United States
Environmen1B1 Protection
Agency .
Office of
Emergency and
Remedial Response
EPAIROD/R01-83/001
December 1983
cop" J
I fB85-Z13S93
\EPA
. Superfund
R-ecord of Decision:
Charles George Site, MA
Hazardous Waste. CoIectton
information Resource Center
US EPAAeg.lGn 3
PhfIadeJphIo# PA 19107
u . S. Environmental Protection Agency
Region III Hazardous Waste .'
Technicallnforrnation Center
84 1 Chestnut Street, 9th Floor
Philadelphia, PA 19107
. .'

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          TECHNICAL REPORT DATA       
       (Please read Instructions on the reverse bel ore completing)   
1. REPORT NO.       12.         3. RECIPIENT'S ACCESSION NO. 
EPA/ROD/ROl-83/00l                  
4. TITLE AND SUBTITLE              5. REPORT DATE   
SUPERFUND RECORD OF DECISION:          l?!?Q!R<   
Charles George Site, MA          6. PERFORMING ORGANIZATION CODE
7. AUTHORCS)                8. PERFORMING ORGANIZATION REPORT NO.
9. PERFORMING ORGANIZATION NAME AND ADDRESS       10. PROGRAM ELEMENT NO. 
                  11. CONTRACT/GRANT NO. 
12. SPONSORING AGENCY NAME AND ADDRESS         13. TYPE OF REPORT AND PERIOD COVERED
u. S. Environmental Protection Agency       1";",,,,1 ~I"IT"\   
401 "Mil Street, S. W.            14. SPONSORING AGE:NCY CODE 
Washington, D. C. 20460           800/00   
15. SUPPLEMENTARY NOTES> >                  
16. ABSTRACT                      
  The Charles George Land Reclamation Trust Landfill is a privately owned municip~
and industrial waste landfill, operating since 1967. The landfill accepted and dis-
posed of chemical waste between 1973 and 1975 under a hazardous waste disposal permit
from the Massachusetts DEQE. Leachate from the landfill has contaminated nearby
residential bedrock wells which were shutdown July 31, 1982 by order of the 
Massachusetts DEQE.  In April 1983, the Charles George Lartd Reclamation Trust filed
for the protection of the bankruptcy court. This is a National priorities List site.
  The selected remedial action is to extend an existing water supply system to
the Cannongate Condominium and local private well users whose wells have been found to
be contaminated with volatile organic chemicals from the Charles George site. An
RI/FS is being conducted to identify and evaluate remedial alternatives to mitigate
threats to public health, welfare and the environment. Determination of future
remedial actions will be made upon completion of this work.   
17.         KEY WORDS AND DOCUMENT ANALYSIS      
a.     DESCRIPTORS       b.IDENTIFIERS/OPEN ENDED TERMS C. COSATI Field/Group
Record of Decision                   
Site Name: Charles George Site, MA            
Contaminated media:  gw,                
Key Contaminants: volatile organics (MEK,          
acetone, toluene, benzene, MIBK, TCE)            
18. DISTRIBUTION STATEMENT         19. SECURITY CLASS (This Report) 21. NO. OF PAGES
               Nnnl"      1 1 
               20. SECURITY CLASS (This page) 22. PRICE 
               None       
EPA Form 2220-1 (Rn.4-77)

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17. KEY WORDS AND DOCUMENT ANALYSIS
(a) DESCRIPTORS. Select from the Thesaurus of Engineerir.l' and Sdentitk Terms the proper aulhori/.~'d krrns Ihat idenlify Ih~' majm
concept of the research and are sufficiently specific and precise to be used as index entries for cataluj:lnj:,

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"
. .~ . ...._.
Record of Decision
Remedial Action Selection
. -- .-..
r-~."" -: .'. "..,....~
~_u ...;,,; ',-'V'\.'
Site:
Charles George Land Reclamation Trust ~andfill
Tyngsboro, Massachusetts
"
Analysis Reviewed:

I have reviewed the following documents describing the analysis of
cost-effective remedial actions developed for the Charles George
Land Reclamation Trust Landf ill site:'
'-Focused Feasibility Study for Water Supply Alternatives,
: Cannongate Area, Tyngsboro, Massachusetts Part 1"NUS,
October 1983: P~rt 2, Fay, Spofford & Thorndike, Inc.,
Septembe.r 1983
~
-Staff summary and additional information submitted by the
public in response to sever~l public meetings.
Description of Selected Option:
-Extend an existing water supply system to the Cannongate
Condominium and local, private well users whose wel~s have
been found to be contaminated with ~olatile organic chemi-
cals from the Charles George site.
Declara'tions:
Consistent with the Comprehensive Environmental Response, Compen-
'sation, and Liability Act of 1980 (CERCLA) and the National Con-
.tingency Plan, I have determined that the provision of permanent
water supply via connection to a local municipal water supply
~ystem is cost-effective and that it effectively mitigates and
minimizes damage to, and provides adequate protection of public
health, welfare and the environment. I have also determined that
the action being taken is appropriate when balanced against the
need to use Trust Fund money at other sites.
A Reme~ial Investigation and Feasibility Study is being conducted.
to idehtify and evaluate remedial alternatives to mitigate threats
to public health, welfare and the environment at or near the site.
A cost effective determination for future remedial action(s) will
be made upon completion of this work.
~'-~
" \.. \...- ~ ~
L e M. Thomas, Assistant
Administrator
Office of Solid Waste and
Emergency Response

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'"
CHARLES GEORGE LAND RECLAMATION TRUST LANDFILL
REMEDIAL ACTION BRIEFING DOCUMENT.
o
The Charles George Land Reclamation Trust Landfill is a
privately owned municipal and industrial waste landfill,
operated by Mr. Charles George since 1967. The landfill
accepted and disposed of chemical waste between 1973 and.
1975 under a hazardous waste disposal permit from the
Massachusetts DEQE. Leachate from the landfill has
contaminated nearby residential bedrock wells which were
ordered to be shutdown by Massachusetts DEQE.by July Jl,
- 1982. In April 1983, the Charles George Land Reclamation
Tr~st filed for the protection of. the backruptcy court.
o
The site, is on the National Priorities List and was
placed on'the interim priority list of'llS priority
sites proposed for CERCLA funding in October 1981.
first.
waste
o
The Commonwealth of
assume the lead for
action at this Site
State Contract.
Massachusetts has requested that EPA
the permanent water supply remedial
and is willing ~o enter into a Superfund
o
In June 1983, NUS and Fay, Spofford, and Thorndike were
commissioned to carry out Part I and Part II respectively
of a Focused Feasibility Study for Water Supply Alternatives
for the Cannongate Area of Tyngsboro. Throughout the summer
of 1983, bi-weekly meetings were held with local water com-
~issioners and the public to discuss the various permanent
water supply options. In the fall of 1983, a series of p~blic
meetings were held to present the findings of the feasibility
study and to receive comments on the proposed remedial alter-
natives. The meetings were well attended and proceedings were
tape recorded for future consideration. Comments were also
submitted to the Agency in writing.
o
The Army Corps of Engineers' was issued Phase I design lAG to
allow for advance selection of the design A/E. The design
will commence immediately following the signature of the ROD
and will be completed about three months later. Construction
will commence as soon as weather allows.
o
In september 1983, emergency funds to a ceiling of 5750,000
were authorized for immediate removal activities at the site.
The activities include establishing an emergency drinking
water supply, covering exposed refuse and wastes at the land-
fill, and construction of a fence around the landfill.
o
In September 1983, incremental funding of 5650,000 was
authorized for a Remedial Investigation and Feasibility
Study (RI/FS) of the site.

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_a_.- - -
Charles
Remedial Implementation
Alternative Selection
George Land Feclamation Trust Landfill
Tyngsboro, Massachusetts
Site
. . Background
,
The Cannongate Condominiums' wells are located within 1000
feet of the Charles George Land Reclamation Trust Landfill.
In July 1982, the Massachusetts DEQE closed the condominiums'
wells ,as a result of increasing organic chemical contamination
~~~the landfill leachate: The contaminants found:in the
c~ndominiumst wells, several of which are potential carcino~ens,
include MEK, acetone, toluene, benzene, MIBK, TCE, and 1,1-1
dichloroethane.. 'Sampling and analysis has shown that the -
contaminants are increasing in magnitude and quantity. Neighboring
private wells are beginning to show the presence of contaminants
not seen a year ago. Sampling of private bedrock wells in the
vicinity of the condominiums carried out in July 1983 revealed
that three private wells contain trace amounts of volatile organics
and a ,fourth well has elevated levels of MEK.
-qpon closing the condominiums' wells, the Town of North
Cheimsford, MA agreed to sell water to the condominium complex.
T~~. State also constructed an emergency water supply pipeline to
th~ .condominium complex. The pipeline froze in December of
1982, and the residents of the condominium were left without a
water:supply. Water was trucked to the condominium, but the
water service was not dependable and residents of the complex
found water unavailable for days during the winter. Also, snow
plows struck and ruptured the pipeline during the winter. The
condominium residents expended 525,000 in pipeline repairs,
reconstruction, operation and maintenance. The line, which is
rusted and pitted and delivers poor quality water, was put back
in~o. ,ervice in Spring 1983. .
1'.. . ,.., ' .
';-, .;,:t'.
r .in:September 1983, EPA allocated 5750,000 for a temporary
water' supply to the Cannongate Condominium Complex and for
corrective actions at the landfill site. The construction work,
under: the immediate remov~l provisions of CERCLA, is expected to
take about three months, October through December, with operation
and maintenance continuing through March 1984. It will consist
of providing storage capacity for. two days' water supply, bulk
water trucked to Cannongate as necessary, and a freeze-resistant
pipe-withina-pipe system with d.irect connection to North Chelmsford.
The landfill will receive a temporary cover will also be fenced.

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_0'.
.-' A two-part focused feasibility study to evaluate alternative
'water supplies was conducted from July to October 1983. Part I
which evaluated treatment options and alternative sources was
prepared by NUS. Part II which evaluated existing municipal
systems was prepared by Fay, Spofford and Thorndike of Lexington,
Massachuse~ts. The studies were distribu.ed to the Water
Commissioner and Selectmen of Tyngsboro, Cannongate Condominium
resident~, State representatives, local officials, and other
municipal water districts~ .
, .
Public meetings were held on August 30, 1983, september 21,
1983, October 17, 1983 and October 31, 1983.. The purpose of
the first two meetings was to discuss .the scope and findings
of the studies, respectively. The purpose of the second two
meetings was to receive input from the affected community. At
all meetings, minutes were recorded and are available through
the Regional Office for review. .
. .
A remedial investigation and feasibility study for site
remediation was initiated in late September 1983. The workplan
will address closure .and post-closure care of the landfill:
treatment and disposal of the landfill leachate: and surface
and subsurface hydrogeology.
Feasibility Study Alternatives
.' .
The ob~ctive of the two-~art Focused Feasibility Study was
to recommend'the most" cost-effective method for providing an
alternate water supply to the Cannongate Condominiums and
surrounding residents whose wells have been or may become
affected by leachate from the Charles George Land Reclamation
Trust Landfill.
The "no-action" alternative is not feasible in this situation.
The wells have been closed because of the presence of several
known and potential carcinogens. The contaminants are increasing
in magnitude as well as the number of contaminants present.
Neighboring private wells are also beginning to show the presence
of contaminants that were not detected a year earlier. Presently,
water is being provided on a temporary basis by an above-ground
emergency pipeline during warm weather and by water tanker
trucks when water in the pipeline freezes. Therefore, a reliable

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The remedial action alternatives considered in Part I by
NUS include:
1.
uncontaminated well water supply from new groundwater
wells.
2.
Contaminated well water supply with treatment.
The development of new groundwater wells would require a hydro-
geologic investigation at each proposed well site to characterize
the aquifer(s) and determine the groundwater quality. The
bedrock ,aquifer would have to be investigated to determine if
there is sufficient yield or if the aquifer in these areas is
contaminated., Several assumptions were made in order to develop
a cost estimat~ for this alternative. The assumptions are discussed
in more detail in the focused feasibility study and are as follows:
o
The unconsolidated aquifer would be investigated and
found to be unsuitable for a water supply because of
contamination.
o
The bedrock aquifer would be investigated and found
to be suitable for a water supply.

Three production wells would be set into the bedrock
aquifer, each with an assumed production capacity of
50 gallons per minute. These three wells would serve
as the water supply source.
o
The cost estimates for new groundwater wells include well explora-
tion, testing 'and installation into the bedrock aquifer.
"--
~-
The treatment of contaminated well water supply would
require a relatively complex t~eatment system. In considering
this alternative, it was assumed that the two existing Cannongate
Condominium wells, along with two of the exploratory wells
, recently drilled by the Field Investigation Team (FIT) and two
nearby domestic wells, would supply the water for the system.
Extensive treatability studies would be required to determine
the most feasible treatment method. These studies must not
only determine the feasibility of effectively treating the
existing ground water, they must also address the ability to
treat increased levels of contamination and also potential new
contaminants that have not reached the wells to date. The
cost estimate for treatment of the contaminated well water
includes a water treatability study, but does not include costs
for a pilot plant study which would be required to properly
size the treatment system and to ensure its ability to

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--
Part II of the Feasibility Study conducted by Fay, .
Spofford, and Thorndike evaluated four specific domestic water
supply systems to determine the feasibility of each system to
- supply the required capacity of water to the impacted area in
Tyngsboro.
The water systems investigated include, the Town of
.Dunstable, .the Ci ty of Lowell, the North Chelmsford Water
District, and the Pennichuck Water Works in Nashua, New Hampshire.
Each source was evaluated in terms of its ability to furnish
water ba~ed.upon:
o
present,and future water requirements of the source:
o
adequacy of distribution facilities of the source to
support a pipeline extension:
o
alternative pipeline length, size and routes:
o
booster pumping requirements:
o
construction costs:
.-
o
institutional issues.
The study concludes that Pennichuck and North Chelmsford are
not viable alternatives because neither at present has a reliable
w~ter supply capacity to serve the ~~~ds of the project.

The study concludes that the Town of Dunstable's aquifer
appears more tha~ adequate to meet the demands of the Project
Area's average daily requirement~ of 100,000 gpd with storage
for fire protection. The primary institutional issue is the
unwillingness of the Town to negotiate a long-term Water Purc.hase
and Sales Agreement with the Tyngsboro Water District.
The study concludes that the Lowell system can adequately supply
the domestic water requirements of the project Area with storage
for fire protection. This route is longer ~nd more costly
than the route from Dunstable and would require filings with
various Commissions and agencies for stream, .river, and railroad
crossings. The City of Lowell has expressed a willingness
to supply water to the Tyngsboro Water District (a letter dated
June 23, 1983, from Mr. George P. Legrand, Jr., Commissioner of
Public works, Lowell, MA, is attached).
COSTS OF ALTERNATIVES
The following table is a summary of the capital, annual operation
and maintenance(O&M), and present worth costs for each a+ternative.
For Alternative 1, O&M would include maintenance of the well

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. -......--..
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8'.' - - .-
. .--.-
house and water line, pump repair and replacement, water quality
analysis, and energy costs. For Alternative 2, O&M costs would
include the replacement of spent treatment materials, water
" quality analysis, maintenance of treatment ~quipment "and the" pump,
"and energy costs. For Alternative 3, O&M would include maintenance
of the water line.
1. Uncontaminated
Water Supply,
CAPITAL
51,789,000
ANNUAL
O&M
PRESENT
WORTH
ALTERNATIVE
$110,000
$2,725,500
2. Contaminated Well
Water Supply
52,042,000
" 5184,000
53,609,000
3. Extension of domestic systems from:
A. Dunstab1e  S1,430,000 S30,000
B. N. Chelmsfo-rd 51,700,000 $41,000
 Water District  
C. Pennichuck Water 51,780,000 . $30,000
 Works   
D. Lowell  52,100,000 541,000
Sl,690,000
52,053,000
52,038,000
52,453,000 .

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The most 'cost-effective solution for providing a permanent water
supply is tying into an existing municipal water supply system.
.The reasons are as follows:
o
Cost The present worth costs for extending an existing
municipal water supply including fire protection from Dunstable
and Lowell are $1,690,000 and $2,453,000 respectively. Both
costs are less than either of tQe present worth costs for
providing new wells ($2,725,000) or treatment of contaminated
well water with fire protection'($3,609,000).
. -.. !
o
Reliabil.ity A known quantity and quality of water
would be available without having to treat contaminated
ground water with potentially varying concentrations and
types of c?ntaminants to potable water standards. .
o
Operability and Maintainability An established water
authority exists for coordinating the program and maintaining
the water eystem. Any ground water treatment system would
be complex and would requir& a highly skilled operator to
to properly operate and maintain the system.

I .
o
Construction Schedule The design of the municipal extension
can be initiated immediately. The other alternatives
would require extensive field investigations and treatability
studies first which will take several months to complete
wi~hout any guarantee of succes~.
COMMUNITY INVOLVEMENT
The primary concern and request by the Cannongate people, which
has been communicated and reiterated, in letter, by phone, and
at all the public meeting~, has been the provision of a permanent
water supply. In general, they are willing to support and
accept the most cost-effective solution identified by the
focused feasibility studies. They have stated that if Dunstable
refuses to sell water, they will urge EPA and DEOE to select
Lowell.
- .....-

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LOCAL INVOLVEMENT
While the Tyngsboro Water Commissioners supported the .selection
of Dunstable for water supply, they have also taken initiative
--to have their consultant look more deeply at the Lowell route
and its costs, with the conviction that a lower cost construction
"from Lowell could be achieved. The Tyngsboro Water Commissioners
favor the selection of Lowell because of Lowell's offer to :
sell water for present needs and their willingness and ability
to sell: water for future needs of the Town. . .

"~D~n~table has -a'pnilosphy of planned growth at a '~~erate
.to s16w :rate and is ~once_rned that the municipal water';-s'Upply
line to Cannongate in Tyngsboro would accelerate growth along
the line in Dunstable. Secondly, Dunstable ~s concerned that
the. future demands of the town and the extended service area
will exceed available supply. Finally, Dunstable has expressed"
the fear that any contract for the purchase and sale of water,
once-honored, could be subject to the pressure of greater:
demand on the part of Tyngsboro because of the spread of co~tam-
'inants .or because of development in Tyngsboro spurred by th~
presence of municipal water supply. The Dunstable Board of-
Selectmen decl.ined a request by the Commonwealth of Massachusetts
Department of Environmental Ouality Engineering (DEOE) to extend
a municipal water supply line to the Tynsboro Water Distrjct on
December 12, 1983 and again on December 21, 1~83. The DEOE lacks
the authority to compel Dunstable to provide that service.
STATE INPUT
The Massachusetts DEOE has concurred with EPA that tying into
an existing municipal water supply is the most reliable and I
cost-effective option for providing a permanent water supply.
A letter confirming the State's recommendation is attached.
The letter from the State also indicates that the Stat'e: .do~s not
have the authority to order the. Town of Dunstable to c~n~ey' water
to the area on a permanent basis. .
ENFORCEMENT STATUS
In 1973, the Trust applied for and received a hazardous.waste
disposal permit from DEOE, Division of Water Pollution Control.
The license was renewed for the years 1974 and 1975. During this
time the landfill filedreq~ired paperwork with the Division listing
classifications and quantities of wastes received at the Charles

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Until 1976, the landfill operated on the western most 38
acres, when the Tyngsboro Board of Selectmen assigned'the
entire property located within town (Tyngsboro) boundaries as
-" landfill. Town residents appealed the decision and asked the
"DEOE to revoke the landfill assignment on the eastern 25.3
acres, but DEOE ruled in favor"Of.~,~e Trust in April 1978.

In March 1978, the Trust and the commonwealth of Massachusetts
signed a Consent Agreement under which the Trust agreed to imple-
ment corrective measures for leachate control and to submit an
approved. engineering plan for operation of the landfill under
Massach~setts Regulation$.for Sanitary Landfills. .
Follow"ing inspections of the landfill conducted by DEQE on
May 23, June' 3, and June 16, 1980, the landfill was notified of
numerous violations.
An Amended Agreement for Judgment between the Trust and the
Commonwealth of Massachusetts was signed on December 17, 1981.
This agreement included completion dates for construction of a
leachate containment system and other remedial actions at the land-
fill site. The Amended Agreement also included provisions for
additional hydrogeologic investigations on and in the vicinity of
the landfill. .
On March 29, 1982, the Tyngsboro Board of Health conducted a
hearing under the provisions of Chapter II, Section l50A of the
Massachusetts General Laws. The hearing was pursuant to a notice
sent to the Charles George Land Reclamation Trust and was to deter-
mine whether a nuisance or danger to the public health existed at the
assigned landfill facility in Tyngsboro. By a unanimous decision
of the Board, tb~ landfill's assignments were suspended, effect1~~
May 14, 1982. With this decision, the Board of Health issued an .
Order of Conditions. Until this Order was met, ~he landfill could
not accept any wastes. However, the Massachusetts Superior Court',..
issued an injunction against the Board of Health decision. The
injunction allowed the landfill to operate while the Order of
Conditions were met.
The Superior Court issued another Order in January 1983 which
~equired additional hydrogeologic investigations at the site (the
study specified in the December 1981 agreement) and ordered pay-
ment of funds to ersure a proper, final closure of the landfill.

Charles George Landfill was initially classified as a state
lead enforcement case because of the states actions described above,
until it became necessary to supply temporary water to Cannongate.

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Superfund notice letters have been issued to the o~ners and
operators, who have declined to undertake cleanup activities more
extensive than those required by the various court orders. In
~pril 1983, the Charles George Land Reclamation Trust filed for
-the protection of the bankruptcy court. Although the petition
'was ultimately dismissed, court records make it clear that the
finances of the owners and operators will be inadequate to complete
even the initial cleanup activities that are proposed.
. .
A responsible party search for generators is in progress.
Region I expects to commence negotiations for site cleanup and
cost recovery for past actions during the 3rd quarter of FY-84.
RECOMMENDED ACTION
Section 300.68(j) of the National Contingency Plan (NCP)
147FR 31180, July 16, 1983] states that the appropriate extent
of remedy shall be determined by the lead agency's selection
of the remedial alternative which the agency determines is
.cost-~ffective (i.e., the lowest cost alternative that is .
technologically feasible anQ reliable) and wnich effectively
mitigates and. minimizes damage to and provides adequate protec-
tion of public health, welfare, or the environment. Based on
our evaluation of the cost-effectiveness of each of the proposed
alternatives, the comments received from the public, the towns
.involved, Tyngsboro's consultant, and State information and
support, we recommend that permanent water supply be provided
fo~ Cannongate by tying into an existing municipal water system.
..
PROPOSED ACTION
We request your approval of the remedial action. Our schedule
calls for design to commence by the design firm selected by
the Army Corps of Engineers immediately upon signing of the
ROD and issuing the Interagency agreement. The design will take
approximately three (3) months for completion. Construction
will commence upon selection by the Corps 6f a construction firm.
The following actions need to be completed to initiate construction
activities:
1) Issue the Interagency Agreement to the. Corp of Engineers.

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