REVIEW OF THE REMEDIAL INVESTIGATION/FEASIBILITY STUDY
FOR THE
IRON HORSE PARK SITE
| NORTH BILLERICA, MASSACHUSETTS
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IRON HORSE PARK (IHP) SITE
NORTH BILLERICA, MASSACHUSETTS
This report was prepared in response to a request from the
Eastern Audit Division for assistance in their review of Region
1's management of the RI/FS program.
I. BACKGROUND
Remedial activities at the IHP site began in October 1985 and
are still underway. In consideration of the size and
complexity of the site, EPA is using a phased approach to
study and determine what cleanup action(s) may be needed.
Under this approach, the site is separated into a number of
discrete problem areas. Where possible, the areas are
studied and decisions on how to clean them up are made
independently. The cleanup work that is implemented under
this approach is called an Operable Unit (OU). A number of
OUs taken together form the complete site cleanup. The
phased approach was selected pursuant to the agency policy
established in June 1986 and documented in the "Guidance
Document for Cleanup of Surface Impoundment Sites" for
limited RIs and the complementary guidance for Operable Unit-
Feasibility Study delineated in "Cleanup of Surface Tank and
Drum Sites"(EPA 1985).
II. OBJECTIVE OF REVIEW
The objective of our review was 1) to determine if the
project cost increases during the RI/FS phase are
attributable to EPA's decision to expand the work plan
activities for the RI/FS, and 2) to determine if the
contractor used due professional care in preparing the Final
Work Plan in 1985 and its amendments which resulted in the
increase from $610,837 (original budget) to $1,326,000 (in
1987).
III. SCOPE OF REVIEW
In conducting this review, we examined selected project
files, discussed the program directives with the EPA project
officer and evaluated the various activities performed by
Camp Dresser & McKee, Inc.(COM), EPA's contractor, including
some of the project deliverables.
IV. PROGRAM OVERVIEW
Prior to initiation of remedial activities, once a site of an
uncontrolled release of hazardous substance is identified a
preliminary assessment (PA) is conducted by EPA or the State.
The PA involves review of any available information and
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documents on the site to determine if further action is
required. If a potential problem does exist, EPA or the
State conducts a site inspection (SI). Typically, the SI
involves collecting information about the site, e.g., types
of soil on site, streams or rivers on or near the site,
number of people in the area, weather conditions, and other
pertinent information. Samples of wastes, soil, well water,
river water, and air are sometimes collected to determine
what hazardous substances are on the site. Samples are also
taken nearby to determine if the substances have traveled or
migrated away from the site. These measures are referred to
as pre-remedial activities.
The remedial action response at a- site begins with the
remedial investigation (RI) and feasibility study (FS). The
RI is designed to produce information needed to identify,
select, and evaluate remedial action alternatives in the FS
based on technological, public health, institutional, cost
and environmental factors. The ultimate goal is the selection
of a "cost-effective" remedial alternative which mitigates
threats to, and provides protection of, public health,
welfare, and the environment, consistent with the National
Contingency Plan (NCP). Typically the RI/FS addresses data
collection and site characterization from the perspective of
contaminant migration pathways. Once pathways are
established and human and environmental receptors are
identified, further data collection efforts are directed
toward evaluating the potential impact upon receptors and in
evaluating potential remedial technologies and alternatives.
V. SITE DESCRIPTION
The Iron Horse Park site occupies an area of approximately
1300 acres in North Billerica, Massachusetts near the
Tewksbury town line 20 miles northwest of Boston. It
consists of several different facilities including industries
and landfills, both active and inactive, as listed below:
Johns-Manville Products Corporation
Johns-Manville Asbestos Landfill (inactive)
General Latex and Chemical Corporation
Shaffer Landfill (inactive)
Reclamation Services, Inc. Landfill (inactive)
Boston & Maine Corporation (B&M)
Massachusetts Bay Transportation Authority (MBTA)
These facilities, except for the Shaffer Landfill, are
included within an area bordered by the B&M Railroad tracks
to the north, High Street to the west, Salem Road to the
south, and Gray Street to the east. A site map (Figure 1-1)
is attached.
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With the exception of General Latex and Chemical Corporation,
most of the existing facilities currently discharge domestic
wastewater and drainage system waters into the unlined sewage
lagoon operated by the B&M Corp. These discharges into the
lagoon were to have been terminated by the end of 1988. The
remaining facilities on the IHP site are either inactive or *
assumed to be within existing discharge permits and continue
daily operations. The site has a long history of activities
that have resulted in contamination of soils, ground water,
surface water and air. Wastes disposed at the site included
asbestos, PCBs, organic solvents, waste oils, and a host of
organic and inorganic chemicals. Now much of the hazardous
waste is disposed of offsite at RCRA permitted facilities.
Significant features of the site and the surrounding area
include the following:
* The site is surrounded by densely populated residential
areas of Billerica and Tewksbury with an estimated total
of 18,256 persons living within a one mile radius and a
total of 61,000 people within a 3 mile radius.
* Most of the IHP site is classified as floodplain. It is
situated within two major drainage basins, the Shawsheen
River basin to the east and the Concord River basin to
the west. There is a potentially critical wetland
habitat area (along Pond Street) within close proximity
to the site.
* The three landfills on site are of particular interest
due to their proximity and/or contact with significant
natural resource/wetlands areas. Shaffer L/F, for
example, is surrounded by potential surface water
migration pathways that may act as receptors for
contamination from the landfill.
* The area topography is characterized by broad, poorly
drained lowlands and rounded hills and the immediate area
is relatively level. The area receives a mean annual
precipitation of approximately 43", which is distributed
evenly throughout the year.
* The site is generally underlain by Pleistocene stratified
glacial deposits which comprise an aquifer with an
average thickness of about 20 feet. The underlying
bedrock is reported to range in depth over the site from
0 to approximately 80 feet and is of variable texture.
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* The site is located in an area with a high water table,
where ground water could be encountered at shallow depths
from 1.4 to 6 feet below ground surface. The ground water
generally flows toward the east and north.
VI. FINDINGS
A. WORK PLAN AND AMENDMENTS
The Work Plan for conducting an RI/FS at the IHP site was
submitted in August 1985. The Final 1985 Work Plan (FWP)
identified specific technical tasks needed to determine the
nature and extent of both onsite and offsite contamination.
The plan proposed that the RI be conducted in two phases (1A
and IB) to allow flexibility in the investigation based on
the results of initial data collection. Phase IB started
upon completion of Phase 1A in order to provide supplemental
information where data gaps were found. Eventually, the
results of the Phase 1A and IB RI work were to lead to
preparation of an FS Report for remediation of the IHP site
problem areas. This Work Plan was amended several times for
different purposes, as follows:
- Amendment No. 1, initiated in December 1985, to allow
shifting of funds from Feasibility Study tasks in the
approved FWP to the well drilling program. As indicated
in the submittal from CDM, all the bids received for
drilling, sampling and well installation were
substantially higher than the amount originally budgeted
for the work. Funding for the FS phase was to be
restored at a later date by a Work Assignment amendment
prior to initiation of the FS in 1986.
- Amendment No. 2, initiated in May 1986, to address
expansion of existing tasks 1, 2, 3 and 4 and revisions
of tasks 5 and 6 in the 1985 FWP. CDM indicated that
additional field and office tasks were needed in order to
collect and analyze additional data and for management
and coordination requirements. Additionally, revision of
office tasks 7, 8 and 9 was necessary to complete the
Phase 1A field program. This amendment required
additional hours and funds, and EPA approved it in May
1986. The amendment to the work assignment was not
available for review.
- Amendment No. 3, initiated in March 1987, to incorporate
the "phased operable unit" approach to selecting a remedy
for the IHP site. The Sewage Lagoons area was selected
to be OU No. 1, and the Shaffer Landfill was proposed as
OU No. 2 to be addressed in future amendments. This
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amendment served as the Work Plan for the RI/FS for the
lagoons (i.e., IHP OU-1). The lagoons, consisting of two
active infiltration ponds and one overflow pond, have
received industrial/hazardous wastes in addition to
sewage during 60 years of operation. They were
identified during the preremedial activities to be a
potential 'source area1 of contamination.
- Amendment No. 4, initiated in May 1987, to increase the
subpool funds for the site survey subcontract. This task
was budgeted at $25K in the 1985 Work Plan. However, the
scope of the survey work was considerably revised
resulting in doubling the area to be surveyed and hence
increasing the estimated cost for the survey work by
$59K. This cost increase plus contractor's fee was
delineated on Form 60 attached to the amendment letter.
- Amendment No. 5, initiated in June 1987, was directed
toward the RI/FS efforts related to the Shaffer Landfill,
designated as Operable Unit no. 2 (OU-2). This amendment
included an allowance for final Work Assignment closeout
costs which applied to the overall IHP site.
B. SCOPE OF RI PHASE 1A & PHASE IB
Phase 1A of the RI was conducted by COM from October 1985
through November 1986 and a report was issued in July 1987.
This phase covered a broad study of the site and helped pin-
point potential problem areas. The purpose of this effort
was to collect the data needed to characterize the site in
terms of the nature of contamination, to assess the
potential risk to public health and environment posed by
these contaminants, and finally to develop and evaluate
remedial alternatives for the site. As a result of this
work, EPA concluded that the wastewater lagoons and the area
surrounding them should be studied further. In March 1987,
EPA amended the 1985 FWP to do this work.
Phase IB of the RI was completed and a report was issued in
January 1988. It covered the Boston & Maine Wastewater
Lagoons and fifteen (15) acres of land surrounding the
lagoons. The lagoons received domestic and industrial
wastewater from 5 manufacturing facilities in the IHP
industrial complex. In addition to the two active lagoons,
there is an overflow lagoon that is usually dry and receives
wastewater only when there is heavy rainfall.
The FS was completed and a report was issued in May 1988,
based on the results of the RI. The cleanup alternatives
for the lagoon area were limited to addressing the sources
of contamination (i.e., sediments, soils and sludge).
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Cleanup alternatives for the ground water contamination were
to be evaluated at a later date, as part of a site-wide
ground water remedy.
C. PHASED APPROACH APPLICATION
In March 1987, the August 1985 work plan was amended to
encompass a "phased operable unit" approach for selecting a
remedy for the entire IHP site. This approach, as pointed
out in the July 1987 report, was taken "...to remediate the
site more effectively by establishing priorities for
potential source areas and then conducting a separate but
overlapping RI/FS on each designated source area or
operable unit1, rather than attempting to remediate all
source areas simultaneously."
In other words, the Phase IB work for the overall site RI
will continue during the implementation of the "phased
operable unit" approach, as some kinds of contamination
problems do not fit this approach.
VII. CONCLUSIONS
l. Carrying out site remediation under the phased operable
unit approach is a viable alternative sanctioned by the
NCP and statutory mandates. The benefit of this approach
is that priorities for dealing with complex contamination
problems can be identified. The remediation of specific
and perhaps more critical portions of a site can be
addressed through the focused, limited RI/FS. The
complexity of the IHP site is such that use of the phased
operable unit approach is appropriate to facilitate
thorough site investigation and expedited remediation.
Separating the investigation into phases allows for
additional data to be collected and evaluated
sequentially or concurrently which in turn results in
refinement or redefinition of data collection needs.
2. The 1985 Final Work Plan developed by COM was based on
review of existing information, consistent with the
agency guidance and under the direction of the EPA
project manager. The five amendments to this plan were
directed toward revising the scope and objectives of the
site remedial activities. Each revision, however,
resulted in an increase in the contractual and/or
subcontracting pool level of effort. Although some of
the additional or revised tasks may have overlapped, this
is sometimes unavoidable at a site of the complexity of
IHP.
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Cost overruns for remedial activities at Superfund sites
are not uncommon given the magnitude of uncertainties
involved in RI investigations and the lack of available
information. These uncertainties and problems in
successfully completing RI activities, combined with the
unique contract approach used by the Superfund program,
will often increase the cost of the project work. The
most costly activity of field investigations is generally
the collection and analysis of environmental samples
which must follow the site specific sampling objectives,
collection methods, chain of custody procedures, and
sample shipment methods. Considering the magnitude of
environmental sampling and analysis efforts at the IHP
site, the cost of $1.3 million falls within the normal
range.
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SCALE IN FEET
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IRON HORSE PARK
BILLERICA, MA
CAMP DRESSER & McKEE
FIGURE 1-1
SITE LOCATION MAP
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