
With Assistance from
ads
2070 Chain Bridge Road
Vienna, VA 22182
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Introduction
This document is the Index to the Administrative Record for the Amended Record of
Decision at the New Bedford Harbor Superfund Site Hot Spot Operable Unit. The citations in the
Index are for those documents that EPA relied upon in selecting a response action at the Site. Site-
specific documents are cited in Section I of the Index, and EPA guidance documents are cited in
Section II. Documents cited in Section I of the Index are ordered by the Documents Number that
appears at the end of each citation.
The Administrative Record is available for public review at the EPA Region I Superfund
Records Center, One Congress Street, Boston, MA 02114 [(617) 918-1440], and Wilkes Library
1911 Acushnet Avenue, New Bedford, MA 02740. Please note that this Administrative Record also
includes documents from Administrative Records for this Site that were issued on April 6, 1990
April 27, 1992, October 30, 1995 and September 25, 1998. EPA guidance documents cited in
Section II are available for review only at the EPA Region I Superfund Records Center. The Staff
of the EPA Region I Superfund Records Center recommends that you set up an appointment prior
to your visit.
Questions concerning the Administrative Record should be addressed to the Project Manager
for the New Bedford Harbor Superfund Site Hot Spot Operable Unit.
An Administrative Record is required by.the Comprehensive Environmental Response
Compensation and Liability Act (CERCLA), as amended by the Superfund Amendments and
Reauthorization Act (SARA).
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ADMINISTRATIVE RECORD INDEX
NEW BEDFORD HARBOR
HOT SPOT OPERABLE UNIT
04/23/99
Page l
04.01 FEASIBILITY STUDY - CORRESPONDENCE
Title:
Addressee:
Authors:
Date:
Format:
AR No.
Title:
Addressee:
Authors:
Date:
Format:
AR No.
Title:
Addressee:
•Authors:
Date:
Format:
AR No.
Title:
Addressee:
Authors:
Date:
Format:
AR No.
Concerning Approval to Dispose PCBs.
DR. NEIL L. DROBNY - COMMODORE REMEDIATION
TECHNOLOGIES, INC.
JOHN W. MELONE - EPA-HEADQUARTERS
March 7, 1996
LETTER No. Pgs. 5
04.01.1 Document No. 000064
Request from Molten Metal Technology to Deploy
its Catalytic Extraction Processing System in
Order to Process PCB Sediment.
THEODORE NIXON - EBASCO SERVICES INC
VICTOR GATTO - MOLTEN METAL TECHNOLOGY INC
March 8, 1996
LETTER No. pgs. ^
04.01.2 Document No. 000135
Letter Concerning the Shipment of a Few Gallons
of Sediment to Commodore's Ohio Facility
DAVE DICKERSON - EPA - REGION I
O.M. JONES, JR. - COMMODORE SOLUTION
TECHNOLOGIES, INC.
November . 1, -1996
LETTER NO. Pgs: 5
04.01.3 Document No. 000134
Recommendation That a New Commodore Technology Be
Used to Treat Hot Spot Sediments.
DAVE DICKERSON - EPA - REGION I
O.M. JONES, JR. - COMMODORE SOLUTION
TECHNOLOGIES, INC.
November 15, 1996
LETTER No. Pgs: 1
04.01.4 Document No. 000110
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ADMINISTRATIVE RECORD INDEX
NEW BEDFORD HARBOR
HOT SPOT OPERABLE UNIT
04/23/99
Page 2
Title: Conditional Approval to Commodore to Address
Untreated Sediment from the Hot Spot Confined
Disposal Facility.
Addressee: O.M. JONES, JR. - COMMODORE SOLUTION
TECHNOLOGIES, INC.
Authors: DAVE DICKERSON - EPA - REGION I
Date: January 24, 1997
Format: LETTER No. Pgs: 1
AR No. 04.01.5 Document No. 000109
Title:Authorization to Commodore to Use Its
Ultrafiltration Unit.
Addressee: DR. NEIL L. DROBNY - COMMODORE REMEDIATION
TECHNOLOGIES, INC.
Authors: JOHN W. MELONS - EPA-HEADQUARTERS
Date: June 9, 1997
Format: LETTER No. Pgs: 14
AR No. 04.01.6 Document No. 000108
Title:Discussion of SET Process and Its Ability to
Remediate Contaminated New Bedford Harbor
Sediments.
Addressee: NEW BEDFORD HARBOR SUPERFUND FORUM
Authors: PAUL E. HANNESSON - COMMODORE SOLUTION
TECHNOLOGIES, INC.
Date: October 15, 1997
Format: LETTER No. Pgs: 1
AR No. 04.01.7 . Document No. 000107
Title:Issues Concerning ETHEC's Process for On-Site
Remediation of Contaminated New Bedford Harbor
Sediments.
Addressee: JIM BROWN - EPA - REGION I
Authors: WILL N. CLURMAN, ALEXANDER GURFINKEL - ETHEC,
INC.
Date: January 9, 1998
Format: LETTER No. Pgs: 1
AR No. 04.01.8 Document No. 000106
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ADMINISTRATIVE RECORD INDEX
NEW BEDFORD HARBOR
HOT SPOT OPERABLE UNIT
04/23/99
Page 3
Title: Retention of One of Four Drums of New Bedford
Harbor Sludge by Commodore.
Addressee: JIM BROWN - EPA - REGION I
Authors: GLEN JONES - COMMODORE SOLUTION TECHNOLOGIES
INC.
Date: March 10, 1998
Format: LETTER No. pgs. j_
AR No. 04.01.9 Document No. 000105
Title:Commodore's PCB Permits."
Addressee: HARLEY LAING - EPA - REGION I
Authors: RAYBURN HANZLIK - COMMODORE SOLUTION
TECHNOLOGIES, INC.
Date: May 21, 1998
Format: LETTER " No. Pgs: 3
AR No. 04.01.10 Document No. 000063
Title:
Addressee
Authors:
Date:
Format:
AR No.
Authorization to Destroy Waste Oils Containing
PCBs.
VINCE VALERI - COMMODORE APPLIED TECHNOLOGIES
INC.
JOHN W. MELONE - EPA-HEADQUARTERS
May 29, 1998
LETTER No. Pgs: 38
04.01.11 Document No. 000062
Title:
Addressee;
Authors:
Date:
Format:
AR No.
Certificate of Destruction Regarding Three of
Four Drums of New Bedford Harbor Sludge.
JIM BROWN - EPA - REGION I
GLEN JONES - COMMODORE APPLIED TECHNOLOGIES, INC
June 23, 1998
LETTER No. Pgs: 9
04.01.12 Document No. 000061
04.03 FEASIBILITY STUDY - SCOPES OF WORK
Title:
Addressee:
Authors:
Date:
Format:
AR No.
New Bedford Harbor Treatability Study Scope of
WO2TJC .
KATHLEEN HUNT
DAVE DICKERSON - EPA - REGION I
January 1995
REPORT, STUDY No. Pgs: 19
04.03.1 Document No. 000184
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ADMINISTRATIVE RECORD INDEX
NEW BEDFORD HARBOR
HOT SPOT OPERABLE UNIT
04/23/99
Page 4
04.04 FEASIBILITY STUDY - INTERIM DELIVERABLES
Title:
Addressee;
Authors:
Date:
Format:
AR No.
Title:
Addressee:
Authors:
Date:
Format:
AR No.
Draft Work Plan, New Bedford Harbor RI/FS, Hot
Spot Sediment Treatability Studies, New Bedford,
Massachusetts.
EPA - REGION I
EBASCO SERVICES INC
February 1995
REPORT, STUDY No. Pgs: 153
04-04.1 Document No. 000111
Massachusetts Department of Environmental
Protection Review of Draft Work Plan -
Treatability Studies.
DAVE D1CKERSON - EPA - REGION I
JAY NAPARSTEK - MA DEPT OF ENVIRONMENTAL
PROTECTION
February 24, 1995
LETTER No. Pgs: 4
04.04.2 Document No.
000185
Title:Draft Field Operations Plan - Pilot Scale
Treatability Studies (Vol. I - Overall Pilot
Scale Test Program.)
Addressee: FOSTER WHEELER ENVIRONMENTAL CORPORATION
Authors: EBASCO SERVICES INC
Date: March 1996
Format: REPORT, STUDY No. Pgs: 73
AR No. 04.04.3 Document No. 000099
Title:Draft Field Operations Plan - Pilot Scale
Treatability Studies (Vol. II - Ionics RCC
Detailed Demonstration Plan.)
Addressee: FOSTER WHEELER ENVIRONMENTAL CORPORATION
Authors: EBASCO SERVICES INC
Date: March 1996
Format: REPORT, STUDY No. Pgs: 111
AR No. 04.04.4 Document No. 000100
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ADMINISTRATIVE RECORD INDEX
NEW BEDFORD HARBOR
HOT SPOT OPERABLE UNIT
04/23/99
Page 5
Title: Review Draft - Field Operations Plan - Pilot
Scale Treatability Studies - (Volume II of V -
Ionics RCC Detailed Demonstration Plan.
Authors: FOSTER WHEELER ENVIRONMENTAL CORPORATION
Date: May 1996
Format: REPORT, STUDY No. Pgs: 168
AR No. 04.04.5 Document No. 000101
Title:Site Specific Safety & Health Plan - Pilot-Scale
Treatability Studies - (Vol. V of V - Overall
Pilot-Scale Test Program.)
Authors: FOSTER WHEELER ENVIRONMENTAL CORPORATION
Date: ' May 1996
Format: REPORT, STUDY No. Pgs: 247
AR No. 04.04.6 Document No. 000102
Title:Field Laboratory Technical Systems Audit Report.
Addressee: DAVE DICKERSON - EPA - REGION I
Authors: ANN JEFFERIES, NORA CONLON - EPA-ENVIRO
MEASUREMENT & EVALUATION
Date: June 21, 1996
Format: MEMORANDUM No. Pgs: 4
AR No. 04.04.7 Document No. 000160
Title:Field Operations Plan - Pilot Scale Treatability
Studies - (Vol. Ill of V - Geosafe Detailed
Demonstration Plan.)
Authors: FOSTER WHEELER ENVIRONMENTAL CORPORATION
Date: July 1996
Format: . REPORT, STUDY No. Pgs: 431
AR No. 04.04.8 Document No. 000104
Title: Comments on the Draft Volume III of the New
Bedford Hot Spot Treatability Study Field
Operations Plan.
Addressee: ALAN FOWLER - FOSTER WHEELER ENVIRONMENTAL
CORPORATION
Authors: ROBERT G. CIANCIARULO - EPA - REGION I
Date: July 11, 1996
Format: LETTER No. Pgs: 18
AR No. 04.04.9 Document No. 000159
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ADMINISTRATIVE RECORD INDEX
NEW BEDFORD HARBOR
HOT SPOT OPERABLE UNIT
04/23/99
Page 6
Title: New Bedford Risk Assessment.
Addressee: NEW BEDFORD ARCS PERSONNEL
Authors: PETER W. VERNON - FOSTER WHEELER ENVIRONMENTAL
CORPORATION
Date: September 19, 1996
Format: MEMORANDUM No. Pgs: 4
AR No. 04.04.10 Document No. 000158
Title:New Bedford Harbor Pilot-Scale Treatability Study
Project Schedule and Review of Draft SAIC Project
Plans.
Addressee: ARTHUR SHATTUCK - SCIENCE APPLICATIONS
INTERNATIONAL CO.
Authors: ALAN FOWLER - FOSTER WHEELER ENVIRONMENTAL
CORPORATION
Date: October 2, 1996
Format: LETTER No. Pgs: 15
AR No. 04.04.11 Document No. 000157
Title:Field Operations Plan - Pilot Scale Treatability
Studies - (Vol. IV of V - SAIC/ECO Logic Detailed
Demonstration Plan.)
Authors: FOSTER WHEELER ENVIRONMENTAL CORPORATION
Date: November 1996
Format: • REPORT, STUDY - No. Pgs: 485
AR No. 04.04.12 Document No. 000103
Title:New Bedford RI/FS Response to EPA and DEP
Comments on the Draft Volume IV - Field
Operations Plan.
Addressee: DAVE DICKERSON - EPA - REGION I
Authors: ALAN FOWLER - FOSTER WHEELER ENVIRONMENTAL
CORPORATION
Date: November 27, 1996
Format: LETTER No. Pgs: 15
AR No. 04.04.13 Document No. 000156
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ADMINISTRATIVE RECORD INDEX
NEW BEDFORD HARBOR
HOT SPOT OPERABLE UNIT
04/23/99
Page 7
Title: New Bedford Harbor RI/FS Response to Sea Change
Comments on the Draft Volume ,-lv - Field
Operations Plan.
Addressee: DAVE DICKERSON - EPA - REGION I
Authors: ALAN FOWLER - FOSTER WHEELER ENVIRONMENTAL
CORPORATION
Date: December 5, 1996
Format: LETTER No. Pgs: 18
AR No. 04.04.14 Document No. 000155
Title:Third ISV Treatability Test at New Bedford
Harbor.
Addressee: ALAN FOWLER - FOSTER WHEELER ENVIRONMENTAL
CORPORATION
Authors: DALE M. TIMMONS - GEOSAFE CORPORATION
Date: January 23, 1997
Format: LETTER No. Pgs: 3
AR No. 04.04.15 Document No. 000154
Title::Comments on January 1997 Draft RCC/CRTI Test
Report.
Addressee: ALAN FOWLER - FOSTER WHEELER ENVIRONMENTAL
CORPORATION
Authors: DAVE DICKERSON - EPA - REGION I
Date: January 28, 1997 .
Format: LETTER No. Pgs: 1
AR No. 04.04.16 Document No. 000153
Title:Pilot Scale Treatability Testing of the In Situ
Vitrification Technology.
Addressee: FOSTER WHEELER ENVIRONMENTAL CORPORATION
Authors: GEOSAFE CORPORATION .
Date: February 10, 1997
Format: REPORT, STUDY No. Pgs: 166
AR No. 04.04.17 Document No. 000131
Title:Response to Comments on Draft Report."~
Addressee: ALAN FOWLER - FOSTER WHEELER ENVIRONMENTAL
CORPORATION
Authors: DALE M. TIMMONS - GEOSAFE CORPORATION
Date: February 10, 1997
Format: LETTER No. Pgs: 5
AR No. 04.04.18 Document No. 000152
-------
Title:
Addressee:
Authors:
Date:
Format:
AR No.
ADMINISTRATIVE RECORD INDEX
NEW BEDFORD HARBOR
HOT SPOT OPERABLE UNIT
04/23/99
Page 8
Title: Test Report for On Site Pilot Scale Demonstration
Testing of the B.E.S.T. Solvent Extraction
Process and Solvated Electron Technology.
Addressee: FOSTER WHEELER ENVIRONMENTAL CORPORATION.
Authors: IONICS RESOURCES CONSERVATION COMPANY
Date: March 1997
Format: REPORT, STUDY No. Pgs: 150
AR No. 04.04.19 Document No. 000132
Follow-Up to ISV Treatbility Test at New Bedford.
DAVE DICKERSON - EPA - REGION I
DALE M. TIMMONS - GEOSAFE CORPORATION
March 20, 1997
LETTER No. Pgs: 12
04.04.20 Document.No. 000151
Final Report - On Site Pilot Scale Testing of the
ECO LOGIC Process.
FOSTER WHEELER ENVIRONMENTAL CORPORATION
SCIENCE APPLICATIONS INTERNATIONAL CO.
May 15, 1997
REPORT, STUDY No. Pgs: 184
04.04.21 Document No. 000133
Title:
Addressee:
Authors:
Date:
Format:
AR No.
Title:New Bedford Harbor RI/FS; Hot Spot Treatability
Studies, SAIC/ECO Logic-Vendor Report of Pilot
Study Testing.
Addressee: DAVE DICKERSON - EPA - REGION I
Authors: ALAN FOWLER - FOSTER WHEELER ENVIRONMENTAL
CORPORATION
Date: May 15, 1997
Format: LETTER No. Pgs: 10
AR No. 04.04.22 Document No. 000150
Title:
Addressee:
Authors:
Date:
Format:
AR No.
MA DEP Comments on Hot Spot Treatability Studies,
New Bedford Harbor Superfund Site.
JIM BROWN - EPA - REGION I
PAUL CRAFFEY - MA DEPT OF ENVIRONMENTAL
PROTECTION
July 8, 1997
LETTER No. Pgs: 5
04.04.23 Document No. 000149
-------
Title:
Addressee:
Authors:
Date:
Format:
AR No.
ADMINISTRATIVE RECORD INDEX
NEW BEDFORD HARBOR
HOT SPOT OPERABLE UNIT
Response to Concerns Expressed in Foster
Wheeler's March 26, 1997 Letter.
ALAN FOWLER - FOSTER WHEELER ENVIRONMENTAL
CORPORATION
O.M. JONES, JR. - COMMODORE SOLUTION
TECHNOLOGIES, INC.
July 22, 1997
No. Pgs: 3
Document No.
04/23/99
Page 9
04.04.24
000148
Addressee;
Authors:
Date:
Format:
AR No.
New Bedford Harbor RI/FS Hot Spot Treatability
Studies Data Compendium.
JIM BROWN - EPA - REGION I
ALAN FOWLER - FOSTER WHEELER ENVIRONMENTAL
CORPORATION
September 25, 1997
. No. Pgs: 3
5 Document No. 000147
Addressee:
Authors:
Date:
Format:
AR No.
Drum and Waste Container Sampling, New Bedford
Harbor Superfund Site.
U.S. ARMY CORPS OF ENGINEERS
ROY F. WESTON
March 1998
REPORT, STUDY
04.04.26 Document No. 000041
04.06
FEASIBILITY STUDY - FEASIBILITY STUDY REPORTS
Addressee:
Authors:
Date:
Format:
AR No.
New Bedford Harbor Hot Spot Treatibility Study
Volume I. ix
EPA - REGION I
FOSTER WHEELER ENVIRONMENTAL CORPORATION
September 1997
REPORT, STUDY
04.06.1 Document No. 000113
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NEW BEDFORD HARBOR
HOT SPOT OPERABLE UNIT
04/23/99
Page 10
Title:
Addressee:
Authors:
Date:
Format:
AR No.
New Bedford Harbor Hot Spot Treatability Study
Data Compendium Volume II.
EPA - REGION I
FOSTER WHEELER ENVIRONMENTAL CORPORATION
September 1997
REPORT, STUDY
04.06,2 Document No. 000114
Title:
Addressee:
Authors:
Date:
Format:
AR No.
New Bedford Harbor Hot Spot Treatability Study
Data Compendium Volume III.
EPA - REGION I
FOSTER WHEELER ENVIRONMENTAL CORPORATION
September 1997
REPORT, STUDY
04.06.3 Document No. 000115
Title:
Addressee:
Authors:
Date:
Format:
AR No.
New Bedford Harbor Hot Spot Treatibility Study
Data Compendium Volume IV.
EPA - REGION I
FOSTER WHEELER ENVIRONMENTAL CORPORATION
September 1997
REPORT, STUDY No. Pgs: 172
04.06.4 Document No. 000116
Title:
Addressee:
Authors:
Date:
Format:
AR No.
New Bedford Harbor Hot Spot Treatability Study
Data Compendium Volume V.
EPA - REGION I
FOSTER WHEELER ENVIRONMENTAL CORPORATION
September 1997
REPORT, STUDY No. Pgs: 336
04.06.5 Document No. 000117
Title:
Addressee:
Authors:
Date:
Format:
AR No.
New Bedford Harbor Hot Spot Treatability Study
Data Compendium Volume VI.
EPA - REGION I
FOSTER WHEELER ENVIRONMENTAL CORPORATION
September 1997
REPORT, STUDY No. Pgs: 307
04.06.6 Document No. 000118
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NEW BEDFORD HARBOR
HOT SPOT OPERABLE UNIT
04/23/99
Page ll
Title:
Addressee;
Authors:
Date :
Format:
AR No.
New Bedford Harbor "Hot Spot Treatability Study
Data Compendium Volume VII.
EPA - REGION I
FOSTER WHEELER ENVIRONMENTAL CORPORATION
September 1997
REPORT, STUDY No. Pgs: 469
04.06.7 Document No. 000119
Title:
Addressee;
Authors:
Date:
Format:
AR No.
New Bedford Harbor Hot Spot Treatability Study
Data Compendium Volume VIII.
EPA - REGION I
FOSTER WHEELER ENVIRONMENTAL CORPORATION
September 1997
REPORT, STUDY No. Pgs: 235
04.06.8 Document No. 000120
Title:
Addressee:
Authors:
Date:
Format:
AR No.
New Bedford Harbor Hot Spot Treatability Study
Data Compendium Volume IX.
EPA - REGION I
FOSTER WHEELER ENVIRONMENTAL CORPORATION
September 1997
REPORT, STUDY No. Pgs: 412
04.06.9 Document No. 000121
Title:
Addressee:
Authors:
Date:
Format:
AR No.
New Bedford Harbor Hot Spot Treatability Study
Data Compendium Volume X.
EPA - REGION I
FOSTER WHEELER ENVIRONMENTAL CORPORATION
September 1997
REPORT, STUDY No. Pgs: 303
04.06.10 Document No. 000122
Title:
Addressee:
Authors:
Date:
Format:
AR No.
Announcing the Results of a Revised Test of the
SET Process on Hot Spot Sediments.
NEW BEDFORD HARBOR SUPERFUND FORUM
PAUL E. HANNESSON - COMMODORE SOLUTION
TECHNOLOGIES, INC.
October 15, 1997
LETTER NO. Pgs: 1
04.06.11 Document No. 000145
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NEW BEDFORD HARBOR
HOT SPOT OPERABLE UNIT
04/23/99
Page 12
Title:
Addressee:
Authors:
Bate:
Format:
AR No.
Comments on Draft Feasibility Study Addendum Hot
Spot Operable Unit.
JIM BROWN - EPA - REGION I
PAUL CRAFFEY - MA DEPT OF ENVIRONMENTAL
PROTECTION
November 13, 1997
LETTER No. Pgs: 4
04.06.12 Document No. 000144
Title:
Addressee:
Authors:
Date:
Format:
AR No.
Comments on Draft New Bedford Harbor Hot Spot
Feasibility Study Addendum.
JIM BROWN - EPA - REGION I
DALE M. TIMMONS - GEOSAFE CORPORATION
November 19, 1997
LETTER NO. pgS: 8
04.06.13 Document No. 000143
Title:
Addressee:
Authors:
Date:
Format:
AR No.
Comments on the Foster Wheeler Draft New Bedford
Harbor Hot Spot Feasibility Study Addendum.
JIM BROWN - EPA - REGION I
ARTHUR SHATTUCK - SCIENCE APPLICATIONS
INTERNATIONAL CO.
November 26, 1997
LETTER No. Pgs: 35
04.06.14 Document No. 000142
Title: Draft Final New Bedford Harbor Hot Spot
Feasibility Study Addendum.
Addressee: EPA - REGION I
Authors: FOSTER WHEELER ENVIRONMENTAL CORPORATION
Date: December 1997
Format: REPORT, STUDY
AR No. 04.06.15 Document No.
000112
Title:
Addressee:
Authors:
Date:
Format:
AR No.
Comments on Draft Final Feasibility Study
Addendum, Hot Spot Operable Unit, New Bedford
Superfund Site.
JIM BROWN - EPA - REGION I
PAUL CRAFFEY - MA DEPT OF ENVIRONMENTAL
PROTECTION
June 15, 1998
LETTER No. Pgs: 5
04.06.16 Document No. 000146
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NEW BEDFORD HARBOR
HOT SPOT OPERABLE UNIT
04/23/99
Page 13
04.07 FEASIBILITY STUDY - WORK PLANS & PROGRESS REPORTS
Title:New Bedford Harbor OU3 RI/FS Scoping
Acknowledgement Letter Hot Spot Sediment
Treatability Studies.
Addressee: DAVE DICKERSON - EPA - REGION I
Authors: ALAN FOWLER - EBASCO SERVICES INC
Date: February 1, 1995
Format: LETTER No. Pgs: 9
AR No. 04.07.1 Document No.
000181
Title:
Addressee:
Authors:
Date:
Format:
AR No.
Title:
Addressee:
•Authors:
Date:
Format:
AR No.
Title:
Addressee:
Authors:
Date:
Format:
AR No.
Scoping Ackowledgement Letter - Hot Spot Sediment
Treatability Studies.
DAVE DICKERSON - EPA - REGION I
ALAN FOWLER - EBASCO SERVICES INC
February 1, 1995
LETTER No. Pgs: 8
04.07.2 Document No. 000186
New Bedford Harbor - Hot Spot Treatability
Studies Draft Work Plan and Cost Estimate.
KATHLEEN HUNT - EPA - REGION I
ALAN FOWLER - EBASCO SERVICES INC
March 24, 1995
LETTER NO. Pgs: 2 '
04.07.3 Document No. 000180
New Bedford Harbor RI/FS Hot Spot Treatability
Studies Work Plan Amendment No. 1.
KATHLEEN HUNT - EPA - REGION I
ALAN FOWLER - FOSTER WHEELER ENVIRONMENTAL
CORPORATION
April 26, 1996
LETTER No. Pgs: 2
04.07.4 Document No. 000179
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NEW BEDFORD HARBOR
HOT SPOT OPERABLE UNIT
04/23/99
Page 14
Title: Technical Direction for Additional Work - Job
Change No. 01.
Addressee: THOMAS J. ABDELLA - ROY F. WESTON
Authors: MAURICE BEAUDOIN - U.S. ARMY CORPS OF ENGINEERS
Date: May 6, 1996
Format: LETTER No, Pgs: 3
AR No. 04.07.5 Document No. 000178
Title:Notification of Delay and Request for Contract
Change Order.
Addressee: THEODORE NIXON - EBASCO SERVICES INC
Authors: WILLIAM F. HEINS - RESOURCES CONSERVATION COMPANY
Date: May 30, 1996
Format: LETTER No. Pgs: 3
AR No. 04.07.6 Document No. 000177
Title: New Bedford Harbor RI/FS Treatability Study
Activities and Schedule.
Addressee: DAN SHEA - ST. LUKES HOSPITAL
Authors: ALAN FOWLER - FOSTER WHEELER ENVIRONMENTAL
CORPORATION
Date: July 12, 1996
Format: LETTER No. Pgs: 1
AR No. 04.07.7 Document No. 000176
Title:New Bedford RI/FS Limitation of Cost Notice.
Addressee: LINDA BYRNE - EPA - REGION I
Authors: MARK TUCKER - FOSTER WHEELER ENVIRONMENTAL
CORPORATION
Date: August 12, 1996
Format: LETTER No. Pgs: 1
AR No. 04.07.8 Document No. 000175
Title:New Bedford Harbor RI/FS Treatability Studies
Geosafe Corporation Testing Program Utility
Support Requirements.
Addressee: MAURICE BEAUDOIN - U.S. ARMY CORPS OF ENGINEERS
Authors: ALAN FOWLER - FOSTER WHEELER ENVIRONMENTAL
CORPORATION
Date: August 16, 1996
Format: LETTER No. Pgs: 2
AR No. 04.07.9 Document No. 000174
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Title:
Addressee:
Authors:
Date:
Format:
AR No.
ADMINISTRATIVE RECORD INDEX
NEW BEDFORD HARBOR
HOT SPOT OPERABLE UNIT
04/23/99
Page 15
Title: New Bedford Harbor RI/FS OU3 Treatability Study
Request for Additional Information.
Addressee: LINDA BYRNE - EPA - REGION I
Authors: MARK TUCKER - FOSTER WHEELER ENVIRONMENTAL
CORPORATION
Date: September 4, 1996
Format: LETTER No. Pgs: 4
AR No. 04.07.10 Document No. 000173
New Bedford Harbor RI/FS OU3 Treatability Study
Request for Additional Information.
LINDA BYRNE - EPA - REGION I
MARK TUCKER - FOSTER WHEELER ENVIRONMENTAL
CORPORATION
September 10, 1996
LETTER
04.07.11
No. Pgs: 2
Document No.
000172
Title: Consent to Subcontract with SAIC for the Third
Treatability Study.
Addressee: MARK TUCKER - FOSTER WHEELER ENVIRONMENTAL
CORPORATION
Authors: LINDA BYRNE - EPA - REGION I
Date: September 12, 1996
Format: • LETTER No. Pgs: 2
AR No. 04.07.12 Document No. 000171
Title:New Bedford Harbor RI/FS Treatability Studies
SAIC Testing Program Support Requirements.
Addressee: MAURICE BEAUDOIN - U.S. ARMY CORPS OF ENGINEERS
Authors: ALAN FOWLER - FOSTER WHEELER ENVIRONMENTAL
CORPORATION
Date: September 24, 1996
Format: . LETTER No. Pgs: 1
AR No. 04.07.13 Document No. 000170
Title:New Bedford Harbor RI/FS Treatbility Studies SAIC
Testing Program Site Lighting Requirements.
Addressee: MAURICE BEAUDOIN - U.S. ARMY CORPS OF ENGINEERS
Authors: ALAN FOWLER - FOSTER WHEELER ENVIRONMENTAL
CORPORATION
Date: October 3, 1996
Format: LETTER No. Pgs: 1
AR No. 04.07.14 Document No. 000169
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NEW BEDFORD HARBOR
HOT SPOT OPERABLE UNIT
04/23/99
Page 16
Title: New Bedford Harbor Pilot-Scale Treatability Study
Revised Project Schedule.
Addressee: ARTHUR SHATTUCK - SCIENCE APPLICATIONS
INTERNATIONAL CO.
Authors: ALAN FOWLER - FOSTER WHEELER ENVIRONMENTAL
CORPORATION
Date: October 8, 1996
Format: LETTER No. Pgs: 3
AR No. 04.07.15 Document No. 000168
Title:New Bedford Harbor Pilot-Scale Treatbility Study
Outstanding Items for Draft Field Operation Plan.
Addressee: ARTHUR SHATTUCK - SCIENCE APPLICATIONS
INTERNATIONAL CO.
Authors: ALAN FOWLER - FOSTER WHEELER ENVIRONMENTAL
CORPORATION
Date: October 15, 1996
Format: LETTER No. Pgs: 2
AR No. 04.07.16 Document No. 000167
Title:Deliverables Promised to Foster Wheeler for the
New Bedford Proj ect.
Addressee: K. CAMPBELL
Authors: ARTHUR SHATTUCK
Date: October 17, 1996
Format: MEMORANDUM No. Pgs: 1
AR No. 04.07.17 Document No. 000166
Title:
Addressee:
Authors:
Date:
Format:
AR No.
New Bedford Harbor Work Plan Amendment No. 2.
LINDA BYRNE - EPA - REGION I
ALAN FOWLER - FOSTER WHEELER ENVIRONMENTAL
CORPORATION
October 18, 1996
LETTER No. Pgs: 4
04.07.18 Document No.
000165
Title: New Bedford Harbor Pilot Scale Treatability Study
Notice to Cure.
Addressee: ROBERT W. LARRICK JR. - SCIENCE APPLICATIONS
INTERNATIONAL CO.
Authors: THEODORE NIXON - FOSTER WHEELER ENVIRONMENTAL
CORPORATION
Date: October 28, 1996
Format: LETTER No. Pgs: 3
AR No. 04.07.19 Document No. 000164
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NEW BEDFORD HARBOR
HOT SPOT OPERABLE UNIT
04/23/99
Page 17
Title: New Bedford Harbor RI/FS Work Plan Amendment No.
2, Revised Budget Recap Table and Technical
Memorandum.
Addressee: LINDA BYRNE - EPA - REGION I
Authors: ALAN FOWLER - FOSTER WHEELER ENVIRONMENTAL
CORPORATION
Date: November 1, 1996
Format: LETTER No. Pgs: 5
AR No. 04.07.20 Document No. 000163
Title:Treatability Study Activities and Schedule.
Addressee: DAN SHEA - ST. LUKES HOSPITAL
Authors: ALAN FOWLER - FOSTER WHEELER ENVIRONMENTAL
CORPORATION
Date: November 6, 1996
Format: LETTER No. Pgs: 1
AR No. 04.07.21 Document No. 000141
Title:New Bedford Harbor RI/FS Treatability Study
Activities and Schedule.
Addressee: KEN SILVIA - CITY OF NEW BEDFORD
Authors: ALAN FOWLER - FOSTER WHEELER ENVIRONMENTAL
CORPORATION
Date: November 6, 199S
Format: LETTER No. Pgs: 1
AR No. 04.07.22 Document No. 000161
Title:New Bedford Harbor Pilot-Scale Treatability Study
Notice to Proceed with Field Mobilization.
Addressee: ARTHUR SHATTUCK - SCIENCE APPLICATIONS
INTERNATIONAL CO.
Authors: ALAN FOWLER - FOSTER WHEELER ENVIRONMENTAL
CORPORATION
Date: November 6, 1996
Format: LETTER No. Pgs: 2
AR No. 04.07.23 Document No. 000162
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NEW BEDFORD HARBOR
HOT SPOT OPERABLE UNIT
04/23/99
Page 18
Title: New Bedford Harbor Treatability Study - Work
Assignment #30.
Addressee: HEIDI HORAHAN - FOSTER WHEELER ENVIRONMENTAL
CORPORATION
Authors: DAVE DICKERSON - EPA - REGION I
Date: November 14, 1996
Format: MEMORANDUM No. Pgs: 2
AR No. 04.07.24 Document No. 000140
Title:
Addressee:
Authors:
Date:
Format:
AR No.
Request for a No-Cost Extension to the Project
Schedule and Extended Working Hours During System
Integrity Testing.
ALAN FOWLER - FOSTER WHEELER ENVIRONMENTAL
CORPORATION
ARTHUR SHATTUCK - SCIENCE APPLICATIONS
INTERNATIONAL CO.
November 15, 1996
LETTER No. Pgs: 1
04.07.25 Document No. 000139
852 Hours of Proposed "New Scope" in the Work
Plan Amendment of 10/18/96.
LINDA BYRNE - EPA - REGION I
DAVE DICKERSON - EPA - REGION I
•November 19, 1996 .
MISCELLANEOUS No. Pgs: 1
04.07.26 Document No. 000138
Title:
Addressee:
Authors:
Date:
Format:
AR No.
Title: Work Plan Amendment No. 3.
Addressee: LINDA BYRNE - EPA - REGION I
Authors: MARK TUCKER - FOSTER WHEELER ENVIRONMENTAL
CORPORATION
Date: February 24, 1997
Format: LETTER No. Pgs: 3
AR No. 04.07.27 Document No. 000137
Title:Work Plan - Scoping for Time Extension and New
Tasking.
Addressee: DAVE DICKERSON - EPA - REGION I
Authors: HELEN DOUGLAS - FOSTER WHEELER ENVIRONMENTAL
CORPORATION
Date: June 27, 1997
Format: LETTER No. Pgs: 3
AR No. 04.07.28 Document No. 000136
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NEW BEDFORD HARBOR
HOT SPOT OPERABLE UNIT
04/23/99
Page 19
04.09
FEASIBILITY STUDY - PROPOSED PLANS FOR SELECTED REMEDIAL ACTION
Addressee:
Authors:
Date:
Format:
AR No.
Title:
Addressee:
Authors:
Date:
Format:
AR No.
Authors:
Date:
Format:
AR No.
Draft Proposed Plan. '. ~~
JIM BROWN - EPA - REGION I
DEBORAH M. SIMONE - METCALF & EDDY
July 20, 1998
FACT SHEET, PRESS RELEASE No. Pgs: 14
04-09-1 Document No.
000060
Authors:
Date:
Format:
AR Nc.
Agency Comments on Draft Proposed Plan
JIM BROWN - EPA - REGION I
PAUL CRAFFEY - MA DEPT OF ENVIRONMENTAL
PROTECTION
July 24, 1998
LETTER No. Pgs: 2
04 no o „
vt.vy.z Document No.
000059
Proposed Plan to Amend the 1990 Cleanup Plan for
the New Bedford Harbor Hot Spot Sediments
EPA - REGION I
August 1998
FACT SHEET, PRESS RELEASE No. Pgs: 13
04.09.3 Document No. 000057
Piano Proposto Emendar o Piano de Limpeza de 1990~
dos Sedimentos no 'Hot Spot' do Porto de New
Bedford.
EPA - REGION I
August 1998
FACT SHEET, PRESS RELEASE No. Pgs: 13
04.09.4 Document No. 000058
05.01 RECORD OF DECISION - CORRESPONDENCE
Addressee;
Authors:
Date:
Format:
AR No.
DEP Concurrence with Proposed Second BSD
DAVE DICKERSON - EPA - REGION I
MADELINE SNOW - MA DEPT OF ENVIRONMENTAL
PROTECTION
March 28, 1995
LETTER No_ pgs. 2
Ub-01-1 Document No.
000194
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NEW BEDFORD HARBOR
HOT SPOT OPERABLE UNIT
04/23/99
Page 20
05.03 RECORD OF DECISION - RESPONSIVENESS SUMMARIES
Title: Comments on the Proposed Plan (Cross Reference to
13.1.).
Addressee: EPA - REGION I
Authors: MANUEL SYLVIA, BERYL SYLVIA
Format: LETTER No. Pgs: 44
AR No. 05.03.1 . Document No. 000195
Title:Comments on the Proposed Plan.
Addressee: JIM BROWN - EPA - REGION I
Authors: CLAUDIA JACOBSEN
Date: August 28, 1998
Format: CORRESPONDENCE No. Pgs: 1
AR No. 05.03.2 Document No. 000190
Title:Comments on the Proposed Plan.
Addressee: JIM BROWN - EPA - REGION I
Authors: ROMAN RUSINOSKI
Date: September 14, 1998
Format: CORRESPONDENCE No. Pgs: 2
AR No. 05.03.3 Document No. 000192
Title: Comments on the Proposed Plan.- ~:
Addressee: JAMES SIMMONS - HANDS ACROSS THE RIVER COALITION
Authors: DAVE BARRETT
Date: September 16, 1998
Format: MISCELLANEOUS No. Pgs: 1
AR No. 05.03.4 Document No. 000187
Title:Comments on the Proposed Plan.
Addressee: JIM BROWN - EPA - REGION I
Authors: CAROL SANZ - DOWNWIND COALITION
Date: September 23, 1998
Format: LETTER No. Pgs: 1
AR No. 05.03.5 Document No. 000191
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NEW BEDFORD HARBOR
HOT SPOT OPERABLE UNIT
Title: Comments on the Proposed Plan.
Addressee: JIM BROWN - EPA - REGION I
Authors: CLAUDIA KIRK
Date: September 24, 1998
Format: LETTER No. Pgs: 2
AR No. 05.03:6 Document No
04/23/99
Page 21
000188
Title: Comments on the Proposed Plan.
Addressee: JIM BROWN - EPA - REGION I
Authors: MARY RYAN - NUTTER MC CLENNEN & FISH
Date: September 25, 1998
Format: LETTER No. Pgs: 9
AR No. 05.03.7 Document No. 000193
06.01 REMEDIAL DESIGN - CORRESPONDENCE
Title: Review of the Draft Report on Pilot Scale
Incineration of Hot Spot Sediments.
Addressee: KEVIN HOWE - U.S. ARMY CORPS OF ENGINEERS
Authors: GAYLE GARMAN - EPA - REGION I
Date: October 17, 1991
Format: MEMORANDUM No. Pgs: 4
AR No. 06.01.1 Document No. 000125
Title:Comments on the Draft Test Burn Report.
Addressee: KEVIN HOWE - U.S. ARMY CORPS OF ENGINEERS
Authors: PAUL CRAFFEY - MA DEPT OF ENVIRONMENTAL
PROTECTION
Date: October 24, 1991
Format: LETTER No. Pgs: 2
AR No. 06.01.2 Document No. 000124
Title:Cover Letter - Submittal of the 100% Design
Report.
Addressee: KEVIN HOWE - U.S. ARMY CORPS OF ENGINEERS
Authors:- ROBERT FOXEN, JAMES FITZGERALD - ERM-NEW ENGLAND
INC.
Date: November 27, 1991
Format: LETTER
AR No. 06.01.3
No. Pgs: 1
Document No.
000123
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NEW BEDFORD HARBOR
HOT SPOT OPERABLE UNIT
04/23/99
Page 2 2
06.04 REMEDIAL DESIGN - REMEDIAL DESIGN DOCUMENTS
Title:
Addressee:
Authors:
Date:
Format:
AR No.
Title:
Authors:
Date:
Format:
AR No.
Preliminary Data Summary Report for Evaluating
the Incinerability of the New Bedford/Hot Spot
Operable Unit at the EPA Incineration Research
Facility.
EPA OFFICE OF R & D - CINICNNATI
ACUREX CORPORATION
August 28, 1991
REPORT, STUDY No. Pgs: 96
06-04.1 Document No. 000183
Title:
Addressee
Authors :
Date:
Format :
AR No.
Final Design Analysis.
: U.S. ARMY CORPS OF ENGINEERS
ERM-NEW ENGLAND INC.
November 1991
REPORT, STUDY
06.04.2
No . Pgs :
Document
606
No.
000128
Title: Specifications for Construction Contract -
Hazardous Waste Cleanup (Vol. 1 of 2 - Proposal
Information - Divisions 1 and 2).
Authors: U.S. ARMY CORPS OF ENGINEERS
Date: December 1991 '
Format: REPORT, STUDY No. Pgs: 431
AR No. 06.04.3 Document No. 000126
Title:Specifications for Construction Project -
Hazardous Waste Cleanup (Vol. 2 of 2 Divisions 3
thru 16).
Authors: U.S. ARMY CORPS OF ENGINEERS
Date: December 1991
Format: REPORT, STUDY No. Pgs: 241
AR No. 06.04.4 Document No. 000127
Specifications for the Pilot-Scale Incineration.
U.S. ARMY CORPS OF ENGINEERS
February 12, 1992
REPORT, STUDY No. Pgs: 257
06.04.5 • Document No. 000130
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NEW BEDFORD HARBOR Page 23
HOT SPOT OPERABLE UNIT
06.09 REMEDIAL DESIGN - BID DOCUMENTS
Title: Request for Proposal For Construction Contract
New Bedford Harbor/Hot Spot Operable Unit.
Authors: U.S. ARMY CORPS OF ENGINEERS
Date: November 1991
Format: REPORT, STUDY No. Pgs: 627
Y AR No. 06.09.1 Document No. 000129
09.01 STATE COORDINATION - CORRESPONDENCE
Title: Comments on Proposed Plan (Cross Reference to
5.3.).
Addressee: JIM BROWN - EPA - REGION I
Authors: PAUL CRAFFEY - MA DEPT OF ENVIRONMENTAL
PROTECTION
Date: September 24, 1998
Format: LETTER No. Pgs: 2
AR No. 09.01.1 Document No. 000189
09.10 STATE COORDINATION - STATE TECHNICAL AND HISTORICAL RECORDS
Title:Final Record of Decision for the New Bedford
Harbor Hot Spot Operable Unit.
Authors: JOHN DEVILLARS - MASSACHUSETTS OFFICE OF ENVIR
AFFAIRS
Date: December 14, 1990
Format: MISCELLANEOUS No. Pgs: 5
AR No. 09.10.1 Document No. 000197
*Attached to Document No. 000196 In 13.01
13.01 COMMUNITY RELATIONS - CORRESPONDENCE
Title:EPA Remedy Selection Process.~~~~
Addressee: PETER KOCZERA - TOWN OF ACUSHNET BOARD OF
SELECTMAN
Authors: JOHN DEVILLARS - EPA - REGION I
Format: LETTER NO. Pgs: 2
AR No. 13.01.1 Document No. 000046
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ADMINISTRATIVE RECORD INDEX
NEW BEDFORD HARBOR
HOT SPOT OPERABLE UNIT
04/23/99
Page 24
Title:
Addressee:
Authors:
Format:
AR No.
Letter of Appreciation for Jane Wells on Serving
as a Neutral Facilitator for the New Bedford
Harbor Forum.
JANE WELLS - MASSACHUSETTS OFFICE OF DISPUTE
RESOLUT
PAUL KEOUGH - EPA - REGION I
LETTER No. Pgs: 1
13.01.2 Document No. 000199
Title:
Addressee:
Authors:
Date:
Format:
AR No.
Response to the August 31, 1993 Newspaper
Article, "What's the Rush to Incinerate? It's
Time for EPA to Look Again."
STEVE URBON - NEW BEDFORD STANDARD TIMES
PAUL KEOUGH - EPA - REGION I
September 16, 1993
No. Pgs: 1
Document No
LETTER
13.01.3
000200
Title:
Addressee:
Authors:
Date i
Format:
AR No.
Response to George Rogers Letter of October 4,
1993 Regarding Hot Spot Remediation - (Cross
Reference to 5.3.)
GEORGE ROGERS - CITY OF NEW BEDFORD
DANIEL GREENBAUM - MA DEPT OF ENVIRONMENTAL
PROTECTION
October 13, 1993
LETTER No. Pgs: 12
13.01.4 Document No. 000196
Title:
Addressee:
Authors:
Date :
Format:
AR No.
Letter Which Requests Jonathan Cairns's Support
for a Review of Strategies for PCB Cleanup.
JOHNATHAN CAIRNS
HENRY LONGEST - EPA - REGION I
November 12, 1993
LETTER No. Pgs. x
13.01.5 Document No. 000201
Title:
Addressee:
Authors:
Date:
Format:
AR No.
Letter Which Requests Claudia Kirk's Support of
Strategies for PCB Cleanup.
CLAUDIA KIRK - CONCERNED PARENTS OF FAIRHAVEN
HENRY LONGEST - EPA - REGION I
November 19, 1993
LETTER No. Pgs: 1
13.01.6 Document No. 000202
-------
Title:
Addressee
Authors:
Date:
Format:
AR No.
ADMINISTRATIVE RECORD INDEX
NEW BEDFORD HARBOR
HOT SPOT OPERABLE UNIT
04/23/99
Page 25
Response to Susan Grace's September 20, 1993
Letter Expressing Opposition to Incineration as
an Alternative Technology.
SUSAN GRACE
PAUL KEOUGH - EPA - REGION I
December 23, 1993
LETTER NO. Pgs: 1
13.01.7 Document No. 000203
Title:
Addressee:
Authors:
Date:
Format:
AR No.
Letter Concerning Future Decisions on the New
Bedford Harbor Cleanup.
DAVID HAMMOND - HANDS ACROSS THE RIVER COALITION
HARLEY LAING - EPA - REGION I
June 14, 1994
LETTER No. pgs. 2
13.01.8 Document No. 000204
Title:
Addressee:
Authors:
Date:
Format: •
AR No.
Article Requested by Diana Cobbold of Sea Change
on the Long Term Stability and Leaching of ISV
Products.
DAVE DICKERSON - EPA - REGION I
ALAN FOWLER - FOSTER WHEELER ENVIRONMENTAL
CORPORATION
August 30, 1996
LETTER No. Pgs: 12
13.01.9 Document No. 000069
Title:
Addressee:
Authors:
Date:
Format:
AR No.
Support Thermal Disorption as a Cleanup Remedy
JOHN DEVILLARS - EPA - REGION I
JAMES SIMMONS, DANIEL MATTO, MAUREEN SANTOS
ELIZABETH TAYLOR - HANDS ACROSS THE RIVER '
COALITION
June 13, 1997
LETTER No. Pgs: 2
13.01.10 Document No. 000068
Title:
Addressee:
Authors:
Date:
Format:
AR No.
PCB Harbor Forum. ~~~~ ~
JOHN DEVILLARS - EPA - REGION I
PETER KOCZERA - TOWN OF ACUSHNET BOARD OF
SELECTMAN
July 14, 1997
LETTER No. Pgs: 2
13.01.11 Document No. 000067
-------
Title:
Addressee:
Authors:
Date:
Format:
AR No.
ADMINISTRATIVE RECORD INDEX
NEW BEDFORD HARBOR
HOT SPOT OPERABLE UNIT
04/23/99
Page 2 6
Development of the Feasibility Study Addendum
Report.
JAMES SIMMONS - HANDS ACROSS THE RIVER COALITION
HARLEY LAING - EPA - REGION I
July 18, 1997
LETTER No. Pgs: 3
13.01.12 Document No. 000066
Title:
Addressee:
Authors:
Date:
Format:
AR No.
Selection of One Remedial Technology Over
Another.
CAROL SANZ
JOHN DEVILLARS - EPA - REGION I
August 19, 1997
LETTER No. Pgs: 1
13.01.13 Document No. 000045
Title:
Addressee:
Authors:
Date:
Format:
AR No.
List of Questions to Submit to the Sea Change
Panel Review.
DIANA COBBOLD - SEA CHANGE INC.
JIM BROWN - EPA - REGION I
October 22, 1997
LETTER No. Pgs: 1
13.01.14 Document No. 000044
Title: - -Organization of the October 30, 1997 Public Sea
Change Review of the Technologies for New
Bedford.
Addressee: DIANA COBBOLD - SEA CHANGE INC.
Authors: HARLEY LAING - EPA - REGION I
Date: December 12, 1997
Format: LETTER No. Pgs: 1
AR No. 13.01.15 Document No. 000043
Title:Resumes of Jim Brown and Dave Dickerson.
Addressee: JAMES SIMMONS - HANDS ACROSS THE RIVER COALITION
Authors: HARLEY LAING - EPA - REGION I
Date: December 23, 1997
Format: LETTER No. Pgs: 4
AR No. 13.01.16 Document No. 000042
-------
Title:
Addressee:
Authors:
Date:
Format:
AR No.
ADMINISTRATIVE RECORD INDEX
NEW BEDFORD HARBOR
HOT SPOT OPERABLE UNIT
04/23/99
Page 27
Complaint from a Resident Regarding a Release of
Hazardous Materials from the Sawyer Street
Facility.
WARREN IDE - CITY OF NEW BEDFORD FIRE DEPARTMENT
JIM BROWN - EPA - REGION I
June 3, 1998
LETTER No. Pgs: 1
13.01.17 Document No. 000065
13.03 COMMUNITY RELATIONS - NEWS CLIPPINGS/PRESS RELEASES
Title:
Authors:
Format:
AR No.
Title:
Authors:
Format:
AR No.
New Bedford Still Seeks Way to Deal with PCBs
PETER HOWE - BOSTON GLOBE
NEWS CLIPPING No. Pgs: 2
13.03.1 Document No. 000052
EPA Announces a Meeting and Invites Public
Comment on the Explanation of Significant
Differences.
EPA - REGION I
NEWS CLIPPING No. Pgs: 1
13.03.2 Document No. 000208
Title:What's the Rush to Incinerate? It's Time for EPA
to Look Again.
Authors: STEVE URBON - NEW BEDFORD STANDARD TIMES
Date: August 31, 1993
Format: NEWS CLIPPING No. Pgs: 1
AR No. 13.03.3 Document No. 000205
*Attached to Document No. 000200 In 13.01
Title:
Authors:
Date:
Format:
AR No.
EPA Virtually Abandons Plan to Burn PCB7~s~.
NATALIE WHITE - NEW BEDFORD STANDARD TIMES
January 27, 1994
NEWS CLIPPING No. Pgs: 2
13.03.4 Document No. 000207
-------
Title:
Authors:
Date:
Format:
AR No.
ADMINISTRATIVE RECORD INDEX
NEW BEDFORD HARBOR
HOT SPOT OPERABLE UNIT
04/23/99
Page 28
EPA Will Proceed with Dredging New Bedford Harbor
Hot Spots.
EPA - REGION I
February 10, 1994
NEWS CLIPPING NO. Pgs: 1
13.03.5 Document No. 000206
Title:
Authors;
Date:
Format:
AR No.
Briton to Document Agency's Victory Against PCB
Incineration.
WILLIAM COREY - STANDARD-TIMES
January 16, 1998
NEWS CLIPPING No. Pgs: 2
13.03.6 Document No. 000049
Title:
Authors:
Date:
Format:
AR No.
Harbor Cleanup of PCBs is Still a Long Way Awav
RACHEL G. THOMAS - STANDARD-TIMES
January 22, 1998
NEWS CLIPPING No. Pgs: 1
13.03.7 Document No. 000048
Title:Time's a Wasting."
Authors: JACK STEWARDSON - STANDARD-TIMES
Date: February 7, 1998
Format: NEWS CLIPPING No Pgs- 5
AR No. 13.03.8 -Document No.
000047
Title:
Authors:
Date:
Format:
AR No.
Title:
Authors;
Date:
Format:
AR No.
Still No Decision on Disposal of PCBs.
JACK STEWARDSON - STANDARD-TIMES
April 1, 1998
NEWS CLIPPING No. Pgs: 1
13.03.9 Document No.
000051
Forum Winding Up PCB Talks, Ready for Action":
JACK STEWARDSON - STANDARD-TIMES
April 29, 1998
NEWS CLIPPING NO. Pgs: 2
13.03.10 Document No. 000053
-------
13.04
Title:
Authors;
Date:
Format:
AR No.
Title:
Authors:
Date:
Format:
AR No.
Title:
Authors:
Date:
Format:
AR No.
ADMINISTRATIVE RECORD INDEX
NEW BEDFORD HARBOR
HOT SPOT OPERABLE UNIT
04/23/99
Page 29
May l, 1998
Document No. 000054
PCBs: To Fill or Not To Fill
JACK STEWARDSON - STANDARD-TIMES
June 6, 1998
NEWS CLIPPING No. Pgs: 2
Document No,
River Cleanup Takes a Giant Step
JACK STEWARDSON - STANDARD-TIMES'
June 19, 1998
NEWS CLIPPING Ho. pgs; 2
1J-03-13 Document No.
000056
000055
COMMUNITY RELATIONS - PUBLIC MEETINGS
Title:
Authors:
Date .-
Format:
AR No.
Invitation to Attend Two Meetings to Discuss the
Treatment of the Hot Spot Sedimint. U1SCUSS the
NEW BEDFORD SITE COMMUNITY FORUM
FACT SHEET, PRESS RELEASE
13.04.1
Title:
Date:
Format:
AR No.
Title:
Date:
Format:
AR No.
No. Pgs : 2
Document No.
Minutes ot Meeting Held on December 7
December 16, 1993
PUBLIC^MEETING RECORDS No. Pgs: 4
13-04-2 Document No.
000094
C00209
Minutes of Meeting Held January 5
January 5, 1994
PUBLIC MEETING RECORDS No. Pgs : 8
13 '°4'3 Document No.
000210
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ADMINISTRATIVE RECORD INDEX
NEW BEDFORD HARBOR
HOT SPOT OPERABLE UNIT
04/23/99
Page 30
Title:
Date:
Format :
AR No.
Title:
Date:
Format :
AR No.
Title :
Date:
Format :
AR No.
Title :
Date:
Format :
AR No.
Title:
Date:
Format :
AR No.
Title:
Date:
Format :
AR No.
Title :
Date:
Format :
AR No.
New Bedford Superfund Site Meeting Agenda
January 12, -1994.
January 12, 1994
PUBLIC MEETING RECORDS No. Pgs : 1
13-04.4 Document No.
Minutes of Meeting Held
January 12, 1994
PUBLIC MEETING RECORDS
13.04.5
January 12, 1994.
No . Pgs : 3
Document No.
000211
000212
New Bedford Harbor Superfund Site Meeting Agenda
- January 26, 1994.
January 26, 1994
PUBLIC MEETING RECORDS No. Pgs: 1
13.04.6 Document No. 000213
Minutes of Meeting Held
January 26, 1994
PUBLIC MEETING RECORDS
13.04.7
Minutes of Meeting Held
February 9, 1994
PUBLIC MEETING RECORDS
13.04.8
January 26, 1994.
No . Pgs : 1
Document No.
February 9, 1994.
No. Pgs: 2
Document No .
New Bedford Harbor Superfund Forum Meeting
- March 1, 1994.
March 1, 1994
PUBLIC MEETING RECORDS No. Pgs: 6
13.04.9 Document No.
Minutes of Meeting Held
March 1, 1994
PUBLIC MEETING RECORDS
13.04.10
March 1, 1994.
No . Pgs : 5
Document No .
000214
000215
Agenda
000216
000217
-------
Title:
Date:
Format
AR No.
ADMINISTRATIVE RECORD INDEX
NEW BEDFORD HARBOR
HOT SPOT OPERABLE UNIT
New Bedford Harbor Superfund Site Meeting
- March 9, 1994.
March 9, 1994
PUBLIC MEETING RECORDS No. Pgs: 1
13.04.11 Document No.
04/23/99
Page 31
Agenda
000218
Title:
Date:
Format:
AR No.
Minutes of Meeting Held March 9, 1994
March 9, 1994
PUBLIC MEETING RECORDS No. Pgs: 2
13.04.12 Document No.
000219
Title:
Date:
Format:
AR No.
Minutes of Meeting Held March 30,1994.
March 30, 1994
PUBLIC MEETING RECORDS No. Pgs: 2
13.04.13 Document No.
000220
Title:
Date:
Format:
AR No.
Minutes of Meeting Held April 6, 1994.
April 6, 1994
PUBLIC MEETING RECORDS No. Pgs: 3
13.04.14 Document No.
000221
Title:
Date:
Format:
AR No.
Minutes of Meeting Held April 13, 1994
April 13, 1994
PUBLIC MEETING RECORDS No. Pgs: 2
13.04.15 Document No.
000222
Title:
Date:
Format:
AR No.
Minutes of Meeting Held April 26, 1994.
April 26, 1994
PUBLIC MEETING RECORDS No. Pgs: 2
13 . 04.16 Document No.
000223
Title:
Date:
Format:
AR No.
Minutes of Meeting Held May 18, 1994
May 18, 1994
PUBLIC MEETING RECORDS No. Pgs: 2
13.04.17 Document No.
000224
Title:
Date:
Format:
AR No.
New Bedford Harbor Superfund Site Meeting
- June 14, 1994.
June 14, 1994
PUBLIC MEETING RECORDS No. Pgs: 1
13.04.18 Document No.
Agenda
000226
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ADMINISTRATIVE RECORD INDEX
NEW BEDFORD HARBOR
HOT SPOT OPERABLE UNIT
Title: Minutes of Meeting Held June 14, 1994
Date: June 14, 1994
Format: PUBLIC MEETING RECORDS No. Pgs: 2
AR No. 13.04.19 Document No.
04/23/99
Page 32
000227
Title:
Date:
Format:
AR No.
Minutes of Meeting Held July 12, 1994.
July 12, 1994
PUBLIC MEETING RECORDS No. Pgs: 3
13.04.20 Document No.
000228
Title: Minutes of Meeting Held August 9, 1994.
Date: August 9, 1994
Format: PUBLIC MEETING RECORDS No. Pgs: 6
AR No. 13.04.21 Document No.
000230
Title:
Date:
Format:
AR No.
New Bedford Harbor Superfund Site Community Forum
Agreement - (Cross Reference to 13.1.)
November 21, 1994
PUBLIC MEETING RECORDS No. Pgs: 13
13.04.22 Document No. 000231
Title:
Date:
Format:
AR No.
New Bedford Harbor Superfund Forum - May 21
1997.
May 21, 1997
PUBLIC MEETING RECORDS No. Pgs: 19
13.04.23 Document No. 000070
Title: New Bedford Harbor Treatability Study
Subcommittee Meeting.
Date: July 16, 1997
Format: PUBLIC MEETING RECORDS No. Pgs: 8
AR No. 13.04.24 Document No.
000071
Title:
Date:
Format:
AR No.
New Bedford Superfund Forum Meeting - July 30,
1997.
July 30,- 1997
PUBLIC MEETING RECORDS No. Pgs: 17
13.04.25 Document No. 000072
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Title:
Date:
Format:
AR No.
ADMINISTRATIVE RECORD INDEX
NEW BEDFORD HARBOR
HOT SPOT OPERABLE UNIT
04/23/99
Page 33
New Bedford Harbor Treatability Subcommittee
Meeting - October 8, 1997.
October 8, 1997
PUBLIC MEETING RECORDS No. Pgs: 8
13.04.26 Document No. 000073
Title:
Date:
Format:
AR No.
Title: '
Date:
Format:
AR No.
New Bedford Harbor Superfund Forum Meeting -
October 20, 1997.
October 20, 1997
PUBLIC MEETING RECORDS No. Pgs: 48
13.04.27 Document No. 000074
Tztle:Sea Change Panel - New Bedford Harbor
Treatability Studies.
Date: October 30, 1997
Format: PUBLIC MEETING RECORDS No Pgs- 27
AR No. 13.04.28 Document No. 000075
New Bedford Harbor Superfund Forum Meeting ^
November 6, 1997.
November 6, 1997
PUBLIC MEETING RECORDS No. Pgs: 4
13.04.29 . Document No. 000076
Title:
Addressee:
Authors:
Date:
Format:
AR No.
Title:
Date :
Format:
AR No.
New Bedford Harbor Superfund Site Treatability
Study Participants - Presentations.
TREATABILITY STUDY PARTICIPANTS
JIM BROWN - EPA - REGION I
November 18, 1997
LETTER No. Pgs. 3
13.04.30 Document No. 000077
New Bedford Harbor Superfund Forum - December 1
1997.
December l, 1997
PUBLIC MEETING RECORDS No. Pgs: 15
13.04.31 Document No. 000078
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Title:
Date:
Format:
AR No.
ADMINISTRATIVE RECORD INDEX
NEW BEDFORD HARBOR
HOT SPOT OPERABLE UNIT
04/23/99
Page 34
Title: New Bedford Harbor Superfund Forum - December 8,
1997.
Date: December 8, 1997
Format: PUBLIC MEETING RECORDS No. Pgs: 28
AR No. 13.04.32 Document No. 000079
Title:Summary of Meeting of the New Bedford Harbor
Forum - December 16, 1997.
Date: December 16, 1997
Format: PUBLIC MEETING RECORDS No. Pgs: 5
AR No. 13.04.33 Document No. 000080
Title:New Bedford Harbor Superfund Forum - January 21,
1998.
Date: January 21, 1998
Format: PUBLIC MEETING RECORDS No. Pgs: 16
AR No. 13.04.34 Document No. 000081
Title: New Bedford Harbor Superfund Forum - January 21,
1998.
Date: January 21, 1998
Format: PUBLIC MEETING RECORDS No. Pgs: 9
AR No. 13.04.35 Document No. 000098
Title:New Bedford Harbor Superfund Forum - February 5,
1998.
Date: February 5, 1998
Format: PUBLIC MEETING RECORDS No. Pgs: 3
AR No. 13.04.36 Document No. 000082
Title:New Bedford Harbor Superfund Forum - February 12,
1998.
Date: February 12, 1998
Format: PUBLIC MEETING RECORDS No. Pgs: 6
AR No. 13.04.37 Document No. 000083
New Bedford Community Meeting.
February 19, 1998
PUBLIC MEETING RECORDS
13.04.38
No. Pgs: 2
Document No.
000084
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ADMINISTRATIVE RECORD INDEX
NEW BEDFORD HARBOR
HOT SPOT OPERABLE UNIT
04/23/99
Page 35
Title: New Bedford Harbor Superfund Forum - February 25
1998.
Date: February 25, 1998
Format: PUBLIC MEETING RECORDS No. Pgs: 5
AR No. 13.04.39 Document No. 000085
Title: New Bedford Harbor Superfund
1998.
Date: March 15, 1998
Format: PUBLIC MEETING RECORDS
AR No. 13.04.40
Forum - March 15,
No. Pgs: 21
Document No. 000086
Title: New Bedford Harbor Superfund
1998.
Date: March 24, 1998
Format: PUBLIC MEETING RECORDS
AR No. 13.04.41
Forum - March 24,
No. Pgs: 7
Document No. 000087
Title: New Bedford Harbor Superfund
1998.
Date: March 31, 1998
Format: PUBLIC MEETING RECORDS
AR No. 13.04.42
Forum - March 31,
No. Pgs: 34
Document No. 000088
Title: New Bedford Harbor Superfund
1998.
Date: April 28, 1998
Format: PUBLIC MEETING RECORDS
AR No. 13.04.43
Forum - April 28,
No. Pgs: 15
Document No. 000089
Title: New Bedford Harbor Superfund
Date: May 7, 1998
Format: PUBLIC MEETING RECORDS
AR No. 13.04.44
Forum - May 7, 1998.
No. Pgs: 6
Document No. 000090
Title: New Bedford Harbor Superfund
1998.
Date: May 22, 1998
Format: PUBLIC MEETING RECORDS
AR No. 13.04.45
Forum - May 22,
No. Pgs: 6
Document No. 000091
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Title:
Date:
Format:
AR No.
ADMINISTRATIVE RECORD INDEX
NEW BEDFORD HARBOR
HOT SPOT OPERABLE UNIT
04/23/99
Page 3 6
Title: New Bedford Harbor Superfund Forum - June 4,
1998.
Date: June 4, 1998
Format: PUBLIC MEETING RECORDS No. Pgs: 6
AR No. 13.04.46 Document No. 000092
Title:New Bedford Harbor Superfund Forum - June 17,
1998.
Date: June 17, 1998
Format: PUBLIC MEETING RECORDS No. Pgs: 26
AR No. 13.04.47 Document No. 000093
Title:New Bedford Harbor Superfund Site Community Forum
Recommendation.
Authors: NEW BEDFORD SITE COMMUNITY FORUM
Date: July 1998
Format: MEMORANDUM No. Pgs: 17
AR No. 13.04.48 Document No. 000234
Title:Notice of a Public Meeting on the Proposed Plan.
Authors: EPA - REGION I
Date: August 7, 1998
Format: NEWS CLIPPING No. Pgs: 1
AR No. 13.04.49 Document No, 000050
Title:Proposed Cleanup Plan for the Hot Spot Sediment -
Public Informational Meeting.
Date: August 26, 1998
Format: PUBLIC MEETING RECORDS No. Pgs: 12
AR No. 13.04.50 Document No. 000096
Attendance List - Proposed Plan to Amend the 1990
Cleanup Plan - Public Hearing.
September 16, 1998
LIST No. Pgs: 2
13.04.51 Document No. 000097
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Title:
Date:
Format:
AR No.
ADMINISTRATIVE RECORD INDEX
NEW BEDFORD HARBOR
HOT SPOT OPERABLE UNIT
04/23/99
Page 37
EPA Public Hearing - Cleanup Plan for the New
Bedford Harbor Hot Spot Sediments.
September 16, 1998
PUBLIC MEETING RECORDS No. Pgs: 50
13.04.52 Document No. 000232
13.05 COMMUNITY RELATIONS - FACT SHEETS
Title:
Authors:
Format:
AR No.
New Bedford Harbor Superfund Site: The Community
Forum's Focus on Cleanup of the Hot Spot
Sediment.
EPA - REGION I
FACT SHEET, PRESS RELEASE
.13.05.1 Document No. 000033
Title:
Format:
AR No.
The USEPA Announces the Scheduling of a Public
Meeting, Hearing, and Public Comment Period on
the Proposed Plan.
FACT SHEET, PRESS RELEASE No. Pgs: 2
13.05.2 Document No. 000095
Title: An Open Letter to the Members of the New Bedford
Harbor Superfund Forum.
Addressee: NEW BEDFORD HARBOR SUPERFUND FORUM
Authors: THOMAS E. NOEL - COMMODORE ADVANCED SCIENCES
Date: July 30, 1997
Format: LETTER No. Pgs: 1
AR No. 13.05.3 Document No. 000037
Title:
Authors:
Date:
Format:
AR No.
New Bedford Harbor Superfund Site Verification
Test. Program.
COMMODORE SOLUTION TECHNOLOGIES, INC.
August 1997
REPORT, STUDY
13.05.4 Document No. 000035
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NEW BEDFORD HARBOR
HOT SPOT OPERABLE UNIT
04/23/99
Page 38
Title:
Addressee:
Authors:
Date:
Format:
AR No.
Explanation of the Merits of the Commodore SET
Process in Remediating PCB Waste.
NEW BEDFORD HARBOR SUPERFUND FORUM
PAUL E. HANNESSON - COMMODORE APPLIED
TECHNOLOGIES, INC.
November 5, 1997
LETTER No. Pgs: 1
13.05.5 Document No.
000036
Title: Innovative Treatment Technology Proposal
, Evaluation Criteria.
Authors: JIM BROWN - EPA - REGION I
Date: January 16, 1998
Format: CORRESPONDENCE No. Pgs: 5
AR No. 13.05.6 Document No. 000034
Title:New Bedford Harbor Superfund Site Community Forum
Recommendation.
Date: July 1998
Format: REPORT, STUDY
AR No. 13.05.7 Document No. 000039
Title:Update on the Release of the Proposed Plan.
Addressee: NEW BEDFORD HARBOR SUPERFUND FORUM
Authors: JIM BROWN - EPA - REGION I
Date: July 17, 1998
Format: LETTER No. Pgs: 1
AR No. 13.05.8 Document No. 000038
14.01 CONGRESSIONAL RELATIONS - CORRESPONDENCE
Title:
Addressee:
Authors:
Date:
Format:
AR No.
Request for Participation in Workshop -
Alternatives to Incineration for Disposal of PCB
Contaminants.
JULIE BELAGA - EPA - REGION I
GERRY STUDDS - U.S. HOUSE OF REPRESENTATIVES
January 29, 1992
LETTER No. Pgs: 2
14.01.1 Document No. 000001
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ADMINISTRATIVE RECORD INDEX
NEW BEDFORD HARBOR
HOT SPOT OPERABLE UNIT
04/23/99
Page 3 9
Title: Response to Representative Studds Letter of
January 29, 1992 Requesting EPA Participation in
a Workshop.
Addressee: GERRY STUDDS - U.S. HOUSE 'OF REPRESENTATIVES
Authors: JULIE BELAGA - EPA - REGION I
Date: February 27, 1992
Format: LETTER No. Pgs: 2
AR No. 14.01.2 Document No. 000002
Title:
Addressee:
Authors:
Date:
Format:
AR No.
Results of the Alternative Treatment Technologies
Workshop Conducted on March 5, 1992.
GERRY STUDDS - U.S. HOUSE OF REPRESENTATIVES
JULIE BELAGA - EPA - REGION I
March 18, 1992
LETTER No. Pgs: 1
14.01.3 Document No. 000003
Letter Congratulating EPA on Its Research into
Treatment Technologies at the New Bedford
Superfund Site.
JULIE BELAGA - EPA - REGION I
EDWARD KENNEDY, JOHN KERRY - U.S. SENATE
March 24, 1992
LETTER No. Pgs: 1
14.01.4 Document No. 000004
Title:
Addressee:
Authors:
Date:
Format:
AR No.
Title: Cover letter - Letter Sent to Congressman Studds
on April 21, 1992 Regarding Use of Alternative
Treatment Technologies.
Addressee: EDWARD KENNEDY - U.S. SENATE
Authors: JULIE BELAGA - EPA - REGION I
Date: April 21, 1992
Format: LETTER No. Pgs: 1
AR No. 14.01.5 Document No. 000005
Title:
Addressee:
Authors:
Date:
Format:
AR No.
Cover letter - Letter Sent to Congressman Studds
on April 21, 1992 Regarding Use of Alternative
Treatment Technologies.
JOHN KERRY - U.S. SENATE
JULIE BELAGA - EPA - REGION I
April 21, 1992
LETTER No. Pgs: 1
14.01.6 . Document No. 000006
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ADMINISTRATIVE RECORD INDEX 04/23/99
NEW BEDFORD HARBOR Page 40
HOT SPOT OPERABLE UNIT
Title: Incineration Considered as Best Treatment
Technology for the New Bedford Harbor Superfund
Site (Hot Spot).
Addressee: GERRY STUDDS - U.S. HOUSE OF REPRESENTATIVES
Authors: JULIE BELAGA - EPA - REGION I
Date: April 21, 1992
Format: LETTER No. Pgs: 2
AR No. 14.01.7 'Document No. 000007
Title:Letter in Response to the Review of Technologies
as Alternatives to Incineration for the New
Bedford Superfund Site.
Addressee: JULIE BELAGA - EPA - REGION I
Authors: EDWARD KENNEDY, JOHN KERRY - U.S. SENATE
.Date: May 11, 1992
Format: LETTER No. Pgs: 2
AR No. 14.01.8 Document No. 000009
Title:Letter Expressing Concerns Regarding EPA's
Proposed Cleanup Plan for the Acushnet Bay, Lower
New Bedford Harbor, and Parts of Buzzards Bay.
Addressee: JULIE BELAGA - EPA - REGION I
Authors: GERRY STUDDS - U.S. HOUSE OF REPRESENTATIVES
Date: May 15, 1992
Format: LETTER No. Pgs: 2
AR No. 14.01.9 Document No. 000010
Title:Response to Letter of May 11, 1992 Requesting
Additional Information on EPA's Review of
Technologies for the Remediation of the Hot Spot.
Addressee: JOHN KERRY - U.S. SENATE
Authors: JULIE BELAGA - EPA - REGION I
Date: June 12, 1992
Format: LETTER No. Pgs: 3
AR No. 14.01.10 Document No. 000011
Title:
Addressee;
Authors:
Date:
Format:
AR No.
Response to Letter of May 11,1992 Requesting
Additional Information on EPA's Review of
Technologies for the Remediation of the Hot Spot.
EDWARD KENNEDY - U.S. SENATE
JULIE BELAGA - EPA - REGION I
June 12, 1992
LETTER No. Pgs: 3
14.01.11 Document No. 000012
-------
Title:
Addressee:
Authors:
Date:
Format:
AR No.
ADMINISTRATIVE RECORD INDEX
NEW BEDFORD HARBOR
HOT SPOT OPERABLE UNIT
04/23/99
Page 41
Title: Letter of Support for Overturning the Decision to
Incinerate PCBs.
Addressee: WILLIAM REILLY - EPA-HEADQUARTERS
Authors: BARNEY FRANK - U.S. HOUSE OF REPRESENTATIVES
Date: June 17, 1992
Format: LETTER No. Pgs: 1
AR No. 14.01.12 Document No. 000013
Response to Gerry Studds Letter of May 15, 1992
Which Commented on the Proposed Plan for the
Estuary/Lower Harbor/Bay Portion of New Bedford
Harbor.
GERRY STUDDS - U.S. HOUSE OF REPRESENTATIVES
JULIE BELAGA - EPA - REGION I
June 18, 1992
LETTER No. Pgs: 2
14.01.13 Document No. 000014
Title:
Addressee:
Authors:
Date:
Format:
AR No.
Request Suspension of the Incineration of PCBs in
Favor of an Alternative Method.
CAROL BROWNER - EPA-HEADQUARTERS
BARNEY FRANK - U.S. HOUSE OF REPRESENTATIVES
January 22, 1993
LETTER NO. Pgs: 2
14.01.14 Document No. 000017
Title: Letter Identifying Incineration as the Best
Treatment Technology.
Addressee: BARNEY FRANK - U.S. HOUSE OF REPRESENTATIVES
Authors: RICHARD GUIMOND - EPA-HEADQUARTERS
Date: March 8, 1993
Format: LETTER No. Pgs: 3
AR No. 14.01.15 Document No. 000015
Title:Request for an On-Site Test of Thermal Gas-Phase
Reductive Chlorination.
Addressee: CAROL BROWNER - EPA-HEADQUARTERS
Authors: EDWARD KENNEDY, JOHN KERRY - U.S. SENATE
Date: July 9, 1993
Format: LETTER No. Pgs: 2
AR No. 14.01.16 Document No. 000016
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ADMINISTRATIVE RECORD INDEX
NEW BEDFORD HARBOR
HOT SPOT OPERABLE UNIT
04/23/99
Page 42
Title: Support for Incineration as the Established
Remedy for the New Bedford Superfund Site.
Addressee: EDWARD KENNEDY - U.S. SENATE
Authors: HENRY LONGEST - EPA-HEADQUARTERS
Date: August 18, 1993
Format: LETTER No. Pgs: 2
AR No. 14.01.17 Document No. 000018
Title:Request to Reconsider the Termination of the
Incineration Remedial Treatment Technology.
Addressee: BARNEY FRANK - U.S. HOUSE OF REPRESENTATIVES
Authors: JOHN MORAN - LABORERS HEALTH & SAFETY FUND
Date: August 20, 1993
Format: LETTER No. Pgs: 6
AR No. 14.01.18 Document No. 000019
Title:Discussion of Issues Involving the Incineration
of PCBs in New Bedford.
Addressee: CAROL BROWNER - EPA-HEADQUARTERS
Authors: BARNEY FRANK - U.S. HOUSE OF REPRESENTATIVES
Date: October 12, 1993
Format: LETTER No. Pgs: 3
AR No. 14.01.19 Document No. 000021
Title:Reopening Discussions about the Method of Cleanup
at the New Bedford Harbor Superfund Site.
Addressee: PAUL KEOUGH - EPA - REGION I
Authors: EDWARD KENNEDY, JOHN KERRY, BARNEY FRANK - U.S.
SENATE
Date: October 19, 1993
Format: LETTER " No. Pgs: 2
AR No. 14.01.20 Document No. 000020
Title:Reopening the Question of How Best to Deal-with
the PCB Problem in New Bedford.
Addressee: PAUL KEOUGH - EPA - REGION I
Authors: BARNEY FRANK - U.S. HOUSE OF REPRESENTATIVES
Date: November 2, 1993
Format: LETTER No. Pgs: 1
AR No. 14.01.21 Document No. 000027
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ADMINISTRATIVE RECORD INDEX
NEW BEDFORD HARBOR
HOT SPOT OPERABLE UNIT
04/23/99
Page 43
Title:
Addressee:
Authors:
Date:
Format:
AR No.
Response to Senator Edward Kennedy's Letter of
October 19, 1993 to Hold a Forum on the Issue of
Incineration.
EDWARD KENNEDY - U.S. SENATE
PAUL KEOUGH - EPA - REGION I
November 8, 1993
LETTER • No. Pgs: 2
14.01.22 Document No. 000022
Title:
Addressee:
Authors:
Date:
Format:
AR No.
Response to Representative Barney Frank's Letter
of October 19, 1993 to Hold a Forum on the Issue
of Incineration.
BARNEY FRANK - U.S. HOUSE OF REPRESENTATIVES
PAUL KEOUGH - EPA - REGION I
November 8, 1993
LETTER No. Pgs: 2
14.01.23 Document No. 000023
Title:
Addressee;
Authors:
Date:
Format:
AR No.
Response to Senator John Kerry's Letter of
October 19, 1993 to Hold a Forum on the Issue of
Incineration.
JOHN KERRY - U.S. SENATE
PAUL KEOUGH - EPA - REGION I
November 8, 1993
LETTER
14.01.24
No. Pgs: 2
Document No.
000024
Title:
Addressee;
Authors:
Date:
Format:
AR No.
Reconsider Support of Incineration as the
Acceptable Treatment Technology.
DANIEL GREENBAUM - MA DEPT OF ENVIRONMENTAL
PROTECTION
BARNEY FRANK - U.S. HOUSE OF REPRESENTATIVES
December 16, 1993
LETTER No. Pgs. ^
14.01.25- Document No. 000025
Title:
Addressee:
Authors:
Date:
Format:
AR No.
Response to Representative Barney Frank's Letter
on the Reconsideration of Incineration as the
Chosen Treatment Technology.
BARNEY FRANK - U.S. HOUSE OF REPRESENTATIVES
DANIEL GREENBAUM - MA DEPT OF ENVIRONMENTAL
PROTECTION
December 29, 1993
LETTER No. Pgs: 2
14.01.26 Document No. 000026
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ADMINISTRATIVE RECORD INDEX
NEW BEDFORD HARBOR
HOT SPOT OPERABLE UNIT
04/23/99
Page 44
Title: Concern Regarding Change in the Cleanup Remedy at
the New Bedford Harbor Superfund Site.
Addressee: STROM THURMOND - U.S. SENATE
Authors: BENEDICT ROSEN - AVX CORPORATION
Date: March 24, 1994
Format: LETTER No. Pgs: 4
AR No. 14.01.27 Document No. 000029
Title:Establishment of a Community Forum to Review
Alternatives to On-Site Incineration.
Addressee: STROM THURMOND - U.S. SENATE
Authors: JOHN DEVILLARS - EPA - REGION I
Date: May 11, 1994
Format: LETTER No. Pgs: 3
AR No. 14.01.28 Document No. 000028
Title:EPA Reviewing Alternatives to On-Site
Incineration at Community Forum.
Addressee: ERNEST ROLLINGS - U.S. SENATE
Authors: JOHN DEVILLARS - EPA - REGION I
Date: May 27, 1994
Format: LETTER No. Pgs: 3
AR No. 14.01.29 Document No. 000031
Title:EPA Reviewing Alternatives to On-Site
Incineration at Community Forum.
Addressee: ARTHUR RAVENEL - U.S. HOUSE OF REPRESENTATIVES
Authors: JOHN DEVILLARS - EPA - REGION I
Date: June 1, 1994
Format: LETTER No, Pgs: 3
AR No. 14.01.30 Document No. 000030
Title: Response to Representative Barney Frank's Letter
of January 25, 1996 Regarding the Performance of
Treatability Studies.
Addressee: BARNEY FRANK - U.S. HOUSE OF REPRESENTATIVES
Authors: JOHN DEVILLARS - EPA - REGION I
Date: March 1, 1996
Format: LETTER No. Pgs: 2
AR No. 14.01.31 Document No. 000032
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ADMINISTRATIVE RECORD INDEX
NEW BEDFORD HARBOR
HOT SPOT OPERABLE UNIT
04/23/99
Page 4 5
Title: Discussion of New Bedford Harbor Superfund
Community Forum's Position on Site Cleanup.
Addressee: BARNEY FRANK - U.S. HOUSE OF REPRESENTATIVES
Authors: CLAUDIA KIRK - NEW BEDFORD HARBOR SUPERFUND FORUM
Date: July 26, 1997
Format: LETTER No. Pgs: 10
AR No. 14.01.32 Document No. 000040
Title:Issues Raised Regarding the New Bedford Harbor
Cleanup Process.
Addressee: JIM BROWN - EPA - REGION I
Authors: BARNEY FRANK - U.S. HOUSE OF REPRESENTATIVES
Date: September 16, 1998
Format: LETTER No. Pgs: 1
AR No. 14.01.33 Document No. 000233
17.08 SITE MANAGEMENT RECORDS - STATE AND LOCAL TECHNICAL RECORDS
Title:Letter Against the Incineration Process at the
New Bedford Harbor Superfund Site/Hot Spot.
Addressee: DANIEL GREENBAUM - MA DEPT OF ENVIRONMENTAL
PROTECTION
Authors: GEORGE ROGERS - CITY OF NEW BEDFORD
Date: October 4, 1993
Format: LETTER No. Pgs: 2
AR No. 17.08.-1 Document No. 000198
*Attached to Document No. 000196 In 13.01
-------
-------
Guidance Documents
The EPA guidance documents listed below were considered during the process of selecting the
response action for the New Bedford Harbor Hot Spot Operable Unit. These EPA guidance
documents may be reviewed at the EPA Region I Superfund Records Center.
1- Conducting Remedial Investigations/Feasibility Studies for CERCLA Municipal Landfill
Sites. OSWER #9355.3-11. February 1, 1991. [C177]
2- Feasibility Study - Development and Screening of Remedial Action Alternatives [Quick
Reference Fact Sheet]. OSWER #9355.3-01FS3. November 1, 1989. [2018]
3- Guidance on Feasibility Studies Under CERCLA. EPA 540/G-85-003 June 1 1985
[C034]
4- Guidance on Preparing Superfund Decision Documents: The Proposed Plan, the Record of
Decision. ESD's. ROD Amendment. Interim Final. OSWER #93 55 3-02 Aprils 1989
[C179] '
5 Guidance on Remedial Actions for Superfimd Sites with PCB Contamination. OSWER*
9355.4-01. August 1, 1990. [2014]
6- Guide for Conducting Treatabilitv Studies Under CERCLA. Interim Final. EPA/540/2-
89/058. December 1, 1989. [2015]
7- Guide on Remedial Actions at Superfund Sites with PCB Contamination [Quick Reference
Fact Sheet]. OSWER #9355.4-01FS. August 1, 1990. [C254]
8 Guide to Addressing Pre-ROD and Post-RQD Changes OSWER#9355.3-02FS-4 April
1, 1991. [C259]
9 Guide to Selecting Superfund Remedial Actions. EPA/540/2-89/052 March 1 1989
[2322].
-------
-------
Appendix C - State Concurrence Letter
New Bedford Harbor Superfund Site
Amended Record of Decision for the Hot Spot Sediments
-------
-------
COMMONWEALTH OF MASSACHUSETTS
EXECUTIVE OFFICE OF ENVIRONMENTAL AFFAIRS
DEPARTMENT OF ENVIRONMENTAL PROTECTION
ONE WINTER STREET, BOSTON, MA 02108 617-292-5500
ARGEO PAUL CELLUCCI
Governor
JANE SWIFT
Lieutenant Governor
Ms. Patricia Meaney, Director
Office of Site Remediation and Restoration
U.S. EPA
JFK Federal Building
Boston, MA 02203
BOB DURAND
Secretary
EDWARD P. KUNCE
Acting Commissioner
April 23,1999
Re: Amended ROD - State Concurrence Letter
Hot Spot Operable Unit #2
' New Bedford Harbor Superfund Site
Dear Ms. Meaney:
The Department of Environmental Protection (DEP) has reviewed the preferred remedial action
alternative recommended by the EPA for the cleanup of the Hot Spot Operable Unit at the New
Bedford Harbor Superfund Site. The DEP concurs with the selection of the preferred alternative for
this operable unit.
The DEP has evaluated the EPA's preferred alternative for consistency with M.G.L. Chapter 21E,
and the Massachusetts Contingency Plan (MCP). The preferred alternative addresses the
contaminated sediments that were previously dredged and are currently being stored in a Confined
Disposal Facility in New Bedford. This Operable Unit's amended remedial action has four
components:
1) Upgrade site facilities;
2) Remove the Hot Spot sediment from the Confined Disposal Facility (CDF);
3) Sediment dewatering and water treatment; and
4) Sediment disposal to an appropriate disposal facility off site.
The DEP has determined that the preferred alternative for this Operable Unit is a remedial action on
a portion of the disposal site which would be consistent with a future permanent or temporary
solution for the entire disposal site. M.G.L. Chapter 21E allows the implementation of remedies on
portions of a disposal site.
This tefmution b avaHable in literate format by calling «ur ADA CMntiaator at <«7) 574-6871.
DEP on the World Wide Vtfeb: httpV/Www.magnetstate.ma.us/ctep
O Printed on Recycled Paper
-------
State ROD Concurrence
April 23,1999
Page 2
EPA's current project managers, Jim Brown and Dave Dickerson, should be commended for a
superb job in managing this complex project. Their efforts to include the State and the public in the
Superfund process at this site have been greatly appreciated.
The Department looks forward to working with you in implementing the preferred alternative. If
you have any questions, please contact Paul Craffey at 292-5591.
Very truly yours,
c.
Deirdre C. Menoyo,
Assistant Commissioner
Bureau of Waste Site Cleanup
cc: Millie Garcia-Surette, Deputy Regional Director, SERO
DBS/BWSC/pc
-------
Appendix D - References Cited
New Bedford Harbor Superfund Site
Amended Record of Decision for the Hot Spot Sediments
-------
-------
APPENDIX D - REFERENCES CITED
City of New Bedford, 1993. City of New Bedford, Code of City Ordinances, Chapter 15,
Licenses and Permits; Business Regulations, Article III, Proposed amendments to Sec 15-70
(June 10, 1993).
Forum Agreement, 1998. New Bedford Harbor Superfund Site Community Forum
Recommendation. June-July 1998.
Foster Wheeler, 1997a. Draft Final New Bedford Harbor Hot Spot Feasibility Study Addendum,
New Bedford, Massachusetts. December 1997.
Foster Wheeler, 1997b. New Bedford Harbor Hot Spot Treatability Study Data Compendium
Volumes H-X. September 1997.
NUS Corporation (NUS), 1984. Draft Feasibility Study of Remedial Action Alternatives,
Acushnet River Estuary Above Coggeshall Street Bridge, New Bedford Site, Bristol County,
Massachusetts. August 1984.
USAGE, 1991a. Construction Plans for the New Bedford Harbor Superfund Hazardous Waste
Cleanup, Hot Spot Operable Unit, New Bedford, Massachusetts. US Army Corps of Engineers,
Omaha District. December 1991.
USAGE, 1991b. Final Design Analysis, New Bedford Harbor/Hot Spot Operable Unit
Superfund Site, Contract No. DACW 45-91-C-0010, Interagency Agreement No. DW96934684-
0, New Bedford, Massachusetts. November 1991.
USAGE, 1991c. Specifications (For Construction Contract), Request for Proposal No.
DACW45-92-R-0020, Hazardous Waste Cleanup, New Bedford Harbor/Hot Spot Operable Unit,
Volumes 1-2. December 1991.
USEPA, 1990. Record of Decision, New Bedford Harbor Hot Spot Operable Unit, New
Bedford, Massachusetts. U.S. Environmental Protection Agency, Region I. April 1990.
USEPA, 1992. New Bedford Harbor Site, Hot Spot Operable Unit, Explanation Of Significant
Difference. April 1992.
USEPA, 1995. New Bedford Harbor Superfund Site, Hot Spot Operable Unit, Explanation Of
Significant Difference for Continued Storage of Hot Spot Sediments. Prepared by the EPA-New
England. October 1995.
USEPA 1998a. Proposed Plan to Amend the 1990 Cleanup Plan for the New Bedford Hot Spot
Sediments, New Bedford, MA. August 1998.
-------
USEPA 1998b. Record Of Decision for the Upper and Lower Operable Unit, New Bedford
Harbor Superfund Site, New Bedford, Massachusetts. September 1998.
VHB, 1996. New Bedford Harbor Historic Overview, Natural Resources Uses Status Report.
Prepared by Vanasse Hangen Brustlin, Inc. For New Bedford Harbor Trustee Council. July
1996.
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