TO
Review of the
Remedial Investigation/Feasibility Study
for the
Baird & McGuire Company>,Site
Holbrook, Massachusetts
iy
Prepared By
Engineering and Science Unit
Technical Assistance Staff
Office of the Inspector General
September 1990*
Report No. E1SGG7-14-0003-04QOQ40
* This final report was completed in January 1990. Although the
issuance date is September 1990, the report does not reflect any
changes at the site that may have occured since report
completion.
*
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I. Purpose
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.
II. Scope and Objectives
Our objectives were to: i) review the EPA-approved Work Plan for
accuracy and completeness of the remedial investigation/feasi-
bility study; 2) determine if the work plan omitted essential
data requirements which delayed the completion of the remedial
investigation; 3) determine if professional care was used by both
EPA and NUS in the Work Plan preparation, review and approval
process; and 4) attempt to determine if the costs and hours
proposed by NUS and their subcontractors were reasonable for the
tasks added after locating the dioxin.
In September 1987 the Eastern Audit Division (EAD) requested
technical assistance from the Engineering and Science Unit (ESU),
Office of Audit, Office of the Inspector General. Initially,
staff members from the ESU went to the Eastern Audit Division
located in Boston to meet with two auditors to further develop
this project. Several documents regarding this site were
obtained for the ESU by the Eastern Audit Division auditors, such
as the Remedial Investigation and Record of Decision. An ESU
staff member made an on-site visit in December 1988 accompanied
by the Remedial Project Manager for this project and documented
this trip with photographs. He also spoke with the On-Scene
Coordinator who was responsible for all emergency work done at
the site. '
III. Background and Site Description
The Baird & McGuire site is located in northwest Holbrook,
Massachusetts, Norfolk County at 775 South Street. The Baird &
McGuire company property itself is slightly less than 8 acres in
size and consisted of a laboratory building, a mixing building,
a storage building, an office and a tank farm area. The Baird &
McGuire operations, especially their waste disposal practices,
extended beyond their 8 acres and the total size of the site, as
defined in the Record of Decision, is approximately 20 acres.
The area covered during the Remedial Investigation and the
Remedial Investigation Addendum was approximately 60 acres in
size. (See attached maps at the end of this report.)
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The site is located on a hillside which steeply slopes to the
north and east. The elevations range from 170 feet mean sea
level datum (MSL) in the southwestern corner of the site to 130
feet MSL in the central and northeast corner. The topography
slopes to 119 feet MSL at the Cochato River which is located in a
northerly direction 500 feet east of the site. Wooded wetlands
occupy the lower elevations of this site and extend to the north
and to a neighboring parcel of land referred to as the "New Can
Property". (A company called New Can owns this parcel of land.
The New Can property also extends to land on the other side of
the Cochato River). There is a 200 foot wide clearing in the
wooded wetland area going toward the River which has been
modified by excavations and fillings and is now clay cappped.
This area had been reported as ak former borrow area. Parts of-
this site are located both within and very near to the 100 year
flood plain of the Cochato River.
Three municipal wells for the Towns of Randolph and Holbrook are
located 1,000 to 1,500 feet south of the site. These wells were
used intermittently between 1958 and 1980. The well closest to
the Baird & McGuire site, Well No. 3, was closed down due to
phenol contamination in 1958. The towns of Randolph and Holbrook
hired Northeast Consultants of Farmington, Massachusetts to
perform a study which concluded that the Baird & McGuire site was
the most probable source of this contamination. Presently, all
three wells are inoperative due to organic contamination.
Land use to the north and further south of the site along South
Street is industrial/commercial. The types of industry, busi-
nesses, or processes in this area now or formerly operated are:
metal engraving, metal finishing, paint production, machine shop
work, metal fabrication, fuel storage for distribution, auto
repair, chemical storage, roofing, leather cutting and grading,
and assorted distribution services.
The area west of South Street and the Baird & McGuire site is
primarily residential. The Baird & McGuire site is located in
Holbrook but is a few hundred feet from the Holbrook/Randolph
town line. Holbrook has a population of 11,140 (1980 Census) and
Randolph has a population of 28,218. The group of citizens con-
sidered most likely to enter the site are children aged 5 to 18
years of age who used this area as a "shortcut" to the
neighborhood bowling alley prior to the construction of the
security fence. These children make up approximately 10 percent
of the population within a 1000 to 2000 foot area near the site.
The Baird & McGuire Company site was listed on the National
Priorities List in December 1982 and is ranked 14th on the
National Priorities List. A Remedial Investigation report,
funded by EPA, was prepared by GHR Engineering Associates, Inc.
for the NUS Corporation of Pittsburgh, Pennsylvania and was
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completed on May 22, 1985. A Final Addendum Report was prepared
by the sane company and was completed on June 27, 1986 as an
addendum to the May 22, 1985 Remedial Investigation. According
to the Eastern Audit Division there is an NUS memo dated January
1984 in which EPA advises NUS to follow-up on evidence that the
Baird & McGuire Company may have handled dioxin in its
operations. The NUS Work Plan which was approved by EPA in April
1984 did not provide for sampling and analysis of dioxin. Dioxin
was later found in a sampling effort in July 1985. A Feasibility
Study was completed on July 18, 1986 and a Record of Decision was
signed on September 30, 1986.
IV. Site History
The site has been owned by the Baird & McGuire Company since 1912
and was operated as a chemical company from 1912 until 1983 when
site operations ceased. Around 1970 the site operations were
changed from manufacturing to mixing, packaging, storing, and
distributing various products, including herbicides, pesticides,
disinfectants, soaps, floor waxes and solvents. Many of the
various chemicals, petroleum products and raw materials were
stored in a "tank farm" consisting of 32 above ground storage.
tanks on site and piped to the laboratory or mixing buildings as
needed. Some materials, such as Dinitro-5-B Herbicide as
reported in the Preliminary Site Assessment, were stored in drums
on-site. The site also includes an area between the buildings
and the Cochato River that was used in the past for waste
disposal. This area was the former borrow area.
EPA became involved with' this site in the period prior to 1977
because of several violations of the Federal Insecticide,
Fungicide and Rodenticide,Act (FIFRA). EPA discovered that the
company had violated FIFRA by mislabeling, improperly
registering, and adulterating their products.
Waste disposal methods at the site included direct discharge to
soils, a nearby unnamed brook and nearby wooded wetlands, and a
former borrow pit (now capped). Underground disposal systems
were also used.
On May 2, 1983 the Board of Selectmen of Holbrook revoked the
company's permit to store chemicals at the site and ordered it to
dismantle its existing storage facilities. This action resulted
in the company's ceasing their operations.
The area known as the former borrow area was capped with clay by
EPA in 1984 as part of a removal action started in 1983 in
response to overflowing waste lagoons containing a creosote-like
waste near the Cochato River. The emergency removal action
included removal of 1,000 cubic yards of contaminated soil,
removal of lab packs from the site, construction of a partial
groundwater interception/ recirculation system to limit
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contamination going into the river, and fencing, capping and
regrading of the contaminated waste disposal area.
In 1985, the EPA planned an Initial Remedial Measure (IRM) for
the destruction of the site buildings, and .demolition and removal
of the tank farm. This IRM included additional temporary capping
for hot spots of contamination (this extends the cap installed
during the removal to include areas to the west where the lab and
mixing buildings once stood and to include the entire former tank
farm area), inspection and removal of underground tanks, and
relocation of a water main line that carries drinking water to
the South Street/Brookville section of Holbrook which passed
under and through the most highly contaminated area of the site.
This water main has been moved by the EPA to prevent contaminants
from entering the line during periods of low pressure or pressure
loss.
The Remedial Investigation for the site was completed in May
1985 and an addendum Remedial Investigation Phase II was
completed in June 1986. It was during the sampling in the
Remedial Investigation Phase II in July of 1985 that dioxin was
discovered at the site. The dioxin contamination, ranging from
low to moderately high concentrations, appears to be in areas of
random distribution primarily in the central and northern regions
of the site. The areas to the east and southeast of the site
showed low levels of dioxin. The Record of Decision stated that
EPA performed more extensive sampling and installed 5,700 feet of
fencing as a second removal response after the discovery of the
dioxin on site. A fence surrounds about 34 acres of land
following the dioxin discovery.
V. Geoloqv/Hvdrology Setting
This area is located in the valley of the Cochato River and is
primarily glacial in nature; therefore, the site geology is
varied. Most of the stratified material at the site consists of
ice-contact deposits, including kames, kame fields, and kame
plains. Part of the area is a part of a kame plain, which is a
flat-topped hill of sand and gravel and may include glacial lake
sediments. The site is underlain primarily by sand and gravel
deposits with frequent boulder occurrence. Due to the soil's
coarse, well-sorted nature, this material is relatively permeable
and constitutes the main aquifer in this area.
The regional groundwater flow is towards the Cochato River which
is primarily a discharging or "gaining" river. In the immediate
vicinity of the Baird & McGuire site there are heterogeneities
and anisotropic conditions which complicate the groundwater flow
regimes in this area.
The bedrock slopes from the site proper toward a bowl-shaped
depression southeast of the facility and the depth to bedrock
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ranges from 5 to 60 feet in the vicinity of the Baird & McGuire
Company property. The bedrock underlying the site is a fine to
medium grained, massive, dark greenish-gray metaquartz diorite
and metadiorite. It is thought to be randomly fractured and is
water bearing with a hydraulic connection to the overburden
aquifer. In the Remedial Investigation it is stated that the
bedrock is capable of transmitting 0.2 gpm of groundwater at an
estimated rate of 0.3 to 3 feet per day through the contaminated
area of the site. Groundwater flow across the site in the
overburden has been estimated to be at 12 gpm during the Remedial
Investigation. The groundwater flowing through the Baird &
McGuire site originates as areal recharge from precipitation
infiltrating between the site and the upgradient edge of the
drainage basin, approximately 1,000 feet west of South Street.
Precipitation is fairly evenly distributed throughout the year.
When the South Street municipal well field was in use there was a
pumping-induced groundwater flow toward these municipal wells.
There are two small brooks that drain through the study area.
One of the brooks flows from west to east across the northern
portion of the site and is referred to as the unnamed brook which
is a "losing" or recharging stream. The other brook flows from
west to east in wetlands south of South street Municipal Well No.
1 and is referred to as Tributary C-2. Both of these brooks
drain into the Cochato River which flows northward past the
Richardi Reservoir approximately 2.5 miles from the site. The
Richardi Reservoir serves as a local supplementary water supply
for the towns of Holbrook, Randolph, and Braintree. Surface
water intakes have been constructed to deliver water from the
Cochato River to the reservoir; however, these intakes have been
closed since February 1983. Wetlands situated along the western
bank of the Cochato River, to the east of the site, receive site
drainage which empties into the Cochato River. This wetlands
area is one of many, but typically smaller, wetlands found along
the entire length of the river.
There are no known wells used for potable water downgradient of
the site. One private well used for potable water supplies is
located southeast and upgradient of the Baird & McGuire site on
English Road.
VI. Enforcement
Baird & McGuire, Inc. owned and operated the Baird & McGuire
facility. Baird Realty Company, Inc., was a record owner of part
of the site. Cameron Baird was the president, treasurer, and
chief executive of Baird & McGuire, Inc. while Gordon M. Baird
(Cameron's brother) was the chairman of the board of Baird &
McGuire, Inc. In October 1983 the Department of Justice on
behalf of the Administrator of EPA, filed a cost recovery action
under Sections 104(a) and (b) and 107(a) of CERCLA. The
complaint sought reimbursement of costs from Baird & McGuire,
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Inc., Baird Realty Company, Inc. (also known as Ann E. Realty
Trust, Inc.), Cameron M. Baird and Gordon M. Baird. The
government then placed a lien on the property and began
negotiations with these defendants for a Consent Decree in which
the defendants will agree to pay a substantial sum to the EPA for
past costs. The Consent Decree was signed during September 1987.
VII. Findings and Discussion
A. Past documentation regarding contaminants
In a memorandum dated February 10, 1982, Greenwood Hartley
stated that "the company mixes and packages pesticides,
herbicides, emulsifiers, floor waxes and strippers, disinfect-
ants, and other associated products for distribution."
In a February 19, 1982 memorandum, Robert Cleary of the
Massachusetts Department of Environmental Quality Engineering
(DEQE), stated that the Baird & McGuire Company had formerly
distributed 2,4,5-T which is a herbicide, and 12 50-pound bags of
49-162 pentachlorophenol (86% pentachlorophenol, 10% other
chlorophenols) were noted on site along with some drums of
santophen (72% obenzyl-p-clorophenol) a germicide used in
disinfectants. Housekeeping in this memorandum was noted as
being "sloppy".
In an August 11, 1982 progress letter report to the Board of
Selectmen, Town of Holbrook, WEB Engineering Associates, Inc.,
reported that there was 100 ug/1 of pentachlorophenol that was
present in water after skimming. This water was probably taken
from the leaching pit located east of the site that had creosote
skimmed from it prior to being pumped to an aeration pond and
then allowed to seep back into the ground for recirculation.
In a letter report of August 16, 1982, Richard W. Keller, P.E. of
E.J. Flynn Engineers, Inc., stated that there was "a concern
regarding the present inadequacy of confinement measures at the
loading/unloading areas" if a spill should happen to occur.
The Preliminary Site Assessment of April 21, 1983, stated that 86
ppb pentachlorophenol was found in a surface water sample from a
green puddle above an underground storage tank along with several
volatile organics and some pesticides, and 66 ppb of
pentachlorophenol was found in the groundwater from well TBW2.
In the Preliminary Site Assessment it was noted that there was a
12-inch diameter yard drainage pipe which extended 20 feet
overland where it disconnected and discharged waste right onto
the soil. However, the Preliminary Site Assessment stated that no
soil samples had been taken at or near the Baird & McGuire site.
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In the Remedial Action Master Plan (RAMP) of May 1983,
pentachloro-phenol along with other chlorinated phenols are cited
as both surface water and groundwater contaminants. The RAMP
also suggested that an initial screen for radioactivity,
particularly in the drums, tanks, and spill areas, be done. The
RAMP further states that "although radioactive wastes are not
expected to be present, it is prudent policy to check to be
certain." It is not obvious from any of the ensuing studies that
this was ever done.
B. National Dioxin Strategy goals
On December 15, 1983 EPA announced the National Dioxin Strategy
which provided a framework for the Agency to: 1) study the
extent of dioxin contamination and the associated risks to humans
and the environment; 2) implement or compel necessary clean-up
actions at contaminated sites; and 3) further evaluate regulatory
alternatives to prevent future contamination, as well as disposal
alternatives to alleviate current problems. The Dioxin Strategy
stated that:
"a number of dioxins, including 2,3,7,8-tetrachloro-
dibenzo-p-dioxin (2,3,7,8-TCDD) are formed as inadvertent
byproducts during the manufacture of certain organic
chemicals, particularly chlorinated phenols. 2,3,7,8-TCDD
is known to be a contaminant of 2,4,5-trichlorophenol
(2,4,5-TCP) when 2,4,5-TCP is made from tetrachlorobenzene.
2,4,5-TCP is used in the manufacture of various phenoxy
'herbicides including 2,4,5-trichlorophenoxyacetic acid
<2,4,5-T).«
As can be seen from the preceding paragraphs, both 2,4,5-T and
chlorinated phenols were already found on site. Therefore,
suspicion of dioxin contamination would appear to be very
probable given this set of circumstances.
C. Site activities and reports
In 1982, the Baird & McGuire Company, in response to the DEQE and
the town of Holbrook, constructed a pump system behind and to the
east of the facility to collect creosote and prevent it from
reaching the Cochato River. During March 1983, due to heavy
rains, this pump system and its associated lagoon or collection
basin had overloaded and a release of creosote or creosote-like
wastes along with contaminated groundwater were entering the
Cochato River. The EPA's removal response program was called to
the site to initiate a remedy. The removal response lasted from
March 1983 to July 1984. The removal objective was achieved by
removing gross buried contamination to a regulated disposal
facility and by installing a groundwater interceptor system,
including a clay cap, to keep the contamination on site.
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The Baird & McGuire On-Scene Coordinator's Report of March
1983 - July 1984, stated that there were no dioxin or PCBs
found. However, it appears that primarily water samples were
sent for laboratory analysis and the only soils that were sent
for laboratory analysis were those soils obtained during the
installation of the monitoring wells. No herbicides were
analyzed in either the water or soil samples. The soils had been
analyzed for base-neutral compounds and this did not appear to
have any 2,3,7,8-TCDD; however, the depth from which these soil
borings were obtained was not clearly evident from the report
"Design Studies for Emergency Response Action - December, 1983".
In the Dioxin Strategy it is stated that containment technologies
are based on the dioxin-soil binding characteristic and focus
upon the restriction of soil particle movement, and that in its
soil-matrix, 2,3,7,8-TCDD appears to be water insoluble, as well
as nonvolatile. Therefore, 2,3,7,8-TCDD may be anticipated at
shallow depths initially.
In the Work Plan of March 4, 1984 in the proposed monitoring well
locations it was not clear where the monitoring well for
background groundwater quality would be located. In the Soil
Sample Analysis section there were no analyses listed for
herbicides or dioxins. Other areas of the Work Plan in which
there were concerns are: 1) Task 22: Analyze and Evaluate
Remedial Investigation Data, should have been done earlier in the
project to aid in the elimination of data gaps and not be
submitted following the completion of all RI tasks as stated in
the Work Plan; 2) Task 26: Prepare Work Plan for Laboratory and
Field Treatability Studies, states that this work plan for
laboratory and field treatability studies would be prepared, but
it does hot appear that this was ever implemented or done. This
Work Plan was planned as a single phase work effort.
In the Remedial Investigation report of May 22, 1985, the
objectives are stated that the study will delineate the nature
and extent of soil, surface water and groundwater contamination
and will define the area of sediment contamination in the Cochato
River and the unnamed brook. These objectives were not met by
the single phased Remedial Investigation. The vertical depth of
the soil contamination was not defined and the recommendations
listed at the end of this phase of the Remedial Investigation
state this. Also, the complete areal and vertical areas of
contamination were not defined in the low lying area north of the
site and next to the Cochato River. No herbicide or dioxin
samples were taken during the Remedial Investigation and
therefore the types of contaminants on the site were not defined.
Also, there were no long-term particulate air borne studies
done. Only in-situ air monitoring utilizing a portable organic
vapor analyzer (HNu) was done during this phase of the Remedial
Investigation. It states in the Remedial Investigation that
"downstream deposition of pesticide-laden particulates will occur
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in slack water areas (e.g., ponded water) and in an area of low
stream velocity". In high stream velocity or during flooding
events deposition of fine pesticide-bearing particles is
prevented. Due to these fluctuations in velocity of the river,
more extensive field sampling of the sediments would have to be
done to determine downstream sediment contamination.
There were no fish or small mammal studies performed during this
phase of the Remedial Investigation to determine what, if any,
effects the site was having on the local fauna. Very little
mention was made regarding the impact of the contaminants on the
wetland areas, despite the fact that approximately 44 percent of
the contaminated soil areas at the site are classified as
wetlands. It is not apparent from this first Remedial
Investigation if the Department of Interior's U.S. Fish and
Wildlife Service was contacted to assist in or to determine any
possible natural resource damage impacts from this site as stated
in Sections 101 and 107 of the Comprehensive Environmental
Response, Compensation, and Liability Act of 1980 (CERCLA).
Many of the data gaps left after the first Remedial Investigation
were filled in and re-evaluated during the Addendum Remedial
Investigation Phase II - June 27, 1986. The wetlands
investigation and an assessment of the wetlands was done during
this effort and a fish study was done. The presence of dioxin in
the northern wetland was found from the analyses of the soil. An
air study for particulates and volatiles was done at this time.
Fortunately, the air study showed no impacts to the air from
contaminants at the site at the time of the study. Ten
additional monitoring wells were installed and additional boring
and groundwater samples were obtained. Analysis did include an
analysis for herbicides. The presence of 2,4,5-T was detected at
this time. Following this Addendum Remedial Investigation the
extent of downstream sediment contamination was still not fully
defined and is so stated in the conclusions to the investigation.
The complete areal extent of groundwater contamination is not
fully defined in the area of the wetland north of the tank farm
between the Accurate Metal Finishing well and the site.
The Assessment Report of Initial Remedial Alternatives of June
24, 1986 discussed the demolition of the lab, mixing building and
tank farm including securing remaining site structures, re-
routing of the 12-inch water main that passes under the
contaminated area of the site, inspection and removal (if
necessary) of underground tanks, and placing a temporary cap over
"hot" spot areas. As part of the planning documents for these
activities, a Health and Risk Assessment for Presence of
Pesticides on Building Walls and Floors-May 1985 was done from
samples taken by the NUS Field Investigation Team in July 1984.
This assessment was done solely on the results of interior wipe
samples collected in three onsite buildings and a boiler house.
Later, an Addendum to the Health and Risk Assessment for Presence
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of Pesticides on Building Walls and Floors had to be done to
address the presence of toxic substances that may be present in
underground piping, in tanks or nixing vessels inside and outside
the sampled buildings, or in other areas of possible accumulation
which were not accessible to wipe sampling. This entailed
another site reconnaissance and sampling trip by the contractor
on September 20, 1984. In the Feasibility Study and in the
Record of Decision there is minimal discussion as to cleanup
levels of contamination. The Feasibility Study states that the
alternatives that have been developed correspond to the 0.0001 to
0.000001 risk levels as recommended in the "Guidance on
Feasibility Studies Under CERCLA (U.S. EPA, June, 1985)". The
Record of Decision does clearly state what levels of contaminants
will be left on site after the remedial action is implemented.
Another area of concern is the impact these low level
contaminants will have on the wetland area and on the river
sediments with time. The Cochato River is primarily a
discharging river and the river sediments near the site seem to
presently be acting as a filter for the groundwater prior to the
groundwater entering the river. There is a concern that
eventually the sediments would become saturated with contaminants
and breakthrough of the contaminants flowing directly into the
river would occur.
On December 16, 1987 a plan entitled "Groundwater Treatability
Test Plan" prepared by Metcalf & Eddy, Inc. was submitted to the
EPA as the design for the one of the sections of the total
selected remedy in the ROD. The removal action which ended in
July 1984 had primarily been involved with this groundwater pump
system and field improvements to this system to prevent further
releases to the Cochato river.
VIII. Conclusions
A. Planning of work
The Remedial Investigation, as first conducted, did not meet its
own objectives and did not appear to have a complete compre-
hensive review of all documents relating to the site to insure
that a thorough and complete work plan was developed. Therefore,
additional work was needed for these "unresolved" issues. This
caused the entire project to be longer than would have been
necessary had the work plan been prepared more thoroughly.
The lack of a thorough work plan is again reflected in the Health
and Risk Assessment for Presence of Pesticides on Building Walls
and Floors causing another time delay and increase in cost.
This is because the contractor had to make a second site and
sampling investigation to assess additional contaminants within
and near the buildings. This could have been accomplished during
the initial assessment.
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B. Wetland issue
The wetland issue was not completely examined until the addendum
Remedial Investigation was done. The additional work also
increased the costs of the project.
In the Record of Decision and the Feasibility Study the impact to
the environment, especially of the wetlands, of low levels of
remaining contaminants is not fully discussed and evaluated.
C. Dioxin contamination finding
The finding of dioxin on site was unsettling because of the
health and safety problems that arose extending the project's
time line. The EPA's decision to limit soil analysis during the
First Remedial Investigation may have also led to a lack of
complete knowledge of contaminant distribution during the study.
The possibility of finding herbicides with dioxin contamination
on site should have been determined from the early documentation
on the case as shown in the earlier discussion on past
documentation regarding contaminants.
In a letter dated July 16, 1985 from Mr. Donald Senovich of NUS
Corporation to Mr. Bob Shatten of the U.S. EPA, Region I, it was
stated that "the Remedial Investigation and Feasibility Study of
the Baird and McGuire Site has been adversely impacted by the
recent determination that dioxin is present on the site" and the
sampling during the week of July 8, 1985 had to be cancelled
until the health & safety requirements could be modified in
connection with the on site activities. The letter continues to
state "because of the uncertainties resulting from the discovery
of dioxin on site, the Remedial Investigation/Feasibility Study
work is essentially on hold".
D. Coordination between Removal team and Remedial team
In the transition period from moving the project from a removal
action to a remedial mode of action, there appears to have been
good coordination between the removal program and the remedial
program. This type of coordination should be commended and
recognized as a positive force in effecting a smooth transition
of the project from a removal action to a remedial action.
E. Pilot Studies
A field pilot study was being planned in December 1987 for the
treatment of the pumped contaminated groundwater found in the New
Can area. The document reviewed was the "Groundwater Treat-
ability Test Plan", December 1987. It was noted that a bench
test was done for treatment of the groundwater in the Feasibility
Study dated July 1986. According to the "Guidance on Remedial
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Investigations and Feasibility Studies Under CERCLA" dated June
1985, bench/pilot studies should be done, if at all possible,
during the remedial investigation process. Since the removal
action was completed in July 1984 according to the On-Scene
Coordinator's report, and the removal action centered around this
area of pumping and treating contaminated groundwater, both the
bench test and the field pilot study could have been done earlier
in the process. However, any budgetary constraints being faced
by the region which would delay these starts were not part of
this review.
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MOLBROOK SOUTH
WELL FIELD
BASE MAP ISA PORTION OFTHE U-3-Q-S. BLUE MILLS, MA QUAD RAN OLE (73 MINUTE SERIES, 1971,
PWOTORE VISED O79) CONTOUR INTERVAL 10'
FIGURE 1-1
LOCATION OF BAIRD a McGUIRE SITE
SCALE'l"» 2000'
PRIMUS
I CGPPGRA71QN
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