SEPA
United States
Environmental Protection
Agency
Ofttcs ot
Emergency and
Remedial Response
EPA/ROO/R01-85/013
September 1985
Superfund
Record of Decision
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TECHNICAL REPORT DATA
(Please ,ead Instructions on the ,evene before completing)
1. AE'OAT NO. \2. 3. RECIPIENT'S ACCESSION NO.
EPA/ROD/ROl-85/0l3
.. TITLE AND SUBTITLE 5. REPORT DATE
SUPERFUND RECORD OF DECISION September 4, 1985
Nyanza Chemical, MA 8. 'ERFORMING ORGANIZATION CODE
7. AUTHORISI 8. PERFORMING ORGANIZATION REPORT NO.
e. 'EAFORMING OAOANIZATION NAME AND ADDRESS 10. PROGRAM ELEMENT NO.
Same as Box 12 11. CONTRACT IGRANT NO.
12. SPONSORING AGENCY NAME AND ADDRESS 13. TYPE OF RE'ORT AND PERIOD COVERED
U.S. Environmental Protection Final ROD Report
Agency 1.. SPONSORING AGENCY CODE
401 M Street, S.W. 800/00
Washington, D.C. 20460
15. SU'PLEMENTARY NOTES
18. ABSTRACT The Nyanza Chemical Waste Dump site occupies 35 acres on the north and
south sides of Megunco Road in the Village of Ashland in Mi4dlesex County,
MA. approximately 35 miles west of Boston. The Nyanza site was occupied
from 1917 to 1978 by a succession of companies involved in the production of
textile dyes and intermediates. Large volumes of industrial waste water
generated by these companies. containing high levels of acids and numerous
organic and inorganic chemicals. including mercury. were partially treated
and discharged into the Sudbury River via a small unnamed stream (referred
to as Chemical Brook). Large volumes of chemical sludges generated by the
waste water treatment processes along with spent solvents. off specification
products. and other chemical wastes were buried onsite. The area that
contains the largest amount of buried waste and exposed sludge is referred
to a8 the "Hill" section.
The selected remedial action for this site includes: excavation of all
outlying sludge deposits and contaminated soils and sediments associated
with these deposits to background levels; consolidation of this material
with the Hill sludge deposits: capping of the Hill area in conformance with
the technical requirements of RCRA: construction of a ground water and
17. KIY WORDS AND DOCUMENT ANALYSIS
~. DESCRI'TORS b.IDENTIFIERS/DPEN ENDED TERMS c. COSAT' Field/Group
Record of Decision
Nyanza Chemical, MA
Contaminated Media: gw, sediments, soil,
sw, wetlands
Key contaminants: acids, arsenic, chromium
heavy metals, inorganics, organics, sludge
1.. DISTRIBUTION STATEMENT 1e. SECURITY CLASS (Tlais Reporrl 21. NO. OF PAGES
None 83
20. SECURITY CLASS (Tlais pOlel 22. PRICE
None
'.,. ,..'" 2220-1 (II... .-n)
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Insert appropriate code.
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1.. ABSTRACT
,'1ndude,.tJdtrf:(1tJO,'-m.., ,fK1u8halDftlltJof
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SUPERFUND RECORD OF DECISION
Nyanza Chemical, MA
Abstract (continued)
surface water diversion system on the upgradient side of the Hill;
backfilling the excavated areas to original grade and revegetating the
wetland areas: and construction of a more extensive ground water monitoring
network to enable future evaluation of the effectiveness of the cap. Total
capital cost for the selected remedial alternative is estimated to range
from $5.6 to $9.8 million, with annual O&M costs of $92,000 for year 1 and
$70,000 for years 2-30. EPA will undertake an additional RI/FS to evaluate
the extent of and risks posed by offsite ground water contaminant migration
and sediment contamination in the Sudbury River and wetlands contiguous to
the site. If additional remedial actions are determined to be necessary, a
Record of Decision will be prepared.
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Record of Decision
Remedial Alternative Selection
SITE:
Nyanza Chemical Waste Dump Site
Ashland, Ma.
DOCUMENTS REVIEWED:
I am basing my decision primarily on the following documents describing
the analysis of cost-effectiveness of remedial alternatives for
the Nyanza Chemical Waste Dump Site:
1.) Nyanza Chemical Waste Dump, Megunco Road, Ashland,MA.
preliminary
site Assessment Report, october, 1980 prepared by Massachusetts
DEQE
2.) Nyanza Chemical site, Ashland, MassachW6e~~s, Remedial Action
Master plan, July 1982, prepared by Camp, Dresser, and McKee,
Inc.., Boston, MA.
3.) Nyanza Chemical site, Ashland, Massachusetts, Phase I Remedial
Investigation/Feasibility Study, March, 1985, prepared by NUS
Corp., Pittsburgh, PA.
4.) Nyanza Letter Report of Field Work performed, July, 1985,
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5.) SU"1rna=/ of ReMedia.l Alt~=-l1ative 5f?lectiol1 (Attetr::i'8<'i)
~.) Community Relations Responsiveness Summary (Attached)
7.) The National Oil and Hazardous Substances Pollution Contingency
"PI a'n , 40 C ~ 'F.R. . 'P"a~t )'00.
8.) 40 C.F.R. Part 264 - Standa=ds for Owne=s and Operato=s of
Haza=dous Waste Treatment, Storage, and Disposal Facilities,
.Subpa.rt .F -G.=.o,u.ndw,at.e.r.Pr.o.tec.t,ion,; ..subp,a=t G - ,C10su=e and
Post Closu=e: Subpart N (S264.3l0 a and b) - Landfill Closure
and Post C10su=e Ca=e.
q.) Executive Order 11988 - Floodplain Management
10.) Executive Order 11990-- Protection of Wetlands
11.) 40 C.F.R. Appendix A Part 6 - Statement of Procedures on
Floodplain Management and Wetlands Protection.
u
12.) RCRA/CERCLA Decisions Made on Remedy Selection, June 24,1985
':OWPE Memo:"andum
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REMEDY
- Excavation of outlying sludge deposits/sediments and consolidation
with Hill area sludge landfill.
- RCRA capping of the Hill area.
- upgradient surface water/groundwater diversion system.
- Downgradient groundwater monitoring system.
DECLARATION
Consistent with the Comprehensive Environmental Response, Compensation,
and Liability Act of 1980 (CERCLA), and the National Contingency
Plan (40C.F.R. Part 300), I have determined that the remedy described
herein is cost effective and provides adequate protection of public
health, welfare and the environment.
The Commonwealth of Massachusetts
a;I'-' .;.".
has been consulted and, as provided in the attached letter, agrees
with the recommended remedy.
This action will require future
maintenance activities and post closure monitoring to ensure the
continued effectiveness of the remedy.
Maintenance will include lawnmowing of the grass cover overlying
the cap, removal of obstructions from the diversion trench, regrading
as needed, and repair of any damage to the security fence.
Monitoring
will include sampling and analysis of upgradient and downgradient
wells and surface water.
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maintenance costs.
I have also determined that the action being taken is appropriate
. ,when balanced against the availabil i ty of Trust Fund monies for
use, at other sites.
EPA will undertake an additional Remedial Investigation/ Feasibility
study to evaluate the extent of and risks posed by offsite groundwater
contaminant migration and sediment contamination in the Sudbury
. ,Ri~ver .,and ,-wetlands:c.ontiguous :to..thesit'e. \I-f 'addi,tion'a-l 'remedi'al
actions are determined to be necessary, a Record of Decision will
be prepared for approval of the future remedial actions.
1/~/~r
I/~I/. c:L;
-~
Date
Regional Administrator
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SUMMARY OF REMEDIAL ALTERNATIVE SELECTION
FOR
NYANZA CHEMICAL WASTE DUMP SITE
u.s. Environmental Protection Agency
Reg ion I
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. ~:TA'BLE. .QECONTENTS
Development of Alternatives
Page s
1-2
2
.2-5
5
5
"
6
6-7
7-8
8-12
12-13
13-14
14
14
14-16
1()-17
17-18
18
\I
Site Location and Description
Site History
I .
. ':
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Figure 1-1
Figure 1-2
Figure 7-1
Table 1
Table 2
Table 2-1
Table 3-1
Table 4-1
Table 7-1
Table 7-2
Table 7-4
Table 7-5
LIST OF TABLES AND FIGURES
Location map
Site layout
Site boundaries
Description of Contaminated Areas
Operation and Maintenance Costs - Recommended Alternative
Remedial Technologies
Remedial Action Alternatives
Remedial Alternative Costs
Air Sampling data
Soil/sludge sampling data
Sediment sampling data
Groundwater sampling data
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.J
. :,:TABLE :;Q!>ATTACHMENTS
1.) Community Relations Responsiveness Summary
2.) MA DEOE Concurrence Letter
. ,3.. )We.t.land Assessment
4.) Floodplain Assessment
5.) FEMA Floodway Maps
6.) MA Preliminary Assessment
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SITE LOCATION AND DESCRIPTION
The Nyanza Chemical Waste Dump Site (herein after "Nyanza Site" or
"Site") occupies 35 acres on the north and south sides of Megunco
Road in the village of Ashland in Middlesex County, MA., approximately
35 miles west of Boston, 2.5 southwest of Framingham, a~d .25 miles
southwest of Ashland Center. (See Figure 1-1 from the NUS Remedial
Investigation Report). For purposes of remedial investigation, the
site study area was limited by the boundaries shown in Figure 7-1
from the NUS Report to include all areas of suspected sludge depositio
Thus, the New York Central Railroad (CONRAIL) forms the northern
boundary and the abandoned trolley bed the eastern boundary. The
western and southern boundaries are defined by property lines to
include areas owned by MCL ~orporation, the landowner of the majority
of the site. The areas south and west of the site are undeveloped
forest land. North and east of the site are residential and commercia
areas.
Site drainage from the western half of the site flows into a 2 acre
wetland just above the headwaters of Chemical Brook in the northwest
corner of the site. Chemical Brook then flows parallel to the
Railroad tracks along the northern site border. The eastern half
of the site drains into a half acre wetland which is the origin of
Trolley Brook. Trolley Brook flows parallel to the abandoned ~rolley
bed until its juncture with Chemical Brook in the northeast corner
of the site. The combined streams flow under the railroad and in
an open ditch for approximately 100 feet parallel to the railroad befo
entering a culvert which extends a quarter mile to the Sudbury
River. It is noted that this 100 feet of stream bed is also
considered a portion of the site study area due to the contaminated
sediments and sideslopes.
The main features of the site are as follows:
- The "Hill" section, which contains the largest amount of buried
and exposed sludge (Approx 70,000 yd3).
- The northwest wetland which received sludge contaminants from
direct deposition and from surface runoff from the Hill section.
- The eastern wetland which received direct discharge of wastewaters
from Nyanza Chemical operations resulting in soil/sediment
contamination.
- A light industrial complex in the low lying area between Megunco
Road and the railroad where scattered waste deposits exist beneath
the. surface in the area of former Nyanza operations.
Groundwater flow in the area occurs in two unconfined aquifers.
The shallow aquifer consists of glacial sediments 10 to 30 feet
thick beneath the Hill section and 30 to 60 feet thick beneath the
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bedrock aquifer of fractured granite. Groundwater flow directior
.,i.n 'bo.th aquifer:sis,northtow,ards.the .s.udburyRi v.er.,. .the .pre.surne
'regional Hdiscbargepo,i"nt.. .Tber;e .in 'currently 'no u.s.ageofeither
aquifer in the area for drinking water supply due to the availability
of municipal .vater supply. (These two aquifers can be considered one
since no confining layer separates them.)
SITE HISTORY
I
The Nyanza site was occupied from 1917 to 1978 by a succession of
compani~s involved in :the produ.ctio'n :of texti ledyesand ,intermediate!
Large volumes o'f industrIal wastewater generated "by.'the'se "companie-s
and containing high levels of acidity and numerous organic and
inorganic chemicals, including mercury, were partially treated and
discharged to the Sudbury River via a small unnamed stream (now ~)
referred to as Chemical Brook). Large volumes of chemical sludges
generated by the wastewater treatment processes along with spent
solvents, off specification procudts, and other chemical wastes
were disposed of by onsite burial, primarily in the Hill Section.
":Scat.tered 'waste :'deposi.ts ;and cont1B!t1:ina-ted :.soil.s.f.r:omspills ...d,ur ing
'.plan:t.,'operatlons"-are "a1so 'fo.undinthe 'Lower i'nd.us,tr.ia1 ',.areas. The
last of these companies was Nyanza, Inc. which ceased operations at
the site in 1978~ the property was then involved in a series of
ownership transfers and subdivisions. MCL Development Corp. nqw
owns the majority of the site and leases the former Nyanza plant
and operational facilities to Nyacol, Inc. and other businesses.
Several small parcels in the lower industrial area were purchaser
from MCL by the business concerns currently operating there
(despite knowledge of the contamination) and by other parties.
The site was actually "discovered" in the early 1970's as a result
of a study of mercury contamination of the water, sediments, and
fish in the Sudbury River by JBF Scientific Corp., an EPA contractor.
The studypi~pointed Nyanza as the cause of this contaminatiol"l.
Ear:lierand later "Feder.al.and 'St.ate .'iTlvolv:eme'nt wd.th;Nyan'za is
outlined in the ''Prellmin'aryAssessment'Rep'ortprepa'r>ed "byM-as.sa-
chusetts DEQR in 1980.
I'
I
The only response action taken thus far was the installation of a
chainlink fence by MCL Development Corp. in 1981 to control access
to the Hill section of the site.
CURRENT SITE STATUS
....A :.,review of ,the;';i:nform'at ion i',ntheRemedical ,I'nve:stigation HH)
report prepared by NUS Corp. and a subsequent Nyanza Letter
Report prepared by Camp, Dresser, and McKee, Inc. indicates the
existence of thirteen (13) areas which have been contaminated either
from direct vaste deposition or from sediment transport via surface
runoff from the deposition areas. Table 1 contains a description
of each area and an estimate of the amount of contaminated material
.in each.. Figur.e 1~2 shows the location of each area. All of these
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including mercury (Hg), lead (Pb), chromium (Cr), cadmium (Cd),
and arsenic (As). Tables 7-2 and 7-4 from the RI report show, the
ranges of concentrations present in the sludges, soils, and sediments.
Additional subsurface testing was conducted during the predesign
phase in the Hill area and in the western wetland, the two areas
where wastewater treatment sludges were directly deposited. The
intent of this testing was to further delineate the depths of tpe
sludge deposits and to assess the extent to which the soils beneath
the sludge deposits had become contaminated from leaching. The
results of this testing indicated that soil metal concentrations
decreased markedly at depths of 1-2 feet below the sludge/soil
interface and approached background levels at depths of 2-3 feet.
In addition to the heavy met.al treatment sludges, the Hill area is
also thought to have been the disposal area for off specification
chemicals, distillation residues, and waste solvents. T.he groundwater
beneath the Hill does show some contamination by organics such as
trichloroethylene, nitrobenzene, and chlorinated benzenes. However,
extensive test pitting in the area has failed to uncover any discrete
concentrated sources, thus supporting the RI report conclusion that
organic wastes were disposed primarily in the lower industrial area
in unlined lagoons and only incidentally in the Hill area.
The identification of certain areas as sludge deposition areas' by
NUS Corp. in the RIFS, based on previous work by Connerstone,Inc.
and Carr Research Laboratories, In~., was not confirmed in the CDM
pre-design field testing, which employed numerous test 'pits and
borings. Area VI (using the RIFS designatiQn) consists of a buried
concrete vault behind the Nyacol production building in the southwest
corner of the lower industrial area. Analysis of the contents of the
vault indicated that the wastes contained therein, while containing
some heavy metals, are primarily organic sludges. Test pits outside
the vault exhibited high organics levels which suggests that the
vault has been leaking for some time and is the probable source
of the organic contamination in monitorin~~e~ls 8 and 5. The
potential health and environmental problem associated with the
organic material stems from migration through groundwater and not
from dermal contact or other exposure pathways. The nature and
extent of the cost-effective remedy for this waste deposit
can be more accurately determined once the groundwater RI/FS is
complete, as then the necessity for and degree of excavation can be
assessed in light of whatever organic groundwater problem exists.
Therefore, consideration of the remedy for the organics in the
vault will be deferred to Phase II of the remedy.
Area II was identified as a sludge deposition area directly north
of the Nyacol office building and parking lot. Test pitting in this
area did not reveal any sludge deposits.
Areas III and IV are in the lower industrial area on the north
side of Megunco Road and are the site of the former Nyanza plant
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and a waste oU reclamation facility. Roth had been identified as
possibly containing buried sludge, contaminated fill, or contamir 'd
,"'so i1:6 "fr.onl "spi:l,lage .aur,i:ngpl,ant.opec,a,tJons,.Test ,.pi ts.and ,bor i1
'~'i.d .:not~cO'n'f~irm'the'searea:s ;:as .grossl'yconot.-am.i,n,ated '-'with ,sludge,
although some surface contamination hot spots were found in Area III.
!
Certain other areas not identified in the RIFS as contaminated were
also investigated based on comments received prior to and during
the public comment period. The remnants of a former waste lagoon
adjacent the two existing Nyacol waste treatment lagoons were
unearthed during the pre-design test pitting. Heavy metal sludge
was :f;oun.aandt~h'is,.;are;a 'wil'l::be,incl.ude:dinthe .'Phase .1 'l"emedy.
The large wetland east of the trolley bed was not investigated by
NUS because it flows into the headwaters of Trolley Brook and was
thought to be upgradient of any waste discharges. However, the
upper reaches of this waterbody did receive some runoff from the
southeastern corner of the Hill area and may also be a discharge
point for groundwater. Preliminary results of pre-design field
tests indicate that both the water column and the sediments are
:con:tamtna:te:d ,beyond n.ormal .bac,kground 1,eve,1.s,.Howe,~;er"t,he, f,u.1l
. ',e:x:tent..o'f this ,'contam'ination,a.nd the .,a-t..ten'da'nt.' :;risks,',are .:unknO'wn.
Since this contamination is a result of offsite migration from
source areas, consideration of this area will be deferred to the
Phase II study and addressed in conjunction with the Sudbury River
sediments and the groundwater contamination problems which have
also resulted from offsite migration.
,.
Three other areas were added to the Phase I project based on the
pre-design sampling. The sediments of Chemical Brook, selected h~~
spots in the wetland on the north side of the CONRAIL tracks, and
the drainage path from the southeastern portion of the Hill all
contain heavy metal contamination and will be excavated.
I:
.'Aspreviously:note:d" 't:his\Phase ;!1actlon is a"'SOurce 'CO'n,trol,Act.ion
and does not address groundwater contami'nati'on. 'However ,"a "br'i'ef
discussion of this contamination is needed since it has some
bearing O'n the justification for phasing the project. The existing
data show contamination of both the bedrock and the unconsolidated
deposits, which are hydraulically connected, with volatile and
semivolatile organic compounds. This contamination centers around
the lower industrial area and is presumed to' have resulted fram the
prior discharge of waste solvents and other organic liquids to the
'g([7oundwa:ter:u,s.lng ti:n.H.-ned .lagoon.s . and ..from ,..the a.fo.r:ement,i,oned
.';.1~a1d;D9.vaul:tin' t:heare.a ',ne:armon'i.:t.or:ing we:lJ.8. Someorganic
contamination is also present beneath the Hill in the vicinity of
manitaring well 7 although efforts to' lacate a source in that area
have proven fruitless. It is suspected that buried lagoans in the
Hill area may have been used as leaching pits for organics at ane
time.
The ,exi,sting da.tao,n heavy metal concentrations in groundwater is
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/
metals in the sludges are leaching to groundwater but to a very
limited extent. This is probably due to the fact that portions
of the Hill and wetland sludge deposits are below the seasonal high
groundwater table. Monitoring wells 2, 7 and 10 in the Hill area
show chromium, cadmium, mercury and arsenic levels below the Maximum
Contaminant Levels (MCLs) set under the Safe Drinking Water Act,
whereas the MCL for lead was exceeded in one well. At monitoring
well 3 in the western wetland downgradient from the Hill, the
metals were all below the MCLs. Monitoring wells 8, 9 and 11 are
located in the lower industrial area on the south side of the
CONRAIL tracks, an area of past discharge of untreated wastewaters
to the groundwater. MCLs for lead and chromium were exceeded in
these wells. Wells 4, 5 and 6 are located immediately north of the
CONRAIL tracks and are the only wells downgradient from all former
waste management areas. MCLs for chromium, arsenic and cadmium
were exceeded at well 5 although this may be a local phenomenum in
that the groundwater pH at this location was 3.9 and 4.2 during two
sampling runs; this well is just north of a former waste acid sump.
At wells 6 and 4, MCLs were not exceeded, although the valid data
points are limited.
In summary, although the most prevalent and concentrated groundwater
contamination is organic in nature, there is some inorganic (metals)
contamination above MCL levels beyond the site boundaries downgradient
from the former waste management areas. The available data suggest
that the organic contamination resulted primarily from direct'
discharge of wastes to the groundwater with a lesser contribution
from leaching of wastes intermixed with the metal sludges, whereas
the heavy metal contamination resulted from the leaching of sludges
placed below the groundwater table and/or from direct discharge of
waste acids to groundwatp.r.
ENFORCEMENT
On March 4, 1982, EPA issued Notice Letters to 17 potentially
responsible parties (PRP) including present and past owners and
operators of the site. Based upon the responses to these notice
letters, investigations by EPA Region I, and numerous discussions
with the primary current owner, it was determined that there is no
PRP willing and able to undertake the necessary response actions
at the site. Therefore, it is recommended that CERCLA Trust Fund
monies be expended on the site cleanup.
ALTERNATIVES EVALUATION
The Feasibility Study has been limited to source control measures
that address the contaminated sludge deposition areas and those
area sediments and soils contaminated by past discharges of 'untreated
wastewaters or runoff from the deposition areas. contaminated
groundwater will be addressed under 40 C.F.R. 300.68(e)(3) as an
offsite remedial action in the Phase II RIFS. Contaminated sediments
in the Sudbury River and in the wetland area east of the abandoned
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A. OBJECTIVES
Tne"iobje:ct.:i,ves . o'f:the ,~.phase "I:.Feasi:biQ,ity ',S1:.'udy':w.er.e :t.or:educe th~
generation of contaminated leachate and thereby mitigate future
groundwater contamination; to minimize offsite contaminant migration
via surface runoff and air transport; and to minimize direct human
and environmental exposure to contaminated sediments. To meet
these broad objectives, the wastes must be isolated to minimize cont~c
with groundwater, surface water, and air and to prevent human
and animal exposure.
'DEVELOPMENTOPA~TERNA~VES
Technologies were developed from a wide range of general response
actions, based upon the technical applicability to the stated
objectives of site remediation.
Table 2-1 lists the general response actions considered appropriate
for evaluation in terms of the Nyanza site and the technologies
"c..onside~ed:for '~.ach ,respon.se.ac.t,iDn~uThes.e technolo,9 ies were then
,comb.i:ned'to :for:m'the thirteen'll:3:) r.eme'd:ia''!.actiona:l.tern'atives
listed in Table 3-1.
Table 3-1 lists the alternatives in a hierarchy. At the bottom are
the No-action alternatives, which do not satisfy the site objectives
since no remediation is provided. Next are the capping alternatives
(3-7) which involve selective excavation of the outlying sludge
deposits and sediments, transfer to the hill area, and capping
along with the hill deposits. The extent of excavation and ratic. ~e
therefore are discussed on pages 25-26. These alternatives differ
in the type of cap, the degree of surface and groundwater diversion/
isolation, the use of fixation processes on the sludge, and whether
or not leachate is collected and treated. Unlike the No-action
.:a1't:e,r:natl'ves~ '1:.nesealterna.ti:ve,s do ;a'ddres's.t1\e: isit'e . 'objec,ti'v,es to
varyin'g degre'e'S' 'aT\t~ would 'also' 'result ,'11\ "gho,rt '~t:erm .impact'sinthe
excavation areas. Each would present the potential for air emissions
and contaminated runoff during excavation, traffic congestion due
to importation of clean fill and transport of wastes from the lower
industrial area to the Hill section, and possible disruption of
business in the lower industrial area. Each would also involve
excavation within the wetlands for brief periods of time. The next
group of alternatives (8-12) involve total excavation of all sludg~
'.,de'posit..s,,!-no.lud,in,g .,t.hose .,inthe Hilla.rea, back f ill i ng/revege ta t ion,
,;and .rwr;facewater :contr.o.l.. -. .The .alternatives .'di:ffe-r,i't1~t:he imethod
of containment, Le. capping or secure 'landfIll ;t:helocation,
i.e. on site or offsite; the use or nonuse of fixation; th~ method
of isolating wastes from groundwater, i.e. backfilling above the
high water table or diverting upgradient groundwater to lower the
water table; and the degree to which wastes are kept above the
high water table, i.e. federal or state standards/guidelines.
-------
-7-
accentuate the aforementioned short term impacts. The final ~lte~-
native (13) involves capping the Hill deposits inplace and excavating
the outlying areas for offsite disposal. This alternative also
addresses the site objectives while adding the impacts associated
with offsite transportation of the outlying wastes. .
INITIAL SCREENING
The thirteen (13) alternatives were screened based on the criteria
in 40 C.F.R. 300.68(h), i.e. cost, effects of the alternative, and
acceptable engineering practices.
The following is a brief discussion of those alternatives that
were eliminated from detailed evaluation and the reasons for the
elimination.
2.) Monitoring This alternative was eliminated from further
consideration because it does not achieve adquate control of source
material and does not mitigate or minimize current or future threats
to public health or the environment. Contaminants will continue
to be released to groundwater, air, and surface waters. The existing
degraded state of the wetlands will persist as will the potential
for direct contact with contaminated sludges and sediments.
4.) Selective Excavation, Onsite Dis osal, Ca
Diverslon, Groundwater Isolation
in , surface water
This alternative was eliminated from further detailed evaluation on
the basis of technical ineffectiveness and unreliability. The
alternative is identical to alternative 3 (which will be fully
evaluated) with the exception that the french drain/grout-curtain
groundwater diversion system on the upgradient side of the Hill
would be extended to encircle the Hill deposits in an attempt to
fully isolate the capped wastes from groundwater. Consideration of
the fractured nature of the bedrock led to the conclusion that
groundwater passing underneath the grout curtain on the upgradient
side could actually accumulate behind the downgradient curtain due
to the Hill slopes with the net result that the capped Hill deposits
would actually have more contact with groundwater (than that under
alternative 3).
6.) Selective Excavation, Onsite Dis osal, Ca in, Surface Water
Divers on, Groundwater Isolatlon, Leachate Collectlon and Treatment
This alternative is identical to Alternative 5 with the exception
that groundwater isolation is attempted rather than upgradient
groundwater diversion. The alternative was eliminated on the basis
of technical ineffectiveness and unreliability for the same reasons
previously given for eliminating Alternative 4, i.e. impracticality
-------
'-8.-
I
: .
7.) Selective Excavation, Waste Fixation, Onsite Disposal, Cappinr
.Surfa.ceWaterDhl,ersion" Gr.oundwa,t.er ,Isolation, Leachate Collecti
. and Treatment
This alternative is similar to 6 with the exception that the outlying
wastes would be fixated to immobilize the contaminants prior to
placing them atop the Hill deposits. This alternative would reduce
the quantity of contaminated leachate but would still result in
contact of the "unfixed" Hill deposits with groundwater due to the
i~racticality of complete groundwater isolation by means of an
'enc iir.cl'ing ,grout. 'curta'i n..'Th.u'S ,,',it 'waseli1l1inated -fur the";same
reasons as Alternative 6.
8.) Total Excavation, Waste Fixation, Onsite Disposal, Capping,
Surface Water Diversion, Groundwater Isolation, Leachate Collection
This alternative is again similar to 6 with the exception that all
outlying wastes and the Hill wastes would be fixated prior to
capping. This alternative was eliminated on the basis of technical
infeasibility. The Hill sludge deposits are a very heterogeneous
:m;i,x,of :sludge"houlde-rs, ..construc,t-iondebr.is, .and r.ubbish which
,.would' :sev;erelyl;im,d::t the deg-r,e:et,o ,which.the 'fixationreagants' could
be mixed with the wastes. Therefore, this alternative was dropped
from further detailed evaluation.
11.) Total Excavation, Waste Fixation, Onsite Disposal in Secure
Landfill, Surface Water Control
This alternative is similar to alternative 12 (which will be ful:
evaluated) with the exception that all wastes would be fixated
prior to placement in the landfill. This alternative was eliminated
on the basis of technical infeasibility due to the heterogeneous
nature of the Hill sludge deposits described above.
,: DETAILED EVALUATION, 'OF' 'ALTERNATIVES
The alternatives remaining for detailed evaluation are as follows:
1.) No Action
3.) Selective Excavation, Backfill/Revegetation, Soil Capping,
Surface Water and Groundwater. Diversion
,5..) .:Se.lective"Ex~.av.a-tion, .Backf.i~,l/Revegetation, RCRA Ca..pping,
,"';Surface'Water'and ,Groundwate,r'Divers.i:on. .I;e'acha'te' 'Col,1:ection
and Treatment
9.) Total Excavation, Backfill/Revegetation, Onsite RCRA Landfill
( DEQE standards ), Surface Water Diversion
10.} Total Excavation, Backfill/Revegetation, Offsite RCRA LandfilL
-------
-9-
12.) Total Excavation, Backfill/Revegetation, Onsite RCRA Landfill,
(.federal standards ), Surface Water Diversion
13.) Selective Excavation, Backfill/Revegetation, Offsite RCRA
Landfill of outlying Deposits, RCRA Capping of Hill Deposits,
Surface Water and Groundwater Diversion
The estimated costs for these alternatives are presented in Tahle 4-1.
The detailed analysis was performed in accordance with 40 C.F.R.
S300.68(i) of the National Contingency Plan considering technical
feasibility, detailed cost estimation including distribution of
costs ov.er time, constructibility, effectiveness in addressing
environmental, welfare, and public health concerns, and adverse
impacts and mitigative measures.
The No-Action Alternative (#1) represents the baseline against
which all other alternatives are to be compared. The objectives
for site remediation, described earlier, are based on the conclusion
that the current and future potential risks to public health,
welfare, and the environment are unacceptable. Those risks were
identified in the Feasibility Study and will be briefly summarized
here. It is noted that the risks being considered are only those
due to the heavy metal sludges, the focus of this Source control
action: this action is appropriate under the NCP since "there is a
substantial concentration of hazardous substances remaining at or
near the area where they were originally located and inadequate
barriers exist to retard their migration into the environment."
The second phase RIFS will assess actions that may be necessary to
address wastes that have already migrated from their original
location (i.e. groundwater contamination, Sudbury River sediment
contamination).
The public health risks associated with the heavy metal sludges
stem from the potential for direct contact with or ingestion of
the sludges, soils, and sediments which are exposed. These wastes
contain high concentration of mercury, lead, and chromium and minor
amounts of cadmium and arsenic. For exposure via other pathways,
the current risks appear insignificant based on comparison of
ambient levels and relevent guidelines. Ambient air concentrations
of mercury vapors in the Hill area are above background levels but
well below existing guidelines at downwind receptor sites.
Thus current exposure via inhalation is negligible (See Table 7-1).
It is noted that much of the Hill sludge deposits are covered with
soil which reduces the volatilization of mercury vapors. Removal or
erosion of this cover could substantially increase the emission rate.
The metal concentrations in Chemical and Trolley Brooks and. the
Sudbury River are below the Interim Primary Drinking Water Standards
(See Table 7-3) and do not present a risk from ingestion or dermal
-------
,-10-
The site has and, if left unremediated, will continue to present
'c'e:nvi:ronmental ris-ks :due to ,s,ur,f..aceruno.fffrom the Hill deposits
in't.o:the . we'tl'811d',areas'and ',the 't,wo b.rooks :'whi'Ch:d;rail1 ithe s.i'te. ".1.,
Hill area exhibits considerable vegetative stress in the form of
dead and dying trees and the wetland areas constitute poor habitat
due to the presence of exposed sludge and contaminated sediments.
Runoff from these areas during storm events will transport suspended
metals for later deposition in the brooks and ultimately in the
Sudbury River and downstream impoundments. The river and impoundment
sediments are already contaminated with mercury, lead and chromium
to ',:th'e e,xtent that "fishha'v,e :una:cceptable';meT:cury ,1eve~'s'for':'human
consumption (using "P .L>;A.s'tano'a'r'ds) . 'ITract'i'O'n't'O ,'m'i':tigate:m1'gr-ation
of these contaminants will aggravate the existing situation. Thus
the No-action alternative is eliminated from consideration because it
will not achieve adequate source control and will not adequately protei
human health and the environment. '
I ,
Alternatives 3, 5, and 13 are similar in that all would leave thp.
largest quantity of contaminated sludges, the Hill deposits, in
':plac.e.. :Exc8y,at,ienwouldbe ,lim.i.tedto t.he outlying contaminated
',soils,. ,sl'udges.'andsedime'nts ,ii1'thewe;tlands"andthecont:ami'nated
sediments and sideslopes of Trolley Brook. The excavated areas
would be backfilled to original grade and revegetated. All three
alternatives would employ a surface water/groundwater diversion
system upgradient of the Hill section to reduce contact with th~
sludges that would remain in place and to protect the cap from erosion
Under alternatives 3 and 5, the excavated wastes would be consol:
with the Hill deposits prior to capping. Alternative 3 would
utilize a synthetic membrane and soil cover to reduce infiltration
of precipitation into the wastes. This would eliminate the direct
contact threat and restore the currently degraded wetland areas.
It would reduce the emission rate of mercury vapors to the air and
, wou,ld,e'liminate I\the '1nigratiion o£ :contaminants "via':;'surf',ace <1:'uno.f f,.
'The imperfec't na'tuTeo'f 'the groundwat,er '(fiv,ers.t.on,,'sch'emecoupled
with that of the cap would allow some continued contact with the
wastes with the result that leaching of soluble contaminants to
groundwater would continue, albeit at a reduced rate. This cap
does not fulfill the requirements of RCRA due to the lack of redunrlanc
(or greater thickness) in the imperMeable layer and is rejected on
the basis of unreliability.
~d
Under,.Al.ternati,veS"the .cap would be built to RCRA standards,
, ",which would virt:ual:ly ,eliminatei'n'fi1:tra'tion"o:f 'precip.itat:i.on i:nto
the wastes. A leachate collection system would a1so 'be installed
beneath a portion of the Hill deposits to collect near surface
groundwater which might circumvent the diversion system. (This
system is not required to comply with RCRA closure standards).
Leaching of soluble contaminants to groundwater would persist
due to the present saturation of a portion of the wastes, the imperfec
.nature of the groundwater diversion system, and the lack of a
-------
-11-
capping and groundwater diversion
leaching.
will greatly reduce this
This alternative provides adequate protection of public health,
welfare and the environment. Leaching of contaminants to groundwater
following implementation of this alternative is expected to be
minimal and, if it occurs, will be addressed in conjunction with
the existing groundwater contamination to be addressed in a second
phase RIFS.
Alternative 13 would slightly reduce the amount of wastes
to be capped on the Hill while greatly increasing the costs
due to the provision of offsite disposal of the outlying wastes
at a commercial RCRA landfill. This alternative is rejected since
it costs substantially more than Alternative 5 while providing the
same degree of protection.
The remaining Alternatives 9, 10, and 12 involve excavation of
both the Hill deposits and the outlying deposits followed by disposal
in a secure landfill. The onsite alternatives 9 and 12 differ
only in that 9 provides 4 feet of clearance between the high water
table and the bottom liner as required by Mass. DEOE secure landfill
standards whereas 12 provides 1 foot of clearance. (The federal
RCRA regulations do not specify a minimum clearance but use a
performance based standard which prohibits hydrostatic pressure
from disrupting the hot torn liner.) Both alternatives address all
site remediation objectives by eliminating all direct contact potentia
isolating the wastes from groundwater, surface water, ,and air, and
restoring the degraded wetland areas. Roth avoid the use of a grout
curtain groundwater diversion system, an unproven technology in the
New England environment, by filling the excavated Hill cavity above
the high water table. This adds considerably to the cost, however,
and also results in the landfill extending approximately 40 feet
above grade. These alternatives were rejected on the hasis of cost
since Alternative 5 presents adequate protection at a much lower
cost.
Alternative 10 provides for offsite disposal of all excavated
wastes in a secure RCRA landfill. For costing purposes, the CECOS
facility in-Niagara Falls, New York was used. This alternative
also satisfies all site remediation objectives by the total removal
of all wastes. However, the cost is approximately twice that of
the onsite secure landfill alternatives. The prime benefit of
this alternative would be the peace of mind given to area residents
who have expressed concern about the long term viability of ' an
onsite containment structure, the commitment of state government
to operate and maintain the facility, and the absence of guaranteed
action by the federal or state government in the event of failure.
This alternative would also have the greatest short term impact~
in addition to those common to all excavation alternatives., The
transport of approximately 100,000 cubic yards of waste material
._- .-."
-------
-12-
I '
would require 7000 eighteen wheel vehicles to enter and leave the
site within a six month period. Considerable traffic co~gestion on
Megunco Road in the lower industrial area could be expected due to
the lack of suitable space for loading operations, vehicle inspec
"parki:ng>p ':,e'tc. '..This congest,ionwould . exten-o't'O" 'the :C.e,n:te'r' ofA'Shl~
through which the vehIcles must passenrout-et'oint'erstat'e- ,t-,ra'n'Sport
rout~s. Selection O'f this alternative would not comply with the
. statutory restrictions an affsite disposal under CERCLA SlOl (24)
in that it is nat the cast effective alternative, it is not necessary
to' pratect public health, welfare ar the enviranment, and it would
nat create new dispasal capacity.
1S
"Ai-} ,0£ ,the- al:.t:ernatives involve 'e1Xcava/tion "of\'the 'wB.stesy'either
selectively ar tatally. This excavatIan will re'su'lt' ,in 'i-n'creas'erl "
Cantact af the wastes with the ambient air, resulting in an increase
in the emissian rate af a~ganic and metallic vapars and particulates
to' the surraunding air. The heteragenaus nature af the wastes '.
tagether with their disparate lacatians precludes the effective
use O'f air modeling techniques to accurately predict ambient
air ~antaminant levels at dawnwind receptO'r sites. The meteora-
,1,O'gi,ca1 .study and air monitaring conducted during the Remedial
.InvestlgatlO',nand during ';the:predesign '~ampling work, "have ,prov'i:ded
infO'rmatian an real time monitaring equipmentccqrabil'i-t'ie-s (md
receptor locatians far dawnwind monitoring sites: this informatian
pravides the basis far the design af an effective manitoring pragram
for implementatian by the canstruction cantractor. '
In summary, the stated abjectives af site remediatian are satisfir'
by Alternative 5, the RCRA capping alternative, which will elimil
direct cantact, surface runaff of cantaminants, and air emissians
while virtually eliminating leachate praductian, ance the presently
saturated portion of the wastes are dewatered, by permanently lowering
the graundwater table below the depth af the waste depasits.
,RECOMMENDED ,AI.TERNAT:IVE
Section 300.68 (j) af the Natianal Cantingency Plan (NCP) states
that the apprapriate extent of remedy shall be determined by the
lead Agency's selectian O'f the alternative that is cast effective,~
i.~. the lawest cast alternative that is technalogically feasible and
reliable and which effectively mitigates and minimizes damage to' and
provides adequate pratectian of public health, welfare, and the
'.::efty,:ir!CM'U'llent,. '. <,sasedon .anevaluatiO'nO',f -the RIFS and addendum and
. :the',~Ny.auza:ietter':repo:rt, ,and 't'be :camment's 'rece.iv,ed:,~frDm, t'hepublic, ,-
lacal afficials, and the Cammonwealth af Massachusetts, EPA has
determined and the MA DEQE has agreed that the fallawing remedy
meets the NCPcriteria:
Excavatian af all autlying sludge depasits and cantaminated
sails and sediments assaciated with these depasits.
-------
Table 3-1
Remedial Action Alternatives
Nyanza Chemical site
Alternate
Technologies
1
No Action
2
Monitoring
3
selective Excavation, Onsite Disposal, Capping,
Surface Water and Groundwater Diversion
4
Selective Excavation, Onsite Disposal, Capping,
Surface Water Diversion, Groundwater Isolation
5
Selective Excavation, Onsite Disposal, Capping,
Surface Water and Groundwater Diversion, Leachate
Collection and Treatment
6
Selective Excavation, Onsite Disposal, Capping,
Surface Water Diversion, Groundwater Isolation,
Leachate Collection and Treatment
7
Selective Excavation, Waste Fixation, Onsite Disposal
Capping, Surface Water Diversion, Groundwater
Isolation, Leachate Collection and Treatment
8
Total Excavation, Backfill Excavation, Waste
Fixation, onsite Disposal, Capping, Surface Water
Diversion, Leachate Collection and Treatment
9
Total Excavation, Backfill Excavation, Onsite Disposa:
in Secure Landfill, (state RCRA) Surface Water
Diversion
10
Total Excavation, Offsite Disposal in Permitted
Landfill, Backfill Excavation, Surface Water Control
11
Total Excavation, Waste Fixation, Backfill Excavation
Onsite Disposal in Secure Landfill, Surface
Water Control
12
Total Excavation, Backfill Excavation, Onsite
Disposal in Secure Landfill (RCRA), Surface
Water Diversion
13
Selective Excavation and Offsite Disposal of
outlying Sludge Deposits/Sediments, Capping
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-13-
~
Capping of the Hill area in conformance with the technical
requirements of RCRA.
,.
-' ',~Const~c'ti.oT1 'of ',a ,groundwa:t'er' 'a'rtd ',"sur;fa;c'e"wat:e,r ~~d'iv'ersion
system on the upgradi'ent ''Sice of 'the :Hill.
Backfilling the excavated areas to original grade and
revegetating the wetland areas.
Construction of a more extensive groundwater monitoring
network to enable future evaluation of the effectiveness
,oftbe ,cap.
This alternative is similar to Alternative 5 in the Feasibiliiy
Study and Addendum except the leachate treatment system and well
point dewatering system are omitted and a trench replaces the
grout curtain. Capital cost estimates are approximately 80% of
those listed in Table 4-1 for #5, with an estimated range of
$ 5.6 to 9.8 million.
f,
",~:Ex't'ent of 'excavation
RCRA closure requirements address the extent of excavation in
those areas to be excavated and then consolidated with the Hill
sludge d~posit.. ,According to RCRA standards, removal of cont~~inated
material to background levels is required for all areas which
will not be capped unless alternative residual levels are develop~~
which adequately protect public health, welfare, and the environ1
Data were gathered during pre-design testing to assess the depths
to which sludge contaminants had penetrated the underlying soils
and sediments and to determine metal levels in undisturbed areas
(background) for comparison. The Metals used for comparison were
:c.ftcas "to ""avo,i:d,destrueti'On ,of
-------
-14-
infiltration of precipitation, erosion and man-made disturbances
resulting in potential direct contact and resuspension and surface
runoff of the contaminants. In addition, the residual lead and
mercury may be remobilized due to biomethylation by benthic microbes.
For these reasons, the extent of excavation will be to background
soil metal levels to the extent possible, given the difficulties of
both excavation and in situ testing below the water table.
The additional "satellite" areas listed in Table I contain less
than 10% of the total volume of contaminated material. Were excavation
in these areas to be terminated without reaching background levels,
they would have to be closed with a RCRA cap to prevent direct
contact and surface runoff and would require individual monitoring
systems for the 30 year post closure period. The cost to close
these areas in place and provide this post closure monitoring is
prohibitive relative to the cost of excavating these areas to back-
ground and consolidating the wastes with the Hill deposits. using
an estimated $ 9.50 / ft2 capping cost, capping the 65000 ft2 area
of the outl~ing areas costs $613,200 whereas excavating 5900 yd3
at $65 / yd costs $383,500. Adding in the 0 & M costs for capped
areas, consolidation is clearly cheaper. Therefore, these areas
will be excavated to background levels also. Table I also lists
the estimated volumes of contaminated material in each area.
Selective excavation will include all areas except the Hill area;
the estimated volume is thus 33,600 cubic yards (105,600 minus.
72,000 = 33,600). certain of these areas will involve excavation
below the water table, depending on weather conditions and the time
of year. All wet material will be stabilized to reduce the free
liquid content to a minimum prior to consolidation with the Hill
deposits. Bench scale testing will be performed during the Design
phase to determine the optimal method of achieving this goal. The
paint filter test described in 40 C.F.~. ~264.3l4 will be used to
demonstrate the absence of free liquids.
Groundwater/surface Water Diversion
Due to the questionable efficacy of grout curtains, the diversion
system concept has been revised to provide an open cut trench which
will extend into bedrock to a depth beneath that of the deepest sludge
deposits. The trench will extend from ridge to ridge immediately
upgradient of the Hill deposits and will intercept both surface water
and groundwater. Discharge from the trench will occur at both ends
as overland flow. Appropriate erosion control measures will be incor-
porated into the design. Construction of the trench will lower the
water table sufficiently to obviate the need for both the leachate
collection system and the wellpoint dewatering system proposed for
excavation in the outlying areas. It will, however, require that
the Commonwealth obtain permanent easments or take the necessary
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-15-
Operation and maintenance (0 & M)
!J
o & M activities associated with the source control remedy inc1ud'
. main.te,nal1ceof'thecap ,,(mowi'n'g., .l:i'ne'rinspe\ct,'ion ,'and 'repai"1':) ,the
security 'f e n c i ng ,a n'6 'thedive-rs iontrenc'h( -remov a l"o~f'Obstr'u c-
tions, regrading for erosion control). Groundwater monitoring
will be performed at upgradient and downgradient monitoring wells
and in the brooks draining the site to determine the effectiveness
of the cap and diversion system. The costs are estimated to be the
same for synthetic or clay cap options. (The final choice will be
made during the Design phase.) Projected 0 & M costs are as follows:
Year 1
: $9'2 ~-OO 0
Years 2 - 30 : $70,000
\:
These costs differ from those presented in Table 4-1 for Alternative 5
in that Alternative 5 provides for leachate collection and treat-
ment at a cost of $99,000 per year whereas the recommended alter-
native omits leachate collection and treatment.
. 'The 'Comrnonwea'lth of '''Massachuset"tsha'S 'lT1cU'ca't'ed 'it.s ,'commitment 'to
provide the required operation and maintenance. A formal contract
(State/EPA Superfund Contract) is presently being negotiated.
between EPA and MA DEQE, the agency responsible for 0 & M. ThiS
contract will be signed prior to execution of the Interagency
Agreement (lAG) by EPA and the Army Corps of Engineers. Table 2
provides a breakdown of estimated 0 & M costs.
COMMUNITY RELATIONS
Appended to the ROD is the Responsiveness Summary (Attachment 1).
,X.his dDc.umen,t .summa.ri.zes the concerns expressed by the communi ty,
tbe ::Commonwealth.,'and -the liocal 'In'dustr.ie.s''du'r.i-ng the 'publ.i-.ccomment
period and provides the Agency's responses to these concerns. 'Detailed
comments were provided by the Ashland Associates for a Clean Envir-
onment (A.A.C.E.), the attorney for. the Ashland Board of Health,
State Representative David Magnani, and Nyacol, Inc., one of the ~
industries occupying the former Nyanza site in the lower industrial
.area.
Tbe:gener.al..t.hrusto.f .the comments ,pertains to the .perceived inadequac
o,f.:t:he,RI:PS and . Addendum ,in deti"Ding ,al.1..8r,eas'of ,con,'t'amination !
and the attendant risks to human health ana the environment and in
describing the alternatives and the effects and impacts of each. A
second concern expressed is the need for EPA to expedite the approval
process to ensure that funds are obligated this fiscal year"and
that construction is undertaken next calendar year.
'The..p,r-e.fecr-ed .a.l.terna.t.iNe ..ref.le,cted,i.n .thepubl ic comments was
;limi't:ed 'to'.the "se.cuc.e .;-!:andfl1iloptions"e,i'tn;e,r on.siteor ',off.site,
-------
-16-
this preference is a perception that the site is unsuitable for a
landfill due to the presence of a high groundwater table and fractured
bedrock underlying the site. Concern was also expressed that
maintenance of the facility by the Commonwealth would not be as
rigorous as that provided at a commercial disposal facility, and
that the commitment of the state and federal governments to rectify
any failure of an onsite facility was suspect. The community also
recommended that, if an onsite facility is selected, it be designed
to provide an extra factor of safety by utilizing waste fixation,
reinforced concrete bottom liners, thicker synthetic 1iners,etc.
Nyacol, Inc. expressed concern that the remedial action not interfere
with its business operations or threaten the health of its employees.
No comments were received from the other industries in the lower.
industrial area, from the Ashland Board of selectmen, or from the
property owners.
The Massachusetts D.E.O.E. also questioned the adequacy of the
existing studies and expressed a preference for the secure landfill
options, either onsite or offsite. They requested that consideration
be given to permanent lowering of the groundwater table by means
of an upgradient diversion trench with the onsite. landfill option
to eliminate the need to import massive quantities of fill to
build the landfill ~bove the high water table.
CONSISTENCY WITH OTHER ENVIRONMENTAL LAWS
Environmental laws applicable or relevant to the proposed source
control action are as follows:
- Resource Conservation and Recovery Act (RCRA), Part 264
- Executive Orders 11990 (Wetlands) and 11988 (Floodplains) and
Guidance outlined under 40 C.F.R. Part 6, Appendix A
The proposed alternatives were reveiwed for consistency with the
applicable RCRA technical standards, specifically 40 C.F.R. S264
subpart G entitled Closure and Post Closure and 40 C.F.R. S264
subpart N, Landfills, Section 264.310 entitled Closure and Post
Closure Care (for landfills).
Alternatives 5,6,7,8 and 13 all comply with the RCRA standards for
closure whereas alternatives 9,10,11 and 12 exceed the closure
standards by excavation of all wastes followed by secure landfill
disposal either onsite or offsite.
The RCRA cap for the recommended alternative (#5 modified) will be
designed in accordance with section 264.310(a) to:
1.) Provide long term minimization of liquids through the
-------
-17-
.2.) Function with minimum maintenance:
3.) Promote drainage and minimize erosion or abrasion of the COVI
4.) Accomodate settling and subsidence so that the cover's
integrity is maintained:
5.) Have a permeability less than or equal to the impermeability
,0.£ ..any ..,bo..ttom liner o,r .subsurface soi Is.
I"
I.
The cap installation will be performed as specified in S264.303.
The landfill will be surveyed and a notice placed in the deed and
to the local land authority as specified in S264.119 and S264.120.
The applicable closure requirements in S264 Subpart G will be "
addressed. (Decontamination/Disposal of Equipment, Certification
by a Professional Engineer, and Site Security will be provided as
specified in S 264.114 - S264.117). Post closure care and groundwate:
,monit,or,ing in .,accor.dance.wi.th .40. C. F.R. Subparts F and G and Sub-
.;p.art,:N~,';'2.64.'3'lO.(b} w.ill .,be ~provided.
Wetlands/Floodplains Impacts
As noted previously, an assessment of wetland and floodplain impacts
was performed and is appended to the ROD. Alternatives for Source
Control were evaluated for possible wetland impacts in accordanc'
with Section 2 of Executive Order 11990. .
I :
A determination was also made that all contaminated areas to be
addressed in the Source Control action are outside the boundaries
of the 100 year floodplain of the Sudbury River and that the project
. 'will' no:t. ':tmp,a.ct:th i.,sf loodpla i 11,.
FUTURE ACTIONS
",. ,.
A second phase Remedial Investigation/Feasibi1'ity Study will begin
in the first quarter of Fiscal Year 1986, pending availability of ~
funds. This phase will further define the extent of groundwater
contamination, locate or further define source areas, including the
aforementioned vault, define migration pathways and ultimate fate,"
':a.nd':defi:ne,the'r.is-K's .topublic'bealth,#'"we.lf:a.re" .,and .,tbe .e,nv.ix.onmen.t. .
"l>t'is .:eurr.e:ntly'iknow;n' .t.ba'tcolltani:i:n'ants,hav.e :.mi,gra.ted ',nort'h "beyond .
the CONRAIL tracks in the direction of the Sudbury River, the pre-
sumed groundwater discharge point. The RI will attempt to confirm
this understanding and will detail the current and future impacts
to the River and to receptors in the path of the plume. The RI will
also address the extent of sediment contamination in the Sudbury
River and its impoundments and in the wetland area due east of the
'.ab'and,oned troll~eyb:ed:abutt'ing. 't'beNycH'tZ'8' :s,i'.te. . .An~aases:smen.tof the.
. -e'nviTonmentcil and. public .t\e.a:rt:h 'r-'i,g.k:s.po$'E!Oby:ttre ..'con'tarninat,ed
sediments will then be made. Following completion of the RI, a
Feasibility Study will be conducted to address the problems ider
-------
-18-
The Phase I source control action will require maintenance and
monitoring activities as described earlier in the 0 & M section of
the Recommended Alternative description.
SCHEDULE
The following are the key milestones and dates for the implementation
of the selected remedy:
Approve Remedial Action Recommendation (ROD)
september 3,198~
. Issue Work Order for Design Services
. Start Design
october 1,1985
October 1,1985
. 95% Design Completion
December 15,198:
* Execute S$C with MA DEOE
December 15,198:
. Execute Construction lAG with Army COE
. Complete Design and Advertise for Bids
December 15,198:
February 1, 198~
. start Construction
May 1, 1986
July 1,.1985
. Select Construction Contractor
. Complete Construction
July 1,1987
-------
, .
III ': ~ -I,.. i.f,'
.,,';lIl!t,:~;.;'.i:;I,,"I." .
...a
I
~
.,'
FIGURE I-I
I
L.d~' .
EMtCAL SITE ASHLAND
SCALE: I" =?... ~I)
MA
cmNU53
LO roRPORATION
.OA
Jurton Cbrhpany
-------
~~~
-"
-~
-
~~
J L
.
w
>
~
z
o
to-
:=!
to-
.~
~
CI.
@(i";;;;'O";;1 ~
;.; :;....;~..;.:.;;.;::.:;:. 0
':;:\?/);:;:;{??)N{ tu
"" ~
;mm:::::::::::mgm:g1Ati LAND JR HIGH APPROX 2000'
:::::::::::1::::::::::::::::::::::. .
F t~. I -"2
PLAN OF SAMPLING AREAS
~ITr:
NVAW7&
~I..U='.AI~ A I
ARWIANn
,.a
10.'
o
~
it
It
~
o
t
\ r=--==
I
I
'.
E9
<"t.'" . , r-
.8
-------
.-
A SUDBURY RIVER UPSTREAM
A SUDBURY RIVER Af DAM
ASUDBURY RIVER OONNSTREAM
-..J
I
W
...ouoy ",V£R'
""""ox. 220' tF
C1 D ~ LJ '~ 0 r{)
",-,.- :~ --:
PLEASANT c:::1 a.,
~ti
JJ : m
STRd:f
.I
...:..=.=..=...=..=. =-=-=--
r-
100 ---... C
MW2S
ROAD
III
to-
U)
~
N
Z
~
>-
z
~.. ~.,
. ,
p
IL.
o
U)
to-
i
::i
LEbEND
S MONitORING WELL
A ApPRoX LOCATIOII of .
SuRFACE WATER SAMPl!:
~ sdiL SAMPliNG AREA
fiJ stbMENT SAMPLN> MEA
~~~ AI~ sAMPLING /\REA
,
..
.
r:tOO'"
. LIMITS OF '
NYANZA sitE:
.
-- -
,
,
II)
~
FIGURE 7-1
;: -. NY ANZA SITE' MAP SHOWING AREAS Or=- .
SU~r=-ACE WATER. SEDIMENT. P C;OILS SAMPLING
NOr TO SCALE
E:tj~Y@
-------
AREA
B
C
D
E
F
G
H
I (1 & 2)
J
K
L
M
N
DESCRIPTION
VOLUME(estima
The Hill area, repository for the largest
volume of metal sludge intermixed with
rubble, boulders, rusted drum remnants.
Soil cover over 75 % of the area; sludge
depth to 13 feet, partially below water table.
Seasonal wetland contaminated from direct
sludge deposition and runoff Hill. Sludge
depth approximately 2 feet.
Remnants of a former lagoon adjacent to the
two existing Nyacol waste treatment impoundments.
Lagoon is buried, approximately 10 feet deep.
Surface contamination hot spots from spillage
and past wastewater discharge to Chemical Brook.
approximately 3 feet deep.
Suspected area of sludge burial; none found.
Wetland area west of abandoned Trolley bed with
sludge deposits and sediments contaminated from
past raw wastewater discharges. Area drains to
Trolley ,Brook; sludge depth approximately 4 feet.
72,600
19,790
2,180
110
-----
6,480
Buried concrete vault with organics and heavy metals. --
Not included in Phase I.
Former lagoon behind Derby Chemical and drainage
path to Trolley Brook. Lagoon contamination to 8
feet, surface contamination of drainage path soils
to 2 feet.
SediMents of Trolley Broo~ and surface
soils behind Tilton Ave. contaminated from
past brook overflows 1 foot depth.
Wetland/pond east of abandoned Trolley bed;
sediments contaminated in scattered areas; not
addressed in Phase I.
Drainage path from southeast area of Hill to
abandoned Trolley bed; surface soil contamination
to 1.5 feet.
1,310
330
1,120
1,030
Extension of Area C wetland on north side of 480
CONRAIL tracks; hot spots from runoff to 1 foot depth
Chemical brook sediments contaminated from
past wastewater discharges 1 foot depth.
170
-------
,Table .II
~
~~NU.~ CPERA!:~G C:S:S
CAPPING
I,'
I "
'.
"
COlt ';~o"eflt " '£'5t::88tl-, '5. " ,',,"... ~:ol, :.t.:,~r.. ," 'fnllwn:~. . ,Y..:
~er~:)c
~ . !'I ;0.".
:. Opeuunl :"DDI'
a.
, 'to.
c. .. "
.. Ita~nr..unc. 2 men $30/hr ~
llaur~.4' ."eI :.. iNI" 24 hrs/ea~ 4 x 1 yr:
.. labor $5760 2 (30)( 24)( 4) ANN 1-30
b. -
c. Mat'h $500 Reveg.
",
,: ,,3. "MllBl.",,-..c ~',
.. Assume replacement of '3')
.no 1,.aDor topsoil ANN 1-30
I. Mat" $1260 1260
II.
"
c.
-. Purcha..eI 5erv~c..
.. ~q..in $1000 ANN 1-30
D.
c. .
.:. ~U'D".1
I.
II.
~. .ClIUft:..t~.: 1011
$1000 ANN 1_':In
. 111I\1Urll:", -:.....
'.
~~C'II."
',' "a..
..
.
..
i. ~"111" III.IIC.
al..:V. In:
::ft:J.18ncy COI:. $1000 ANN 1-30
.'
.':r. ~:..':"
A:~:-:J.:.::t: :;.p :~~ $10520 ANN 1-30
::57
I '
"
-------
Table II (cant.)
~~NUAL O?~~~:!~G C:S:S
SURFACE & GROUNDWATER DIVERSION
C~lt COmpOIl.IIC. htuuu ISi !UlI' of ~1t:.-tI F:eqy,nI:V ' ':'.er'
!ler:.oa
: ~ ~ Co.u
l. ~,uu"l wOOf'
I.
b.
::.
e' Kall1C..II&-' 2 men $30/hr.
Kac'ril~' Ind ~~~ 40 hrs/ea. 4 x lyr.
I. Labor $9600 2 (30)(40)4 . ANN 1-30
b.
;. Mat" $ 500 Reveg.
.' AUS11ilrJ -.c.,rlI1s
Ilia LAbor
e. MIlt" $1000 Replacement ANN 1-30
tI.
;.
-. pur::aa'id S,rvlC"
I. Equip. $1000 ANN 1-30
CI.
;.
~. ;uIIO.ll
..
b.
~. ..1":.sc.rlno,,
$1000 ANN 1-30
e l".u:'I"::.', T..",
.
1."1"'"
I.
:.
.
e'
a. ~lnc.,".n;'
.. II ~, InG $1000 ANN 1-30
:~":ll'''CY Ce.t.
... ~:.n.:
~~:::J.:.::~ :;.p:":A1. ~'30'
-------
~
Table n (cant.)
~~NUAL OP~RATING C~S7S
,MONJJ,QRING A, ANAL Y 515
I
I
,-
!;OIC !;08!'OftlftC b:u.aC.IS, IIiU o'f 1sc lIUC. Frt~\llftc" I Y..r',
Per~od
1 man S25/hr.
;) " !I CoIU 2 cnen S30/hr.
1. Op.nUfti &.aDoI' '30 hrs. - 4 times per
:....> Labor ';$'1'0.-200 ' ',(65 )('30)(,.Jea r ,ANN ,1..30
"
b.
c.
.. lSIJ.ftCIB&ncl
ISIUI'Ul.l a'lC:I ...iM'?'
a.
II.
"
&-: '
"
3. AUZJ.1J.ary 1SI:.rJ.al.
ana &.altOI' :
'I. I='QII;" . $500 Experience ANN 1.30
II. .
c.
10. tvrcaal.d S.rv1~'1 1st. 1st yr. 25 samples $525
lab Ana1vs1s $56260 el. 4 times a year
I. Sed/Soil 3 ~~80 x 4 ANN 1.30
II. ir 2 350 x 4
~., 2nd. nd.30 Z~ samples ~31Z/ea
. 'Ii : .$34960 -
-------
TABLE 2-1
POTENTIAL REMEDIAL TECHNOLOGIES
NYANZA SITE
General Response Action
No Action
Groundwater Containment
Groundwater Collection
Groundwater Treatment
Surface Water Control
Sediment Control
Sediment Treatment
Airborne Particulate Control
Excavation of Wastes
Fixation of Contaminants
Treatment of Waters
Disposal of Wastes
Site Access Restrictions
Applicable Technoloqy Types
Continued monitoring of
contaminant migration and water
quality analyses.
Barrier walls, capping of site
surface.
Barrier walls, pipe drains,
wells.
Onsite, and offsite treatments.
Diversion measures, collection
systems, capping, grading,
revegetation.
Capping, dredging, filters,
barriers.
Onsite, and offsite treatments.
Capping, dust control measures,
grading, revegetation,
excavation.
selective removal (sludge,
debris, highly contaminated
zones), complete removal.
In situ, onsite and offsite
treatment.
In situ, onsite, and offsite
treatments.
Onsite RCRA landfill, offsite
RCRA landfill, onsite non-RCRA
landfill.
Fences, signs.
-------
Iable 3-1
Remedial Action Alternatives
Nyanza Chemical Site
Alternate
Technologies
1
No Action
2
Monitoring
3
Selective Excavation, ensite Disposal, Capping,
Surface Water and Groundwater Diversion .
,4
Sele.ct.i.v.e .Ex,cav.a.tion.,. Onsite ,j)isposal~ Ca.pping,
, SurfaceWater..Di vers,io.n ,'Gr:oun.dwat'er :lsolation
5
Selective Excavation, ensite Disposal, Capping,
Surface Water and Groundwater Diversion, Leachate
Collection and Treatment
6
Selective Excavation, ensite Disposal, Capping,
Surface Water Diversion, Groundwater Isolation,
Leachate Collection and Treatment
7
Selective Excavation, Waste Fixation, ensite Disposal,
Capping, Surface Water Diversion, Groundwater
.Isol'a~tio.n, :Leacha,t'€Col1:e.c t.ion . ,,and ,,!I'.rea.tment
8
Total Excavation, Backfill Excavation, Waste
Fixation, ensite Disposal, Capping, Surface Water
Diversion, Leachate Collection and Treatment
9
Total Excavation, Backfill Excavation, Onsite Disposal
in Secure Landfill, (State RCRA) Surface Water
-------
Table 3-1
Remedial Action
Nyanza Chemical
Page Two
. Alternate
10
11
12
13
Alternatives
Site
Technologies
Total Excavation, Offsite Disposal in permitted
Landfill, Backfill Excavation, Surface Water Control
Total Excavation, Waste Fixation, Backfill Excavation,
Onsite Disposal in Secure Landfill, Surface
Water Control
Total Excavation, Backfill Excavation, Onsite
Disposal in Secure Landfill (RCRA), Surface
Water Diversion
Selective Excavation and Offsite Disposal of
Outlying Sludge Deposits/Sediments, Capping
-------
--d"':~
Remedl.. Ac:deh
Aller".11". .
J .: Nt) .tUo"
. .
3'; .".~"v. Elre.vlIlI,,": bW.,..
O'-titiul. Surfllce and O",.'ft'dwater
oivi;tslon. Consl,uctlon Wit."
Tt.ehnen'
. .
5 ..~ Sel.cllve hcavallon; (j~s"a
oi'ihiul. 5",'a1:8 Ind O,;o..,lidwate,
01"8;slon, lellr.hl'o COllettl!'In.
c6itillruc:tlon Wate, and hiilt.ha..
" .ahnent
o .. tot I' hcaveflon, Oniiti!i Dlspos.'
In Secu,. lendfili. Constr"ction Wa'I'
Ttltiliment .
;- :- '~ ".'
10 :... Total huv.flon. oi,!itn 015"05111
IrfPlttmlttod landfill. n0510'8 1\,...
Chnstrucllon Wa'e, T,o.iitlin.
. . .
11 - Tot.1 huv.llon. OHsito OIspoSllI
h.. iI !;1Ir.",O lIIndflll, Dndfill.
Ctii1~i,uctlon Wlte, T,e81"lont
, - .
13 - C8p IIIIt Uoposlls. d.,~lto
nl*p~8II1 0' Outlying no,,~~I". ~.."atll
8nd ",oundwat., Olvn,:dnn. t 41111:hll'0
Ind Construction Wate, i;O~llIIo"t
TABlE 4-1 .
PttOJECT COST SUMMARY .'1,000'..
tapll., CoSI
. . hllml'e. .
Ui... IIlah~
.
i. ',~.:
';"4
.
10,4'4
.;i63
11 ,545
ubiee
18,804
21,813
44,597
.,j~I
15,706
d.44'
28.020
Page retyped for NTIS--Decembet 31, 1985
~".IIon .nd
M,'ill'~.nc:. Co.l.
.!!!!..! V.., 2-30
.
.
'81
70
191
110
183
&4
157
45
'83
64
101
.70
"...nl Wo,th
An.Iy... .30 Yn ) .
lo.. -!I.!u!!.-
I
s
',837
l1,a18
'.626
13,161
Ii ,&99
19,515
:11,418
44,ho
1.,032
16, 4t 7
lIi.Oft3
30,242
-------
TABLE 7-1
AMBIENT AIR SAMPLING DATA(A)
NY ANZA CHEMICAL SITE
January 1983
Mercury vapor (-4 inches above
Area A surface) ,
Mercury vapor (50-75 yds. downwind
01 Area A)
June 22. 1983
Mercury vapor (above Area A
surface)
Mercury vapor (- 6 inches below
Area A surface)
Mercury vapor (50-75 ft. downwind
of Area A)
Organics In Air
November 19833
Trichloroethylene
1.2 Dichlorobenzene
1.3 Dichlorobenzene
1.4 Dichlorobenzene
Nitrobenzene
Concentration
Detection
Limit
74 ng/m3
Unknown
7.2 ng/m3
Unknown
220 ng/m3
Unknown
450 ng/m3
Unknown
48 ng/m3
Unknown
0.5 ppb
ND
NO
ND
NO
NO
0.5 ~g
0.5 ~g
0.5 ~g
0.5 ~g
0.5 ~g
Typical New England Ambient Air Mercury Vapor Concentration: 7-10 ng/m3.
ND - Not Detected
7-4
-------
DRAFT
TABLE 7-1
'AMBJENT,AIR\SAMPUNG DATA
NY ANZA CHEMICAL SITE
PAGE lWO .
A.
See Figure 7-1 for sampling locations.
.1. "Januarv 1.983.Climati,c Data
. . Temp: 15-20of
Wind: Velocitv Unknown. From W-SW
2. June 1983 Climatic Data
Temp: 85-90oF
Wind: 2-4 Knots. from W-SW
3. November 1983 Climatic Data
Unknown
Note:
January and June Sampling Reference: EPA Interoffice Communication,
July 19. 1983. F.' Willey to D. Gagne, Air Toxics at Nyanza Chemical
Site.
-------
DRAFT
TABLE 7-2
NY ANZA CHEMICAL SITE
SOIL SAMPLES
TOTAL OF 66 SAMPLING LOCATIONS IN THREE AREAS
ALL VALUES mg/kg
Soils - Area B of Figure 7-1
Positive
Contaminant HiQh Averaqe Std. Dev. Observations
Cr 975 215.4" 260 39
Hg 420 35.3 67 40
Cd 2.3 0.25 0.39 38
Pb 558 79.6 102.4 40
Total Halogen None Detected
Total Organic Carbon 103,300 33.473 24,756 40
Soils - Area C 01 Figure 7-1
Positive
Contaminant Hiqh Averaqe Std. Dev. Observations
Cr 182 126.1 55.6 5
Hg 420 281.5 162.9 5
Cd 0.2 0.14 0.03 5
Pb 109 68.3 33.9 5
Total Halogen None Detected
Total Organic Carbon 120,100 43.760 43,132 5
Soils - Area D of Figure 7-1
Positive
Contaminant HiQh AveraQe Std. Dev. Observations
Cr 87.5 25.8 23.6 19
Hg 58 16.6 20.3 19
Cd 1.3 0.29 0.35 18
Pb 154 51.9 39.9 19
Total Halogen 700 272 193.9 7
Total Organic Carbon 98,600 33.705 27.152 19
-------
DRAFT
TABLE ]-3
, , ,NY ANZA CHEMICAL SITE,
SURfACE WATER CONTAMINANTS
( ~g/I)
" "
Trollev Brook Maximum Observed Maximum Allowable Number of
Contamlnftr'its BackgroUnd Sample Concentration Concentraiioh* Observations,
Trichloroethylhne " 25 ** 6
Chromium <10 20 50 9
lead 1.0 10 50 7
....,
I
W Mercury <.4 1.8 2.0 12
*
InteriM Primary Drinking Water Standards, 40 tFR 141
No bdriking Water Staridard exists. Ambient Water Quality criteria corresponding to an ihcreased cancer risk of one
additional case per one million people is 2.1 ~g/l.
*~':
-------
DRAFT .
TABLE 7-4
SEDIMENTS - 7 SAMPLES
NY ANZA CHEMICAL SITE
Critical Health Maximum (mg/kg) Average Sediment Background (mg/kg) Number of
Contaminant Concentration Concentration (mg/kg) Concentration Observations
Chromium 6,600 142.;t. 28 7
Cadmium 1.8 0.53 1.2 7
Lead 1,200 190'" 120 7
" Mercury 420 254 Unknown 7
I
....
m
Volatile Organic$ None Detected None Oetected None Detected ,',~,
Compounds
1: In averaging, a single order of magnitude outlier value was discarded
,':1: Two samples were analyzed
Note: See Appendix D for complete analytic data.
-------
OHI\H
TARLE 7-5
NY ANZ/\ CllEMICAl SITE
. GROUNDWATER CONTAMINANTS
44 SAMPLES
Critical Health Average Maximum Maximum Allowable. Number of
Contaminant Concentration (~g/Ii Concontratlon l.1!9L!.L Concentration (J!9& Observations
Aniline 1,189 4, 132 .. 1G
Benzene 8.9 27.8 ** 7
Chloroform 5.8 6.9 100 ~gll ,-
.)
1,2 Dichlorobenzene 840 5,345 .. 1fi
1,3 Dichlorobenzene' 70 254 .. !)
..... 1.4 Dichlorobenzene 490 i ,900 .. 21
I
... 1,1,1 TrlchloroothDne 137 180 .. ..
CD .1
Trlchloroothono 1,550 7,000 ." ') ,-
.1
Vinyl Chlorldo 7G 121 .. II
.. No Drinking Water Standard Presently In iorce.
Note:
-------
COMMUNITY RELATIONS RESPONSIVENESS SUMMARY
NY ANZA CHEMICAL SITE
ASHLAND, MASSACHUSETTS
INTRODUCTION
This Responsiveness Summary for the. NVanza Chemical Site documents, for the
public record, the concerns and issues raised during remedial planning, the
comments presented during the comment period on the Feasibility Study, and the
responses of the Environmental Protection Agency (EPA) to these concerns.
ACTIVITIES CONDUCTED PRIOR TO THE FEASIBILITY STUDY
COMMENT PERIOD
Public interest in this site has been moderate and the primary concerns have been
with the extent of the offsite migration of contaminants and with the adequacy of
site test data. Community relations activities conducted by the State and by the
EPA at the Nyanza Chemical Site include the following:
. EPA prepared a Community Relations Plan (CRP).
. A public meeting was conducted by the EPA and attended by the
Massachusetts Department of Environmental Quality Engineering (DEQE),
the Ashland Board of Health, local news media, and 10 citizens to discuss
the OEOE site assessment. (1981)
. EPA participated in a series of public forums on hazardous waste
sponsored by the Massachusetts Foundation for the Humanities and Public
Policy. One of the forums was conducted in Ashland, Massachusetts.
(March 1983)
. A public meeting was held by the EPA in Ashland to discuss the Remedial
Investigation/Feasibility Study (RI/FS) work plan. The DEQE, town
selectmen, the Ashland Board of Health, the local news media, Senator
Edward Kennedy's representative, the EPA contractor, and 25 residents
attended. (June 1983)
. The EPA's project officer established an informal polley of presenting
verbal reports to major community participants every 2 weeks. (1983)
. Fact sheets describing the progress of the Remedial Investigation were
mailed to local citizens and officials by the EPA. (November 1983)
. EPA held a public meeting to discuss RI progress. In attendance were
representatives from the DEQE, the Town of Ashland, the Ashland Board
of Health, State Senator Ed Burke's office, State Representative Andrew
Roger's office, Senator Edward Kennedy's office, the South Middlesex
Chamber of Commerce, Ashland Advocates for 8 Clean Environment
(AACE) and local business. (December 1983)
-------
. Copies of the Remedial Action Master Plan (RAMP) and the Work Plan,
which were produced by the EPA contractor, were sent to the information'
repositories at the Ashland Public Library and the Ashland Board' of
. Health..by ..the EPA.(1BB3)
. The EPA held a pUblic meeting to discuss RI findings. The RI and data
gaps that it identified were discussed. The EPA contractor and the
Ashland Board of Health were represented. (November 1984)
CONCERNS RAISED PRIOR TO THE FEASIBIUTY STUDY COMMENT PERIOD
The' '.primatyconcern :;explused.'.:bv;.the ,'Ashland ..;l;:ommunitv ,..at..,tbe .first ,pubJic
"
-------
Approximately 30 citizens attended the April 10 meeting held at. the local high
school auditorium. They included community officials, representatives of the
AShland Board of Health, and members of AACE.
Present at the April 18 hearing were members of -the AACE, the Ashland Board of
Health, the community of Ashland, and State Representative David Magnani.
Comments from 18 hearing attendees were officially recorded and a transcript was
produced. The hearing transcript was made available at EPA offices in the
John F. Kennedy Federal Building in Boston and at the Ashland Public Library.
SUMMARY OF COMMENTS AND RESPONSES
Numerous questions of a general nature were asked at the public hearing. These
were addressed as they were presented. Questions raised included EPA decislon-
making policy, enforcement strategy, funding and distribution of funds, financial
and legal liabilities, statutory limitations for excavating and transporting
hazardous wastes, State responsibility for remedial action funding and
maintenance, the physical limits of the RI study area, an emergency evacuation
plan, remedial technologies, range of costs, community input and control,
monitoring, and the hazard ranking system. Copies of the complete transcript are
available at the locations mentioned on the preceding page.
Commen'ts that were not addressed at the hearing have been summarized and
categorized in the following sections. Within each category, comments were
separated into three groups according to source: community comments, State
comments, and Potentially Responsible Party (PRP) comments.
Community comments Include opinions from Individual residents, local officials,
the Ashland Board of Health, and the AACE. C.omments from State
Representative David Magnani were also Included in this section because he
seemed to be speaking on behalf of his constituents rather than as an official
representative of the Commonwealth of Massachusetts.
State comments are from the Commonwealth of Massachusetts, Executive Office
of Environmental Affairs, Department of Environmental Quality Engineering,
Division of Solid and Hazardous Waste.
The only Industry that was officially identified as a commentor was Nyacol, Inc.
ADDmONAL ALTERNATIVES SUGGESTED BY THE COMMUNITY, STATE,
OR PRPS/OTHER INDUSTRIES
In addition to the remedial alternatives evaluated In the Feasibility Study, DEQE
requested an evaluation of an optional configuration for a secure landfill
constructed atop the hill area. This option was to Include the excavation of all
waste materials fottowed by the construction of a secure waste repository founded
at the base of the excavation. It was also to provide for permanent groundwater
and surface water lowering and diversion.
Subsequent evaluation showed that the alternative proposed would require less
backfill for the excavated cavity than Alternatives 9 and 12. Groundwater
-------
lowering would be achieved in a manner similar to Alternatives 3 and 5. These
alternatives have been previously described in the Phase I Feasibility Study or in
the Addendum to the Phase I RifFS.
,'The '\ri!dU'Ctlon '-'Of:badcfUk ,'quantity .would Joe' ';app-roximately"3B:BOO'.,cubi'c,yard s. The
cost savings for this reduction of backfill would range between $444,000 and
$1,022,000 based upon the -20 percent and +30 percent volume of sludge that might
be encountered. The additional cost for the surface and groundwater diversion
requested would range between $571,000 and $1,180,000 for the variations of
factors evaluated in the cost-sensitivity analyses. These costs are added and
subtracted to the remedial action Alternative 12, which Is similar to the other
conStrUtticm . work .1'8QUif\8d :forfhis .,:04'tion. ,The:net ';-.ffect ':'on, 'the, capite' " .cost,
estImate' wou'fd . 'be "11tgtt1!T "tha",'"tt1e''Cb'St5lfor ?Attemative'12. . Th~:','iCllp1t81',costs
would range between 59,455,000 (low estimate) and 515,863,000 (high estImate).
The reductIon in risks to public health and the environment would be less than that
afforded by Alternatives 9 and 12 which provide for a secure repository. The
technology of permanently lowering the groundwater level to the surface of 'the
bedrock would not be as reliable as backfilling the cavIty above groundwater levels.
Therefore, this alternatIve is less effective and less reliable than Alternatives 9
'and 12.
REMAINING CONCERNS
The community remains concerned about the quantity of contaminated materials
present at the Nyanza Chemical Site. They have asked to be kept well informed of
site-related progress and activIties. Several individuals and officials suggested a
biweekly fact sheet distribution be arranged.
Concern also remains regarding loss of committed funds If a remedial alternative is
not chosen and designed before the end of the fiscal year. Therefore, project
scheduling is important to the community.
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COMMENT INDEX
PAGE
t. Superfund Procedures:
Community Comments 6
II. Technical Procedures and Data Gaps:
Community Comments 7
State Comments 11
III. Costs and Funding:
Community Comments 13
PRP/Other Industry Comments 15
IV. Remedial Action Alternatives:
Community Comments 15
State Comments 21
v. Health Risk Assessment and Environmental Impacts:
Community Comments 22
State Comments 24
PRP/Other Industry Comments 25
VI. Site Investigation Parameters:
Community Comments 25
State Comments 25
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SUPERFUND PROCEDURES:
COMMUNITY COMMENTS
I "
,":Commlint ,',What. ,impact ,;does "EPA'si,May '6..11985 .memDr.andumon '?rocedures for
Planning and Implementing OffsiteResponse Actions. have on
remedial alternatives at this site, and has that impact already been
considered in the choice of site alternatives?
Response:
The procedures outlined in the May 6, 1985, memorandum would only
be implemented if the Record of Decision selected an offsite disposal
,,',option. ,At "ths RifFS ,,S,tage. .EPA'.s ..contra,ctors select a commercial
,--:::.disposaJ facUjty;,'.tD,'.costout':8n :a'ternatbfa. ~;CDntact .Is \made' -with the
facility to get information on price, wastes accepted, and general
availability.
Comment:
Objections were raised to the alternatives presented in the Addendum
on grounds that EPA policy requires a 3-week comment period and
,':onJy ,s:4avs........e'.pI'DVjdad lDr,.v.aluating ,these Jastaltemath/es.
Response:
The Addendum addressed comments made during the RIIFS review
process and public comment period. The two .new. alternatives
, . presented were modifications to or hybrids of existing alternatives.
Comment
Are remedial alternatives subject to local zoning, building, and fire
codes, and Is written approval from local authorities and the Board of
Health needed. Does the community have any recourse If the selected
remedial alternative Is unsatisfactory?
f
i ,
'.,Response: .
'.".Uno'eT' ..'cun-em' :.:ePA draft '1J)o'Ucy, ':(Superfund~!remetiia1.'.'Cti,ons ,'wU1not
have to comp1yw1th'1he"DTOC'eduTSI 'lInd!''8'dmtnlstnttve ''8s!pet:tsof
other environmental laws and regulations (Federal, State, or local).
The' construction contractor will need to secure other permits a5
necessary.
I ..
Comment
Remedial cleanup technologies are often Impermanent. What
, .,.......ce :;;is '8HRB'i2hllt ':monltoring:.wm. 'tbe'. "..dequate. 'Can ,--:ft8W
technologies developed' in 'the'futurebea-pp'fied"tQ..'t'hfs"slte? "How will
the future use of this site be restricted to protect the integrity of any
remedial measures taken here? Will It be necessary for, the
Commonwealth of Massachusetts to take possession of the property to
perform long-term operation and maintenance?
6
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Response:
Cleanup and monitoring activities are current. state-of-the-art
procedures for identifying and remediating inadequately disposed
wastes.
Whether or not new technologies developed in the future may be
applied to this site will depend on the need; Le., does the onsite
containment remedy adequately protect public health and the'
environment? As long as waste remains on site, the site can be listed
on the NPl if it meets the National Contingency Plan (NCP) criteria.
Thus, new technologies can be applied to the site in the future if the
current remedy fails.
Future use of the property will be restricted by the imposition of use
restrictions or other legal procedures. The Commonwealth will not
have to possess the property but will need to have a right-of-access to
perform operation and maintenance.
Comments: The public needs to be informed of progress and developments during
the construction and design phase. It is suggested that biweeldy fact
sheets be reinstated.
Response:
The existing community relations plan will be updated to provide
information'during design and construction. Periodic progress reports
will be sent to citizens and the press on the mailing list. Informal
conversations between the Site Manager and local citizens and
officials will continue also.
TECHNICAL PROCEDURES AND DATA GAPS:
COMMUNITY COMMENTS
Comment:
Response:
The RIIFS Report is inadequate and does not present enough
information to make a remedial 8ction alternative decision. The
report Is based on the same data that was considered Inadequate In
September 1984. Both the report and the EPA contracto~, hired for
the design of the remedial 8ctlon alternative, stress that additional
sampling Is needed. .
The Nyanza Chemical Site has been studied by 3 different consultants
in the last 5 years with EPA and DEaE review. As with every other
uncontrolled site, the data do not always provide 8 perfect
understanding of the situation; anomalies do exist. However, EPA is
confident that adequate data exists to support source control In the
Record of Decision. Further refinements will be made during the Pre-
Design and Design Phases. and contingencies will be built Into the
construction contract to handle unforeseen circumstances.
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Comment: Arsenic was found in 31 groundwater samples, yet no link has been
established between the arsenic contamination and the sludges. Since
Phase I is supposed to deal with all of the heavy metals on site, it
seems premature to proceed with remedial actions until the source .of
. ' '.tb8 'arsenic \isfound.
Response:
Comment
Response:
Comment
"Reaponse:
The results of tests for arsenic in the environment, reported by
previous investigators, indicated the concentrations were within
naturally occurring limits in soils and below safe drinking water
standards in water samples. Therefore, testing for arsenic In sludges
was not deemed necessary in the RifFS, since It was not previously
. ,idantifJad..at..hi,gh .J;DACe,nuatio.ns.
How can the treatment of sludge deposits and groundwater be
separated? What Impact will sludge removal have on groundwater
quality and groundwater remediation?
Phasing is fully In accordance with 40CFR 300.68 of the National
'. :Contingencv .pjan.;.whid1 'ditt.umtiaw ,.betWMI1 .t5.o.uriiCe4:ontr.oj~actions
JendlOffsitezem.edial.4ctions.
The existing data indicate minimal groundwater migration of heavy
metals frolT' the leaching of sludge deposits. These sludges do migrate
via surface runoff and also present a potential direct contact hazard
where exposed. Both surface migration and direct contact potential
can be abated by in situ capping.
Even after these sources are removed, the groundwater will remain
contaminated until the aquifer Is purged. The Phase II FS will examine
the threats posed by No-Action, I.e., allowing the aquifer to cleanse
Itself. If unacceptable risks are presented, various groundwater
<"remediation'Stt8tegies )wiU . 'be .:studied. "These'Temet:UB'S'wou'ldbe
different since "source control remedieslnvotve' -exc'8vatlona'nd/or
isolation. Groundwater remediation might require pumping out the
contaminated water and treating It.
The validity 01 background samples Is highly questionable. In most
cases, only one sample, per medium, was taken. Often, those samples
sbowed '.8I8vated' .COJI'tam'inant.1ev'8ts;,:additlonel';I8Sting shou1d be
performed to rule out the possJbUIty of1aboratory error. "If 'Iaboratory
error did not occur, how can the EPA claim to have taken these
samples from a clean area, and how can assumptions based on these
samples be valid? In some cases, no background values were presented
at all.
.The -..backgr:ou.nd-,.sampJes wer.e obtaine.dfr,om area,s. tha%.were
.:believed .to :"be.-1JP9~adlent'8nt:f. D'Utslde.theJimits ':of .sk.adge' dumpl"g
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Comment:
Response:
Comment:
Response:
activities. Concentrations of heavy metals and other contaminants
can be expected to be present in soil and water samples reflecting the.
ambient conditions (background) of the locale. Other possibilities for
the contamination found in background samples might be attributed to
a random incident of dumping, contamination during test pit
excavation, contamination during sampling, and/or contamination. in
the laboratory. The pre-design sampling is expected to clarify the
questions associated with the limits of contamination and background
conditions.
Test results should be presented individually for critical contaminants,
and concentration units for each specific medium should be
standardized.
Test results for individual constituents are reported in Volume 1A of
the Phase I RifFS. Summations of concentrations 01 key constituents
were presented in the report to summarize site contamination and
simplify the presentation. The presentation supports the conclusions
of contaminants present at the site and the need for remediation.
Different media such as soil and groundwater cannot have
standardized concentration units. Concentrations in soils are.
traditionally expressed on a weight-by-weight basis, whereas
concentrations in water are expressed on a weight-by-unit basis.
Boring samples should be taleen prior to sludge removal to determine
the depths to clean soil; soil color should not be considered adequate
to determine the presence of contamination. The possibility of an
Inorganic sludge deposit beneath the lower Industrialized area should
be explored. Monitoring well samples should be collected during rain
conditions to help determine whether the hili sludge deposition area Is
a major contaminant source.
The quantities 01 sludges were determined by 16 NUS test pits,
80 Connerstone and Carr test pits, use of previous reports, and
Interpretation of historical photographs. Analytical tests were
preformed on 66 samples of sludges, and the results are reported In
Volume 1A. The Identification 01 sludges Included visual observations,
Including all colors, !M laboratory testing. These data were used to
estimate the likely quantity of sludge to be encountered.
The sludge solids tend to be less mobile than liquid fractions In the
environment and are not likely to be transported through the ground.
The more mobile constituents associated with the dumping (I.e.,
solvents, soluble materials) that have migrated Into the groundwater
will be addressed In the Phase II RifFS for groundwater remediation.
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Comment:
. .':;fte'SpOnS8~
Comment: .
Response:
I.'
j'
Additional test pitting and sampling are proposed prior to the final
engineering design. The testing will establish the precise extent of
waste deposits and the amount of contaminated materials that must be
. realov.ed,during .site £Jea.nup.
The extent of contamination in the bedrock aquifer should be
determined. Fracturing of the bedrock should be characterized to
determine the feasibility of using a grout curtain/slurry wall at the
site. .
'~'8 '''fUn ..;'StUdV~oof ''grOundweter ''Cont.m:tn.tton ;:,.nd ':\...medl.l~measures
are proposed under' Phase II. The contaminants in the groundwater and
the bedrock have migrated to these locations from the location where
they were dumped. Dealing with the source of the contamination, I.e.,
the sludges, will control the generation of additional groundwater
contaminants and may isolate them from the potential for direct
contact by human and environmental receptors. The grout curtain
technology has been dropped and replaced by an open cut trench.
Conflicting and/or incomplete information was presented in the
drawings in the RIfFS Report, especially Drawing 0714-06-03, in the
October 1984 and March 1985 reports. No additional data were
supplied for the second report.
In December 1984 additional field testing and test pit excavation were
conducted In the hili area to visually determine sludge deposits.
Drawing No. 0714-06-03 In the March 1985 report illustrates all known
sludge deposits based on previous reports, historical data, and onslte
,In.v.astigatlons. Based on this data, the volume of sludges and
<.>amtaminatetJ1iU w.ers ,reca:lcuiated.
The volume of sludge, fill, and contaminated materials present on the
Nyanza Chemical Site, and Immediately downstream along Trolley
Brook. Is estimated as 103,700 cubic yards. This figure was the best
estimate of the volume of sludge, fill, and contaminated material
based on data available in April 1985. The locations and volumes of
Individual deposits are summarized on Drawing No. 0714-06-03,
,..,Sbeat,3.of ,,8, . lnthe . RemadiaJ Investigation .Rep.ort. The limitations
'::.;posacf.;by .u..",availabj8.':data.and -the need/for :8ddltionat>-'taatlng'were
presented in the report. In order to estimate the impact on project
costs due to a greater or lesser volume 01 contaminated material that
might be encountered during actual construction, reasonable variations
in the volumes of minus 20 percent and plus 30 percent were
incorporated into the cost estimates.
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STATE COMMENTS:
Comment:
Response:
Comment:
Response:
The scope of the Phase I investigation was too narrow. It is unclear, in
reading the RifFS Report, whether NUS utilized past investigations
conducted at the Nyanza Chemical Site by DEQE, private consultants,
and the EPA. Wetlands east of the trolley embankment were not
investigated, even though an earlier evaluation indicated the area was
contaminated with 011 and mercury. Wetlands and stream sediments
Immediately adjacent to the former Nyanza property and sediment
transport to the Sudbury River were not investigated. These .should be
addressed prior to a final decision.
The presence of contaminated sediments along Trolley Brook has been
identified as Area VIII and the volume is estimated at 800 cubic yards.
The limits of these deposits were determined In the field during the
December 1984 sampling. Contamination was found within 16 feet of
the brooK. The removal and reclamation of this area has been included
in all remedial action alternatives except the "no-action"
Alternatives' and 2. Any significant decrease or increase in the
quantity of contaminated sediments in Area VIII will be within the
range of contaminated materials estimated for this project.
The eastern wetland was investigated during the remedial
investigation by a walkover, looking for evidence of waste deposition.
The portion of this wetland that is east of the trolley road grade drains
to Trolley Brook through a drainage way In the road grade
embankment. Therefore, the flow is from the area beyond the trolley
road grade Into the established study area for the Nyanza Chemical
Site. The limits of sludge contamination was based on available data
including personal observations, previous reports, and a series of
historical aerial photographs.
Analytical procedures, sampling dates, and compound analyses should
be included In an appendix. and actual laboratory report sheets should
be included to substantiate data. .
The samples were obtained In accordance with EPA-approved
procedures and tested In qualified laboratories. Standard methods
have been employed to obtain the test results. A comprehensive data
review procedure was then employed to validate the laboratory test
results. These test results have been summarized In Volume 1A of the
Phase I Remedial Investigation. The sampling dates for the various
media are presented in Volume I, Phase I, Remedial Investigation.
Presenting the raw, laboratory test sheets would entail a large number
of additional pages (thousands) that would not be meaningful to most
readers.
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Comment:
No calculations were provided for storm water or groundwater
dewatering volumes. Based on soil descriptions from the test pits,
Infiltration rates should be recalculated for surface water.
:'Response: '; :;"Estimates,.of ..,the\'Waters,:to, '
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COSTS AND FUNDING:
COMMUNITY COMMENTS
Comment:
ResDonse:
Comment:
ResDonse:
Comment:
Response:
The range in capital cost estimates and the overlap of the higher cost
of a less construction-intensive alternative with the lower cost for a
more construction-intensive alternative needs explanation.
As explained at the public hearing of April 18, 1985, the factors that
affect the capital costs would affect all alternatives in a similar
manner. These factors included quantities of work, material costs,
and Installation costs. The ranges of costs presented for each
alternative are within the prescribed accuracy for Superfund projects,
Le., plus 50 percent, minus 30 percent. The amount of sludge has a
major impact on costs for both onsite and offsite disposal. High end
estimates will result in costs toward the high end of the range for both
alternatives. .
Methodology for quantifying the sludge and fill volume Is
unacceptable. Therefore, the cost estimates could be Inaccurate and
misleading in deciding on a remedial action.
The methodology for quantifying the sludge volume, i.e., test pitting
analysis and cross-sectional volume computations, is acceptable. The
impact that variable quantities 01 sludge might have on the cost
estimates was accounted for in the sensitivity analyses. The same
range 01 sludges, which might reasonably be encountered, was
incorporated Into the cost estimates of all the alternatives. The
amount of sludge that Is actually encountered will affect all the
alternatives in a similar manner.
Transporting excavated wastes by rail carrier for offsite disposal may
cost less than truck transport.
Use of Conrail to ship wastes 10r offslte treatment presents two major
problems. First, the actual disposal site would not be finalized until
all bids were received and evaluated and a contractor selected. The
particular disposal site will be the prerogative 01 this contractor as
long as the site has all the necessary permits and a good compliance
record. The feasibility of using Conrail cannot be verified until the
disposal site has been selected.
Second, use 01 the railroad will entail two additional
loadlngs/unloadings, one at the Ashland end and one at the terminus
nearest the disposal site. This would have a major Impact on the
transportation cost and would create additional risks due to the
rehandling operations.
-------
Comment:
'Response:
Comment:
Response:
The Cecos facility does not have a rail spur or car
unloadingfdeco~tamination facility to receive wastes transported in
railroad cars. In addition, the presence 01 Conrail trackage adjacent
:.to .'.the';$ite jsnot$ufficieT1t .10.r 'ioading 'r.s1Jcarswith weste.A.si.d,jng.
. . .1oed1T1g. . e'ntidecontem4natloT\ 'fa'cility :would"1)e,requirtransiferconstruction ,'funds-'to"tn8 ,tJ.:S. .'Anny ,OoTps 'Of
.'&tglneers'bv"me'8ns' "of an Interagency .Agreement /(tAG).
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PRP/OTHER INDUSTRY COMMENTS
Comment:
Response:
EPA policy for the recovery of funds should be defined. EPA should
malee provisions to protect businesses on site from financial loss during
the remedial construction period. If local Industries are forced to shut
down, losses could range from missed shipments to permanent loss of
business. .
EPA's general policy on cost recovery was outlined at the public
meetings; the specific cost-recovery strategy for this site (or any site)
Is not suitable for public disclosure. Remedial actions will be designed
to minimize any Impact to the ongoing businesses on site. No forced
shutdowns are foreseen.
REMEDIAL ACTION ALTERNATIVES:
COMMUNITY COMMENTS
Comment:
Response:
Only a secure landfill with a bottom liner, leachate collection system,
and cap Is acceptable for the disposal of the onsite wastes. Therefore,
alternatives that do not provide all these features are. unsatisfactory.
The prescribed scenarios to be included In a Feasibility Study require
remedial action alternatives for five categories of site cleanup. These
five categories include:
.
No-action alternatives
.
Alternatives to minimize generation and/or to mitigate against
migration of contaminants (CERCLA)
.
Alternatives that comply with Federal requirements (RCRA)
.
Alternatives that exceed Federal requirements.
.
Alternatives that provide for the removal and/or destruction of
the wastes
The alternatives proposed are Intended to fulfill the requirements of
one of the cleanup categories. All alternatives are not intended to
provide equal site cleanup and reduction 01 health and environmental
risks. The evaluation of feasible solutions for each category 01 site
cleanup presents data on reduction 01 health risks, Improved
environment, and Implementation costs to aid the decision makers..
-------
Comment:
I -'
I
I.
. '1btsponse:
I
1-
Many of the alternatives do comply with the technical standards of
oth.er laws,principally the Resource Conservation and Recovery Act
.. ,{RCRA). ,Un.der .RCBA. a site mav be ..cJ.ose.d . if .it ~s .capp.ed - wi.t.h .a cap
". "( meeting'tne.requirem.ents:of ,4DCFR Pan .264.
The existing data are so inadequate in defining the extent of
contamination that a remedy should not be chosen at this time pending
further data gathering and analysis.
. :':'Jher:e ':ts"'~ieftt.fRfonn8tion.~ ,"to::~""';""~n.:,8bout
onsite or offsite landfiiling. There is no discussion of siting
considerations for the onsite landfill. A flat low-lying area that is not
marshy would be preferable to the hill area. Groundwater in the hill
area is at a very shallow depth and the hill Is defined as a groundwater
recharge' area. If a landfill on the hill leaks, contamination will spread
quickly to the low-iying areas. What quantity of waste can be safely
placed in a hilltop landfill at the Nyanza Site?
'The .'Nyanla ':OhemiC1!l.Stte "hl'S '"been 'S'tUdied''by-''1hree{S)'-:dtfferent
consultants in the last 5 years with EPA and DEOE review. As with
every other uncontrolled site, the data does not always provide a
perfect understanding of the situation; anomalies do exist. Further
refinements will be made during the Pre-Design and Design Phases,
and contingencies will be built Into the construction contract to handle
unforeseen circumstances. However, in EPA's opinion, there Is
adequate data to determine the extent of contamination and the
appropriate remedy.
The hill was chosen for use for an on site landfill since it Is the only
.area .ofthe "site" of adequate size to accommodate a landfill. The
, .'towerindustriat",aTu' is''DCcupiedby:a :number.,'.of,..,ongDing .,businesses
(unrelated to Nyanza) and is therefore unavailable, as are the wetland
areas.
The landfill Itself would be built to satisfy the technology
requirements of the RCRA reauthorization legislation. A double liner
with both a leachate collection zone and a leak detection zone would
be included, a5 would an Impermeable cap to minimize Infiltration Into
..the .-WAStes.. ,TJ1ass..safe.g,uar,ds.~oupJed .wlth "groundw,atermon1torJns
:-wHJ,.prav.ent ..undetected "8augefrom ,,:tbe -.tecUity ,In ';time .totake
corrective action.
Based upon the type of Insltu solis encountered during the onslte
drilling work and the topography of the Nyanza Chemical Site, a '8afe
landfill can be constructed atop the hill area to accommodate the
volume of wastes that Is likely to be encountered on the Nyanza
: :Chemical,Site.
-------
Comment:
Response:
Comment:
Response:
Comment:
Response:
Can -land disposal- of wastes be relied upon? Landfills will eventually
leak.
The remedial action alternatives calling for the placement of sludges
and wastes into a lined and capped repository are current, state-of-
the-art technology for storage of waste materials. Placement of a cap
over existing waste piles is an applicable technology for closure of an
inactive waste deposit. Waste disposal facilities with these features
are in conforma.nce with State and Federal hazardous waste disposal
regulations.
The required 20 mil thickness of the synthetic Impenneable membrane
Is Inadequate, and compatibility testing for selection of this membrane
should be conducted.
The'synthetic, impermeable membrane should be specified during the
final design phase of the project. The 20 and 30 mil thicknesses for
the impermeable membrane proposed for the cap and liner and cited In
the Phase I Feasibility Study are In conformance with Federal
regulations and were used for costing purposes. In the final design
phase, thickness, strength, durability, and compatibility
determinations will be made to specify the type, material, and
thickness of the synthetic, Impermeable membrane.
The first use of an Impermeable membrane was In 1960, when
polyvinyl chloride sheet was used in the construction of Mission Dam
in British Columbia, Canada. (Construction and Geotechnical
Engineering Using Synthetic Fabrics, R. M. Koerner, J. P. Welsh;
John Wiley & Sons, New York, 1980 pg. 72.) Since that time, much
more knowledge of synthetic membranes and Improved materials Is
available for use in engineering construction. The selection of a
membrane liner system is based on proper installation, physical
properties of the fabric, chemical compatibility data, and durability
data to provide a facility with a suitable service life.
Alternative 10 is most likely to meet with the necessary approvals to
maintain the scheduling required to prevent the loss of funds currently
available for remediation of the Nyanza Chemical Site. However, it Is
unclear whether offsite landfill capacity Is available to accommodate
the contaminated materials from the site If the offsite alternative Is
chosen. By what mechanism must the Commonwealth of
.Massachusetts assure the EPA that offsite landfill capacity will be
available?
It is impractical for the Commonwealth (or others) to reserve landfill
capacity. Should EPA choose an ottslte disposal remedy, the actual
facility will be selected during the competitive bid process. Prior to
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construction contract award, EPA and DECE would jointly implement
the procedures in the May 6, 1985, Offsite Disposal Policy
memorandum. The State Superfund Contract would be the mechanism
by which EPA would require DECE to participate in the facility
. seJectionprocess.
!
Comment: The EPA granted Final Authorization (of remedial actions) to the
Massachusetts Hazardous Waste Management Program (Federal
Register, 2fl /85, pg. 3344). Selection of - a remedy, such as
. . ,AltematJvs-,.l2..vjolatas .sta1e.JandfJU .standards and contravenes State
., :;,and' .:&deral ..,Jaw. .<.AIso. ~ciiPA },pOJicy,.,ntquil'es,,1batthe :,'publlc .be
informed of the extent to which any remedial action alternative falls
to attain or exceed public health and environmental standards; the
report fails to mention that Alternative 12 doesn't comply with State
landfill standards.
Response:
Who o'e a State adopts more:: 'rlngent regulations than the Federal
regulations, the State may be required to pay 100 percent of the
,..i,addittonaJ,;costs"be,yond ,tba.t"naaded.to,,compJy .with .the Federal
, :<$tanderds",:l'egardJass of ,wbetner-;er,.'not ,,:theJ9A'nas,.adOJ)ted 'the '.State
standards In authorizing the State program to operate In lieu of the
Federal program.
EPA has not adopted Massachusetts hazardous waste landfill standards
but has ruled that the State has an acceptable program for dealing
with and controlling the disposal of hazardous wastes.
Alternative 12 complies with the requirements described on page 19.
I'
,:Commem:' .~.,Why 'wer8,!tWO:'new:'aftemllfives ,'present8d:m,,~"";~ndum";,to .;:the
"'Phase 1 - "'Rt1F'S~. and 'Why 'is"'the "surf8ce ~'81'88 ""dftAftemat1ve''9 'gNater
than the surface area of Alternative 121
Response: '
EPA (Region I) requested that two new alternatives be developed,
described, evaluated, and presented to the public In the -Addendum to
the RifFS: The EPA described these two remedial action alternatives
in their review comments to the RifFS reports.
I
I .
';Alternative '12 ,'constructs ''t''e "secure "',f8:posltory:;8bove' ';'.the ...eason'it
high groundwater level. 1t requires less "b8'c'kfitl ''th'an'-A1termrtive:g' and
the resulting surface area of the repository Is only 3.1 acres. This
alternative complies with Federal (RCRA) requirements concerning
placement above the 5easonal high groundwater level. .
Alternative 9 constructs the secure repository above the probable
. maximum bighgr.oundwater level In accordance with Massachusetts
. waste .:disposat 'requi.rements. "ThisaJtern:etive ," requires"moreOffsite
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Comment:
Response:
material than Alternative 12 to backfill the excavated cavity to 4 feet
above the probable maximum high groundwater level. Consequently.
more total material (greater amount of offsite borrow material) is
placed on the hill and a larger surface area of the secure repository
results.
Alternative 11 offers more risk reduction, through waste fixation, than
other alternatives that employ onslte disposal but this alternative was
deleted from the final evaluation. Waste fixation should be researched
further.
As stated in the Phase I Feasibility Study, the presence of debris and
olher waste material" mixed in with the sludges and fill will hamper the
fixation process. The presence of these wastes will cause the "fixed"
product to be unreliable. The g081 of producing 8 highly impermeable
mass will not be achieved and the fixation process will not be
effective. The reduction in health risks by this alternative will be the
isolation of the sludges and waste from the environment In a secure,
lined. capped repository. This isolation will reduce health risks and
improve the environment by:
.
Having no potential for direct contact of contaminated materials
.
Being secured against surface water erosion and transport of
contaminated materials
.
Being secured from contact with the atmosphere and tra.nsport as
airborne particulates or emissions
Being secured against contact by groundwater and the potential
for leaching and transport by this medium
Other alternatives providing for onsite disposal In a secure repository
provide the same Isolation and attendant reduction In health risk and
adverse environmental impacts. However, these other alternatives
require less work and would be more cost effective in reducing the
risks.
.
In summary, waste fixation was eliminated during. the initial
technology screening process due to the simple fact that the largest
sludge volume Is on the hili and Is Intermixed with building rubble and
debris. It is not amenable to mixing with any fixation reagents.
-------
Comment:
How was the determination of the seasonal high groundwater level
made and does Alternative 9 comply with the requirements specified
in the Massachusetts Code for hazardous waste disposal?
!
.;ftespcmse:" '1:b.e;avaiJat)~e' ':daUW8S' .,used.,to:Jestjmate :.the \probable.maximum high
groundwater level, as specified in 310 CMR 30.620. Alternative 9
would locate the bottom of the liner 4 feet above the estimated,
probable maximum high groundwater level consistent with this
requirement.
! .
'~OMn..M.''Wttat'is :1tM.'.pUf.pOR~':of,!tM~:water,;tI88tm8nt ~l8nt :dUringithe !PJvsseI
remediation of the sludges, contaminated soils, and sediments?
Response:
During the Phase I construction, contaminated waters encountered will
require treatment. The sources of these waters were discussed In the
"Addendum to the Phase I - RifFS" and are identified again as follows:
.
Contaminated groundwater from dewatering wells employed to
'. '1ower1he 'g:rDunGWllterkPie:t...in:.areas".WfteM',8XC8vation .ls:pJaGAsd.
.
Contaminated drainage from saturated solids drying on the
rehandling area after excavation from below the groundwat~r
levels.
.
Runoff after a rainfaJI
contaminated materials.
from construction
areas
containing
STATE COMMENTS:
Comment
Should 8 gas venting/control system for onSite 1andfinopt1ons 'conslder
methyl mercury generation? .
Response:
The onsite air sampling and testing did not indicate hazardous levels of
mercury at the site boundary from the undisturbed sludges, obviating
the need for a gas venting/control system. Once the sludges are
properly disposed In a secure landfill, high concentrations of landfill
. ~,.and .mercury ,v.apor.sarenot expected. Caution will be required
. ,.:,during':5iUdS8'8XCavation. which 'sbouklOe:8ccomp1Jshe:d'in';cDnfonnance
with approved excavation' and monitoring plans. 'These specific plans
are to be designed during the final design phase.
-------
Comment:
Response:
Comment:
Response:
Consideration should be given to the possibility that. cleanup at the
Nyanza Chemical Site could be slowed or halted 'by a lack of
out-of-state disposal space.
Availability of disposal capacity at any future date cannot be foreseen
with any degree 01 certainty. Should offsite disposal be selected in
the Record of Decision, the bidders would have to consider the
existing capacity situation and fallback options in developing their bid
proposal.
Aeration/air stripping of VOC-contaminated water prior to or Instead
of treatment by activated carbon may be a cost-effective alternative
for water treatment in Phase I. Iron and manganese removal by
aeration may be more desirable than by chlorination. Perhaps aeration
of the equalization lagoon followed by sedimentation would accomplish
this goal. Adverse Impacts of adding chlorine to water with an
appreciable organic burden should be examined.
Bench-scale testing should be considered to optimize design and
construction of the water treatment facility, especially metal
precipitation unit(s).
A temporary, unitized, factory-assembled treatment plant system that
can be disassembled or scaled-down following construction activities
should be considered.
The design phase of the wastewater treatment plant can consider
these options. A plant should be designed using compatible unit
processes and optimal systems to provide a satisfactory effluent.
An optimal plant should be provided to fulfill short-term (construction)
and longer-term goals, such as groundwater renovation, if required.
The above comments should be considered during final design.
HEALTH RISK ASSESSMENT AND ENVIRONMENTAL IMPACTS:
COMMUNITY COMMENTS
Comment
Response:
Health risks associated with onslte disposal of wastes have not been
adequately assessed. There is concern that children might come into
contact with contaminated sediments in the surface waters and future
residents might install wells for potable water supplies.
The reduction in risks to public health and the lessening 01 adverse
impacts to the environment for sludge-related contamination have
been stated in the Phase I RifFS and the -Addendum to Phase I RifFS:
Reiterating the findings of these reportsl the main health and
-------
. "1:omment:
Response:
environmental hazard associated with sludge deposits is the potential
for direct contact with the sludges and contaminated sediments in and
along the surface water streams. Potential for exposure will exist
until these sludges are placed in a secure configuration to prevent
. ;direct 1:0nt8ct .and/Of:' 'Offs'ite ".transp'OTt I"and ';;depos'ition :b:e'C'aU'seof
continued erosion by surface 'run'O'ff. '{')ta'Cl"'~r'the'Sludges '1nt'O 'a 'secure
configuration, i.e., capping with ground and surface water diversion
(Alternatives 3, 5, and 13), a secure onsite landfill with underliner,
leachate collection and cap (Alternatives 9 and 12), or offsite disposal
(Alternative 10), achieves the same immediate reduction 'Of risk for
direct centact 'Of the sludges and/or centaminated sediments. The
.reductien 'Of risk and impreved envlrenment, ever the leng term, will
:tm maintain.d .~\by.tt\.'ong'otng .;mcnitoring',an:d. .m8intenance Of the
cempleted, secure facility. The censtructien, menlterlng,and
maintenance are current, state-ef-the-art technelegies fer securing
and/er dispesing 'Of waste materials.
The centamlnated sediments In the drainageway dewnstream from the
site ceuld be remeved and placed In a secure repesitory. This actien
weuld remeve the centaminants frem the envlrenment and eliminate
,.tbs.potantiaJ fer direct contact by children and residents. These
. "actions "ar.proposed lnan ..action . aJtemattves 'pro'p'Osed;ln~the 'Phase 1
RI/FS (Seurce Centrel).
Centamlnatien Is . knewn te be present In the greundwater In the
vicinity 'Of the site. The full extent 'Of greundwater centamlnatien Is
net knewn at this time. The Phase II RI/FS Is prepesed te 'Obtain mere
data te identify this contamlnatien. Until the extent 'Of the
greundwater centaminatien is determined, It Is recemmended ~hat ne
wells be censtructed dewngradlent 'Of the site fer the purpese 'Of
extracting greundwater fer potable water 'Or Irrlgatlen purpeses.
'''\What,,1t1'OC8fJunls -wm'be:~~',to ,'i8SSUf'8:~tbe:~ rof.the
public health during the Implementation phase '01 the site cleanup?
These procedures and any emergency response planning should be made
available t'O the public 8S soen 8S possible prior to constructlcn.
Cests fer cnslte menltering 'Of the envlrenment during c'Onstructlen
have been included in the cost estimates. Safety monitoring will
Include testing 'Of air, sediments, soils, surface and gr'Oundwater t'O
,"-.assure .that.the ..,wont :its :1'f'09"8ssing .~jn. :8,:safe !cl'lHlnnet"mu:f .::the..,tnl88t. ''Of
resldent 'and -womrvxpcsure, ,antS ,'offstte 'mlgAttion :of';,"COntam11\8nts
are at acceptable minimums. A detailed safety meniterlng plan will
be fermulated and Included in the final design documents.
-------
Construction procedures will be formulated to safely perform the
onsite activities. These procedures will include safeguards to prevent
hazardous concentrations of contaminants in the environment.
Contingency plans will be formulated and implemented if hazardous
conditions would occur.
Design of the remedial option will include the design of an air
monitoring system to continually monitor air emissions for comparison
with ambient air standards or guidelines for toxic air pollutants. A
contingency plan will be developed by the designer in concert with
EPA, the Center for Disease Control (CDC) and the DEQE. This plan
will outline hazard levels which, if reached, will trigger response
actions such as work stoppage, evacuation, or additional monitoring.
This plan development must await selection of an alternative to be
specific. Other issues of safety, site security, etc., will be addressed
in the bid documents and will have to be satisfied by the construction
contractor before the U.S. Army Corps of Engineers will issue the
Notice to Proceed.
STATE COMMENTS:
Comment:
Response:
Comment:
Response:
Not all of the contaminated areas are. fenced. Also, potential for
direct contact 01 contaminated sludges along the stream, in both the
culverted and open areas, is not clearly defined.
The contaminated sediments, soils, and sludges in unsecured areas do
pose a risk to the public. The potential for direct contact of these
contaminants exists in the wetlands along Trolley Brook.
Massachusetts DEQE is currently planning to fence these areas to
restrict access.
The potential for contact with contaminants in the air Is not known
because previous studies have addressed point sources rather than a
20-acre source.
Design of the remedial option will include the design of an air
monitoring system to continually monitor air emissions for comparison
with ambient air standards or guidelines for toxic air pollutants. A
contingency plan will be developed by the designer In concert with
EPA, the Center for Disease Control (CDC) and the DEQE. This. plan
will outline hazard levels that, If reached, will trigger response
actions, such as work stoppage, evacuation, or additional monitoring.
This plan development cannot be specific until the selection of an
alternative. Other issues of safety, site security, etc. will be
-------
Comment:
Response:
I
I '
addressed in the bid documents and will have to be satisfied by the
construction contractor before the Corps will issue the Notice to
Proceed. '
The unprecedented magnitude of oftsite transport creates a demand
for the development of vehicle decontamination measures.
Decontamination of construction equipment leaving the site will be
required. This can be performed on the rehandling area provided for
",all,onsite . .d~spo.s.aJ .aJternatjves.8BmowaJ, :;ofw:8ste,to.n :.offsite
acUity 'will ;,,~.quiT.e'_contamir.ation.',;of' ','1be :~rBn~o.r.ter, ',prtor .to
exiting the site.
PRP/OTHER INDUSTRY COMMENTS:
b
Comment: ,,~o.sure .to",J:Ontaminants "!during~onstlUction,,. ,activtties";~coutd ';:affect
" 'both ,short-,;and..:,~term,'ibeaIth ,:.ot,M'ortera::8ft..:the.:onstte.,mdustrial
complex.
I
I ~'
Response:
: Design of the remedial option will include the design of an air'
monitoring system to continually monitor air emissions for comparison
with ambient air standards or guidelines for toxic air pollutants. A
contingency plan will be developed to outline hazard levels that will
trigger response actions, such as work stoppage, evacuation, or
additional monitoring if exposure action levels are reached.
,'jStT:E:1NVES11GA11ON (PARAMETERS:
';';;GOMMONt1Y"'COMMENTS
Comment:
The areas north of the railroad tracks and east of the trolley
embankment should have been Included In the scope of the RIfFS.
Surface water dralnageways should be Included In the Phase I cleanup.
The Board of Health requests that the Trolley Brook drainageway be
made the focus of a" Immediate removal action. The area upgradlent
of the site should have been more widely sampled.
Response: 'The 'wetfand'are's'snorth of the Conral1 tracks and east of the trolley
bed were sampled by COM during the pre-design phase; the results are
provided in the pre-design report. '
The sediments in Trolley Brook will be included In the Phase I cleanup.
Actions to fence the open portion of Trolley Brook untl1 excavation
next year are under consideration by EPA and.DE.OE.
-------
Additional upgradient sampling was conducted by CDM to better
define background contaminant levels.
STATE COMMENTS:
Comment:
Response:
The State reiterates that the above named areas north and east of the
site should have been included in the RIIFS.
Refer to response to .Slte Investigation Parameters:
Comments:
Community
-------
Mr. Michael Deland
Regional Administrator
U.S. Environmental Protection
JFK Federal Building
Boston, Massachusetts 02203
."
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S. RUSSELL SYLVA
CommisSioner
?lA€ -f5~1Ih 0/ J~~
/c. (";)3' - r: ~r/,f'
-nltll d((al<~'f i:"'q('n~~'I"-!:nJ
C~11{nk?' JtHe~ ~v;kn O.tt08
September 3, 1985
AGency'
Nyanza, Ashland
Phase I Remedial Action
Re:
Dear Mr. Deland:
The Department of Environmental Quality Engineering has reviewed the
following documents prepared by EPA and its consultants on the Nyanza federal
Superfund site in Ashland, Massachusetts.
1)
2 )
3 )
4)
Draft - Phase I - Remedial Investigation/Feasibility Study Report
Volumes 1 and 2, March, 1985;
Draft - Phase I - Remedial Investigation/Feasibility Study Report
Volume lA, Phase I, RI Appendices, March, 1985;
Appendum to Phase I - Remedial Investigation/Feasibility Study
Apri 1, 1985;
Report of field Work Completed, Technical Assistance for the Nyanza
Chemical Site, Ashland, Massachusetts, July 1985
Draft Record of Decision, Remedial Alternative Selection, Nyanza
Chemical Site, August, 1985.
The Department has also received and reviewed comments from the Ashland
Board of Health, the Ashland Advocates for a Clean Environment (AACE), the
Citizens Advisory Committee, and State Representative David Magnani.
Additionally, Department staff have met with members of the Board of Selectmen,
. Board of Health, AACE, and interested citizens and abuttors to discuss further
issues regarding the Nyanza site. .
5)
The concerns of the community, as expressed in writing and at the public
hearing and meetings, have been: (1) the technical inadequacy of the Remedial
Investigation/Feasibility Study (Rf/FS), and (2) the community's preference for
excavation and disposal of contaminated materials in a 'secure landfill' as the
-------
'~ .'MlchaelDeland
Regiona l'Ad,miTll's't'ra t'or
Page two
The Department has two major areas of concern regarding this project. The
first.conc.ern ,,re9ards ,the lack of community involvement in the decision-making
'pro.c'e5s. ,;T.he\design and:impJ.ementatiDn'cf ~.both 'Phase :,I:and ,Phase :lImust pro-
vide ample opportunity for community and DEQE involvement.
An Advisory Committee aireacy has been es::c: jsnea by ~ne ::mm~nlty f;r
this purpose. The Jeoartment strongly supports tne :ommittee ana believes ~na:
snort and long term sol~tions ac~eptao1e to the ~cmmunity can only be acnieved
through a ciose working relationShip among the community, DEQE. and EPA.
'. . The ,J)e'P'aT':tment:J:s '''S'e.r:.D:no, ;ar:ea;of :;c.on.c.ern:;.s -:te'Cnnic:a'l "tn ''nature. , First. the
;'~aTtmen't ';'s'ccm'C~ne'd 'a;bout,;' t~ :'~'deQtJ~cyo'f 't'tte'd:at,! :i'n "tne>dra'ft'fI/fS to
support the proposed Phase I Remedial Action. Secondly, we are concerned about
the patential impacts associated with implementing the praposal. These cancerns
have alsa been expressed by the cammunity.
In respanse ta the technical inadequacies .of the draft RI/FS, EPA tasked
Camp, Dresser, and McKee ta perfarm additianal field and labaratary wark ta
better define the nature and extent .of cantaminatian. EPA then chase the
. '~'o11(oW;ng '1'"I!mt!di'.') <;:aCt;1'Oft coa l~erna~:ive:
o Excavatian .of .outlying sludge depasits/sediments and cansalidatian
with Hill area sludges
o
RCRA capping .of the Hill area
o
Upgradient surface water/graundwater diversian system
Dawngradient manitaring system
o
The Department feels that the remedial action strategy chasen by EPA will.
b,y remaving the highly-cantaminated lowlands areas, remave the greatest source
, .of ''heavy- ~meta~]:'COrJtam1;nat~ion 'tosurface!~nd::grotln'd'Waters. ~CapJ):i'ng.icnste-ad of
the Hlll area excavatian necessary'forHa secure'lan'df'fl1, will minimize air
emissians and assaciated patential health impacts. This alternative, if the
groundwater data an which it is based is canfirmed during design, presents an
acceptable balance between graund water protection and the patential negative
impacts associated with the canstruction .of a lined landfill. The Department
daes not anticipate the use of this site far any other hazardous waste.
. Therefor.. after review and evaluatian of all the data and the potential
,t)eftef,i:ts ".land. ,blltacts'.Dfc,tfIe '.l~temathe, ,remedi\a'1'ac,t''t1m5,.;prestmted,''the
Department concur's, subject 'to the-cond'it10ns outl'ine'dbe'law, with the 'Phase 'I
remedial action strategy praposed by EPA. This cand1tional concurrence is based
an the premise that information to be developed during design will confirm EPAls
analysis which justifies the canceptual basis far its choice of remedy, and
that, 1f 1t daes not, the remedy will be reconsidered.
The f.ollowing 1.5 necessar.,y t.o ,confirm the canceptual b,asis for EPAI,s
dec 151 on:
-------
~'r. '1 i : h a..: ~ : ~ ~ a. n a
~~giJnal Ac~~~~s:a.tJr
:; ::9'= :~r-:~
:>
The :ons:r~c:~~n arc eva~ua:~~n of :ne ;Jri~c~
di~ersion sys:em ~rior :: Hi~l c5coirg.
... ~ : -=~. . ; r ~ ~ n c ,'. .: : ..; ~
o
~dditional assessment of the impact of Hill s1udges on groundwater.
o
excavated
of these highly
might be
An evaluation of the feasibility of the fixation of the
materials from the lowlands. If feasible, the fixation
contaminated materials would minimize any leachate that
generated.
The following areas should be evaluated for inclusion in the Phase I
remedial action:
o
Old Nyanza lagoons
Spring-bed on eastern side of hill
o
Suspected antimony pit
In addition to confirming the conceptual basis, the following is needed to
address major technical concerns regarding the implementation of the proposed
remedial action:
o
o
A small pilot project on the northwestern wetlands near the Conrail
tracks to validate theoretical estimates of modelling in order to deter-
mine the impact of vapor and particulate mercury emissions on workers,
abuttors, and ambient air quality. Phasing of the construction such
that minimal construction during the summer months may be warranted.
o
An evaluation of the methods of trench excavation to ensure adequate
performance of the surface water groundwater diversion system.
Additional issues will arise during implementation.
discussed thoroughly with the Advisory Committee.
The Department believes that both the conceptual and implementation issues
can be resolved and is looking forward to working closely with both the
Advisory committee and EPA toward that end. We anticipate that as design
progresses, the information which becomes available will allow us to either
reconfirm or reconsider the Phase I remedial action proposal.
These should be
Finally, as has been discussed between our staffs, the Department feels it
is necessary to fast-track an evaluation, and take removal actions if
appropriate, of the organic chemical contamination associated with the 'vault
areal, presently scheduled to be studied by EPA in Phase II. This area is, a
major source of groundwater contamination, and while not addressed in Phase I,
should not be delayed until the results of the Phase II study are available.
Therefore, the Department believes it is appropriate to use its own contractors
for this purpose and will apply to receive 'advance match credit'. We look
forward to working cooperatively with EPA to begin this study in the near
future.
",'.
, -;-
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Ashland Board 'Of Selectmen
Ashland Board of Health
A.A.C.L
State Representative
State Senator Edward
Sanford M. Matathia,
Senator John Kerry
. ?$ena'tor :,£dward . Kel1n:edy
. 'U ~\S. ''0ongT''esosman ,Jos,eph tar 1 y
Richard Chalpin, DEQE .
Mr. ~~:nae; Je"anc
~~;i~~a~..~:m'~n.'s':r~::~
"' -
... 3;i i? ~ ~ '..J 1"'
.'SRS/MS/j'p
cc:
I
I
David Magnani
Burke
Esq.
-------
"
. "
"
ATTACHMENT III
-------
"Wetlands-A'Ssessrnent'forthe Nyanza.Cbemi:ca.l .,Site" . -Ashland. MA.
on March 20, 1985, Richard Cavagnero, EPA project officer, and
Douglas Sparrow, u.s. Army Corps of Engineers staff biologist,
'Y.isit-edthe . Ny,anza ..si.te to perform an assessment of the wetland
areas both on and cont iguous to the s'1 te which may be imp'a'C'te'd
p
by remedial actions taken at the site. Assessments of this nature
are based solely on visual observations and typically include:
I
I'
-'. :a'g.e.neral -:charac,ter.iz'a t.iion. o:f:wetland.v:ege.tati'on 'coveT. ~types.;
- a general characterization of hydrologic features;
an evaluation of the level of disturbance to the wetland
areas from human factors (i.e. degradation).
That assessment follows:
Observations:
The site walkover began on the Hill area from which we pro-
"
I
ceeded north down the slope to a wetland area ot approximately
'2 :ecres..which.is :bounded'.on .the 'north :by:tbe:CONRA:'X'L'trac'ks...:The
c
eastern terminus of the wetland is just above the headwaters of
Chemical Brook, an intermittent stream which was virtually dry' at
the time of our tour.
Standing water was present over one third
.of ';tbe;wetland
-------
~ (, t ~/
inants to the water column for eventual transport into Chemical
and Trolley brooks and ultimately to the Sudbury ~iver.
Thus
it was deemed that in order to effectuate the CERCLA goals of
minimizing public health and environmental risks, no practicalbe
alternative exists but to excavate the sediments in the wetlands.
c
In situ capping would effectively destroy the wetlands which would
eliminate their value in providing storage of stormwater runoff
and discharging groundwaters.
The result would be to increase
flows in the two brooks, although the impacts to each would be
negligible since neither is suitable for recreational usage.
Excavation of the contaminated sediments followed by backfilling
to ori~i~al grade and revegetation would maintain the existing
water storage capacity while providing the opportunity for establishment
of a more diverse plant community and improved habitat value.
The alternatives for handling the sludges would have minimal impact
on the wetland areas.
All of the onsite options involve capping,
;:>
which would eliminate the runoff of contaminants from the Hill
area into' the wetlands.
Certain of the capping options include
provisions for upgradient diversion of groundwater and surface
waters around the Hill area~ these waters would nevertheless still
. .
flow to the wetland areas although their path would be slightly
altered.
Page retyped for NTIS-"'December 31, 1985
-------
(>
to the west along with discharging groundwater.
The only plant
s~ecies obse~ved was ~eed ~~ass (Phragm_~tes_~~~?~i~).
No
aquatic life was observed although some bird species were observed
in the a~ea.
Sludge of various colors including black and purple
was observed on or dir,ectly. bene.at.h th.e ,sur..face .
-------
...,) 1 ~ ( ,
o
,
"
<..>
Conclusions and Recommendations:
Excavation of the contaminated sediments followed by backfiLli~g
to o~iginal g~ade and ~evegetation is the p~efe~~ed option.
measu~es will be ~equi~ed du~ing the excavation to isolate the
wetlands f~om the two brooks to prevent suspension of contaminants
from ~unoff into the b~ooks. Typical sedimentation and erosion
Mitigati
cont~ols will be employed to p~event overland runoff of contaminants
du~ing excavation.
Final details will be developed during the
design phase.
The large water body east of the T~olley bed will be addressed
the Phase II RIFS; a thorough assessment will be performed to
characterize the vegetation, hydrology, and animal life in that
in
area.
Comments from the Water Quality Branch and a wetland map are attached
. .'
'.'
'."'..:. .
. :'::>.}A~.~~(~:~
-------
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i-1ard1 l~, l~tJ~
I.
,- ,iteVi-ewot ;;tfte1&/~ .on .the .Nyanza Chemical ::;ite
AtJvltoabi li:ty,.of ;'Section404
Matt Schwe isberg ~
Planning and Standards Sect ion
[k)n Porteous , <:hief /;/'/?
W,a,te,r ~;tty Branch - ~,;. ~ /
:rt:IRU:,.:Bill.Butler, Chle1¥ y-
, '.:PJanni.ng. 'and Standards Section
for .Wetlard Impacts aro
(>
I'
I' .
Generally, due to the size am degraded state of the wetlarrls in question
(see attached map), selection of an alternative which involves excavation
of the contaninated wetlarrl soils am plants woold be preferred, altoough
recognizably expensive. If an alternative requiring excavation is selected,
s~cific care must be taken to isolate the wetlarrl areas duriDJ excavation
so as to prevent any contaminated materials fran being transported into
either Chemical Broc:X, Trolley Brook, or the larger wetlam adjacent to the
half-acre wetlam on the southeast corner of the Nyanza property. Q1ce
excavation is canplete, regradiOJ to original slope am plantiDJ with
. .,wetJand,..plant,iSpecies.,woulcLbe-,recamended. Q10e r~grading is catplete,
'the ,"hy'dro);QJic:;connec:tions 1:0 :txt:-h -wetland ,areas'Sb:>lild~be,J:8'tDred.
I .-
Hegarding applicability of Section 404, the excavation and subseqent re-
gradiDJ of the half-acre wetlarrl would probably be COlered umer a COrps
of Engineers nationwide permit (e.g., this area is above the headwaters
aro less than one acre in size). - Similar activities in the tw~acre wet-
lam on the northwest corner would probably require a predischarge notifi-
cation to the Corps (e.g., this area is ~e the hea:!watem. but is between
one,i1Ind't:en~.in .size)". " ,In..both cases, an individual permit woold not
'be ,'TtqUi'red.
~
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LIMITS Of NYANIA SITE
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LEGEND
f'7)J AREA Of SLUDGE
~ DEPOSITION
. lOWER UGHT INI
TRIAL COMPLEX
--22$- EXISTtNG CONTOl
{g WETLAND DEPO~
FIGURE 1-2
GENERAL ARRANGEMENT
NYANIA CHEMICAL SITE. ASHLAND. MA
- SCALE ,": 400'
Of\NUf
LD~TK
«:) A HaUiburton Comr
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July 15, 1985
Potential Wetland Impacts from Remedial Activities at the Nyanza Chemical Site
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r\lch Ca'''aJT1~ro
site Res~nsc s~ction
H\.~'t1-19a 3
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'In .res.p:>nseto .~r inquiri:r~ard iO:'J:t:he effects ;0£ unts of water flowin;J to it.
If YaJ. have any other questions, please 'call '-neat223-3949.
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cc:
Carol W:>od
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Page retyped for ~S--Decernber 31, 1985
E PA Form 1320-6 (Rn. 3-76)
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ATTACHMENT
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Floodplain Assessment for the Nyanza Chemical Site, Ashland, r~.
Attached a~e the floodway maps fo~ the Town of Ashland whi6h
.Je ~ e
p~epa~ed by the Fede~al Eme~gency Management Agency.
These""'maps
clea~ly demonst~ate that the Nyanza site is outside of the 100
yea:: floodway of the "Sud'bu::y 'Riv'e~. 'No "ex'C'a'va't.i-on will 't"8,'k'E!place
within the floodplain and no st~uctu~es a~e to be built in the
floodplain o~ which will alte::the existing limits of the floodplain.
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