United States
Environmental Protection
Agency
Office*
Emergency and
Remedial Response
EPA/ROO/R01-86/017
•September 1986
3 EPA
Superfund
Record of Decision
-------
TECHNICAL REPORT OATA
{PIHU ntld /,mftlctlo"s 0" ,ht "vtnt ~fon com"lt;,,,,}
1. II'1'OIitT "'0. f2. 3. "'CI'IINT'S ACCesSION NO.
EPA/ROD/R01-86/017
.. TIn! ANO SU,TITL. 5. "'I'O"'T DATI
SUPERFUND RECORD or DECISION Sectember 30, 1986
Baird &. McGuire, MA t. 'IIII'OillMINO O'-OAN,ZATION CODe
,. AuTHOIIICSI e. I"1II'IIOillMINO OIllOANIZATION Rel"OI'lf "0
,,'IIII'OIllMI...O OIllOANI%ATION NAMI AND AOOilllSS 10. 'IIIOOAAM II..EMINT 1140
\'1. (;ONTI'IACTIOI'IANT NO
I
12. S'ON501llINO AoeNCY NAMI ANO ADDIIIESS 13. TYI"E Oil REI"OI'lT ANO I"EAIOO CO\lE"E:
U.S. Environmental Protection Agency Final ROD Recort
401 M Street, S .w. 1.. S'ON501llINO AOENCV COOE
washington, D.C. 20460 800/00
15. SU"I.IMINTAIIIY NOTIS
IT A8STI'IACT
The Baird &. McGuire site encompasses approximately twenty acres in Holbrook, Norfoll<
County, MA. Wetlands occupy approximately 44 percent of the site with approximately 66
percent of the site lying within a lOO-year flood plain. Baird Ii McGuire, Inc. (BM!)
operated a chemical mixing and batching company from 1912 to 1983. Between 1954 an";
1977 the company was fined at least 35 times by the EPA for numerous violations.
Consultants to the Town of Holbrook reported that BMI's disposal practices from 1959 :0
1962 were the source of ground water and '...etlands contamination. In February 1982 a
citizen's complaint of an oily substance on the Cochato River initiated a site
inspection which reported surface water, ground water, and wetlands contamination. ,,"':
was also found to be in violation of hazardous substance hauling practices. In l'4arc"':
1983 heavy rains caused a breach of the creosote collect ion lagoon resulting in an
EPA-initiated Immediate Removal Action. This action included: the removal of
approximately 1,000 cubic yards of contaminated so il s, construction of a clay ca9,
installation of a ground water interception/recirculation system, and erection of
limited fencing. In ~ay 1983, Holbrook revoked BMI's permit to store chemicals an~
ordered it to dismantle the existing storage facilities. Dioxin, detected in su"fi~~~:
soil samples in July 1985, prompted an EPA-initiated second removal response involvl:1';
the installation of 5700 feet of fencing and extensive soil, ground water, surface
(See attached sheet)
11. o
-------
.
....
"
EPA/ROD/R01-86/017
Baird & McGuire. MA
16.
ABSTRACT (continued)
water. and air lamPlinq. The primary contaminants of concern include:
VOCs. orqanics. PARS. dioxin. pesticides. and metals.
The selected remedial action includes: excavation in "hot areas" to
remove approximately 191.000 cubic yards of contaminated soils; onsite
incineration of excavated soils: ground water extraction and onsite
treatment with discharge to an onsite aquifer; restoration of wetlands at
excavated areas; construction of levees; relocation of the Unnamed Brook;
ground water monitoring: and air quality monitoring. The estimated capital
COlts are $44,386,000 with 30-year O&M costs of $4,132.000.
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RECORD OF DECISION
REMEDIAL ALTERNATIVE SELECTION
SIT E:
Baird & McGuire, Holbrook, Massachusetts
DOCUMENTS REVIEWED
I am basing my decision primarily on the following documents
describing the analysis of cost-effectiveness of remedial
alternatives for the Baird & McGuire Site:
1.
Baird & McGuire On-Scene Coord inator 's Repor t: Holbrook,
Massachusetts, March, 1983 - July, 1984: Prepared by the
U.S. EPA Region I.
2.
Installation and Monitoring of Interim Groundwater Contain-
ment System, Bai~d & McGuire Site, Holbrook, Massachusetts:
August, 1985. Prepared for the U.s. EPA, Region I by
Goldberg-Zoino & Associates, Inc. Newton Upper Falls,
Massachusetts.
3.
Remedial Investigation Report, Baird & McGuire Site, Holbrook,
Massachusetts, Volumes I, II and III: May 22, 1985. Prepared
for the u.s. EPA Region I, by GHR Enginee~ing Associates, Inc.
New Bedford, Massachusetts, sub-contractor to the NUS Corp,
P-~ttsburgh, PA.
4.
Remedial Investigation Phase II, Baird & McGuire Site, Holbrook,
Massachusetts: June 27, 1986. Prepared for the U.S. EPA
Region I, by "GHR Engineering Associates, Inc. New Bedford,
Massachusetts, sub-contractor to the NUS Corp, Pittsbu~gh, PA.
5.
Feasibility Study Report, Baird & McGuire Site, Holbrook,
Massachusetts: July 18, 1986. Prepared for the u.S. EPA
Region I, by GHR Engineering Associates, Inc. New Bedford,
Massachusetts, sub-contractor to the NUS Corp, pittsburgh, PA.
6.
EPA Supplement to the Baird & McGuire Feasibility Study Report of
July, 1986: August, 1986. Prepared by the u.S. EPA, Region 1.
7.
Summary of Remedial Alternative Selection (attached).
8.
Commu,ni ty Relat ions Respons iveness Summar y (attached).
The National Oil and Hazardous Substances Pollution Contin-
gency plan, 40 CFR Part 300: November 20, 1985.
9.
DESCRIPTION OF SELECTED REMEDY
Excavations in "hot areas" to remove approximately 191,000
cubic yards of contaminated soils.
Treatment of contaminated soils utilizing on-site thermal
destruction. A test burn and air quality modeling will
occur during design.
-------
Groundwater extraction and treatment at on-site treatment
plant. Treated groundwater will be discharged to the extent
feasible to the aquifer on-site. If other discharge points are
necessary, the treatment plant will be modified.
Restoration of wetlands where contaminated soils are excavated.
Temporary flood protection through the construction of levees.
Relocation of the Unnamed Brook.
Groundwater monitoring on-site and off-site.
Air quality monitoring during remedial construction and
implementation of thermal destruction.
OPERATION AND MAINTENANCE
Operation and maintenance (O&M) will be a necessary component of
the management of migration alternative. Actual operation of the
thermal destruction unit and the operation of the groundwater
extraction and treatment system are considered to be part of the
remedy until the soil is remediated. If, after soil remediation,
groundwater treatment cleanup levels have not been attained,
then, after an additional one year of operation of the extraction
and treatment system, 100% of the O&M cost responsibilities will
belong to the State. O&M will continue until the groundwater
treatment levels are attained. Additional O&M will consist of
site maintenance, sludge and waste carbon disposal, and monitoring.
DECLARAT IONS
Consistent with the Comprehensive Environmental Response Compen-
sation, and Liability Act of 1980 (CERCLA), and the National
Contingency Plan (40 CFR Part 300), I have determined that the
excavation and on-site treatment of contaminated soils and the
extraction and treatment of contaninated groundwater is a cost
effective complete and permanent remedy and provides adequate
protection of public health and welfare and the environment at the
Baird & McGuire site. This remedy is considered to be an on-site
remediation. The need for off-site actions will be determined in
the future.
The Commonwealth of Massachusetts has been consulted and agrees
with the remedy.
'} )3u /H,
Date
r;~~_.,./ ~~ -z
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SUMMARY OF REMEDIAL ALTERNATIVE SELECTION
FOR
THE
BAIRD & MCGUIRE SITE
HOLBROOK, MASSACHUSETTS
September 29, 1986
U.S. Environmental Protection Agency
Region I
Boston, Massachusetts
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TARLE OF CONTENTS
Site Location and Description
Site History.
Current Site Status.
Extent of Contamination
Groundwater tontaminatio~.
Enforcement
Remedial Planning Activity
Alternatives Evaluation.
Recommended Alternative
Consistency with Other Environmental Laws
Operation and Maintenance.
. -
Schedule ~nd Future Action
Community Relations.
.
Page
1-3
4-5
. 6-9
. . . 10-14
. 15-16
. l7-1A
. 19
20-33
. . 34-39
. . 40-42
~ . 43
. 44-46
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LIST OF FIGURES
Figure 1
Locus Plan
Figure 2
Baird & McGuire Site
Figure 3
Ruildings and Tank Farm Area: Baird & McGuire Site
Figure 4
Remedial Action Zones; Baird & McGuire Site
Figure 5
Contour Map of Bedrock Elevation
Figure 6
Phase II Remedial Investigation Sampling Points
Figure 7
Map of "Hot Area" Soil Removal Zones
-------
Tahle 1
Table 2
Tab le 3
LIST OF TABLES
Selected Critical Contaminants at the Baird &
. McGu i re Site
. PAH Compounds Included in the "Total Other PAH's"
Category
-------
ATTACHMENTS
Appenc1ix A
C~nsistency with State Environmental Laws
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Site Location and Description
The Baird and McGuire site is located in northwest Holbrook,
Norfolk County, Massachusetts at 775 South Street. The site
represents the area within the EPA security fence erected in
1985. The Raird and McGuire property itself is less than 8
acres in size and is occupied by an office building, tank farm,
laboratory building, mixing vat building and storage building.
The total size of .th~ ~ite represents approximately 20 acres.
Baird and McGuire's process buildings, tank farm, and office
buildings are situated on a hillside which steeply slopes to the
north and east. (See Figures 1, 2 and 3)
The process buildings consist of a one story masonry laboratory
building, a two and one-half story mixing building (metal and
wood construction) and a storage buildi.ng. The mixing, laboratory
building and tank farm are to be demolished as a result of Initial
Remedial Measures (IRM's) (July, 1985). The tank farm consists
of 33 above ground tanks varying in capacity from 2,000 gallons
to approximately 12,000 gallons. Eight underground tanks have
been inentif1ed with capacities varying from unknown to 5,000
gallons. The underground tanks will be either filled with concrete
or removed as part of the IRM. Twenty-five additional tanks
exist within the mixing and laboratory buildings. Their capacities
vary from 100 gallons to 13,000 gallons. .
The facility is surrounded by deciduous and coniferous woonlands.
Elevations range from about 170 feet MSL (mean sea level datum)
in the southwestern corner of the site, to about 130 feet MSL to
the northeast ann in the central portion of the Site. From this
130 feet MSL elevation, the topography slopes gently to 119 feet
MSL at the Cochato River. These relatively flat, wet and poorly
drained central and eastern portions of the site are characterized
by dense, deciduous wooded wetland vegetation. Similar wooded
wetlands are situated to the southeast of the facility.
Based on the results of the wetland boundary
occupy approximately 44 percent of the site.
percent of the site lies within the 100 year
of 126.9 feet.
delineation, wetlands
Approximately 66
floodplain elevation
To the east of the facility, primarily on property owned by Newcan
Company, there exists a clay capped area. This area was formerly
a 200 foot wide clearing which was utilized for waste disposal
purposes and for the collection of a black-oily liquid which was
present in low-lying areas. This area exists within the 100 year
floodplain. Approximately 1000 yd3 of material was removed from
the clearing prior to the installation of the clay cap and a
groundwater collection/recirculation system. These improvements
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-2-
Land use in the general vicinity of the site (i.e., to the north
and south of the site along South Street: on Center and Union
Streets, all or part of which are in Randolph, and in the Cochato
Industrial Park located to the northeast of the site) is intensely
industrial/commercial. The types of businesses which now or
formerly operated in this area include: metal engraving, metal
finishing, paint production, machine shop work, metal plating,
metal fabrication, fuel storage for distribution, auto repair,
chemical storage, materials research, spray painting, roofing,
printing, leather cutting and grading, and assorted distribution
services. .
The area west of South Street and the Baird
primarily residential. Another residential
along the north shore of Lake Holbrook some
southeast of the site. (See Figure 1)
The Holbrook/Randolph South Street Well Field
to the south ~f the site (within 1,500 feet).
space currently lies to the east-southeast of
Figure 1)
& McGuire site is
community is located
2,000 feet to the
lies i~mediately
Undeveloped open
the site. (See
The predominant surface water feature of the site is the Cochato
River. It is a Class R stream and f1ow~ from south to north
through the Towns of Holbrook, Randolph and Rraintree. It is
located approximately 500 feet from the Baird & McGuire facility
and forms the eastern perimeter of the site. Two unnamed brooks,
one flowing from west to east across the northern portion of the
site (known as the "unnamed" brook) and the other from west to
east (designated tributary C-2) in the wetlands south of South
Street Well No.1, empty into the Cochato. Wetlands situated
along the western bank of the Cochato, to the east of the former
waste disposal area, receive site drainage which empties into
the Cochato River.
There are two lakes within 0.5 miles of the site. Lake Holbrook,
one of the sources of the Cochato River, is 2000 feet upstream of
the site. About 2100 feet downstream of the site, the Cochato
flows by Sylvan Lake. In flood conditions, water from the Cochato
enters Sylvan Lake via an elevated inlet. Also downstream,
approximately 3500 feet from the site, is a major wetlano. This
wetland is one of many typically smaller wetlands found along the
entire length of the river.
Approximately 2.5 miles downstream of the site, the Cochato River
flows past the Richardi Reservoir, which serves as a local
supplementary water supply. Richardi Reservoir is adjacent to
the Cochato River. A surface water intake, the level of which is
controlled by splash boards in the river exists to deliver water
from the Cochato River to Richardi Reservoir: however, this
surface water intake has been closed since February 1983. In
addition to the remaining surface water sources, there is a
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-3-
substantial amount of groundwater flow into the reservoir such
that water is periodically pumped from Richardi Reservoir into
Upper Reservoir, which in turn feeds Great Pond. Both Upper
Reservoir and Great Pond, which are outside of the Cochato River
basin, provide public water supply for the Towns of Holbrook,
Randolph and Braintree.
North of Richardi Reservoir the Cochato River joins the Monatiquot
River, which flows' tb the Weymouth Fore River, which ultimately
discharges into Massachusetts Bay.
The groundwater resources in the area have been utilized in the
past as a Municipal water supply source in two locations. The
South Street well Field (1.8 mgd) is located 1500 feet south and
cross gradient from the site. The last of the three production
wells at South Street was shut down in 1982 due to volatile
organic chemical contamination. The Donna Road well field (.5
mgd) is located 1-2 miles southeast and upgradient from the site.
It consists of 16 well points driven to a depth of 30 to 40 feet.
These wells were shut down due to high iron and manganese levels
in 1979.
Other known users of the groundwater in the area are the Accurate
Metal Finishing Company on South Street and a private well on
English Road in Holbrook. These users are within 2,000 feet of
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-4-
Site Histo~y
8ai~d & McGui~e, Inc. o~e~ated a che~ical ~ixing and batching
company from 1912 until 1983. It fo~~ulated a variety of p~oducts,
including disinfectants, soaps, floo~ wax and ~esticices. Baird
& ~cGui~e, Inc. is a cor~o~ation inco~po~ated under t~e la~s of
Massachusetts. aet~een 1957 and 1983, Bai~d Realty Co, Inc. ~as
the reco~d owner of the Bai~d & McGui~e site. In 1983, title
transferred to 8ai~d & McGuire, Inc. (aai~d Realty Co., Inc. ~as
subsequently known as the Ann E. Realty Trust, Inc.). Ca~e~on~.
aai~d was President and Treasurer of aaird & McGuire, Inc. while
his brother Gordon acted as Chairman of the Boa~d.
EPA beca~e involved with Baird & McGuire in the period bet~een
1954 and 1977 when the company was fined at least 35 ti~es for
numerous violations of the Federal Insecticide, Fungicide a~d
Rodenticide Act of 1947. The charges were brought against the
company due to mislabeling, improperly ~egistering and adulterating
thei~ p~oducts.
Waste disposal practices employed by Baird & McGuire we~e first
documented in Northeast Consultants Reports to the Town of Holbrook
between 1959 and 1962. These reports refer to contamination from
the ~lant to wetlands via "drain lines." The reports concluded
that contamination from Bai~d & McGuire's disposal practices was
the source of contaminatioD of the South Street Wellfield. Othe~
early documentation of illegal disposal practices includes a
citizen's complaint to DEQE regarding an odorous discharge to a
wetland in 1975.
In May 1981, the DEQE performed a site inspection and documented
a numbe~ of questionable disposal practices. These included a
laboratory sink which discharged into a parking lot which d~ained
to a nea~by brook, a sto~age tank which showed evidence of previous
ove~flows (stained soils), and an uncovered "beehive" cesspool.
In Feb~uary 1982, a citizen's complaint of an oily substance on
the Cochato River initiated another DEQE site inspection. This
inspection repo~ted the following: the tank farm was not lined
or diked, which allowed contaminated surface water runoff to
reach the adjacent brook; sewage waste, process waste and surface
water runoff we~e collected in an open "beehive" cesspool which
cont~ibuted to groundwater contamination; wastewa~er which contained
haza~dous constituents was collected and dumped into a Metropolitan
. District Commission (MDC) sewe~ by a hauler not pe~mitted to
transport hazardous substances; and a pipe was identified as
discha~ging a black oily substance to wetlands.
During February through April, 1982, Baird & McGui~e volunta~ily
implemented a series of ~emedial actions. These included:
installing a catch basin near the tank farm to intercept surface
water runoff~ filling of the "beehive" cesspool with concrete
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-5-
on the Cochato River and unnamed brook to prevent oil runoff
downstream: removing a discharge pipe and application of absorbent
pads to the wetland to soak up the oil: and installation of a
creosote collection system and construction of a clay dike around
the creosote lagoon to prevent a release of contaminants in
flooding conditions. .
The site was scored .01"\ the Hazardous Ranking System in August,
1982 by EPA's contractor, Ecology and Environment, Inc. It was
proposed on the National priorities List (NPL) in October 1982
with a total score of 66.35 (score for groundwater was 100.00,
surface water was 56.36 and air was 0). It currently ranks 14
out of a total 888 current or proposed sites on the NPL. (June,
1986 Fed. Reg.)
In March 1983, heavy rains resulted in a breach of the creosote
collection lagoon. This constituted a release of a pollutant
which may ha~e presented an imminent or substantial threat to the
public health or the environment. EPA responded by initiating an
(immediate) remo~al action under Section 104 (a)(1) of CERCLA.
In the course of the removal action, EPA removed approximately
1000 cubic yards of contaminated soils, constructed a clay cap,
installed a groundwater interception/recirculation system, and
erected limited fencing.
On May 2, 1983, the Board of Selectmen of Holbrook revoked Baird
& McGuire's permit to store chemicals at the site and ordered it
to dismantle its existing storage facilities. As a result of
this order, Baird & McGuire was forced to cease operations.
In July, 1985, site sampling detected the presence of dioxin in
surficial soils. This prompted EPA to reactivate its removal
program. The second removal response installed 5700'; of fencing
and performert extensive sampling of soil, groundwater, surface
water and air to better delineate the extent of dioxin contamination.
A cost recovery action was filed in the fall of 1983 under Section
107 of CERCLA against Baird & McGuire, Inc. and related individuals,
seeking recovery of costs expended by EPA for the removal action
and expected to be expended during the remedial action. The
litigation is in the process of being settlert. The defendants
include Baird and McGuire, Inc., Cameron Baird, Gordon Baird, and
the Ann E. Realty Trust, Inc., all of whom are considered site
owners and/or operators. Settlement negotiations have occurred
and are ongoing. Settlement appears likely but has not been
finalized. Aecause of the defendants' financial status and the
high cost of the remedy, the Government's recovery will be for
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-6-
~urrent Site Status
The populations which were studied to determine risk through
potential exposure scenarios are those who either live or work
near the site and those who are served by the Great Pond Reservoir
system.
Populations Near the Site
The population of 'people who live near the site was calculated by
taking concentric circles of 1000 feet, between 1000 feet and
2000 feet and between 2000 feet and 1 mile from the site and
correlating the circles with census data. In addition, telephone
contacts were made with area employers to obtain the number of
workers in the area. The populations for these areas are estimated
as follows:
Within Between Between
1000 ft 1000 and 2000 ft 2000 ft and 1 mile
Residential 117 826 9067
Non-
residential 280 178
Total 397 1004 9067
EPA has also determined the population served by the Great Pond
Reservoir. Great Pond Reservoir serves inhabitants of the towns
of Holbrook, Ranrlo1ph and Rraintree. Great Pond formerly received
some water from the Cochato River after dilution and holding in
the Richardi Reservoir and Upper Reservoir. The Richardi Reservoir
is located 2.5 miles downstream from the Baird & McGuire site.
The sluice gates on the Richardi Reservoir have been closed since
February, 1983, so water from the Cochato is no longer used as
part of the drinking water supply.
Population Served by Great Pond
residential
non-
residential
Total
77,841
114,841
192,682
The routes of exposure which may affect the population near the
site are through exposure to groundwater, dry soils, muck, contam-
inated fish, surface water, or through swimming. Out of a total
of 102 contaminants detected at the site, a list of 53 critical
contaminants has been determined. This list can be found attached
as Tables 1 and 2. The critical contaminants are compounds which
have the greatest toxicological potency and have been detected in
the highest frequency.
Refer to the FS Tables 2-19 through 2-78 for a presentation of
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-7-
routes of exposure for the critical contaminants in each of the
risk assessment zones (see Figure 4). A complete discription of
these zones is contained in the text further on in this section.
The hydrogeologic factors which affect the soil and groundwater
contamination are complex and varied throughout the site.
Geology and Hydrogeology
. .
The geologic site features are representative of processes associated
with glaciation. The observed features are bedrock, till, outwash
deposits of stratified sands, gravel and silts, organic soils and
fill materials.
The bedrock underlying the Baird & McGuire site is mapped as the
Salem Gabbro-Diorite. It is a metamorphosed igneous rock believed
to be of Precambrian age (older than 600 million years). The
rock is oescribed as a fine to medium grained, massive, dark
greenish-gray. metaquartz diorite and metadiorite. Field observation
of bedrock cores indicate an intrusion of Dedham Granodiorite
into the Salem Gahbro-Diorite. The Dedham is described as massive
medium to coarse-grained pink granite and quartz monzonite believed
to be of Precambrian age.
The bedrock underlying the site is fractured and shows indication
through monitoring well and rock core observations of groundwater
movement through the fractures. The topography of the bedrock
ranges from 129 feet ahove MSL to less than 20 feet above MSL.
In general, the top of competent hedrock appears to slope downward
from South Street towaro a closed depression or bowl located
along seismic line 4 (see Figure 5). A bedrock valley extends
northwestward from this bowl. The wall of the valley is steep on
the northern side, and relatively gentle on the southern side:
the valley apparently ends near well 910. A lesser valley extends
northeastward from the "bowl": the extent of this valley to the
northeast is not known. A buried bedrock hill is located between
the Holbrook-Randolph Well Field and the Cochato River.
The top of the dense glacial till/weathered bedrock shows less
relief than does the top of competent bedrock. The deep howl or
depression described ahove appears to be filled with a significant
thickness (up to 60 feet) of glacial till and/or weathered rock,
and lesser thicknesses of till and/or weathered rock are present
elsewhere at the Site.
The characteristics of the soil and bedrock of Baird & McGuire in
terms of hydrogeology are critical to an understanding of the
fate of contaminants which have entered the aquifer. Hydraulic
conductivities for the principle overburden units are summarized
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-8-
Material
Hyd~aulic Conductivity
Range Ave~age
ft/day ft/day cm/sec
Silty sands, sand & silt
1.0 - 6.0
3
lxlO-3
Fine to medium,
coarse sands
fine to
Glacial till
1 - 20
10
1.6xlO-2
3.5xlO-3
10 - 100
45
These conductivities represent horizontal "perrneabilities." In
stratified deposits such as the sands, silts, and silty sands
observed at the Site, anisot~opic conditions will p~evail (i.e.,
vertical hydraulic conductivities will be significantly lower
than horizontal). The average ratio of horizontal to vertical
hydraulic conductivity is estimated to be between 10:1 and 20:1.
Transmissivities of groundwater through bed~ock have been estimated
to be at 0.3 to 3 feet/day.
Use of Groundwate~
The current uses of groundwater resou~ces in the vicinity of the
site are a private drinking water well approximately 3000 feet
southeast and upgradient of Baird & McGuire and a process water
well 500 feet no~thwest and c~ossgradient at Accurate Metal
Finishing. The private drinking water well has been determined to
be safe to drink since it is free of detectable contaminants.
A past use of groundwater resources in the vicinity of the site
was the Holbrook Municipal South Street Well Field (1.8 mgd).
The well field consisted of three wells located within 1500 feet
of Baird & McGuire. Well No.3 is located 1000 feet from Baird &
McGuire and is the closest well to the site. It was closed in
1959 when phenols were detected shortly after it was put into
service. Well No.2 was pe~manently closed in 1980. Well No.1
was closed in 1982 due to volatile chemical contamination. The
appropriate groundwater class for the aquifer underlying the
Baird & McGuire site and vicinity is Class II (classification
based on EPA's Groundwater Protection Strategy). This class
. represents a current and potential source of drinking water and
waters having other beneficial uses.
Climate
The main climatic factor affecting site contamination is precipi-
tation. Precipitation is fairly evenly distributed throughout
the year, with a total annual record mean of 45 inches, and
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.,
-9-
Snow can be expected from November through early April. Of the
total annual precipitation, approximately 14 percent occurs as
snow or sleet. "Northeasters", which are coastal storms accompanied
by high winds and heavy precipitation in the form of snow or
rain, are regionally significant weather events.
Man-made Barriers
Man-made barr.iers 'cu"rrOently are used to control the migrat ion of
contamination from the site. The barriers are the groundwater
interception/recirculation system and temporary capping performed
under the EPA's removal program during 1983 and 1984. According
to GZA's report on "The Installation and Monitoring of Interim
Groundwater Containment System", calculations suggest that the
cap and containment system has reduced discharge of pollutants
from the site by 85-95 percent. The groundwater interception/
recirculation system was designed for a one year operation. The
present system has been in operation for two years and expects to
be operating tor an additional one to two years until the permanent
remedy can be implemented.
The temporary impervious capping was designed to
runoff from precipitation away from the site and
infiltration. It also raduced the potential for
with contaminated soils.
divert clean
to limit direct
direct contact
Migration
Contaminated substances have migrated and continue to migrate
through groundwater and surface water routes. The groundwater
contamination ultimately discharges into the Cochato River.
However, according to GHR, this contamination is being effectively
attenuated by organic soils and sediments on the river bottom,
biodegraded by anaerobic and aerobic bacteria and diluted by
surface water so as to prevent the measurable degradation of
water in the Cochato River. The sediments of the Cochato River
could be considered to be a natural barrier in containing site
contamination. A slight seepage of contaminated groundwater is
also occurring into a sewer line which is located on the far side
(east) of the Cochato River.
Migration of contamination through surface water is primarily via
stormwater runoff. Uncapped contaminated soils have in the past
eroded, and continue to do so, and are transported during storm
events. The wetlands surrounding the site show the greatest
evidence of contaminated particulate transport via surface water.
Sediment contamination of the Cochato River and unnamed brook
near the site and downstream from the site can be attributed to
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-10-
Extent of Contamination
The presentation of soil contamination data is based primarily on
the results of 73 soil samples taken during the Remedial Investi-
gation (RI) and 217 soil samples taken during the RI Addendum
field programs. During these sampling events, organic and inorganic
chemicals belonging to all the major classes of HSL constituents,
including dioxin and herbicides, were detected.
. '. .
This identification and characterization of the soil contaminants
is documented in Sections 5.20-5.21.5 of the RI and Sections
5.40-5.42.5 of the Addendum to the RI. From the data in these
Sections, the areal and vertical extent of soil contamination is
developed.
Zones
Since the Site is not homogeneous in terms of geology, soils,
hydrology or contamination, it has been divided into eleven
distinct Zones described below: (See Figure 7)
1.
Zone 1, an upland portion of the Site, contains the tank farm
and the abandoned buildings which were used for offices,
storage, mixing and laboratory facilities:
2.
Zone 2, fenced and capped after EPA removed approximately
1,000 cubic yards of contaminated soils in 1984, contains the
primary former on-Site disposal area:
3.
Zone 3 contains the ephemeral stream called the unnamed Brook:
4.
Zone 4N (N for North) contains low-lying areas and wetlands
along the Cochato River downstream of Zone 2 to Mear Road;
5.
Zone 4S (S for South) contains low-lying areas and wetlands
along the Cochato River upstream of Zone 2:
6.
Zone 5 contains an area of suspected overland flow along the
dirt access road from Zone 1 towards Town Well No.3:
7.
Zone 6 represents the Cochato River and a narrow strip of
wetland along each side from the southerly (upstrea~) border
of the EPA security fence downstream to Mear Road;
8.
Zone 7 represents areas across the Cochato River from Zones
2,3 and 4N (this Zone has no distinct eastern boundary):
9.
Zone 8 represents the area to the south of the main Site,
which contains the closed Town Wells Nos. 1, 2 and 3 (this
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-11-
10.. Zone "Up. represents the upstream portion of the Cochato
River from the dam/weir at Lake Holbrook to Zone 6;
11. Zone "Down" represents the Cochato River downstream of Zone
6 (this Zone has no distinct downstream boundary).
The analytical results for soils at the surface and at various
depths for the zones are summarized in Tables 5-1 through 5-13
(RI Addendum)~ Th~ ~o~pounds listed in the tables are the critical
contaminants for the site. T~e critical contaminants were selected
based on their toxicological potency, concentration and- frequency
detected in different environmental media. T~e determination of
critical contaminants can be found in Section 2.32 of the Feasibility
Study (FS). (See Table 1 for a listing of the critical contaminants.)
The number 'of contaMinants found at the site, the media in which
they exist and the fact that the contaminants are not individually
separate from one another all are factors which eliminate the
possibility of reuse or recycling of substances on the site.
Soil Contamination Evaluated by Zone
In Zone 1, the extent of contamination of soils is surficial and
at depth. Since this waS the facility area, this zone exhibits
the highest contamination levels found anywhere on the site.
Soil areas of particular concern are in the tank farm, beneath
the buildings, behind the mixing building and north of the laboratory
building. High concentr3tions of volatile organics, base neutrals,
acid extractahles and pesticides (percent levels in some samples)
exist. Contaminant distribution shows no discernible decrease in
total contaminant level with depth, meaning that the soil is
contaminated down to bedrock. Redrock depth varies in Zone 1
from exposed bedrock to approximately 15 feet below the surface.
In Zone 2, soils contamination exists to a depth of at least 30
feet. Concentrations do not decrease with depth so the soils to
bedrock are contaminated. Contaminants detected were volatile
organics, base neutrals (primarily coal tar derivations), acid
extr~ctables (primarily phenols) herhicides and pesticides (percent
levels in some samples).
Zone 3 contamination represents the sediment of the unnamed
brook. The predominant contaminants detected in the sediments
were the base neutrals, pesticides, volatile organics and arsenic.
Contamination exists to a depth of at least 15 feet. Contamination
decreases with depth in this zone.
Of the compounds detected in Zone 4S and 4N soils, pesticide
contamination exists in the highest frequency. Other contam-
inants detected in lower frequency are volatile organics, base
neutrals (coal tar derivitives) and metals. Contamination of
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-12-
presence of Baird & McGuire indicator compounds, chlordane and
dieldrin in the samples and the relative higher concentration of
contaminants compared to off-site wetland areas.
Soil contamination in parts of 4S differ because two Baird and
McGuire indicator pesticides, chlordane and die1~rin, were not
detected south of borings B-75 and B-76. (See Figure 6.) Pesticide
contamination in this part of 4S can be attributed to Norfolk
County mosquito s~raYirig or other sources.
In general, pesticide contamination detected in 4N and 4S is
concentrated in the organic-rich topsoils (0-4 feet depth). The
volatile, base neutral and acid extractable compounds are more
evenly distributed with depth (at least 14 feet deep).
In Zone 5 soils, volatiles, base neutrals, acid extractables,
pesticides and metals were detected. This confirmed the fact
that waste water runoff from Baird and McGuire contained contam-
inants which adversely affected the South Street well field.
Early investigation of Zone 5 reported yellow-green wastewater
from Baird ah~ McGuire collected in a depression. Contamination
exists surficially and to at least a 14 foot depth in this zone.
Zone 6 soils consist of sediments of the Cochato River adjacent
to the site. Volatiles, base neutrals, pesticides and metals
were the predominant contaminants detected. The highest level of
contamination existed at the mouth of the unnamed brook in the
Coehato River. Sediments whieh contained the greatest amount of
contamination had large amounts of organic material. The underlying
bed soils (less organic material) exhibited less contamination.
The upstream sediment contamination boundary exists near station
SD-10 and SD-11. (See Figure 6.) ~reas upstream of this location
were devoid of the characteristic "creosote" odor of the site.
Zone 7 soils are physically isolated from the site since they are
on the opposite side of the Cochato River therefore no soil
analyses were performed. There are no visible signs of dumping
of wastes on the soil in Zone 7.
Zone 8 soils are contaminated with pesticides. The pesticide
levels increase with depth. Base neutrals and volatiles were
also detected in this zone. The pesticide contamination in the
field east of the South Street wells is believed to be attributed
to Baird and McGuire. It represents residual contamination from
the period when the South Street wells were pumping. Contaminants
were drawn through the aquifer towards the wellfie1d when the
wells were pumping. At location B-116 and B-120 (See Figure 6)
contamination is likely attributable to background levels with
source(s) unknown. This is because these locations are far
displaced from the site. The other areas in Zone 8, including
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-13-
well field, and the Lake Holbrook area, have contamination which
cannot be attributed to Baird and McGuire and the levels can be
considered to be at an elevated background.
Zone "up" exhihited volatile, base neutr~l, pesticide and herbicide
contamination. Since this zone is an upstream sediment zone,
contamination cannot be attributed to Raird and McGuire. Contam-
ination was detected in three out of four samples. Likely sources
of the contaminati~~ a~e past mosquito spraying practices and
herbicide applications in Lake Holbrook.
Zone "down" soil contamination exhibited volatile, base neutral
and pesticide contamination. The more organic material in the
sarn~le, the greater the contaminant concentration. Deposition
areas of organic materials showed higher contamination levels.
The sand and gravel deposits in downstream areas are relatively
clean.
Extent of Dioxin Contamination in Soils
The dioxin soil contamination data are based on 125 soil samples
collected by EPA and its contractors. The majority of these
samples were collected at the ground surface level, except in
Zone 1 soils, where samples were collected beneath the mixing,
1ahoratory and storage huildings.
In Zone 1 soils, dioxin ~as detected in 35 percent (11 out of 28
samples) of those analyzed. In general, higher levels were
discovered beneath the building soils which were in the closest
proximity to the process chemicals.
In Zone 2, soils dioxin was detected in 2 out of R samples. The
levels were helow 1 pph in this zone. Further analysis will be
performed during design of the creosote-like oil which is known
to contain high pesticide levels. No valid analysis were obtained
on this oil.
In Zone 3, 50% (13 of 2n) of the samples contained dioxin.
occurrence of dioxin in the upland soils of the plant area
through the unnamed brook clearly estahlishes the hrook as
route of transport.
The
down
a
In t~e wetland Zone 45, no dioxin was detected in nine saMples.
In Zone 4N, dioxin was detected in 47% of the sa~ples (11 of 27).
Dioxin distribution in this zone appears to be randomly distributed
from low to moderately high concentrations. Zone 4S is not
subject to the same depositional scenario as Zone 4N. Zone 4N
can receive site contaminants via the unnamed brook or the Cochato
downstream of the site while 4S is upstream of hoth routes of
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-14-
In Zone 5 low levels of dioxin have been detected in 2 out of 3
saMples. Zone 5 was subject to plant runoff.
No dioxin was detected in any of the remaining site zones nor in
residential areas along South Street opposite of the site.
Summary
In general, the areas with the highest levels of soil contamination
include the tank farm, under and around the buildings, under the
paved areas of the plant area (Zone 1) and under the capped
portion of the Site (Zone 2). In these areas, .there is no dis-
cernihle decrease in total contaminant levels with depth, including
below the water tahle. The chief mechanisms by which soil contam-
inants were distributed in these areas (including spills and
lea~s, intentional disposal of waste, stormwater run-off, and
groundwater transport and fluctuation) have resulted in contamination
of virtually the entire soil column down to bedrock in these
areas. .
The soils in'the 'outlying areas of the Site, including the north
and south wetlands, the seasonally wet area and the wetlands
north of the tank farm are, in general, less contaminated than
soil in the plant and cap areas. The depth of soil contamination
in these areas is also less than in the plant and cap areas. The
prime transport mechanism by which soils in the outlying areas
have become contaminated are stormwater run-off from the Site,
intentional disposal of wastes into the wetlands, flooding and
groundwater transport of contaminants from the site.
The sedi~ents with the highest
detected adjacent to the site.
centrations were usually lower
ination.
contaminant concentrations were
Upstream sediment contaminant con-
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-15-
Extent of Groundwater Contamination
As presented in the RI, infiltration of precipitation through
contaminated soils has been determined to be the main source of
groundwater contamination. Groundwater and precipitation move
through contaminated soil and pick up contaminants through parti-
culate transport and/or chemical solubilities. Other sources of
groundwater contamination include the direct discharge from
septic systems, pipes and drains.
. '. .
The identification and characterization of groundwater contami-
nation is documented in Sections 5.30-5.40 of the RI and Sections
5.30-5.32.7 of the Addendum to the RI. Areal and vertical extent
of groundwater contamination is developed within these sections.
Plume Description
Analytical data define the presence of a groundwater contamina-
tion plume originating at the Baird & McGuire facility, extending
east towards,' and to a limited extent beyond the Cochato River.
The plume runs beneath those soils which received the" bulk of
contamination from Baird & McGuire disposal practices. It exists
in varying degrees in portions of Zone 1, 2, 3, 4N, 4S, 5, 6 and
7. The eastern terminus of the plume is abrupt and is not a
significant distance east of the river. Th~ northern. extent of
the groundwater plume has been determined to terminate near well
919 in Zone 4N. (See Figure 6.) Groundwater contamination detected
further north of well 919 is attributed to a leak in a subsurface
gasoline tank which occured on property west of the northern
monitoring locations.
The core of the contamination plume is characterized by levels of
total base/neutral and acid extractable organics exceeding 10,000
ppb and by levels of total aromatic and chlorinated volatile
organics exceeding 1000 ppb and 100 ppb, respectively. . Concentra-
tions of contaminants typically drop in orders of magnitude with-
in 200 feet north and south of the plume axis.
The southern side of the groundwater contamination plume is
skewed further south than would be expected from observed static
groundwater flow. The skewing of the plume may be caused by the
residual effects of pumping the South Street Well Field, or
hydrogeologic factors. The contaminated groundwater extends
into Zones 4S and 5 to the south.
Further south, near Well 11 in the South Street Well Field,
contaminated groundwater exists. Since EPA has not discovered
Baird & McGuire indicator contaminants at this location, it is
believed to have been contaminated from an upgradient (southern)
source.
Groundwater contamination has been detected upgradient or west of
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-17-
Enforcement
The Baird & McGuire facility has had a lengthy history of
violating environmental laws. From the mid-1950's on, the
company received numerous citations for violations of the
Federal Insecticide, Fungicide, and Rodenticide Act. Further,
both the state and the local governments took legal actions
against the company at various times.
As noted iB the Sit. History section, BPA involvement under
CERCLA began in March 1983 with a removal action. Baird and
McGuire Inc. stopped operating shortly thereafter, and the
company and its officers took the position that they did not
have sufficient assets to pay for the work necessary at the
site.
In October 1983, the United States of America, on behalf of
the Administrator of EPA, filed a cost recovery action under
sections l04(a) and (b) and l07(a) of CERCLA. The complaint
sought reimbursement for costs incurred by the United States in
remedying site conrlitions from Baird & McGuire, Inc., Baird
Realty Co.. Inc;, (subsequently known as the Ann E. Realty
Trust, Inc.) Cameron M. Baird, and Gordon M. Baird.
Baird & McGuire, Inc. owned and operated the Baird & McGuire
facility. Baird Realty Co. Inc. was a record owner of part of
the site. Cameron Baird was the president, treasurer, and
chief executive of Baird & McGuire, Inc., while Gordon M.
Baird (Cameron's brother) was the chairman of the board of
Baird & McGuire, Inc. The government contends that both
individuals exercised control over the company's conduct,
~ctivities and operations.
The defendants to the lawsuit, as listed above, were also
the sole Potentially Responsible Parties ("PRPs") identified by
EPA. As described earlier, Baird & McGuire, Inc. operated as
a chemical mixing and batching facility. Chemicals were sent
to Baird & McGuire for use in producing final products. The
company was not in the business of disposing of hazardous
substances or waste sent hy other companies, so that EPA has
not designated the Baird & McGuire chemical suppliers as PRPs.
The PRPs maintained from early on in discussions with EPA both
that they lacked the financial assets to conduct the remedy and
that they were not liable. The PRPs also provided some infor-
mation as to their finances, and the United States ohtained a
lien on a parcel of property owned by the Anne E. Realty Trust.
As a result, EPA determined that the PRPs were unable and
unwilling to implement the full remedy at the site.
At this time, the parties have reached an agreement in principle
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-18-
a Consent Decree continue. The PRPs, as well as the insurers
of one of Baird & McGuire, Inc., have agreed to pay a substantial
sum to EPA. EPA will also have full access to the site for the
purposes of implementing the remedy. The United States will
retain the right to proceed against two other Baird & McGuire,
Inc. insurers. EPA anticipates that the parties will reach
final agreement on the terms of a Consent Decree in the near
future, if they have not a1reacty done so. That Consent Decree
will be publishe"dOfo"r public comment by the Department of
-------
-19-
Remedial Planning Activity
The response actions at Baird & McGuire have been phased into
operable units. An operable unit is a response action consistent
with achieving a permanent remedy. These operable units may
include removal or remedial actions involving source controls
and/or management of migration. The first operable unit involved
the emergency removal action of 1983-84. This action consisted
of the removal of approximately 1000 cubic yards of contaminated
soils, the in-sta11'at"ion of the groundwater interception/recirculation
system, temporary capping and limited fencing.
The second operable unit represents the IRM. The IRM encompasses
the construction of a new 12" water supply main, demolition of
the mixing building, laboratory and tank farm, disposal of under-
ground tanks and the installation of temporary capping.
The third operable unit was the emergency removal action of 1985
in response to the discovery of dioxin. This action resulted in
extensive sampling of the air, water and soil of the area and the
installation of approximately 5700 feet of fencing.
This ROD characterizes the selected remedy which will comprise
operable unit 4. The selected remedy, Alternative No~ 4M, will
be discussed in sections to follow.
Operable unit four focuses upon management of migration and
source control remediation solution. Management of migration is
defined in the NCP (Fed. Reg. Nov.20, 1985 Vol. 50 No.224) as
actions that are taken to minimize and mitigate the migration of
hazardous substances or pollutants or contaminants and the effects
of such migration. Source control is defined as measures which
are intended to contain the hazardous substances or pollutants or
contaminants where they are located or eliminate potential contam-
ination by transporting the hazardous substances or pollutants or
-------
OBJECTIVES
-20-
Alternatives Evaluation
The puhlic health and environmental objectives for the Baird &
McGuire site are as follows:
1 )
2 )
Mini~ize the risk for the human population of direct
contact with contaminated soils/sediments
Remediate the contaminated aquifer within a reasonable
time to prevent present or future impacts to groundwater
drinking.water supplies
Protect surface waters from future contaminant migration
Minimize long-term management and/or maintenance
requirements
3)
4 )
DEVELOPMENT OF ALTERNATIVES
The process of generating alternatives to meet these public health
and environmental objectives was affected by the presence of dioxin.
Presently, there are no RCRA permitted facilities off-site which
can accept dioxin contaminated wastes. Therefore, only on-site
remediation .alternatives for dioxin contaminated soils were
included in the FS. Conta~ination occurs sporadically in Zones 1
through 5.
There are several other limiting factors which also affect the
alternative generation process. Some of these are:
1 )
Approximately 66% of the contaminated soil areas are
located within the 100 year floodplain
2)
Approximately 44% of the contaminated soil areas are
classified as wetlands
3 )
Benrock underlying the Site is fractured and now carries
contaminated groundwater
Other limiting factors can be found in the FS on pgs 4-6 and 4-7.
The alternatives were grouped based on the requirements in the
NCP 300.68(f)(i-v).
1) Alternatives for Off-Site Treatment or Disposal
There are no remedial alternatives involving off-site treatment
or disposal of wastes from the Site because there are no off-site
facilities permitted to treat or dispose of dioxin-contaminated
materials in the nation.
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-21-
2) Alternatives Exceeding Standards
Due to the extent of contamination at the Site and background
contamination present in surrounding areas, it was not possible
to develop an alternative that would exceed all applicable,
relevant or appropriate requirements.
3) Alternatives That Attain Standards
There are six remedial alternatives that are considered to attain
standards. These are identified as Alternative Nos. 3, 3A, 38,
4A and 4M.
4) Alternatives That Do Not Attain Standards
There are three remedial alternatives that are considered not to
attain standards, but which are expected to reduce the likelihood
of present or future threats from the hazardous substances and
that provide'significant protection to public health and welfare
and the environment. These are identified as Altern~tive Nos.
4B, 4C and 4'D. .
5) No Action Alternative
Under the No Action Alternative, identified herein as Alternative
No.5, the following actions are assumed:
1.
Building demolition and water line relocation will proceed as
currently planned:
2.
The Site will remain fenced as at present:
3.
Clean soil material will be placed over portions of Zones 1,
2, 3 and 5 where surficial soils are contaminated. '
4.
The existing groundwater recirculation system will be shut
down: and,
5.
periodic groundwater and surface water'qua1ity monitoring
will be done for 30 years.
The alternatives were developed based on the components listed
below:
1. RCRA CAP Zone dependent
2. NON RCRA CAP - either Zone 6 or none
3. NO CAP - Zones 7 & 8
4. SOIL EXCAVATION - zone or hot area dependent
-------
, 7.
-22-
5. '
SOIL DISPOSAL - RCRA landfill, incineration, or none
6.
GROUNDWATER CONTAINMENT - slurry wall around Zones 1, 2 and
3 and/or pumping wells or none
7.
GROUNDWATER INTERCEPTION - pumping wells or none
GROUNDWATER TREATMENT - included or none
8.
9.
FLOOD PROTECTION - levees, temporary or permanent
All the alternatives include relocating the unnamed brook.
INITIAL SCREENING OF ALTERNATIVES
The alternatives were screened initially, consistent with the
process outlined in the NCP Section 300.68(G). This resulted in
the dropping of three alternatives from further consideration.
These alternatives (48, 4C and 4D) are described below with
justification for elimination.
Description of Alternative 48
Alternative No. 48
1.
RCRA CAP - Zones 1 through 5 (in-place capping of contaminated
soils)
2.
NON-RCRA CAP - Zone 6 (Cochato River inside security fence)
3.'
NO CAP - Zones 7 and 8
4.
SOIL EXCAVATION -
None
5.
SOIL DISPOSAL - None
6.
GROUNDWATER CONTAINMENT - Slurry wall around Zones 1, 2 and 3
GROUNDWATER INTERCEPTION - Wellpoint system
8.
GROUNDWATER TREATMENT - On-Site treatment plant
9.
FLOOD PROTECTION - Levee option C (permanent)
Alternative 4B was eliminated from detailed evaluation for two
reasons as defined in the NCP:
( 1. )
( 2. )
Acceptable engineering practices, (i.e., reliability); and
Effectiveness, (i.e., adverse impacts).
This alternative essentially relies on containment of contaminated
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-23-
contaminated soils would not be excavated and would not be dest~oyed.
they will remain as a source of g~ound~ate~ contamination until the'
a~e ~emoved by the g~ound~ate~ ext~action/t~eat~ent/~einjecti0n sys~
tern. The estimated time ~equired fo~ g~oundwate~ pu~ping and t~eat-
ment would be a mini~um of 65 yea~s and probably longe~. This time
pe~iod is based on the assumption that treat8ent will continue until
contaminants ~each non-detectahle levels. All subseGuent esti~ates
a~e based on this rationale. The ~eliability of the t~eat~ent
system's operation and maintenance over this extended ti~e pe~iod
is ext~emely unce~tain; this, in turn, calls into question the
effectiveness of this alte~native in ~eeting the stated objective
of aquifer ~estoration within a ~easonable period of time.
The in-situ capping also ~culd cause adve~se environ~ental
in that the wetlands in Zones 4 and 5 would be pe~manently
without oppo~tunity for reestablishment. This alternative
would violate Executive Order 11990 by unnecessary filling
wetland where other practical alternatives exist.
lmpact
destroye,j
thus
a
Description of Alternative 4C
1.
RCRA CAP - Zones 1, 2 and 3 (over on-Site landfill)
2.
NON-RCRA CAP - Zone 6 (Cochato River inside security fence)
3 .
NO CAP - Zones 7 and 8-
4 .
SOIL EXCAVATION -
Zones 4N, 4S and 5 (to 4-foot depth)
followed by clean backfilling to facilicate
future wetland restoration
5.
SOIL DISPOSAL - On-Site landfill (RCRA design) of 100,000
cubic yards of material
6.
GROUNDWATER CONTAINMENT - Slurry wall around Zones 1, 2 and 3
7.
GROUNDViATER INTERCEPTION - none
8.
GROUND\JATER TREATMENT - none
9.
FLOOD PROTECTION - Levee Option C (permanent)
Alternative 4C was eliminated from detailed evaluation for two
reasons as defined in the NCP.
( 1. )
( 2. )
Acceptable engineering practices,
Effectiveness.
(i.e. reliability); and
This alternative relies on permanent containment of contaminated
soils/groundwater by means of a cap and slurry wall with no
groundwater extraction/treatment and an onsite RCRA landfill for
100,000 cubic yards of soils excavated from wetland Zones 4 and
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-24-
questionable. Furthermore, the renovation of groundwater would
rely on natural attenuation/degradation processes expected to
take hundreds of years. Thus, the objective of groundwater
restoration within a reasonable time period would not be achieved.
Description of Alternative 4D
1.
RCRA CAP
Zones 1 through 5 (in-place capping of contaminated
soilS') .
2.
NON-RCRA CAP - Zone 6 (Cochato River inside security fence)
3.
NO CAP - Zones 7 and 8
4.
SOIL EXCAVATION -
None
5.
SOIL DISPOSAL - None
6.
GROUNDWATER CONTAINMENT - Slurry wall around Zones 1, 2 and 3
7.
GROUNDWATER INTERCEPTION - none
8.
GROUNDWATER TREATMENT - none
9.
FLOOD PROTECTION - Levee option C (permanent)
Alternative 4D was eliminated from detailed evaluation for two
reasons as defined in the NCP:
(1.) acceptable engineering practices: and
(2.) effectiveness.
The containment of contaminated soils and grounnwater by means
of a surface cap and a slurry wall tied into the till, without
a system for withdrawal and treatment of the contaminated ground-
water, addresses the direct contact threat but does not reliably
address the problem of migration of contaminated groundwater.
The existence of downward vertical gradients and the lack of an
impermeable till, among other reasons, casts consinerable doubt
on the ability of this alternative to reliably prevent future
continued offsite migration of contaminated groundwater. This
alternative fails to meet the remedial goal of aquifer restoration.
Secondly, this alternative, by capping contaminaten wetland soils
in Zones 4 and 5 in-situ, would effectively permanently destroy
the wetlands. This would directly violate the Executive Order
11990, since other alternatives exist which would not require
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-25-
DETAILED EVALUATION OF REMAINING ALTERNATIVES
The remaining alternatives were subject to the required detailed
analysis as described in the NCP S 300.68(h). This analysis
evaluated the remedial alternatives and used the following criteria:
1.
Technical Evaluation
a. reliability
b. implementabi-li'ty
c. safety considerations
2.
Institutional Evaluation
a. applicable or relevant and appropriate requirements
b. ability of alternative to attain or exceed standards, or
reduce likelihood of present or future threats from the
hazardous substances
3.
Public Health Evaluation
a. ability to meet remedial objectives of maintaining low
risks or reducing risks
4.
Environmental Impact Evaluation
a. beneficial effects of the alternative
b. adver~e effects of the alternative
5.
Cost Evaluation
a. capital costs
b. operation and
c. present worth
maintenance costs
analysis
A more complete description of these criteria can be found in the
FS in Sections 5.11-5.15. Sections 5.20-5.80 in the FS evaluate
the required criteria for the detailed analysis of the alternatives.
The following section represents the general findings of the
detailed analysis for the alternatives, beginning with Alternative
No.3. A summary of the costs of the remedial alternatives is
included as Table 3.
Description of Alternative No.3
1.
Zones 1, 2 and 3 (over on-Site landfill)
RCRA CAP
2.
NON-RCRA CAP - Zone 6 (Cochato River inside security fence)
3.
NO CAP - Zones 7 and 8
4.
Zones 4N, 4S and 5 (to 4-foot depth)
followed by clean backfilling to facilitate
future wetland restoration
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-26-
.5.. SOIL DISPOSAL - On-Site landfill (RCRA design) of 100,000
cuhic yards of material
6.
GROUNDWATER CONTAINMENT - Slurry wall around Zones 1, 2 and 3
7.
GROUNDWATER INTERCEPTION - wellpoint system to recover groundwater
plume from Zones 1 through 7
GROUNDWATER TREATMENT - On-Site treatment plant
8.
9.
FLOOD PROTECTION - Levee op.tion C (permanent)
Alternative No.3 represents an alternative which is considered
to attain all applicable or relevant and appropriate Federal
public health and environmental requirements. It has been developed
to incorporate known and proven remediation technologies.
Technically, Alternative No.3 is believed to be capable of
construction; Areas of difficult constructahility involve the
excavation of wetland soils due to the high water table. In
addition, sedimentation controls in the Cochato River would need
to be implemented during river sediment capping. Ambient air
monitoring would be required during excavation and landfilling
and mitig~tive measures taken if necessary to protect workers
and area residents from adverse air impacts.
The areas of highest soil contamination on the site are or will
be contained beneath temporary caps installed as part of the
emergency removal and IRM actions. These areas will not be
excavated under this alternative. The soils which are to be
excavated will be disposed of in a RCRA landfill which will be
built on top of these existing capped areas.
Under Alternative No.3, the capping of Zones 1, 2, and 3 as part
of a RCRA landfill will he in compliance with the relevant and
appropriate RCRA regulations (40 CFR 264.310). The cap and
slurry wall will he designed to meet the closure performance
standard (40 CFR 264.111). The capping of Zones 2 and 3 in place
will leave a large volume of contamination within the seasonal
high water table and subject to continued migration. This alternative
requires the construction of the slurry wall, groundwater pumping
and long term post closure care.
Excavation, filling and landfilling in a RCRA landfill in' Zones
1, 2 and 3 of waste from Zones 4N, 4S and 5 will remove the great
majority of waste from the wetlands and with wetlands restoration
will comply with Executive Order 11990 relating to wetlands. How-
ever, it is not certain that wetlands can be fully reestablished
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Flood protection (Levee Option C) is necessary to insure the long
term protection of the cap and landfill. The flood protection
will be d.esigned to meet the RCRA location requirements (264.ll8(b»
and appropriate guidance.
The groundwater interception and treatment system will be designed
to attain RCRA groundwater protection requirements under 40 CFR
264.94. Consistent with the Ground Water Protection Strategy
(GWPS), the aquifer ~ill be restored to usable water quality to
the extent feasible. Storage and process tanks associated with
the water treatment plant will also meet Federal guidelines under
RCRA. The groundwater would be treated to a quality sufficient
for either subsurface or surface discharge.
Because a large quantity of wastes are left in contact with
groundwater beneath the existing temporary caps, the groundwater
interception and treatment system would take at least forty years
and possibly as long as sixty-five years to treat groundwater to
acceptable levels at the monitoring boundary. Because of the
relatively long time frame for treatment of groundwater, Alternative
No.3 fails to meet the remedial objectives of aquifer restoration
within a reasonable time and minimization of longterm management
and maintenance.
The stabilization proposal for Cochato River sediments (Zone 6)
does not provide total containment and isolation as is generally
required for hazardous wastes under RCRA. However, in-place
stabilization of the sediment, which functions as a groundwater
filter, reduces the 1i~elihood of present and future threats from
resuspension of contaminated materials in the river. Cochato
River water quality would be monitored to ensure that applicable
or relevant and appropriate standards are met.
Long-term institutional requirements will include permanent
regulatory limitations on future land use of the on-site landfill
and prohibitions on excavation in the Cochato River and temporary
limitations on activities in the wetland areas undergoing restoration.
The levee, landfill and slurry wall must he. maintained in perpetuity.
In addition, long term, post-closure requirements will be implemented
for the landfill.
Description of Alternative 3A
1.
RCRA CAP - Zones 1, 2 and 3 (over on-Site landfill)
2.
NON-RCRA CAP - Zone 6
3.
NO CAP - Zone 7 and 8
4.
SOIL EXCAVATION -
Zones 1 and 2 to 8 feet, Zones 3 thru 5
to 4 feet and removal of "creosote"
material followed by clean backfilling
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5.
SOIL DISPOSAL - On-Site RCRA landfill of 250,000 cubic yards
of material
6.
GROUNDWATER CONTAINMENT - Slurry wall around Zones 1, 2
and 3
7.
GROUNDWATER INTERCEPTION - We11point system
GROUNDWATER 1REATMENT - On-Site treatment plant
8.
9.
FLOOD PROTECTION - Levee option C (permanent)
Detailed Analysis of Alternative No. 3A
Alternative No. 3A is considered to attain all applicable or
relevant and appropriate Federal Public Health and environmental
requirements.
These technologies are believed to be capable of being constructed.
The difficulties with construction in the wetland Zones 4S, 4N and
5 are the same as those previously discussed for Alternative No.3.
In addition, Alternative No. 3A involves deep soil excavations in
Zones 1, 2 and 3 with an increase in both technical complexity
and health and safety requirements. The logistics of excavating
in the same Zones where the landfill will be constructed would
further complicate the construction. A temporary staging area
would need to be constructed to contain soils from these Zones
until they could be placed in the landfill.
The estimated lifetime of the RCRA landfill is at least 30 years.
However, the wastes to be landfilled are expected to remain
hazardous for much longer. Therefore, the long term reliability
of this alternative is questionable. The remedial objective of
minimization of long-term management and/or maintenance" is not
achieved.
Groundwater treatment time is anticipated to be 38 years and is
shorter than Alternative No.3 (65 years) due to the fact that a
large volume of soil (source material for groundwater contamination)
will be removed (i.e. isolated from groundwater). This time
frame for treatment fails to meet the remedial objective of
aquifer restoration within a reasonable time frame.
The performance and institutional considerations are the same as
those described in the previous alternative, Alternative No.3.
The Public Health concerns and environmental evaluation are the
same as discussed in the FS for Alternative No.3.
Description of Alternative No. 3B
1.
RCRA CAP - Zones 1, 2 and 3 (over on-Site landfill)
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2.
NON-RCRA CAP - Zone 6
3.
NO CAP - Zone 7 and 8
4.
SOIL EXCAVATION -
Zones 1 and 2 to 8 feet, Zones 3 thru
5 to 4 feet and removal of "creosote"
material: wetland restoration in Zones
4N, 4S and 5
5.
SOIL DISPOSAL -
On-Site RCRA landfill of 250,000 cubic yards
of material, until destruction in on-Site
incinerator with delisting of residue and
on-Site disposal
6.
GROUNDWATER CONTAINMENT - Slurry wall around Zones 1, 2
and 3
7.
GROUN~WATER INTERCEPTION - Wellpoint system
GROUNDWAT~R TREATMENT - On-Site treatment plant
8.
9.
FLOOD PROTECTION - Levee option C (temporary)
Alternative No. 38 is consictered to attain all applicable or
relevant and appropriate Federal Public Health and environmental
requirements. These technologies are believed to be capable of
being constructed and will be reliable upon completion. The
difficul~ies with excavation and construction in the wetlands are
the same as previously discussed.
Alternative No. 38 involves deep soil excavations which will
result in greater technical and health and safety requirements.
Logistic complications would develop during excavation for excav-
ation is planned in areas in which the interim RCRA landfill
would be built. A temporary staging area would need to be con-
structed to contain soils from these areas until they could be
placed in the landfill.
Soil treatment in Alternative No. 38 involves the use of inciner-
ation technology to permanently destroy the contamination contained
in the landfill. Design phase pilot studies would be performed
to eliminate uncertainties as to the specific type and operation
of thermal destruction technology necessary to attain the stringent
regulatory requirements for destruction of dioxin, while producing
an ash that can be backfilled on-site without posing an unacceptable
risk to either human health or the environment. (Pilot studies at
other dioxin sites have shown that these technologies do exist).
Groundwater treatment time is anticipated to be 38 years due to
the fact that a large volume of soil (contaminant source material
for the groundwater) will be removed. This treatment time is
approximately 30 years shorter than the 65 years estimated under
Alternative No.3 but still fails to meet the remedial objective
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for aquifer resto~ation within a ~easonable time frame.
other remedial objectives a~e met.
All
~lternative 38 provides a high degree of reliability since it
removes the majority of waste from within the water table and
dest~oys it in an on-site incine~ator. The institutional iss~es
are the sa~e as in the previous alternative (~lternative 3)
regarding landfilling, excavation, groundwater extraction anrl
treatment and flood ~rotection. In addition, the construction
and operation of an onsite incinerator must comply with the
relevant sections of RCRA (40 CFR 264, subpart 0) and ~elevant
air quality standards. The incine~ator must meet the technical
standards in RCRA including the January 14, 1985, rule requiring
the achievement of dest~uction and removal efficiency (D~~) of
99.9999%. The soil ash remaining afte~ incineration must be
demonst~ated to be p~otective of the public health and the
environment or disposed of in a RCRA landfill.
Description of Alternative No. 4M
Alternative No. 4M
1.
RCRA CAP
- none
2.
NON RCRA CAP - none iIT Zone 6 - Cochato River (see Future
Ac t ions Sect ion)
3.
NO CAP - Zone 7 and 8
4.
SOIL EXCAVATION -
"Hot Areas" only in Zones 1 thru 5 and
remove "creosote" material (191,000 cubic
yards) (See Figure 7)
5.
SOIL DISFOSAL - T'':.=atm~nt in o:1-site incinerater
storage in a RCRA landfill)
(No interim
6.
GROUNDWATER CONTAINMENT - wellpoint pumping system
7 .
GROUNDWATER INTERCEPTION - wellpoint system to recover ground-
water plume from Zones 1 through 7
8.
GROUNDWATER TREATMENT -
On-site treatment plant providing
metals precipitation, activated
sludge, biological, filtration and
activated carbon treatment
9.
FLOOD PROTECTION - Levee option C (temporary)
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Alternative No. 4M is a slight modification of Alternative No.4
presented in the FS. Alternative No. 4M differs in components
1, 2, 5 and 6 above. No interim RCRA landfill or RCRA capping
would be required. Instead, staging areas would be utilized to
contain excavated soils prior to incineration.
The river sediment capping decision would be deferred to the
future water supply feasibility study (discussed in the Future
Actions Section). . . .
The" soils would be excavated, dewatered if necessary, staged and
then incinerated as is described in Alternative No. 3R. Staging
amounts would be in proportion to the feed ability of the incin-
erator. Excavated areas would be backfilled and revegetated.
A slurry wall was not included as part of this alternative
due to questions about its reliability and effectiveness which
are discussed in detail in the Recommended Alternative Section.
Alternative No. 4M can be described as an advanced and innovative
application bf a "technology (thermal decomposition) to remediate
a hazardous waste problem. Through use of this technology,
minimization of present or future threats to the public health,
welfare and the environment would be achieved. This alternative
also is consioered to attain all applicable or relevant and
appropriate Federal public health and environmental requirements
and achieves all the remedial objectives.
Alternative No. 4M has an estimated groundwater treatment time
of 10 yrs. The estimate is based on the number of aquifer pore
volumes that would be necessary to treat contaminants in the
groundwater to non-detectable levels following the removal
of 95% of the total mass of contaminants from the soil.
This 10-year estimate of treatment time may change depending
on the treatment standards determined in design (see Consistency
with Other Environmental Laws Section). Alternative No. 4M
has an incineration program time of an estimated 5 years.
As in the previous alternatives, the excavation and filling
of wetlands will be consistent with Executive Order (11990)
and Section 404(b)(l) guioelines. The destruction of waste in
the onsite incinerator will meet the RCRA standards and relevant
air standards. The groundwater interception and treatment
system will meet the RCRA Groundwater Protection requirements
and Ground Water Protection Strategy.
Alternative No. 4M has beneficial environmental effects because
no permanent loss of wetlands would occur. Wetland reestablish-
ment is more feasible since not all of the wetland zones would be
excavated. Smaller areas would be excavated and therefore would
be easier to replant and reestablish. Zone 3 wetland areas
would not be lost for no permanent RCRA cap is anticipated to
be needed after excavation. Wetlands in Zone 3 would be re-
established instead.
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The wetland areas which will be excavated represent a severe but
temporary impact. Nonetheless, through restoration, a low
permanent impact is expected.
Description of Alternative 4A
1 .
RCRA CAP - Zones 1, 2 and 3 (over on-site landfill)
2.
NON-RCRA CAP - Zone 6
3.
NO CAP - Zone 7 and 8
4 .
SOIL EXCAVATION -
"Hot Areas" only in Zones 1 thru 5
and remove "creosote" material
(191,000 cubic yards) (See Figure 7)
SOIL DISPOSAL - On-Site landfill (RCRA design)
5.
6.
GROUNDWATER CONTAINMENT - Slurry wall around Zones 1, 2
and 3
7.
GROUNDWATER INTERCEPTION - wellpoint system
8.
GROUNDWATER TREATMENT - On-Site treatment plant
9.
FLOOD PROTECTION - Levee option C (permanent)
Alternative No. 4A is an alternative which attains all the
applicable or relevant and appro~riate Federal public health
and environmental requirements. The alternative is expected to
provide significant protection to the public health, welfare
and the environment and to reduce the likelihood of present or
future threats from the hazardous suhstances.
Alternative No. 4A is the same as Alternative No.4, except that
the excavated "hot area" materials would not be ultimately
disposed of in an onsite incinerator, but would remain landfilled
onsite. Thus, Alternative No. 4A is similar to Alternative No.
3, but involves excavation of a larger quantity of material for
onsite landfill disposal. The deep excavation into the watertable
in the "hot areas" would make the construction aspects difficult.
Additional safety considerations would he necessary due to the
deep excavations. .
Alternative No. 4A involves limited excavation in wetlands
areas which results in a reduced wetland restoration area. This
gives wetland restoration a better chance of being successful
because many of the established plants in the undisturbed
wetlands could propagate to the excavated and backfilled wetland
areas.
The length of groundwater treatment time is approximately 10
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would occur because 95% of the mass
removed. The remedial objective of
aquifer within a reasonable time is
native.
of contaminants have been
treating the contaminated
achieved under this alter-
The technologies described in Alternative No. 4A would be
implementable and reliable for the design life of the landfill,
estimated to be at least 30 years. However, the wastes to be
landfilled are expectea to remain hazardous for a much longer
time period. Therefore, the long term reliability of this
alternative is questionable. The remedial objective of mini-
mization of longterm management and/or maintenance would not be
achieved.
Alternative 4A excavates hot spots in Zones 1 through 5 and
landfills them. It has many of the same institutional issues
involved with the previous alternatives relating to capping,
excavation, landfilling, groundwater interception and treatment,
flood protection, air quality during construction and stabilization.
Alternative No.5
Alternative No.5 is the No Action Alternative. Under a No
Action scenario, all the-public health and environmental risks
associated with the Site would remain. The remedial objectives
would not be achieved. This alternative was eliminated from
further consideration. Further explanation on why the No
Action alternative was eliminated can be found in the FS on
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Recommended Alternative
The NCP defines the appropriate extent of remedy as a cost-effective
alternative that effectively mitigates and minimizes threats to and
provides protection of public health, welfare and the environment.
With certain specific exceptions, this requires the selection of
a remedy that attains or exceeds applicable or relevant and
appropriate Federal public health and environmental requirements.
Cost, technology and reliability are also to be considered.
Based on a cons ide'rat ion of these cri teria the recommended a 1 terna t i ve
for the Baird & McGuire Site is Alternative No. 4~.
Alternative No. 4M represents a cost effective alternative which
effectively mitigates and minimizes threats to, and provides adequate
protection of, public health and welfare and the environment.
This alternative attains applicable or relevant and appropriate
Federal public health and environ~ental requirements for the
Site. Alternative No. 4~, in conjunction with future actions at
the Site, achieves all the remedial public health and environmental
objectives: .
1) The human"population will be at minimum risk from direct
contact with contaminated soils.
2) The aquifer will be remediated within a reasonable time-frame
to prevent present or future impacts to groundwater drinking water
supplies.
3) Surface water will he protected from future contaminant migration.
4) Longterm management and/or maintenence requirements will be
minimized.
As previously noted, certain components of Alternative No.4 as
presented in the FS were modified in developing Alternative No.
4M. The following' discussion presents the rationale for the
modification of those components.
1. RCRA CAP: 5. SOIL DISPOSAL (INTERIM RCRA LANDFILL)
Alternative No.4 utilized a RCRA landfill (including a RCRA cap)
as an interim storage measure for the soils until they could be
incinerated. The landfill would prevent direct contact and
further contamination of groundwater and surface water during the
incineration set up time (estimated 2-3 years). EPA does not
believe this is a cost-effective approach due to the needless
extra costs of construction of the landfill and the risks associated
with the additional soil handling requirements such as increased
particulate generation, additional worker exposure, and potential
runoff and erosion problems. The status of the site with the
temporary caps, groundwater recirculation system, and fence,
achieves the goals of an interim solution without a landfill. soil
excavation will be coordinated with incineration feed rates to
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2.
NON RCRA CAP (River sediment capping)
Alternative No.4 included placement of a permeable cap over the
contaminated Cochato River sediments of Zone 6 to prevent direct
contact and to minimize the downstream transport of sediments.
More data is needed on the sediment contamination upstream and
downstream of the site before a decision on sediment remediation
can be made. The Fu~u~e Actions Section details the proposed
study. The ekisting fence will prevent direct contact until that
time.
6.
GROUNDWATER CONTAINMENT
On pages 5-12 and 5-13 of the FS, GHR lists technical reasons why
slurry walls were determined to be advantageous. ~PA disagreed
with the use of slurry walls for the Baird & McGuire site for the
following reasons:
1. In general, the Agency's experience with slurry walls at
other sites demo~strates that they tend to leak contaminants when
not properly. keyed into bedrock. The GHR proposal calls for the
slurry wall to extend to the top of a very permeable (10-3 cm/sec)
glacial till. Thus, the permeable glacial till-vill undermine the
effectiv~ness of the slurry wall.
2. The slurry wall will not extend to bedrock, and vertical
downward gradients will enable contaminants to pass under the
slurry wall, resulting in a large amount of contaminants continuing
to migrate from the site toward the Cochato River. At the present
time, a large amount of contaMination is present in the till
verifying that the till is a potential pathway of contaminant
migration which would not be affected by slurry wall construction:
it would continue to be a source that needs remediation.
3. The potential is strong that the slurry wall which was
planned completely around the site would inhihit fresh groundwater
inflow. The cap would prevent vertical infiltration (recharge).
The result of a slurry wall and a cap with a pump would be that
the permeable deposits would become unsaturated in a short time
leaving the volatile and semivolatile organics tied up in the
soils in an unsaturated zone and unahle to be flushed.
4. Groundwater treatment time is unaffected by the slurry wall
installation because migration in the till deposits remains
unchanged. Cleanup in the overhurden will be an order of magnitude
sooner than the elimination of contamination in the till deposits.
The ultimate length of cleanup time is based on the time needed
to clean the till.
5. Eecause groundwater velocities are less than a foot per day,
and power outages and pump failures are short term problems,
power outages do not represent a significant problem. The amount
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6. Based on the minimal drawdown from the present groundwater
recirculation system, a system will be designed to minimize the
capture of clean groundwater while maximizing the capture zone of
highly contaminated water. The data presented by GZA in their
Interim Groundwater Containment Report, August, 1985, shows
c1pture zones of less than 200 feet at a 15 gpm pumping rate. A
slurry wall will do little to enhance capture of contaminated water.
7. The recommendeH groundwater treatment system will also have
the capability of shutting off certain areas once they are clean
or reach performance standards. With a slurry wall, pumping may
have to continue indefinitely to prevent mounding effects.
8. A slurry wall will also create a boundary which might have a
detrimental effect on the future yield of the South Street Well
Field if or when it comes back into service.
Alternative No. 4M is more cost effective than Alternatives Nos
3, 3~ and 4A,' which rely on a permanent RCRA landfill for all
excavated soils. Although the respective present worth costs of
$15.4 million, $18.1 million and 514.7 million are significantly
lower than the $44.4 million for Alternative 4M, the long-term
effectiveness and reliahility of on-site landfilling are uncertain.
The wastes involved are persistent, toxic, bioaccumulative and
mobile. Thus, the ability of the landfill alternatives to meet
the objectives of ~ite remediation depends on the viability of
permanent containment, since no waste destruction or stabilization
would occur prior to landfilling. The questionable reliahility
of a well nesigned landfill to provide containment in perpetuity
for wastes of this type together with the uncertainties associated
with forever maintaining the landfill are key factors in ruling
out these landfill alternatives.
~oth Alternatives 3~ and 4M utilize thermal decomposition which
will provide permanent destruction of the contaminants in the
excavated soils. Alternative 3~ would include excavation of
250,000 cubic yards of soil in Zones 1-5. The surface area to be
excavated is greater than that of Alternative 4M with the additional
area ~rimarily in wetland Zones 4N, 45 and 5. Given the uncertainties
that exist in reestablishing wetlands in these excavated areas,
an attempt was made to restrict the excav3tion in the watland~ to
the "hottest" areas and to leave intact those wetland soils where
contaminant levels pose minimal risks to human health and the
environment. Thus, Alternative 4M utilizes a "hot area" approach
to define the areal limits of excavation, resulting in an estimated
lQl,OOO cuhic yards for excavation~ ~ecause this excavation goes
deeper than 3A, the alternative is actually more effective since
it reduces the time needed for groundwater renovation from 38 to
10 years while reducing the present worth cost from $65.6 Million
to $44.4 million. Alternative 4M is also more effective in that
it minimizes hoth the short term wetland impacts associated with
excavation and the area requiring longterm reestablishment.
Detailed wetland mitigation through restoration will be developed
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Alternative ~o. 4M is a complete remedy. It treats or destroys
all contaminated media (soil, groundwater) with concentrations
which pose a risk to the public health, through incineration and
groundwater treatment technologies.
Following successful completion of incineration, groundwater
interception and treatment and wetland restoration under Alter-
native No. 4M, longt~rm beneficial environmental results will be
achieved. Specifically, uncontaminated wetlands and soils will
increase the environmental vitality of the site compared to its
present state.
In summary, Alternative No. 4M has the following advantages:
3 )
4 )
5 )
A permanent remedy following the conclusion of incineration
and groundwater interception and treatment
Complete destruction of hazardous substances on-site
elimjnating future containment/leaching problems and the
potential need for future off-site remedies
No long .term wetland loss since wetlands are restored or
left uncapped
Aquifer remediation
Low O&M costs
1 )
2 )
Extent of Excavation
Alternative 4M incorporates excavation of Hot Areas. The excavation
of Hot A~eas has been determined by EPA to he the most advantageous
form of excavation. The Hot Areas were delineated based on
contamination profiles developed in the RI Addendum Plan ~os.
GS-l thr.ough GS-3. The limits of excavation were estahlished so
that the contaminant levels in the remaining soils are one to two
orders of magnitude lower than the levels in the soil which are
to he excavated. Change in levels of contamination were correlated
with change in topog~aphic elevation lines to define the Hot
Areas. The FS anticipates that this approach will result in
approximately a 95% removal of the total mass of contaminants
from the soil.
The Hot Area excavation scenario does leave hazardous substances
behind in wetland Zones 4N, 4S and 5. Concentration of critical
contaminants in the remaining unexcavated areas will be within
the EPA recommended guidance for target chemicals in terms of public
health risk. The target total individual carcinogenic risk
resulting from exposure may range anywhere between 10-4 to 10-7. The
following tables represent the reduction in risk in the Zones
where hazardous substances remain. The II Risk After Remediation"
column values were ohtained by lowering the risk assessment
numbers by one order of magnitude (a factor of ten) from the
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Risk After
Zone 4N Risk Remediation
Surface Soil - "No Action, Norst Case" 4.3 x 10-4 4.3 x 10-5
Surface Soil - "No Action, Present
Conditions" 9.2 x 10-5 9.2 x 10-6
Deep Soil "No Action, Worst Case" 1.5 x 10-5 1.5 x 10-6
Risk After
Zone 45 Risk Remediation
Surface Soil - "No Action, t'lor s t Case" 6.2 x 10-5 6.2 x 10-6
Surface Soil - "No Action, Present
Conditions" 1.3 x 10-5 1.3 x 10-6
Deep Soil "No Action, Worst Case" 1.6 x 10-5 1.6 x 10-6
Risk After
Zone 5 Risk Remediation
Surface Soil - "No Action, t"lors t Case" 6.0 x 10-5 6.0 x 10- 6
Surface Soil°- "'No Action, Present
Conditions" 1.3 x 10-5 1.3 x 10-6
Deep Soil "No Action, Worst Case" 3.7 x 10-5 3.7 x 10-6
The remaining areas of contamination after Hot Area excavation
present carcinogenic risk of anywhere between 10-4 to 10-7 from
potential exposure based on toxicity and chemical intake data for
both the "present conditions" and "worst case" scenarios.
The depth of excavation in the Hot Areas will be to the top of
the water table only. Technical difficulties develop if excavations
were to proceed into the water table. SOMe of the complications of
excavation into the water table include: the extensive dewatering
of the soils required: side wall cave-ins: contamination of clean
soils by contact with contaminated groundwater: and the possibility
of volatization of organics when groundwater is exposed to the
air.
However, a maximum excavation depth will be achieved by hynrodynarnic
lowering of the water table. Water which is withdrawn will be
treated in the onsite groundwater treatment plant. Treated
groundwater would be either discharged on-site or off-site through
injection wells into the aquifer or discharged to surface'waters
(Cochato River: Unnamed Brook) or discharged directly to the
sanitary sewer. The final point(s) of ~ischarge will be mainly
dependent on the capacity of the aquifer to handle the additional
water from the treatment plant. The nquifer is the preferah1e
point of discharge. If the aquifer cannot achieve the rechnrge
capacity, other discharge points will he utilized. Any additional
treatment requirements based on the final point of nischarge will
be included in the design of the treatment plant (i.e. activated
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The test bu~n will be designed and ca~~ied out in full complicnce
~ith RCRA ~equir~ments. The test burn will include each of the
va~ious soil types, including samples from the most conta~inated
areas of the site. The ai~ emissions and ash will be tested to
confi~m that the contaminant levels re~aining are p~otective of
the public health and the envi~onment. The ash will be backfilled
onsite into areas where excavations occu~red. Loam will be added
to supplement the fill mate~ial and aid in the reestablish~ent of
vegetation.
A~bient air quality will be monitored during on site remediation
activities to ensure that on-site and off-site levels of particulates
and volatile organic compounds do not reach unacceptable levels.
A detailed monitoring plan including on-site action levels, site
pe~imeter monitoring and collection of meteorologic data will be
included in the design.
Acceptable site perimeter levels and on-site "action levels" "'-'ill
be developed based on applicable standards and guidance from SPA
and the Cente~s for Disease Control. Action level$ are the
ambient levels which will trigger specific actions which may include
discontinuing the excavation, groundwater treatment or incineration
and any additional measures needed to reduce air contaminant
levels. The design will describe these specific measures in
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Consistency with Other Environmental Laws
Environmental laws which are applicable or relevant and appro-
priate to the recommended source control and management of migration
alternatives at the Baird & McGuire site are:
- Resource Conservation and Recovery Act (RCRA)
- Clean Water Act
- Safe Drinki~g Water Act
- Clean Air Act
- Executive Order 11990 (Protection of Wetlands)
- Executive Order 11988 (F1oonp1ain Management)
As specified in the Detai1en Analysis of alternatives section,
Alternative 4M is expected to fully comply with the above laws.
The primary environmental law of concern at Baird & McGuire is
the Resource Conservation and Recovery Act (RCRA) 42 USC S 6901,
et seq. The recommended remedy was reviewed for consistency with
relevant and appropriate RCRA technical standards:
40 CfR
40 CFR
40 CFR
40 CFR
40 CFR
S .264
~ 264
~ 264
S 264
S 2*54
Subpart G,
Subpart 0,
Suhpart F,
Subpart T(,
Suhpart N,
Closure and Post-Closure
Incinerators
Groundwater Protection
Surface Impoundments
Landfills
The source control action of closure by excavation of the hot
spots in areas 1, 2, 3, 4N, 45 and 5 will comply with the closure
perforMance standard ~ 264.111 and the the surface impoundment
closure requirements: closure by removal of waste and waste
residues.
The proposed residual soil levels will provide adequate protection
of public health and the environment. During the design, a
sampling plan for_excavation will be proposen that will document
that the remaining contamination will present a lifetime cancer
risk from potential exposure to be within the 10-4 to 10-7 risk
range. The sampling will occur in conjunction with construction.
Excavation, filling and restoration of the wetlands will comply
with the technical intent of Executive Order 11990 -~ Protection
of Wetlands and the Clean Water Act ~ 404(b)(1) guinelines. The
hot spot excavation will minimize the destruction of the wetlands
in comparison with the capping alternatives. The remedial action
contains components to restore the wetlands which may result in
the improvement of the beneficial values of the wetlands. The
restoration of the wetlands after excavation will be performed
consistent with the 404(b)(1) guine1ines, and with EPA and State
review of the design of the mitigation measures. The Agency
feels it is necessary to perform the hot spot excavation to
-------
-41-
The treatment of the approximately 191,000 cubic yards of excavated
soil and debris will he in compliance with the RCRA 264 Subpart 0
Incinerator Standards. A test burn will be performed to ensure
that it is feasible to meet the required Destruction and Removal
and Efficiency (DRE) of 99.9999% for Principal Organic Hazardous
Constituent (POHC). The POHC'S will be estimaten prior to the
trial burn. The trial burn will demonstrate that air emissions
meet all relevant State and Federal air quality standards and
other levels neces~a~y' to protect public health. The trial burn,
operating par~meters, and monitoring plan will be reviewen by EPA
and DEQE prior to implementation.
Following the completion of the trial burn, the Agency will make
a decision regarding the final disposition of the treated soil.
The Agency will utilize site-specific exposure/risk modeling to
determine if the residu~l contamination will pose a threat to
health or the environment through any route of exposure (groundwater,
surface water or direct contact). If it is found that incineration
residual contamination requires further treatment or has disposal
restrictions, th~ Agency will reevaluate the recommended alternative.
The recommended management of migration, groundwater extraction
and treatm~nt, will meet the intent of the RCRA Groundwater
.Protection requirements. The groundwater protection. regulations
require the setting of groundwater protection standards which
must be protective of the public health and the environment. The
groundwater levels can be set at background, Maximum Contaminant
Levels (MCL's) or Alternate Concentration Levels (ACL's) -- site
specific levels that are demonstrated to be protective of the
public health and the p.nvironment. Ouring the design of the
groundwater interception and treatment system, restoration target
levels will be proposed based on existing data. After 5 years of
operation, the Agency will determine in a supplemental decision
document if the restoration target levels are achievable and if
they are adequate to protect public health and the environment.
Due to the wide range of contaminants at the site, levels will be
based on both standards ann risk levels. Due to the nature of
contamination and site specific conditions, it is not possihle to
establish levels at this time. The syste~ will be designed to
recover groundwater to the extent feasible from the contaminated
~reas. The restoration of the aquifer is consistent with the
Groundwater Protection Strategy (GWP's) which classifies the
aquifer at Baird & McGuire as Class II (current or potential
usage) and requires the restoration of these aquifers.
The effluent from the groundwater treatment system will meet the
applicable and relevant standards. To the extent feasible treated
groundwater will be discharged back to the aquifer to aid in
flushing. In the event that all extracted groundwater cannot be
recharged to the aquifer, an alternative method of discharge will
-------
-42-
A groundwater monitoring program will be designed and implemented
to document the efficiency of the pu~p and treat system consistent
with 40 eFR 264.l00(d). The monitoring program will include
sampling points that will verify that the "hot spot" excavation
was successful at removing the large majority of contamination.
Flood protection measures will be designed and implemented consis-
tent with 40 eFR 264.l8(b). This measure will insure that there
are no unplanned releases to the environment during excavation
and treatment due to flooding. Alternative 4M is consistent with
Executive Order llQS8 (Floodplain Management) since it results in
the restoration and preservation of the natural and beneficial
value of the floodplain.
Appendix A includes a more specific discussion of consistency
-------
-43-
Operation and Maintenance
Alternative No. 4M includes two components which involve long
term remediation, incineration and groundwater interception and
treatment. Incineration costs are considered to be part of the
capital costs of the clean-up. Capital costs will be split on a
90% Federal and 10% State cost sharing basis.
The operation and maintenance (O&M) costs of the groundwater
interception and t~e~t~ent system are considered as capital
costs until soil remediation is complete. Following soil
remediation, operation of the groundwater interception and
treatment system are considered O&M costs. Costs for operation
and maintenance are split on a 90% Federal, 10% State basis
during the first year. After the first year of O&M, the State
is responsih1e for 100% of the O&M costs into the future.
Some of the specific duties included under O&M of the groundwater
interception and treatment system are the monitoring of
interception/reinjection pumps and pipes, and effluent and
influent, daily O&M of the treatment plant and periodic disposal
of spent carbon and waste sludge. The possibility exists of
on-site regeneration of spent carbon and dispo~a1 of sludge in
the on-site incinerator. The feasibility of this will be
determined during design.
General overall site O&M will continue during remediation. Some
of these duties include fence maintenance, trash disposal, lawn
mowing and snow plowing of access roads.
The following table represents the estimated costs and duration
of O&M activities at Raird & McGuire.
Activity
Unit Cost
Duration
Net Cost
Treatment Plant
O&M (1)
Security
Mow Cap (2)
Well Monitoring
$1,520/day
$10,OOO/month
$3,900/year
S23,500/year
4 years
10 years
2 years
30 years
2,219,200
1,200,000
7,800
705,000
Total
$4,132,000
Notes
(1) Cost based on 25-75 gpm treatment plant. A 100 gpm treatment
plant is the recommended design but the co~ts are not anti-
cipated to vary greatly from the O&M value presented.
(2) Based on 3 mows per year until cleanup begins.
The State agency responsible for the impiementation of O&M is the
Massachusetts Department of Environmental Ouality Engineering
(DEQE). EPA's estimated level of funding is considered to be 90%
of the cost of the first year of O&M (O&M co~ts for the ground-
water treatment plant are expected to commence in year 7 of the
cleanup). This is approximately $631,935.
-------
-44-
Schenule
Approve Remedial Action (sign ROD)
Complete Enforcement Negotiations
Start Design.
Sign Superfund State Contract
Complete Design
Start Construction.' .
Complete Construction of Treatment
Complete Incineration
Complete Groundwater Treatment
Plant
9/29/86
10/30/86
11/1/86
3/31/87
11/1/87
1/1/88
7/4/89
7/4/94
-------
-45-
Future Actions
Additional remedial actions are necessary due to the water supply
shortages caused by contamination from the Baird & McGuire site.
Past contaminant releases from the site into the Cochato River
resulted in the closing of sluice gates on the Richardi Reservoir.
The Cochato River formerly had been utilized as a surface water
source to the Richardi Reservoir. Loss of the river as a source
of water affects the" Towns of Holhrook, Randolph and Rraintree
whose water supply is the Richardi/Great Pond Reservoir system.
Baird & McGuire's pollution has been documented as the cause of
contamination of the South Street Well Field. The South Street
Well Field was capable of supplying 1.8 mgd of water into the
Holbrook/Randolph water supply system. The wells were never
fully utilized due to the contamination from Baird & McGuire,
originally detected in Well No.3 in lq59. Well No.3 was shut
down in 1959, Well No.2 in 1980 and Well No.1 in 1982. EPA,
under Superfund, can replace the lost demand for a well supply,
when it was operating, not its capacity. The most likely replace-
ment source for the lost demand is the Donna Road Well Field.
The wells have been closed due to high iron and manganese concen-
trations in the water. Sampling results this spring indicate
that the water is free of other contaminants. A focused Feasibility
Study will he performed to establish the amount of past demand on
the South Street Well Field and establish costs for modernization
and iron and manganese removal at the Donna Road Well Field to
replace the lost demand.
The sediments of the Cochato River adjacent to the site warrant
remediation based on existing contaminant data. The FS proposed
capping the sediments in place to eliminate the threat of direct
contact and prevent downstream contaminated sediment transport.
EPA believes that in order to remediate the sediment contamination
problem both the upstream and downstream sediments must be evaluated
in the remediation. Since it was beyond t,e scope of this FS to
establish the risk associated with upstream and downstream sediments,
no determination can be made presently as to what remediation
appro~ch should be taken. The future additional sampling and
risk characterization of the sediments is integrally tied to the
water supply issues of the Cochato River.
Further information will need to be obtained prior to sediment
remediation and the determination of the feasibility of once
again utilizing Cochato River as a water supply source. The
study will include the following:
1) Distrihution of sediment contamination and its associated
risk to the public health or the environment
2) Flood issues associated with sediment remediation
-------
-46-
4) The potential for monitoring of river water quality
to its entering into the Richardi Reservoir.
5) The risk to the public health if the river is to be
as a water supply source under the various sediment
remediation plans
prior
used
In conjunction with design of the remeoy, additional air monitoring
will be performed in. o~der to establish ambient air quality levels
for volatile organics at the site. Two past air sampling events
for volatile organics have resulted in invalid data due to laboratory
contamination of the samples.
In conjunction with the design "target", groundwater restoration
levels will be set. After five (5) years of operation and evaluation,
the Agency will prepare a supplemental decision document to
determine how long the ground~ater extraction and treatment
system will remain operational and to oocument that the target
-------
-47-
Community Relations
Community interest in the Baird & McGuire Site began in 1975
when a Holbroo~ resident reported a suspected illegal discharge
to a wetland area adjacent to Baird & McGuire, Inc. The site
was placed on the NPL in December 1982. Public interest has
been high throughout EPA removal and remedial actions, as the
problem has been covered in depth by the local and metropolitan
Boston news media.. Two hearings on renewal of the company's
license to store chemicals were heavily attended, one in 19R2
and the second in April 1983 when the Town Selectmen refused to
renew the permit. Citizens are concerned about potential con-
tamination of the municipal water supply for Braintree, Holhrook,
and Randolph, and about potential airborne contamination.
Local interest heightened further in early 1985 when the Clean
Water Action Project (CWAP), a national environmental action
group, sent nn organizer into the community. ~pproximately 250
letters were received by the EPA Regional Office around this
time. They requested that BPA fence the site and provide 24 hour
security, and urged reauthorization of Superfund. CWAP helped
form a local group, People United to Restore the Environment
(PURE). About 200 persons attended an EPA public meeting on June
10, 1985 to explain the results of the RI. PURE and CWAP held
a press. conference at which they demanded that a fence be erected
around the eight-acre facility and that warning signs be posted.
They also demanded that buildings on the site be removed, that
a comprehensive health study be conducted, that a water main
supplying water to Holbrook be diverted from the site, that
citizens participate in the development of cleanup plans, that
Cochato River sediments and area drinking water sources he tested,
and that a meeting be held with the EPA Regional Administrator.
The Holbrook Selectmen facilitated the formation of the Baird &
McGuire Citizen's Task Force, which has met frequently on an
as-needed basis since its inception.
In July 1985, public interest was increased when low levels of
dioxin were discovered in soil at the site. EPA announced that
emergency response authority would be used to erect fencing.
The Massachusetts OEOE announced that it would grant funds to the
Holbrook hazardous waste coordinator -- a position set up in towns
statewide by OEOE -- to educate the public about the site and to
serve as a liaison between the community and government agencies.
EPA and OEO~ representatives have attended frequent meetings of
the Baird & Mcguire Task Force in the past year to provide infor-
mation and hear citizens' concerns. EPA held a public meeting to
explain the results of the RIfFS on August 20, 1986, at Holbrook
High School. Approximately 50 persons attended, including repre-
sentatives from the Baird & McGuire Task Force, citizens, and
local off.icials. On September 3, 198~, a public hearing was held
at the same location to record comments by the public including
-------
-48-
tatives from the Baird & McGuire Task Force, a State Representative,
a State Senator, members of PURE, members of the National Clean
Water Action Project, Town Selectmen from Holbrook and Randolph,
and local residents and citizens. Written comments from some of
the same parties and additional parties were received during the
remainder of the comment period. These comments and EPA's responses
are summarized in the attached responsiveness summary. In addition,
the comments are surn~a~ized below. After receiving several
hundred letters and about a dozen telephone calls from citizens,
EPA had postponed the two meetings and had extended the public
comment period to ensure that all interested parties had an
opportunity to comment.
Several citizens favored excavation of the "hot spots" with
treatment in an on-site incinerator. Several citizens commented
that EPA should consider the use of innovative technologies such
as biodegradation in the cleanup process. Many citizens were
opposed to th~ containment-based alternatives, as well as to the
temporary solutions. Many citizens expressed concern about the
overall effectiv~ness of incineration of contaminated soils, and
ahout the types of testing to be done prior to on-site operation
of an incinerator. One citizen questioned whether water quality
sampling would be conducted during hook up of the watermain.
Many commenters oppose the import of contaminated materials from
other locations for storage, destruction, or treatment at the
Baird & McGuire site. A citizen expressed concern about the
current groundwater interception and recirculation system. This
citizen expressed concern that volatile organic compounds released
during the aeration process may not be treated. A citizen questioned
whether sources of contamination have been detected outside of
the immediate site area. Many citizens requested frequent testing
of the water supply and monitoring of contaminant levels on an
-------
1
~
I SCALE 1 :25000
J 0 1 Mll(
r-= ---' ..,~- -a ~=-::::=o~ --====-;:::--=----'---=---=~
1000 0 1000 :>000 Jooo '000 ~ 6000 7000 '(eT
o=r-r-~-. -"'.=-- .::::=:----=.:. -~-"'-~ ,- -'~----J
FIGURE
LOCUS PLAN
I "~
-------
FIGURE 2
BAIRD & M
HOLBROO:GUIRE SITE
. MASSACHUSETTS
CENTRE
C
- - . SECURITY
-. LOCA nON FENCE, APPROXIM"
.. - ~ TE
... - . WETLANDS
I I . III RAILROAD
300
-------
HOLBROOK, MA.
SITE PLAN
'CCAMP, DRESSER, and McKEE
~: BOnO~, MA. DECEMBER, 181111
'.e>,. ~
~
o !>U' ,,'0' , ~o'
-------
FIGURE
4
REMEDIAL ACTION ZONES
BAIRD & McGUIRE SITE
ZONE 7
.'"".~...~..,.
....-
- ..
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-.
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0\,,1
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SCALE IN-FEET
~.
-------
FIGURE 5
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A
.IICAYATION .U.-ION.
,.-
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PAESENT COUII8E-
UNNAM.D '.AOOII
.IICAY.TlON 8U.-IONE .OUNDAA.
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-------
Table
~
Selected Critical Contaminants at
the Baird and McGuire Site
CClj)cur.d
(Note 11
heilth
Rab ng
(licte 2)
--.____4___~__----------------- ---------------
1,I-Dichloroethylene
1,2-Dichloroethi~e
:,3,7,B-TCDD
~,4'-DDD
4,4 '-DDE
4,4'-~DT
Aldrir.
Arsenic
Senane
FPr,z i dine
h~zoia)pyrene
Be~) 11 iut
B"!:-alpha
Br!:-~etil
rn:-deltaite:ht
Er1:-g~ua
CiCt::!.
Ct,i c'di:'le
n,j C~ of or.
£!e;c-:r.
~..;:tjj~t,lc'r
~€;tjj:~ic' e~o:idE
Ii; c ~ e I
TEtrjj:hlcrcethile~e
ir)~hjcrc..~hyie:'le
Vir,~1 chic-ide
J,~-tra~5-Dlch;crc€thyleoe
1.3-trir~-ric~1~-c;:roPile~e
2-F~tiTione
f.~iul
t~h.r !3!'~I:ere
.it;c~ ar.ther,e
C
C
C
C
C
C
C
C
C
C
C
C
C
C
C
C
C
C
C
C
C
C
C
C
C
C
ICC
Ii~
Ii~
leat
::1\'E-
II:
liC
HC
IiC
hC
IiC
HC
tiC
liler.H
Teol~H,e
I:C~) (tpct,)
Zi rl:
T c~.1 (jtt,€~ f~:i~
[-. ter,:eofu-.,
SC
SC
-----...--------
-------
Table
2
PAH compounds Included in the
"Total Other PAH I sit Category
2-"ethylnap~thaJfnE
A:enaphthene
kC erlaph H,,. I enE
kr.Horacene
~f~~o(a)ar.thricene
&en:olbiflu~ranthene
Fe~:o(ghi)peryler.e
Ffn;~ikifjuorinthene
C~lry.se;"le
tlb~~:o(a,h}a~thra~ene
>!U:lrf~e
iC2noil,:,3-cdipyrene
".~'~IHr~ 1 er,e
P~, er,. ~ tt,r er, 2
-------
1~BLE 3 - 5U~MARt OF ~LiERNMTIVE COSTS
--------------------------------------------------------------------------------------------------------
ITE~ DESCRIPTION ALiERNATIYE ALTERN~TIVE ALTERNATIVE ALTERNATiVE ALTERNATIVE ALTERNATIVE
3 3A 38 4A 4~ 5
--------------------------------------------------------------------------------------------------------
1. Construct Levee Option C 202,000 202.000 202,000 202,000 202,000 202,000
'1 Install slurry .all 920,000 920,000 920,000 920,000 NIA N/A
...
1 Prepare landfill base 1,130,000 1,469,000 1,469.000 1,356,000 NiA NiA
~.
4. Excavate 100,000 CY soil and
place in landfill 1,387,000 NiA NiA NiA N/A NiA
5. Wetland restoratIon 1,402, 'JOO 1,402,000 1,402,000 514, 'jOO 553,000 NIA
6. Excavate 250,000 CY soil and
place in landfill NIA 3,308,000 3,308, OOf) N/A NiA NIA
7. Excavate 191,000 CY soil and
place in landfill NIA NiA N/A 3,308,000 NIA NIA
8. Excavate 191,000 CY and
stage MIA MIA NiA NIA 1,681,000 NiA
9. Install groundwater intercept
and recharge systel 598,000 598,000 598,000 598,000 598,000 N/A
10. Install RCRA cap on landfill 1,975,000 2,568,000 2,568,000 2,370,000 NIA NIA
11. Cap Zone 6 river sedilents 337,000 337,000 337,000 337,000 NIA NiA
12. Install and operate On-site
treatlent 'plant for 65yrs 6,675,000 NIA NIA NIA NIA MIA
14. Install and operate On-site
treatlent plant for 38yrs MIA 6,540,000 6,540,000 N/A MIA N/A
15. Install and, operate On-site
treatlent plant for 10yrs MIA NiA MIA 4,297,000 4,297,000 N/A
16. Install GN lonitoring systel
and lonitor for 30yrs 720,000 720,000 720,000 720,000 720,000 720,000
17. Relocat! unnaled brook 45,000 45,000 45,000 45,000 45,000 MIA
18. Incinerate soils in On-site
incinerator MIA NIA 47,500,000 N/A 36,290,000 N/A
19. Other 'no action' items MIA NIA MIA N/A NIA 220,000
--------------------------------------------------------------------------------------------------------
--------------------------------------------------------------------------------------------------------
TOTAL 15,391,000 18,109,000 65,609,000 14,667,000 44,386,000 940,000
-------
Appendix A
Consistency with State Environmental Laws
The State of Massachusetts has identified various technical
requirements of State environmental laws which will be taken
into account during implementation of the rp.medy. This
section will describe the requirements or standards identified
to EPA by the State in terms of the various media affected by
the remedy.
Air
The Massachusetts Department of Environmental Quality
Engineering (DEQE), Division of Air Quality Control (DAOC)
requires certain standards to be met during remediation at
Baird & McGuire. The areas of concern include: dust and
volatile emissions during site excavation, incineration of
soil and incineration of sludge. The specific
standards which DAQC sets as goals are attached and are
the same as those utilized by EPA. These goals will be
achieved during remediation.
The DAOC will have the opportunity to review EPA's contractor's
prevention plan for dust, odor and noise, and the testing
protocol for the burning of contaminated soil and sludge.
Air quality modeling will be performed to determine air
quality impacts during incineration and excavation. Monitoring
and stack testing will occur in conjunction with the inciner-
ation test burn and operation. The design of the incinerator,
test burn protocol and test burn data will be shared with
DAQC staff for their review. Any site work is open to moni-
toring and review by DAQC staff.
Water
In regards to the groundwater interception and treatment
system, all design plans and design specifications will be
shared for review by the DEQE's Division of Water Pollution
Control (DWPC). Operation manuals and maintenance schedules
will be developed for the system and provided to assure proper
O&M of the plant by the State. Groundwater monitoring plans
and schenules will be developed to allow their implementation
by the State.
Any DWPC requirements for formal public co~nent (such as
allowance of discharge to groundwater from the system) will be
superceded by the Superfund Public Participation process.
During the operation of the groundwater interception and
treatment pl~nt, monitoring reports will be submitted to the
EPA and DWPC by the contractor in charge of the plant operation.
If the State r.equires stricter discharge standards than EPA,
the State will be required to pay the associated incremental
cost (see NCP Compliance with State Requirements, Federal
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If discharge from the treatment plant will occur in either
surface water or the municipal sewer, NPDS goals and publicly
owned treatment works pre-treatment requirements will be met.
Wetlands
Alternative No. 4M represents the alternative which results
in the least amount of wetland alteration while still achieving
the public ~ealth goals and objectives. Any wetland alternation
will be mitigated to the fullest possible extent. Wetland
vegetative damages will be remediated. This is consitant with
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-- .
Superfund Pr02ram
Holbrook - Baird & McGuire Site
DEQE/DAQC Standards Reouirements
The Division of Air Quality Control (DAQC) requires certain standards to
be met by Superfund site restoration contractors.
The DAQC will revie~ for
co~?leteness and standards compliance in three areas of this site restoration
program.
The three ph~se~ 9f interest to DAQC are:
A.
Site Excavation;
B.
Incineration of soil;
and C.
Incineration of
sludge.
1.
Pre-excavation: background air quality should be deter~ned.
DAQC
would like to revie~ test results in order to do so~e background
modeling.- resources permitting.
2.
Excavation:
.continuous air quality monitoring should be conducted.
St~jdards for particulate matter should not be exceeded.
The standards
are:
S/~~\'~WL4/Vf~
PriII:.a TV
Secondarv
annual
75 ug/m3
260 us/m3
60 (guideline)
150 ug/m3
24 hour
During excavation it is e>:pected that all necessary precau:io;ls \d.ll be
us~d to control dust, odor and noise. DAQC ~ould like to review the
...,J,e,.
dust, odor and noise prevention plan contractor will be utilizing.
I'
(310 CXR 7.09, Dust, Odor, Construction, and Demolition, and
310 Qm 7.10 t\oise attac.hed).
B.
Incineration 'of 50il
1.
Test b~rn.
DAQC would like to revie~ the test protocol for the test
burning of contaminated soil.
If resources permit DAQC staff ....ill/l ""
. ... "
- r.' ...';'
. .4"
. ,. . 0"" .
.
,-
!~
review the test report for the test burn.
The emission standards for
Hazardous ~aste Incinerators are:
a.
Destruction and Removal Efficiency (DR!) of 99;997. for each
Principal Organic Hazardous Constituent (POHG) [ref. 310 CXR
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b.
For Dioxin DR! (guideline) is 99.9999~.
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-'
c.
Fer Particulate emissions not to exceed 0.08 grains per dry
standard cubic foot when corrected for the amount of oxygen
in the stack gas.
When the waste water treatment phase of the program produces sludge,
for incineration, a separate test burn should be conducted and the
, "0 b 0 .
e=issions ~. as~ should be analyzed. A sludge disposal plan should
'fr.'tt'd d . .
be rec~ye an cont~genc~es should be provided for to deal with any
residual heavy metals.
"X
A
-r
I
The incinerator Waste should be analyzed prior to returning the
residue back, to the excavated areas.
2.
Incineration Program.
If the test burn is found to be satisfactory
the incinerator test/prototype is expected to b.e upscaled to a
full-scale incinerator.
Tne on-going incineration of conta=inated
soil should be stack tested on a continuous basis.
Toe standards in
part B.l.a;b; & c, are expected to be met throughout the complete
site
restoration program.
--;r;-
The DAQC expects to be receiving interim reports of the incineration
program.
It can be expected, since the infra-red incinerator is
innovative technology, that some design changes and modifications will
take place.
DAQC would e~~ect to be informed of these changes.
(The
proposed soil burning is planned to take five years, or more depending
upon unforeseen interuptions.)
E}~:HR::""'l
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1
,
-I
" .
,
310 C~R:
DEPART~NT or ENVIRONM::NT.&.L QUAlITY ENGINtE~ING
.
(310 CMR 4.00 through 310 eMF. 5.00:
310 CMR 6.00: AMBIENT AIR QUALITY
OF MASSACrruSETTS
RESERV'!D)
ST ANDARDS FOR THE COMMOt\WtAL TH
Section
6.01 DefirU tions
6.02 Scope
6.03 Reference Conditions
6.04 Standards
6.01:
De!iJ'Ii tions
(1) Depar-.ment
Engineering.
(2) Ambient Air means that por~on of the atmosphere, external to
b~ldii'igs, to whjch :.."Ie gene:-al public has access.
means
the
Depar-.ment
of Environmental
Qu ali ty
(3) Reference met}10d means a method of sampling and analyzing for
an . aU" poilutant. as described in t."1e Federal Register, Volume 36,
nuniber 228, Nove~er 25, 1971.
(4.) EiT..:!valent method means any method of sa.!r.pling and analyzing
fer an a.U" poLlutant which can be de::1onstrated to the Department's
satisfaction to have a consistent relationship to the reference method.
6.02:
Scooe.
(1) Pri=lary a."!lbient air quality standards define levels of air quality
wrJch the Depart:De:1t judges are necessary, with an adeqiJate margin
of salety, to protect tl'.e public health. Seconca..ry u..bient air quality
staJ"Idards define levels of air quality whJc:' the Depar~ent judges
necessary to piotect the public Io.:e!!are frem any k.."'Iown or anticipated
adve:se effec~ of a pollutant. Such standards are subject to revision,
and adCj'jo:-:al prir.1ary and secon.:ary standards roay be promuJgated as
ti:e Department deems necessary to protect the public health and
wel1are.
(2) The prnmul~at:ion of primary ~nd se':oncary a..'nbient air quality
s:c.ndards shall not be considered in any !T',anner to allow sll;niIicant
deterioraucn of exjsting air quality in any portion of the CAm.!':1on-
wealth. .
6.03:
Re!'ere:"!ce Conditions.
All measure."nents of air quality a:-e corrected to a re!e:-e:"!ce te."npera-
ture of 25°C. and to a re:e:-ence pressure of 760 millimeters of mercury
(l ,013.2 millibars).
6.04:
St~ndards
(l) ?~lr\JL.9.:..udes (sulfur djoxjde).
(a) ?n.7.arv ;'w":,,..;:);e:H All" O\.:amv Standards fer Sulfur Oxides (sulfur
di,2yjde). The primary ai:ililentaii- ~t:alJty standards for suliur ox-
iCes. measured as sulfur dioxjde by t."1e reference method described
in 40 CrR Part, 50 or by an equivalent method, are:
1. 80 microg:-:.!T1S per cubic meter (0.03 p.p.m.) annual arithme-
bc mean.
2. 365 micrograms per cubic me!er (0.14 p.p.m.) ~faxilm.~:n
24-hour concentration not to be exceeded more than once per
year.
(b) Secondarv .~_~.bjent Air QualitV Standards for SuJfur O:-ddes
Lsulfurdjox;ce). The natIonal seconcary ~J:lent all" quainy stand-
ard for sulfur oxides, :neasured as sulfur dioxide by the re!e!"ence
method described in 40 crR Part 50 is: 1-.300 microg:-a!~s .~er cubic
meter. (0.5 p.p.m.).. maximum 3-hour concentratIon not to be
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1
.
.
~
310 CMR:
DEPARTMENT OF tNV1RONME~'TAl Qt;ALITY ENGINEERING
v
"
-::::. .
.6.04:
continued
(2) ParticuJate Maner.
(a) Prur.arv .:"'~Ient Air ualitv Sunda:-ds for Part1cuJate Matter.
The prlmary ar:.blent alr qua ry stan ar s or partie ate matter,
measured by the reference meti10d described in 40 CFR Part 50, or
by an equivalent method, are:
1. 75 aUcrog:-am5 per cubic meter -- annual geomett'ic mean.
2. 260 micrograr.\s per cubic meter -- maxlmwn 24-hour concen-
. tration not 'to be exceeded more than once per year.
(b) Seconda...""" J._r:"Ibient Air QualitV S~andards for Particulate Maner.
The seconcary c..'!'.blent aU" qualiry st.a1'ldards for part1culate matter,
measured by the reference meti10d described in 40 CrR Part 50, or
by an equivalent method is: 150 micrograms per cubic meter --
ma.xi.'!1UlT\ 2~-heur concentration not to be exceeded /tIore than once
per year.
(3) P:-tmaIj' aI1d Secondarv Arr2::ie:"lt Air Qualitv Standards for Carbon
MonOXloe. The pn!I'Iary a.."Id seconoary ambient aU" cp.;aliry stanoarc:s
fer carbon monoxjde, measured by the reierence method described in
CFR Part 50, or by an equivalent method.. are:
(a) 10 milligrams per cubic meter (9 p.p.m.) -- maximum 8-hour
concenttation not to be exceeded more than once per year.
,(b) 40 rrjiligrams per cubic meter (35 p.p.m.) -- maximum I-hour
concenttation not to be exceeded lDore than once per year.
(4) ?;i:narv and Secondary ..aJT'.bier:t Mr QualitV Standards for Ozone.
The pn.'i1ary and sec::mdary ai-.51er.t aU" quality standard for ozone,
measured and- corrected for interferences due to nitrogen oxides and
sulf'Jr dioxide by the reierence meL"'Iod described in 40 CFR Part 50,
or by an equivalent meL"'Iod, is 240 mic:"oqrams per cubic meter (0.12
ppm) - and is expressed i."l a s~tistical fonn so that determination of
artair..ment will be made .,...hen tJ1e ex;.ected nU:::lber of days pel" calendar
year ,"itil max.im\.W'n hourly average concentrations above 235 ~g/M'"
(0.12 ppm) is equal to less tilan one.
(5) P;i=.ary and Seconcary ;.....nbie~t Air QualitV Standard for Hvdro-
carbc:1s. The hydroca::.c:\S stanca!'O IS for use as a giJlde U'I deVlsiJ"lg
implementation pla..ns to achieve cx.idant standards. The primary and
secondary a.m.i:.ient air qualiry s:andards for hydrocarbons, measured
and corrected for meL,ane by t..,e refere;1ce method d~sc:,ib1d in 40
eFR Part 50, or by a..n equivalent method is: 160 micrograms per
cubic meter (0.24 p.p.m.) .. ma.xi.'i11.l!:1 3-hour concentration (6 to 9
a. m.) not to be exceeded more u.an once per year.
(6) Prir:':arv and Seconc!arv .~bie~t Air QualitV. Standc.rds fc:" Nit:ocen
Dioxide. The pri::':ary and seccncary ambient air qU21lty s~ndard for
rutrogen diox.ide. measu:ed by the reference method described in 40
erR Part 50, or by an equivalent method, is: 100 Micro<;:-ar:ls per
cubic meter (0.05 p.p.m.) .. annual arithmetic mean.
(7) Pri;~ary and Secondarv Ambient Air Quality StaJ'ldards for Lead.
The pn.O'1ary and sf:concary -a..=nblen~ aU" quality standard for lead
!':':easured by the reference method described in 40 eFR Part SO, or by
an equivalenl method is: 1.5 rnicrograms per cubic meter - calendar
quarter.
REGULATORY AUTHORITY
310 CMR 6.00:
M. G. L. c. 111. s. 142 D.
~
&
.-.
i
:;
,
t-.
12/31(80
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COMMUNITY RELATIONS
RESPONSIVENESS SUMMARY
BAIRD & McGUIRE SUPERFUND SITE
HOl8iUJOlC, MASSACHUSETTS
INTRODUCTION
This community relations responsiveness summary for the Baird & McGuire
Site documents for the public record concerns and issues raised during
remedial planning, comments raised during the comment period on the
feasibil ity study, and the responses of EPA to these concerns.
The responsiveness summary is divided into the following sections:
Section I
Overview. This section
for remedial action, and the
The al ternative preferred by
section.
discusses EPA's proposed alternatives
public reaction to these alternatives.
EPA is also included in this
Section
II Background on Community Involvement and Concerns.
secti.on provides a brief history of convnunity interest
concerns raised during remedial planning activities at
Baird & McGuire Site.
This
and
the
Section
III Summary of Major Comments Received ~uring the Public
Comment Period and the EPA Responses to the Comments. Both
written and oral comments are categorized by relevant topics.
EPA responses to these major comments are also provided.
In addition to the above sections, Attachment A, included as part of
this responsiveness summary, identifies the community relations activities
conducted by the EPA during remedial response activities at the Baird
& McGuire Site.
1.
OVERY lEV
The Baird & McGuire Site encompasses the former Baird & McGuire chemical
laboratory, storage and mixing buildings, office and tank farm. The
Site itself is approximately 20 acres in size, and the plant area is
located within 1500 feet of the water supply wells for the Town of Holbrook.
These wells have been shut down permanently due to the presence of organic
compounds in groundwater samples from the wells. In addition, an underground
water main, ~hich carries drinking water to sections of Holbrook, passes
through the site. A new main is being completed to replace this main.
EPA initiated emergency response actions including removal of contaminated
soil and construction of a groundwater interception/recirculation system
in response to a breach in a creosote collection lagoon in 1983. In
1
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..
1985, EPA announced I~itial Remedial Measures 'IRM) which included the
destruction of Site buildings and the tank farm, relocation of the water
main and capping soil hot spots.
An initial (Phase I) Remedial Investigation !RI) identified contaminated
areas within the site and types of contamination which are present.
Further information regarding the extent of contamination was gathered
during the second phase of the RI. In order to assess various cleanup
alternatives, a Feasibility Study (FS) was completed. Areas of contamination
':t and near the Site were divided into zones, and combinations of technologies
were considered for the different zones. Ten alternative cleanup strategies
were developed as outlined below:
* Alternative 3 (soil excavation and on-site disposal, groundwater
containment, interception and treatment)
* Alternative 3A (more extensive soil excavation and on-site disposal,
groundwater containment, interception and treatment)
* Alternative 38 (soil excavation, incineration and on-site disposal,
groundwater containment, interception and treatment)
* Alternative 4 (soil excavation of "hot areas", incineration
and on-site disposal, groundwater interception and treatment)
* A1ternath~ 4A (soil excavation of "hot areas" and on-site disposal,
groundwater containm@nt, interception and treatment)
* Alternative 48 (capping rather than. soil excavation, groundwater
containment, interception, and treatment)
* Alternative 4C (soil excavation and on-site disposal, groundwater
containment)
* Alternative 4~ (capping rather than soil excavation, groundwate~
containment)
* Alternative 4M (soil excavation of "hot areas", incineration
and on-site disposal, groundwater interception, and treatment~
* Alternative 5 (No action)
All of these alternatives (except the no. action alternative) would also
involve relocation of an unnamed brook which runs through the site,
and construction of a flood protection levee. Citizen responses to
these alternatives centered on groundwater treatment, future water supply,
the handling of contaminated soil on-site, continued groundwater monitoring
and disclosure of test results.
The alternative which is preferred by EPA is Alternative 4M. This alternative
is based on Alternative 4. Alternative 4 proposed "hot area" excavation,
interim on-site storage, incineration and groundwater interception and
treatment. Alternative 4M does not include interim storage prior to
incineration. Through the use of incineration technology and groundwater
treatment, the present and future threats to the publ ic health, welfare
and the environment would be minimal.
II. BACKGROUND ON COMMUNITY INVOLVEMENT AND CONCERNS
. .
Public interest in the Baird & McGuire site has been high since 1982
when hearings were held to consider renewal of the company's license
to store chemicals. That interest has continued during the EPA's investigations
and removal actions. The Clean Water Action Project (CWAP) helped to
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organize a local citizens group, People United to Restore the Environment
(PURE,. In June 1985, EPA held a public meeting to explain the results
. of the preliminary remedial investigation. PURE and CWAP presented
seven demands to EPA at this meeting. To answer those demands, EPA
announced the Initial Remedial Measures to be undertaken at the site
including relocation of the water main which runs through the site.
EPA also assisted concerned citizens and officials in forming a citizens
advisory committee to review and comment on technical reports.
Questions regarding the extent of contamination at the site were unanswered
at the conclusion of the initial RI. Therefore, EPA initiated a second
phase of the remedial investigation. I)uring the second phase of the
RI, dioxin was discovered in soils at the site. This announcement prompted
heavy media coverage and intense public interest. In response, EPA
authorized emergency funds to erect a longer fence around the site and
the Massachusetts Department of Environmental Quality Engineering (QEQE)
funded the postion of Hazardous Waste Coordinator to assist in public
education and to act as a liason with government agencies.
Many concerns regarding the site and the findings of the RI were expressed
by citizens during this time. These concerns and how the EPA and State
Agencies addressed them are described below.
1.
Residents conducted an informal survey and prepared a map of cancer
incidences in the area.
EPA Response: Review of the survey results by the Masss~chusetts
~epartment of Public Health indicated no significant increase in
the incidence of cancer in 1982-83 or in adverse birth defects
or infant mortal ity from 1980 to 1984. The Massachusetts Department
of Public Health is continuing to study the problem.
2.
Concern was expressed by residents that a water main running through
the site may become contaminated.
EPA Response: Testing of the water carried through the main revealed
no contamination, however, EPA has authorized diverting the main.
This action will limit possible future exposure and ease maintenance
and construction problems which might arise during the implementation
of the final remedial alternative. EPA will continue to test the
water in the main on a quarterly basis until the new main is completed.
3.
The public is concerned over the continued problems of access to
the contaminated buildings on the site. Even though EPA erected
a fence surrounding the site, teenagers and vandals reportedly
enter the contaminated area at night.
EPA Response: EPA has authorized destruction of the site buildings
as part of the Initial Remedial Measures. The State is providing
a 24 hour guard for the site.
3
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...
III. SUMMARY OF MAJOR COMMENTS RECEIVED ~URING THE PUBLIC COMMENT PERIOD
AND EPA RESPONSES TO THE COMMENTS
Comments raised during the Baird & McGuire Site public comment period
are sunrnarized below. The public conrnent period was held from August
13 until September 8, 1986 to receive public comments and feedback on
the draft Feasibil ity Study. Also included in this summary are comments
received at an informational public meeting held August 20, 1986 and
at a publ ic hearing held September 3, 1986. The comments received during
this period are categorized by relevant topics.
A.
1.
Re8edial Alternative Preferences/ROO Reco..endations
Several citizens expressed a preference for Alternative 4M, which
is based on the excavation of "hot spots" with treatment in an
on-site incinerator. Concerns were raised regarding the lack of
a thorough risk assessment of this alternative. A comprehensive
risk assessment was requested for the final alternative chosen.
2.
EPA Response: Alternative 4M is a modification of technologies
evaluated under Alternatives 4, 4A and 38, for which detailed risk
assessments were performed as part of the Feasibility Study. The
Record of ~ecision includes estimates of risk reduction achieved
by the implementation of the reconrnended Alternative 4M. Further
characterization of the risks of thermal destruction (e.g. incineration) ,
will be performed during the Remedial Oesign. Trial burns of candidate
thermal destruction technologies and air modeling of potential
emi ss ions wi 11 be performed.
There were several suggestions that EPA should consider the use
of innovative technologies such as biodegradation in the cleanup
effort. Commenters indicated that these technologies would be
acceptable for use at the site on an experimental basis providing
the public could maintain a high level of input into the testing
and treatment process.
3.
EPA Response: Biodegradation was considered as a candidate technology
during the Feasibil ity Study and was rejected by GHR Engineering
Associates, Inc. on the basis of technical feasibil ity and rel iabil ity.
The large number of hazardous compounds present at the site and
the widespread distribution of these compounds in soils, sediments,
and groundwater were factors which precluded the use of in-situ
biodegradation. The recommended Alternative 4M includes the use
of thermal destruction (e.g. incineration) for soils, an innovative
technology. . It also includes a multi-unit process treatment ~ystem
for contaminated groundwater which does include a biological treatment
process.
Many citizens indicated that the Record of ~ecision (ROO) should
remain flexible and should include provisions for periodic review
of new cleanup methods, comprehensive monitoring systems and a
statement clarifying the role of the public as a participating
force in the cleanup program.
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"
EPA Response: The Record of Decision (ROD) is a statement of EPA's
determination of the cost-effective remedial solution for a site.
As such, it defines a conceptual framework for the remedial action.
During design this conceptual framework will be translated into
a detailed set of plans and specifications suitable for bidding.
Minor modifications can be made during the design process, but
maJor changes such as 1andfi11ing or offsite incineration rather
than the recommened onsite thermal destruction cannot be made without
amending the ROD.
Newly developed technologies which are developed with similar effectiveness
in coming years will be reviewed for applicability to this site
if the technologies selected in this ROD are determined to be ineffective
or cannot be implemented for whatever reason.
Comprehensive monitoring systems will be developed during the design
phase for inclusion in the plans and specifications. These systems
will ensure that the remedy performs as designed and that the health
and safety of onsite workers and local residents are protected
during construction and operation.
The design and construction will be carried out by private contractors
under Federal and State supervision. The public, primarily through
the Task Force, will be involved in the design process by reviewing
and commenting on the plans, specifications and other de1iverab1es
as they are produced by the design engineers. The Coll1t1un1ty Relations
Plan will be updated to cover these design phase activities.
4.
Many citizens opposed the containment-based alternatives as well
as the temporary solutions. Citizens want the site and groundwater
to be permanently decontaminated and appropriate measures provided
to protect the public health and safety.
EPA Response: The
treatment of soils
based alternatives
and effectiveness.
ROD recommends waste destruction by thermal
and mu1tiphase treatment of groundwater. Containment
were reJected on the basis of long term reliability
5.
A citizen stated that the cleanup should not subJect the community
to new and substantial risks, and that natur.a1 resources be disrupted
as little as possible.
EPA Response: EPA will monitor the remedial activities during
construction and implementation to ensure that no new or substantial
risks to the community will occur. Wetlands or other natural resources
will be restored where disrupted to result in little or no 10ng-
term pe,.manent damage.
B.
1.
Technical Questions/Concerns Regarding the Remedial Alternatives
Many citizens expressed concerns about the incineration of contaminated
soils. These concerns were related to the overall effectiveness
of this procedure, and the types of testing that will be done prior
to on-site operation of an incinerator. The need for continuous
5
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monitoring of the incineration operations, especially for volatile
organic compounds and inorganic metals, was stressed throughout
these comments.
2.
EPA Response: Thermal destruction in general is a proven technique
for virtually complete (greater than 99.99999%) destruction of
organic wastes. During the design phase, pilot scale testing of
various types of thermal destruction units will be conducted using
actual soils from the site. Testing will be performed on critical
or indicator pollutants, both inorganic and organic, to determine
the effectiveness of the particular unit. This will be based on
the ability of each unit, under various operating conditions, to
destroy the wastes without creating residual ash that must be managed
as a hazardous waste. Continuous monitoring of the thermal destruction
process during operations will definitely be required.
A citizen requested that EPA provide documentation to demonstrate
that n~ adverse publ ic health impacts will occur due to stack gas
emissions.
EPA Response: EPA will develop models and document that no adverse
publ ic health or environmental impacts will occur as a result of
incineration.
3.
A major concern of many residents is the threat to their water
supply due to the loss of the South Street well field. The public
feels that EPA should perform further investigations into water
supply issues, for example, the feasibility of using Great Pond
as a water source and reopening the Donna well for use.
EPA Response: EPA Region I will request funds in fiscal year 1987
to conduct a focused Feasibility Study on the various options available
to replace the lost South Street well field production. The scope
of the projects will be developed by EPA with input from DEQE and
local officials. The schedule for this work is dependent on reauthorization
of Superfund and the availability of funds.
4.
A citizen requested that EPA treat groundwater at the South ~:reet
wells so that these wells will be a usable water source in the
future.
5.
EPA Response: EPA cannot consider the feasibil ity of treating
the water at the South Street well field until the portion of the
aquifer beneath the Baird & McGuire site is remediated.
One citizen questioned whether water quality sampling would be
done during the hook up of the new water main.
EPA Response: Water quality sampling for the EPA's 129 priority
pollutants has been conducted on a quarterly basis and will continue
until the new water main is hooked up. Samples are taken from
the water main before it enters the site area and after it leaves
the site area to ensure that no contaminants are enteriny the water
main. To date, the water supply has been free of contaminants
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and safe to drink.
.6.
One citizen inquired about the quality of the surface water
the unnamed brook and the effect that heavy rains, seasonal
or diversion of the brook might have on its water quality.
was also expressed that the unnamed brook could back up and
other areas.
in
changes
Concern
contaminate
EPA Response: Sampling in the unnamed brook was performed by GHR
during the Remedial Investigation and the results are presented
in that document. The results showed no contamination at the time
of sampling. The analysis does not reflect changes which may occur
due to seasonal fluctuations or storm events. The brook does not
reach the Cochato River through surficial flow. It discharges
to a wetland adJacent to the site and the river. The backup of
contamination from the site is not of concern due to the fact that
the river would carry any contaminants downstream with its flow.
Due to the effects of dilution, any contaminants which reach the
river would be below detectable limits.
7.
Citizens
Richardi
result.
in order
inquired about the flow of the Cochato River into the
reserv10r and the changes in water quality which might
Commenters stated that the Cochato River should be diverted
to protect water quality in the Richardi reservoir.
EPA Response: The Cochato River has already been diverted from
the Richardi reservoir and eventually flows into Boston Harbor.
The river was diverted as a precautionary measure even though the
analytical results of water samples from the river over the past
few years have not evidenced surface water contamination from Baird
& McGuire or other sources.
8.
A citizen requested a guarantee from EPA that the Cochato River
will not be tied into the water supplied by the Richard1 reservoir.
EPA Response: The decision on whether to use the Cochato River
as a water supply source ultimately rests with the Braintree, Randolph
and Holbrook Joint Water Board and the Massachusetts DEQE. EPA
sampling to date indicates that the river water is free of contamination.
Further EPA studies of the river sediments will provide more information
regarding the risk associated with using the river as a water supply
source.
9.
Many commenters oppose the import of contaminated materials from
other locations for either storage, destruction, or treatment at
the Baird & McGuire site.
EPA Response: EPA will not accept waste from offs1te for storage,
treatment or destruction at the Baird & McGuire Site.
10.
The reliability of the current groundwater interception and recirculation
system was questioned. Concern was expressed that volatile organic
compounds released during the aeration process may not be treated.
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EPA Response: The current groundwater interception and recirculation
system is designed as a stop gap measure pending full remedial
action. The system has fulfilled its objective of minimizing the
offsite migration of contaminants in the aquifer system. Reports
by GZA Corporation indicate that the system successfully captures
85-95% of the core of the contaminant plume.
The detailed design of the groundwater treatment system will consider
the potential emission of volatile organics in the aeration process.
If determined to pose a threat to workers and/or the area residents,
air pollution controls will be incorporated into the system design.
11.
The Question was raised as to whether sources of contamination
have been detected outside of the immediate site area.
12.
EPA Response: Contamination which cannot be attributed to Baird
& McGuire was detected during the Remedial Investigation. The
Massachusetts OEQE is investigating other potential sources in
the general area.
Many citizens requested frequent testing of the water supply and
monitoring contaminant levels on an on-going basis. The type of
tests performed, frequency of testing and sampling locations used
were Questioned. It was requested that this information be made
available to the public as soon as possible.
EPA Response: See response to Question B5 for the schedule of
priority pollutant analysis and sampling locations performed under
Superfund authority. Other water supply testing and water quality
monitoring functions are performed under the Safe Orinking Water
Act's National Interim Primary ~rinking Water Regulations for Maximum
Contaminant levels (MClts) by local and state water supply officials.
Testing covers organic and inorganic chemicals, turbidity, microbiological.
radiological and aesthetic drinking water parameters.
c.
1.
Public Participation
Both the active citizen groups and concerned individuals stressed
the importance of public participation in the cleanup process.
The commenters would like to participate in the selection of the
cleanup technology, in design of the testing and monitoring plans
and in the design and construction of the chosen cleanup alternatives.
Qisclosure of all test results for public comment was also recommended.
2.
EPA Response: EPA has continually solicited public participation
during the RIfFS and IRMs and will continue to do so during the
design and construction phases of the remedial action. Full public
disclosure of all test results and other information will continue
to be the Agency's policy, with the exception of information protected
by confidential ity laws or contained in enforcement sensitive documents.
A citizen requested that EPA provide monthly public notices of
information including test results.
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EPA Response: The Agency will provide the public with information
regarding the site activities, including test results, as they'
become available.
3.
One citi!en suggested that EPA set up educational programs on the
subject of the site within the school system.
EPA Response: EPA has neither the funding nor the personnel to
set up educational programs within the school system near the Baird
& McGuire Site. We will assist local officials to the extent that
our resources allow should they decide to 1nstitute such programs.
o.
1.
Funding Issues/Financial Responsibility
Several citizens commented that cost should not be a major consideration
in choosing a remedial alternative. The thorough and safe cleanup
of the site was cited as the most important priority.
EPA Response: The extent of remedial action elected by EPA must
conform to a regulation known as the National Contingency Plan
(40 CFR Part 300). Cost is one of several factors which must be
considered in the decision making process. However, longterm effectiveness
and reliability are also major considerations. In this particular
RO~, thermal destruction was recommended over onsite landfilling
even though the cost was approximately 3-4 times greater because
it will provide a permanent remedy to contamination at the site.
2.
Concern was expressed that funding for the cleanup process may
not be available from EPA over the long term. Suggestions were
made to award the funds under the constraints of a budgetary control
mechanism or to util ize open-ended funding to address this problem.
EPA Response: Full funding for both the design and construction
phases must be authorized before a contract can be awarded to either
a design engineering firm or a construction contractor. EPA Region
I has requested design funds for fiscal year 1987 and will request
construction funds for fiscal year 1988. Availability of funds
is dependent on Superfund reauthorization.
3.
The Baird & McGuire Advisory Task Force requested that EPA allot
funds to them for consultants and support personnel. The Task
Force also suggested that a memorandum of understanding be established
with the publ ic schools in the area to provide for continued educational
efforts. O~Q citizen requested that a consultant be hired to study
the necessity of relocating the Cochato River. A citizen also
requested a technical assistant be provided to act as a liason
between the Task Force and the government agencies.
EPA Response: The existing Superfund statute does not authorize
the expenditure of funds for Advisory Task Force activities and
therefore, EPA cannot provide these funds. The rEQE is currently
funding an educational/support position on the Task Force.
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5.
E.
1.
~ecision Process
What recourse is available to the public in the event that the
final remedial alternative chosen by EPA is in conflict with the
alternative Supported by the public?
EPA Response: Given the history of public involvement in EPAts
studies at the site and the close working relationship between
the Regional Project Manager and the Task Force, we do not anticipate
public rejection of the recommended alternative. Although there
is no formal appeal process, EPA would certainly be willing to
meet with local officials and citizens to discuss the ROO and any
objections which may be expressed.
2.
. One citizen questioned who would be responsible for approving future
modifications to the final remedial alternative once it was chosen.
3.
EPA Response: The Regional Project Manager will be responsible
for ensuring that the design and construction of the remedial action
conforms to the ROQ. Should the ROO require modification, the
Regional Administrator would be the official responsible for authorizing
any such modification.
Concern was expressed over the action to be taken against the potentially ~
responsible parties (PRPs) involved in the Baird & McGuire site.
Citizens want the PRPs to be held financially and/or criminally
liable for the cleanup and damages.
EPA Response: The United States, on behalf of EPA, initiated cost
recovery actions in 1983 against the Baird & McGuire, Inc., Gordon
Baird, Cameron Baird and the Baird Realty Trust, Inc. These are
the only PRPs identified to date. A preliminary agreement has
been reached which will require the PRPs and one insurer of Baird
& McGuire. Inc. to pay a significant amount of money to the United
States. EPA will have full access to the site to implement the
remedial action and will receive proceeds from any land sales which
may take place in the future. When the final agreement is signed,
it will be released for public review prior to being final ized
in court.
..
4.
The feasibility of transferring the cleanup operations to the private
industry which is developing in the area of hazardous waste cleanup
was questioned. One citizen suggested that this option be kept
open for future consideration.
EPA Response: EPA has the authority and responsiblity under Superfund
to remediate hazardous waste sites. EPA contracts with private
engineering firms and construction companies to perform the design
and construction activities. However, the Federal government is
responsible for ensuring that the work is performed correctly since
Federa 1 funds are i nvo 1 ved .
Several citizens wanted to know which companies were involved in
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contamination of the site and which chemicals were used..
F.
1.
EPA Response: Baird & McGuire is the only company known to be
responsible for site contamination. A list of the chemicals which
were used and/or purchased by Baird & McGuire can be found in Appendix
A of the Remedial Investigation.
Oesign/Construction Phase
Several citizens stated that the design of the remedial alternative
should include provisions for reclamation of the site for future
public use.
EPA Response: The site in question is privately owned. EPA plans
to remediate the site as necessary to protect public-health, welfare,
and the environment. The final disposition of the property will
be in question until settlement with the owners is reached.
G.
1.
Background/Historical Questions
A citizen questioned who authorized digging of the Sout~ Street
wells number I, 2, and 3, and when this authorization was issued.
The reason for the location of these wells was also questioned.
EPA Response: The digging of the South Street wells was authorized
by ~~e Massachusetts ~QE and the Holbrook-Randolph Joint Water
Board. The location of the wells was chosen based on recommendations
received from consultants to the Joint Water Board.
2.
The reason for diversion of the Cochato River several years ago
was questioned. The results of testing performed at the Richardi
reservoir at the same time were also questioned.
EPA Response: The gates on the Richardi Reservoir were closed
as a precautionary measure as a result of a contaminant release
from the Baird & McGuire Site into the Cochato River. Testing
was performed in the reservoir at the time of the release. The
results did not show any contamination from the Cochato River at
the point of intake to the Richardi reservoir or in the reservoir
itself.
3.
One citizen inquired about the groundwater pumping direction and
which residential areas were using contaminated water from the
South Street wells prior to their closure.
EPA Response: The groundwater pumping at the South Street well
field induced flows towards the wells. Modeling has shown that
~roundwater contaminants from Baird & McGuire could be induced
to flow towards the wells under pumping scenarios. The South Street
well field serviced residential areas in Holbrook.
4.
The role of the Holbrook Board of Health during the site investigations
was questioned.-
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EPA Response: The Holbrook Board of Health acted as an information
source and interacted with the EPA on health issues during the
investigations.
H.
1.
Heal th Risks/Effects
Concern was expressed by several citizens regarding the possible
effects of the contamination on future generations. They urged
EPA to expedite the cleanup of the site in order to lessen the
potential health risks.
EPA Response: EPA has recommended the alternative which will remediate
the site in the shortest possible time given the complexities of
the site contamination and cleanup technologies available.
..
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APPEN~IX A
,COMMUNITY RELATIONS ACTIVITIES CON~UCTED AT THE BAIR~ & McGUIRE SITE
Community relations activities conducted at the Baird & McGuire Site
include the following:
*
U.S. EPA, Massachusetts ~EQE, NUS Corporation and local officials
met to discuss Superfund remedial action plans. This meeting resulted
in mandatory clean up and preventive measures being imposed on
Baird & McGuir.e by EPA and the Town of Holbrook (March 1983).
A Preliminary Site Assessment was released in April, 1983.
*
*
In May, 1983 EPA released a Remedial Action Master Plan.
*
Information repositories were established at the Braintree, Holbrook
and Randolph Public Libraries.
A Remedial Investigation Work Plan was developed in March 1984.
*
*
A draft Remedial Investigation for the Baird & McGuire site was
released (May 1985).
A public meeting was held by EPA to accept comments on the Remedial
Investigation (June 1985).
*
*
EPA assisted in the organization of the Baird & McGuire Citizens
Advisory Committee (July 1985). This committee has met on a monthly
basis to review technical documents and act as a liason between
concerned citizens and government agencies.
*
After the discovery of dioxin at the site EPA solicited input from
local officials and residents regarding sampling locations in August,
1985. This input was incorporated into the sampling plan.
The final Addendum to the Remedial Investigation (phase two) was
released (June, 1986).
*
*
The final Feasibility Study was released in July, 1986.
*
A fact sheet which summarized the Remedial Investigation and Feasibil ity
Study was sent to concerned citizens and the information repositories
in July, 1986.
Following the release of the Feasibility Study, a public comment
period was held from August 13 to September 8, 1986.
*
*
EPA held a public hearing to discuss the results of the Feasibility
Study and to describe the remedial alternatives that are being
evaluated (September 3, 1986). Citizen comments were also documented
,at this hearing.
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