Environmental Protection
Aflcncy
Offlo* of
EPA/ROD/R01-85/008
July 198a
Superfund
Record of Decision:
Charles George, MA
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TECHNICAL REPORT DATA - I
(PI,. MId IlflllUctiofll 01f the nveru kfon camp/en,.,)
1. ".'O"T NO. 12. 3. JIIEClttIENT'S ACCESSION NO.
EPA/ROD/ROl-8S/008
.. TITLE AND SUBTITLE 5. JIIE'OJIIT DATE
SUPERFUND RECORD OF DECISION July 11, 1985
Charles George, MA (Second Remedial Action~ e. ttERFORMING ORGANIZATION CODE
7. AUTHOJIIISI - 8. 'EJIIFOAMING ORGANIZATION REPORT NO'
1. 'ERFOJIIMINO OJIIOANIZATION NAME AND ADDRESS 10. 'JIIOORAM ELEMENT NO.
11.l;gNT"ACT/u""NT No.
12. SttONSORINO AOENCY NAME AND ADDRESS 13. TYPE OF REPORT AND PERIOD COVEREO
U.S. Environmental Protection Agency Final ROD Reoort
401 M Street, S.W. 1.. SPONSORING AGENCY CODE
Washington, D.C. 20460
800100
15. SUPPLEMENTARY NOTES
1e. ABSTRACT
ThB Charles George Land Reclamation Trust Landfill (CGLRT) site is a
69-acre landfill located in Tyngsborough. Massachusetts about 30 miles
northwest of Boston and 4 miles south of Nashua. New Hampshire. From 1955
until 1971. the site was operated as a municipal dump. In 1973. CGLRT was
issued a permit by the Massachusetts Division of Water Pollution control to
handle hazardous wastes in addition to municipal and domestic refuse. Dis-
posal of hazardous wastes and substances. primarily in the form of drummed
and bulk chemicals containing volatile organics and tox .c metal sludges.
continued from January 1973 to at least June 1976. The exact quantity of
hazardous substances disposed at the site is unknown. Records submitted by
the landfill operators and other available information show that at least
2,500 cubic yards of chemical waste material were landfilled and over one-
thousand pounds of mercury were disposed of at the site. ,
The selected remedial action includes the installation of: a full syn-
thetic membrane cap. a surface water diversion and collection system; a vent
network with an off-qas collection system venting to the atmosphere; and a
full peripheral leachate collection system. Total capital cost for the se-
lected remedial alternative is estimated to be $13.613.725 and O&M costs are
approximately $1.252.901 per year.
17. KEY WORDS AND DOCUMENT ANALYSIS
I. DESCR.,TORS b.IDENTIFlIRS/O'EN ENDED TEAMS C. COSATI Field/Group
Record of Decision
Charles George, MA
Contaminated media: air, gw, sw, wetlands ,
Key contaminants: volatile organics,
sludge, acids, heavy metals (mercury),
toluene
18. DISTRIBUTION STATEMENT 18. SECUJIIIT'I' CLASS (Tllil R,po"J 21. NO. OF PAGES
None
20. SECURITY CLASS (TIliI/HI,eJ 22. PRICE
None
I'A ,- 2220-1 (R... '-77)
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c
SITE:
RECORD OF DECISION
REMEDIAL ALTERNATIVE SELECTION
~
Charles George Reclamation Trust Landfill
Tyngsborough. Massachusetts
DOCUMENTS REVIEWED
I am basing my decision primarily on the following documents
describing the analysis of cost-effectiveness of remedial alterna-
1.
tives for the Charles George Site:
2.
3.
4.
5.
6. .
7.
Charles George Reclamation Trust Landfill. Tyngsborough.
Massachusetts. Remedial Action Master Plan. November 1983.
prepared by NUS Corporation. Pittsburgh. Pennsylvania.
Charles George Reclamation Trust Landfill. Tyngsborough.
Massachusetts, Work Plan for the Remedial Invest1gat10n/
~easibility Study. March 1984. pr,p'~ed by NUS Corporation.
Pittsburgh. Pennsylvania.
Charles George Reclamation Trust Landfiil. Tyngsborough.
~
Massachusetts, Draft Source-Oriented
Feasibility Study, March
1985. prepared by NUS Corporation. Pittsburgh. Pennsylvania
and EPA comments on the draft document.
.
Summary of Remedial Alternative Selection (attached)
Community Relation Responsiveness Summary (attached)
The National Oil and Hazardous Substances Pollution Contin-
gency P~an. 40 C.F.R. Part 300.
40 C.F.R. Part 264 - Standards tor Owners and Operators ot
Hazardous Waste Treatment, Storage. Disposal Pacilities.
Subpart P - Groundwater Protection; Subpart G - Closure and
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-2-
Closure Care.
8.
9.
Executive Order 11988 - Floodplain Management
..
10.
Executive Order 11990 - Protection of Wetlands
40 C.F.R. Appendix A Part 6 - Statement of Procedures on
11.
Floodplain Management and Wetlands Protection.
Preliminary Wetlands Assessment for the Charles George
Reclamation Trust Landfill, Tyngsborough, Massachusetts,
prepared by U.S. Environmental Protection Agency, Water
Division, Wetland Section.
DESCRIPTION OF SELECTED REMEDY
REMEDY
o Full synthetic membrane cap (with the establishment of
a 3:1 grade where required.)
o Surface water diversion and crllection system
o Vent network with off-gas collection system venting to
the atmosphere
:
o Full peripheral leachate collection system
OPERATION AND MAINTENANCE REQUIREMENTS
o Annual mowing and maintanence of the vegetated surface
.
o Quarterly inspection of the following:
- pump station
- leachate cOllection/disposal
- cap surface
DECLARATION
Consistent with the Comprehensive Environmental Reponse
Compensation, and Liability Act of 1980 (CERCLA), and the Nation-
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-3-
full synth~tic membrane cap, surface water diversion and c~llec-
tion system, vent network with off-gas collection syst~m ventin~
~
to the atmosphere, and full peripheral leachate collection system
at the Charles George Site 1s a cost-effective remejy and provides
adequate protection of public health, welfare, and the environment.
The State of Massachusetts has been consulted and agrees with the
approved remedy.
In addition, the action will require future op-
eration and maintenance activities to ensure the continued effec-
t1veness of the remedy.
These act1vit1es w1l1 be cons1dered part
of the approved act10n and e11gible for Trust Fund monies.
I have also determ1ned that the action being taken 1s appro-
priate when balanced against the availab1lity of Trust Fund monies
for use at other sites.
EPA will undertake ana(!d1 tional feas1bili ty
t.jy to eval-
uate the groundwater and off-site remediation, whether the
treatment of vent gases is required, a~d the effectiveness of
the leachate handling option selected.
If additional remedial ac-
tions are determined to be necessary, a Record of Decision w1ll be
prepared for approval of the future remedial action.
, !
-1 i I ~ /8' S
I ate
, . --
17 . .
I ~>'t+/~;? ~.~ _.~- .
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SUMMARY OF REMEDIAL ALTERNATIVE SELECTION
CHARLES GEORGE LAND RECLAMATION TRUST LANDF"',LL
INTRODUCTION
The Charles George Land Reclamation Trust (CGLRT) Landfill located
primarily i~Tyngsborough, Massachusetts is a large and relatively
complex site. In order to facilitate clean up, the decisions
concerning long-term remedial action at this site have been broken
into three Records of Decision (ROD).
The first ROD signed December, 1983, addressed the planned installatio~
of a permanent water supply line to the residents of the Cannongate/Re~
Gate road area. The focus of this ROD is the implementation of
source control measures to contain contamination and thereby to
minimize any further off-site impacts. The third and final ROD
will select remedial actions designed to clean-up and control off-
site contamination and resolve any remaining on-site issues.
LANDFILL LOCATION AND DESCRIPTION (see figure 1 and 2)
The Charles George Land Reclamation Trust Landfill site is a 69-acre
landfill located primarily in Tyngsborough, Massachusetts about 30
miles northwest of Boston and 4 miles south of Nashua, New Hampshire.
The site occupies approximately 60-acres in Tyngsborough and 9
acres in the adjoining Town of Dunstable, Massachusetts. Access to
the site is via Route 3 to the Tyngsborough Interchange. The site
lies immediately adjacent to Route 3, and is reachable via Dunstable
Road. The landfill entrance lies at the intersection of Dunstablc
Road and Blodgett -C~umings Road, at the northwestern corner of tl
site.
The land adjacent to the landfill is predominantly a rural wooded
area with developed land primarily devoted to residential and
recreational purposes. The closest residences are located on
Dunstable Road, Blodgett St., and Cummings Road within a radius
of 500 feet to the north and west of the landfill. The Cannongate
Condominium Complex (96 units) and private residential homes are
approximately 500 feet south of the site. Another residential
community, 1000 feet east of the landfill, exists along the north
and east shores of Flint Pond. All the area residents are on
private drinking water wells. A day school, the Academy of Notre
Dame, is situated along the southwest shore of the Flint Pond.
"
There are two surface water resources within the immediate site
vicinity which are impacted by contamination at the site, Dunstable
Brook and Flint Pond. TO the west of the site is Dunstable
Brook. Sampling data of Dunstable Brook indicates the presence of
contamina'nts from the landfill. The Brook flows in a southerly
direction before turning east, then northeasterly, discharging
into Flint Pond Marsh, which in turn supplies Flint Pond. Flint
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FIGURE I-I
LOCATION MAP
CHARLES GEORGE SITE. TYNGSBORO. MA
SCALEl=2OOd
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Route 3 physically separates the Pond from the site, a drainage
culvert under the highway provides a direct conduit for site
leachate to impact the Pond. Drainage from this culvert, which
contains leachate contaminated by hazardous substances, enters
Flint Pon~rsh. Sample results indicate contamination of the
marsh which is the headwater for Flint Pond proper. The outlet
of the Pond discharges into the Merrimack River, futher to the
east of the site. The Merrimack River is the drinking water source
for the downstream communities of Lowell, Lawrence, and Methuen~
There are six wetlands in the vicinity of the site. These six areas
are discussed preliminarily in the Wetlands Assessment (Attachment
1). A review of the Federal Emergency Management Agency map dated
September 2, 1982, for this area indicates that the site is not in
a Floodplain and the proposed Remedial Action will not impacy a
floodplain. Groundwater flow from the landfill occurs in two
unconfined aquifers as documented in the various engineering studies
referenced. The first is a shallow aquifer beneath the site. It
consists of unconsolidated deposits of glacial till and stratified
sand deposits. The other aquifer is to the southwest of the site
located in the bedrock and consists of highly fractured metamorphic
and less fractured igneous rock. There is a hydraulic connection
between these aquifers; and therefore they may be considered as one
hydrologic unit. The topograpy in the eastern half of the site is
believed to have consisted of a central lowland filled with outwash
sands and gravels prior to the creatioD of the landfill. This
lowland was flanked on the north and south by higher knobby terrain.
The western half of the site was characterized by three small
druml i is. .
The site area has a shallow depth to bedrock, though widely varying
(from 5 feet to over 80 feet below grade), "and a high groundwater
table. The base of the landfill appears to lie between 180 and 190
feet above mean sea level (msl). The groundwater table is
approximately 1 foot to 15 feet below the surface depending upon
seasons of the year. A partial leachate collection system is in
place at the site which is intended to drain to sumps at the eastern
and western landfill peripheries. Discharge from the eastern sump
is pumped back to the eastern landfill crest. Leachate collected
in the western sump is currently pumped to a sedimentation basin
on the western landfill periphery. This system continually breaks
down and is frequently inoperative allowing leachate to migrate
off site into local drainage systems.
In the northwestern corner of the landfill there remain a number
of above ground structures relating to the landfilling operations.
These items consist of approximately 30 large industrial dumpsters,
a 40 ft. .by 110 ft. maintenance garage, and miscellaneous scrap
metal, machinery, and truck parts.
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Site History
Previous reports indicate that waste disposal activity at this site
was initiated near the intersection of Dunstable and Blodgett-Cummings
Road in 19S~ During the period from 1955 until the land was
purchased by Charles George Sr. in 1967, the site was operated by
persons unknown under contract to the Town of Tyngsborough as a
municipal dump. This site continued as a municipal dump following
acquisition by Charles George Sr. in 1967 and by Charles George Sr.
and Dorothy George as Trustees of CGLRT in July 1971. In 1973,
CGLRT was issued a permit by the Massachusetts Division of Water
Pollution Control (DWPC) to handle hazardous wastes in addition to
municipal and domestic refuse. Disposal of hazardous wastes and
substances primarily in the form of drummed and bulk chemicals
containing volatile organics and toxic metal sludges continued from
January 1973 to at least June 1976. The exact quantity of hazardous
substances disposed of at the site is unknown. Records submitted
by the landfill operators and other available information show that
at least 2,500 cubic yards of chemical waste material were landfilled
at the site. Records submitted to EPA also show that over a thousand
pounds of mercury were disposed of at the site.
In 1982, the Tyngsborough Board of Health suspended the assignment
of the CGLRT land as a landfill. At approximately the same time,
formal notice was served by the Massachusetts Department of
Environmental Quality Engineering (DEQE) that two wells serving the
Cannongate Condominiums were no longer considered suitable as a
potable water supply and were ordered closed. This action was
taken in light of increasing levels of volatile organic contam ..:\C iLiI1 .
in the wells. In order to provide a temporary solution to the
water shortage created by loss of the wells, an above ground water
line was installed by the DEQE from the North Chelmsford Water
District to the condominiums. The water line froze and was ;
subsequently dismantled in December 1982. A.Removal Action, pursuant
to the National Contingency Plan (NCP) at 40 CFR 5300.65 (a) (2),
an insulated pipeline was installed by the EPA's Environmental
Response Team (ERT) in 1983. This line continues to serve the
residents' of the Cannongate Condominiums.
The EPA completed a Focused Feasibility Study in September of 1983
evaluating the need and most practical route for a permanent
waterline to replace the temporary aboveground line. The EPA signed
a ROD on the permanent waterline issue in December of 1983. The
permanent waterline will connect the Cannongate/Red Gate road area
with the City of Lowell's existing municipal water system. When
installed, the line will consist of approximately 4.9 miles of
pipe, a 514,000 gallon storage tank, and a pump station. . The
construction of the waterline will not only replace the temporary
Cannongate system but will also be able to serve residents whose
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substances from the site into the groundwater. There is an
ongoing monitoring program of those residences still on private
wells and not served by the temporary water line. Construction
on the line is scheduled to start in the fall of 1985.
---,
During the fall of 1983 and winter of 1984, the ERT also installed
a security fence on portions of the landfill, regraded portions
of the landfill, placed a soil cover over exposed refuse, and
installed 12 gas vents along the crest of the landfill. These
vents are intended to provide temporary control of gas emissions
until a more permanent remedy can be implemented.
Current Site Status
A number of actions have been undertaken by the EPA since its
initial involvement. These actions not only included Removal
actions, such as the temporary waterline, but also preliminary site
investi~ations including some limited hydrogeologic surveys.
The current ongoing investigation is the Remedial Investigation
(RI). This RI started in summer of 1984 and is expected to be
completed in the fall of 1985. The RI will primarily address the
extent of off-site contamination and will evaluate off-site
remedial actions.
The Charles George landfill, as noted earlier, is a large (69
acres) site with approximately 4 million cubic yards of refuse
contained on-site. Within this 'refuse an estimated 2,500 cubic
yards of hazardous substances have been disposed of. Landfilling
operations ceased in June, 1983, leaving the site with inadequate
cover material to prevent precipitation from infiltrating the
landfill with subsequent leachate generation. The landfill has
developed large erosion gullies, exposing refuse, on .all sides of
the site. In addition, there are numerous areas where leachate
breaks out to the surface of the landfill.' These breakouts mix
with the surface runoff and quickly flow offsite. This fact is
evidenced by the substantial amount of distressed vegetation
surrounding the landfill. The results from the RI field studies
indicate that volatile organics, acids, and heavy metals are the
most commonly occurring contaminants found both on and off site.
Some of the data is summarized in T~bles 1, 2a, 2b, and tables 3
through 6. Included in each table is the exsisting federal
standards and criteria for each compound listed.
Table 1 summarizes leachate data migrating from the landfill to
surface receptors including soils, vegetation, and water courses.
As can be' seen, the leachate contains known human carcinogens,
various volatile organic compounds, and heavy metals which are
significantly in excess of available criteria. Potential receptors
include surrounding flora and fauna as well as humans transversing
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-5-
the area or using the water bodies as recreational or drinking
sources.
Tables 2A and 5 reflect organic and inorganic compounds flowing
in ground~r which contains moderate to very high concentrations.
Most groundwater flows through fractured bedrock as shown by the
installation of many monitoring wells during the ongoing Phase
III Remedial Investigation. Potential receptors include the
Cannongate Condominium wells which have been closed due to
contamination and any other persons using the aquifer for drinking
water. Tables 2, 3, and 4 indicate organic and inorganic
contaminants found in wetlands and surface waters surrounding the
site. Again potential receptors include flora and fauna as well
as humans coming into contact with surface waters.
The primary focus of the Source Control Feasibility Study is to
control leachate from CGLRT, which contains the highest concentrations
of contaminants. The Phase III RI/FS (offsite) will address the
remedial alternatives for offsite surface and groundwater
contamination.
It is estimated, based on a water balance model in the Source
Oriented Feasibility Study, that the site presently generates
approximately 36 million gallons of leachate per year. Using the
average concentrations of compounds detected in the leachate it
is estimated that over 9,300 pounds of Total Volatile Organic
Compounds and over 188,000 pounds of toxic heavy metals are
migrating offsite per year.
There are four potential routes of exposure associated with the
CGLRT Landfill: direct contact, surface water, groundwater, and
air.
The surface waters and wetlands surrounding the site are a major
environmental concern. They flow through residential neighborhoods,
are used for recreational purposes, and provide a habitat for wildlife
(ducks, fish, etc.). Wildlife that feed and nest on, or near, the
landfill may be exposed and accumulate contaminants from the site.
The leachate is impacting the surrounding surface waters and
wetlands as shown by similar contaminants found in the surface
waters and wetlands as those which were found in the leachate.
There are several major routes for surface migration of the
leachate off-site which have been identified. These are on the
east, west, and southern sections of the landfill. First, on the
western section of the landfill, leachate flows under Dunstable
Road and into Dunstable Brook. During periods of precipitation the
leachate is so voluminous that it flows across Dunstable Road,
often times so deep that cars have to slow down almost to a
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TABLE 2a
ORGANIC COMPOUNDS FOU~D IN GROUNDWATER
CHARLES Gf.O~GE SITE
TYNGSBOROUGH, MASSACH~SETTS
Compound.
Relative Concentration
..~
Methylene Chloride
Very High.
Very High
Acetone
Benzene
High
High
Toluene
4-Methylphenol
~oderate
l,l-Dichloroethane
Low
Trans-l,2-dichloroethane
Moderate
2-Hexanone
High
Ethylbenzene
Total Xylenes
Moderate
Low - Moderate
Phenol
Moderate
2-Butanone (MEK)
Very High
His,h
4-Methyl-2-pentanone (MIBK)
Bis(2-ethylhexyl)phthalate
Low - Moderate
Benzoic Ac id
High -
Very High
2-Methylphenol
Low - Moderate
Phenanthrer'1e
Low
Diethyiphthalate
Low
Ranges:
2 10,000 ppb . Very high
1,000-10,000 ppb . High
100-1,000 ppb . Moderate
DL-100 ppb . Low
Source:
(DL = Detection Limit)
NUS Corporation, Pittsburgh, Pennsylvania (March 1985)
*Listed in order of decreasing frequence of occurrence
-------
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-------
-6-
flows southeasterly into Bridge Meadow Brook, which eventually
empties into Flint Pond Marsh. The outlet of the marsh is the
primary source of supply to Flint Pond.
Second, ~he eastern end of the landfill, the leachate and
eroded contaminated soils discharge directly into Flint Pond
Marsh through a culvert under Route 3. Flint Pond is used for
recreational purposeB: Fishing, boating, and swimming have been
some of, the activities that have been observed. There are 16
residencies along the northern shore that use shallow wells next
to the pond as their drinking water supply. These wells are
being investigated as part of the Phase III RI/FS. The outlet of
Flint Pond flows to the Merrimack River. The Merrimack River is
a drinking water source for the downstream communities of Lowell,
Lawrence, and Methuen. Samples collected from the Route 3 culvert
area contained most of the compounds found in the leachate samples
collected during the Phase III RI.
Except for a small area of Flint Pond Marsh, the results of the
Preliminary Wetlands Assessment, appended to the ROD, did not
document any visually observe able any adverse impacts to the
wetlands. During a site tour a fringed area of the marsh running
linearly along Route 3 appeared to be dying ("Browned-out from
landfill and/or road salt impacts"). However, the assessment
recommended that a more thorough and detailed wetlands assessment
should be included in the RI/FS. This more thorough investigation
will include a characterization of vegetation, hydrology, soils,
tissue analysis and wildlife in the wetlands. A Wetland mitigation
plan will alse be O'V loped as a result of this more detailed
assessment the plal w 11 be incorporated into offsite remedial
alternatives to be proposed in the Phase III RI/FS of the project.
Additionally, a wetlands mitigation plan for the source control
will be developed during the design for the source control action.
. .
A final leachate contamination pathway is located along the
southern portion of the site. As noted earlier, the landfill is
located over a shallow aquifer of unconsolidated deposits and a
fractured bedrock aquifer to the southwest. Highly fractured
bedrock outcrops along the northern toe of the landfill and along
the southeastern drainage channel indicate that areas of exposed
bedrock were dynamited in order to expand the landfill. Surface
water flow patterns and the close proximity of the landfill to
these outcrops provide a direct conduit for the leachate to
migrate into the bedrock aquifer. Sampling results of Two bedrock
water supply wel~s (Cannongate wells) 500 feet downgradient of the
landfill indicate a significant degree of contamination. Analytical
results of downgradient monitoring wells indicate that the landfill
has significantly contaminated the shallow and bedrock aquifers.
A number of the hazardous substances detected in the aquifers are
-------
-7-
and 2b summarize this data. A number of the compounds detected
during sampling conducted to date on and off site (See Tables 1-
6) are either known human carcinogens (e.g. vinyl chloride,
benzene), suspected carcinogens (e.g. toluene, arsenic), or
cause some.adverse health effects such as neurological dysfunction
(lead). Many of these compounds exceed federal standards and
criteria, such as the Health Advisories and Maximum Contaminant
Levels (MCLs) issued pursuant to the Safe Drinking Water Act
(SDWA) and water quality criteria and the exposure levels based
upon unit cancer risks issued pursuant to the Clean Water Act
(CWA). The UCRs are values identified by EPA for drinking water.
These levels, UCRs, are based upon an incremental increase in
cancer risk of 10-6 assuming exposure to a 70 Kg adult consuming
2 liters of water per day. Concentrations of Benzene, 2-Butanone
(MEK), and Arsenic are 529, 28, and 2600 times higher than their
URC levels, respectively (based upon maximum concentrations in
Table 5). Toluene was three times the recommended Health Advisory
for Chronic Exposure Limit under the SDWA, while Mercury levels
found in the Route 3 culvert were found to be twice the recommended
Water Quality Criteria for Mercury.
Several volatile organic compounds were detected in the air
samples collected from the vents on the landfill, as part of a
preliminary air monitoring study undertaken in order to idenitfy
the composition of the gas emissions. These compounds are shown
in Table 6. Concentrations of the gases at the vents ranged from
500 ug/m3 to 10,000 ug/m3. The majority of the compounds were
detected in the surrounding environment at concentrations ranging
'-'" r\"'n 100 ug/m3 to 500 ug/m3. These gases have th~ potential to
.e~rade the quality of air and public health.
:
As part of ERT's effort in 1983 fencing was installed across the
site access road to prevent vehicular traffic. This has left the
majority of the site unsecured. Presently, trespassers on-site
or individuals walking along Dunstab1e Road may come into direct
contact with the leachate outbreaks. These are the only human
receptors believed to be threatened by direct contact with the
leachate streams.
.
While it is premature to draw any definitive conclusions relating
to the extent of the long term off-site impacts until completion
of the off-site Remedial Investigation it is not too early to
implement a source control measure to reduce the ongoing impacts
of 36 million gallons/year of leachate on the surrounding public
health, welfare, or environment. It should be noted that while
the data contained in Tables 1 through 6 indicate that there is a
substantial ongoing impact to areas surrounding the site, that
this 1and~il1 is relatively "young". Many of the hazardous
substances were disposed of in the mid 1970'S7 it is believed
-------
-8-
representative of the wastes that may be ultimately discharged to
the environment if no action is taken to minimize their release.
There are a number of reasons for this belief: intact drums may not
have degraded to the point of releasing their contents, contaminants
may be pe~ing in relatively impermeable zones within the landfill
which over time may change due to natural settling, or solid toxic
residues may solublize when exposed to solvents such as water.
The estimate of 2,500 cubic yard~ of hazardous substances comes
from scanty records by the landfill operator: the history of
investigations of similar hazardous wastes sites indicates that
available information is usually a small percentage of wastes
ultimately found to be associated with a particular site.
Source Control measures such as capping and leachate collection
are commonly employed at landfills and installation of them is
justified at the earliest practicable date to minimize the public
health threat or environmental damage from leachate streams,
which by their very nature, are the most heavily contaminated
sources likely to migrate from the site. The fact that there is
an ongoing discharge of significant quantities of contaminated
leachate and there exists a significant potential for additional
contaminants to leach from the landfill argues for proceeding
with the Source Control measures at this time. Source Control is
aimed at significantly reducing the threat caused by the volume
of leachate generated and the rate of transport off-site of such
leachate. It is further aimed at reducing contamination of
groundwater in the fractured bedrock aquifer which may be difficult
if not impossible to extract. Thp cap is also aimed at reducing
health threats from air emissie :s
Enforcement
Attached is the list of potentially responsible parties currently
identified by EPA for the Charles George Site (see attachment 2).
The list has been developed as a result of title searches and
responsible party searches for owners, operators, generators and
transporters. The responsible party search for generators and
transporters is still in progress.
. .
In March of 1982 and again ir: May of 1983, Superfund notice
letters were issued to the owners and operators of the site
inviting them to participate in the Remedial Investigation/
Feasibility Study. Responses received from counsel on the behalf
of the owners and operators have not indicated a willingness to
undertake EPA's proposed clean up measures.
In January 1985, EPA sent a combination information request/notice
letter to Karen Karras, as an operator and transporter, to which
no reply has been received to date. EPA issued a combination
-------
-9-
inviting them to participate in the clean-up process, on December
10, 1984. The agency received a reply from BFI on March 6, 1985.
In this reply, BFI did not indicate a willingness to undertake
cleanup measures. .
~
On October 3, 1983, EPA issued an information request letter to
the Charles George Reclamation Trust (CGLRT). CGLRT responded
only by providing available public waste manifests, which did not
indicate the identities of any generators.
In January, 1985, EPA sent informational requests letters to the site
owners and generator, Charles George, Sr., Charles George, Jr.,
Dorthy George, and James George and to a transporter, the Charles
George Trucking Company. EPA has not received a reply to any of
these requests.
The Coast Guard is a generator in this case. On January 29,
1985, EPA issued a Superfund notice letter to the Coast Guard.
The Coast Guard responded on March 12, 1985, expressing an interest
in pursuing the possibilities of participating in a portion of
the clean up process for which they were responsible. However,
it is not possible to determine this portion until other PRP
generators are identified.
As a result of the response or lack of response received by the
agency from the PRP's, The EPA has not been able to hold negotiations
with any of the the PRP's regarding PRP participation in the
RI/FS process. The Agency intends t( open negotiations again for
the PRP participation during the construction phase of the ~ou~ce
control remedy. However, the Agency has recommended the use of
fund monies to proceed with the RI/FS until the Agency is able to
identify PRP's who are interested in undertaking the clean-up.
The case was referred to the EPA Headquarters in December 1984,
to begin cost recovery actions against all. recognized owners and
operators to date.
On June 14, 1985, a complaint was filed in the Federal District
Court for the District of Massachusetts against the Charles George
Trucking Company, Charles George Sr., Dorothy George, Charles
George Jr., and James George for the 1.7 million dollars spent by
the EPA on responding to the site conditions thus far. The
complaint also seeks to compel these defendants and another
defendant, Karen Karras to respond to requests by EPA for
information regarding wastes which were dumped at the site.
Finally, the complaint sought and Federal District Judge Arthur
Garrity granted on June 21, 1985 an injunction preventing defendants
from conveying nearly two million dollars worth of real estate
-------
-10-
Alternatives Evaluation
The purpose of this ROD and the Source Oriented Feasibility Study
is to address source control measures in accordance with 40 CFR
300.68 (e)(2.). An additional ROD for off-site actions in accordance
with 40 CFR S300.68 (e)(3) (those areas outside the actual landfill)
will be developed when the Phase III RI/FS i~ completed.
The objective of the source control measures is to abate the
continued release to the environment of large quantities of
leachate containing hazardous substances and to further minimize
the threat to public health and other environmental concerns such
as wetlands.
The Source Control measures are intended to be the second of three
operable units and will be consistent with the final remedies
contained in the Phase III RI/FS (i.e. the source control measures
are not temporary in nature and will not need to be reconstructed
to be compatable with the final remedy). Indeed, this second
operable unit will probably mitigate the level of any final off-site
remedial action.
Specifically, the objectives of the source control measures are:
- Abate additional impact to surrounding surface waters and
wetlands.
- Minimize, to the extent practicable
the n :mdwater.
continued release to
,
- Control the emission of gases containing hazardous
constituents to the surrounding residents.
- Minimize potential contamination of the water supplies
and impacts on recreational uses around Flint Pond.
:
1
- Minimize potential exposure, via direct contact with
leachate, to the surrounding public and wildlife.
- Secure the site to eliminate unauthorized access.
To comply with existing federal~ state, and local laws.
- Ensure a Consistency with any off-site remedial
alternatives which may be selected in the third ROD as
-required by CERCLA S 101 (24).
A summary of the information used to select a source control
-------
-11-
- the site has inadequate cover material to retard leachat~
generation. Many areas of the site still had exposed
refuse and numerous erosion gullies continue to appear
exposing refuse and enhancing the potential for direct
contact. Those areas which were covered were only
covered with a relatively permeable soil cover.
- Inadequate barriers (man made or ~atural) exists onsite
to retard leachate generation and its subsequent off-
site migration.
- An ineffective partial leachate recirculation system does
little to retard off site migration of leachate. In
fact, the recirculation system may enhance the potential
for leachate to impact groundwater by maintaining a higher
hydraulic head in the landfill. This system is presently
inoperative.
- Substantial volumes of leachate and surface water runoff
(36 million gallons/year) are being produced and are
migrating off-site. (see Table I for list of contaminants).
-The nearest potable water supply closed down, due to
elevated levels of volatile organic chemicals. Sampling
results of potable water wells when compared with monitoring
wells and leachate samples show many of the same constituentE
in similar concentrations.
- There are numerous areas ~f distressed vegetation in
those areas where leachate -s allowed to run off as
observed during many site inspections.
- Air samples from gas vents indicate gases containing
known human carcinogens are being emitted from the
landfill. Strong odors are detected in residential
neighborhoods under certain atmospheric conditions.
- The large size of the site (69 acres, 4 million cubic
yards) and the lack of definition of possible hazardous
waste disposal area preclude an off-site removal and
disposal option.
The Source Control Feasibility Study evaluated a total of eight
possible alternatives. These alternatives were developed and
evaluated using S300.68 (g), (h), and (i) of the NCP. The
following alternatives were selected as remedial actions to be
-------
-12-
- .
1. No Action
II. Partial Soil Cap
III. Partial Clay Cap
IV.Partial Synthetic Membrane Cap
V. Full Soil Cap
VI. Full Clay Cap
VII. Full Synthetic Membrance Cap
VIII. Complete Off-site Removal and
Disposal.
Each alternative, with the exception of the No Action and completed
removal alternatives evaluated the following major components as
part of the alternative. (see attached conceptual design which
further describes these components).
- Site regrading and capping techniques - Portions of the
landfill have side slopes steeper than the commonly accepted
3:1 ratio. Each alternative evaluated different techniques
and material to obtain the appropriate slopes. In addition,
different types of cover materials were evaluated against
cost, quality assurance of material, and ease of installation.
The evaluation of these items appears in more detail in the
Source Control Feasibility Study.
- Surface/storm water collection and diversion - Surface-
water control will be required to facilitate expedient
removal of uncontaminated rainfall from the site. Each alternati'
will have, as part of its design, a surface water control
s~~tem installed around the site to collect precipitation
which was not uptaken by the root'S, f the vegtative ;;over.
The control system will transpor': tqe surface water "0 areas
off site. These areas will be designed to promote a wetlands ~.
area and will be used to compensate for any lost wetlands as
a result of the remedial alternative.
- Gas collection and Venting - Presently the site emits gases
to the ambient environment through cracks, fissures, vents,
and the permeable soil cover. These gases contain volatile
organic compounds, some of which are known human carcinogens
(vinyl chloride, benzene). A detailed air sampling survey
will be completed during the design phase of this project to
determine if gas treatment will be needed. In the meantime
these gases will collect and exert increased pressures on the
underside of the impermeable cap which will need to be
controlled and minimized. The method used to ensure that
trapped gases do not cause a problem is to equalize the
pressure by venting the gases to the atmosphere or a treatment
system. Presently there is not adequate data to determine if
a treatment system will be required1 efforts are underway to
-------
-13-
Each alternative incorporates a gas collection and venting
system to ensure that trapped gases are not a problem. The
alternatives evaluate a gas collection system which collect
the gases under the cap through a permeable media. This
media chanels the gases to a number of vents (between 12
and 24 depending on alternative). These vents will vent
the gases to the atmosphere, untreated, until a determination
can be made on treatment. The vents will be designed to
easily incorporate a manifold collection system to carry to
gases to a central treatment location, if necessary.
- Leachate Collection - Leachate will still tend to migrate
off-site via break-out and shallow groundwater even after
the installation of an impermeable cap. This leachate will
,be intercepted by a peripheral leachate collections system.
This system will consist of a slotted pipe buried in a
trench backfilled with crushed stone. The pipe will collect
leachate, transport it via gravity to two collection sumps.
Once the leachate is contained within these sumps it can be
recirculated, trucked off-site to a Publicly Owned Treatment
Works (POTW), or as to the long term method of disposal
will be addressed during the Phase III RI/FS. Camp, Dresser
and McKee (COM) will evaluate feasible alternatives for
leachate disposal prior to the completion of the Phase III
RI/FS. Each alternative will have the same leachate collection
system.
- Dispos~l of Remaining Above Ground Structure - There is a
maint'!n?nce building remaining on site as well as a number
of aban~oned dumpsters. The maintenance garage will be
used for storage of materials and supplies during and after
the completion of the remedial actions. The remaining
dumpsters will be either sold as scrap or dismantled and buri~d
on-site.
The different capping alternatives are depicted in Figure 3. Also
shown in Figure 3 is the proposed surface water control structures.
Figure 4 shows the different cross-sections used in the capping
alternatives.
It should be noted that the data collected during the ongoing
RI/FS indicates that shallow groundwater may intersect parts of
the bottom of the landfill and would produce a certain amount of
leachate regardless of which alternative is selected. Because
existing information also indicates that the bedrock, in which
the bulk of the groundwater contamination appears to be flowing
in, is highly fractured with the deeper fractures (400+ ft. below
grade) being the ones contaminated, alternatives such as slurry
walls and establishing artifical groundwater gradients were not
-------
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~WASTE ~
SOIL CAP
LANDFILL CAPPING OPTIONS - TYPICAL SECTIONS
. CHARLES GEORGE SITE. TYNGSBORO. MA
NOT TO SCALE
/
"
I It
G" TOPSOil'
LlE1NUS
L..JJ CO 1-0 \AI LJr'
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amount of leachate will be addressed as part of the off site
remedial alternatives.
Initial Screening of Alternatives
Each alternative was evaluated for compliance with 40 CFR S300.68
(h) (1), (2), and (3). Specifically, each alternative was screened
on the basis of cost, environmental effects of the alternative,
and acceptable engineering practices. Each was also evaluated
for consistency with any remedial alternative which could result
from the third operable unit in accordance with CERCLA SlOl (24).
The first step in the initial screening evaluated the public health
and environmental effects. Each alternative was evaluated for the
reduction of the potential public health and enviromental risks and
for whether the alternative is sufficient to achieve adequate
control of source problems as required by S300.68 (h)(2) of the
NCP. Preliminary cost screenings followed next and served as a
basis for the elimination of alternatives that far exceeded the
cost of other alternatives but did not provide substantially greater
public health or environmental benefit. (see Table 7). Effects of
the alternative evaluation addressed adverse short-term impacts
against long term gains. The acceptable engineering practices
section evaluated items such as quantities of materials, needed,
implementation timeframe, short term impacts, and reliability of
chosen alternative. Finally, each alternative was evaluated for
consistency with any proposed off-site remedial action.
The following alternatives were effectively eliminated from
further consideration as a result of the initial screening:
No Action Alternative
(Alternative I)
The No Action Alternative has the least cost of all the alternative~
evaluated, the only costs being monitoring costs. This alternative'
would allow the site to remain in its present state. The large
volume of leachate and surface water would continue to impact the
surrounding public health and environment. Because of the nature
of the fractured bedrock it is very difficult to accurately predict
groundwater movement and as a result it is likely that additional
wells may be contaminated in the future, especially if the rate of
leachate production is allowed to continue unabated. The No Action
Alternative would not prevent a continuation and futher expansion
of the erosion gullies with their subsequent potential for direct
contact and/or release of additional contaminants to the environment.
In summary, the No Action Alternative would not be likely to achieve
adequate control of source material-as required by S300.68 (h)(2)
of the N0P.
While off site remedial measures are the subject of the Phase III
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Table 7
Order
of Magnitude Cost Comparison of
Remedial Alternatives
Charles George Site
Tyngborough, Massachusetts
Alternat1ve
Present Worth Cost Est1mate (1985 Dollars)
109
106 107 108
I No Action X
II Partial Soil X
Cap
III Partial Clay X
- Cap
IV Partial Synthet1c X
Membrane Cap
V Full Soil Cap X
VI Full Clay Cap X
VII Full Synthetic
Membrane Cap X
VIII Complete Removal
Source: NUS Corporation, P1ttsburgh, Pennsylvania
-
sss
X
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remedial measure is the elimination or minimization of an ongoing
source of contaminants. The No Action Alternative would not
provide this critical component. The source would continue to
introduce'-l~rge quantities of contaminants into the environment
including the wetlands. As a result, the No Action Alternative
was eliminated from futher consideration because of its failure
to achieve adequate control of source materials as required under
40 CFR S300.68 (h)(1),(2), or(3).
Complete Removal and Off-Site Disposal (Alternative VIII)
This alternative seeks to control further off site contamination
by removing the source i.e. the landfill itself. Aside from the
two orders of magnitude cost differental, this alternative presents
a number of technical concerns which eliminates it from further
consideration. The landfill contains approximately 4 million
cubic yards of refuse and hazardous substances. In order to
remove this massive amount of material, NUS Corp. estimated that
it would require approximately 226,000 truckloads over an eleven
year period of time to complete this task. Non-hazardous refuse
would be trucked to the nearest available landfill or resource
recovery operation and the material deemed to be hazardous would
need to go to the nearest permitted RCRA facility (probably
upstate New York). This alternative would create numerous short
term environmental impacts to the surrounding areas, such as
significant odor and traffic problems, releases of sediments to
wetlands, etc. It is questionable whether such an operation
could be undertaken safely. There is a signi~icant potential for
a fire or explosion resulting from the use of construction
equipment, or spontaneous combustion, due to the presence of
methane from the disposal of organics and anerobic decomposition
of the landfill wastes. This alternative was eliminated from
further consideration on the basis of adverse environmental
impacts and on the basis of cost. The Source Control Feasibility
Study calculated that complete removal and'disposal of the landfill
materials would cost two orders of magnitude more than the next
acceptable alternative. (see Table 7) Therefore this alternative
was excluded from further consideration because of requirements
in S300.68 (h)(l) and (2) of the NCP.
Detailed Analysis of Alternatives
The remaining six (6) alternatives were further screened according
to CERCLA guidance which requires that this screening process be
consistent with 40 CFR Part-300.68(i) (see Table 8). The six (6)
alternatives were screened first using non-cost criteria, which
includes ." Technical Feasibility", "Institutional Requirements",
and "Public Health and Environmental" factors. Next, detailed cost
estimates were developed in order to compare the alternatives on
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Partial Soil Cap (Alternative III)
The Partial Soil Cap Alternative would place a six inch cover of
local soils on the landfill. The cover would extend from the crest
of the landf.ill down the side slopes to an elevation of 225 feet
above mean sea level (MSL). Sections of the landfill would be
regraded to facilitate surface water runoff: the cover would be
seeded to establish vegetation: and a leachate collection system
along the toe of the landfill would be installed. The intent of
this alternative is to retard percolation of precipitation into
the landfill by maximizing surface water runoff and uptake of
moisture by the root system. The elevation of 225 ft. MSL was
selected based primarily on two factors. 'The slopes of the
landfill sides below 225 ft. MSL increase substantially (less
than 3:1) and when the landfill is viewed cross-sectionally it
can be determined that the reduction in area potentially impacted
by precipitation versus the much larger area under the cap
substantially decreases below the elevation of 225 ft. MSL.
The advantages to this alternative is its relatively low cost
and short implementation time frame. The disadvantages are that a
substantial amount of precipitation would be permitted to percolate
into the landfill either through the relatively permeable soil
used as the cover material or through 'the exposed area below the
elevation of 225 ft. MSL. In addition, the area not covered
could provide a direct contact problem. With a design thickness
of six inches, the potential for erosion gullies to appear and
futher expose refuse is significant. This alternative would
permit leachate to continue to impact the ~~. :lands as a result of
soil erosion and leachate flowing into th"~.
Partial Clay Cap and Partial Synthetic Cap (Alternatives III and
IV)
~
These two alternatives are similar to Alternative II e.xcept that
the capping material is relatively impermeable (10-7 cm/sec).
NUS Corp. estimates that these alternatives would reduce leachate
migration. by approximately 50 percent.
These alternatives would produce similar environmental impacts as
the pervious alternative except that surface erosion below the
cap may be more pronounced (precipitation would parallel the
interface between the impermeable layer and the soil overburden
instead of continuing downward into the landfill and would break
out when the cap. ended). This problem may be eliminated by a
more substantial surface water collection/diversion system.
These alternatives are feasible and have a positive effect on the
environment, however both would permit large quantities of leachate
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surrounding area. Similar impacts to the wetlands as Alternative
II can be expected. They also will have the same problems as
Alternative II below the end of the cap. In addition these
alternatives would not minimize nor control air emissions from
the uncapped area.
Alternatives II, III, and IV do not meet the applicable state
standards for landfill closure nor do they meet the requirements
of 40 C.F.R. S264 Subpart G and 40 C.F.R S264.310 Subpart N.
Full Soil Cap
(Alternative V)
This alternative is similar to Alternative II (partial soil cap);
the major differences are that this alternative extends the soil
cover past the 225 ft. MSL elevation to the toe of the landfill and
that the amount of material needed to complete this alternative is
substantially greater. The partial soil cap estimated 24,050 cubic
yards were required to complete the task while this alternative
estimates that 174,050 cubic yards are needed. This alternative
would also require substantial site regrading on the lower slopes
to obtain a slope of 3:1. This alternative is technically feasible
and would provide an improvement to the surrounding environment.
It would, however, permit a substantial amount of leachate to
still be produced as a result of the relative permeability of the
local soils. This alternative as well as Alternative II would do
little to prevent refuse from becoming exposed at the surface or
control continued leachate break out as a result of. the freeze-
thaw cycle typical of the region. The impact to the wetlands
would be minimized, h, re,er there would still be considerable
leachate entering the ~etlands.
Full Clay Cap
(Alternative VI)
This alternative is conceptually the same as Alternative V except
for the type of cover material used. This alternative uses a two
foot thick impermeable clay (10-7 cm/sec) has its cover material.
The clay acts as an umbrella to shed the water from reaching the
contents of the landfill, directs the water to a surface water
diversion channel, and off site. This technique effectively
eliminates precipitation from interacting with the contents of
the landfill and producing leachate.
-
This alternative is capable of meeting the response objectives,
. is technically feasible, and produces a net positive impact on
the environment.. The major drawback to this alternative is the
amount and availability of clay necessary to complete the job.
Camp, Dresser, and McKee (CDM), as part of a pre-design task,
evaluated possible clay sources and other alternatives, such as
benonite or sprayed bituminous membrane. CDM rejected the use of
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a synthetic membrane liner (Alternative VII). CDM's investigation
of possible clay sources indicates that there is an insufficient
amount of clay with a permeability of 10-7 cm/sec available.
The closest source was in Exeter N.H. however the clay only reached
the required. permeability at 100% compaction (100% compaction is
not technically practicable given the conditions found at large
landfills). The impact to the wetlands are substantially minimized
as a result of elimination of :.eachate and surface water runoff.
Full Synthetic Membrane Cap
(Alternative VII)
This alternative is similar to Alternative VI except that it uses
a High Density Polyethylene (HDPE) membrane to provide the
impermeable layer instead of the clay. This alternative meets
all the response objectives, is technically feasible, and has a
net positive effect on the surrounding public health and environment.
It is less expensive than Alternative VI, $17,423,000 versus
$22,047,000, and does not have some the problems inherent with
the use of clays. In addition, less fill material is needed to
complete the project and the project is not as dependent on
weather conditions, as is clay. As in Alternative VI impacts to
wetlands will be substantially minimized.
Alternative VII, which is the recommended source control remedial
measure is consistent with any off site remedial measures that
may be reasonably evaluated. This is demonstrated by the following:
1.
Standard engineering prpctice calls for capping landfills
2.
The cap will not hav~ ;l be removed or replaced to implement
off site remedies~
3.
Reduced leachate generation will minimize off site migratior
of hazardous substances~
Table 8 shows the various costs associated with the alternatives
considered in the final screening.
Community Relations
Appended to the ROD is the Responsiveness Summary (attachment 3),
the Executive Responsiveness Summary (attachment 4), and the
Responsiveness Summary History (attachment 5).
These documents summarize the community's and PRP's concerns and
EPA's responses and the state's comments regarding the entire
project~ Phase I - Installation of the waterline, Phase II Source
Control Remedial Action, (capping of landfill for site closure),
and Phase III - Off-Site contamination and any unresolved issues
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"
,
TABLE R
OIARLES GEDRGF. LAND ROCI.MATIOO 'mwiST LAND"'[LL
'f'nQ;RORXllJ, MA..c;,.,,.: ", ttiF.S'I~I'S
~lmlAL ALTERNI\'''' V";
Present Public He",lth Env i ronnentd I Thchnic",l PlJhl ic
Alternatives Capital tt>rth Considerations Cons iderat ions Cons iderat lme; Cmment
($ mil) ($ mil)
tt:> Act ion 0.92 unacceptable. Cont inoor1 ptn1uct ion StroBJ
~tential for direct of leachate a~ oontam- puhlic
contact wi th exposed ination of surface "'00 resistance.
wastes and leachat~. ~roundwater. llaifi i t iOM I
~tential threat to water supply wells may
City of 1Dwell's wdter 00 ill\);)cted.
supply if presistent
COITpJUnds are relc.1seci.
Partial Soil 2.S 4.0 Reduces anDUnt of Still signiific",nt {J!:;es OJII'IIII.>r I Un.1ccept-
cap. exposed wastes. lbes i~ct to surface and construct ion able to
not minimize air .;,roundwater. Continued techniques. public.
emissions and only degradation to \IIIIIJt1ams.
partially reduces
aroount of leachate
generat ion.
Part ial Clay 8.8 10.3 St i 11 pertnits a Provides a greater fJl;es 0 JIIIIIUI1 unaccept-
su'~tdnt ia 1 reh:ase reduct ion in leachate engineering able to
to groundwater w't:h generat ion than practices - publ ic .~s
subsequent contanr p~vious alternative. nnre d if. ficu t t they prp.-
ination of watl~r to illt> lement . ceive it
supply wells. than Alternative as on 1 y
II. halt ,"
reso lution.
, It
-------
Present Public Health Environncntal Technical Puhlic
Alternatives Capital ~rth Considerations Considerations Cons iderat ions Can"ent
----
IV. Partial 7.2 8.7 Simi lar to Similar to Similar to Simi Iar to
synthetic previous previolls previous previous
mermrane cap. alternative. alternative. ,,It.'~rnative. alternative.
V. Full soil cap. 4.9 6.5 QJvers all Still permits a O:moon erg i -
exposed refuse. substantial amr~nt neerirg practice.
lbes not mini"": .'" of leachate to he
air emnission. generated with its
i~ct on t.he ~urface
and groundwater..
VI. Full clay 16.8 18.4 Reduces potential Minimizes leachate lSeS ccmron erg i - Preceived
cap. threat to grourrl- generation. Controls neer.ing methorts. as desirahle
water and surfaces release of ai r hy cannunity.
to extent practicable. ernnissions.
13.6 15.2 Simi lar to Simi lar to . fJsP.s CCI1I'OOO ~rceivect
VII. Full syn- AI ternati ve VI. A.l ter.nat i ve vt. ergineerirYj as d~si r.,hIe
tOOtie Mem- techniques. by cO'mlun i ty.
brane cap.
VII I. (bnplete 104
renoval.
I ,.
965
Causes major short
tenn impacts to public
health arrl environment.
Alternative may
produce IOOre harm
than good as
contaminants may be
released during
excavation.
. 'I
Prece i vetl by
comunity as
caus ir"}!] to
ITUch disrup-
. lion t.O loea 1
area.
1echnically
feasible
however not
practiable
due to large.
m..mer of .
vechic1es arrl
aoount o[ time
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In general, the pubIc recommended that a full cap of impermeable
material along with the necessary components to control the
migration of leachate and air emmissions from the landfill be
implemented, as soon as possible. Residents recommended that
drummed hazardous waste be removed before construction of the
cap. Some community residents in the Flint Pond areas suggested
that more concentration be placed on controlling soil erosion
during construction into Flint Pond Marsh via the Route 3 culvert.
These source control technologies are offered by Alternatives VI -
Full Clay Cap and VII - Full Synthetic Membrane Cap.
The Dunstable Town Board of Health Summarized its concerns in three
areas: (1) They would like more testing of the aquifer on the West
side of the landfill, (2) Insure capture and removal of the organic
gases from the landfill, and (3) a complete capping of the landfill
with a material of the low permeability. Answers are contained in
the Responsiveness Summary, attached.
The state selected Alternative VI and VII as their recommendation.
The determining factor for their final recommendation of either
Clay or Synthetic Membrane Cap was the availability of a clay
source.
CONSISTENCY WITH OTHER ENVIRONMENTAL LAWS AND REGULATIONS.
Environmental laws which may be applicable or relevant to the
source control action proposed are as follows:
- Resource
o. 3ervation and Recovery Act (RCRA), Part 264
- Executive Orders 11990 (Wetlands) and 11988 (Floodplain)
Guidance outlined under 40 CFR Part 6, Appendix A.
- Clean Water Act
."
- Clean Air Act
Safe Drinking Water Act
The proposed alternatives were reviewed for consistency with
applicable RCRA technical standards, specifically 40 C.F.R. S264
Subpart G entitled Closure and Post Closure and 40 C.F.R.
S264.3l0, Subpart N, Landfills entitled Closure and Post Closure
Care. The cap will be designed in accordance with Section
264.310(a): .
1) Provide long-term minimization of migration of liquids
through the closed landfill.
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3) Promote drainage and minimize erosion or abrasion of the
cover.
4) Accomodate settling and subsidence so that the cover's
integrity is maintained.
5) Have a permeability less than or equal to the permeability
of any bottom liner or subsurface soils.
The cap installation will be performed as specified in S 264.303.
The landfill will be surveyed and a notice will be placed in the
deed and to the local land authority as specified in S 264.119
and S 264.120. The applicable closure requirements in S 264
Subpart G will be addressed. (Decontamination/Disposal of
Equipment, Certification by Professional Engineer, and Site
Security will be provided as specified in S 265.1l7(b». Post
Closure Care and groundwater monitoring will be performed in
accordance with 40 C.F.R. 264 Subparts F and G and Subpart N
264(b).
Wetlands Impacts
As noted previously, a preliminary Wetlands Assessment was performed
and is appended to this ROD. Alternatives in the Source Control
Feasibility Study were evaluated for possible wetlands impacts in
accordance with Section 2 of the Executive Order 11990. The assessment
determined that impacts to the wetlands as follows: No Action -
this alternative would not eliminate any wetlands howE.ver the
leactat~ would continue to impact the wetlands unabated. Complete
Rem~al - this alternative would effectively eliminate the wetlands
adjacent to the site on the short term, however the potential for
restoring partial wetlands to the 69 acres could be part of the
remedy. The remaining alternatives (II-VII) will have similar
impacts on the adjacent wetlands with the exception of varitior
leachate impact. All of these alternative will require the ins
of a leachate collection system. This system will destroy a r.
small wetlands (on the north side of the landfill) however the
pre-design of the cap will compensate for the loss of this partlc.,
area by establishing a larger wetlands to the south of the site.
As described previously the only alternatives which will significantly
reduce quantities of leachate generated by the landfill are the
full capping options. As the following section describes the
recommended option will be a full impermeable cap.
As has been repeatedly discussed throughout this ROD, off site
wetlands impacts will be additionally evaluated in the Phase III
RI/FS.
Since the source control remedy is not considered a final remedy,
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EPA is not addressing the issue of groundwater remediation. This
is to be studied in Phase III of this project regarding offsite
contamination.
Recommended Alternative
As shown in Figure 3, Alternative VII is a full synthetic membrane
cap with surface water diversion. and collection, a full peripherial
leachate collection system, gas collection and venting, and
establishment of 3:1 grades where required. This alternative is
the one recommended by EPA as "the lowest cost alternative that
is technologically feasible and reliable and which effectively
mitigates and minimizes damage to and provides adequate protection
of public health, welfare, or the environment" 40 C.F.R. S300.68
( j ) .
Alternative VII, as stated previously, meets applicable and relevant
local, state and federal regulations for site closure (40 CFR 264
subpart G and N) and CERCLA regulations as set forth at 40 C.F.R.
S300.68 of the NCP. Alternative VII is acceptable to the public.
As has been stated throughout this ROD, the selected alternative is
for source control and is not the final remedy which will address
off site contamination and will be the subject of another ROD.
A tabulated summary of annual operation and maintenence (O&M)
costs and capital costs with description of each for Alternative
is given below.
O&M Costs for Recommended ylt~rnative
- Cap
- Peripheral Leachate Collection System
18,235.00
23,577.00
"
- Gas collection system
5,340.00
- On-site surface water collection system
- Temporary on-site diversion system
13,100.00
9,000.00
- Renovation cost
component
10% of capping
Note: (Figures assume a major renovation will be necessary to cap
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CAPITAL COST FOR RECOMMENDED ALTERNATIVE
Component
Costs
Basic Costs
Present Worth
Cap
11,836,494
-15,442,000
Temporary onsite surface water diversion
41,101
On site surface water collection
Peripheral surface water collection
264,189
194,532
Leachate collection
833,439
332,631
Gas collection system
Dumpster clearing and removal
111,339
o & M activities associated with the implementation of Alternative
VI are as follows:
- Annual mowing and maintanence of the vegetated
quarterly inspection of the following:
- pump station
- leachate collection/recirculation system
- cap surface.
surface.
State Role
The state's role in this federal lead site is multiple.
The state reviews documents to determine whether they are in
compliance with existing state laws. The state will provide 10%
of the costs of the on-site remedy and will assume reponsibility .
for the long-term 0 & M.
- .
Milestones
List of key milestones for project implementation: - Complete
. enforcement negotiations Approve Remedial action (sign ROD) -
Award Superfund state contract (and lAG) for design - Start design
- Complete design - Award/Amend Superfund state contract (and
lAG) for construction - Start Construction - Complete constructio~
Future Actions
As not~d previously the objective of this ROD is the implementation
of source control measures. There are a number of issues relative
to off-site impacts that will have to be resolved prior to the
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These actions include;
- completion of the offsite RI/FS. Presently, the field portion
of the RI has been completed. A risk assessment will be finalized.
Review of the Existing data indicates that the landfill is
significantly impacting groundwater and surrounding surface
water. Data collected to date is inconclusive to define the
extent of contamination in the fractured bedrock aquifer
surrounding the site. Additional monitoring wells, sampling
and analysis will be needed in order to reasonably characterize
off-site groundwater alternatives. A similar effort will be
required for the Flint Pond Marsh wetlands. A definitive
scope of work for this additional effort has not been finalized.
- Development/signing of an off-site ROD. Based on information
resulting from the completion of the Phase III RI/FS the
agency will need to complete a ROD which minimizes and
mitigates the migration of hazardous substances off-site.
This ROD will also address any additional source contol
issues that might need to be resolved as a result of the
post closure monitoring program. - Development and.
Implementation of a Post Closure Monitoring Plan. As part
of the design resulting from this ROD a post closure monitoring
plan to determine the effectivenss of the source control
measures will be developed. This plan, once approved, would
be implemented, however, it is reasonable to assume that
upon completion of an off-site remedial design another post
closure monitoring plan incorporatin~ and modifying sections
-------
PrelUninary Wetlands Assessment for the Charles George
Land ReclClTlation Trust Landfill, ~sborou;;;h, Massachusetts
Q'\ May 22, 1985, Richard Leighton, EPA ~ion I remedial site project officer, aro
Matthew SChW1eisberg, EPA Region I W1etlar.ds progrCITI staff, visited t!'1e Charles George
Larofill site located in Tyngsborough, Massachusetts. 'Ihe purpose of this site
visit was to perfoIm a preliminary assessnent of the wetland areas both on- aro off-
site which may be impacted by remedial actions taken at the site. A9sessnents of
this nature are based solely upon visual observations and typically include:
o a general characterization of wetlan:l vegetation CCNer types:
o a general characterization of hydrologic features: and,
o an evaluation, based upon visual observations, of the level of disturbance
to the wetland area fran tunan-caused factors ( typically referred to as
degrcdation) .
'!he resulti~ prcrluct of the investigation was to be a report assessirg the pote~
tial impacts upon the wetland areas of the p)SSible remedial alternatives as
described in the draft source-oriented feasibility study (March 1986). '!hat
assessment follows.
Cbservations :
"
W:! began OJr visit on the north side of the lardfill. A small wet-Ie d area (Area 1
on the attached map) was found that beg. ~ at the toe-of-slope arx ~fa: lows the land-
fill linearly for abo.1t 10Q feet. '!his wetlan:l area exten:ls l!Itla'J fran the lan:lfill
for about 75 feet, trough its width only reaches about 70 feet at its widest part.
The ranain~ wetlan:l continues as a narrow strip about 50 feet 101'9 an:l it extems
10 feet away fran the landfill. In total, the area encaapasses approximately 4,000
square feet. starrlirg water was present anj was aboot 2-4 inches deep in the ce~
ter of the wetland. '!he principal source of this water appeared to be fran land-
fill runoff. Plant species observed include cattail (~ app.), horsetail
~~;:~~ ~:i~e:':te~~.!ftT, V=i~;)';il~: ~t~x =:a)~~~~:~;~
colored leachate was evident in the water and an oily 1IIiiI was present 00 the water
surface, a few green fregs were cbseIVed as well as s::me passerine bird species
(red-wirged blackbird) usirg this area. Q1 the vtx>le, this wetland area did not
appear to be degraied despite the presence of the lamfill.
'!he next wetland area (Area 2) that was foum is located 00 the southwest side of
the lamfill. '!his area begins at the toe-of-slope am follows the lan:lfill line-
arly for about 300 feet. It exteros away fran the landfill for about 1,000 feet ~
it gradually narrows down to a width of abwt 50 feet. In total, the area CCNers
. approximately 2-3 acres. Near the landfill, a vegetated area exists canprised
primarily of cattail. 'Ihe area then becaaes open water (about 4 feet maxiDn.m in
depth) . The open water grades into a forested swanp, J'lK)Stly CCJVered in 8tarxUrg
water of abaJt 1-2 feet in depth. '!he source of the water was not readily evident.
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areas not subnerged, marsh fern (DryOpteris thelypteris), sensitive fern (cnoclea
sens ib il is), blue. flag, am swamp-pi nk or pi nk lady's sli ppe r (Arethusa bulbosa).
While walking this area, we flushed 5 mallards. In addition, numerous aquatic
insects were seen in the water. Sane sign (tracks) of deer was observed also.
This wetland area appeared not to be affected by the landfill.
Pt:wing toward the western em of the lamfill, we fourKl two anall strecSnS (Area 3),
one perennial and one inteanittent. Both streams originate at the toe of the land-
fill am flow away fran it. The intexmittent stream eventually flows into the peren-
nial stream. The intexmittent strec:wn, Wiich was dry,' is vegetated along its course
~:n::il srre~e~~f o~i~e af;:l~~= ~~~~~t(~~~Al~:ti1~) ~u~
it is vegetated with tDrseta11, blue flag, skunk cabbage, sensitive fern am red
maple.
The perennial strec:wn appeared to flow into a wet meadow (Area 4) behim.-an abamoned
rouse (this property belongs to Mr. Charles George) Wiich is adjacent the lamf11l.
Eventually, water fran the wet meadow flows to the west am enters D.Jnstable Brook.
The wet meadow is canprised of sane small black willow, sensitive fern, and purple
looasestrife (Lythnm salicaria). This wet meadow ccweIS an area of appradmately
2,000 square feet. It is probably seasonally wet, OOiwever, there was no water
evident while we were present. These strec:wns appear to be unaffected by the lam-
fill.
on the norttM!st edge of tb> lamfill, a retention basin enpties (thrcugh aI.
undergroum channel or culver. (?» into a stream (Area 5) Vtich appears above
groom on the opposite side of D.Jnstable lb:Id. tsachate was evident in this strean
until its confluence with DJnstable Brook app:oximately 100 feet £ran the roadway.
'At the confluence, the leachate is sufficiently diluted so as to make it visually.
undetectable. DJnstable Brook had a IIDderate volune of flow (approximately 5-10 .
cfs). '!he banks of the Brook's caJrse are vegetated with ]/ellow birch, black
willow, red maple and various herbaceous species. Although flow was fairly rapid,
large 81'11.)unts of algal growth were evident in nmstable Brook. Also, a duck (mal-
lard?) was flushed just downstrec:wn of the confluence. Other than the leachate in
the snaller strec:wn cx:ming fran the lamfill, no ~cts upon the brook were cb-
served .
Finally, we vfsited Flint ForD marsh (Area 6) which is located to the east of the
lamfill across RJute 3. Flint ~m marsh is a large (>20 acres) 8Dergent wtlam "
conplex primarily daninated by cattail. Other plant species present include purple
loosestrife, yellow pond-lily (~ var~at\ID) and black willow. IBachate fran
the lamfill enters this marsh~h verts Wiich nm beneath lO.tte 3. ~"
observed that fJ fringe area of the marsh nrmirg linearly along the highway appears. .
to be dying (browned-out fran lardfill am/or road salt impacts?). .
Discussion:
Accoroing to the draft feasibility study, eight possible ranedial alternatives
exist for addressing clean-up of the lamf111. 'Ihese possible alternatives rarge
fran no action to partial cappirg to canplete excavation am reteVal. '!be potential
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-3-
Obviously, the no action alternative would have no direct Unpact upon the wetlands
ot~r than to maintain the current situation. N3 this alternative would pel:!T\i t
larofill leachate to continue to enter the wetland areas, lo~-term Unpacts might
prove unacceptable.
partial cappi~ of the site, either with soil, canpacted clay or a syn':hetic membrane
would not directly impact the wetland. ftJwever, the activities associated with
installation of the partial cap and leachate collection system would have definite
impacts upon wetland areas 1, 2, and 3. Strict sedimentation and erosion control
measures would be required to minimize these impacts.
A full cap would have a direct impact upon wetland areas 1, 2 and 3. 1b achieve
prc:per side slc:pes for the cap, placement of fill probably would eliminate most or
all of area 1. As the slope of the landfill is rrore gradual by areas 2 and 3, only
a snall portion of these areas might need to be filled for placement of the cap.
In adpition, with installation of a leachate collection system surrounding the
laoofill at the toe-of-slc:pe, the possibility of eliminatirYJ the primary source of
water for areas 1 and 3 would be high. As the source of water for area 2 was not
evident, it is unclear what impact the leachate collection systan would have on this
wetland area. Further, elimination of the primary source of water for area 3 might
impact area 4, altrough area 4 is located sane distance fran the laoofi11- arD the
level of such an impact is unknown. CappirYJ and installation of a leachate collec-
tion would eliminate the leachate strean (area 5) runnirYJ fran the on-site retention
pond to nmstable Brook. As a full cap would renediate the problem adequately, it
probably is a viable alternative.
.'
Canplete excavation and rem:>val of the 1800fill would result in ..i~~1ificant :i5-
turbance to wetland areas 1, 2, 3, and 5, even if care was taken regardirYJ erosion
aoo sedimentation controls. In all likelitDcx1, areas 1, 2 am 3 wcW.d be effectively
eliminated. AlttnJgh this alternative would meet RCRA requirEments, the impacts.
upon the wetlaoos clearly are rrore significant than ttDse fran installation of a'
full cap. -
:
Conclusions and Recxmnendations:
Full cappirYJ appears to be ~ roost preferable alternative fran a wetlaoos impact
perspective. AlttnJgh areas 1 and 3 probably would be eliminated, these areas are
small aoo relatively insignificant. Area 2, the only 100ellarXI of significance which
would be directly impacted, probably would not suffer greatly particularly if the
lamfill CQ1ld be cut back ore it abuts area 2 prior to cappirg. In addition,
careful erosioo and sedimentation controls would need to be implemented. Further,
Area 5 could be used to mitigate the probable loss of areas 1 and 3. Area 5 could
be extended aoo widened at 'its far end away £ran the 1400£111, possibly including
placement of ~ water control structure to maintain adequate water level within the
wetland. ftJwever, in teIJ1\9 of mitigating for these wetlaoo impacts due to the
source control remedial measures, develqment am implementation of an actual
mitigation plan srould be delayed and addressed as an integral part of phase III,
the remedial investigation am feasibility study which will address off-site
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"
.\ -
-'
-4-
While performing the phase III RIfFS, a more thorough ard detailed wetlands assess-
ment should be penormed. This additional assessnent should include a more trorough
characterization of the vegetation, hydrology, soils and wildlife present in the
wetlan:i area (or toose that rEmain). Based up:>n this IOOre detailed assessnent ard
the potential off-site remedial alternatives, an adequate wetlan::i mitigation plan
can be develq>ed.
"
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F
ATTACHMENT 2
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List of Potentially Responsible Pa~ties for the Charles George
Reclamation T~ust.
Cha~les Geo~ge, S~.
Tyngsbo~ough, MA.
Dorothy Geo~ge
Tyngsborough, MA.
James George
Tynsborough, MA.
Karen Karras
Ipswich, MA.
Charles George, Jr.
Tnysborough, MA.
Charles George Trucking Co.
U. S. Coast Guard
Boston, MA.
Browning- Ferris Industries
Tyngsborough, MA.
- -
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. a:U~",>l t~
r'\
JRNUS
_tJ LU"lPOR/\TON
J) A Halliburton Company
. RESPONSIVENESS SUMMARY
CIIARLES GEORGE SITE
TYNGSDOnOUGlI, MASSACIIUSETTS
EPA WORK Af;~IGNMENT NO. 54-1L16.2
NUS PROJECT NO. S166 (0166)
JUNE 1905
rEM
~O.
ISSUE' CONCERN
RESPONSE
tt
During the Remedial Investigation fteld
study, an atteMpt was made to idootify
the landfi11 gas composit1on. Samples
were taken dfrectly from the landfill
gas vents in July 1984 to determine the.
composttion of" landf111 gases. On
October 19, 1~84, samples were again
taken from the vents, as well as upwind
(northwest of the 51 te) background
pofnts, points between the landfill and
the Cannongate Condominiums, and from
points near the Cannongate buildings;
I t must be emphas1 zed that the October
sampling was not an attempt at a
definitive atmospheric study, but merely
an at tp.mpt to determi ne re 1a ti ve
concentrations of volattle organic
compounds wi thin the. vents and the
surrounding area. The results
demonstrated that on October 19 the
nUmb~r of vol~ttl~ organic contamfnants
'''I'! ,;,,,Ir ,-,.",..."I-f-fl(;' "f;'"'''''' ,"III '1;
La.
GAS [MISSIONS/PUBLIC IlEALTIl
Organic compounds are escaping to the
afr around the site; the odor fs
noxious, especially during heavy fog.
Is there Iny program planned to study
the effects on children or commuters in
the local areal These individuals may
be part1cuhrly susceptib1e to the
gases, since they typfcaHy must stand
for extended pertods of ttme watttng for
bdses 1
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c
:'""'\
f,\.
~
IRNUS
jj ccr-POAATON
~ A Halliburton ~p~ny
.RESPONSIVENESS SUMMARY CONTINUA TION
CHARl~ tEORGE SITE
TYNGSO'ORouoff. MASSACIIUSEnS
JUNE 1985
I rAGE..L OF 59 I
EM
10.
ISSUE' CONCERN
RESPONSE
No detailed atmospheric study has been
dorie at the site to date. Addittona1
studies wl11 be done by CDM In order to
deftne rates of flow and concentrations
of const ituents in gases emi tted from
the landfi11. These studies, however,
wt1l be directed toward defining
parameters usefu1 In designing lhe
landfill venting system, and wtll not be
direct1y app1icable to eva1uatlon of
hca1lh rtsk.
...
At the present time. the need for more
specific studies to eva1uate the
potential health riskS associated with
breathing the air around the landfill Is
being studied by the EPA. It Is I known
fact that under certain atmospheric
conditions (e.g.. inversions), the afr
qualtty In the site area 15
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(- \ . .. ,
RESPONSIVENES~ SUMMARY CONTINUA T/~,V
. .
JR\I\HUS
~ ca:PORA-roN
o A Halliburton Company
CHARLES GEORGE SITE
TY~!GSBOROUGH. MASSACHUSETTS
JUNE 1985
, PAGE -L O~I
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TEM
NO.
ISSUE' CONCERN
RESPONSE
The present phn w111 be to prevent
landf111 gases from being released
directly to the a1r by 1nsta111ng a gas
venting system. Approxtmat~ly 17 gas
vents have been suggested w1th the full
capping option. Each of these vents
could be fitted with its own treatment
unit. or individual vents could be tied
together via a manifold system with
centra1tzed treatment. COM w111
evaluate the number, she and location
of vents requ1 red. end wUl further
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~~~
RESPONSIVENl:SS~SUMMARY CONTINUA TIC~
. .
CHARLES GEORGE SITE
TYNGSBOROUGU, MASSACIIUSETTS
. JUNE 1985
t A Halliburton Company
I PAGE -L- OF M....I
M
t.
ISSUE' CONCERN.
RESPONSE
- -"'t--
.b.
Uave you looked at harmful effects from
the gases emt tted from the hndft11:
heve you considered harmful effects
IndIvIdually and in combination?
The aIr sampling done to date was
Intended on1y as a pre1imtnary
Investigation. not necessarily designed
to deftne whether a public health threat
exists at the stte. As such no one can
expect a defini tt ve response to the
question of potentill off-site public
heal th 111pacts via Inhl1lt10n of gases
from the landfi11.
However. the Char1es George S1 te
Remedia1 Investlgat10n Report wl11
contain a chapter devoted to def1nlng
present and potentta1 heallh risks
associated with uncontrolled movement of
con tam 1 nants from the site to the
surrounding area. The atr quality data
w111 be reviewed with respect to the
specHic species of gases present.
W1 thin the constr.ints of the data.
given its qualitative nature.. discussion.
wfll be provfded wh1ch'wll1 tonsfder
additive potentill hel1th effects of
each compound. Considering their
effects to be addU he. II Hhough thts
may not be the actual case. 15 a
conservative approach which follows EPA
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~~~~.
) " Halliburton Company
RESPONSIVENES5JSUMMARY CONTINUA TICJJ
CHARLES GEORGE SITE
TYNG5DOnOUGtI. MA55AClIU5ETTS
. JUNE 1!J85
, rAGE -L OF ji.. I
--. ~. ----...- ....-
M
t.
ISSUE' CONCERN.
RES.PONSE
..
In connection with each 0' the remedtal
alternatives identified in the Source-
Ort cnted FS Report. ga ses w t 11 be
collected via a venting system.
Col1ectlon of gases in this manner
provides the opportunity' ior the t r
treatment prior to being discharged to
the atmosphere, either at each vent
location, or at a common location wllh
all or a portion of thee vents tted
together through I system of piping.
The deciston to tmplement treatment has
not Yl!t bel!n finalized. Additional
studies may be done In conjunction wllh
the study of off-sUe relledlal actions
(Phase III), which ~ould be useful to
EPA In evaluating the need for
treatment.
. c.
Wi 11 the gases continue to be released
Into the air, or will they be vented or
collected onslte1
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Fl~~;JS
~ CCA='ORAT1ON
A Halliburton Company
RESPONSIVENESS"'SUMMARY CONTINUA 1"/lP-V
CHARLES GEORGE SITE
TYNGSDOROUdU. MASSACHUSETTS
JUNe 1985
I rAGE -6- OF.5L I
v1
ISSUE I CONCERN
RESPONSE
d.
Clin you provide a qualitative
descr1pt ion of the contents of the
hnd(t11 !}ases 7
Vent sampling in both July and October
1984 provided a qualitative assessment
of the constituents of t.hc lond(111
gases. The more prevalent gases found.
1n the vents have been noted below 1n
declining order of magnitude:
. Vinyl chloride
. Chloroethane
. Methylene chloride
. Acetone
. Carbon disulfide
. l,l-Dtchloroelhane
. Trans-l,l-d1chloroethane
. 2-8utanone (MEK)
. l,I,I-Tr1chloroethane
. Denzene
. 4-Methyl.2-pentanone (MIOK)
. Tetrachloroethene
. Toluene
. Chlorobenzene
. Ethyl benze,..c
. Xylenes
. 1,2-D1chloropropene
. Trichloroethene
. Chloromethane
. l,l-D1chloroethene
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r----
IRINLBS
JJ CCFPOAATION
b 1\ Halliburton Company
RESPONSIVENES{SUMMARY' CONTINUA TI('~
CItAR"~S GEORGE SITE
TYNGSOOROUGff. ~ASSACfIUSE1TS
JUNE 1905 .
I rAGELOf~_i
:M
o.
ISSUE I CONCERN
RESPONSE
.e.
What causes the odor 1n the glses7 It
is especially not1ceable when drtvtng
810ng Route 3. .
The odor In the gas em1tted from the
landfill Is produced by the presence of
compounds which have artsen from the
breakdown of organic rcfuse 1n the
absenco of oxygen. Such compounds
Include sulfides and merclptans. As an
example. hydrogen sul fide is typically
referred to as "rotten egg gas".
Mercaptans are i c1ass of organic
compounds whtch possess a sulfhydryl
group and may readt ly form sul fides or
di sul fides. Carbon dtsu1fidfl was found
In numerous samples froM the stte. whtle
. methyl disulfide was found In vent
samples.
The Charl es George landft11 Is not
unique tn producing these types of
gases; they are typicil of off-gases
from Iny landfill whtch his accepted
sant tary . wastes.
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EF1N~S
D LD~RATION
) A Halliburton Company
RESPO NSIVENES!'''S U M Mj{'R Y, CONTINUA TIC'f\J
CHARLES GEORGE SITE ' ~ '>:::,..:' ".: "', /:: ,i, : ",\';~4..~
TYNGS~OROUGH. MASSACHUSEns ,;,e: ,'c,::':', :.!'.:~X1:"}~';',~,~ . e; it I: .' '\ '
JUNE 1985 . ,~.," ,;- ';:'~r"~::}""'~ '. ~ . ,.,
. .' '.', ~'. ".~' "'1'~J,l...~. '. . f:t'. :'1'."
,"
.,
. i '
RESPONSE i
:M
o.
ISSUE' CONCERN
.r.
Can you explain the venting and
treatment process? Would the treatment
ellmfnate the noxious odors?
As shown in figures 2-5 through 2-7 In
the draft Source-Oriented fS Report. a
typical vent insta11atfon would consist
of a length of 4-1n (O.D.), perforated
plastic pipe. This pipe would extend
from a zone of gas generation deep
within the Jandfill to I crushed stone
gas collection layer which wfl1 be
p1aced on the present landfill surface.
Oxygen from the air t s unab 1 e to
penetrate very deeply Into the 1andfl1l
and will penetrate even less after the
landfl11 Is capped. As organic
materials break down within the landfill
In the absence of oxygen. compounds such
as mercaptans and sulftde and methane
- gas are generated. The landfill vents
will tap these zones of gas production
and provide II route for controlled gas
migration to the surface. Gases from.
zones not directly tapped by the"plastlc
pipe vents will migrate upward and will
come Into contact with the crushed stone
layer Immedlatoly underneath tho
landfill cap. This crush~d stono layor
will fac11ttate lateral movement of the
gases until they encounter a vent.
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tRtl\nUS
o c;o::PORATON
, A f-fnlliburton Company
'RESPONSIVENES~' SUMMARY CONTINUA TICN
(ItAnlES GEORGE SITE
TYNGSD.OROUGII. MASSACtlUSETTS
JUNE 1905
I~~~~~~~~_I
--....--- -.-- ..._-.....-
----.----...
M
).
ISSUE I CONCERN.
RESPONSE
The gas vent will be an unperforated
length of 4-in plastic pipe above the
crushed stone gas collection layer.
Aftei the gas enters the unperforated
portion of the vent it may be either
discharded at the open end of the vent,
or it may be collected along with gases
from other vents for treatment at a
common point.
Treatment will include the use of
activated carbon filters, which will
eliminate the noxious ordors in the
landfill gases. These odors are caused
by. mercaptans and sulfide gases. The
other volatile organic gases that
accompany these malodorous compounds
will also be eliminated from the
landfill gases by treatment.
However, additional studies need to be
conducted before it is determined if
treatment of the vent gases is .necessary.
As one of the tasks for the Phase III,
EPA is in the process of developing a
quantitative air monitoring plan. The
results for the study will be included
within the Remedial Investigation
scheduled to be completed Fall of 1985.
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RN;JS
J co=PCAATON
A Halliburton Company
RESPONSIVENESS"SUMMARY CONTINUA TIOl
CHARLES GEORGE SITE
TYNGSBOROUGtI. MASSACHUSETTS
. JUNE 1985
'"
I PAGE..!Q... OF]L I
'.
ISSUE' CONCERN.
RESPONSE
g.
00 gases coming from the landfill vents
pose Iny fire hazard?
Gases emitted from the existing landfill
vents. as well as those which may be
collected and dtscharged from the
proposed gas venting system. do not pose
a fIre or explosion hazard. Methane ts
an explosive gas under certain
conditions. How.eve... in order to pose a
rtsk of explosion the methane must be
confined so that the gas can concentrate
to exploshe levels. These conditions
do not extst at present because of the
ease with which the vent gases can mix
wtth the ambtent air.. In destgning the
venting systeM. adequate precauttons
wtl1 be taken to ensure that the rtsk of
fire or explosion ts eliminated.
I
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m~~s
lJ a:FPOAATON
) A Halliburton Company
RESPONSIVENES[" SUMMARY' CONTINUA T/lV
CHARLES GEORGE SITE
TYNGSBOROUGH. fv1ASSACItUSETTS
JUNE 1985
, PAGE l.L OF .M...I
.__a_.
EM
O.
.'
RESPONSE
ISSUE I CONCER~
.h.
An adequate atmospheric study has not
been done at the site to fully
characterize air flow patterns.
including seasonal. diurnal. and
recurring welther patterns. The lack 01
this data renders the air sampling data
meaningless.
",
There has been no effort to'date to
conduct an atmospheric study at the site'
which would yield data essential to
defining local climatologtc condi tions.
The 1imtted data co11ected to date
include wind speed and direction and air.
temperature. These data have been
collected by a portable meteorological
statton whtch has been in place at the
landl111 since September 1904. A
continuous recording rain gauge was
placed onsite at the salle time.
The da ta obta i ned from the on 5 He
recordtng tnstruments. coup1ed with
historic data..from weather staUons in
the local area (Nashua Airport. Hanscome
Field. University of Lowell) will be
used to develop I preliminary
. understanding 01 local weather patterns.
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IF1N~S
JJ CCA=DRATON
) A Harriburton Company
RESPONSIVENESS-"SUMMARY CONTINUA Tla~.1
CHARLES GEORGE SITE
TYNGSBOROUGH. MASSAC.,USETTS
JUNE 1985
I PAGE...!!.. OF ~ I
EM
10.
ISSUE' CONCERN
,"
RESPONSE
o' I .
The sampling methods used to c011ect
ambient at r samples are inappropriate.
Rather than adsorbent tubes, the
. sampling orifice should be large, with
air drawn through the collectfon chamber
over a significant perfod of time and
under a11 prevatling weather conditions
and air flow patterns.
'0
Sampltng methodology, IS well as sample
handling and shipment, followed EPA-
approved protocols and was fully
documented fn notes taken in the fIeld
at the time of sampling. .
The use of adsorbent tubes wIth
ca11brated pumps operated over the time
periods employed in the field study Is
based on the accepted literature and is
an accepted practice in the fteld.
Articles of literature which support
these sampling methods fnclude
.Compendtum of Methods for the
Determination of TOXIC Organfc Compounds
In Ambient Air. (EPA Document No. 600/4-
84-041, April 1984) and .Organlc
Solvents tn Air. (NIOStl Manual of
Analytical Methods, Second edition.
Volume I, Oepar~ment of flealth.
Education and Welfare pUb'fcatton No.
77-157-A). The use of .hlgh-vot
samplers, which draw high volumes of
sample per unit time through a large
diameter orifice and across I cel1ulose
filter, ts restrlctod to those
situations where the contaminants of
Interest are particulates or chemicah
adsorbed to the surface of particulates.
1h1s Is not the case at the Charle
George Site. where the contamlnan' t
r f') n, ,.. t." f ':. \J',\ 1 " , f 1" ...,..~ n" n , .. ....:- ~ ,... ~
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.~~y~
o A Halliburton Company
RESPONSIVENESS SUMMARY CONTINUATION
CHARLES GEORGE SITE
TYNGSBOROUGH. MASSACHUSETTS
JUNE 1985
I PAGE...!L OF~ I
ITEM
NO.
ISSUE I CONCERN
RESPONSE
The limited duration of the field study
permitted during the RIfFS and the
availability of analytical resources
through the EPA Contract Laboratory
Program did not allow the collection of
air samples during all prevailing
weather conditions and air flow
patterns. In addition, such
characterization was not considered
necessary in the context of the
prel iminary study.
.0
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F1NLJS
iJ a:A='ORATON
, A Halliburton Company
. RESPONSIVENESS-'SUMMARY CONTINUA TIU-~I
CHARLES "EORGE SITE
TYNGSBOROUGH. MA5SACttUSETTS
, JUNE 1985
, rAGElLOFM-1
.
t.
ISSUE I CONCERN,
RESPONSE
M
j.
Does prox1m1ty to the 51te create any
haurd to the restdents at the present
time?
Before the f1e1d 1nvestfgat10n was
started. a health and safety
reconnaissance was conducted using an
Instrument (HNu) sensittve to the
presence of volatile organtcs tn the
air. The s1te was a1so surveyed using a
meter. ..capable of identifytng the
presence of any'radiatlon.
Based upon the reconnaissance, the level
of persona1 protection deftned for the
pe rsonne 1 who perforMed the site
investigation work did not require the
use of any respiratory protectton,
except for activittes which tnvolved
co11ect1ng samples frOM the leachate
sumpS on the eastern and western
peripheries of the landfi11. The latter
was required because these sumps are
enc10sed spaces where gases may
accumu1ate.
Ana1yt1ca1 data froll the site
tnvestigatton, as we11 as hea1th and
safety surveys of the s1te area do not
. tnd1cate that the sHe presents an
imminent threat to residents 1n the
surrounding area. The degree of hazard
posed by the site 0" a chronic basts
(years) wtll be evaluated tn the rtsk
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~~~
) A Hallibur10n Company
RESPONSIVENES~'5UMMARY C.-UN I 11VUJ.\ , '.l' ".V
CHARLES G£ORGE SITE
TYNGS80ROUGU. MASSACIIUSETTS
JUNE 1985
\ rAGE 2i.. OF L 1
RESPONSE
EM
o.
ISSUE' CONCERN
~. a.
At TtRHATE VATER SUPPLY (PERMANENT VATER
LINE) .
The permanent water line to be
constructed. from the North Chelmsford
Water District In lowell, Massachusetts.
to the Cannongate area has been designed
with capactty 1n excess of that required
at the present time. If residential
we 115 a long Blodgett Road, or, for tha t
matter, along Dunstable Road northwcst
of the site. wer.e found to be
contaminated as a result of the Charles
.George Site adequate capacity exists to
p..ovl de a permanent al ternate water
supply.
If wells are found to be contaminated
Horth of Blodgett Road, will the present
. water line be extended?
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n
RNUS
J a::A=DRATON
A I rlll/ihurton Company
,- '\ ,t'"")
. RESPONSIVENESS SUMMARY CONTINUA T/O,tJ
CHARLES GEORGE SITE
TYNGSDOROUGII. MASSACIIUSETTS
JUNE 1905
II'A6E~ or 59l
ISSUE I CONCERN
RESPONSE
ENVIRONHENTAl SAMPLING/RESIDENTIAL WEll
SAHPLING
. No 5011 sampling was done north of
Blodgett Road. Sotl sampltng was
confined to the 51 te area 1 tsel r. No
samp11ng of so115 off of the landftll
was done durtng the 'field study.
Sampling of soils was done to determine
whether eroston of suface 50t15 from the
landf111 may prov1de II route of
contamtnation to recef~ing streams.
So 1 l' sa mp1 es were ta ken sou th of
810dgett Road. lIow many were taken
north 0.( tht s roadway? .
Streambed and lake bed' sediments were
sampled 1n Dunstable and Br1dge Meadow
Brooks. and fn f1tnt Pond. The
objective was to determ1ne the extent,
if any. of contamtnant mtgration from
the stte as a result of deposftion of
. eroded sotl tn the stream channels or
I a ke.
'.
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, PAGE J!... OF ~ I
"
j\g~S
.:xJf=POF\ATION
lallibur10n Company
. RESPONSIVENESSf)UMMARY CON' INUA IIU".
CHARLES GEORGE SITE
TYNGSDOROUGH. MASSACBUSETIS
. JUNE 1985
-~
ISSUE I CONCERN
RESPONSE
lIow many residential wel1s were sampled
north of Blodgett Road and in the Flint
Pond area? Surface water sampl ing
apparently ignored the northwestern
portion of Flint Pond. Residents in
Dunstab1e, northwest of the site,
expressed a similar concern regarding
the frequency of sampling of their
we 11 s .
The NUS Field Investigation Team (FIT)
has been. conducting a quarterly
residential well sampling program 1n
parallel with the Remedial
Investigation. Residential wells
along Blodg~tt Road to the north of the
site were sampled on two occasions 1n
1903. In the first of these, one we11
was tested, while in the second e19ht
were tes ted. Organi c contamtnat 1 on
less than 2 parts per bil1ton (ppb) was
found in two samples taken during the
second sampling round. One well was
found to contain chloroform, wht le the
other was found to contain 1,1,1-
trichloroethane.. .
The general inference here i5 that there
has not been enough sampling done 1n
these arelS.
\
/
During the Remedtal Investigation. two
wells north of Blodgett Road used for
dr1nk1ng purposes were sampled and two
wells not currently used ~s potable
water suppltes were also samp.led. No'
contamination was found tn these wells.
Resul ts of past hydrogeologic studies.
and of that recently completed by the
REMPO. indicate that groundwaler
contamtnat1on from the site area does
not appear to migrate to the northeast.
Therefore, there was no ba s 15 for
extensive sampling In this area.
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3H\h-US
j CCFPORATJON
\ Hallibulton Company
RESPONSIVENES~\SUMMARY CONTINUA TIC )J
CHARLES GEORGE SITE
TYNGSOOROUGH. MASSACIIUSETTS
. JUNE 1985
l PAGE l!L OF ~ I
ISSUE' CONCERN
RESPONSE
In response to pub1ic comments, however.
the EPA has deve10ped a supp1emental
we11 sampling program which was
undertaken In mid-May Ind Included a
number of the residences a10ng B10dgett
Road 85 well IS along Dunstable Road
northwest of the site entrance.
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N;:nS
cx:FPORATJC)f\J
talliburton Company
RESPO'NSIVENESS~SUMMARY CONTINUA T/G~ J
CHARLES r;.;!:'ORG£ SITE
TYNGSBOROUGII. MAS SACttUSETTS
, JUNE 1985
, PAGE!.L. OF 2L I
ISSUE' CONCERN.
RESPONSE
Is groundwater flowing through fractures
in the bedrock? What direction are
contaminants being carried by
groundwater flowing in the bedrock?
To the north of the landfill very 1 ittle
unconsolidated material exists above
bedrock. To the south, of the landfill
unconsolidated deposits are somewhat
deeper, but are still less than 20 feet
In depth. While groundwater does exist
within the unconsolidated deposits, the
greater portion of the aquifer In the
site victnity occuptes fractures wtthin
lhe bedrock.
Within the fractu'red bedrock, flow
directions are governed by the
,orientation of the fractures and by ttle
degree to which the fractures ar~ pumped
by wells. For. Instance, groundwater
flow trom the southeastern periphery of
the landfill could have been Induced In
the direction of the Cannongate wells
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~Nins
j cn:PCJRATON
\ t-tallibur1on Company
. RESPONSIVENESS SUMMAnt LUIV,,,"UM..v.8
CHARLES GEORGE SITE
TYNGSDOROUGH. MASSACUUSEnS
. JUNE 1985
I
(PAG£1!LOF~ I
RESPONSE
ISSUE' CONCERN
. The sampling. program implemented at the
site Is "not in accord with standard
professional analytical protocols for
site selection for samp11ng, but
displays an irregular end incomplete
pattern of sampling wtth complete
dtsrcgard for stathU.ul parameters of
significance and the baste underlying
groundwater hydrogeology.-
The location of environmental sampling
stations (for surface water,
groundwater. soil, sediment. benthic
macro1nvertebrates. and fish) was based
upon a review of the available data
regarding the extent of contamination in
all media. For example, the sampling
10catlon5 and frequency of sampling were
designed to characterize background and
potentially impacted zones in Oun5table
and Bridge Meadow Brooks, tn order to
provide adequate points of cOMparison to
evaluate the extent and potential effect
of contaminant entry into receiving
streams.
The nature of the data base (low number
of replicate famples, large number of
approximated data) is such tha.t
statistical manipulation is not a
posstbtltty 1n most cases. The
Important point 15 that a primary
objective of the envtronmental sampling
i5 not to precisely characterize the
extent of contamination within the site
area, but to define the contamination In
a manner which is sufficient to
determine the best application of
remedial measures. A crucial 'po'rUon of
this objecthe 15 definition of the
nature and extent of contamlnatton In
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jNUS
C(JFPORATKJN
Halliburton Company
RESPONSIVENES~.~SUMMARY l'UN IIIVUA III V
CHARLES GEORGE SITE
TYNGSBOROUGU. MASSACIIUSETTS
JUNE 1985
\ rAGE~OF}L I
ISSUE I CONCERN
RESPONSE
adequate detail to permt t . a lIeaningful
evaluation of the prosent and potenttal
rtsk to the general popuhtton and the
environment.
In concluston, the gOll of the
envtronmental sampl tng was not
necessarily to produce a data base
.amenable to statistical tests of
significance. Rather, the objective was
to identtfi the general extent of
contaminatIon and potential mIgration
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3N:JS
j CCFPORATION
\ Halliburton Company
RESj- .ONSIVENES~~'.~.UIVIJVIAI( r
\.. U I V , "" U rI . . ~ '.
CHARLES GEORGE SITE
TYNGSOOROUGII. MASSACtlUSETIS
JUNE 1985
~(jt K- Of »- ,
-.
------_.
ISSUE I CONCERN
r
~
RESPONSE
Will EPA attempt to is01ate zon~s of
more Intense contaminat10n w1 thin the.
landfill and treat these dtfferently
prior to capp1ng?
EPA 1s aware that both drummed and bulk
(1.e.. tanker truck del her1es) volat t1e
organ1c~ were d1sposed of 1n the
landft11 from 1973 to 1975. Quarterly
reports made by Charles George do not
specifically 1dentify the areas in which
d1sposal took place.
Identif1cation of zones of more intense
contamination with1n the landfill after
the fact would have required the use of
remote sensing techniques such as
magnetometer surveys al'd other . types of
geophysical techniques. The depth of
cover material over potential areas of
volatile organic waste disposal (in some
cases as much as 200 feet) and the
. interferences which might be antic1pated
from m1scellaneous refuse placed 1n the
landfill would pose difficulties 1n
accurately interpreting the results.
R[H[DIAl DESIGN
~oes EPA plan to 1nvest1gate specific
areas of contamination within the
landfill prior to capptng? Drums may be
located wHMn the landft11 which would
pose an ong01ng threat of contamtn~tio~
1 f they start to leak. .
The only means by which the presence of
spectfic zones of contaminatton could be
vertf'ed would be through direct
excavalton of the landfill. Not 0"1,
:would this pose a health risk to the
remed 1a 1 i nves t i gl t1 on personnel. and
potent'ally to the surrounding public 1n
. the event of an unanticipated release.
but Ilso the work would be labor
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. ..'""\
i[\nUS
J CCA=DRATJON
, Hallibur10n Company
. ,.... .
RESPONSIVENES~ "SUMMARYCONTINUA T/L,\I
CHARLE~~[ORGE~TE
TYNGSDOROUG~> ~I\S SACtlUSETTS
JUNE 1985
, PAGE.1L OF J2... ,
ISSUE I CONCERN
RESPONSE
intensive and extremely costly.
Excavation into .the 1andfi11 wou1d also
pose the risk of Igniting the wasles,
resulting in a subsurface fire which
would be very difficult to deal with.
In the event that concentrated lones of
contamination cou1d be identified, the
logistics of removing these lones and
finding suitable secure disposal areas
would be a difficu1t task, and could
potentially present additional heallh
risks for the local popu1ation.
Notwi thstanding the above, the EPA has
been conductlng'an ongoing Investigation
Into potentla1 contributors of
hazardous wastes to the landfill. In
conjunction with this, Information has
been sought relative' to specific areas
of the landfl11 which were used for.
waste disposal. .
The present EPA position Is that
:excavation Into the hndf1.11 Is nol
justified In .lIght of lhe inherent
risks. .
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~~~~s
J aJi-PORATON
\ 'falliburton Company
RESPONSIVENESS .SUMMARY ('UIV IIIVUA I fL."
CHARLES GEORGE SITE
TYNGSBOnOUGtI. MASSACtlUSETTS
. JUNE 1985
'rAGE~OF2L ,
I
ISSUE I CONCERN.
RESPONSE
lIow w 111 the clay cap keep water from
causing furlh~r prob1~ms1
Clay materials. properly compacted. wt11
proYI de a zone of 1 0" p~rm~ablll ty
ma tori a 1 ovor the surface of the s t tee
The objective of this zone 15 to shed
ratnwater or snow melt which runs onto
the landfill so that the water does not
penetrate and percolate down through the
refuse. brtnglng potentially hazardous
compounds Into solution and forming a
leachate.
Surface water runoff from the capped
area will be collected via a system of
dtverston channels and conveyed off stle
through sedimentation basins.
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=li1\t1~S
j ca=IFDRATICJI"J
1\ t-fallibUlton Company
RES,PONSIVENES~ ~
~UMMARY-CON" INUA II( '-I\r
CHARLES GEORGE SITE
TYNGSBOROUGU. MASSAOtUSETTS
JUNE 1985
, PAGE ~ ()(~L -,
"
ISSUE I CONCERN
RESPONSE
As part of the remedial action.
dt scharge from the culvert from the
landfill which carries drainage under
Route J to Flint Pond Harsh should be
addressed. flint Pond Marsh should be
sealed off from Flint Pond proper. and
the ent 1 re area dredged to prevent
contaminants deposited In the marsh from
migrating into the pond.
The question of whether Flint Pond Harsh
should be sealed off and/or dredged will
be addressed in the offsite study of
remedial alternatives. Additional
samp 11 ng of the marsh sed I menls 15
proposed as a part of the field
investigations for this phase of the
work in ord(!r to determine whether
dredging of the sediments would
significantly reduce the contaminant
load to Flint Pond. .
.
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Nt:JS
CCf-"F'Of=1ATION
lalliburton Company
RESPONSIVENESS SUMMARY C'UN IINUA llU J
CHARLES GEORGE SITE
TYNGSDOROUGIt. MASSACtIUSETTS
. JUNE 1905
. 'rAGE 2fJ- OF ~L I
ISSUE' CONCERN.
RESPONSE
Is the landfill pr~sently capped with
c1 8y1
The landfill is not covered with c1 aYe
It 1s presently covered with a sandy
5011. Those areas which had not been
covered by Charles Geoerge were covered
by the EPA Emergency Response Team (ERT)
-during the winter of 1983-1984. WhUe
no refuse 1 s exposed on the surface of
the landfill at th1s time, revegetation
of the so11 cover is not complete. In
addit10n, the sandy soil cover, coupled
with the irregularities In the landfill
surface, does little to ltmit
infiltration of surface water.
._-_._,,;:":-::-
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. .
~\h.JS
c:x:R='ORATDN
I fallibur10n Company
RESPONSIVENES~~ '~'UMMJ\" Y lUIV' ',VUJ.\, Il V
CHARLES GEORGE SITE
TYNGSBOROUGH. MAsSACtfUSETIS
JUNE 1985
I rAGE1LOF~ I
ISSUE / CONCE" N
RESPONSE
Wi11 there be any difference in
loghties. and particularly in the
numb~r of haulage trucks. tf . flextble
membrane cap is used instead of a clay
up?
. Because of the volumes of crushed s~one,
. sand. and borrow 5011 wh1ch w111 be
required irrespective of whether a clay
cap or a synthetic membrane cap is
installed, the actual difference in
number of haulage trucks wt 11 be
minimal. With respect to the full clay
cap. the clay component makes up
approximately 196.000 cubic yards (cy)
of the total 615.000 cy of material
requtred. The t9ta1 volumo of mater1al
(crushed stone. sand buffer, borrow
5011. topsotl) requirod 1n connect1on
" with the full synthetic membrane cap has
been estimated at 419.000 cy. At
approximately 11.5 cy per haulage truck,
this st111 would translate to
approximately 24.000 trucks.
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t tClJlibur10n Company
( '\
RESPONSIVENESS SUMMARY CONTINUATIO.J
CHARLES GEORGE SITE
TYNGSDOROUGII, MASSACIIUSETTS
JUNE 1905
I~~~
'. ~r~~~ ,2~~ ?f:.5!'-~,L
. .'. r-t~~.~!I; ,;r.~rrTT .
RESPONSE- -: - i .'1~. -. . .
.-
ISSUE I CONCERN'
What is the aval1abl1ity of II flexible
memhrane?
Flexible membranes are produced by a
number of fabricating firms. While the
availability IIIIY not be Immediate.
enough 1t~ad time w111 be 1Y811able for
its procurement while the'slte 15 being
prepared so that ava11ab11ity w111 not
be a critical factor In the project
schedule.
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=lI!\11.JJS
J fXTPORATON
" Halliburton Company
RESPONSIVENES!:.-"'SUMMARY ('UN 111VUA III :V
CHARLES GEORGE SITE
TYNGSDOROUGJI. MASSACHUSETTS
, JUNE 1985
, rAGE~ OF»-I
ISSUE I CONCERN
RESPONSE
How many truckloads would ',e required in
order to remove the entirr landfill?'
Removal of the entire landfill mass is
~
not area l1st1c poss 1bl11ty. Assuming
the capacity of a haulage truck to he 20
cubic yards (cy) 10 order to adhere to
~assachusetts weight restrictions for
haulage 00 state roads. it would requ1re
an est1mated 226.000 trucks to ent1rely
remove the 3,950.000 cubic yards of
material. To carry this a ltttle
further. with stxtrucks operatin9 at
four round trips per day. the estimated
ttme for removal of .11 of the landftll
would bo about 40 years.
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~f1\hUS
j cu=PORAlXJN
A t lalliburton Company
RESPONSIVENES~'SUMMARY CON'TINUA T/'( ~'V
CHARLES GEORGE SITE
TYNGSDOROUGU. MASSACHUSETTS
JUNE 1985
'rAGE2~OF~ I
ISSUE I CONCERN
RESPONSE
What is contained in the industrial
wilstf! dumpsters1 What will be done with
the dumpsters?
The majority of industrial waste
. dumpsters are empty. It appears that
they were being stockpiled onstte
pending the need for their use. However,
those which are not. empty contain
industrial refuse. Screening of each
dumpster with an HNu during initial
reconnaissance identified no volatile
organic contamination.
In their present location. the dumpsters
are an obstruction to regrading, and
will require relocation onsite at the
very least in order to permit effecttve
site closure.
The ultimate fate of the dumpsters has
not yet been determined. The
possibility exists, however. for them to
be decontaminated and disposed offs He.
It is a1so possible that .they may have
some salvage value.
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3N~S
J CJ=PORATION
\ Halliburton Company
RESPONSIVENESS'S UM MARY'CONTINUA Tl0-'1
(IiARtES GEORGE SITE
TYNGSBOROUGU. MASSACltUSETIS
. JUNE 1985
'rAGE-R-OF~ I
ISSUE I CONCERN.
RESPONSE
Will a synthetic liner (flextble.
membrane) break down when it comes 1nto
contact with other c;,emlcals or
contam1nants1 How long w111 the
membrane hs t1
The synthetic 1tner app1tcatlon at the
Charles George S1te 15 somewhat
different than the manner In which th.e
11iler might be used 1n the preparation
of a new refuse dhposal sHe. In
development of a new site. the liner
would be placed at the bottom of the
st te to contatn the wastes. Following
completion of each waste cell a liner
would be placed over the wastes and
mated with the boltom liner lo form a
complete capsule for the waslos. In
this type of application the 1tner
matorlal is In Intimate contact with the
waste materials and must be des1gned to
be compatible with the wastes.
As a COYer for the Charles George SI te
the primary object1ve 15 to provide a
low-permeabl11ty cap for the landfill to
reduce infiltration of su~face water.
As such. the membrane will not be In'
direct contact with the leachate. and
compatlbl1 tty betwecn the leachatc and
the liner materhl w111 be less
critical. The liner will al~o b«!
protected from mechan I ca 1 damage by
virtue of the manner In which It will be
constructed (t.e.. sandwiched between
two slx-tnch layers of sand). and will
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l1\fiiJS
C(JFPORATKJN
lalliburton Company
. .
RESPONSIVENES~'5UMMARY CONllNUA IlL.. 'tI
CttARlES GEORGE SITE.
TYNGSDOROUGtI. MASSACIIUSETTS .
JUNE 1985
, PAGE...R OF ~ I
----..-...-... --
ISSUE I CONCERN
RESPONSE
. .
liners made of p01yv1ny1 ch10rlde (PYC),
for example, are sensitive to
ul travi01et 11ght and require at 1east
12 Inches of so11 cover to provide
. adequate protection from sunlight.
The estimated 1tfespan 0' 11ner
materials actual1y exceeds the
period of time for which historica1 data
exist. Use of membranes Is relatively
new In site closure. The firsl
extenstvo use dtd nol occur until the
1970's. Based upon acce1erated
laboratory testing (with elevated
temperatures, rapid te.perature
fluctuations, extreme loading, etc.),
it appea rs tha t 11fe eJepec tancy at
optimum performance will be about 20
years. Some estimates Ire as high as 30
years.
As with a clay cap. poriodtc matntenance .
wi11 be required to pro1ong tho 11fe of
tho membrane cap.
. .
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N~S
cor-PORATDN
Halliburton Company
RESPONSIVENESS--SUMMARY lUIV IIIVUA I IV.'J
ttlARlES GEORGE SITE
TYNGSBOROUGH. MASSACHUSETTS
JUNE 1985
, PAGE.1L OF jL I
----..-.-.-..------..- ------
ISSUE I CONCERN
RESPONSE
What design criteria will be employed in
developing the remedial design following
the selection of the remedy?
EPA will select an alternative for
remedial action. COM will then develop
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,~
iNLBS
j (XFPORATDN
\ I fallibur10n Company
RESPONSIVENESS"SUMMARY .CONTINUA TIO'. J
CtiARLES GEORGE SITE .
TYNG5IJOROUGIt. MA55ACIIU5ETTS .
JUNE 1985
, PAGE 1L OF~ I
ISSUE' CQ'" -:ERN.
RESPONSE
Whnt criteria will be used
decision between a ch)
synthetic membrane?
t making the
cap and a
The technical criteria to be used In
dectding between 8 clay cap and
synthet ic membrane, as outl tned In the
Sonrce-Oriented FS Report. are as
fol1ows:
. Substrate grade requirements
. Permeability requirements
. Material availability
. Resistance to degradation
. Reduction of leachate generation
Since the degree of benefit is
. essentially equivalent with each type of
cap material. cost and Institutional
requirements (public opinion. regulatory
requirements) will a150 be Important
factors to be addressed In making the
dec1 slon.
In addition to evaluating the.
alternatives proposed for this site. the
cost of remedial action at the Charles
George Site wl11 be ba1ance~ w1lh the
costs of proposed remedial actions at
other sites. Based on. th1 s comped son,
the EPA Regional Administrator w111
define the best 8110c8t1on of monies
from the "Superfund".
. .
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~NUS
] CCFP(JRATJON
, I-falliburton Company
. - ( ') . . \
RESPONSIVENES~ 'SUMMARY CONTINUA T/0N
CHARLES GEORGE SITE
TYNGSBOROUGtt. MASSACtIUSETTS
JUNE 1985
I PAGE J.L OF -59- )
ISSUE' CONCERN-
RESPONSE
Dunstable Road is I light-duty roadway.
We do not want large dump trucks and
heavy equipment travelling over the
roadway in large numbers. What will be
done to avotd thts during the clean-up
process?
The EPA is currently examining
alternatives to the use of Dunstable
and/or Blodgett Roads IS haulage routes.
All other alternattves wtll be exhausted
. before any dectsion 15 made to use these
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~ijCJjS
~TION
'allilJur1on Company
RESP0NSIVENESSr]UMMARY CUN IIIVUA 11U~ I
CHARLES GEORGE SITe
TYNGSOOnOUGII. MASSACHUSETTS
. JUNE 1985
'rAGt~Of~ I
ISSUE' CONCEI J
RESPONSE
How 100g will the capping process take
to complete?
The duration of the capping process will
depend upon weather conditions, and a150
upon whelher chy or synthetic nlenlbrane
capping materials wfll be used. It Is
conceivable that construction wUl have
to avoid poor weather conditions during
the winter months. It 15 EPA's intent
to obligate construction lI'Ionles by
September, with construction to be
Initiated during the fall of 1985. It
Is possible, however, that a decision
may be made to defer the start of the
work until spring 1986 In order to take
advantage of better weather conditions.
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, '.
RESPONSIVENES5 'SUMMARY CONTINUAT/G.'J
CHARLES GEORGE SITE
TYNGSBOROUGtI. MASSACtIUSETTS
JUNE 1985
, rAGEE- OF 2L I
llNuS
J Q:FT.J(JRAnON
. Halliburton Company
ISSUE I CONCERN.
REsrONSE
~
What will be done with the leachate that
is generated while tho cap is being
installed? Will leachate flow continue
from the landfill durtng the capping?
Four potential alternatives are being
considered to address the problem of
leachate handling during the Interim
period whl1e the cap 15 being
constructed. These will be presented as
an addendum to the Source-Orl ented
Feasibility. The four alternatives are
listed below: . .
. Treat leachate collected In the
sumps on either end of the site.
and discharge the treated
leachate to Dunstable Brook and
Flint Pond Harsh'
~
. Pump 1 eacha te from the sumps
Into tanker trucks as required
and haul the leachate to a
publicly-owned treatment works
(POTW) for treatment
. Rectrcu1ate the leachate from
the sumps to the top of the
landfill on the east and west,
thus eliminating any discharge
to surface waters
. No Action (1.e.. permit leachate
to discharge to Flint Pond Harsh
and Duns tab 1 e Brook a s it does
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=1\N~S
J ca=PORATON
" , lallibu.ton Company
RES 'ONSIVENES~ '~SUMMARY CONTINUA IlL V
CHARLES GEORGE SITE
TYNGSDOnOUGH. MA55ACtiUSETTS
JUNE 1985
, rAGE~OF~L I
---.--..-..-..--. -.
RESPONSE
ISSUE I CONCERN
.,
$:
While the No Action alternative has been
el1mlnated, .. firm decision by the ErA
and DEQE has not yet heen made regarding
the remaining alternatives.
It 1s important to note that the above
alternatives are 1ntertm measures to
m1n1m1ze further leachate contam1nat1on
of the area surroundfng the landfill.
These measures w111 be implemented In
conjunctfon with capping to reduce
1nfl1tratton of surface water into the
landfl11. Even after capping some
leachate will continue to be produced
within the landfill. Thfs 15 so for the
fol10w1ng reasons:
. . difficulties tn ach1ev1ng 1001
el1mlnatlon of InfH tration of
surface water Into tho landfill,
f rre spec t 1 ve of th.e type and
configuration of cap
, residual moisture In the 5011
and refuse material wfthln the
landfill, which will be forced
out with decomposition and
settling of the landfill
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lN~S
j CCAPORATON
. I ~alliburton Company
RES PONS I VENESS 5 UMMARY CONTINUA T/CI
CHARLES GEORGE SITE
TYNGS80ROUGII. MASSACIIUSETIS
JUNE 1985
T
, PAGE -»- OF J9-1
RESPONSE
ISSUE I CONCERN.
",
'.
. the probability that the base of
the hndftl1 ts in contact with
the local groundwater system
A long-term response wi11 therefore he
required to address leachate generation
by the landfill. Alternatives to
achieve this objective will be addressed
in the Phase III Feasibility Study,
which w111 focus upon off-sHe control
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RN~S
IJ ca=PORATION
I A J-f"IIiburton Company
RESPONSIVENES5~5U,'V1MARY CONTINUA Tla
.cHARLES GEORGE SITE
TYNGSDOROUGfI. MASSACflUSETTS
JUNE 1985
I rAGE~Of~ I
-..----...--. ..--.---.-...- -."...-- ... -------
V1
ISSUE I CONCERN
RESPONSE
).
tlow will you holate the sUe to prevent
erosion and sedimentation in receiving
streams once you start to do the
earthwork on the site7
The means by whi ch further 1 eacha te
discharge to Dunstab1e 8roc~ and fl1nt
Pond Harsh will be mitigated during the
construction phase wi11 be addressed in
the F1na1 Feasib111ty Study Report.
This design will also address means by
which erosion and sedimenlatlon control
w111 be provided in order to avoid
degradation of the receiving streams.
Approval of an Erosion and Sedimentation
Contro1 Plan wtll be required by the
state of Massachusetts prior to
Initiation of construction activity.
This plan will be .available for pub11c
. review as we11.
In addition. I Site Safety Plan will be
developed to address appropriate actions
tn the e~ent of an unanticipated rolease
of contaminants from the site during the
construction phase. Thts plan wfll also
be Ivai1able for public review prior to
lho start of construction.
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qN:.JJS
jcn=A:JRATON
A Halliburton Company
RESPONSIVENESS~--SUMMARY CONTINUA TIC~
CHARLES GEORGE SITE
TYNGSDOROUGU. MASSACUUSETTS
. JUNE 1985
'PAGE~OF~ I
ISSUE I CONCERN
RESPONSE
What are the possibilities of using
"innovative" techniques such 85 placing
a "bow'" under the hndf111 to prevent
migration of contam1nat10n 1nto the
groundwater system?
Innovative technologies, such as in-situ
destruction Of encapsulation (or
building a "bowl") of the wastes, are
applicable primarily to sites where the
waste materials are readily accessed.
and where the quantities of wastes are
not large. Neither of these conditions
are met at the Charles George Site.
.".
The log1st1c5 of total encapsulation of
the 3.950,000 cubic yards of material
estimated to comprise the volume of the
Jandf111 are bC!yond the I1mtts of
technical feasibility. If not
el1nllnated on the bas1s of cost, the
potential for uncontrolled release of
contaminants to the env1ronment would be
slm11ar to that for total removal of the
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qfi\H~S
J C(FPORATON
1\ Halliburton Company
RE$PONSIVENESS1SUMMARYCONTINUA TIO~
. CHARLES GEORGE SITE
TYNGSOOROUGtI. MASSACtlUSETTS
JUNE 1985
'rAG{~OF~ I
---------'-'-.'-..--- -.....
....-.----.
ISSUE I CONCERN
RESPONSE
l£GAl/ADHIHISTRATIYE ISSUES
The public has the opportunity to
comment without specIfic right to appeal
the decision. EPA will select the most
cost-effective remedy. If the public
desires a less cost-effective remedy,
the opportun1ty extsts to suggest that
the Massachusetts Department of
fnv i ronmene t. 1 Qua 1t ty Engi neertng
(OEQE) pursue this a Iternattve with the
EPA.
Wtll the public have In opportunity to
appeal the decision made by EPA
regarding the selected remedial
al ternattve?
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IRN~S
.lJ ~RATON
~ A Hallibur10n Company
. .
RE5'PONSIVENES5SUMMARY CONTINUA TIG-:tI
CHARLES GEORGE SITE
TYNGSUOROUGH. MASSACHUSEnS
JUNE 1985
, PAGE.!L OF~ I
M
).
ISSUE' CONCERN
RESPONSE
,.
'n alternate-wlter supply should be
provided for restdents 110ng Fltnt Pond.
If resident1al wells 110ng Flint Pond
are found to be adYers~ly affected by
contamInation migrating from the Charles
Georgo Slle to the point that lhe public
health could be threatenod, an alternale
water supply would be a potential
remedy, ~Any action to be taken In this
area would be subject to additional
study prior to implementation.
This Ilternate supply .ay or may not be
the same as that which Is presently
being brought into the Cannongate area
from the North Chelmsford Water
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IRtN~s
Jj ca=PORATION
) A Halliburton Company
RESPONSIVENE5S-SUMMARY CONTINUA TIC' ~
CHARl.:s GEORGE SITE
TYNGSDOROUGII. MASSACtlUSETTS
JUNE 1985
EM
O.
I PAGE -11.:' ~F.5L I
----......_....._~ -- 0-
. -. .-. ... __18._,,_.... .
ISSUE I CONCERN
RESPONSE
-_.---~ .-...-.--.-
. C.
Wi th respect to funding, does EPA have
to request 811 of the money from the
Superfund at one ttme. or can you go
b~ck for addittonal fundtng as needed?
In particular, will funding 01 Phase II
now jeopardhe Phase III (off-s He)
funding later?
The funding of Phase I, the Permanent
Alternate Water Supp1y, and Phase II.
Source Control. have no bearing on
potentta1 fundtng for Phase III. offsite
contr01. It Is convenient (or the EPA
to expedite actton at Superfund Sites by
subdividing the remedial actions.
. Instead of wattlng untt1 the sHe has
been completely studied, and all of the
classes of action have been evaluated.
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-JN~S
J CCR=DRArON
. Halliburton Company
RESPONS/\lENESS'-;UMMARY CONTINUA TIO~;
. CHARLES GEORGE SITE
TYNG5DOROUGIf. MASSACIIU5ETT5
. JUNE 1985
(PAGE~Of~ I
ISSUE I CONCr-RN .
RESPONSE
What is the schedule for. ,lase 1111
The Remedial Investigation Report is
schedu1ed to be avai1ab1e 1n mid-summe~
The Feasibility Study of Off-Site
Control Measures ,wi11 be comp1eted 1n
ear1y fall and another round of pub1fc
meetings and hearings wil1 occur at that
time to discuss the recommendations made
in that report.
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R~..JS
tJ a::J=P(JRATKJN
, A Halliburton Company
RESPONSIVENES~SUMMARY CONTINUA TIC1I
CHARLES GEORGE SITE
TYNGSBOROUGH. MASSACIIUSETTS
JUNE 1985
I PAGE..1L Of -»-1
'v1
ISSUE I CONCER~ .
RESPONSE
'.
, ,
How do you take public comments into
constd~ratton 1n making a dec1s1on?
EPA w111 cllreful1y consider pub1tc
comments received 1nformally at the
informational meet1ng (held on Harch
20), and comments received formally at
the public hearing (held. on April 16).
in reaching a decision regarding the
most suitable remedial action at this
sHe. In addition, EPA wil1 careful1y
consider comments obtained from written
letters of correspondence.
\"
local concerns are a factor in selecting
a remedhl action, 1n addition to
technical feasibility, protection of
public health and the environment. and
cost.
\ .
i I
All public comments are recorded and
responses are provided in this
Responsiveness Summary. Copies of this
report will be made available (at the
Tyngsborough Town tlal1) so th&t citizens
can see how each comment was treated,
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3N~ijS
j CCFPORATJON
\ I ~l1l1iblJfton Company
.RESPONSIVENESS--SUMMARY CUN IIIVUA Ill~-~V
CHARLES GEORGE SITE
TYNGSDOROUGII. MASSACHUSETIS
JUNE 1985
, PA(jE~ OF ~ I
--
ISSUE I CONCERN
RESPONSE
When will EPA complete the remedial
design Bnd obligate funds for
construction?
The remedial design will be initiated by
Camp, Dresser, & McKee (COM), under
contract to the EPA, IS soon as the
recommended alternative has been defined
by EPA. This.is forma1tzed in a Record
of Oechon (ROD) document. Signing of
the ROD 1s ant1cpated during June.
COM wi11 initiate design immedtate1y
after ROD approval by headquarters EPA.
ErA hopes to have a completed design by
. August or September, ready to inUiate
the process of soltc1ttng bids for
construction.
Obligation of funds for construction is
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JNl~S
J CCA=ORATON
, Halliburton Company
RESPONSIVENESS'-SUMMARY CONTINUA TIU.8\f
(HARLE) GEORGE SITE
TYNGSBOROUGU. MASSAOIUSETTS
. JUNE 1985
'rAGE~OF~ I
ISSUE' CONCERN
RESPONSE
Flint Pond Harsh should be included in
the def1n1t1on of .on~s1te..
Since the site usually is conceived of
as a source of contamination, the
landfill itself and private access
roads to the landfill constitutes the
site in this instance. The Flint Pond
Marsh area is actually a receptor of
contamination. Remedial measures
required to deal with this area will be
evaluated in the context of the Phase
III study of off-site control.
The fact that Flint Pond Marsh has not
been included in the definition of the
site does nothing to reduce the
importance of its address in the Phase
III study as both a receptor of
contamination a~d a potential source of
additional contamination to Flint Pond.
'.
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B~;US
LJ CQFPORATON
~ A Halliburton Company
RESPONSIVENES~~ISUMMARY CONTlf\lUA TIC~V
CHARLES GEORGE SITE
TYtJGSBOnOuGK MASSACtIUSETIS
. JUNE 1985
, rAGEJLor~ I
.'
VI
ISSUE' CONCERN
RESPONSE
I.
I.
What 1$ the interrelationship between
Phase II and Phase III (Off-sUe
FeasibIlity Stvdy)1 Is it possible that
the results of the off-site study may
nu11 ify all or a part of the work done
in support of Phase II source control?
EPA is not of the optn1on that the
results of the Phase III study wt 11 In
any way negate the work done under Phase
11. E stab 1 tshmen t of a cap on the
landfill w1ll m1nimize the threat of
surface and groundwater contamination
from the s1te. However. 1t wtll not
eliminate tt enttrely, and that ts where
Phase III 15 tied 1nto the overal1
program for remedial actton at thts
site.
I
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~N~S
j ca=PCJRATON
" Halliburton Company
RESPONSIVEivES5'SUMMARY.CONTINUA T/GJI
CHARLES GEORGE SITE
TYNGSBOROUGH. MASSACHUSETTS
. JUNE 1985
'rAGE~Of~ I
ISSUE I CONCERN.
RESPONSE
Who owns the sHe now1 . ) w111 own the
s He after 1t 15 cleaned .1
The current owners of the site are Dorothy.
George as an individual and James George
as trustee of Charles George Land
Redclamation Trust. After clean-up their
ownership will continue.
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,~
FlNLDS
J o::n=uRATION
A , 1t\lIib\l11on Company
RESPONSIVENESf's UMMARY CONTINUA T/C,')J
cnARLES GEORGE SITE
TYNGSDOROUGII. MASSACltUSETTS
JUNE 1905
, ~~.~. ~1... ~~-~~_J
".,
ISSUE I CONCERN
REsrONSE
Is money an issue in deciding which
alternative wl1l be selected for
cleaning up the site?
As noted on page 31 of this summary, in
addition to evaluating the alternatives
proposed for this sHe, the cost of
remedial action at the Charles George
Stte will be balanced with the costs of
proposed remedial actions at other
sites. Based on this comparison, the
EPA Regional Administrator will define
the best allocation of monies from the
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iEfI\~~S
D cx::FPORATION
~ A '.ICllliburlon Company
RESPONSiVENES}'SUMMARY CONTINUA T/LV
CHARLES GEORGE SITE
TYNGSDOROUGtf. MASSACHUSETTS
JUNE 1985
I rA(jE~ OF 2!..1
I
"'
M
).
ISSUE I CCICERN
RESPONSE
k.
What 1 s the state rank 19 of the stte1
Does the ranking of. th site take Into
cons1derat1on the degree of hazard posed
by each Indlv1dua1 site. or does It rink
tho hazard wtth respect to all stto~
listed? .
The State recommends those sites to be
ranked. The ranking or the sites is
consistent with criteria established by
the National Contingency Plan (NCP). The
ranking 1s based upon an evaluation or
factors such as, specific quantities and
types of wastes, observed releases and
proximity of receptors. '
The Charles George site w~s ranked 163rd of
418 sites on the December 1982 National
Priorities List (NPL). The position on the
list is not necessarily indicative of the
degree of hazard, but does indicate the
potential for impact to the surrounding
environment and the threat posed to public
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-,
.~~~
> A Hallibur10n Company
RESPONSIVENES~'SUMMARY CONTINUA TIC~V
CHARLES GEORGE SITE
TYNGSDOROUGII. MASSACIIUSETTS
JUNE 1985
'PAGE~OF~ I
M
).
ISSUE I CONCERN
RESPONSE
II.
EXTENT OF CO"TAHINATION
Studies to date have Indlcit~d that the
potential exists for contamination from
the site, 1.e., leachate, Lo have
entered the groundwater sy)tem and moved
vert1cnlly through fractures 1n the
bedrock to relatively significant
depths. The lack of a slglficanl
quantity of unconsolidated material
above bedrock indicates that most of the
aquifer of concern Hes within bedrock.
It has been a11eged that the wastes
w1th1n the landfill May have been placed
directly on bedrock, with no intervening
mater1al.
What are the difftculttes tn addressing
groundwater contamination from the site?
".
If contamination has entered bedrock It
may be migrating from the site In the
bedrock fractures. I.e., turbulent now.
Under conditions ~here the bedrock Is
not fractured. or where contam1nation 15
found In the unconsoltdat~d deposits.
flow takes the form of an advancing
contaminant front (1aminar flow). This
flow system can be modeled, and the
extent of contamination CDn be'predicted
based upon assumptions regardlnq the
rate of advance of the contaminant
front. Oased upon a projection of the
migration of contaminants. monl torlng
wells can be installed to verify the
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Rll\b~S
LJ CORPORATION
I A Halliburton Company
RE. PONSIVENES5"SUMMARY CONTINUA T/CV
CHARLES GEORGE SITE
TYNGSDOnOUGtt, MASSACtiUSETTS
JUNE 1985
'rAGE~OF~ I
\1
ISSUE I CONCERN
RESPONSE
'.
,.'dO.
~
data from these we11s can be added to
the model to extrapohte additiona1
projections of extent of contamination.
.
Contaminant movement, and groundwater
f10w within fractured bedrock i5 1ess
amenable to modeling and prediction,
'since the medium through which the
groundwater ts lIovlng 15 not
homogeneous. There 1 s no "1Idvanc 1 ng
"contaminant front", but rather the
contamination 15 carried by the
fractures to varying dtstance5 from the
source dependent upon the degree of
fracturlng..1ts orientation, and
d1fferent1a1s In piezometric heads which
drive the groundwater through the
fractures.
, I
Not only is 1t dtfflcult to define the
extent of contamination In fractured
bedrock, buta150 It 15 difficult to
define remedh1 measures which arc
. successful In tnterceptlny the
contamlnftlfon and evacuatfng It from the
. groundwater system. Similar
dlff1cu1tles wou1d be encountered In
defining means by which barriers to
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RII\~~S
o cx:nPORATON
\ " Halliburton Company
RESPONSIVfNES5'S UMMARYCONTINUA TIClI
CHARLES GEORGE SITE
TYNGSDOROUGfI, MASSACHUSEtTS
JUNE 1985
lI'AGE~OF~ I
---. .-..........................
VI
ISSUE I CONCERN
RESPONSE
"
In unconsolidated material underlain by
relatively impervious bedrock, 1t 15.
possible to install barriers to lateral
groundwater movement. However, if the
. bedrock 15 fractured, the effectiveness
of a barrier wi thin the unconsolidated
depos t ts 1 s dras t1 ca 11 y reduced, since
the groundwater has a potentlll route
around the barrier via the fractures.
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3N~S
j (D=PORATDN
'Halliburton Company
.RES 'ONSIVENESS-'SUMMARY'CONTINUATIC-V
CHARLES GEORGE SITE
TYNGSOOROUGIt. MASSACItUSETTS
. JUNE 1985
, rAGE~ OF~ I
ISSUE I CONCERN
i
RESPONSE
The Source-Oriented Fels1blity Study
Report should prov1de I more detatled
discussion of the resu1ts of the
hydrogeolog1c 1nvesttgat10n done dur1ng
the Remedhl Invest1gatton. It should
take 1nto cons1deration past studies
done by COM and others.
The results of the hydrogeologic
1nvestigation done in concert wHh the
RI/FS will be fully evaluated In the
Remedial Investigatton Report. which
will be available by lite summer.
An understanding of the hydrogeology of
the site is important to the definition
of remedial action. lIowever. the
primary goal of the Source-Oriented
Feasibility Study was directed at
evaluating techniques wh.ich' may he
valuable in mitigating the source of
. contamination. A detat1ed description
of sHe hydrogeology was not presented
in this report~ s1nco this issue is more
pert"inent to evaluating means of
mitigating off-sit"e l1igration of
contamination.
-------
3N~S
j CCFPORATION
\ Halliburton Company
RES,"ONS/l'EiVESS"'SUMMARY CONTINUA T/~J
CHARLES GEORGE SITE
TYNGSDOROU
-------
,
=1NuS
J CXJr-P(JRATION
" Halliburton Company
RESPONSIVENESi"SUMMARY CONTINUA TIC-V
CHARLES GEORGE SITE
TYNGSBOnOUGtf. MASSACIIUSETTS
JUNE 1985
, rAGE~OF2!-1
ISSUE I CONCERN
RESPONSE
The Source-OrIented FS Report indicates
that inorganic conhmlnat ion -does not
appear to be a severe prob1em.- lIow can
this be the case when arsenic levels are
shown which are significantly In excess
of the EPA Prtmary Drtnktng Water
Standard?
.
As a group, Inorganic contaminants do
not represent as significant a threat ~5
dO the organics. This Is because
Inorganic contaminants. includ1n9
arsenic, are not a5 wide spread and have
not been found In as high levels In
bedrock-groundwa ter as the organ I cs
have. Nor have InorgAnic contamInants
been found In domestic supplies and
Cannongate wells 15 have organic
contaminants.
Arsenic has been found. albeit In lowr.r
concentratIons than In prevIous studIes
( 80 0 V s 2 3 ,.0 0 0 p P b ) Ins h a I low
groundwater and site 1eachate near the
Route 3 drainage area and In shallow
we 11 s adjacent to the southwes tern
periphery of the landfill. The
potentla1 risks to pub11c heallh and
environment posed by these s.ttuattons
wt11 be ful1y addressed In the Risk
Assessment Included In the RI Report
which wl11 fol10w lhe' Source-Oriented
'Feasibility Study.
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.~
o
.JfJB~~US
_U cor-POFtATION
tl) A t I..IIiburlon Company
R.:SPONSIVENE~S SUMMARY CONTINUA rON
CHARLES GEORGE SITE
TYNGSDOROUGII. MASSACIIUSETTS
. JUNE 1985
I rAGE ~2- OF 2~ I
!TEM
NO.
- -_...... .. .. --~-. . ...-
ISSUE / CONCERN
RESPONSE
7.d:
In terms of possible receptors, why was
the Merrimack River not mentioned, as It
serves IS a source 0' drinking water for",
the cHles of Lowe11 , Methuen, and
lAwrenc~, downstream of the site.
The Merrimack Rtver was not noted as a .
. potential receptor of contamination from
the, .~.lte. 5.1 nce tht! m i gra it on pa thway
Trom the Charles Georg~ Site to the
Merrimack is via Flint Pond. Th~ field
sampling did nol document contamination
via surface water flow through Flint
Pond, and the potential for the
Merrimack to let IS I discharge arel for
. groundwater flowing through bedrock
fractures Is undetermined.
In any event, sampling of the Merrimack,
which would have been done had It been
considered I logical point of Impact for
contamination (rom the site, would In
a 11 11 ke 11 hood have been I nconc 1 us tve.
In other words, because of the potential
for the Herrlmack Rher to recehe
contamination from a variety of sources
other than the Charles George SHe, the
finding of contaminants In samples from
the Herrlmack River would not have been
8 conc1usive Indictment of the Charles
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<>
EXECUTIVE SUMMARY
COMMUNITY RELATIONS RESPONSIVENESS
CHARLES GEORGE LANDFILL
TYNGSBOROUGH, MASSACHUSETTS
SUMMARY
This report summarizes major issues and concerns raised during the
publ ic comment period (Mar,::h 29 to April 19, 1985) for the draft
Source-Oriented Feasibility Study (SOFS) for the Charles George
Landfill Site. .
Citizens directed numerous comments to the EPA
selectmen concerning air quality and potential
from landfill gas emissions. The noxious odor
as a basis for this concern.
as well as to town
adverse health effects
was frequently cited
EPA explained that a detailed atmospheric study has not been done
at the site to date but that additional studies may be conducted in
the future. During the Remedial Investigation (RI) field study,
samples were taken from the gas vents to identify gas composition.
Specific gases identified are listed in the SOFS report. EPA may plan
for additional air monitoring in the future to better define potential
impacts on air quality. In conjunction with capping the site, EPA
intends to install a gas venting system to collect landfill gases
before releasing them directly into the air. The Remedial Action
Design Report, to be submitted this summer by Camp, Dresser, and
McKee, will further address air quality and gas vent construction/
design.
C~tizens also expressed; g eat deal of concern about the environmental.
sump1ing and we1l-samp1ir..;} programs. Specifically, comments addressed .-
lack of soil sampling north of Blodgett Road. Additional comments
focused on the lack of residential well sampling in three areas: north
of Blodgett Road, in the Flint Pond area, and northwest of the site iR'
the Dunstable area. Because groundwater is thought to be flowing
through fractures in the bedrock, it is difficult to determine the
direction of groundwater flow. Citizens have expressed concern over
this uncertainty and over the selection of sampling points around the
site. .
The EPA explained that no soil samples were taken north of Blodgett
Road because soil sampling was confined to the site area. Streambed
ane:. :'wi._". . - lediments were sampled in Dunstab1e and Bridge Meadow.
Brooks, as well as in Flint Pond, to determine the extent, if any, of
contaminant migration from the site. A residential well sampling
program has been conducted on a quarterly basis in conjunction with
the RI. Residential wells north of Blodgett Road were sampled on two
occasions in 1983. On the first occasion, one well was tested; on the
second, eight wells were tested. Results of these tests will be
included in the RI report. EPA stated, however, that in response to
public comments, a supplemental well sampling program has been
developed and will include a number of the residents along Blodgett
Road, as well as along Dunstab1e Road northwest of the site entrance,
and in the Flint Pond area. This sampling occurred during the week of
May 13, 1985.
-------
EPA explained that the selection process for the sampling locations
was designed to yield the most information 80 as to best define the
nature and extent of contamination.
Residents in the Cannongate and Dunstable areas questioned the remedial
design concepts, particularly as they relate to eliminating or control-
ling leachate contamination to Flint Pond and nearby brooks in that
area. Concerns revolved around capping options: will EPA attempt to
isclate zones of more intense contamination within the landfill and
treat these areas differently prior to capping? will the Flint Pond
Marsh be sealed off and/or dredged? Which capping material is most
effective, least costly, and most easily obtained? What criteria will
be used in selecting a capping material? What are the logistics of
transporting the large quantities of soil and other construction
materials to the site area? In particular, the citizens were concerned
about the use of Dunstable Road by haulage trucks and construction
vehicles during the cleanup procedure.
EPA explained that the only means by which the presence of a specific
zone of contamination could be verified would be through direct
excavation of the landfill. Because of the health risks involved and
the intensive labor costs, this option was not considered. Other
remedial actions £or the site, particularly technical aspects of
capping options, will be addressed more fully in the RI report.
Additional sampling of the marsh sediments was conducted during the
period from May 13-16, to determine whether dredging of the marsh
would reduce contamination of Flint Pond. With regard to the logistics
for the haulage of materials, EPA explained that alternative routes of
traDsportation would be investigated.
~ e issue of alternative water supplies for residents along Flint Road
and north of Blodgett Road was also raised. If residential wells were
found to be contaminated, alternative water supplies would be a
potential remedy. However, further study would be necessary to
evaluate the feasibility of other alternatives to address the problem. .
Citizens expressed concern over the leachate problem in terms of
collection, treatment, and storage. Also, they felt that Flint Pond
Marsh should be included in the definition of "on site".
EPA responded by describing the four alternatives for leachate
collection, treatment, and storage: these alternatives will be outlined
in the final SOFS report. Also, EPA explained t~,...." ~~! ~ ":' '"(I 'A, "'~
may be a receptor of contamination. Remediati Or tne marsh will be
addressed in Phase III of the study, dealing with offsite contamination.
Concern was expressed about the site's ranking on the National
Priorities List. Also, the decision-making process and sources of
funding for remedial measures were questioned, as well as whether
citizens could appeal the final alternative selection. Additional
questions concerned legal aspects of the site, such as present
ownership and future responsibility.
-------
u
EPA explained that the Charles George Landfill was ranked 163rd out
of 418 sites listed on the National priorities List in December 1982.
Sites are ranked according to the risks from potential or actual
migration of contaminated substances through groundwater, surface
water and air. The Regional Administrator of the EPA establishes the
priority for remedial action funding. The site that can get the
maximum amount of remediation from the available money is the one
that receives the funding. The public has the opportunity to comment
without specific rights to appeal. EPA will select the most cost-
effective remedy. Should the public desire a different alternative,
the opportunity to suggest that the Massachusetts Department of
Environmental Quality Engineering (DEQE) pursue that remedy with
EPA is available to them. .
,"
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Q
\!
COMMUNITY RELATIONS RESPONSIVENESS SUMMARY
CHARLES GEORGE LANDFILL SITR
TYNGSBOROUGH, MASSACHUSETTS
JUNE, 1985
Introduction
This responsiveness summary documents for the public record concerns
and issues raised during remedial planning (prior to the comment period
on the Feasibility Study), comments raised during the co~ent period
on the Feasibility Study, and how the U.S. Environmental Protection
Agency (EPA) responded to these concerns.
Because of the complex nature of the Charles George Landfill Site, the
investigative study was divided into three different phases, briefly
outlined below.
. Phase I:
Selection and implementation of alternative water
supplies for residents in the Cannongate area. A
Focused Feasibility Study was conducted to evaluate
possible sources of alternative permanent water
supplies.
Phase II:
Evaluation and selection of remedial alternatives to
control the source of contamination. A Source-
Oriented Feasibility Study was connucted to identify
the source of contamination ~ ,Ad '!:II mine possible
remedial action.
Phase III:
Investigation to determine the nature and extent of
offsite contamination and evaluation and selection "
of remedial alternatives to clean up the areas. A'
Remedial Investigation/Feasibility Study is currently
in progress.
o
Phase I construction activities are currently in progress for the chosen
alternative. A summary of public concerns and EPA's response was
included in the Record of Decision for Phase I. Phase II study has been
completed: design and construction activities will begin after a Record
of Decision is signed. The Ph~~~ rrr ~emedial Investigation is expected
to be completed by the end of summer, .985, and the corresponding
Feasibility Study by late fall, 1985.
This Responsiveness Summary focuses on concerns and issues related to
Phase II.
Activities Conducted Prior the the Source-Oriented
Feasibility Study Comment Period
Periodic fact sheets/progress reports were distributed to residents and
officials on EPA's mailing list in order to inform citizens of current
activities at the site. Informal meetings were held with key local
citizens to brief them on study progress.
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Concerns and Issues Raised Prior to the Source-oriented
Feasibility Study Comment Period
Residents in the Cannongate area expressed considerable concern during
this period over possible health effects from contamination spreading
from the site. Specifically, the risk of potential well contamination
and respiratory effects from airborne contamination caused the greatest
concern. Gas emissions, odor, and the potential contamination of Flint
Pond and the subsequent loss of the pond as a recreational resource were
also cited by citizens in that area.
Although exposed refuse had been covered as a result of earlier actions
by EPA, the risk of fire or explosion was still a concern of the
community during this time. Concern was also conveyed about the
effectiveness of the leachate system and the possible effects of
erosion at the landfill.
Citizens expressed an additional concern that the EPA would not fulfill
obligations for remedial actions and would end its involvement with the
"site once the permanent water line was constructed.
Agency/State Response to Concerns and Issues Raised
Prior to the Source-oriented Feasibility Study
As a result of concerns expressed by citizens in the Cannongate area,
and in an effort to speed up the overall cleanup process, EPA decided
to split the RI/FS into two phases and commissioned a contractor to
prepare a Source oriented Feasibility Study. The objective of this
study was to identify the source of contamination at the landfill and
recommend remedial action~ to control contaminant migration.
Activities Conducted During the Source-Oriented
Feasibility Study Comment Period
The final Source Control Feasibility Study was released to the public
the week of March 18, 1985. Copies of the report were placed at the
Tyngsborough Town Hall and at the Littlefield Library.
EPA held a public informational meeting on March 28, 1985, at the
Tyngsborough Junior/Senior High School in Tyngsborough at 7:30 p.m. to
explain the findings of the Source Oriented Feasibility Study and to
solicit input from the citizens.
Approximately 30 cit" ~ting and asked a series of
questions pertaining _0 the proposed remedial methods of capping the
landfill and controlling the source of contamination.
A six-page fact sheet summary of the study was prepared and distributed
at the meeting by EPA.
A public hearing was held April 16, 1985, at the Tynsborough Junior/
Senior High School in Tyngsborough at 7:15 p.m. to receive oral comments
from the community.
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Concerns Raised During the Source-Oriente.l Feasibility Study Comment
Period
A high level of concern was expressed by citizens concerning the air
quality in the affected area. The select~en and the Director of Public
Health of Tyngsborough directed questions and comments to EPA and the
State regarding this matter, and citizens questioned whether a health
study would be conducted to determine potential health effects from
breathing the air.
Well sampling and environmental sampling programs also were a cause of
great concern for residents in the affected area. The perceived lack
of adequate sampling was the specific issue addressed.
Additional concern was voiced regarding the leachate collection system,
alternate water supplies, and various legal and administrative topics.
Letters addressing these concerns were received by the EPA from Paul
G. Dinneen (chairman), Dana E. Metzler, and David E. Tulley of the
Dunstable Board of Health and from the following citizens of Tyngsborough:
Artie Jackson, Linda Jackson, Gilbert Ohnesorge, and Neil and Kathleen
Robinson. A letter from Elizabeth Coughlin of Flint Analytical Service
was also received. In addition, comments were submitted at the public
hearing by Thomas Borril, Director of Public Health for the Town of
Tyngsborough; and seven citizens living in the affected area.
Part II of this Responsiveness Summary addresses more completely these
concerns and issues.
Remainil~ Concerns
PHASE III
A large number of comments received verbally at the meeting and hearing
pertained to activities that would occur or are now being' addressed'
under Phase III of the investigative study of the Charles George Land-
fill. Phase III deals with offsite contamination.
d
Upon completion and release of the Remedial Investigation report, a
public informational meeting will be held to explain the findings of
the r~port and to solicit public input. When the Feasibility Study
for offsite contamination is released, EPA will conduct a public
comment period on the clean up options.
In response to the comments received conc~rning air quality-and
possible respiratory health effects, EPA offered to conduct a small
group meeting between members of EPA's Air Quality Division and citizens
to discuss th~ findings of various studies previously conducted.
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Com~i!.;ionC':-
May 17, 1985
~erril1 S. Hohman, Director
~!s~e ~anaoement Division
U.S. Environment Protection Agency
J~r.~ F. Kennedy Federal Building
Bosten, ~~ 02203
Ce!r"Mr. Hohman:
The Jepartment of Environmental Quality Engineering has received the March
19E3, Source-Oriented Feasibility Study for the Charles George Landfill Federal
Sut;rfu~d site in T sboro Massachusetts. The study, prepared fDr the
En\'iror;:ie:1ta Protection Agency by NUS, presented eight renedi~1 ~'ternatives
th,t were developed to reduce the impact of the landfill on the surrounding
aqdfer a~.d surface water system- ' The De;lartmerrt has n!vtewed t:'nE document and
is givin9 the following evaluation on the eight al~rnat;ves presented in the
st~dy. The,recommendations made by the Department 1n this \~tter should be
include~ in the Record of Decision (ROD) for the source centrol phase of the
Su~erf~~d project.
Fer discussion purposes, the eight alternatives have been divided into
three general categories: (a) Alternatives I through III include those measures
that cell for the plac~~ent of a partial 'ap to cover dcs1gnate6 ~reas of the
lar.dfi11, (b) Alternatives IV through VI include those measures that call for the
placeme~t of a full cap to cover the landfill, (c) Alternatives VII and VIII
include the two conceptual extremes of the eight proposed alternative remedial
. r:-:e!sures, Le., complete removal and no action.
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The partial cap options, alternatives 1 through ~~!, ;~:::~~ --:-:_- con-
fic:urations that will cover a portion of the landfill. These options ceo;1 for
ca;pins the landfill to the 225 foot Mean Sea Level eleva:ion and include the
ap~ropriate technologies to control surface water 'runofF, leachate generation,
ercsion, and gas emission for only the capped portion of the landfill. Since a
portion ef tne landfill will remain uncovered and subject to rainfall infiltra~
ti:n, the Department finds that the partial cap options are not in co~pliance
wi:h RC~A landfill closure standards set forth by the Department's Hazardous
~aste f.eS:.Jlations,' 310 CMR 30.000. Under 310 CMR 30.633(1), (a)" the final c10-
su~e pian for the landfill must provide a d;sign that will mini~ize the migra-
~i:n of liquids through the landfill. The proposed partial cap options will not
~e:t ttese requirements.
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wh.=it the final remedy 'Nill be, at a minimum, it ...Quld b;:
useful tQ discuss the possible "final re~edies" such as
;roundwdter interce~tion and treatment, and to further
discuss how the cap is consistent with these possible
final remedies and how the cap is in fact the only logical
source control measure. Appropriate places for such discussic)~
would be on pages 24 and 30 as indicated in the marginal
comments. (See also Lynn Peterson's July 3 comment i9).
3.
Need for Action Now:
In light of the fact that we are moving forward with a source
control measure before all relevant remedial investigation
is completed, it is important that the ROD explain why it
is necessary to act now as opposed to six months or a year
from now to prevent or-minimize the release of hazardous
substances from the landfill. This discussion could be in-
cluded at page 11 of the draft ROD.
4.
Wetlands:
We recommend that although the ROD may indicate that some
alteration of wetlands is unavoidable in providing the .cap,
it should also indicate that and explain why there is no
practicable alternative to the cap in accordance with Sec-
tion 2 of E. o. 11990. We also recommend that wetlands
impacts be included in the discussions of alternatives in
th3 "Alterr.3tives Evaluation" section. (see Lynn Peterson's
July 3 Comment 17).
unvalidated Data:
5.
See Lynn Peterson's July 3 Comment 13.
position on this problem.
We need to develop a
.
6.
Form:
Because the ROD is a lengthy document we recommend that a
Table of Contents and numbered sections be added to help
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The com~letE re~~v:l a;d no ac"~or. c::~o~s re~resent the ~wo rE~e:iai
measure extremes fer the ;r:ject. T~e cc~p:::e re~ovai o~:;on calis f:r the
excavation and disposal of ,~prcx;~a~e1y 4 ~i11ion cubic yards of lar.d7il1 ~aste
in addition to an unc:!e~i~ed a~ount of cor.taminated soil. 1he no ac:ion
o~tionwould only include periOdic monitoring of groundwater Qua1i"y. The
Department finds that t~th these options are unacceptable and basis its deter-
mination on the high cost ar.d un(nown environmental impacts of the com;lete
remjval option and the failure of the no action alternative to mitigate the
landfill's impact on various environmental media.
The full cap options, alternatives IV through VI. present capping con-
figurations that will cover the entire landfi1l area and, similar to the partial
cap category. include technologies that are designed to control surface water
runoff. leachate generated by rain-water infiltration, erosion of the cover. and
gas emissions. Each configuration varies in its selection of a primary capping
material. Soil, clay. or a synthetic mem~rane are presented in the report as
alternatives for use as this material. Of the three alternative capping
materials, only the selection of a clay or a synthetic membrane cou1d effec-
tively reduce the amount of rain-water infiltrating into the landfill. The
use of clay or a sjnthetic ~embrane as the primary capping material will func-
tion as a relativey im~errneable barrier. A full cap option with either clay
(Alternatives V) or synthetic me~brane (Alternative VI) wil1 significantly reduce
the volume of leachate generated in and migrating from the landfill.
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It ':s for this rea',on the Department reconmends the concF.~t of a full cap'
to be ;>Lced over the landfill with efther a clay or a synthetic membrane as the '.
primalY capping material. The Department understands that the ultimate selection.-
of the primary capping material will be based on an availability of the material
and that the design details for the overall remedial action will occur once the
. concept for the source-control measure for the landfill has been selected. .,
We look f~rward to wor~ir.g with EPA to i~pleme~t a source control r~w.eJia~
action at thi~ site. Should you have any questions in regard to this letter.
please contact Bob Bois at 292-5833.
WFC/BB/jp
t:a~)lQ~~
.AI ,.0- Wi1liamF.Cass .
"~d" Director
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cc:
Ed Benoit, DREE, D;QE,CRO
Town of Tyngsboro
Madeleine Kolb, DSHW
Linda Holden-Johnson. EPA
Rick Leighton. EPA
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