United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPA/ROD/R01-86/020
September 1986
3 EPA
Superfund
Record of Decision
-------
TECHNICAL REPORT DATA
(PltaS6 'tad t,UtfUCtlO'U Off (ht ,tvt,U IHfort co"''''UIfIIJ
1. RI!!tOIilT NO. \2. 3. RECIPleNT'S AcceSSION NO.
EPA/ROD/ROl-86/020
4. TITL.E AND SU8TITL.& 5. RepORT DATE
SUPERFUND RECORD OF DECISION ~pnrember 30 1986
Industri-plex, MA 6. peRFoRMINC ORCANIZATION cooe
7. AuTHOR'S. 8. peRFoRMINC ORGANIZATION RepORT "'0
t. peRFORMING ORGANIZATION NAMe AND AOOl"eSS 10. pAOGI"AM eL.EMeNT NO.
i' 1. CONTI"ACT/GRANT NO
I
12. SPONSORINC ACENCY NAME AND AOOl"eSS 13. Type OF RepORT ANO PEI"IOO COvERE.':;:
U.S. Environmental Protection Agency t;'; "'''' I 1U1n Qc,..,,..,rr
401 M Street, S.W. I.. SPONSORING AGENCV cooe
Washington, D.C. 20460 800/00
15. SUPPLEMENTARY NOTES
16. A8STI"ACT
The Industri-plex site is a 245-acre industrial park located in Woburn,
Massachusetts. Various manufacturing fadl it ies operated on the site from 1853 to
1968. 0 u ring these years the site has supported manufacturers of sulfur ic acid (and
related chemicals), animal hide glue, arsenic insecticides, acetic acid, dry colors and
munitions; and producers of organic chemicals including phenol, benzene and toluenes.
Prior to 1934, waste materials appear to have been randomly disposed of over a wide
area. The wastes were used to fill lowlands, wetlands and shallow ponds, and as
construction material to build dikes and levees to contain liquid wastes. After 1934
wastes were deposited directly on top of the existing deposits and reached heights in
excess of forty feet above natural grade. The presence of hazardous substances was
detected in 1979 when the current owner of the site, Mark Ph i 11 i p Trust, began
developing portions of the site. As site development began to encroach on the buried
animal glue manufacturing wastes, a very strong and pervasive Rrotten eggR odor was
released. Despite repeated citizen cOMplaints and notices of violations issued by th~
MDQE, the Trust continued its development of the site. Portions of stockpiled wastes
sloughed off, releasing hydrogen sulfide gases to the atmosphere and toxic metals anc
soils to the pond and wetlands. Large areas of the contaminated soils are exposed at
the surface thereby allowing individuals and animals to come in direct contact \oIith
(See Attached Sheet)
17. oc:EV WORDS AND DOCUMENT ANAI..VSIS
a. OESCI'IIPTOIilS b.loeNTIFlel"S/OpeN eNoeo TeRMS c. COSA TI Field. Group
Record of Decision
Industri-plex, MA
Contaminated Media;. soil, sludge, gw,
air
Key contaminants: VQC s, heavy metals,
toluene, benzene
18, DISTRIBUTION STATEMENT 19. seCUI"ITY CL.ASS I nlu RtpoN/ 21. NO. OF PAGeS
None 244
20. secuRITY CL.ASS iT/its pagtl 22 PRice
JoJ",nc
!PA ,~'" 2220-1 (It.y, .-77)
-------
EPA/ROD/ROl-86/020
Industri-plex, MA
16.
ABSTRACT (continued)
arsenic, chromium and lead.
and toluene.
The selected remedial alternative for this site includes the following
actions. For contaminated soils and sludges: site grading; installation of
a permeable soil cover cap over certain areas; implementation of
institutional controls; water quality monitoring; and post closure
maintenance consistent with RCRA regulations. For ground water: an interim
remedy of pumping "hot spot" areas and ground water treatment to control
odors, air stripping to remove VOCs and discharge to the upgradient portion
of the aquifer; and ground water monitoring. For air: stabilization of the
side slopes of the East and West Hide Piles; installation of a gas
collection layer; installation of a synthetic membrane cap to establish
impermeability; and treatment of gaseous emissions with either activated
carbon or thermal oxidation with the final treatment selection to be decided
after the impermeable cover has been installed; implementation of air
quality monitoring program; and routine maintenance. The estimated capital
cost for the entire remedial action is $12,302,300 or $12,612,000 depending
on air treatment with annual o&M of $285,500 or $311,000 depending on air
treatment.
-------
Record of Decision
Remedial Alternative Selection
SITE:
Industri-plex
Woburn, Massachusetts
DOCUMENTS REVIEWED
I am basing my decision primarily on the following documents
describing the analysis of cost-effectiveness of remedial
alternatives for the Industri-plex Site:
o
plan for Investigation of Hazardous Waste problems: Woburn,
Massachusetts, Fred C. Hart Associates, Inc., March 1980.
o
Monitoring of Metal Content in Airborne particulates Migrating
From Mark Phillip Trust, Ecology and Environment, Inc.,
TDD No. Fl-8005-01B, December 29, 1980.
o
Amendment to the North Woburn, Massachusetts Monitoring of
Metal Content in Airborne particulates, Ecology and Environment,
Inc., TDD NO. Fl-8l04-05, May ~3, 1981.
o
Inventory and Analysis of Existing Well Data for East and North
Woburn, Massachusetts, Ecology and Environment, Inc., TDD NO.
fl-8010-03, January 9, 1981.
o
Interim Report on The Geology and Groundwater of North and East
Woburn, Massachusetts, Ecology and Environment, Inc., TDD NO.
F1-80l0-02A and Fl-8010-03A, April 3, 1981.
, 0
Evaluation of the Hydrogeology and Groundwater Quality of
East and North Woburn, Massachusetts, Final Report, Ecology
and Environment, Inc., TDD NO. F1-8109-02, June 25, 1982.
o
woburn Environmental Studies Phase I Report volume 1-3,
Environmental Assessment, stauffer Chemical Company, April
1983. '
.."
o
Woburn Environmental Studies phase II Report volume 1, Remedial
Investigation, stauffer Chemical Company, Auyust 1984.
o
Woburn Environmental Studies Phase II Report volume 2 Feasibility
Study, volume 3 Appendices 1-8, stauffer Chemical Company,
April 1985.
o
.safe Levels of Arsenic, Chromium and Lead in soils at the
Woburn Industri-plex 128 site, woburn, MA, Environmental Research
-' Technology, Inc., Document No. D242-001, July 1985.
o
Technical comments DOcument for the woburn Industri-plex 128 site
Feasibility study, Woburn, MASS, Environmental Research'
-------
- 2 -
o
Floodplain and Wetland Assessment, Woburn Industri-plex 128
Superfund Site, Woburn, Massachusetts, Volume I, Roux Associates,
Inc. and Wetland Management Specialists, Inc., July 1986.
Volume II Wetlands Assessment Woburn Industri-plex 128 Superfund
Site, Woburn, Massachusetts, Wetland Management Specialists,
Inc., July 1986.
o
o
Woburn Environmental Studies, Supplemental Report to Flood Plain
and Wetlands Assessment Study Submitted July, 1986, Stauffer
. Chemical Company and Roux Associates, August 28, 1986.
o
Industri-plex Technical Review of Roux Associate's Groundwater
Discussion Near the East Hide pile, Memo from Dave Lang to
Rick Leighton, september 10, 1986.
o
Summary of Remedial Alternative Selection
o
Responsiveness Summary
Description of selected Remedy
Contaminated Soils and Sludges
The remedial action selected for the contaminated soils and
sludges includes site grading, capping certain contaminated areas
with a permeable soil cover and the implementation of institutional
controls for all areas containing wastes to ensure the long term
effectiveness of the remedial action. Operation and maintenance
requirements will include water quality monitoring and post
closure care consistent with relevant Resource Conservation and
Recovery Act (RCRA) regulations. It is anticipated that water
quality monitoring can be accomplished using existing monitoring
wells.
Groundwater
J"
The remedial action selected for the groundwater is an interim
remedy of pumping and treating "hot spot" areas. This interim
remedy will consist of several interceptor/recovery wells
located to capture approximately eighty percent of the most
contaminated portion of the plume. Recovered groundwater will
be treated to control odors followed by air stripping to remove
vo~atile organic compounds. The treated effluent will be dis-
charged via a subsurface leaching pit to the upgradient portion
of. the aquifer. Concurrently with this action, a multiple source
groundwater response plan will be developed and implemented to
address the larger area groundwater problems. A final remedy
for on-site groundwater problems will be developed and implemented
consistent with the finding and conclusions of the multiple source
-------
- 3 -
operation and maintenance requirements will include operating
and routine maintenance of the pumping system, periodic replacement
of Hydrogen Peroxide and Ferric Chloride to keep the odor control
system functional and routine inspection of the subsurface
discharge system to ensure it is free from clogging. A monitoring
program, consistent with RCRA requirements, capable of monitoring
the effectiveness of contaminant removal from the aquifer and removal
efficiency of the treatment system will be developed and implemented.
The monitoring program will also monitor surface water quality to
ensure compliance with water quality criteria and NPDES requirements.
Air
The remedial action selected for control of air emissions consists
of stabilizing the side slopes of the East and West Hide Piles,
installing a gas collection layer, capping with a synthetic
membrane to establish impermeability and treating gaseous emissions
with either activated carbon or thermal oxidation. The Agency
has determined that either treatment system is equally protective
of the public health, welfare and the environment. The final
decision as to which treatment system will be selected will be
made after the impermeable cover has been placed and the pile
allowed to reach equilibrium. The final decision will be based
primarily on the rate of gaseous discharge and other engineering
criteria established during the Remedial Design process. The
final treat~ent decision and the basis for it will be approved
by the Regio~al Administrator in a subsequent document.
operation and maintenance requirements involve the periodic and
routine maintenance of the gas collection system and treatment
system. Routine operations include replenish~ent of chemicals,
regeneration of spent carbon as well as maintaining treatment
efficiency. Implementation of an air quality monitoring program
is also included as part of this task.
Declarations
consistent with the Comprehensive Environmental Response
Compensation and Liability Act of 1980 (CERCLA) and the National
C~ntingency Plan (40 CFR Part 300), I have determined that the
re~edial actions selected for the site areas are cost-effective
and provide adequate protection of the public health, welfare
and the environnent. The Commonwealth of Massachusetts has been
consulted and concurs with the Agency's decision. In addition,
the 'remedy will require certain operation and maintenance
activities, as described above, to ensure its continued
effe<::tiv'eness. These o?eration and maintenance activities will
be' considered part of the ap?roved action and are eligible for
Trust Fund m~nies on a 90/10% cost share basis with the State
for a period not to exceed one year. I have also determined
that the action being taken is appropriate when balanced against
the availability of Trust Fund monies at other sites.
/ /
C):'3D..Ij2,
, Date
1)tt;~V7,,~
~icnael R. Deland
Regional Administrator
EPA, Region I
J<
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SUMMARY OF REMEDIAL ALTERNATIVES SELECTION
INDUSTRI-PLEX SITE
Woburn, Massachusetts
-------
I.
II.
Summary of
TABLE OF CONTENTS
Remedial Alternatives
Industri-plex Site
woburn, Massachusetts
selection
Description
site Location and Description
Site History
III. Current site Status
IV.
V.
VI.
A. Remedial Investigation
1. soils
2. Air
3. Groundwater
Alternatives Evaluation
A. Alternatives Development, screening and Analysis
B. Development and screening of soils Alternatives
C. Detailed Analysis of soils Alternatives
D. Development and screening of Air Alternatives
E. Detailed Analysis of Air Alternatives
F. Development and Screening of Groundwater
Alternatives
..
G. Detailed Analysis of Groundwater Alternatives
community Relations
consistency with Other Environmental Requirements
VII. Recommended Alternatives
Recommended Remedial Action for Contaminated
soils
Recommended Remedial Action for Air
Recommended Remedial Action for Groundwater
VIII.
Operation and Maintenance
pages
1-5
5-10
10-21
10-12
12-13
13-17
17-21
21-71
21-23
23-26
26-48
48-51
51-59-
59-65
65- 71
71
71-81
81-97
81-91
91-95
95-97
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IX.
X.
Summary
TABLE OF CONTENTS (contI d)
of Remedial Alternatives Selection
Industri-plex Site
Woburn, Massachusetts
Description
schedule
Future Actions
Figures
Tables
Responsiveness Summary
Statement of Finding - Soils Contamination
Statement of Finding - East Hide pile
#-
pages
100
100-102
Attachment
Attachment
Appendix A
Appendix B
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LIST OF FIGURES
Figure
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15 ~
16
17
Description
Site Location Map
phase I Study Area
Phase II Study Area
Monitoring Well Locations
Contaminated Soil Deposits
Hide pile/waste Deposits
Shallow Groundwater Monitoring
Wells
Toluene in Groundwater
Benzene in Groundwater
Groundwater Recovery Alternatives
Flow schematic for Alternative GW-2
Remedial Action for Alternatives
A-3 and A-4 .
schematic for Alternative A-3
schematic for Alternative A-4
possible sources of Contamination
proposed Wetlands Area requiring
Fill under A-3 or A-4
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'TABLE 1:
'TABLE 2:
'TASLE 3:
'TABLE 4:
'TABLE 5:
'TABLE 6:
'TABLE 7:
'TABLE 8:
'TABLE 9:
'TABLE 10:
'TABLE 11:
'TABLE 12:
TABLE 13:
'TABLE 14:
TABLE 15:
TABLE 16:
T.r\BLE 17:
TABLE 18:
TABLE 19:
TABLE 20:
'TABLE 21:
TABLE 22:
TABLE 23:
TABLE 24:
TABLE 25:
TABLE 26:
TA~LE 27 :,.'
TABLE 28:
TABLE 29:
TABLE 30:
TA~LE 31:
TABLE 32:
TABLE 33:
TABLE 34:
'1'ABLE 35:
TABLE 36:
TABLE 37:
TABLE 38:
TABLE 39:
'TABLE 40:
INDEX OF TABLES
Summary of Phase II soil Heavy Me~al Analysis
Monitor well Analysis
Monitor wells with Elevated VOC Analysis
EP Toxicity Tests of soil Com~osites
Borehole Gas Emission Rates
Borehole Air Analysis
Direct sensory Evaluation of Bore Hole Gases
sensory Evaluation of Adsorbed Bore Hole Odors
Ground Water Remediation Methods omitted From Further
Evaluation
Ground Water Remediation Methods Omitted From Further
Evaluation
Ground Water Remediation Methods omitted From Further
Evaluation
Functional Analysis Matrix -- Functional Area:
Ground Water Interce~tion/Recovery
Functional Analysis Matrix -- Functional Area:
Ground Water Treatment
Functional Analysis Matrix -- Functional Area:
Ground Water Discharge
Cost com~arison of selected Alternatives From Ground
Water Functional Analysis Results
Waste De~osit and Contaminated soil/Sediment Control
Remedial Methods omitted From Further Consideration
Functional Analysis Matrix -- Functional Area:
Contaminated soils
Costs Comparison of selected Alternative From
contaminated soils Functional analysis Results
Air Emissions Methods Omitted From Further Consideration
Functional Analysis Matrix -- Functional Area: East
Hide pile
Cost com~arison of selected Alternatives From East
Hide pile Functional Analysis Results
ca~ital Cost Interce~tor Well System - Hot S~ot Recovery
Alternative GW-3
o~erating and Maintenance Costs BOD Removal System
Alternative GW-4
~a~ital Cost Heavy Metals
Ca~ital cost Heavy Metals
o~erating and Maintenance
System 110 GPM
operating and Maintenance Costs Heavy Metals Removal
System 360 GPM
Alternative 5-2
Alternative 5-3
Alternative 5-4
Alternative 5-5
Alternative 5-6
Alternative 5-7
Alternative 5-8
Alternat ive 5-9
Alternative 5-10
Alternative 5-11
Alternative 5-12
Removal System 110 GPM
Removal System 360 GPM
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TABLE 41:
TASLE 42:
.TABLE 43:
TABLE 44:
TABLE 45:
TABLE 46:
TABLE 47:
TABLE 48:
TABLE 49:
TABLE 50:
TABLE 51:
"TABLE 52:
- 2 -
Alternative S-13
Monitoring and Maintenance Costs
semi Annual Sampling and Analysis Costs
Alternative A-2
Alternative A-3
Alternative A-4
Alternative A-5
Alternative A-6
Operating and Maintenance Costs vent Gas Handling
operating and Maintenance Costs Activated Carbon System
Operating and Maintenance Costs Thermal oxidation
Summary of Alternatives, Ca~ital, 0 & M and present
Worth Costs
~.
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SUMMARY OF REMEDIAL ALTERNATIVE $ELECTION
Industri-plex
woburn, Massachusetts
I .
SITE LOCATION AND DESCRIPTION
The Industri-plex site (the site) is a 245 acre industrial park
located in woburn, Massachusetts (refer to Figure 1), an old
industrial community located approximately ten miles northwest
.of Boston. primarily known for its tannery industry at the turn
of the century, Woburn is presently experiencing an economic
revitalization with the infusion of a number of computer and
service-related businesses. The intersection of two major high-
ways, Route 128 traversing east to west and Route 93 oriented
north and south, has turned the northeastern third of the city
into a commercial/industrial area. presently, the City has
approximately 36,600 residents and is a mixture of light indus-
trial, commercial, and residential properties.
Located in the industrially zoned northeast corner of Woburn,
the site is bounded by another industrial park and the community
of wilmington to the north, while Interstate Route 93 and the
Town of Reading form the eastern border. A commuter rail line,
oriented in a north-south direction, transects the western
third of the site. commercial and light industrial/manufacturing
companies are located to the north, west and south of the site.
The Site, then owned by a developer, Mark phillip Trust, was
undergoing commercial development when the presence of hazardous
substances was detected in 1979. presently, the majority of the
Site is undeveloped~ however, two portions contain some active
businesses. TO the west of the railroad tracks eleven buildings
are. built on areas containing some degree of contamination.
Access to these buildings is via New Boston and Merrimac streets!
East of the tracks but west of Commerce Way are six buildings
constructed on areas of suspected contamination. Access to
these areas. is by Commerce Way and Atlantic Avenue. NO homes
are located~on or abut the site. The nearest residences are
located approximately three quarters of a mile to the north
along Eames Street in the Town of wilmington. TO the south,
another small residential neighborhood is located off Mishawum
Road and washington Street.
The hazardous substances problems at this site are primarily
related to more than a century of manufacturing operations.
~esults from a privately funded Responsible party remedial
investigation indicate that the major environmental concerns at
~he Site involve soils and sludges contaminated with heavy metals,
animal glue wastes emitting odors and two discrete groundwater
plumes containing volatile organics. This investigation, conducted
under an administrative Consent order, was split into a two-phasea
study. Phase I focused on the entire Site, including an area to
the north and east of Commerce Way subsquently found free of
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-2-
greater level of detail as to the extent of the problems on the
contaminated portion of the property and developing feasible
alternatives for remedying those prohlems. The Site boundaries
for the Phase I study area are shown in Figure 2 and for the
Phase II study area in Figure 3.
The Site is located in the Aberjona River valley. Woburn is
located on the Eastern Avelonian Platform of the Northern
Appalachian Mountain System. The Site is locaterl between the
Northern Boundary and Blood Bluff fault zones which divide the
greater Boston area into a series of northeast trending hlocks.
These blocks are in turn dissected by north/south trending
faults, one of which has controlled the location of the Aberjona
River Valley. The general area has a moderate relief with
occasional bedrock outcrops scattered throughout. Vertical
relief is approximately 40 feet above grade.
The bedrock at the Site is the Salem Gabbro-Diorite. At the
northern portions of the site, bedrock is exposed as knobs and
ridges throughout. Towards the south where the Aberjona River
valley is more pronounced, bedrock occurs as knobs rising
rapidly from the valley to the east and west. See Figure 4
for well locations. Depth to bedrock ranges from zero (OW-2)
to fifty feet below grade at OW-12 on the southern border of
the site. South of the site a buried valley becomes. increasingly
narrower and deeper with depth to bedrock being Ino feet at
OW-7. On the Site, the bedrock appears to be competent at
topographic highs (OW-2) and fractured/jointed in lower areas
(OW-9). Results of pumping and recovery tests indicate that
the bedrock has relatively low permeabilities yielding less than
0.1 gpm to pumped wells OW-l, OW-2, OW-3. Well OW-9 yields 1 gpm,
while OW-3 yields 2 gpm. ~ock well OW-4 yields the highest values
of 15 gpm: however, this yield was attributed to the well location
abutting a rock quarrying operation with substantial blasting.
Unconsolidated deposits immediately overlying the bedrock are
low permeability glacial till, permeable outwash sands, peat
and miscellaneous fill deposits.
~
The till mantles the irregular surface of the hedrock, being
exposed where bedrock is near the surface and virtually
non-existent at the center of the valley. The thickest deposit
of till is located at the sides of the valley (OW-5 and OW-l7)
where maximum depths are 12 feet.
Glacio-fluvial outwash deposits overlay the till with a maximum
thickness of 80 feet observed in the center of the valley near
OW-20. The investigation indicated that these outwash deposits
have a high degree of sorting and are uniform in size. sanrl/gravel
wells installed during the study indicate that this geologic
unit has a high permeability and is capable of producing
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-3-
The buried valley begins at the southern end.of the Site near
OW-14 and OW-12. Two smaller valleys or troughs are present at
~he site that merge with the buried valley. A smaller trough
trends from the area of the Woburn City Dump (northwest of the
site) through OW-ll to OW-l4 to OW-12. South of OW-l2 the
center or deepest part of the buried valley extends through
OW-l8, OW-19 and OW-20. The valley is relatively narrow immedi-
ately below the Site but doubles in width in the area south
of the Digital Equipment building (OW-l9 and TB-6). The valley
also becomes deeper to the south, away from the site.
.since the buried valley deepens and the topography is gentle,
the saturated thickness of the sand deposits becomes greater
towards the south. At OW-12, 44 feet of sand above the
bedrock are saturated with water as compared to 82 feet at
OW-20.
Peat overlays the outwash deposits. This peat originally
covered a substantial portion of the Site; however, the majority
of it has been removed as part of the Site development. peat was
encountered in many borings and test pits, and the maximum
thickness of 11.5 feet is south of Phillips pond at OW-5.
Results of the groundwater monitoring program indicate that the
area wide groundwater flows in a southerly direction into the
buried valley. However, on-site hydrology is more complex.
Groundwater on the western half of the Site as far east as the
East Hide pile flows into the buried valley near OW-17 while
groundwater found just west of Commerce way extension flows
easterly, discharging into the marshes east of Commerce Way.
Groundwater which does not intercept the marsh continues
downgradient curving slowly to the southwest until it intercepts
the buried valley down around OW-l9 and 20.
Results of the groundwater mapping indicate that a groundwater
mound exists near the center of the Site as a result of a
sharp contrast in permeabilities between an elevated oedrock
knob and th& overlying waste materials. This mound serves to
control groundwater flow locally and to keep the lower portions
of the wastes saturated.
Groundwater flow rates have been estimated to range from 1 foot
per year for bedrock to 5 feet per day for the most highly
permeable outwash materials. Flow rates between 0.2 - 1 foot
per day have been calculated for the buried valley south of
the Site.
The groundwater in the immediate area of the Site is currently
used solely for noncontact cooling water. The nearest municipal
drinking water supply wells are approximately 1.25 miles down-
gradient. These wells, wells G & H, have been out of service
since June 1979 when they were found to contain elevated levels
of volatile organics. The wells are currently listed as a separate
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-4-
for location of wells. The results of the Remectial Investigation/
Feasibility Study (RI/FS) and hydrogeological investigations of
Wells G , H indicate that the two NPL sites are hydraulically
connected. However, the same investigations also indicate that
while contaminants in the groundwater from the Industri-plex
have migrated off-site they have not impacted Wells G & H. The
source of contamination in and around Wells G & H appears
to originate from areas south of Route 12A and not from the
Industri-plex area.
Within the Aberjona River valley, surface water as well as
'groundwater generally tends to flow in a southerly direction
toward Boston Harbor. The site is not located in a base (100
years) floodplain of the Aberjona River as defined by the HUD
floodplain management maps. There are two significant streams
and several small wetlands on the Site. The Aberjona River enters
the Site from the northeast. The Aberjona crosses under Route 93
in two places: the more northerly segment enters the Site in the
northeast corner, flowing in a southwesterly direction, meandering
through a wetlands prior to discharging into an open swale that
forms the centerline of Commerce Way. The southern branch of
the Aberjona crosses under Route 93 and discharges into Phillip
Pond, an artifically created pond to provide flood storage capacity
for the proposed industrial park. The pond is located on the
southeastern boundary of the Site and discharges through an open
swale into the swale located along Commerce Way.
The other stream of concern is an unnamed brook that enters a
flood storage pond, similar to Phillips pond, created to assist
in managing surface water run-off from a newly created industrial
park abutting the Site along its northern border. The outlet of
this pond flows over a dike and spillway onto the Site creating
a shallow pond along the northern border. The pond and its
associated wetlands, 4.1 acres in size, are located between
the East and West Hide Piles, with an exposed arsenic and lead
deposit forming the southern boundary of the pond. A review of
historical aerial photographs indicates that these piles and
deposits fil~ed in a portion of the original pond and wetlands.
The outlet, of the pond forms a small brook that flows southeasterly
intersect{ng the swale immediately upstream of the Aberjona
River. Less significantly, streams found to the north and
northwest of the Site are intercepted by a narrow drainage
ditch abutting the westerly side of the railroad tracks on the
western third of the Site. The railroad tracks serve as a
surface water divide, forcing the water to flow in a southerly
direction. Several small streams, including Hall's Rrook, west
01 the Site, join this drainage ditch, ultimately passing under
the railroad tracks and entering Hall's Brook Storage Area.
Hall's Brook Storage Area, located just south of the Site, was
created by the developer to control stormwater runoff from the
industrial park. The outlet of the storage area joins the
Aberjona River just north of Mishawum Road. Refer to Figure 3
for location of wetlands and surface water flow patterns.
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-5-
AS noted previously, there are several wetlands found on or
adJacent to the Site. These wetlands are found in the northeast
and northwest portions of the site. The wetland northeast ,of
Commerce Way is approximately 11 acres in size, is uncontaminated
and would not be impacted by remedial actions taken on other portions
of the site. The previously noted wetlands and pond situated
between the East and West Hide piles will need to be addressed
as part of the remedial actions. The remaining wetland abuts
the northwest corner of the Site, is upgradient of the Site and
should not be affected by the remedial actions.
'II.
SITE HISTORY
various manufacturing facilities operated on the Woburn Site
from 1853 to 1968. prior to 1853 the property was undeveloped
land, covered forest along the northern, upland border and
wetlands and marshy swampland over the southern two thirds
of the Site.
Date I
Prior
1853
1853
to
1863
1863
to
1929
1929
1931
1931
1934
1934
1936
1961
1961
1968
1968
f)resentl
SUMMARY OF SITE OWNERSHIP
Ownership
unknown
Robert B. Eaton
Merrimac Chemical Co.
(New England Manufact-
ur ing Co. made
munitions from 1915
to 1920)
~Monsanto Chemical Co.
F + L Land Salvage
and Improvement Co.
New England Chemical
Industr ies, Inc.
I Consolidated Chemicals
Industries
Stauffer Chemical Co.
Mark Phillip Trust
Comments
natural undeveloped land
manufactured Hartshorn,
vitriol, Copperas, Glue,
Gums, Nitrates
manufactured many types of
acids, Tin crystals, oxy-
Muriate of Antimony,
Arsenical pesticides. Waste
products were arsenic, lead;
zinc, copper and mercury
Similar products to Merri-
mac Chemical Co.
salvage existing plant equip-
ment
manufacture of animal glues,
"technical gelatin"
same products as previous
owner
sarne as previous owner
industrial developer
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-6-
In February 1853, Robert Eaton purchased approximately 105
acres in North Woburn to establish the Woburn Chemical Works.
'Operations began in the summer of 1853 with the manufacture of
chemicals for the local textile, leather and paper industries.
In 1863 Robert Eaton joined three other individuals to form
a company called Merrimac Chemical Company. This company continued
to operate and expand the existing facilities.
.During the period of 1858-1890, the main products of the Merrimac
Chemical Company were sulfuric acid and related chemicals. At
. this time, sulfuric acid was the key to most chemical production,
being the intermediate for many chemicals required by the
previously mentioned industries.
In 1899, Merrimac purchased the William H. Swift Company (East
Boston), a producer of arsenic insecticides, acetic acid and
dry colors. Between 1899 and 1915, Merrimac became the leading
U.S. producer of arsenic insecticides.
In 1915, Merrimac organized a separate company, located just east
of the main plant, called the New England Manufacturing Company.
The purpose of New England Manufacturing Company was to produce
war materials, specifically munitions for World War I. Merrimac
Chemical Company supplied New England Manufacturing Company
with acid by a pipeline. New England Manufacturing produced
organic chemicals, including phenol, benzene, picric acid and
toluene and trinitrotoluene (TNT). During this period of time,
Merrimac Chemical Company also acquired the entire plant, .assets
and goodwill of the Cochrane Chemical Company of Everett,
Massachus&tts.
In November, 1929, the Monsanto Chemical Works of St. Louis
purchased and merged with the Merrimac Chemical Company.
Merrimac was allowed to retain its identity as the Merrimac
Division of Monsanto and continued to operate at the Site until
1931. By 1931 all Merrimac operations located in Woburn were
consolidated to the Merrimac plant in Everett. From 1931 to
1934, no operations were conducted on the Site. Existing
equipmen~ was salvaged by F & L Land Salvage and, in 1934, the
Site was sold to New England Chemical Industries.
From 1853 until 1929 the Site development was characterized by
numerous small buildings scattered over 90 acres. Old maps of
the Site show that these buildings were built or destroyed as
quickly as there were changes in the demand for certain chemicals.
It appears, based on a historical search and visual observations,
that waste products were disposed of randomly over the years, usually
~herever it was convenient, eithar to fill in a low spot or
out behind a building.
New England Chemical began construction of an animal hide glue
manufacturing plant on the site in 1934, and started up the plant
in Marcn, 1935. New Enyland Chemical Company was purchased by
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-7-
purChased by Stauffer Chemical Company in the early 1960's.
stauffer continued plant operation until mid-l969, when it
completed equipment removal and vacated the site.
Glue was made by extracting a protein called collagen from animal
tissue or bones with hot water. The raw materials included
raw, salted or limed hides, hide fleshings, or chrome tanned
leather scraps fro~ cattle, hogs, sheep or other animals.
Various steps were required to prepare these materials for
cooking. Once prepared, the glue stock was cooked three times
'with the resulting cooking water (containing 3-5% glue) drawn
off in order to be concentrated. The glue in the cooking water
was concentrated using evaporators followed by a continuous belt
dryer. once dry, the glue was ground up and bagged for shipment.
The material (called tankage) remaining in the bottom of the 0
tank after cooking was disposed of on-site. The tankage consisted
of wood shavings, raw products, and hide materials.
Disposal practices for the tankage and other byproducts of the
glue operations were similar to those of Merrimac Chemical
Company. on-site burial of the tankage, other solids and
the sludge from the primary waste water settling lagoon occurred
east of the plant. Frequently this entailed burying material
directly on top of materials left behind from Merrimac's previous
operations. The liquid effluent from the operation exited the
plant from the southwest corner of the building into a grease
and oil separator. The effluent then flowed into a primary
settling basin, the effluent of which was discharged into the
City of Woburn sewer line located next to the plant. over the 35
years period of operations, the waste deposits accumulated to
such an extent that large piles of hides and other wastes rising
for~y to fifty feet above grade covered a number of acres east
of the plant.
In December, 1968, the Mark Phillip Trust purchased the property
from stauffer Chemical Company. Together with land he owned
south and east of the Site, the Trust intended to develop the
property as an industrial park to be called Industri-plex 128.
The Trust. began development in the early 1970's on the southern
most section of the property, near Mishawum Road and Route 128.
This involved filling and excavating portions of the property to
facilitate sale of various parcels of property. Develo~ment
continued northward in phases until the Trust reached the southern
end of the Site in 1975. As site development began to encroach
qn the buried animal glue manufacturing wastes, a very strong and
pervasive "rotten egg" odor was released into the surrounding
~reas. The odor, characteristic of hydrogen sulfide is caused
by the anaerobic decomposition of the organic wastes. Because of
the prevailing wind direction the odor routinely impacted the
community of Reading to the east where it was known as "the woburn
Odor". Despite repeated complaints by local citizens and notices
of violations issued by the Massachusetts Department of Environmental
Quality Engineering (DEQE), the Trust continued its development,
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-8-
small.pond on the northern border of the Si~e. These two stockpiles,
or "hlde piles. as they came to be known, fllled a considerable
portion of the pond and ultimately reached dimensions of up to 40
feet high, 250 feet long and 100 feet wide.
After repeated violations of its administrative orders, the DEQE
and the Massachusetts Office of the Attorney General filed suit
in Suffolk Superior Court. At approximately the same time, the
Town of Reading filed a similar suit in Middlesex Superior Court.
These two suits were merged, and in 1977 the Court issued an
.order prohibiting the Trust from disturbing two small parcels of
land where the bulk of the remaining glue wastes were thought to
be buried. The order was only partially successful in abating
the odors since the stockpiles, especially the eastern one,
continued to generate and release substantial amounts of hydrogen
sulfide.
The State has a 16ng history of enforcement actions against the
Mark Phillip Trust's development of the property. These actions
began in August of 1969 when the developer began work without
the proper permits from the Massachusetts Department of Natural
Resources (DNR). In December, 1970, The DNR issued a permit
to the Trust: the permit acknowledged the existence of the
former Stauffer wastewater treatment lagoon and disposal area
and required that they be addressed in compliance with current
state regulations.
Federal involvement began in June 1979 when the united States
Attorney's office, on behalf of the U.S. Army Corps of Engineers
(COE) and EPA, filed suit against the Trust alleging violations
of S404 of the Federal Water Pollution Control Act which regulates
the filling of wetlands. An injunction was issued and further
development activity stopped. In support of this injunction EPA
provided the results of its soil and water testing at the Site
which showed that hazardous substances, primarily arsenic, chromium
and lead sludges, had been released at the Site. Negotiations
between the Trust and the state and federal reyulatory agencies
began and cohtinued until May,1985, when separate state and
federal Consent Decrees were approved by their respective courts.
The decrees, similar in scope, required the Trust to undertake a
series of steps, including investigations to determine the nature
and extent of the hazardous waste problems, cleaning up the
hazardous waste problems and resolving the wetland filling issues.
In exchange, the Trust would be able to develop certain pieces
of the property in order to generate enough revenue to continue
~ith the remedial investigations and clean up. Citing the inability
to generate sufficient capital, the Trust has never complied with
~e terms of the Consent Decrees.
Two response actions have been undertaken at the Site. The first,
conducted by the DEQE in November 1980 involved a sprayed
latex cover over a large exposed arsenic and lead deposit to
minimize air entrainment of arsenic and lead dust. In the
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-9-
a chainlink fence around the site to prevent unauthorized
,access to the site. A subsequent removal action was undertaken
in June 1986 to repair the existing fence.
In May, 1982, the Massachusetts Department of Environmental
Quality Engineering (DEQE) and EPA entered into a Consent
Order with Stauffer Chemical Company to undertake a Remedial
Investigation/Feasibility Study (RI/FS) and subject to certain
conditions to pay for its apportioned share of the remedial
actions. stauffer began implementing the order in the summer of
, 1982 with Phase I of a remedial investigation and completed the
RI/FS process in April 1985 with the submission of the phase II
RIfFS. These documents serve, in part, as the basis of this
ROD.
AS briefly noted previously, the waste products resulting from
115 years of industrial activities were randomly disposed of On-
site. prior to 1934 it appears that waste materials were
disposed of over a wide area, encompassing all the property
owned by Merrimac Chemical Company west of the current location
of Commerce way, including the property west of the railroad
tracks. It appears that the wastes were used for two purposes:
the first was to fill lowlands, wetlands and shallow ponds in
order to provide more useable land on which to locate new
processes. The second use was as a construction material used
to build dikes and levees to contain liquid wastes in a particular
area.
After 1934 and for the remainder of industrial operations, the
disposal of waste products was more limited to areas east and
southeast of the main plant. These wastes were deposited
directly on top of the existing deposits and reached heights in
excess of forty feet above natural grade. As the Trust began
development on the site it removed unsuitable material left
behind by the previous operations, including waste deposits.
This unsuitable material was either trucked off-site to a private
landf ill to .be used as cover material, placed under the Boston
Edison Right of Way (ROW) south of the site or stockpiled on
a second Boston Edison ROW on the northern border of the Site
impinging on a shallow pond and wetland.
presently the Site is a mixture of developed and undeveloped
parcels of land containing the waste products of the former
industrial operations. These deposits remain either as they
were initially placed or as relocated to another location on the
Site to facilitate site development. site investigations indicate
that under existing conditions the site continues to release
'-contaminants to the environment and poses a significant potential
for the continued release. sampling data indicate exposed arsenic,
chromium and lead deposits are continuing to be transported to
the area surface water and wetlands found on site. While this
finding does not appear to be presently impacting, to a significant
degree, the water quality, these toxic metals will continue to
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-10-
term environmental problem. The East and West Hide piles because
of slope stability problems continue to slough off substantial
portions of the piles, releasing hydrogen sulfide gases to the
atomsphere and toxic metals and soils into the pond and wetlands.
Large areas of the contaminated soils are exposed at the surface
thereby allowing individuals and animals to come .in direct contact
with arsenic, chromium and lead. Despite repeated attempts to
exclude people from coming in contact with these metals, evidence
suggests that individuals are routinely exposed to elevated levels
of heavy metals resulting from their unauthorized presence on the
.S i te.
I I 1.
CURRENT SITE STATUS
pursuant to a Consent order CERCLA S 106, Stauffer Chemical
Company conducted a two phased RI and an FS for the Site, as
shown on Figure 1.
A.
Remedial Investigation
Results of the
the nature and
and receptors,
during the FS.
RI characterized current site conditions, defined
extent of contamination, identified the pathways
and identified remedial alternatives for evaluation
Phase I af the RI was designed to determine the types of
contaminants present, their areal extent and the environmental
media impacted. It entailed sampling the entire site and
determined that the majority of the waste problems were contained
on the western half of the Site. The area to the east of the
proposed extension of Commerce Way contained none of the metals
or hide deposits.
The Phase II investigation focused in greater detail on the area-
containing the wastes and documented the presence of approxi-
mately one million cubic yards of contaminated soils and sludges
deposited over a hundred acre area. This material tends to be
deposits co~taining arsenic, lead, zinc or copper derived from
Merrimac Chemical's operations. The RI established that these
materials reach a depth of eight feet below grade and that
approximately fifteen percent of these materials were within
the saturated zone. Materials generated during the glue manu-
facturing operations produced wastes containing elevated levels
of chromium and organic material such as leather scraps, hair
and fleshings. originally, this material was deposited
east of the Stauffer Chemical plant, directly upon the previous
waste deposits. This material reached substantial heights
~bove grade. However, as a result of recent Site development,
much of this material was redistributed throughout the site,
as well as some of it being transported off-site. Currently
the bulk of this material is contained in four discrete areas
on-site, with heights exceeding thirty feet above grade.
Results from the RI indicate that some of these sludge deposits
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-11-
and surface water. sampling results of the surface water
indicate that the present impact from these deposits are below
applicable standards. Groundwater results indicate sporadic
levels above drinking water standards: however, the impacts of
the deposits on groundwater appear to be localized. During
Phase II, however, two plumes of groundwater contaminated with
benzene and toluene were discovered. The toluene plume originates
just northeast of the intersection of Commerce way and Atlantic
Avenue. This plume is the only contaminant found east of
Commerce Way. The benzene plume appears to originate on the
"southern side of Atlantic Avenue between 10 and 20 Atlantic
Avenue.
As previously noted, the Site is located in a highly industrialized
area of the City. within the Industri-plex park itself, over
sixty companies employ over 4,000 people. Within a half mile
radius the numbers swell to over 200 businesses and 10,000
employees. The closest residential neighborhood is roughly
three quarters of a mile to the northwest of the site. The RI
identified the potential pathways of contaminant migration
as surface water, groundwater, air and direct contact with
contaminated soils. The RI determined that soils presented
two potential threats to receptors. The primary threat from
soils was a direct contact threat to individuals traversing
the Site. These individuals would either be from the industrial
parks or more likely, persons who use the Site for recreational
purposes, despite repeated attempts to restrict site access.
The second potential threat from soils, a less significant
one, was the off-site migration of toxic metals via surface
waters resulting from either direct contact of the deposits
with the surface waters or run-off from a storm event. Surface
waters flowing off-site pass Wells G and H and ultimately
discharge into the upper Mystic Lakes, a recreation area.
Results from previous studies and the RI indicate that the
prevailing wind direction is from the northwest, toward the
east, southeast. Odors originating on-site tend to impact the
east, southeastern portions of the industrial park and the
western bord"er of Reading, where approximately 5,000 people
live. Re~idents of this neighborhood were the primary reci~ients
of the odors during active Site development and as a result
logged the most compliants with the DEQE.
presently the groundwater leaving the Site is utilized solely for
non-contact cooling water by several downgradient companies.
It is not used for a potable water supply. Separate studies
evaluating existing land-use patterns and aquifer characteristics
indicate that the aquifer immediately downgradient of the Site
~ould be unsuitable for use as a municipal water supply, given
current regulations. Further downgradient, the aquifer was
used as a potable water supply by the the City of woburn.
Woburn Wells G and H withdrew ground water from the aquifer
underlying the Aberjona River. These wells were abandoned in
May 1979 when they were found to be contamina~ed with volatile
organic chemicals.
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-12-
The RI/FS identified three areas requiring remedial actions:
o soils:
Approximately one hundred acres contained levels of
arsenic, chromium, or lead above background values.
These soils were determined to pose a direct
contact threat.
o Air: Air emissions from the East Hide pile contained
hydrogen sulfide gas creating a substantial odor
problem.
o Groundwater: Two groundwater plumes, one contaminated
with benzene and the other with toluene,
potentially impact the Wells G & H aquifer.
1 .
Soils
The RI verified that the majority of the hazardous wastes
problem, at the Site resulted from the presence of soils and
sludges contaminated with toxic metals. The RI determined that
these metals posed a direct contact threat to the public health
and environment. While substantial quantities of zinc, copper
and, to a lesser extent, mercury were detected, the primary
metals of concern were arsenic, lead and chromium. In addition
to the toxic metals, the organic materials such as hair, leather
scraps and fleshings resulting from the glue manufacturing
process are of concern. These organic material deposits release
obnoxious odors when disturbed and the leachate discharges
from the deposits adversely impact general water quality
because these materials have a significant Biochemical Oxygen
Demand (BOD).
Lead was the most prevalent contaminant of concern found on
Site. Levels of lead ranged from background values (10 parts
per million (ppm)) to a high of 54,400 ppm, the average value
being 1,263 ppm. In most instances, where elevated levels of
lead were detected arsenic levels were elevated also. This is
the result of the manufacture of lead arsenate insecticide.
Values for arsenic ranged from less than 10 ppm to 30,800 ppm,
the average concentration being 288 ppm. Elevated levels of
lead and arsenic were found on a total of approximately 57
acres. Approximately half the 57 acres contained values in
excess of 1000 ppm. Figure 5 shows the approximate areal
extent of the lead and arsenic contamination.
Both lead and arsenic have long been associated with significant
Tong term health effects. The primary route of exposure to
these metals at the Site is soil ingestion: however, skin
contact and inhalation are also of concern. Lead poses a
hazard to reproduction and exerts toxic effects on pregnancy
and the fetus. Evidence suggests that lead has a toxic effect
on the brain, central nervous system, the kidneys and hematopietic
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-13-
lead encephalopathy and in severe cases permanent brain damage.
Lead has been particularily associated with detectable learning
disabilities in children exposed to relatively low levels.
Arsenic is a human carcinogen causing skin tumors when it is
ingested and lung tumors when inhaled. Arsenic has also been
linked to chromosomal damage in humans as well as animals. An
increased incidence of multiple malformations has been documented
among children born to women occupationally exposed to arsenic.
.Chromium in soils and hide deposits was the other major contami-
nant of concern. These wastes, associated with the disposal
of glue manufacturing wastes, were detected above background
levels on approximately thirty five acres. Chromium values ranged
from background (less than 10 ppm) to a hiyh of 80,600 ppm (average
718 ppm). Approximately half of the 35 acres of waste contained
chromium values in excess of 1000 ppm. The RI indicates that
elevated values of chromium are typically found in areas of
hide deposit disposal or in the chrome lagoon area. Hide
deposits, the source of the obnoxious odor, were confined to
approximately 13 acres. Figure 6 depicts the hide deposit areas
and the areal extent of wastes with elevated chromium values.
The health impacts of chromium are very dependent on its
oxidation st~te. Hexavalent chromium has a greater adverse
health impact than the trivalent form of chromium. Hexavalent
chromium salts are found carcinogenic in laboratory animals
and cause excess cases of lung cancer in workers occupationally
exposed. Hexavalent chromium causes DNA and chromosomal damage
in animals and humans. In addition, hexavalent chromium impacts
the kidneys and to a lesser extent, the liver. Hexavalent
chromium in the environment quickly reduces to the less toxic
trivalent. The primary health effect associated with trivalent
chromium is contact dermatitis in sensitive individuals. The
RI/FS did not detect the presence of hexavalent chromium at
the site.
2.
Air
..-
The Site's impact on the surrounding air quality has historically
been one of the major concerns associated with the site. The
odors emanating from the Site have been the source of much
discussion and input from the surrounding community. Initially
there was concern about the potential for particulates containing
hazardous metals becoming entrained in the air of surrounding
neighborhoods and fear of health hazards associated with the
obnoxious odor resulting from the disturbance of hide waste
-depos its.
prior to the RI, the Agency's Field Investigation Team (FIT)
conducted an air emission survey for particulates containing
metals. The survey concluded that the exposed metals deposits
were not being entrained in the air and therefore were not
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-14-
as part of the RI health and safety plan also indicated that
airborne particulates are not a problem.
The RI investigation of potential air impacts focused on locating
and characterizing areas of potential air emissions, specifically
odors. The Phase I investigation identified four areas containing
buried glue manufacturing wastes that were actual or potential
sources of odors. These are the East, West, East-Central and
South Hide Piles. 'Phase II of the RI used several analytical
techniques, as well as an odor evaluation panel to characterize
the type and strength of the odors being emitted from each of
the four waste areas.
The Phase II investigation used a' field screenin9 technique,
called Bar hole sampling, to delineate potential sources of
odors. Areas so identified were subjected to additional investi-
gation. Air samples were collected by driving a steel bar two
or three feet in the ground's surface to establish a temporary
hole, inserting one end of a plastic sampling hose into the
hole, and attaching the other end to a combustible gas meter
and a hydrogen sulfide (H2S) meter connected in series.
using a calibrated pump, a sample of air was withdrawn from
the bar hole, passed through the meters and exhausted to
the ambient air. Hydrogen Sulfide values were recorded in ppm
and combustible gas as a percent of total gases measured for
each hole.
Results of the Bar hole sampling indicate that each area
identified as containing glue manufacturing wastes had detectable
levels of combustible gas and H2S, and therefore had the
potential for emitting odors. The sampling identified the East
Hide Pile as the area with the greatest potential for being a
major odor source. All readinys collected from the East Hide
Pile had levels that exceeded the upper detection range of the
instrumentation.
The majority of samples collected from the West Hide pile were
at the lower~detection limit of the instruments: however,
areas wit~ elevated readings similar to those found in the
East pile were found widely scattered throughout the pile.
In these areas, values fluctuated wildly, with results ranging
from not detectable to exceeding upper limits in bar holes less
than three feet apart. These findings indicate that either the
material deposited in the West pile is different than that of the
East pile or that the physical composition of the pile controls and
limits the potential odor emissions.
The results of the Bar hole analysis indicate that four discrete
areas within the East central Hide deposit have elevated levels
of combustible gas and H2S. These areas received additional
investigation. The South Hide pile, located east of the Chromium
Lagoons produced only one small area with elevated levels.
In addition to the four known hide deposit areas, the RI
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-15-
Areas owned by Anthony S. Femmino, Mary E. Fitzgerald and
John J. Mulhern/Michael A. Howland, woodcraft supplies and"
Boston Edison Electric Company Right of Way (ROW) number 9 all
exhibited values in excess of 50 percent combustible gases and
250+ ppm of H2S. samples on the Mary E. Fitzgerald and John
J. Mulhern/Michael A. Howland property and Anthony S. Femmino's
property were severely limited due to asphalt pavement.
Based on a knowledge of the site and results of the Bar Hole
sampling, stauffer installed seventeen four inch diameter bore-
holes to determine the quality and quantity of gases being
"emitted from the various deposits. Table 5 summarizes the
generation rates of gases being emitted while Table 6 displays
the chemical characteristics of the emissions. The conclusions
reached by this program are:
- The East and West Hide piles are the only
releasing gases. Gas generation rates vary
borehole. The borin~s located within other
exhibit gaseous release.
locations actively
from boreho le to
areas did not
- Similarily, hydrogen sulfide readin;s vary considerably
between boreholes. The methane gas tends to diffuse through
the soil and decrease in concentration over distance, while
the hydrogen sulfide appears to collect and stay within a
narrowly defined area.
- While hydrogen sulfide and methane gases are the two primary
constituents of concern, several other compounds were
identified durin~ the VOC analysis. These compounds are in
substantially (order of magnitude) lower concentrations than the
hydrogen sulfide.
- The gas release rates from the boreholes totalled 1.82
Standard Cubic Feet per Minute (SCFM) and 0.65 SCFM for the
East and West Hide pile, respectively.
-.
The final po-ase of the air sampling involved characterizing the
odors emanating from the site. Duriny active site development,
odors resulting from the disturbance of the animal glue manu-
facturing wastes pervaded the surrounding industrial parks and
the neiyhorhood immediately east of Route 93. These odors
adversely impacted the surrounding community and produced
numerous complaints to the DEQE, as well as several lawsuits
attempting to eliminate the odors by stopping development.
Odors cause a special problem to regulatory agencies because
the human nose can detect odors in the parts per trillion
range while the most sensitive analytical instruments are only
capable of detecting in the parts per billion range. AS a
result, the Arthur D. Little Company (ADL) odor evaluation
team was retained to conduct an odor survey. Results of their
findings are highlighted below and summarized on Table 7.
For each borehole the odor evaluation team determined the
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-16-
to a threshold level where each member of the team was still
able to barely detect the odor, the number of dilutions required
to reduce the odor to varying qualitative judgments as to its
intensity, termed total intensity of aroma (TIA), and the primary
characteristics of the odor. The odor team suggested that the
dilution TIA is an indicator of complaint/intensity of odor.
using information gathered during this effort the odor team
concluded:
Hydrogen sulfide was the characteristic odor of concern.
The East
seven of
quantity
odors to
Hide pile was the primary source of odors, with
the fifteen boreholes producing odors in sufficient
to require up to a million dilutions to reduce the
the detection level.
The remaining piles, West, East-Central and south, were not
significant contributors to the odors detected on-site.
The EA evaluated the acute and chronic risks associated with
volatiles potentially being emitted from the animal glue
manufacturing waste deposits. Hydrogen Sulfide, Mercaptans,
Benzene and Toluene were the compounds of interest. Of these
compounds, H2S was determined to be the indicator compound.
H2S is primarily a respiratory irritant. In high concentrations
(500-1000 ppm) H2S acts primarily as a systemic poison, causing
unconsciousness and death through respiratory paralysis. In
lower concentrations (50-100 ppm) H2S acts primarily as a
respiratory irritant. A literature review indicates that
pulmonary edema and bronchial pneumonia may follow prolonged
exposure at concentrations of the order of 250-600 ppm. At low
concentrations (5-100 ppm) H2S effects the eyes, with conJunctivitis
being the most common effect.
The RI found that in the breathing zone vicinity of the waste
piles, H2S was at nondetectable levels (less than 0.5 ppm).
However, for the purposes of calculating a potential exposure to
hide pile ewissions a value of 0.5 ppm H~S was assumed. Based
on the relative concentration ratios derlved from borehole air
measurements, the ambient air directly around the waste piles
should contain no more than an average of 5 ppb of total
mercaptans and 5 ppb of total aromatic compounds (benzene,
toluene). Based on these assumptions, the EA determined that
air emissions from the hide deposits would not adversely impact
the public health if the no action alternative was selected.
3.
Groundwater
The RI investigated the potential for on-site materials to
adversely impact the local and regional groundwater. Initially,
fifteen monitoring were installed and sampled during Phase I
of the RI. An additional nine wells were installed and sampled
under the second phase. Locations of these wells can be found
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-17-
The aquifer underlying the Site is currently not used as a
potable water supply; however, several nearby companies do
extract groundwater for non-contact cooling water purposes.
The closest potable water supply was Wells G & H approximately
one and a half miles downgradient. These wells have been unused
since 1979 as a result of contamination from chlorinated
volatile organics. The Wells are currently listed on the NPL
as a separate site.
The RI determined that the Site is located over the upgradient
, portions of the Aherjona River aquifer. This determination was
based on data collected as part of the Site groundwater monitoring
plan as well as a review of the regional geology and ground-
water characteristics. Groundwater flow northeast and
upgradient of the pond located between the East and West Hide
Piles tends to discharge into the pond, while groundwater to
the north, northwest of this ponct flows in a southeasterly
direction until it intercepts the buried valley that lies
just east of and parallel to the railroad tracks. Groundwater
directly south of the pond discharges directly into the previously
noted buried valley. Groundwater located to the east and
southeast of the pond, because of a bedrock high, tends to
flow to the southeast prior to arcing in a southwesterly
direction, joining the buried valley south of the Site. The
groundwater leaving the Site continues to flow in a' southerly
direction, ultimately moving into the aquifer underlying
Wells G and H. It appears, based on limited data, that some
porti~n of the groundwater discharges to the surface water at
Hall's Brook Storage Area.
Groundwater samples collected during Phase I and Phase II RI
were analyzed for metals and priority pollutants. Results from
the RI are briefly su~marized in the following paragraphs.
During the Phase I sampling, wells OW-5, 0W-7, OW-9, OW-l2,
and OW-14 produced results above the drinking water standards
for metals. With the exception of OW-l2 where 54 pph and l2n
ppb of chromium was detected in Phase I and II respectively,
the elevatea' levels in these wells were not replicated in
Phase II.., Analysis of groundwater for metals in Phase II
indicated that wells OW-12, OW-l3, OW-l6, OW-17 and 0W-20A
each contained one metal above drinking water standards.
Wells with Metals exceeding Drinking Water Standards
for Phase I and Phase II sampling rounds (ppb)
OW-7
I 2~:s\n:: I I L\a~I I ihr\mi~m I iadli~~ t
I 420 \ ND \ 120 ! ND \ \ I \ ~
Well
OW-5
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-18-
Wells with Metals exceeding Drinking Water Standards
for Phase I and Phase II sampling rounds (ppb) cont'd
Arsenic
Lead
Chromium I
Cadmium
Well I II I II I II I II
OW-12 54 120 11 ND
OW-13 ND 120
OW-14 74 ND
OW-16 100
OW-17 70
OW-20A 106
As evidenced by the table above, metals in ground water were
found sporadically in the monitoring wells. Despite these
sporadic positive results, the RI concluded that the metal
deposits found on-site posed only a localized impact and that
the general off-site groundwater quality was not impacted
sufficiently to warrant remedial action. This conclusion
was based on several observations. First, the majority of the
wells with elevated levels were wells either drilled through
known waste deposits or located immediately downgradient of a
deposit. Secondly, the metals of concern are relatively insoluble
in groundwater at the pHS found at the Site, therefore they
tend not to leach. This fact is verified by the results of
the EP Toxicity testing performed on a number of samples.
Sample results indicate that all values were below the accepted
level of fifty times the drinking water standards. For those
limited amounts of metals which do leach out, they quickly
precipitate, attenuating on the s011 matrices, thereby producing
a localized Fondition. As a result, the RI concluded that
actions taken to remediate groundwater contaminated with
toxic metals was unnecessary. With respect to groundwater
contamination not associated with metals, phase I sampling
indicated that virtually every monitoring well including those
upgradient or laterally to the site contained trace levels of
organic compounds. In addition, Phase II sampling during the
RI did discover two discrete plumes containing volatile organics
(.benzene and toluene) emanating from the Site as well as low
levels of volatile organics, different than those found on-site,
~ntering the Site from sources upgradient.
In the Phase II (1983) monitoring program, significant
concentrations of benzene, toluene and several other priority
pollutants, not previously detected in phase I, were discovered
in four wells, OW-12, OW-14, OW-16 and OW-17. As a result,
four additional permanent wells, OW-19, OW-19A, OW-20 and
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extent of downgradient migration. In addition to the four
permanent wells, sixty-one temporary monitoring wells were
installed upgradient and downgradient of OW-16 and OW-12 to
characterize the areal and vertical extent of contamination.
A review of historical information and a search of City records
for possible underground storaye tanks was also conducted as
part of the RI. The RI failed to produce any information as
to the probable origin of the contamination; however, it
concluded that the'plumes are limited in extent and there were
three possible source areas for the toluene: 1) upgradient of
'SD-4 on the east flank of the hide burial ground; 2) upgradient
of OW-16, just north of the intersection of Commerce Way and
Atlantic Ave.; and 3) on the southwest flank of the hide burial
ground near SD-46. The source of the benzene is in the developed
area just south of Atlantic Ave. Results of these additional
investigations are shown in Figures 7, 8 and 9.
The RI focused on the Site specific groundwater problems and
did not attempt to identify the other possible sources of
either the upgradient or adjacent groundwater contamination;
however, preliminary investigations in the general area of the
site prior to the start of the RI indicate that a number of
potential problems exist. Results of these surveys indicate
the following:
o
AS a result of a 10ng history of industrial develo~ment in
the general area, there are numerous potential contaminant
sources impacting the groundwater.
o
The City of Woburn landfill, located adjacent to the
northwest corner of the Site, is hydrologically upgradient
of the Site. several groundwater investigations have been
conducted in relation to the landfill, indicating a leachin~
problem. Because the landfill is regulated under the state's
solid waste regulations, the DEQE has ~rimary responsibility
to resolve problems associated with the landfill. The City
is cu;rently attempting to comply with all the DEQE's
requirements.
o
To the north of the Site, bordering either side of the
railroad tracks, are several active industries currently
under state orders for remediating groundwater problems
caused by their operations.
o
Other potential groundwater impacts include two active
barrel reclamation operations and two major trunk sewer
lines paralleling the railroad tracks. These sewers
receive industrial wastes and are known to have
exfiltration problems.
o
In addition to the above noted problems, the general
area experiences an unusually high traffic load as a
result of the numerous small companies located throughout
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increase the potential for an accidental spill. In
areas presently undeveloped, evidence of unreyulated-
disposal exists, such as cans, boxes, household trash
and used motor oil.
The RI evaluated, as part of the EA, the potential impacts to
the public health and environment from groundwater containing
benzene, toluene, arsenic, lead, cyanide, zinc, di(ethylhexyl)
phthalate (DEHP) or total phenols. The calculations found in
the EA are based on the impacts to Wells G and H, an actual
-receptor point, though not one currently in use. Current
agency guidance requires the EA to evaluate potential impacts
on the nearest receptors, (i.e., groundwater immediately
off-site). For the purposes of identifying the compounds of
concern, the assessment as outlined in the EA will be sufficient.
From the EA conclusion that impacts at Wells G and Hare
unacceptable one can conclude that impacts immediately off-site
will also be unacceptable.
The RI used a two dimensional groundwater flow model to
calculate concentrations of contaminants that would reach Wells
G and H. The RI used the maximum concentration found for each
contaminant as input into the dispersion formula calculations.
The calculation assumed that dispersion was the only factor that
would limit the concentrations from ultimately reaching Wells G & H.
The precise risks created by off-site groundwater contamination
are discussed in the EA and include carcinogenic and non-
carcinogenic effects.
The EA assumed that no attenuation of the contaminants would
take place. Results from the model are noted below:
Concentrations of Contaminants reaching wells G & H
(ppb)
Compound Conc. ~ wells Applicable Standard
Arsenic " 7-13 50 (1)
Lead 2.5 50 (1)
Zinc 1800 5,000 (1)
Cyanide 0.3
Benzene 5-10 6.7 ( 2)
Toluene 35 14,300 ( 3)
DEHP 0.1
phenols 140 3,500 ( 3 )
(1) Drinking Water Standards
( 2) SNARLS leve 1
(3) Human Health protection Criteria
As result of the EA, the RI determined that benzene was the
contaminant of concern, and would require remedial action to be
protective of the public health. The potential health effects
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portions of this section.
IV.
ALTERNATIVES EVALUATION
The overall objective of the remedial actions at the Site is
to effectively mitigate and minimize threats to and 'provide
adequate protection of public health, welfare and the environment.
Specifically, the FS evaluated alternatives which addressed the
following three remedial objectives:
1.
Protection of the public health and surface waters from
direct contact exposure to soils/sludges contaminated with
elevated levels of arsenic, lead and chromium.
2 .
Protection of the public health, welfare and environment
from the contaminated soils, odors and leachate in or
emanating from the East Hide pile.
3.
protection of the public health and environment from
groundwater contaminated with benzene and toluene.
A.
Alternatives Development, Screening and Analysis
Pursuant to S 300.68 (f) 74 alternatives were developed for
possible application at this Site. Each alternative was screened
with the criteria set forth in S 300.68 (g). Waste characteristics
and general Site conditions permit the application of discrete
remedial alternatives to each environmental problem, much like
a series of operable units. For example, a discrete set of
remedial alternatives to address the direct contact problems
associated with the contaminated soils was developed and screened.
Similarily, sets for air and groundwater actions were also
developed. Remedial alternatives to abate any potential impacts
to surface waters were incorporated as part of other media's
actions. With the exception of the pond and wetlands between
the East and West Hide piles, surface water actions were
addressed a. part o( the soils evaluation. For the pond, its
remedial action was incorporated into the evaluation of the
East Hide. pile alternatives, referred to as the air alternatives.
As a result, the development of alternatives and initial screening
are listed by type of media being addressed.
The FS developed and screened a number of classes of alternatives
that are based on similar technologies. Because of these
similarities, these technologies provide the same relative
benefits and problems, and therefore the FS screened these
~lternatives as classes instead of discrete alternatives.
For example, all stabilization/solidification technologies were
~creened as a group.
Section 300.68 (g) specifies three broad criteria, cost,
acceptable engineering practices and effectiveness, to be
applied to the list of alternatives. In applying the cost
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alternative. In the majority of cases, differences in costs
.were not the reason for rejection of an alternative.
The remaininy two criteria, acceptable engineering practices
and effectiveness are less quantifiable and more dependent on
experience and judgment. The nature of the hazardous waste
problems and general site conditions permit a wide range of
potential alternatives to be considered. When viewed in light
of the remedial objectives, however, a number of these
alternatives were excluded during the initial screening.
The remedial alternatives not eliminated during the intial
screening were retained for a detailed evaluation consistent
with 40 CFR Part 300.68(h) which requires that the following
factors, as appropriate, be considered:
( i )
( i i )
( i i i)
( i v)
(v)
(v i )
Refinement and specification of alternatives in detail,
wi th emphas is on use of estab 1 ished technology.
Innovative or advanced technology shall, as appropriate,
be evaluated as an alternative to conventional technology.
Detailed cost estimation, including operation and
maintenance costs, and distribution of costs over time:
Evaluation in terms of engineering implementaiton,
reliability, and constructability:
An assessment of the extent to which the alternative is
expected to effectively prevent, mitigate, or minimize
threats to, and provide adequate protection of public
health and welfare and the environment. This shall
include an evaluation of the extent to which the
alternative attains or exceeds applicable or relevant
and appropriate Federal public health and environmental
requirements. (Where the analysis determines that
Fede~al public health and environmental requirements are
not applicable or relevant and appropriate, the analysis
shall, as appropriate, evaluate the risks of the various
exposure levels projected or remaining after implementation
of the alternative under consideration] :
An analysis of whether recycle/reuse, waste minimization,
waste biodegradation, or destruction or other advanced,
innovative, or alternative technologies is appropriate
to reliably minimize present or future threats to public
health or welfare or the environment:
An analysis of any adverse environmental impacts, methods
for mitigating these impacts, and costs of mitigation.
For ease of reading, each environmental problem identified in
the FS will be discussed separately. Beginning with soils,
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by the detailed analysis for that particular problem.
For each alternative evaluated under this section a brief
summary of whether the alternative meets or exceeds applicable
or relevant and appropriate Federal public health and environment'al.
requirements will be included in the narrative. For a more
detailed analysis of the applicable or relevant and appropriate
requirements the reader is referred to the section labeled
Consistency with Other Environmental Requirements.
.B.
Development and screening of Soils Alternatives
The RI determined that there exists a potential for the public
to come in direct contact with soils contaminated with arsenic,
lead or chromium. The RI also identified areas where these
soils were in contact with surface water or wetlands. Under
adverse conditions, these deposits could impact the environment.
The FS evaluated a number of alternatives to abate the direct
contact problems associated with the metal deposits. Listed
below are the remedial alternatives developed for the initial
screening for the soils problem.
SOILS ALTERNATIVES
No Action
Infiltration control
Regrade and revegetate contaminated areas to promote
site drainage.
Regrade and cap contaminated areas with clay material.
Regrade a~ cap contaminated areas with a synthetic liner.
Regrade and cap contaminated areas with an asphalt cover.
Removal/Consolidation
Excavate contaminated areas to depth of water table with off-
site disposal.
Excavate contaminated areas to depth 6 inches below visual
detection, with off-site disposal.
~
Excavate contaminated areas to depth 6 inches below visual
detection, consolidate between East and East central Hide
piles, and cap.
Excavate contaminated areas to depth 6 inches below visual
detection, consolidate around East-Central Hide pile, and
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Excavate contaminated areas to depth 6 inches below visual
detection, consolidate between East and East-Central Hide
piles, and cap.
Excavate contaminated areas, construct RCRA-permitted
hazardous waste facility, consolidate waste, cap according
to RCRA re~ulation.
Excavate and land farm contaminated areas.
Excavate contaminated areas, encapsulate, and rebury on-site.
soil/Sediment Treatment
Incinerate excavated contaminated areas and dispose residue
on or off-site.
Wet air oxidation of excavated contaminated areas and dis~ose
residue on or off-site.
Cement-based solidification of contaminated areas.
Lime-based solidification of contaminated areas.
Thermoplastic-based solidification of contaminated areas.
organic polymer-based solidification of contaminated areas.
Classification-based solidification of contaminated areas.
Apply solution mining technology to contaminated areas.
Apply neutralization/detoxification technology to contaminated
areas.
seed contaminated areas with micro-organisms to achieve
degradat~on and stabilization.
Access/Development Limitation
surround site with chain link/barbed Wlre fence.
Surround contaminated areas with chain link/barbed wire fence.
Establish deed restrictions for contaminated area.
provide 6 inches of topsoil where necessary and vegetate.
Each alternative was screened to determine its effectiveness in
eliminating the potential for direct contact. Additional
measures of effectiveness included rendering the wastes inert
and minimizing their potential for leaching contaminants into
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A number of remedial alternatives involving various
stabilization/solidification techniques were subject to the
initial screening. These techniques involve the mixing of a
solidifying agent with the waste material to either physically
surround or chemically fix the waste into a hard stable mass.
The stabilization/solidification techniques evolved from the
Department of Transportation's regulation of the transportation
of radioactive waste. AS such, many of the techniques used
.were designed for temporary stabilization of waste and not
necessarily long term stability. In addition, these techniques
are very waste-specific and require a substantial amount of
analytical investigation to determine their effectiveness and
compatibility with the waste. Costs associated with these
techniques are presently quite high and as a result, it was
estimated that implementation of this technique would cost
approximately an order of magnitude greater than other
techniques capable of obtaining the stated objectives. These
remedial alternatives were therefore eliminated from futher
evaluation based on cost, acceptable engineering practices and
effectiveness.
Encapsulation/Reburial of the contaminated soils was evaluated
as a technique which might provide a long term solution for the
site. Encapsulation involves the use of a synthetic compound
to physically enclose the waste. At some sites this method
has been found to be protective of the public health and
environment. It has effectively eliminated the potential for
direct contact, reduced infiltration and minimized the potential
for leaching. presently however, this technique has just
emerged from bench-scale testing, and no commercially sized
unit has been built. Therefore, there is no data to support
its long term reliability or engineerin9 feasibility as a
remedial alternative. The costs associated with this method
are also very high. This technique was eliminated from further
analysis.
High temperature incineration with on-site ash disposal was
screened..While it is an attractive alternative because it
permanently destroys the hazardous waste with no hazardous
byproducts, it is not applicable to heavy metals because they
cannot be destroyed by oxidation. Thus it was excluded from
further consideration.
~
The use of wet air oxidation/residue reburial was also excluded
foi reason noted above with respect to high temperature
incineration.
Landfarming and in-situ microbial degradation are techniques
that use the assimilative capacity of plants or microbes to break
down the waste. under certain conditions these techniques are
capable of being effective for a wide range of organic compounds.
Metals cannot be broken down however, and as a result this
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In-situ solution mining was evaluated as an alternative for
metals removal. The technique involves injecting a solvent,
usually water or some other aqueous solution, into the area of
contamination. The contaminant is stripped from the soils and
the contaminated elutriate is recovered, and pumped to the
surface for treatment or disposal. This technique is most
effective when the contaminated area is relatively homogenous
and the contaminant is relatively mobile in the soil. Neither
case exists at the Site. In addition, the technique has only
seen limited application, usually to areas where a spill has
occurred. The size of contaminated area at this Site coupled
with the associated problems of collection and disposal make
this alternative infeasible for use at the site. Therefore,
this alternative was rejected on the basis of acceptable
engineering practices.
The remaining class of techniques considered and rejected was
in-situ neutralization/detoxification. presently this technique
is limited to specific chemical contaminants. Given the
heterogeneoys nature and size of the Site, this alternative
is impractical. It was eliminated from further consideration.
c.
Detailed Analysis of soils Alternatives
The retained alternatives were analyzed in greater detail
pursuant to 40 C.F.R. part 300.68 (h). Each alternative was
evaluated using the six criteria previously noted.
The FS evaluated thirteen alternatives for the control
direct contact threat posed by the arsenic, chrome and
soils and sludges. These alternatives ranged from the
alternative to complete off-site removal and disposal.
of the
lead,
no action
For ease of reading, the alternatives as discussed in this
document will be renumbered from those found in the RI/FS.
The changes are summarized below:
Old number found in RI/FS
New Numbe~
5-1 Shall be considered the
No Action Alternative
Not specifically addressed in
FS as a discrete remedial
alternative
S-6
Alternative I page 64
Alternative II page 65
Alternative III page 66
Alternative IV page 67
Alternative V page 68
S-2
S-3
S-4
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5-7
Alternative VI page 69
5-8
Alternative VII page 70
5-9
Alternative VIII page 71
5-10
Alternative IX page 72
5-11
Alternative X page 72
5-12
5-13
Alternative XI page 73
option II listed in Appendix
I. It is the complete of f-
site disposal o~tion
Based on the EA, the objective of the remedial alternatives
addressing contaminated soils and sludges is to prevent the
public from coming into direct contact with these materials.
The F5 analyzed various combinations of caps, both permeable
and impermeable, methods of waste removal and consolidation.
The F5, completed prior to the current NCP, made several
assumptions to form the basis for its evaluation of alternatives.
First, the F5 assumed that physical barriers between the wastes
and the public would meet the remedial objectives for the site.
Second, once the remedial action was implemented, the primary
concern would be ensuring that the wastes would not become
exposed again. In this regard, the effects of the freeze-thaw
cycle and of erosion are the two primary factors most likely
to im~act the lon~ term effectiveness of the remedial action.
Based on these assumptions, the F5 further assumes that buildings,
lawns and parking lots covering contaminated land would be at
least as effective as barriers specifically designed to eliminate
the potential for direct contact and would resist the effects
of erosion and the freeze-thaw cycle.
Based on these reasonable assumptions the evaluation of the
alternatives within the FS does not specifically address develo~ed
properties. The FS assumed that developed properties would not
require remedial actions. If, however, excavation or removal
alternatives were selected, the volume and costs for excavating
in developed areas would be significant. For the in-site capping
alternatives, institutional controls and existing structures
would act as effective barriers to eliminate the potential for direct
contact. The cost of additional fill required to cover grassed
areas within the developed portion of the Site would need to
be developed and added to the total remedial action costs.
5-1
NO Ac t ion
The no action alternative for contaminated soils was not
specifically delineated in the FS as a discrete alternative.
Site conditions and RI sampling results indicated that exposed
deposits containinc high levels of metals pose a direct contact
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was not a feasible option. For the purpose of this document
the no action alternative will be discussed.
A no action alternative assumes that no remedial actions are
taken to abate or address problems at the Site, with the
exception of quarterly sampling of ground and surface waters
and air quality to monitor Site conditions for evidence of a
sUbstantial change. Since institutional controls restricting
disturbance of the Site are considered a form of remedial
action, the no action alternative would permit unrestricted
development of the Site. Not only would the hide piles and
, metals deposits remain exposed at the surface and in contact
with Site surface waters, but also durin~ site development these
materials would be moved, thereby creating new releases impacting
the pUblic health, welfare and environment.
Costs associated with this alternative only involve monitoring
costs at $90,000 per year or a present work cost of 5850,000
for thirty years.
The implementation of S-l requires no special enyineering
techniques as it only requires periodic monitoring. The only
permanent structures would be the groundwater monitoring wells,
which are reliable and easily constructed. Due to their nature
and characteristics the wastes if left undisturbed, will remain
relatively ~table. If however, Site development is permitted
to resume, the reliability of this alternative changes
dramatically, releasing odors and toxic dusts to the surrounding
community, increasing the direct contact potential and
discharging contaminants into the site surface waters.
The no action alternative does not prevent or abate the threats
to or provide adequate protection of public health and welfare
and the environment. Under this alternative exposed deposits
permit direct contact. They are also toxic to vegetation and
will thus remain subject to erosion by surface water run-off.
The northern half of the Site is presently undeveloped thereby
providing a~prime area for easy access. In addition the Site
tends to be a local meeting and socializing spot for the area's
teenage population. These unauthorized Site activities continue
despite repeated attempts at maintaining a chain link fence
and posting the Site with warniny signs.
As a result, this alternative was found not to be ~rotective of
the public health, welfare or environment. In addition, this
alternative does not meet or exceed applicable or relevant
'and appropriate Federal requirements as it would permit the
continued release of toxic metal contaminants to impact surface
-water in violation of Water Quality Criteria. The applicability,
relevance and appropriateness of these regulations will be
discussed in a subsequent section of this document.
The alternative does not address any form of waste minimization,
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having greater than
24 inch cla barrier,
and establlsh a vegetative
S-2
Alternative S-2 is a source control remedial action that
involves leaving the waste deposits in their current location
and eliminates any potential for direct contact with the wastes
through the use of containment techniques. This alternative
involves modifying the site's contours to establish uniform
.slopes and covering any contaminated deposits containing above
100 ppm of arsenic, chromium or lead with 24 inch of impermeable
material (bentonite/soil mixture with 10-7 cm/sec permeability)
followed by a 6 inch top soil cover with vegetation. As part
of this alternative, the shallow pond located between the East
and West Hide piles would be drained and filled. The use of
institutional controls to ensure the effectiveness of the
remedial action is included as part of the alternative.
The cover proposed in this alternative would eliminate the
direct contact threat by placing the metals deposits below the
zone where the freeze-thaw cycle force them back to the surface.
Weather conditions in New England produce an action called the
freeze-thaw cycle. This cycle produces an effect that tends
to force objects and materials found within the frost zone to
the surface. An example of this phenomenon is found every
spring when farmers "harvest" another crop of rocks that nave
been pushed to the surface as a result of the previous winter's
frosts. Results of field experiences gained in the region.
indicate that covering with approximately thirty inches of
cover material is effective in minimizing the effects of the
freeze-thaw cycle. This alternative has the added benefit of
providing a level of impermeability which would effectively
exclude infiltration from migrating through the wastes. As
noted in the previous section, the RI results indicate that
while a portion of the metals deposits are in direct contact
with ground~ater, remedial action relative to leaching of
toxic metals was not necessary. Therefore the use of an
impermeab~e cover is unnecessary for preventing continued
leaching of wastes to the groundwater, however it is effective
in eliminating the potential for direct contact.
As noted above, part of the S-2 proposal is to drain and fill a
shallow pond along the northern border of the Site. This action
would eliminate approximately 4.1 acres of pond and associated
wetlands. The elimination of the pond would serve two purposes.
First, the RI determined that several waste deposits including
.portions of the East and West Hide piles were in direct contact
with the pond. Draining and filling the pond would effectively
eliminate the potential for direct contact and future surface
water quality impacts. The second reason is that the FS concluded
that it was the most effective method for addressing and resolving
the air pollution problems resulting from the East Hide pile.
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piles will be discussed in detail in the air pollution section
of this document. For the purposes of evaluating this proposed
remedial action it should be noted that limited water quality
analysis conducted prior to and durin9 the RI did not detect
any significant present impact of the metal sludges on the
surface water quality.
Because the draining and filling of the pond and its associated
wetlands is included in every soils alternative except the no
action alternative, S-l, it is important to address the applicable
'or relevant and appropriate Federal public health and environmental
requirements in more detail now.
The presence of a wetlands is one of the most important
environmental media requiring protection. A wetland serves
many functions such as a habitat for water fowl, animals, plants
and numerous s~ecies of aquatic life. In addition to servin9
as a habitat, wetlands act as nature's treatment system filtering
out and trapping pollutants. While hardy in many respects, the
continued good health of a wetland requires a fragile ecological
balance. AS a result, the Agency is committed to retaining, in
their natural state, as many wetlands as possible. section
404(b) of the Clean Water Act (CWA) is the statute governing the
discharge of dredge and fill material into a wetlands. primary
authority for administering ~ 404(b) of the CWA rests with the
Army Corps of Engineers (ACE). section 404(b) addresses the
discharge of dredge or fill into a wetlands; if fill is removed
or dredged from the wetlands S 404(b) technically does not,
apply. Federal actions conducted in a wetlands which could
potentially impact the wetlands is controlled under Executive
Order 11990. Executive order 11990 is much broader in scope
than S 404(b) of the CWA. The executive order effectively
prohibits any action from impacting a wetlands unless it can be
demonstrated that no practical alternative exists to completing
the re~uired action. Any action ultimately undertaken involving
wetlands must minimize to the extent practicable any adverse
impacts to ~e wetlands. The criteria and requirements of
S 404(b) are used during the implementation of the executive order.
As noted above, several toxic metals deposits were in contact
with the wetlands as well as portions of the East and West
Hide piles. Because of proximity of the wastes with the wetlands
there exists no alternative which does not impact the wetlands.
As stated earlier, the action of taking no action allows the
continued release or threat of release of contaminants into the
environment. All other alternatives would also impact the
wetlands to some degree. If only the toxic metal deposits and
not the hide piles were needed to be removed, then a practicable
-alternative would be the excavation of these materials from the
wetlands thereby increasing the flood storage capacity of
the wetlands - a positive impact. This action would comply
with S 404(b) as it does not discharge dredge or fill material
into a wetland and minimizes to the extent practicable the
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'11990. However, the disturbance or removal of the hide deposits
would create the release of an obnoxious odor adversely impacting
,the surrounding community's welfare. Because the release or
threat of release of this odor has created much concern within
the community and nearby workers within the industrial parks
the FS instead recommended the draining and filling of the wetlands.
This alternative eliminated the need to disturb the hide piles,
eliminated the potential for direct contact and assisted in
the e;fective im~lementati~n.of remedial actions required for
the alr alternatlves (speclflcally addressed in detail in the
air section).
This alternative was found to be protective of the public
health by eliminating the potential for direct contact. In
addition, the alternative would meet Water Quality Criteria by
eliminating any future impacts to the surface water. However,
as noted above, the alternative does not meet or exceed applicable
or relevant and appropriate Federal public health and environmental
requirements. Clearly, the elimination of the pond and wetlands
is in direct conflict with Executive order 111990.
Post closure monitoring and maintenance would be consistent,
with RCRA regulations S 264.310, and S264 subpart G concerning
landfill closure and post closure and groundwater monitoring.
The implementation of this alternative uses sound and well
tested construction techniques. However the availability of a
suitable clay source in sufficient quantity and the installation
of the cap around existing structures while maintaining an
effective impermeable layer are two major concerns. The time
required to implement this remedial action and the ability to
Dring sufficient quantity of material to the Site without a
substantial disruption of local traffic are additional concerns.
proper maintenance and monitoring would ensure the effectiveness.
and reliability of the remedial action. The alternative does
not make use of any techniques to reuse, minimize or destroy
the waste material. Therefore, the cap system must be maintained
and monitored indefinitely since in-situ physical, chemical,
or biodeg~adation mechanisms are not expected to ever reduce
the material to a non-hazardous classification. Finally,
institutional controls would be imperative to ensure that future
land uses did not disrupt the cover.
The useful life of a pro~erly maintained clay cap is estimated
to be greater than 50 years, at which time replacement may be
required. The surface cap system is a reliable and well-
demonstrated technology which prevents surface water infiltration
ihrbugh the buried waste material. operation and maintenance
requirements are not complex. They include long term ground-
water monitoring, cap maintenance and mowiny to maintain grass
cover and prevent tree growth. The facility would have to be
maintained indefinitely. The area of the site cap would not
be available for future development. Deed restrictions would
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The ca~ital, operation and maintenance, and present worth costs
of this alternative are summarized in Table 30. There are no
identified site conditions or waste characteristics that would
adversely impact the implementation or construction of this
alternative at the site. However, there are several concerns
which require resolution prior to implementation of the remedial
action. The major adverse environmental impact under this
alternative is the elimination of a wetlands. AS discussed
earlier in this alternative, the elimination of the pond and
wetlands would not be required to meet the established objectives
. for the Site if it were not for the need to drain and fill the
wetlands to control the problems associated with the East Hide
pile. These issues will be discussed in detail in the
air section. Additional study during the Remedial Design (RD)
for all the soils alternatives will be required to determine
the specific impacts resulting from the dredging of the materials
from the wetlands.
Another concern is the regrading of those areas of the Site
where it is necessary for controlling Site drainage. This
regrading presents the possibility of entraining contaminated
soils in the air during construction. The clay and topsoil
brouyht in also pose a potential threat of dust generation,
both during construction and until the cap is fully vegetated.
These cap materials also pose a threat of eroding sediments into
the Site's surface waters during the same time period. These
potential problems can be avoided and/or mitigated with strict
enforcement of conventional dust and sediment control construction
practices.
S-3
Cover contaminated soils containing any toxic metal in
excess of 100 ppm in place with 6 inches of clay, 18 inches of
common borrow, followed by 6 inches of topsoil and estaolish a
vegetative cover.
Alternative .5-3 a is source control action similar in design
and scope to the previous alternative. The only difference
oetween the two is the thickness of the impermeable barrier.
This alternative proposes to use 6 inches of bentonite clay
material and 18 inches of common fill instead of the full 24
inches of bentonite clay proposed under S-2. Alternative S-3
would provide a similar degree of protection relative to the
direct contact potential: however, it would not provide the
same degree of reliability for impermeability as would 5-2.
The capital and operation and maintenance costs associated
with S-3 are summarized in Table 31.
This alternative would meet the estaOlished public health
response objectives for the site. The surface cap system would
effectively contain the soil/waste material and prevent
contaminant migration, and as a result the potential for direct
contact and accidental ingestion exposure would be eliminated.
Conformance to applicable or relevant and aporoQriate Federal
requ1rements 1S t~e same as that in S-2 and 1s ~iscussed in more
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The primary advantage of 5-3 over 5-2 is the substantially
lower capital costs, S13.25 million versus S23.6 million. The
O&M and monitoring costs are equivalent and as a result the
difference in present worth cost is slightly less than S10
million. While 5-3 meets the remedial objectives established
for the Site, the degree of added protection against
infiltration under 5-3 is substantially less than that for
5-2. There are se~eral reasons for this. Qualjty assurance
and in-the-field application of bentonite are critical
.to ensure that the installation provides the degree of
impermeability designed for. Typically, greater thicknesses,
such as twenty four inches or greater, placed in several lifts,
are necessary to minimize the potential of barrier failure.
These failures usually occur as a result of placement, improper
compaction or the clay cracking and shrinking as the moisture
content comes to equilibrium once in place. placement of a
thicker layer, in three or four discrete lifts, eliminates
most of these failures. A six inch thickness, placed in one
lift, negates the benefits derived from the multiple lift
technique. The resultant effect is the greater potential for
infiltration and a lower reliability than in 5-2.
The same concerns relative to the adverse impact to the wetland
remain for this alternative as for the previous one. Likewise
this alternative poses the same short term potential dust and
sedimentation problems posed by 5-2. Like all capping
alternatives, 5-3 does not recycle, reuse, minimize or destroy
the wastes, and is dependent on perpetual 0 & M and institutional
controls to ensure the efficacy of the remedial action.
5-4
Cover contaminated soils containing any toxic metals in
excess of 100 ppm with 24 inches of common fill material,
place 6 inches of topsoil and establlsh a vegetative
cover.
~
Alternative 5-4 is a variation on 5-2 and 5-3, the only
difference being that the twenty four inches of fill below the
six inches of topsoil is clean borrow material instead of clay
or clay and borrow material. As in other alternatives,
institutional controls would be implemented as part of the
alternative. The capital O&M and monitoring costs of 5-4 are
located in Table 32.
The use of this cover, even though it is permeable to surface
water and rain water infiltration, would meet the established
environmental and public health objectives for the site.
placement of the cover material will effectively prevent the
threat to, and provide adequate protection of the public health,
welfare and environment resulting from the potential for direct
contact. With the exception of compliance with Executive
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and appropriate Federal public health and environmental
requirements.
Similar to S-3 and S-2, this alternative does not recycle, reuse,
minimize, destroy or eliminate the waste material, only
containing it on-site while eliminating the potential for
direct contact. As a result, the remedial alternative will
require continuing oversight and periodic maintenance
indefinitely.
There are no identified Site conditions or waste characteristics
that would adversely im~act the implementation or construction
of this alternative at the Site, other than those discussed
under S-2 and S-3.
Cover contaminated soils with 20 mil PVC synthetic membrane,
cover membrane with an additional 12 inches of common fill
followed by 6 inches of topsoil and vegetate.
The intent of Alternative S-5 is similar to the previous three
alternatives, which is to eliminate the potential for direct
contact by placing cover material over the exposed or near
surface deposits. Alternative S-5 uses a synthetic membrane
instead of soil or clay to establish a protective barrier.
Like S-2 through S-4, the pond abutting the East Hide Pile
would be drained and filled.
S-5
Similar to S-4, S-3 and S-2, areas requiring remedial action
under S-5 would receive Site preparation, including recontouring
to promote drainage, prior to the cap installation. After
this initial step, a six inch cover of screened sand would be
compacted over the area. The purpose of the sand is to establish
a stable and protective layer between the ground's surface ana
the synthetic membrane. The membrane, proposed to be 20 mil
thick PVC, would then be placed on top of the sand. The
membrane is delivered to the site in large rolled panels.
Field insta!lation includes placement of the panels and field
seaming t~ join each panel together followed by an in-situ
quality control check. once the membrane has been placed,
seamed and tested, it is covered by an additional six inches
of sand. This layer of sand serves as a protective cover to
prevent puncturin~ of the membrane and as a mechanism to drain
off any moisture in contact with the membrane. The sand layer
is followed by twelve inches of fill material and six inches
.of topsoil. vegetation is established to control erosion.
The additional cover material serves two purposes. First, it
.adds additional protection to the synthetic cover and second,
it provides sufficient depth to minimize the effects of the
freeze-thaw cycle.
Since the synthetic membrane is impermeable it provides the
same added degree of protection against infiltration as does
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and present worth costs are summarized in Table 33.
The implementation of this alternative uses proven engineering
techniques. The operation and maintenance requirements are
not complex and are similar in nature and scope to those
found in Alternatives 5-2 thru 5-4. The application of
Alternative 5-5 offers several advantages over the previously
discussed alternatives. The constructibility of this alternative
is better than those alternatives which use clay to establish
impermeability. Because the barrier is a synthetic product,
.it is manufactured under carefully controlled factory conditions.
As a result, the quality and impermeability of the membrane can
be more carefully controlled, resulting in an impermeability
higher than natural materials. Field placement is easier
to perform, less susceptible to inclement weather conditions
and changes in the raw product. The disadvantages of using a
synthetic material are the possibility of puncturing the liner
during placement, the maintenance of quality control over
field seaming, and the potential incompatibility of the
membrane with the wastes or the susceptibility to attack from
chemical contaminants. Another disadvantage of synthetic
membranes is that they are relatively new for use in hazardous
waste applications. As a result, their useful life has not
been documented.
Alternative 5-5 is protective of t.he public health and
environment. AS in the previous alternatives, minimization of
potential for direct contact is the primary objective, and
alternative 5-5 meets this objective. In addition the
installation of a synthetic membrane minimizes the potential
of infiltration, thereby providing an additional degree of
protection against leaching. It also meets all applicable or
relevant and appropriate public health and environmental
requirements except for Executive order # 11990. It also poses -
most of the same dust and sedimentation concerns posed by the
previous three alternatives.
~.
The use of alternative 5-5 would effectively contain the waste
deposits and prevent future contact or contaminant migration.
However the waste material to be capped would not be recycled,
reused, minimized or destroyed, and therefore the cap must be
maintained and monitored indefinitely since in-s.itu physical,
chemical, biodegradation mechanisms are not expected to reduce
the material to a nonhazardous classification. Institutional
controls similar to those previously discussed would also be
required to prevent disturbance of this remedial alternative.
S-6
Cover contaminated soils in place with six inches of
topsoil and vegetate.
Alternative 5-6 consists of regrading portions of the Site to
promote better drainage. Once the site has been regraded, six
inches of topsoil will be placed over those areas where exposed
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cover would be established over the entire area. This
alternative includes some limited excavation in the northwest
corner of the Site along New Boston Street to minimize contact
of wastes with the surface water. In addition, actions relative
to the West and East Hide piles (as previously discussed) are
incorporated as part of this remedial alternative. The use of
institutional controls would be needed in order to ensure that
the remedial action was maintained as initially implemented.
Capital costs and operation and maintenance expenses associated
with this alternative are found in Table 34.
. Implementation of alternative S-6 uses conventional and well
established technolo~ies. The alternative is relatively easy
and straightforward to implement. The alternative is also
attractive in that it provides minimum disruption to the local
businesses and community during the implementation phase,
since less material must be trucked into the site.
The alternative meets the remedial objectives established for
the Site, similar to the previous alternatives, but the degree
of reliability is substantially less than those alternatives.
The Operation and Maintenance (O&M) costs are higher to
compensate for the decreased reliability. These two disadvantages
can be related directly to the fact that the effects of the
freeze-thaw cycle are much more pronounced on this alternative
(six inches of cover material) than those alternatives using
thirty inches of cover materials. As a result of only six
inches of cover, the frost is permitted to penetrate to the
actual waste deposits, thereby forcing wastes to the surface as the
ground begins to thaw.
This occurrence significantly increases the potential for exposure
of wastes to the public and environment. Another concern is
that of erosion. Site conditions and surrounding land use
patterns indicate a high potential exists for erosion to occur.
The effects of erosion on a six inch cover will obviously pose
a greater potential for release of contaminants tnan on a
thirty inch ~over. In order to minimize the potential for
release oGcurring, the frequency of monitoring and routine
maintenance for a six inch cover needs to be increased, hence
an increased O&M cost. A second technique is to select and
establish a vegatative cover which enhances the ability of the
vegetative cover to minimize erosion. Again, this increases
the operation and maintenance costs.
Alternative S-6 is protective of the public health, welfare,
and environment since it meets the remedial objective of
preventing direct contact with the public and surface water.
This alternative has similar status with respect to applicable
or relevant and appropriate Federal public health and environmental
requirements as the previous alternatives, especially those
employing permeable caps. An analysis of 5-6 indicates that
like the previous four alternatives it is a source control
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long term in-situ cover. This alternative does not avail
itself of new or innovative technologies. It provides an
effective, if somewhat less reliable means of eliminating the
potential for direct contact than the preceding alternatives
with the exception of 5-1. In addition, implementation does
not pose any significant adverse environmental impacts over
and above those noted in the previous four alternatives.
Alternative 5-6 does nothing to recycle, reuse, minimize
or destroY the wastes found at the Site. This alternative does
'not use new, innovative or alternative technologies to reliably
minimize either the present or future threats to the public
health, welfare or the environment.
Construct a RCRA on site containment facility. Excavate
and de osit into the RCRA facilit an waste de osit
contalnlng arsenlc, chromlum, or ea waste wlth lndlvidual
concentrations of one or more exceeding 100 ppm, as well
as the East Central, the West, and the south Hide Deposits.
Alternative 5-7 evaluated the feasibility of excavating and
relocating on-site all waste deposits containing heavy metals
in excess of 100 ppm and all hide deposits except for the East
Hide pile to a hazardous waste landfill designed in conformance
with the Resource Conservation and Recovery Act (RC~A). This
would effectively contain site contamination and prevent future
potential migration of contamination associated with the Site.
The technical performance of an on-site RCRA landfill is good
compared to other containment technologies. A double liner,
an impermeable cap, a leachate collection and storage system,
and a leak detection system would prevent the migration of
contaminants from the landfill. Any leakage through the first
liner would be captured by the second liner and would be
detected and collected prior to entering the groundwater.
The useful life of a properly maintained RCRA landfill
would be at least 30 years. The exact service life cannot
be accurate~y predicted. However, the in-effect "triple" liner
system would effectively eliminate the potential for release and
therefore. should provide for long-term waste containment.
Site conditions are such that a minimum of ten feet would exist
between the base of the landfill and the groundwater table.
Long-term groundwater monitoring would also be provided. The
various tasks associated with this alternative are indicated
on the detailed cost estimate sheet, Table 35. It should be
noted that the costs presented are underestimated because they
represent the costs for consolidating wastes found on undeveloped
property only.
5-7
Operation and maintenance requirements for an on-site landfill
would be relatively complex. They would include groundwater
monitoring, facility inspection and maintenance, and
disposal/treatment of any leachate that may be generated from
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Land use restrictions would be required for "the area of the on-
site landfill. NO development would be allowed at the landfill
site.
This alternative effectively mitigates the threat to, and
provides adequate protection of public health and welfare and
the environment and achieves the remedial objective for the
site. With the exception of compliance with S 404(b) and the
Executive Order 11990 this alternative exceeds applicable or
relevant and appropriate Federal public health and environmental
requirements since it also eliminates any potential for the
wastes to leach contaminants into the groundwater. While
" regulatory permits would not be required implementation of
S-7 would meet the technical requirements for new RCRA facilities.
The impacts to the wetlands under this, as well as the other
consolidation alternatives will be significant. primary attention
has been given to the wetlands located between the East and
West Hide Piles; however, several smaller wetlands found on-site
would be impacted under the consolidation options. As continually
noted throughout the ROD, waste deposits are scattered over a
large area often times in direct contact with wetlands and
surface waters. Under the consolidation alternatives, the
entire Site would be effectively excavated, eliminating existing
wetlands and streams in the process. Implementation of the
consolidation alternatives would not minimize the impacts to
the wetlands it would eliminate them completely. Efforts
would be required to compensate or create new wetlands once the
proposed remedial action was complete.
Alternative S-7 minimizes area impacted and restricted. It
uses more advanced technologies than previous alternatives
to contain the wastes and eliminate the present and future
threats to the public health or welfare or the environment.
The use of a RCRA on-site facility would consolidate the waste
deposits scattered over 90 acres to an area approximately 15
acres in size with satellite deposits under existing buildings,
unless the buildings were removed. This alternative would
result in a net gain in the amount of land not needin~ use
restriction~.
There are"several conditions that could adversely impact the
implementation or construction of this alternative at the Site.
The Site contains a number of existing buildings, roadways,
and parking lots. In order for the remedy to be completely
effective, waste deposits located under these existing
structures would need to be removed in addition to those on
the undeveloped portions of the Site. Allowing the wastes to
remain in place under the buildings means leaving satellite
deposits outside the RCRA containment facility, thus reducing
t~e overall effectiveness of this alternative. From a practical
standpoint there is no effective method for removing deposits
underneath buildings without destroying or removing the
buildings. Irrespective of these increases in the estimated
costs, the disruption of existing businesses would also make
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Further, while the east side of the Site (east of Commerce
Way) appears to meet engineering criteria for the siting
of a RCRA landfill, the relatively high groundwater table and
a major wetlands adjacent to the proposed facility would adversely
impact the implementation of this alternative. A waste
compatibility evaluation would also be required during the
design of the RCRA landfill to ensure compatibility between
the waste deposits and the liner system.
Additional impacts resulting from the implementation of this
alternative would include the short term generation of dust,
.odor and sedimentation problems similar to those noted in
previous alternatives. Impacts to the wetlands between the
Hide piles would be similar to those previously mentioned,
however the wetlands east of Commerce Way would also be impacted
by this alternative. The amount of fill material, such as
clay, necessary to construct the RCRA facility would need to
imported from off-site. This would place a substantial hurden
on the local traffic flow patterns (which are currently stretched
to capacity now). Implementation of this alternative would
require that clean uncontaminated land slated for development
would be unavailable for future development as a result of this
alternative. In addition to all the adverse impacts resulting
from this alternative, the alternative does not recycle, reuse,
minimize or destroy the wastes materials.
In addition to the logistical and implementation problems
noted above, there are several short term adverse impacts
associated with implementation of this alternative. The RI
determined that approximately fifteen percent of the sludge
deposits are contained within the saturated zone. In addition,
local surface waters are found in contact with the waste deposits
at several locations. Excavation of the deposits will tend to
suspend a portion of the waste material in the ground and
surface waters. While engineering technique can be implemented
to minimize these potential impacts, the sheer volume of wastes
to be excavated in order to successfully impleMent these
alternatives make the potential for a short term release ve.ry
high. .
Further, a significant ~ount of the material requiring removal
as part of these alternatives is the animal glue manufacturing
deposits. Past experience with the primary developer (Mark
Phillip Trust) indicates that disturbance of these deposits
will cause a substantial release of odors. Release of these
odors will pose a significant adverse impact to air quality
surrounding the Site. Historical information indicates that
during active excavation of the hide deposits, the odor emanating
from the Site was pervasive throughout the surrounding
communities. Continuous complaints of the obnoxious odor,
severe headaches and nausea were reported to the State regulatory
agencies. Reports of workers becoming physically ill are
contained in past reports. Strong public reaction from the
recipients of the odor resulted in the Town of Reading suing
the developer to cease and desist generating the odors. A
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number of techniques were experimented with in an effort to
.control the odor, none of which was successful. In the six
years since the active excavation, odors can still be detected
under certain circumstances as a result of the disturbance of
the deposits. As a result of the adverse impact to the welfare
and the strong public resistance, the removal or rearrangement
of the hide deposits is not feasible.
Remove all arsenic, chromium, and lead de osits with
lndlvldua concentratlons 0 one or more exceedlng 100
ppm and consolidate these deposits on the East Centrall
East Hide deposits areas, backfill excavated areas with
clean fill material and cover the East Central and East
Hide Deposits with impermeable cover.
The FS evaluated the feasibility of consolidating approximately
90 acres of deposits containing elevated levels of arsenic,
~hromium, and lead into an approximately 15 acre area on the
northern border of the site. Implementation of this alternative
involves the removal of approximately .460,000 cubic yards of
waste deposits and their consolidation into one large deposit.
The consolidated deposit would then be covered with a cap
similar in design to that found in alternative S-5. Capital
costs, operation and maintenance and present worth costs can be
found on Table 36. For the same reasons as were dis6ussed for
alternative S-7, these costs are underestimated.
S-8
Once completed, Alternative S-8 is protective of the public
health, welfare and environment. It eliminates the
potential for direct contact between the wastes and the public
and surface waters. It will not provide the same degree of
protection as the previous alternative, S-7. The advantage of
the previous alternative S-7 was that once the waste was removed
from the present location it would be placed in a secure RCRA
landfill. under alternative S-8 the waste would be consolidated
to an area which presently contains waste deposits. The physical
handling of .the material and the placement of it on top of
existing waste deposits may in fact cause more adverse than
beneficia{ environmental effects. Similar to the animal glue
wastes which were not generating substantial odors until some
of the deposits were disturbed, creating the East Hide pile
and its subsequent release of odors, the physical relocation
and restructuring of the deposits to a new area may create a
situation that promotes the potential for increased leaching
of the wastes. Implementation would not meet applicable or
relevant and appropriate Federal public health and environmental
requirements. Implementation of this alternative would have
~ignificant adverse impacts on surface water quality, the
elimination of a wetlands and the release of an obnoxious odor.
In addition, impacts to the wetlands and concerns about compliance
with the appropriate requirements are similar to those discussed
in s- 7 .
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alternative 5-7 but without the increased cost of constructing
a RCRA facility or of moving Hide piles. Like 5-7 this alternative
consolidates the wastes onto a smaller parcel of land (15 acres
versus 90 acres), thus minimizing the amount of land that must
be maintained, monitored and restricted from development.
Because of the reduction in physical size there will be a
reduction in O&M costs. In addition this alternative, unlike
5-7, would consolidate the contaminated materials on propertj
that is already contaminated. The physical removal of the
material and its consolidation onto another portion of the
property would use standard earth moving techniques that have
.proved effective in this kind of operation. This alternative
has a substantially lower capital cost and is easier to implement
than the previous alternative 5-7. The alternative is similar
to previous alternatives in that it seeks to control the potential
for direct contact potential through containment rather than
recycle, reuse, minimize or destroy the waste.
Implementation of this alternative could cause several adverse
environmental impacts. The physical removal and relocation of
approximately 460,000 cubic yards of waste deposits would
impact the local groundwater, surface water, and eliminate
several wetlands found on-site. This quantity of material to
be moved will require a substantial earthworking effort.
Because a substantial portion of the waste materials are in
direct contact with ground and surface waters, the heavy
equipment will need to intrude into these media in order to
remove the wastes and eliminate the direct contact. Despite
using every available technique to lessen the impacts to
surface and ground waters, nonetheless an impact will occur.
In addition, issues similar to those found in alternative 5-7
involving excavation under existing structures would be
applicable to this alternative. The alternative proposes to
backfill the excavated areas with clean fill material. In
addition to the large amount of traffic to physically remove
the waste deposits for waste consolidation, there would be a
significant ~traffic impact on the surrounding community as a
result of the large amount of clean fill required from off-
site to backfill the excavated areas.
5-9
Remove all arsenic, chromium, and lead de osits with
indlvldua concentratlons of one or more exceedln 100
ppm: conso 1 ate on the East Centra West Hlde Deposits:
and cover the East Central and West Hide Deposits with
an imlermeable material: and leave excavated areas
unfil ed.
Alternative 5-9 is exactly like alternative 5-8 except that the
excavated area would not be backfilled with fill material. The
primary advantage of this alternative over the previous
alternative is a substantal decrease in the capital costs.
The capital, operation and maintenance costs and present worth
costs of this alternative are summarized in Table 37. Again,
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This alternative could be successfully implemented with the
application of standard engineering and construction techniques.
Site conditions do not pose any significant adverse impacts to
the implementation of tnis alternative, however the concerns
to those noted in alternative S-8 relative to the material
under existing structures and impacts to the environment also
apply to this alternative.
The primary advantage of this alternative is that it costs
approximately half that of alternative S-8 in terms of both
,money and implementation time. The primary disadvantage to
this alternative would be that, without the clean backfill, open
excavations up to 15 feet deep would be left behind once the
site remediation was completed. Allowing these excavations to
remain is not practicable as they would create an attractive
nuisance to area children and would leave the area pock marked
by numerous shallow ponds or ditches. On the other hand, the
land would be clean and hence developable. These ponds would
be no worse' to deal with than common development problems like
high groundwater or bedrock.
5-10
..............
Fence areas of waste deposits, enforce institutional
controls~ excavate l'imited area in northwest corner of
site~ cover the East Central and West Hide deposits.
Alternative 5-10 involves the limited excavation of waste.
deposits from one of the developed properties, PX Engineeriny,
to eliminate the direct contact between these deposits and the
surface water. This excavated material would be transported
to the East/West Hide piles area. The East Central, and East
and West Hide pile areas would be regraded and reshaped to
promote better drainage. In addition the south Hide pile
would be relocated to the West Hide pile area in order to fill
low spots and help stabilize side slopes. The area which was
reshaped and regraded would be covered with a six inch topsoil
cover and v~getative growth established. The remaining deposits
would be .fenced to prevent unauthorized access, and institutional
controls would be enforced throughout the entire site to ensure
that the remedial action was not disrupted. The capital,
operation and maintenance, and present worth costs are summarized
in Table 38.
This alternative may not meet the environmental and public
health goals established for the site. The alternative does
not effectively prevent, mitigate, or minimize the threats
-to, and provide adequate protection of the public health and
welfare and the environment.
presently there exist a number of areas within the Site where
exposed deposits present a direct contact threat. under this
alternative the barrier between the waste and the public would
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is ineffective in eliminating entry and the potential for
direct contact. In the five years since the initial installation
'of the fence, the Agency has made repeated attempts to repair
damage to the fence resulting from vandalism. Implementation
of this alternative would permit the continued release or
threat of release to the environment of the waste deposited on
the Site.
In addition the presence of exposed deposits creates the
possibility of their erosion by precipitation runoff, adversely
impacting the surface water and ultimately the groundwater
found on-site.
This alternative does not meet the applicable or relevant and
appropriate Federal public health and environmental requirements.
Because exposed deposits would be allowed to remain in direct
contact with surface waters the release or threat of release
of contaminants would violate Water Quality Criteria. The
initial placement of the East and West Hide pile in or near a
wetlands was in violation of the Clean Waters Act S404(b): leaving
them in their current state would continue to violate S 404(b).
This alternative is extremely simple to implement because this
alternative approaches no action. Because the alternative
takes only limited actions, the actions are easily constructed.
unfortunately, as previously stated these actions are ineffective
in preventing unauthorized access to the Site: thus'the actions
have to be considered unreliable.
The capital cost is obviously low since 5-10 entails only placing
fences around the area after limited consolidation, reworking
and capping some portions of the site.
Alternative 5-10 does nothing to recycle, reuse, minimize or
destroy the wastes found at the site. This alternative does
not use new, innovative or alternative technologies to reliably
minimize either the present or future threats to the public
health, welfare or the environment.
Implemen~ation of this alternative, like 5-1, does not take
additional actions in or near a wetlands. As a result there
would be no additional adverse impacts resulting from remedial
actions. However, the potential does exist over the long term
however, for exposed deposits to impact the local surface
water as a result of storm water runoff and erosion. This
alternative does nothing to minimize these potential problems.
~
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to the construction details of the cover, i.e. twenty-four inches
of permeable material followed by six inches of topsoil. There are
several important differences between this alternative and S-4,
as well as the other alternatives. Most notably the action levels
have changed from an arbitrarily established value of 100 p~m
to values developed in the Endangerment Assessment (EA). In
addition, previous alternatives addressed covering any deposit
exceeding 100 ppm, irrespective of the depth below grade at which
the waste was detected. In S-ll the alternative seeks to
eliminate the potential for direct contact with any deposit
.above the action levels established in the EA that could become
ex~osed as a result of the freeze-thaw cycle or effects from erosion.
This objective is accomplished through the use of a permeable
cover over deposits exceeding the action level that are within
thirty inches of the ground's surface. Institutional controls
would be implemented to control any area having deposits
exceeding the action levels regardless of depth. for contaminated
materials located in areas where buildings, parking lots and
roadways currently exist the structure itself would serve as the
barrier to eliminate the potential for direct contact. As in other
portions of the Site, institutional controls would be implemented
to restrict disturbance of the effectiveness of the remedial action.
The premise of this alternative is to establish a thirty inch
zone of uncontaminated material over the waste deposits to
eliminate the potential for direct contact, minimize the effects
of the freeze-thaw cycle and help control exposure resulting
from erosion.
This alternative, S-ll, utilizes remedial action levels
established by the EA. A discussion of the action levels can
be found in the current Site status section of this document
and in Appendices F and G of the FS. In addition to the EA
performed as part of the FS, another potentially responsible
party (PRP), Monsanto Chemical Company, retained a consultant
to independently assess the potential risk posed by the Site.
Results from this independent analysis were similar to those
found in the FS. Both the EA found in the FS and the independent
risk assessment were submitted to the Department of Health and
Human Seryice's Agency for Toxic Substances and Disease Registry
(ATSDR) for their review and comment in the form of a Health
Assessment. ATSDR'S review and interpretation of the data was
based on a literature review as well as empirical data gathered
from several studies conducted by the Centers for Disease
Control (CDC). The values determined to be protective of the
public health by ATSDR were similar to those found in the EA
and the independent analysis. However ATSDR concluded that
safe levels for an industrial settin~ could be an order of
~agnitude (factor of ten) higher than those determined to be
protective of the public health in a residential neighborhood.
As a result, ATSDR concluded that maximum acceptable surface
soil residues of 6,000 ppm Arsenic, 10,000 ppm Lead and 30,000
ppm for trivalent Chromium were appropriate for this Site,
assuming the exposure was the type to be encountered in an
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The Agency reviewed and evaluated ATSDR's Health Assessment and
rejected their use of an arbitrary increase by an order of
magnitude in projecting safe clean-up levels. As previously noted,
if the order of magnitude increase is eliminated, ATSDR's
values are similar to those calculated in the FS and Monsanto's
risk assessment. The Agency does not believe that final
determination of clean-up levels should be based, in a large part,
on, the proj ected use of the Site. Wh ile a port ion of
this Site is currently an industrial area, the remainder of the
Site receives a fair amount of recreational use. Hunters,
berry pickers, and motorcyclists are often discovered using
'the Site. under the proposed remedial action a portion of the
site would remain undeveloped and as a result, these activities
are likely to continue. Since at least a portion of the Site
would remain undeveloped under all but two of the remedial
action alternatives and therefore an attractive area for ado-
lescents and others to frequent, it is prudent to assume that
the potential for exposure is substantialy higher than if the
Site were truly an industrial area. It could reasonably be
argued that as the land around the Site becomes more industrialized,
the site would become more attractive for recreational use
because open space would be that much rarer in this section of
the City. The Agency therefore concludes that the action levels
established in the EA, not ASTDR's, are protective of the
public health, welfare and environment and provide a greater
margin of safety given the uncertainty of future land use
patterns around the site.
In addition, the ATSDR Health Assessment is limited to issues
directly related to the protection of public health; it does
not address levels protective of the environment. As discussed
in the EA and in connection with the no action alternative, the
'arsenic deposits are phytotoxic at levels as low as 300 ppm.
Further, the East Hide pile has a very sparse vegetative cover
despite the fact that the last earth moving there ceased seven
years ago. This fact supports the relationship between elevated
levels of m~tals and phytotoxicity.
~
The assoc~ated capital, operation and maintenance, and present
worth costs for this alternative can be found in Table 39.
The primary advantage of this alternative over S-4 are the
lower capital and O&M costs resulting from the decreased
area requiring remedial action.
Alternative S-ll meets the environmental and public health yoals
established for the site. present and future potentials for
direct contact are eliminated by the installation of a permeable
cover and institutional controls. In addition the alternative
meets the applicable or relevant and appropriate Federal public
health and environmental requirements for the site.
-
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S-12
Cover the East-Central and West Hide Deposits and
all waste deposits with values greater than 300 ppm
arsenic, 600 ppm lead, or 1000 ppm chromium with six
six inches of topsoil and vegetate. Impose lnstitutional
controls on property.
Alternative S-12 uses the same action levels and depth criterion
as S-ll, but replaces the twenty-four inch cover in 5-11 with a
six inch cover like that used in alternative 5-6. Like S-11
institutional controls would be needed to prevent disruption
'of any deposit exceeding the action levels regardless of the
depth at which it is found. Cost evaluation can be found in
Table 40. Evaluation in terms of engineering implementation
and constructibility is the same as with the preceeding alternative.
Alternative 5-12 meets the remedial objective for soils contamination
since it would effectively eliminate direct public contact
with wastes exceeding the action levels. As discussed regarding
S-6, the six inch cover is readily constructed using conventional
engineering techniques. This alternative would be easier to
implement because less land, forty-three acres versus seventy
acres, would require covering. The smaller area reduces the
amount of topsoil that must be brought to the Site, thereby
reducing traffic impacts and disruption of the surrounding
community. Implementing this alternative poses no long term
adverse environmental impacts and poses only minimal construction
related impacts, primarily the potential for generating dusts
and causing sedimentation of surface waters. These are easily
dealt with.
As with 5-6, the thinness of the cover proposed here makes it
a less reliable remedial action than the thirty inch covers
proposed in other alternatives. The six inch cover would be
much more susceptible to disruption by erosion and the freeze-
thaw cycle. Since this alternative is a containment action, it
does not recycle, reuse, minimize or destroy the wastes and
contaminated soils.
.."
This alternative has similar status with respect to appli-
cable or ielevant and appropriate Federal pUblic health and
environmental requirements as the previous alternatives.
Based on its lower reliability and higher action levels this
alternative while meeting the remedial objective for soils at
the Site is less protective of the pUblic health and the
environment than all other alternatives except 5-1 and 5-10.
The capital, operation and maintenance, and present worth costs
for this alternative are summarized in Table 40.
~
Remove all arsenic, chromium, and lead waste deposits
with individual concentrations of one or more exceeding
100 ppm and remove the East Central, the West, and
South Hide De osits to an off-site location. Backfill
excavated areas wlth c ean of slte fl materla.
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This alternative, S-13, evaluates the off-site disposal
alternative. under this alternative all materials above 100
,ppm located on undeveloped land would be excavated and trucked
off-site for disposal at a RCRA landfill. The majority of the
Site would be effectively cleaned up and the wastes disposed
of at an off-site RCRA landfill.
The costs of this alternative are presented on Table 41.
The associated capital costs are approximately 210 million
dollars. Detailed evaluation was not conducted in the FS
because its costs far exceed those of the other alternatives
. without substantially increasing the protection of the public
healtn and environment. Since there are other alternatives
that meet the remedial objective and the requirements of other
Federal public health and environmental requirements, this
alternative is not substantially more effective than other
viable alternatives. This alternative is substantially more
reliable than other alternatives as evidenced by there being no
operation and maintenance costs or institutional controls
associated with it. For this reason the Agency will analyze
tnis alternative here.
This alternative is constructable, but the implementation time
is extremely long. The FSestimated that it would take
approximately seven years of constant soil removal to effectively
remove this amount of material. This would severely disrupt
traffic and businesses around the site.
In order for these alternatives to be completely effective, all
the waste deposits would need to be excavated and redeposited
into a secure facility. This alternative was evaluated in
terms of excavating and removing wastes from undeveloped portions
of the property. Areas containing buildings, parking lots or
roadways were not included as part of this alternative for
reasons noted previously. The physical problems and logistics
associated with waste removal from under these structures is
costly and impractical. Assuming that these deposits are
allowed to remain in place, the effectiveness and driving
force behjnd this alternative is substantially reduced.
If all deposits are to be removed, these buildings would have
to be taken down, parking lots and lawns excavated and the
wastes removed. AS a result, a complete removal would cost
more than the $210 million estimated in the FS.
The logistical and odor problems discussed previously in
connection with alternative S-8 apply to this alternative as
well.
This alternative would effectively eliminate any long term
public health, welfare, or environmental impacts through the
removal of the waste deposits to an off-site facility.
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D.
Development and Screening of Alternatives for Air
The remedial actions required to abate air problems center
around the East and West Hide piles.
The East and West Hide piles are lar~e mounds of glue
manufacturing wastes and heavy metal sludges that are built out
from the sides of hills on the east and west sides of a pond
located in the northwest section of the Site. The piles extend
from the hillsides across a wetlands and into the pond itself.
The West Hide .pile is relatively staole and is almost entirely
covered with vegetation, primarily reeds. There are ex~osed
metals deposits on the West Hide pile at the base of the slope
where it meets the pond. The East Hide Pile is larger, has
unstaOle side slopes and has almost no vegetation covering it.
Sections of the East Hide pile have sloughed off into the
wetlands, simultaneously releasing strong, obnoxious odors. The
RI determined that the East Hide Pile is the source of the
odors emanating from the Site. It also has several intermittent
leachate seeps that impact the wetland.
Since the RIdetermined that the West Hide pile was not an odor
source, the remedial objectives for this pile are to maintain
stable side slopes and to eliminate the potential for direct
contact. Therefore, the West Hide pile remedial action alternativef
were evaluated as part of the soils section of the FS.
The remedial action objectives for the East Hide pile are:
1)
to eliminate the potential for direct c~ntact with the
heavy metal wastes:
2 )
3 )
to stabilize
of materials
to el iIDinate
air. .
the side slopes in order to eliminate sloughiny
into the wetlands, and
the emission of obnoxious odor into the ambient
For convenience, the RIfFS discussed all the problems with the
East Hide pile as "odor" problems. Similarly, this document
will discuss all the remedial alternatives for this problem as
"air" alternatives.
The evaluation of the potential air remediation techniques
consisted of two parts. The first was an evaluation of various
techniques to stabilize the side slopes, to eliminate the potential
_~or direct contact and collect the odorous gases. The second
evaluated several treatment techniques which would either
eliminate the potential generation of gases or treat the gases
being released to the environment. Listed below are the
alternatives initially screened for potential use at the site.
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AIR ALTERNATIVES
No Action
Gas collection
and Control Alternatives
Construct a passive gas collection system
Construct an active gas collection system
Installation of a tall stack
Construction of a cap system consisting of either an
impermeable membrane liner, clays, soil admixtures, asphalts,
or urea-formaldehyde materials.
Gas Treatment Alternatives
Vapor Phase Adsorption
Carbon adsorption treatment system
Ion exchange resin treatment system
Thermal Oxidation
Installation of flare or afterburner
Stabilization
A pH adjustment using sodium bicarbonate or lime to
expedite the transition of the East Hide pile from an
active to passive emission source
Chemical Oxidation
Addition ~f hydrogen peroxide or ozone to reduce odor emission
."
Each alternative was evaluated for its ability to either contain
and control the gaseous emission or eliminate the formation of
the odor in the first place. The following is a brief discussion
of each alternative.
The use of urea-formaldehyde barriers to contain the gaseous
emi~sions was evaluated and eliminated based on acceptable
engineering practices. The use of foam to eliminate exfiltration
o~ gases is dependent on its permeability. A review of
available information indicated that the effective permeability
of the foam varied widely as a result of frequently encountered
installation problems.
The use of a tall stack dispersion as a technique was eliminated
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electrical transmission lines make~ the placement of a tall
stack in close proximity to the lines infeasible. Furthermore,
the use of a tall stack would not prevent or eliminate the
release of odors: it would minimize their impacts through
.enhanced~dispersion. While there are advantages to maximizing
the dispersion and resulting assimilation of a plume into the
environment, enhanced dispersion techniques are not recognized
by DEOE or EPA as good engineering practice since they do not
reduce pollutant mass.
The use of chemical oxidation to eliminate odors was eliminated
based on effectiveness. The use of an oxidizer, such as hydrogen
. peroxide or ozone, has the potential for generating a hazardous
waste as a byproduct of the reaction. This is because the
oxidation reactions frequently are not complete, leaving an
oxidation product which could be in a more toxic form than the
initial compound which would create a significant adverse
environmental impact.
Ion exchange as a treatment technique for odors was eliminated
based on acceptable engineering practices because it is not an
appropriate technique for the treatment of the type of air
emissions found at the Site.
The physical removal of the East and West Pile was eliminated
based on cost, acceptable engineering practices and effectiveness.
The East Hide Pile, determined to be the primary source of
odors, was created from the relocation of other hide deposits
on-site during Site development. During the excavation of
several building foundations, the odor was at its worst.
Numerous techniques were implemented to attempt to reduce the
odor while still permitting Site development. All efforts to
contain odors during excavation and removal failed. Since on-site
activities have ceased, the odors have abated significantly,
only being detected when one of several conditions, such as changes
in barometric pressure, occur. The costs associated with .
removal of the pile far exceed the costs of other alternatives
evaluated (536 million versus 52.8 million) and the alternative
does not pr9vide substantially greater public health or environmental
protection. Excavation and removal of the piles would destroy
a wetlands during the actual removal. In addition, a substantial
impact to the abutting surface water would occur causing serious
sedimentation and degradation of water quality. Currently
there are no acceptable engineering technologies capable of
controlling the release of odors during the excavation of
these materials. As a result, there would be a significant
release of odors. Workers involved in the excavation and
~emoval would be exposed to concentrations of hydrogen sulfide
and methane gases in excess of allowable occupational exposures.
Therefore there are no acceptable engineering practices for
'avoiding these adverse environmental and occupational problems.
The use of lime or sodium bicarbonate as a stahilization
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involve the injection of a solution into the pile which would
raise the pH to a level which would stop the microbial
. decomposition, a major factor in the generation of odor. The
use of this technique was eliminated based on effectiveness.
Like grout curtain wells, injection of a stabilization slurry
is highly dependent on waste material characteristics and the
number and location of the injection points. In addition, use
of this technique has not proven effective in reducing emission
rates from sanitary landfills.
E.
Detailed Analysis of Air Alternatives
Six alternatives, including the no action and total removal
alternatives, remained after the initial screening process and
were evaluated in detail for use at the Site. The remaining
alternatives were subjected to a detailed analysis consistent
with S 300.68(h) of the NCP.
Again, for ease of reading, the alternatives as discussed in
this document will be renumbered from those found in the RI/FS.
The changes are summarized below:
New Number
Old number found in RI/FS
A-l Shall be considered the
No Action Alternative
Not specifically addressed in
FS as a discrete remedial
action
A-3
Alternative I page 43
Alternative II page 43
A-2
A-4
Alternative III page 43
~
Odor Control portion of
alternative V located in
Appendix I.
A-5
~6
Odor Control portion of
Alternative II listed in
Appendix I.
A-l
No Action Alternative.
Similar to the alternatives evaluation for
~oils, a no action alternative for air was
addressed in the FS. As a result, a brief
alternative is summarized here.
groundwater and
not specifically
analysis of this
The emission of obnoxious odors caused by hydrogen sulfide
(H2S) and other reduced sulfur compounds resulting from the
anaerobic decomposition of the glue wastes has been a continual
source of disturbance to the neighboring communities and has
thus been viewed as posing an adverse impact to their welfare.
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In the course of the RI it was determined that the odor threshold
for H2S was between 0.02-0.15 ppm for ambient conditions.
~ased on air modelling conditions found in Appendix C of the
FS, it was calculated that H2S concentrations found at the
nearest residential area under worst case conditions would
approach 0.187 ppm. Even at three kilometers downwind of the
Site under current conditions (i.e., no excavation), H2S
concentrations would exceed the lower detection level, allowing
odors to impact the public welfare.
Implementation of the no action alternative (A-l) would have no
.capital costs associated with it. The FS estimated $18,000
per year for a quarterly air monitoring program, resulting in
a present worth cost of approximately $171,000. If implemented
the alternative would permit the East Hide pile to continue
emitting obnoxious odors containing H2S, In addition to the
emission of odors, the physical disposition of the East pile
causes several additional impacts. The pile was initially
placed in a wetlands and as the pile increased in size, it
further encroached on the. pond and its associated wetlands.
presently the pile has unstable side slopes which result in
occasional sloughing of contaminants into the pond and adjacent
stream. In addition, as a result of inadequate cover material,
precipitation continues to percolate through the pile causing
leachate breakouts to impact the local surface water. These
leachate breakouts were observed following rainfall events and
were sampled as part of the RI. While analysis of surface
water exiting the pond conducted as part of the RI does not
indicate a significant adverse impact, clearly the potential
for future impacts exists as the pile continues to decompose,
causing additional contaminants to be released to the wetlands.
Because of the previously mentioned lack of adequate vegetative
cover, large erosion gullies are evident on the sides of the
pile, as the slopes moderate, the displaced soils begin to
form deltas in the wetlands. Together with the decomposition
of the organic matter in the pile this erosion is a contributing
factor to t~e sloughing of material into the wetland.
The implementation of this alternative is simple and straightforward
as it only requires development and implementation of a monitoring
program.
This alternative does not meet the applicable or relevant and
appropriate Federal public health and environmental requirements.
Continued leaching and sloughing of the pile would further impact
surface water quality and the wetlands in violation of the Federal
Clean Waters Act (CWA). Furthermore, the NCP permits that State
standards can be considered by the Agency in selecting remedies
at Superfund sites. The Agency believes that in this instance
the Massachusetts Regulations for the Control of Air pollution,
and specifically its regulation (310 CMR 7.09) prohibiting the
release of odors into the ambient air is both relevant and
appropriate for use at this site. (The reader is referred to
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for more detail supporting this decision). As previously discussed,
the pile continues to release odors even when there has been
.no excavation or sloughing occurring at the time.
It is important to note here that under the terms of their
Consent order, stauffer Chemical Company, the Agency and DEQE
have agreed that "odors originating on the site... shall be
deemed and addressed in the same manner as 'Hazardous Substances'"
as defined by CERCLA. It is also important to note that under
the existing S 106 Administrative order, stauffer is obligated
to treat the odors as hazardous substances and is obligated to
. implement or reimburse the Government for the costs of remedial
actions to abate the odors.
selection of the no action alternative would continue to permit
odors to be released impacting the environment and the surrounding
community's welfare. Continued leaching and sloughing of the
pile would further impact the wetlands. The no action alternative
does not involve any techniques which minimize, degrade or
recycle the waste.
A-2
Dewatering, slope modification, installation of synthetic
membrane, topsoil and vegetation.
Alternative S-2 utilizes several standard engineering techniques
to stabilize the pile and reduce the odor potential. specifically,
A-2 would reduce the mounded groundwater table within the pile
using two methods. The first involves installing a 60 inch
drainage system to dewater the pond and depress the local
groundwater table. Once drained the pond and associated lowlands
would be filled in order to establish a base for slope modification
and recontouring. Clean fill and fill from the south Hide pile
will be used to establish a three to one side slope on the
pile. Recontouring and shaping of the original pile would be
kept to a minimum in order to minimize the release of odors.
Following the stabilization of the pile, a six-inch layer of
sand, which~will serve as a bedding layer, will be placed over
the pile. A 20 mil thick PVC synthetic membrane will be placed
to form a.' cover impermeable to gases and liquids over the
waste deposit. This synthetic membrane is the second step to
reduce the mounded groundwater table within the pile. On top
of the membrane another six inches of sand followed by six
inches of topsoil will Oe placed to complete the remedial
action. A vegetative cover and surface water control and
diversion structures will also be included as part of the
~over design.
The RI determined that the generation of odors is controlled
-by five factors: moisture contained within the pile, anaerobic
decomposition of the organic material within the pile, sloughing
of side slopes, gas migration via pore spaces, and rapid changes
in Oarometric pressure. A-2 seeks to control four of the five
factors by dewatering the pile, utilizing the synthetic membrane
to prevent gas migration and precipitation infiltration, lowering
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the l~cal groundwater table by de~atering the pond, and stabilizing
the slde slopes to prevent sloughlng. A-2 does not involve
any gas venting and/or treatment system, nor does it attempt
to prevent decomposition of the wastes. The capital, operation
and maintenance and present worth costs are summarized in
Table 44.
This alternative meets the environmental and public health
goals for the Site by reducing the potential for direct contact,
odor generation and degradation of the wetlands and surface
.waters. The techniques used to obtain these objectives involve
standard civil engineering techniques and have an expected
useful life of 50 years. Operation and maintenance costs and
efforts are similar to those involving soil capping alternatives.
There is nothing in the characteristics of the wastes which
would adversely impact the alternative. .
Results of the RI indicate that the air emissions from the East
Hide Pile are adversely impacting the ambient air quality at
and around the Site, but are not currently presenting a threat
to public health and the environment. The continued emission
of the H2S and the other reduced sulfur compounds, with their
attendant odors, are adversely impacting the public welfare.
In addition to eliminating the potential for direct contact
and the impacts to the surface water the remedial actions
taken to abate the odors would also be addressing a threat to
the public welfare.
Alternative A-2 does not propose remedial actions to actively
eliminate the potential release of odors. Under this alternative,
elimination of odor potential relies on elimination of moisture
to interrupt the anaerobic decomposition cycle and on the
impermeable cap to trap the gases that are generated. Since
it is difficult to predict the relative importance of each
factor in the release of odor, the elimination of moisture
from the pile may not provide the degree of reliability
necessary t~.eliminate the odor. Further the synthetic liner,
while impermeable to the gases, will be tied into relatively
permeable "materials at the base of the pile. Trapped gases may
escape into the ambient air via this pathway. Elimination of
the odor's adverse impacts on the welfare of the surroundin~
community is considered a major component to the successful
resolution of the Site's problems.
This alternative does not use recycling, reduction or destruction
as a technique to minimize or eliminate the problems. The
alternative uses containment and monitoring as the means to
achieve the remedial objectives. Implementation of this alter-
native would also produce an adverse environmental impact.
Under this alternative the FS indicates that the abutting
wetlands would need to be drained and filled as part of the
remedial plan. The elimination of wetlands is prohibited
under both S 404(b) of CWA and Executive order 11990 unless it
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-55-
the event that a wetlands requires filling, mitigation techniques
must be implemented to compensate for the eliminated wetlands.
The FS indicates that a substantial portion of the groundwater
. mound results from the high groundwater table and artesian-like
conditions within the pile. Lowering the localized groundwater
table by draining the wetlands will reduce this mound. The
remaining reduction will result from the synthetic membrane.
In addition, the FS concluded that the drainage of the wetlands
was necessary in order to establish a good base for building
the necessary three to one side slopes. .
. The alternative uses standard engineering practices in implemen-
tation of the remedial action. Implementing it is simple and
straightforward. Care must be taken in field seaming the
synthetic membrane and in checking the integrity of the installed
membrane.
The overriding disadvantage of this alternative is that it
destroys the wetlands. A second disadvantage would be the
possible failure of the membrane resulting from gas pressure
building up beneath it, rupturing the liner. Another possible
disadvantage is that even if the membrane does not rupture the
pressurized gases may travel laterally out from under the edges
of the membrane and ultimately enter the ambient atomsphere.
A-3
Dewatering, slope modification, installation of synthetic
membrane, gas collection and treatment utilizin carbon
adsorption, topsoi an vegetate.
A-3 is exactly like A-2 except that A-3 includes installing a
gas collection and treatment system.
Prior to the installation of the synthetic liner a gas collection
sy&tem consisting of a series of six inch diameter PVC pipes
bedded in a twelve inch layer of gravel will be installed.
These pipes will be manifolded together to form a header pipe
which is connected to a blower system. The blower system
discharges into the influent of a treatment system. The
treatment. system proposed in A-3 consists of two stainless
steel tan~s connected in series containing activated carbon.
The odor containing air would be passed through an activated
carbon filter especially treated to remove H2S and mercaptans.
The use of a specially treated activated carbon makes this an
effective technique. The effectiveness of carbon adsorption is
dependent upon the polarity of the compounds to be removed.
For example, nonpolar organics such as benzene adsorb well.
Hydrogen sulfide, however, is polar and as a result, tends to
be absorbed well on standard activated carbon. The removal
-efficiency of carbon adsorption for hydrogen sulfide can be
increased by impregnating the carbon with metal oxides. several
types of carbon can be used dependent on influent conditions.
A Calgon metal impregnated activated carbon, specially formulated
for H2S and mercaptan adsorption in oxygen free atmoshperes,
Type FCA, could be used to adsorb emissions from a passive gas
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vent. However, the low emission rate would not ensure equal
distribution through the carbon, increasing the likelihood of
.early odor breakthrough. Therefore, a passive venting system
is unsuitable for carbon adsorption.
Another type of Calgon carbon specially treated for H2S and
mercaptan adsorption in the presence of oxygen, Type IVP,
could be used with an active venting system. Introduction of
air would ensure good distribution through the carbon bed
thereby prolonging the useful life of the system, reducing
methane concentrations below the 5-15 percent explosive range,
. and providing the oxygen atmosphere required for IVP adsorption.
Carbon may also act as a catalyst to oxidize hydrogen sulfide.
selection of the most appropriate type of carbon, sizing of the
system and other operating parameters will need to be defined
as part of the remedial design.
The effluent from the carbon treatment would be vented to the
atmosphere. If activated carbon treatment is chosen to remove
H2S, mercaptans, and volatile organic compounds (VOC) from the
East Hide pile, a monitoring plan should be developed in the
design phase to determine when breakthrough occurs. This will
ensure that the carbon is replaced before obnoxious odors and
elevated amounts of VOCs are emitted from the adsorber. The
remainder of this alternative would be the same as A-2.
Capital, operation and maintenance, and present worth costs
are summarized in Table 45.
Similar to A-2 this alternative uses standard engineering
applications to meet the stated objectives. The use of an
activated carbon treatment system is a well proven technique
which will effectively capture the H2S, rnercaptans and low
levels of volatile organics contained in the air emissions.
As a result the treatment technology effectively eliminates
the potential adverse impacts from air emissions.
Alternative~A-3 achieves the remedial objectives established
for the East Hide pile. Active collection and treatment system
will effectively eliminate any additional impact to the public
welfare, as discussed in connection with Alternative A-2.
releases. Stabilizing and covering the pile with an impermeable
membrane will eliminate the potential for direct public contact
with the wastes, will protect the surface waters from the
effects of sloughing and sedimentation, thus protecting the
~urface water quality from being degraded.
This alternative does not meet or exceed all the applicable or
~elevant and appropriate regulations because of the filling of
the wetlands. It will meet or exceed the applicable or relevant
and appropriate Federal and State requirements for the eliminate
of gaseous emissions, specifically odor.
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actual source creating the odor. As a result, the remedial
action will require O&M and monitoring until natural degradation
of the wastes is completed. Once the remedial action under
this alternative begins, the length of time for the pile to
.come into equilibrium cannot be predicted.
Dewatering, slope stabilization, gas collection and
treatment utilizing thermal oxidation followed b
instal ation of 20 mil PVC synthetlc membrane, cap
topsoil and vegetation.
This alternative is similar to A-3 except for the treatment
.method used to eliminate odors. Because methane gas, a
combustible gas, is a principal component of the pile's
emissions, thermal oxidation is a feasible alternative. The RI
measured emission rates from various locations within the pile
over time. These rates varied depending on weather conditions,
time of year and amount of recent precipitation. Based on
data collected, the FS screened various treatment scenarios
based on the emission rates of gases from the East Hide pile.
The FS concluded that either the treatment system proposed in
alternative A-3 or the one proposed in this alternative would
be equally effective in meeting the established remedial objectives.
The primary difference in selection of either alternative A-3 or
alternative A-4 is one of cost-effectiveness. The FS concluded
that alternative A-3 was more cost effective in removing the
odors than alternative A-4 if the rate of gaseous emissions
remained relatively low. If however, the emission rate exceeded
2 actual cubic feet per minute (ACFM) then alternative A-4 was
more cost effective than than alternative A-3. The treatment
system proposed under this alternative consists of a small pre-
manufactured incinerator unit using liquid propane as a supplemental
fuel to maintain an exit temperature between 1,400-1,600 OF.
At these temperatures the H2S would be thermally oxidized.
A-4
with
Since A-4 differs from A-3 only in its substitution of incineration
for carbon adsorption as the gas treatment system and since the
two treatment systems are equally effective, A-4 also meets the
remedial ob}ectives for the site.
The alternative uses well proven technologies to implement the
remedial action. The use of a small commercially available
incinerator makes the implementation of this alternative simple
and straight forward. As such, the alternative presents no
significant engineering or implementation problems and would
provide a high degree of reliability. All other construction
details are the same as evaluated in A-3.
The use of this alternative would pose the same impacts and
-concerns as the previous Alternative, A-3, including destroying
the wetland. Thus A-4 meets the applicable or relevant and
appropriate Federal public health and environmental requirements
for air but not for wetlands. Since the alternative uses
incineration, the H2S would be converted into S02. The FS
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Massachusetts primary and Secondary Ambient Air Standards,
developed in conformance with the Federal Clean Air Act (CAA).
If thermal oxidation is chosen to remove H2S, mercaptans, and
VOCs from the East Hide pile, a sampling and analysis plan
should be developed in the design phase for S02' particulates,
toxics, and VOCs to ensure the safety of the public and to
ensure that the National Ambient Air Quality Standards (NAAQS)
are not exceeded.
This alternative does not recycle, reuse, minimize or destroy
.the wastes.
A-S
Complete excavation and removal of the East Hide pile,
contain material in an on-slte RCRA landfill, gas
treatment.
Alternative A-5 involves the excavation of the entire East Hide
pile and relocation to an on-Site RCRA landfill. This alternative
was initially discussed as part of the S-7 alternative for
remediating soils contaminants. The capital, operation and
maintenance and present worth costs associated with this
alternative are found in Table 47.
While the East Hide pile could be excavated and transported
simply and directly to the new facility, the operation is
infeasible because of the intense short term adverse impacts
caused by the action itself. As stated previously, any
disturbance of these deposits releases a strong pungent and
obnoxious odor, creating a situation which would not be
tolerated by either the construction workers, area businesses
or the neighboring community. Also noted eariler, in spite
of numerous experiments, no way of excavating these materials
without generating odors was ever found. As a result, the
need to physically remove the piles in order to protect the
public health, welfare and environment is unwarranted given
these adverae impacts and attendant violations of DEQE air
regulations:
~
In addition to the adverse air impacts, implementing this
alternative would significantly impact the abutting surface waters
and wetlands. In the previous alternatives, the need to drain and
fill the pond in order to depress the local groundwater table
was an integral part of the proposed remedial action. under
this alternative, once the pile was removed there would not be
a need for groundwater table adjustment and as a result, at
least in theory, the pond and associated wetlands would not be
impacted. As a practical matter there would a substantial
adverse impact to the local surface waters and wetlands resulting
from this alternative. As stated throughout this document, the
East Hide pile is physcially located in and next to the pond
and wetlands. The physical size and location of the pile would
require a substantial earthmoving effort in order to accomplish
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roads would need to be constructed in order to be able to
effectively remove the deposits. A major portion of these
roads would be located in the wetlands, around the pile and in
. parts of the pond, effectively destroying the wetlands and pond.
In addition, sedimentation and erosion control would be a major
concern for those portions of the wetlands and pond remaining.
This alternative does not effectively involve the reuse,
recycling, minimization or destruction of the wastes, rather it
seeks to eliminate the present and future potential threats to
the public health and environment through the use of containment
. techniques.
~6
Complete excavation and off-site removal of East Hide
pile to a RCRA approved faclllty.
Alternative A-6 was evaluated as part of the screening process.
The alternative did not receive a detailed analysis because the
FS screened it out. However, it is included and briefly discussed
here as a benchmark for the upper range of remedial actions.
Alternative A-6 involved the excavation and off-site disposal of
the East Hide pile. The waste would be transported to an
approved RCRA landfill for disposal. The capital costs associated
with this alternative are $35.86 million.
The public health and environmental impacts of this alternative
are similar to those previously outlined in alternative A-5.
F.
Development and screening of Groundwater Alternatives
Two plumes of contaminated groundwater were detected in the
southeastern portion of the Site during the Phase II remedial
investigation. The plumes, of unknown origin, containing
volatile organic compounds (benzene and toluene) have migrated
off-site and if left untreated would ultimately impact the Wells
G&H aquifer that yielded water to the former municipal water
supply wells. The FS evaluated a n~mber of alternatives to
minimize or ~liminate the present and future potential impacts
to the pub'lic health, welfare and environment resulting from
these plumes. Listed below are the alternatives initially screened
pursuant to S 300.68(g) of the NCP.
GROUNDWATER ALTERNATIVES
No Action
. Groundwater Interception/Recovery
Slurry wall around site perimeter tied intb possible underlying
confining strata.
Slurry wall at north end of Site tied into possible underlying
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Slurry wall across southern boundary of Site tied into
possible underlying confining strata.
Slurry wall across southern boundary of Site and along East
and West Site boundaries, south of hide piles to mid Site
and tied into possible underlying confining strata.
Slurry wall around detected groundwater plume near wells OW-
12 and SD-55.
Slurry wall across northern boundary and southern boundary of
the Site tied into possible underlying confining strata.
Grout curtain around entire Site anchored in bedrock.
Grout curtain across northern boundary of Site anchored in bedrock.
Grout curtain across southern boundary of Site anchored in bedrock.
Grout curtain across southern and northern boundaries anchored
in bedrock.
Grout curtain around detected groundwater plume near wells
OW-l2 and SD-55.
Bottom seal under entire Site by injection of a g~out curtain
base layer.
pump groundwater via recovery well system along entire.
perimeter of the site.
pump groundwater via recovery well system along northern
boundary of the Site.
pump groundwater via recovery well system along southern
boundary of the Site.
pump gro~ndwater via recovery well system in the vicinity
of the. detected groundwater plume near wells OW-l2, SD-55,
and OW-6.
pump groundwater via recovery well system along the northern
and southern boundaries of the Site.
Construct interception trench along northern boundary of Site
be tween East/West Hide piles and wetlands.
Construct interception trench along northern and southern
boundary of site.
Construct interception trench along southern boundary of site.
Construct interception trenches downgradient of detected
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Groundwater Treatment
-
Treat recovered groundwater with air stripping column for
VOC removal.
Treat recovered groundwater with granular activated carbon
(GAC) columns for removal of adsorbable organic compounds.
Treat recovered" groundwater with powdered activated carbon
(PAC) for removal of adsorbable organic compounds.
Treat recovered groundwater with oxidizing agent for odor
destruction.
Treat recovered groundwater with ion exchanJe resins for
cation and anion removal.
Treat recovered groundwater with suspended or attached
growth biological reactors for removal of biochemical oxygen
dema nd (BOD)
Treat recovered groundwater with air stripping column and
with PAC.
Treat recovered groundwater with reverse osmosis for multi-
compound removal.
Treat recovered groundwater with pH adjustment/precipitation-
flocculation/sedimentation for metals removal.
Install permeable treatment beds (GAC) downgradient of East
and West Hide piles.
Install permeable treatment beds (GAC) downgradient of wells -
OW-12 and SO-55.
Install ~ermeable treatment beds (GAC) along down~radient
boundary of site.
Groundwater Discharge
Direct discharge to MDC sewer.
..
.Treatment, discharge to MDC sewer.
-
Direct discharge to downgradient surface water body.
Treatment, discharge to downgradient surface water body.
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Alternatives capable of eliminating or minimizing the impact to
the aquifer resulting from the organics plume were subjected to
an initial screening broke into three sections: groundwater
interception/recovery, groundwater treatment and discharge of
groundwater to the environment.
The use of containment barriers, slurry walls or grout curtains
both with and withqut groundwater pumping were evaluated for
application at the Site. Various combinations of these
techniques were evaluated. The intent of containment technique
is to control and contain either the contaminant itself or
the upgradient groundwater so that the contaminant can be
pumped from the aquifer in the most efficient manner without
inducing a large amount of uncontaminated groundwater into the
collection system. The effectiveness of this technique is
lar~ely dependent on the ability to seal the containing structure
against an impermeable layer, such as bedrock or till. Geologic
conditions at the site make implementation of this technology
difficult. The bedrock to the east, west, and south of the Site
is pervasively fractured, permeable and dips steeply. As a
result, it would not be suitable as an impermeable layer into
which to tie a barrier. In addition, the Agency has found that
slurry walls tend to leak, allowing contaminants to be continued
to be released to the environment. Slurry walls, therefore,
will not meet the groundwater clean-up objective. For these
reasons containment barriers were excluded from additional
consideration.
Water table adjustment to minimize groundwater flow through the
waste deposits was subject to the initial screening process.
This alternative uses either interceptor wells to extract
groundwater or subsurface drains to depress the level of
groundwater below the waste deposit. Diverting the groundwater
below the deposit greatly reduces the leaching potential. The
technique remains effective so long as there is continued
extraction of groundwater at a sufficient rate to keep the
groundwater~table depressed. This technique is usually used
in conjunction with impermeable cover to eliminate the effects
of precipitation.
The water table adjustment technique is most efficient when the
source of the groundwater plume is fairly large, in contact
with the groundwater and will continue to leach into the
groundwater if allowed to remain. Maximum effectiveness then
occurs when low pumping rates produce a significant lowerin~ of
~he water table. Neither case is found on-site. The RI
investigation failed to locate a source of the organics
impacting the groundwater. In order to make this technique
"effective, an impermeable cover would need to be placed over
the entire Site in order to reduce the amount of precipitation
leaching organics into the groundwater. Site conditions and
the nature and extent of the plumes cause this technique to be
excluded from further consideration based on acceptable
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The next component of the screening process was the evaluation
,of possible treatment alternatives. The FS screened twelve
groundwater treatment processes for possible use at the Site.
These twelve processes were evaluated as unit operations capable
of being combined in some manner to form a treatment system
which would effectively treat the contaminated groundwater.
AS a result, the initial screening focused more on the use of
specific technologies to treat contaminants than discrete and
complete treatment systems. The detailed analysis of groundwater
.alternatives does address complete treatment systems and
not unit processes. Of the twelve unit processes initially
screened, four' were eliminated from further consideration. The
reasons why they were excluded are summarized below.
Treatment of the recovered groundwater with ion exchange resins
was evaluated and excluded based on cost and acceptable
engineering practices. The use of ion exchange resins is
particularly effective for the metals and considerably less
effective for volatile organic compounds such as those found
in the groundwater on-site. Because the primary contaminants
of concern are volatile organics and not metals, the application
of ion exchange is not effective.
Treatment of the groundwater using reverse osmosis was also
evaluated. osmosis is the flow of a solvent (e.g., water)
from a dilute solution through a semipermeable membrane
(dissolved contaminants permeate at a much slower rate) to a
more concentrated solution. Reverse osmosis is the application
of sufficient pressure to the concentrated solution to overcome
the osmotic pressure and force the net flow of water through
the membrane toward the dilute phase. This allows the
concentration of solute (contaminants) to build up on the
one side of the membrane while relatively pure water is
transported through the membr~ne. Ions and small mol~cules in
solution can be separated from water by this technique.
The basic components of a reverse osmosis unit are the membrane,
a membran~ support structure, a containing vessel, and a high
pressure pump. The membrane and membrane support structure are
the most critical elements.
The use of reverse osmosis is usually limited to polishing low
flow waste streams containing high concentrations of contaminants.
Because reverse osmosis is extremely sensitive to fouling,
plugging and chemical attack, it requires extensive pretreatment
and careful operation to ensure effective removal. Because of
.these concerns and associated costs, the FS excluded reverse
osmosis from further consideration based on acceptable
engineering practices and cost.
The use of powdered activated carbon (PAC) was evaluated as was
granular activated carbon (GAC). GAC was retained for further
evaluation, but PAC was eliminated because it did not offer
an increase in environmental effectiveness but did have higher
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operation and maintenance (O&M) costs associated with it.
At sites where the contaminated groundwater is relatively
shallow, the use of permeable treatment beds may be an effective
method to intercept and treat the groundwater. The beds are
built by excavating a trench downgradient of and perpendicular
to the flow of contaminated groundwater and backfilling it with
a media which is capable of either chemically or physically
removing the contaminant. The use of this technology was
rejected for use at the Site based on acceptable engineering
practices and effectiveness. The permeable treatment
beds are subject to plugging, saturation of the media, and
short circuiting. As a result the beds would not provide the
10ng term treatment or reliability necessary to ensure effective
removal of the contaminants.
The last component evaluated during the screening of groundwater
alternatives was the discharge of the treated effluent.
Each alternative was evaluated for acceptable engineering
practices, effectiveness and costs. Differences in cost was
not a significant factor for this portion of the evaluation.
The first alternative evaluated was the discharge of the treated
effluent to the Metropolitan District Commission (MDC) sewer.
A major MDC interceptor sewer line is located on-site
paralleling the train tracks. The FS evaluated the feasibility
of this alternative but rejected it based on effectiveness.
Several factors serve as the basis for its rejection. First,
the MDC regulations prohibit the discharge of groundwater into
its system. More importantly is the fact the MDC operates a
regional system of which only a relatively small percentage of
the wastes received treatment. This small percentage receives
primary treatment prior to discharge into Boston Harbor.
primary treatment is ineffective in removing the contaminants of
concern. Finally the system is old, in various states of disrepair
and generally overloaded. During a major storm event, many of
the system's sewer lines surcharge, dumping untreated waste
into the surrounding environment. Even though the anticipated
discharge would be an insignificant portion of the total flow
handled by ~he system, the alternative does little to effectively
contribut~ to the protection of public health and welfare and
the environment. .
The FS evaluated the disposal of the treated effluent by
recharging it to the aquifer using a trench or leachfield. This
alternative is unsuitable for use in situations involving
large quantities of treated effluent, except in limited appli-
cations.
The aquifer in the general Site area is relatively shallow.
a result the aquifer has a limited capacity to accept the
introduction of large quantities of water over a short period
of time. Any discharge from a treatment system would be
limited to approximately 50-100 gallons per minute (gpm).
Quantities in excess of these values would cause ponding and
flooding to occur. .
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The anticipated discha~ges from the treatment plants are
projected to be greater than the ability of the aquifer to
,assimilate the discharge; as a result, this alternative was
dropped from further consideration, based on acceptable
engineering practices.
Discharge to the aquifer downgradient of the Site via an
injection well was rejected for same reasons.
G.
Detailed Analysis for Groundwater Alternatives
'The FS retained three alternatives for detailed evaluation
involving remediation of the groundwater. The alternatives,
labelled GW-2, GW-J and GW-4 involve various interception,
treatment and discharge options necessary to minimize or
eliminate the present or future threat to the public health,
welfare and environment posed by the organic plume in the ground-
water. Similar to the previous evaluations, the no action
alternative, GW-l, was not specifically delineated in the FS.
For the purposes of the ROD the no action alternative will be
cons idered.
Again, similar to the previous media discussed, the ground-
water remedial alternatives retained for detailed analysis have
been renumbered for readibility.
New Number
,Old number found in RI/FS
GW-2
Not specifically addressed in
FS as a discrete remedial
alternative.
option 1, on-Site, hot-spot
recovery groundwater ,plume
GW-l Shall be considered the
No Action Alternative
GW-3
~.
option 2, Recovery at Site
Boundary of groundwater
plume
,"
GW-4
option 3, Recovery
downgradient of Site of
groundwater plume
It should be noted that FS evaluated a number of unit processes
~or a treatment system. FS assumes that any combination of
unit processes could be applied to each alternative above.
GW-l
NO'Action Alternative
The no action alternative allows the existing plumes to
to migrate off-site unabated. 'The -only action required
involve the periodic monitoring of groundwater quality,
to track the downgradient migration of the plume and to
continue
would
both
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any significant changes in the status of the plumes which might
require additional actions to be taken. under this alternative
the plumes would continue to impact groundwater quality, not
only immediately downgradient of the Site, but by ultimately
reaching Wells G and H aquifer. As stated earlier, Wells G
and H once served as a municipal water supply prior to detection
of contamination.
According to costs developed from Appendix I and summarized in
Table 52, the quarterly monitoring costs would be $90,000 per
.year with a present worth costs (assuming a 10% discount rate
and a 30 year monitoring period) of approximately $850,000.
There are no operation and maintenance costs associated with
this alternative except for any monitoring system installed as
part of the overall Site remediation.
Discussion of engineering implementation, reliability and
constructability is inappropriate, as this is a no action
alternative.
The no action alternative does not effectively prevent,
mitigate, or minimize threats to, and provide adequate protection
of public health and welfare and the environment. under this
alternative, contaminants would continue to be released to the
off-site environment permitting an adverse impact to the
downgradient groundwater quality. In addition, the alternative
would not comply with applicable or relevant and appropriate
Federal public health and environmental requirements. The use
of the groundwater protection standards under RCRA part 264
Subpart F, while not applicable would be relevant and appropriate.
These standards require that groundwater leaving a Site
must meet either background levels, alternate concentration
limits (ACLs) or Maximum Contaminant Levels (MCLs) established
under the safe Drinking Water Act (SDWA). The FS concluded
that under this alternative, levels of benzene found at Well G
would range between 5 to 10 ppb, above the MCL of 5ppb and
well above the RMCL of zero.
,,'
In addition to the requirements under RCRA, the Agency's
groundwater protection Strategy (GWPS) would require clean up
to similar levels. (The reader is referred to the Consistency
with Other Environmental Requirements section for more detail.)
This alternative does not reuse, recycle, minimize of destroy
the contaminants, nor does it employ the use of advanced or
~nnovative technologies.
Jmplementation of this alternative would not pose any adverse
environmental impacts.
Q!t:l
Groundwater interception/recovery of on-site "hot spot"
areas.
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recovery wells in the vicinity of the highest detected concentration
of benzene. With proper well placement the FS calculated that
approximately 80% of the benzene detected would be extracted
,from the groundwater over a three month period. In addition
to the benzene a substantial portion of the toluene would also
be captured. The exact number and location of the wells would
be determined as part of the Remedial Design (RD) process. The
prime criteria to be resolved in the RD is maximizing the
contaminant capture while minimizing the length of pumping required.
The captured groundwater would be treated to eliminate
potential obnoxious odors. Treatment would consist of the
, addition of ferric chloride and hydrogen peroxide as strong
oxidizing agents to quickly break down odor causing sulfur
compounds. This treatment would be followed by the use of two
counter flow air stripping towers. The use of this type of
treatment is particularly effective (99+ % removal) for the
compounds identified in the groundwater7 The effluent of the
treatment system would be discharged upgradient of the plumes
via a subsurface leachfield. The costs associated with this
alternative are summarized in Table 22.
The implementation of this alternative uses conventional
engineering technologies and is simple and straightforward 'to
implement. The application of groundwater recovery wells,
odor abatement and air stripping for volatile organic compounds
(VOCs) are all well established and proven techniques. While
subsurface discharge is a proven technology, its success
is dependent of a number of factors. Typically the primary
problem with subsurface discharge is the clogging at the
reinjection point from a stimulated bacterial growth. In the
case of Industri-plex, bacterial growth is of real concern
due to the presence of a high BOD detected in the on-site
groundwater. In addition the presence of a high groundwater
tab,l~ may cause ponding of the leaching trench at the anticipated
discharge rates. on the positive side, discharge to the aquifer
upgradient of the plume will increase the hydraulic gradient
and thereby decrease the required pumping times. By discharging
upgradient ~ higher degree of protection from treatment process
upsets would be provided as the effluent would be recycled
through the system. The overall effectiveness of this alternative
would not be materially affected if the surface discharge
portion of the alternative was eliminated. Discharge to surface
water would be substituted.
This alternative will eff~ctively prevent, mitigat~, or minimize
threats to, and provide adequate protection of the public
health and welfare. It is marginally protective of the environment.
Currently the aquifer underlying the site is unused as a potable
"water source and only used by several industries as non-contact
cooling water. AS a result, at present there is no impact to
the public health and welfare. While groundwater analysis
indicates that the plumes have migrated off-site impacting the
environment, surface water quality sampling has failed to
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to nearby streams or Hall's Brook Storage Area. The relatively
low capital costs, associated lower O&M costs and relatively
short length to complete (estimated at 6 months) make this
alternative attractive. The alternative, however, does not
meet the applicable or relevant and appropriate Federal public
health and environmental requirements for the Site. While
this alternative would effectively remove approximately 80% of
the contaminants from the groundwater, the remaining 20%
would be allowed to migrate off-site. As previously noted in
alternative GW-l, off-Site migration of contaminants would not
comply with RCRA nor meet the intent of the groundwater protection
S t rat eg y .
The alternative uses treatment of groundwater as a technique to
minimize present and future adverse impacts on the groundwater
underlying the Site.
Implementation of GW-2 does not pose any significant adverse
environmental impacts. However there are several issues which
need to resolved as part of the RD. These include, accurate
definition of the "hot spot" area so that the type, number and
location of recovery wells can be determined, sizing of the
treatment system and further investigation as to the feasibility
of the use of a subsurface discharge.
Groundwater interception/recovery at Site boundary,
treatment with surface water discharge
The implementation of GW-3 is similiar to that of GW-2 except
for the location of the interception system. Alternative GW-3
would intercept the groundwater at the southern boundary of
the Site, thereby preventing any further off-site impact.
The RI calculated that placement of five interceptor recovery
wells with a total pumping rate of 110 gpm would remove
approximately 95% of the benzene within a ten year operating
period.
GW-3
Once collected the recovered groundwater would require treatment.
The sampling" results from the monitoring wells located along
the south~rn edge of the Site contained high values (300 ppm)
of biochemical oxygen demand (BOD). The study concluded that
the probable source of the high BOD was the organic materials
leaching f.rom the buried hide deposits. The FS determined
that, in addition to odor control and VOC removal, BOD treatment
would be required in order to minimize clogging of the air
stripping towers and to meet NPDES requirements. The FS
concluded that use of a Rotating Biological Contactor
(RBC) unit would ~rovide effective reduction in BOD while
minimizing O&M costs and susceptability to shock loadings.
The remainder of the treatment process is similar to that of
GW-2. Discharge of the treated effluent will be to the local
surface water. Costs and specifications for GW-3 can be located
in Tables 23 and 24.
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of GW-2 and does not present any significant implementation
problems. Concerns similar to those noted in GW-2, such as
the design of the recovery well system will be'resolved as part
of the Remedial Design.
Similar to alternative GW-2 this alternative was found to meet
the remedial objectives established for the Site and like GW-2
this alternative does not meet all applicable or relevant 'and
appropriate Federal public health and environmental requirements.
The FS calculated that using this alternative would reduce the
-concentration of benzene at well G below the MCL of 5 ppb.
However RCRA and the GWPS require that the MCL criteria be
applied to the aquifer immediately downgradient of the site as
a potential receptor of concern, not an actual receptor, We-lls
G and H. As a result, this alternative would not meet the relevant
and appropriate requirements.
The FS determined that the effluent from the treatment system
is capable of meeting NPDES standards and Water Quality Criteria
and therefore would not degrade the local surface water. (see
consistency with Other Environmental Requirements section).
Similar to the previous alternative, this alternative uses treatment
of groundwater as an effective technology to minimize present and
future adverse impacts to the public health, welfare and
environment resulting from contaminated groundwater.
Implementation of GW-2 does not pose any significant adverse
environmental impacts.
GW-4
Groundwater Interception/recovery at the leading edge of
the plume, treatment and surface water discharge.
Alternative GW-4 uses the same basic framework as the previous
alternatives. The primary difference is in the placement of
the interceptor/recovery well system and the degree of treatment
required in order to meet discharge requirements and effectively
treat the wastes. In alternative GW-4 the interceptor/recovery
well system is placed at the leading edge of the plume so as to
capture the contaminants in their entirety. As a result,
virtually all the contaminated groundwater is captured and
pumped to the surface for treatment. Based on results from
the monitoring wells, the FS concluded that metals removal for
zinc, in addition to odor and VOC control, was necessary to
meet water quality standards prior to surface water discharge.
The FS determined that the Sulfex process for zinc removal was
the most suitable treatment system for reducing the concentration
of zinc to meet the standard. The metal removal process will
be placed after odor control and prior to BOD removal.
The remaining treatment system is the same as described in GW-3
except in size. With the increase in recovery system size (a
result of more groundwater to treat) and the addition of the
Sulfex process, the disposal of waste sludges generated by the
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the ease of implementation and reliability is similar to that
of the previous groundwater alternatives.
This alternative is protective of the public health and welfare
and the environment. It meets or exceeds the remedial objectives
established for the site. Because the alternative is designed
to capture the entire plume it will effectively prevent, mitigate
and eliminate any present or future threat to the public health,
welfare and environment. Of the groundwater alternatives
evaluated, this alternative, GW-4, meets all applicable or
. relevant and appropriate Federal public health and environmental
requirements.
The use of GW-4 eliminates any potential impacts to the aquifer
by using containment and disposal techniques. These techniques
are acceptable and proven technologies for removing and treating
contaminants from the groundwater. The alternative does not
recycle,reuse or destroy the wastes, rather it eliminates the
adverse impacts by stripping the VOCs from the groundwater and
utilizing the assimilative capacity of the ambient atomsphere
to prevent future environmental impacts. As a result, the
benzene plume will ultimately be removed from potentially
impacting the aquifer directly downgradient of the site as
well as the Wells G and H aquifer. The length of time required
to completely remove all the contaminants of concern was not
estimated in the FS. However the FS did estimate that it
would take approximately ten years to complete one flush
cycle in the contaminated portion of the aquifer. Data on
transmissivity, storage coefficient and aquifer yield gathered
as part of the RD will enable a better prediction as to length
of time required to clean the aquifer.
This alternative, similar to GW-3, has several potentially
adverse impacts. while the remedy effectively controls or
eliminates the impacts to the aquifer resulting from the Site,
neither alternative adequately addresses ongoing and potential
problems around the Site. The increased capital and operation
and maintenance costs, increased period of performance required
to meet objectives and the potential of the need to handle a
hazardous waste sludge make this alternative of questionable
benefit as an remedy. In addition to the above noted concerns,
the RI calculated that there was likely to be a localized
lowering of the groundwater table as the result of the
substantial pumping required for the interception/recovery
network to be effective. This decrease in the localized water
table may partially dewater portions of wetlands located south
of the Site.
V.
COMMUNITY RELATIONS
The Industri-plex 128 site was one of the first sites identified
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within the Region on the NPL while another site (Wells G&H)
associated with childhood leukemia was located just south of
this site. As a result public and media attention as well as
community involvement has always been very high.
In April 1980, the Massachusetts secretary of Environmental
Affairs formed a Citizens Advisory Committee (CAC) under a
provision in the Massachusetts Environmental pOlicy Act (MEPA).
The committee, consisting of representatives of the city, local
residents, ad hoc environmental groups, the Chamber of Commerce
.and surrounding towns, has met on a regular basis to be briefed
by regulatory personnel, comment and have input on draft
proposals or reports. By all standards the involvement of the
CAC has been an outstanding success in allowing the impacted
community to be involved in the decision making process while
allowing the regulatory agencies to have a better understanding
of the needs and feelings of the community.
In addition to the CAC, the Agency has held numerous public
meetings. upon completion of the RI/FS the Agency held a formal
public Hearing on the RI/FS in July 1985. Comments received
with Agency responses are appended in the Responsiveness Summary.
VI.
CONSISTENCY WITH OTHER ENVIRONMENTAL REQUIREMENTS
The CERCLA Compliance with Other Environmental Statutes policy
requires that subject to limited exceptions, superfund remedies
shall attain or exceed applicable or relevant and appropriate
Federal environmental and public health requirements in CERCLA
response actions. This policy is embodied in 40 CFR S300.68(h)(iv)
which requires as part of the detailed analysis of alternatives an
evaluation of the extent to which the alternatives attain or
exceed the applicable or relevant and appropriate requirements
(ARARS). Where the FS was initiated but the remedy not selected as
of the october 2, 1985 effective date of the policy, the ARARS
analysis was to be incorporated into the FS and Record of Decision
(ROD) as practicable.
A review of applicable or relevant and appropriate Federal public
health and environmental requirements was conducted as part of the
FS. This evaluation was deficient with respect to S300.68(i) of
the NCP, dated November 20, 1985. AS a result, the Agency undertook
an independent review of the requirements to determine their possible
implementation at the site. Summarized below are the findings for
each environmental media requiring remedial action.
. As applied to this case there are three types of ARARs: cleanup
~evels of hazardous substances, cleanup technology requirements and
requirements triggered by the implementation of cleanup activities.
soils
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establishing cleanup levels.
'With respect to cleanup technologies, RCRA requirements were reviewed
as potential ARARs. As the wastes were disposed of ~rior to the
effective implementation date of the RCRA waste management regulations,
RCRA was determined not to be applicable. If the wastes on-site
were either a listed waste or met the characteristic waste tests,
then all the waste management requirements of RCRA would be relevant
and appropriate. The metal wastes found on-site are neither listed
nor meet the characteristic tests. However certain technological
,engineering concepts were viewed to be relevant and appropriate.
RCRA closure requirements call for impermeable covers for landfills.
The rationale for this technology is that an impermeable cover
eliminates the potential for direct contact and mitigates adverse
groundwater impacts resulting from percolation of precipitation
through the wastes. Results from the RI indicate that percolation
of precipitation through the metal wastes at this Site is not
presenting a significant impact to off-site groundwater. As a
result the requirement of impermeability is not relevant and
appropriate to capping technology at this Site. However, the use
of a cap is appropriate to eliminate the potential for direct
contact.
For alternatives that cap wastes in-situ or consolidate wastes
elsewhere on-site, sections of Part 264 Subpart G involving closure
and post closure care are also relevant and appropriate for use at
this site. Part 264 Subpart G requires a written closure plan for
the Site, establishes a period of post-closure care (30 y~ars) and
use of the property and outlines maintenance and monitoring
requirements. In addition, this Subpart outlines a procedure for
documenting the location of the wastes to ensure against accidental
disturbance. The primary purpose of this subpart is to ensure
that the effectiveness of the remedial action is maintained and
that, in the event of a problem it is quickly detected and resolved.
Implementation of several of the alternatives considered in the FS
would trigger other ARARs. For instance: Alternatives that require
discharge of fill material to a wetlands trigger CWA ~404(b)(1)
guidelines. In addition, Federal actions involving wetlands are
subject to the conditions of Executive order 11990. The essence oE
these two requirements is to prohibit the filling or impacting of a
wetlands unless no other practicable alternative exists and to
mandate mitigative measures where actions in wetlands are taken.
The implementation of the two requirements, noted above, involve
areas of the Site where waste deposits are in direct contact with
surface waters and wetlands. Specifically, these areas are the
-pond located between the East and West Hide Pile along with the
stream discharging from the pond, the drainage ditch paralleling
New Boston Street and the drainage swale next to the Chromium
Lagoon area, draining into the Hall's Brook Storage Area. In each
area, waste deposits are in direct contact with surface waters and
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materials being placed into the wetlands during initial disposal
or a drainage ditch being excavated through a waste deposit during
Site development. In any event, the presence of these wastes in
contact with the wetlands permits the continued release of
contaminants to the environment. In order to eliminate this on-
going release or threat of release, the waste material must be
physically separated from direct contact with the surface waters
and wetlands. Basically there are two methods for accomplishing
this goal. The first involves excavating the material from
.the surface waters and wetlands and then placing the excavated
materials in an uplands area. Excavation and removal of this
material to an uplands would comply with S404(b)(1) of the
CWA, as it only regulates the discharge of dredge or fill
material into a wetlands, not the removal of the material.
The second method involves the placement of either clean fill
material or piping into the surface waters or wetlands to
physically separate the wastes from the media. If the former
alternative was available and practicaOle for use in a particular
application, then this latter alternative would not comply with
S404(o)(1) as it involves the placement of fill material into a
wetlands. Neither alternative would comply with the intent of
Executive Order 11990. This is because the Executive order 11990
is much broader in scope than S404(O)(1). The Executive Order
addresses any action (excavation or filling) which might adversely
impact the wetlands.
The no action alternative, S-l, is the only remedial action
which'would not adversely disturb and impact the wetlands,
thereby complying with S404(b)(1) and the Executive order 11990.
under this alternative, the waste materials would be allowed to
remain in, and adjacent to, the surface waters and wetlands.
This would allow the continued release or threat of release to
the environment. In addition, the alternative would leave
exposed levels of toxic metals in excess of action levels
determined to be protective of the public health and welfare.
Due to the nature of the site, there exists a real potential
for individuals to come in direct contact with these exposed
wastes. As a result of the continued release or threat of release
to the public health and welfare and the environment the Agency
rejected the no action alternative as not being protective and
not meeting the established goals for the Site. AS a result of
this determination, the Agency has determined that there is no
practicable alternative that exists which would comply with the
Executive order 11990 and not impact the wetlands. The Agency
believes, however, that there remain alternatives that can be
. structured in such a manner as to minimize potential harm to the
~etlands using mitigative measures and to compensate for any impact
as required under S404(b)(1). For metal wastes, the deposits can
be dredged from the wetlands, thereby complying with S404(b)(1)
requirements: however, for the West Hide pile this dredge alternative
is not practicable because of the potential for release of obnoxious
odors. As a result, in order to stabilize the side slopes of the
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w ill be
howeve r
section
will be
required. The exact quantities are currently not known,
the projected areas of concern are detailed in the appropriat
and compliance with the technical requirements of S404(b)(1)
incorporated into the Remedial Design process.
The National Ambient Air Quality Standards (NAAQS) of the Clean Air
Act (CWA) may be applicable to alternatives involving the removal
or placement of materials, either clean or waste deposits.
The Standards, listed below, are mandatory goals for non-attainment
areas to protect both the public health (primary standards) and
'welfare (secondary standards). The Total Suspended particulates
and Lead standards would be applicable during the excavation of
waste material or the placement of cover material at the Site.
Applicable National Air Quality Standards
pollutant Averag ing Time primary Standard secondary
Standard
Total Annual 75 ug/m3
suspended 24 Hours 260 ug/m3 150 ug/m3
particulates
Lead Quarterly 1. 5 ug/m3 same
During test pit excavation the RI collected and analyzed ambient
air samples for these parameters to determine if a violation of
the NAAQS standards existed. Results indicate that all remedial
alternatives would be well below the standards.
In addition to the NAAQS requirements, the unit Risk values developed
by EPA's carcinogenic Assessment Group were considered for use at
the Site as a relevant and appropriate guideline under the CAA.
Although referred to, at several points within the document, as an
ARAR, the unit Risk values fall within the category of standards
that are "to be considered by the Agency". The definition of unit
Risk is the increased lifetime cancer risk occurring in a hypothetical
population in which all individuals are exposed continously from
birth throughout their lifetimes to a concentration of one ug/m3
of the agent in the air they breathe. A lifetime is considered to
be 70 years. These are considered guidelines and not requirements.
Application at this site could potentially apply during excavation
and removal.
Chemical unit Risk
Benzene 8.0 x 10-6
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Chemical
unit Risk
Nickel
3.0 x 10-4
Toluene
NA
Results from the RI indicate that air emissions from implementation
of any of the soils alternatives would be well below the established
guidelines for the Unit Risk.
In addition to the relevant and appropriate requirements for the
protection of the wetlands, National Ambient Water Quality Criteria
.may be relevant and appropriate for alternatives which involve the
release or potential for release of contaminants to the surface
water. under the Clean Water Act (CWA) the Massachusetts Water
Quality standards are federally enforceable standards and would be
applicable. In the absence of a numeric standard for a given
substance in the State Water Quality Standards, the criterion is,
under CERCLA policy, deemed relevant and therefore to be considered
in the selection of the remedy. Listed below are the National
Ambient Water Quality Criteria.
Arsenic
Concentration
( ppm ).~.
<10 min
288 avg
30,800 max
Chronic
4 day avg/3 yr
(ug/l)
Acute
1 hr avg/3 yr
( ug/ 1 )
Compound
190
360
Lead
ND min
1,263 avg
54,400 max
1.3
34
Chromium
<10 min
718 avg
8 0 , 6 0 0 m ax
120 (11)2
980 (16)2
Zinc
47
159
Copper
6.5
9.2
Mercury
0.012
2.4
Benzene
5,300
Toluene
17 ,500
di(ethyhexyl)
.phthalate
3
940
Phenol
2,560
10,200
1-
2.
Criteria variable: toxicity is dependent on hardness
Values within ( ) are for hexavalent chromium, other values
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These criteria are used to ensure that the surrounding water
quality is not adversely impacted during or after the implementation
of the remedial action. Efforts to minimize any potential threat
of release or impact to the surrounding water quality would be
incorporated as part of the Remedial Design process. For example,
use of sedimentation basins and erosion control fabric are two
possible techniques to prevent a surface water quality impact from
occurring.
As stated previously, with the exception of the no action
. alternative, S-l, no alternatives will meet all the applicable
or relevant and appropriate Federal public health and environmental
requirements. Alternatives S-2, S-3, S-4, S-5, 5-6, S-7, S-8,
S-9, S-ll, S-12 and S-13 would closely approach the level of
protection provided by the applicable or relevant and appropriate
Federal public health and environmental requirements.
Alternative S-ll, the recommended remedial action, would comply
with the applicable or relevant and appropriate Federal public
health and environmental requirements. Because no practicable
alternative exists which does not impact the wetlands, compliance
with the mitigative measures required under S404(b)(1) will be
required during the implementation of this alternative.
unlike some alternatives which include consolidation or removal as
part of the remediation, Alternative S-ll seeks to meet the wetland
requirements by leaving the majority of the waste deposits in-situ.
This would minimize the effects of sedimentation, erosion and the
need to construct access and egress roads in and around the wetlands.
Under the consolidation/removal alternatives the majority of the
wetlands and surface waters would either be destroyed or altered
during the implementation of the alternative. under alternative
S-ll waste deposits from the area south of the East and West Hide
Piles which were in direct contact with surface water and/or
wetlands would carefully be excavated, using a drag line. Sufficient
quantity of material would be removed in order to allow limited
placement of clean fill material to form a dike or berm between
the surface waters or wetlands and the remaining waste deposits.
The amount of waste material excavated would be in excess of the
amount of clean fill material placed yielding a net positive
increase in flood storage capacity and increasing the area for the
affected wetlands to reestablish itself. The excavated material
would be located in an upland area, eliminating any future impacts.
In addition, the Agency shall also act to restore and preserve the
natural and beneficial values of the wetlands.
Air
............
With respect to air contamination there are three ARARs establishing
cleanup levels at the site. First, as noted under the soils ARARS
section, they are the NAAQS requirements. These standards would be
applicable for use at this site to ensure that the ambient air
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treatment system.
Listed below are the a~pro~riate standards.
Applicable National Air Quality standards
poll u tan t Averag ing Time primary Standard
Sulfur Dioxide Annual 80 ug/m3
24 Hours 365 ug/m3
3 Hours
Total Annual 75 ug/m3
sus~ended 24 Hours 260 ug/m3
Part iculates
Carbon 8 Hours 10 ug/m3
Monoxide 1 Hour 40 ug/m3
ozone 1 Hour 235 ug/m3
Nitrogen Annual 100 ug/m3
Dioxide
Lead Quarterly 1. 5 ug/m3
Secondary
Standard
1300 ug/m3
150 ug/m3
same
same
same
same
same
The i~plementation of an ambient monitoring plan will be required
to determine that the ambient air quality of the surrounding area
is not degraded as a result of the implementation of an air
alternative.
Second, because the ~otential exists that some carcinogenic
volatile organic com~ounds may be emitted in low levels from the
East Hide pile the use of the unit Risk values is relevant and
a~pro~riate for the site. These values are summarized below.
Chemical unit Risk
Benzene 8.0 x 10-6
Chromium 1.2 x 10-2
Dioxin 3.3 x 10-5
Nickel 3.0 x 10-4
Phenol NA
Toluene NA
The third ARAR to be considered as relevant and appropriate is
the applicable state requirement relative to the control of
nuisance odors. Similar to the use of unit Risk values in the
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"to be considered" category and technically is not an ARAR.
.The Agency has decided, in accordance with parts 300.68(i)(4) and
(i)(S)(ii) of the NCP, that the Commonwealth's "Regulations for
the Control of Air Pollution" (310 CMR 7.00) to the mandates of
the CAA and Massachusetts General Laws Chapter III, parts 142 B
and 0, are relevant and appropriate to the East Hide Pile. There
are no numeric standards for the control of odor, only the require-
ment that nuisance odors are not permitted to exist, and that every
reasonable appropriate control technology be used to prevent the
release of nuisance odors. While the Agency can regulate these
odors based on their adverse impacts on the public welfare as
defined in both CERCLA and CAA, the Agency considers 310 CMR 7.00,
and specifically 310 CMR 7.09 relevant and appropriate since it
formed the legal basis for the protracted litigation initiated by
the DEQE and the Town of Reading against the site's developer.
This litigation resulted in an order issued by the presiding judge
prohibiting any excavation at Industri-plex that could result in
the release of odors. The judge ~rohibited excavation rather t~an
requiring odor control measures during excavation because after
experiments and field tests of various methods, none were found to
be effective in preventing or minimizing the release of intense
odors during excavation. The odor problem caused by the Site is
so long standing and the community opposition to it is so strong
that in addition to harming the public welfare, the intense,
obnoxious odors that would necessarily attend excavating the pile
would in all likelihood provoke renewal of the previously mentioned
lawsuits.
It should also be noted that the Agency, the DEQE and Stauffer
Chemical Company have agreed in their administrative consent order
to treat odors as hazardous substances pursuant directly to the
requirements of CERCLA.
With respect to ARARs triggered as a result of the implementation
of a cleanup activity, S404(b)(1) and the Executive Order 11990 on
Wetlands would be applicable. This is because a significant portion
of the East Hide pile is physically located in a wetlands. The
implementation and restrictions for the air alternatives would be
similar to requirements under the soils ARARs. As previously
noted, these wetlands requirements prohibit impacting a wetlands
unless no other practicable alternative exists.
The East Hide pile is unstable and continues to slough material
into the wetland and/or surface water and because it is essentially
~arren of vegetation allowing toxic material and material high in
biological oxygen demand (BOD) to readily erode into the wetland
and/or surface water every time it rains or snows. Any action
-taken to abate the continued sloughing of the pile into the wetlands
would, by its very nature, impact the wetlands. For reasons
previously stated in the soils section, there exists no practicable
alternative which would not impact the wetlands. AS noted above,
any disturbance of the hide material releases a strong obnoxious
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the wastes from the wetlands is not appropriate. Because the side
slopes of the pile are steep, thereby allowing continual sloughing,
.remedial actions to stablize the slopes are required. This will
necessitate impinging on the wetlands. The FS illustrated remedial
alternatives which involved the total draining and filling of the
wetlands in order to eliminate the potential for direct contact and
to lower the local groundwater table, thereby assisting in dewatering
the pile. The Agency disagrees with the conclusion that it is
necessary to dewater the wetlands in order to reach the remedial
objectives established for the Site. The Agency believes that
.techniques involving sheet piling and more aggressive slope
stablization methods can significantly minimize the impacts to
the wetlands. The recommended remedial action for the air alternative
uses the modified slope stabilization techniques to address this issue.
Groundwater
The groundwater protection requirement~ under 40 CFR Part 2~j
Subpart F would be relevant and appropriate to the grounrlwater
problems associated with this Site. Subpart F requires that.
hazarrlous constituent~ in groundwater leaving the Site must not
exceed the background level of that constituent in the ground-
water, a Maximum Contaminant Level (MCL) or an Alternate Concent-
ration Limit (ACL), site specific levels that are determined to he
protective of the public health and environment.
Forty CFR Part 141 and Part 142 of the National Primary Drinking
Water Regulations are regulations which implement the Safe
Drinking Water Act (SDWA). The SDWA has promulgated interim
~aximum Contaminant Levels (MCLs) for a number of metals and also
has proposed MCLs and/or Recommended Maximum Contaminant Levels
(RMCLs) for some metals and synthetic organic chemicals. Listed
below are the RMCLs and MCLs for the compounds of concern:
Compound RMCL(mg/l) MCL(mg/l)
Arsenic 0.05 proposed 0.05 interim prom
Chromium 0.12 proposed 0.05 " "
Lead 0.02 proposed 0.05 " "
Benzene Zero promulgated 0.005 proposed
Toluene 2.0 proposed
. MCL~S are standards for public water systems based on health,
~echnological and economic feasibility. RMCL's are suggested levels
for drinking water based entirely on health considerations. The
use of MCLs and RMCLs as target groundwater cleanup levels is
consistent with the RCRA requirements. Results from the ground-
water sampling indicate groundwater leaving the Site is in excess
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In addition to the applicable regulation, the Agency's Ground
Water protection Strategy (GWPS) establishes guidelines for
protection of the nation's groundwater.
The strategy classifies all groundwater into three basic categories.
The 9roundwater underlying the Site would be classified as a
Class 2B aquifer. The Class 2B is an aquifer which is a potential
Source of Drinking Water and Water Having Other Beneficial Uses.
As noted previously, the aquifer underlying the Site flows southerly
,feeding the portion of the Aberjona River aquifer which supplied
Wells G and H, two of the City of Woburn's municipal drinking
water wells. As noted above, the GWPS establishes guidelines for
groundwater protection. For a Class 2B aquifer, cleanup of
contamination will usually be to background levels or drinking
water standards, but alternative procedures may be applied for
potential sources of drinking water or water used for agricultural
or industrial purposes. EPA recognizes that in some cases alter-
natives to groundwater cleanup and restoration may be appropriate.
In addition the GWPS indicates that for groundwaters not used as
current sources of drinking water, the Agency will also consider
regulatory changes to allow variances in cleanup that take into
account such factors as the probability of eventual use
as drinking water and the availability of cost-effective methods
to ensure acceptable water quality at the point of use. other
factors such as yield, accessibility, and alternative sources
will also be considered.
Once the groundwater has been successfully extracted from the
aquifer it would receive treatment to remove the contaminants prior
to discharge. The effluent from the treatment system would need
to comply with all applicable or relevant and appropriate Federal
public health and environmental requirements. Two regulations are
applicable to the treatment and discharge of the groundwater to a
surface water. section 303 of the Clean Water Act (CWA) requires
that any discharge to a surface water be subjected to the federally
enforceable Massachusetts Water Quality standards. In the absence
of a numeric standard for a given substance in the Water Quality
standards, the National Ambient Water Quality Criteria are applied.
In addition S402(a)(1) - 402(a)(3) of CWA which deals with the
National pollutant Discharge Elimination System (NPDES) would be
relevant and appropriate for the effluent of the treatment system.
The NPDES program establishes limits on a permit by permit basis,
using secondary treatment standards as a starting point. The
permit program not only requires that mimimal treatment standards
be met but that water quality standards (noted above) be attained
as well. .
As noted iA the air section, the emission from the air stripping
tower would be subject to the Clean Air Act, both in terms of the
NAAQS standards and' the unit Risk guidelines.
Only alternative GW-4 would meet the applicable or relevant and
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By capturing the leading edge of the plume this alternative
woulrl ultimately reduce the levels in the groundwater to
Drinking Water Standards. The FS estimates that this alternative
would require in excess of ten years to accomplish this goal.
Alternatives GW-3, GW-2 and GW-l would not comply with the
applicable requirements as each would allow levels to remain
in the groundwater in excess of the RCRA requirements. The
treatment systems outlined in GW-2, r,W-3 and GW-4 are all
capable of meeting NPDES and water quality standards. However,
pilot studies during the Remedial Design would be necessary to
ensure the effectiveness of the treatment system to remove
metals to the low levels needed.
VII.
RECOMMENDED ALTERNATIVES
Consistent with 40 C.F.R. ~300.6A(i), the following alternatives
have been determined to be the cost-effective remedial
alternatives that effectively mitigate and minimize threats to
and provide adequate protection of public health and welfare
and the environment.
This section summarizes the recommended remedial actions to he taken
to eliminate the hazardous waste impacts to the contaminated soils,
the East Hide Pile and the contaminated groundwater.
RECOMMENDED REMEDIAL ACTION FOR CONTAMINATED SOILS
Alternative 5-11 was selected as the recommended remedial
alternative under ~300.6A(i) of the NCP. The alternative will
eliminate the potential for direct contact with contaminaten
soils at levels above 300 ppm arsenic, 600 ppm lean, and 1000
ppm chromium. These levels were estahlished in the Endangerment
Assessment (EA) as being protective of the public health and
welfare and the enVironment. Specifically, the alternative
will cap contaminated soils with clean materials to a depth
sufficient to minimize the effects of the freeze-thaw cycle and
the potential for exposure resulting from erosion. Based on
knowledge and experience gained in other CERCLA responses, most
notably the capping of asbestos landfills, the Agency has
determined that thirty inches of clean cover material over an
exposed deposit is an appropriate method for eliminating the
potential for direct contact and future exposure. As a result
the recommended remedial action will cover the exposed deposits
with thirty inches of clean fill material. In areas where the
waste is already partially protected by clean fill material,
only enough additional cover material will he placed to provide
for the minimum of thirty inches of protection. Areas containing
buildings, roadways and parking lots would not receive cover
material, instead allowing the structures themselves to act as
. the protective cap. In addition, there may be small areas
on-site where it is more advantageous to remove waste material
than to attempt to establish protection using cover mat~rial.
These areas are likely to be around existing structures, i.e.
the grassed area between a huilding and a parking lot. Clearly
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against an existing structure may be inappropriate and could
result in significant problems. In these instances the waste
.material may be excavated from the area to an appropriate
depth and the excavation backfilled with clean material.
The excavated material will be consolidated elsewhere on-site
with wastes having the same characteristics as the excavated
material. Another alternative would be the placement of
a protective layer such as asphalt to cap the deposit. In any
event, these areas will be further identified and specific
actions to resolve the issue will be developed during the
. Remedial Design process.
For areas where waste deposits are in direct contact with
wetlands or surface waters, one of two alternatives will be
used to eliminate the adverse impacts resulting from the
potential for direct contact. First, for areas involving wetlands
or the pond where there are no hide materials, the wastes will
be excavated using a drag line. use of a drag line will minimize
the adverse impacts to the wetlands while allowing the wastes
to be physically removed from the water. For areas containing
hide materials which have the potential for odor release, the
deposits will be covered in-situ, minimizing to the extent
practical the impact on the wetlands. For manmade drainage
swales, culverting may also be an acceptable alternative to the
drag line.
Irrespective of the depth below grade, location or the presence
of an existing structure, any areas containing wastes above the
action levels will receive institutional controls. These
controls are designed to ensure the long term effectiveness of the
remedial action by preventing the unauthorized or inadvertent
disturbance of the waste deposits. The nature and scope of the
institutional controls will be similar to those required under
part 264 subpart G of RCRA. Specifically, S264.1l7 post Closure
care and use of property, S264.119 Notice to local land Authority
and S264.120 Notice in deed to property. In addition to these
requirements, the Agency is currently investigating the possible
modification of the City of Woburn's zoning regulations to
further assist in the control and future use of the affected
properties. The Agency recognizes that the remedial action may
need to be disturbed or modified at some future point, given
the amount of site development currently existing. A plan
outlining th~ conditions under which the remedial action could
be disturbed will be developed and approved as part of the
Remedial Design process.
The primary advantage of this alternative over previous
alternatives, specifically S-4 is the lower capital and O&M
'costs resulting from the decreased area requiring remedial
action. In S-4 the alternative encompassed any deposit above
100 ppm irrespective of depth below grade. In alternative S-11
clean uncontaminated fill material will be placed in sufficent
quantity to establish a thirty inch protective layer. This
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forty three acres under S-ll. The alternative would control
the difference in acreage by implementing institutional controls
over those areas not receiving cover ~aterial. The approach
used in S-ll is a sound and logical method for eliminating the
potential for direct contact. First, the alternative uses
values determined to be protective of the public health, welfare
and environment, not an arbitrarily selected number. Secondly,
the alternative minimizes unnecessary disruption to surrounding
areas by covering only those areas necessary to minimize the
effects of the freeze-thaw cycle and erosion. Finally, the use
of institutional controls over the entire contaminated area
'will ensure the long term effectiveness of the remedial action.
This alternative is not without its disadvantages. The primary
one involves the dependence on the use of institutional controls
not only to ensure the long term effectiveness of the alternative,
but as part of the alternative as well. An argument could be
raised that the reliance on institutional controls is inappropriate
as an effective means to contain the waste deposits on-site.
The Agency recognizes that use of institutional controls have
some disadvantages hut that Site conditions are such that the
use of them is the key to implementing an effective environmental
solution to the Site. Because Site development occurred after
the deposition of the wastes, many of the existing structures
are built on top of waste deposits above the action levels. While
it is unlikely that these deposits will be exposed to the public
health or environment in the near future, at so~e point in time
these deposits could pose a significant threat to the public
health and environment as a result of the structure being
removed or altered in some fashion. In order to prevent this
from arbitrarily occurring one of two things must happen.
Either the disturbance of the waste is controlled through
institutional controls or the material must be physically
removed from its present location and placed where the Agency
can be assured it is not inadvertently disturbed. Removal
from its present location is not justified, based on results in
the EA, therefore in-situ covering and monitoring are the most
appropriate remedial action to be taken.
In the event that institutional controls are not obt?inable,
this alternative would have to be reconsidered, leaving alternatives
S-7, S-8, 5-9 and 5-13 as the more viable alternatives.
Selection of one of these alternatives instead of S-ll would
require a subsequent decision by the Regional Administrator.
Alternative 5-11 was determined to be the most cost effective
soils remediation alternative for the Site. As stated earlier,
. the alternative effectively prevents and minimizes the threats
to, and provides adequate protection of the public health and
welfare and'the environment. while four alternatives (S-l,
5-6, S-lO and S12) had lower costs than 5-11, the degree of
reliability was substantially less for each of them than the
recommended remedial action. S-ll is the lowest cost alternative
which eliminated the potential for direct contact and effectively
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for exposure resulting from erosion. Alternatives higher in
.costs than 5-11 involved establishing an impermeable cap or
consolidation of the wastes. While these features are desirable
they are considerably more expensive and are not necessary to
protect the public health and welfare and the environment at
this Site. Summarized below are the alternatives evaluated and
the reasons why they were not selected as the recommended
remedial action.
Evaluation of the alternatives reveals that they can be broken
. into four categories.
No or Minimal response
5-1,
No Action Alternative
$848,000
5-10, Limited excavation, fencing, Deed restrictions
$3,593,000
permeable Covers
5-4,
24" Fill, 6" Topsoil, VeCJetate, Deed Restrictions $9,453,000
5-6,
Limited excavation, 6" Topsoil, vegetate
$5,323,000
5-11,24" Fill, 6" Topsoil, Vegetate,
Higher Action Level
$6,543,000
5-12, 6" Topsoil, Vegetate,
Higher Action Levels
$4',253,000
Impermeable Covers
5-2,
5-3,
5-5,
$23,923,000
24" Clay, 6" Topsoil, Vegetate, Deed
Restrict;ions
6" Clay, 18 Fill, 6" TOpsoil, Vegetate,
Deed Restrictions
$13,575,000
20 Mil Synthetic Membrane, 12" sand,
12" Fill 6" Topsoil
$12,703,000
Consolidation Actions
5-9,
5-8,
5-7,
$10,253,000
Consolidate on-Site, Cap Deposits
with 20Mil Synthetic Liner No Backfill
Consolidate On-Site, Cap Deposits
with 20Mil Liner
$19,213,000
RCRA on-Site Landfill
$80,253,000
5-13, Removal & Off-Site Disposal
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Alternative 5-1, the no action alternative, and 5-10 limited
excavation, fencing and deed restriction alternative, were
rejected as inappropriate remedies for the Site. Both these
alternatives were found not to meet the remedial objectives
for the Site, nor would either meet or exceed applicable or
relevant and appropriate Federal requirements. The RI determined
that a substantial amount of waste deposits above the recommended
levels were exposed or near surface. As a result, a direct
contact potential existed. The 5-1 Alternative clearly would
do little to minimize or eliminate this potential. The 5-10
Alternative, while taking positive steps to mitigate the short
term direct contact potential by installing a fence around the
exposed deposits would not provide for an effective long term
means of preventing access to the Site and the exposed deposits.
In the five years since the initial installation of the fence,
the Agency has made repeated attempts to repair damage to the
fence resulting from vandalism. In the interim, unauthorized
access to the Site continues. Implementation of either
alternative would permit the continued release or threat of
release of hazardous substances to the environment from the
waste deposits located on Site.
For contrasting reasons, 5-7 and 5-13 were eliminated as th~
recommended remedial action. Implementation of these
alternatives would produce significant short term adverse
impacts to the surrounding area. In order for these alternatives
to be completely effective, all the waste deposits would need
to be excavated and redeposited into a secure facility. These
alternatives were evaluated in terms of excavating and removing
wastes' from undeveloped portions of the property. Ar~as
containing buildings, parking lots or roadways were not included
as part of these alternatives. The physical problems and
logistics associated with waste removal from under these
structures is costly and impractical. Assuming that these
deposits are allowed to remain in place, the effectiveness and
driving force behind these alternatives is substantially reduced.
In addition to the logistical and implementation prohlems
noted above, there are several short form adverse impacts
associated with implementation of these alternatives. The RI
determined that approximately fifteen percent of the sludge
deposits are contained within the saturated zone. In addition,
local surface waters are found in contact with the waste deposits
at several locations. Excavation of the deposits will tend to
suspend a portion of the waste material in the ground and
surface waters. While engineering techniques can be implemented
to minimize these potential impacts, the sheer volume of wastes
.to be excavated in order to successfully implement these
alternatives makes the potential for a short term release very
high.
Further, a significant amount of the material requiring removal
as part of these alternatives aie the animal glue manufacturing
deposits. Past experience with the primary developer (Mark
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Phillip Trust) indicates that disturbance of these deposits
will cause a substantial release of odors. Release of these
odors will pose a significant adverse impact to the public
welfare surrounding the Site. As a result of the adverse
impact to the welfare and the strong public resistence, the
removal or rearrangement of the hide deposits is not feasible.
Costs associated with S-7 and 5-13 are substantially higher
than the next most costly alternative, S-R, which involves the
excavation and on-site consolidation of waste deposits, capping
the consolidated area with a 20 mil thick synthetic ~embrane
.and backfilling the excavated areas with clean off-site fill.
S-8 costs approximately $24 million. S-7 costs SRO million
while S-13, the off-site disposal option, would cost S209
million. Because S-8 was determined to be protective of the
public health, welfare and environment and met the remedial
objectives established for the Site, it would be considered
acceptable as a remedial action. While the S-7 and S-13
alternatives are found to exceed the same criteria as S-R, the
added costs would not produce a substantially better degree of
protection than S-8.
The remaining alternatives basically can be classified as either
in-situ containment or on-site consolidation and containment.
The in-situ containment group can be further divided into
permeable and impermeable covers.
Each alternative evaluated was found to meet' or exceed the
remedial response criteria for the wastes at this Site.
Variations between alternatives evaluated in each subgroup were
dependent on response level (action levels) and degree of
reliability. The lower the response level and greater the
degree of protection and reliability, the greater the costs.
Briefly summarized below is a comparison of the remaining
alternatives by subgroup.
Permeable Covers
This group includes alternatives S-4, S-n, 5-11 and 5-12.
Costs ranged from S4.25 million for 5-12 to S9.45 million for
5-4. Each alternative in this subgroup was found to meet the
remedial response criteria of minimizing or eliminating the
direct contact potential. Each alternative was also found to
meet applicable or relevant and appropriate Federal requirements.
However, there was found to be a wide discrepancy in the degree
of reliability provided by the alternatives in this group.
. The lowest cost alternative in this group, S-12, involved
remedial actions on areas found to be above the action levels
established by the EA in the Feasibility Study. This alternative
was rejected because it was determined to be only marginally
protective of the public health, welfare and environment.
While a six-inch topsoil cover would minimize the potential
for direct contact, it is too thin of a layer to provide any
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of the freeze-thaw cycle plays an important role in the
determination of the adequacy of the cover. Any material
contained within the frost zone is susceptible to being forced
to the surface by the freeze-thaw cycle. Given the substantial
reworking of the Site, high groundwater table and the
heterogeneous nature of the waste deposits, the poten'tial for
this cover to fail from the freeze-thaw effect is a distinct
possibility. Roots of weeds, bushes and trees may penetrate'
through the cover to the waste and expose it. In addition,
erosion and unauthorized site activities, such as all-terrain
vehicles or motorcycles, will quickly penetrate the effectiveness
of this cover. These weaknesses in the reliability of this
alternative could be minimized by an aggressive operation and
maintenance program as well as increased frequency of monitoring,
but given that this remedial action must last indefinitely,
this aggressive approach could prove unreliable.
Alternative S-6 is very similar to 8-12 except the area
requiring remedial action is increased as the result of a
lower response level (100 ppm versus 300 ppm As, 600 ppm Pb,
1000 ppm Cr). This lower action level is a somewhat arhitrary
level selected by the responsible party. Stauffer Chemical
Company selected 100 ppm based on a literature review of
ambient concentrations of metals found in soils, a reasonable
detection level given the proposed analytical equipment ann as
a result of establishing a correlation between an analytical
number and a visual observation in the field. Stauffer
demonstrated that for the Site there was a good correlation
between visual observations of potential waste deposits and
values of metals above 100 ppm. This correlation is potentially
very important because visual detection of areas requiring
remedial action with occasional spot checking using analytical
methods is much quicker and less expensive than determination
of the limits of remedial actions solely through the use of
analytical equipment. As a result, the FS evaluates most of
the alternatives based on this lower number. Alternatives 5-12
and S-1l are the exception in that they use numbers ohtained
from the EA.
The use of Alternative S-n was rejected for the same reasons
discussed in the evaluation of Alternative S-12.
Alternative S-ll attempts to overcome the deficiencies found in
S-6 and S-12 by increasing the thickness of the cover material
to thirty inches. Under this alternative the Site would receive
a site preparation similar to previous alternatives. Placement
of the cover material would commence with eighteen inches of
permeable bank run gravel. An additional six inches of fine
sieved sand is placed on top of the eighteen inches, followed
by a six-inch topsoil cover upon which is established a vegetative
cover.
Implementation of this cover will place the waste deposits
below the mean frost level for this part of the region. The
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for asbestos landfills in Southern New Hampshire. The
alternative is found to be protective of the public health,
welfare and the environment by minimizing the direct contact
potential. The cover is designed for a fifty to one hundred
year design life. The cover will minimize the freeze-thaw
cycle, eliminate root penetration by placement of the ~aste
below the typical depth of root penetration (12 inches). In
addition, erosion control of the cover can be maintained at
regular intervals without the potential for accidental exposure.
Alternative S-ll is approximately S 2.2 million more expensive
than S-12. Th~ majority of this additional increase in cost is
directly related to the additional fill material required. The
greater degree of reliability and protection resulting from S-
11 more than offsets the increased costs.
Alternative S-4 is similar to S-ll, except that it uses the
lower action levels. Implementation of alternatve S-4 will
provide a slightly greater degree of protection than S-ll, except
the alternative will cost an additional S 2.9 million without
providing a substantially greater degree of protection.
Impermeable Covers
Alternatives S-5, 5-3, and S-2 are alternatives which provide
a degree of impermeability. Each of these alternatives exceed
the response objectives established for the Site. In addition
to eliminating the direct contact potential, these alternatives
prevent precipitation from leaching materials from the deposits
and into the environment. The need for an impermeable barrier
is not required for this Site. As noted in previous sections,
the RI determined that waste deposits containing metals were
not significantly impacting the ground or surface waters. A
series of EP Toxicity testing further supported this conclusion.
As a result, the installation of an impermeable barrier while
further minimizing any leaching potential is unwarranted.
The FS evaluated three alternatives which provide a greater
degree of impermeability. Of these three, two use a natural
material, a bentonite soil mixture, and the remaining
alternative uses a synthetic membrane to achieve its objective.
In spite of the increased costs, the increase in environmental
and public health protection is minimal. There are several
reasons for this, each common to the three alternatives. The
primary purpose of an impermeable barrier is to eliminate
infiltration through a waste deposit. At this particular site
a third of the area contains structures (buildings, parking
lots and roadways) around which it would be impractical
to establish and maintain a seal. Therefore, implementation of
these alternatives would be jeopardized by the many gaps in
the barrier. The effectiveness of an impermeable cover is
hased on the assumption that the wastes covered would remain
above the saturated zone and as a result continued leaching
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-89-
approximately fifteen percent of the deposits are contained in
the saturated zone.
Alternative 5-5 uses a 20 mil thick PVC synthetic membrane to
maintain impermeability. This membrane is bedded between two
six inch thick zones of sand. Twelve inches of common borrow
material would be placed over the sand followed by a six-inch
topsoil cover with vegetation established to control erosion.
This alternative was found to be protective of the public
health, welfare and environment. The alternative was rejected
based on increased cost without a substantial increase in
protection or reliability. In addition, the use of a 20 mil
thick liner raises concerns about implementability and long
term usefulness. Current Agency guidance would require a
thicker membrane to resist construction hazards and increase its
resistance to failure.
Alternative S-3 uses a six-inch thick layer of a bentonite soil
mixture to maintain an impermeable cover. The impermeability
would be protected by the placement of an additional 24 inches
of cover materials. While this alternative was rejected for
the same reasons as 5-5, the use of only six inches of a
bentonite soil mixture raises some concerns about the ability
of the alternative to effectively meet its goals. The use of a
bentonite soil mixture, mixed on-site, raises issues relative to
the ability of the mixture to maintain its stated permeability.
Changes in mixtures, moisture content, raw materials or site
conditions can produce areas where there may be lenses of less
impe~meable material than required. This potential is minimized
by increasing the thickness of the impermeable layer.
Increasing the thickness of the layer also compensates for
variations in application thickness and cracking resulting from
shrinking and swelling of the clay as the moisture ~ontent
changes.
Alternative 5-2 attempts to minimize the problem associated
with 5-3, however costs increased from S13.6 million for S-3 to
524.9 million for 5-2. This alternative was rejected because
the 524.9 million cost when compared to the 5~.5 million cost of
an alternative deemed to meet the remedial objectives is
unwarranted. Implementation of this alternative would have
required some modification (with an associated cost increase)
as part of the Remedial Design. The modification would be the
addition of fill material between the six inch topsoil cover
and the twenty-four inch clay layer. This additional soil
would be required to protect the impermeable layer from the
effects of evapotranspiration and penetration by the root
s truc ture.
Consolidation Actions
The two remaining alternatives, 5-9 and 5-8, involve the use of
on-site consolidation with subsequent covering of the consolidaterl
deposit. The alternatives are the same except that Alternative
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-90-
S-9 does not require the excavated areas to be backfilled with
clean material, while S-8 does.
In each alternative the elimination of the potential for direct
contact is accompanied by a reduction in the physical
area requiring remedial action. Under these alternaiives,
waste deposits are excavated from various portions of the Site
and used to recontour and consolidate deposits onto a fifteen
acre parcel already containing waste deposits. These alternatives
have the advantage of minimizing the area requiring deed
restriction, operation and maintenance and monitoring. This
would "free up" land for future development. Consolidation
options are attractive alternatives when there is a substantial
reduction in area requiring additional controls. Site
conditions, however, do not lend themselves to this attractive
feature. As noted previously, the Site contains a number of
structures, which indicated that waste material should remain
in-situ. As a result, while reducing the areas which required
ongoing O&M and monitoring, this alternative would leave behind
a number of discrete satellite deposits under the structures
which would still require institutional controls and monitoring.
This fact destroys the primary feature of the consolidation
option. In addition, once the material is excavated, it is
typically deposited into some sort of engineered structure,
such as a RCRA landfill. By placing the material into a RC~A .
landfill the waste can be carefully controlled to eliminate the
potential for future release. Under this alternative the waste
does not receive full benefits of the consolidation option, such as
a bottom liner or leachate collection system.
Site conditions and the level of protection required at the
Site does not warrant the increased costs for only a small
increase in protection associated with these alternatives.
The primary advantage gained from this group of alternatives
is minimizing the area requiring deed restrictions and freeing
up land for additional development. In addition to these
concerns, Alternative S-9 does not require backfilling of the
excavated areas. While this substantially reduces the costs
(510.25 million versus 519.21 million), it allows the Site to
remain in an unacceptable condition. Area requiring excavation
may reach depths in excess of fifteen feet below grade. These
areas would quickly fill up with precipitation and groundwater,
thereby creating an attractive nuisance.
operation and Maintenance costs for the soils alternatives are
found on Tables 42 and 43, and the capital, operation and maintenance
and present worth costs are summarized on Table 52.
RECOMMENDED REMEDIAL ACTION FOR AIR
Listed below are the six alternatives evaluated in detail for
remediating the problems posed by the East Hide Pile. Present
-------
A-1
A-2
A-3
A-4
A-5
A-6
-91-
Alternative
Present Worth
Costs
No Action (Monitoring Only)
5171,000
Dewater the wetlands, stabilize
slope, cover with 20 mil synthetic
membrane, vegetate, deed restrictions
52,030,000
Dewater the wetlands, stabilize
slope, install gas collection/
blower system, cover with 20 mil
synthetic membrane, vegetate,
activated carbon treatment,
deed restrictions
52,799,300
Dewater the wetlands, stabilize
slope, install gas collection/
blower system, cover with 20 mil
synthetic membrane, vegetate,
thermal oxidation treatment,
deed restrictions
53,109,000
Excavate and remove East Hide pile,
dispose of in on-site RCRA landfill
with gas treatment systems as in
A-3 or A-4
SlS,SlO,OOO
Excavate and remove East Hide pile,
dispose of at off-site RCRA landfill
535,860,000
A modified version of alternative A-3 or A-4 will be selecterl
as the most cost effective remedial action that mitigates the
threats to, and provides adequate protection of public health
and welfare and the environment. These two alternatives offer
equivalent degrees of protection and reliability. The final
solution of an alternative that will mitigate the odor impacts
will be made by the Regional Administrator in a supplemental
decision document. This decision will consider results of a
monitoring study conducted subsequent to installation of the
impermeable barrier and gas collection system. Final selection
of gas treatment offered by alternatives A-3 or A-4 will be
made after evaluation of gas emission rates from the pile once
the impermeable barrier is in place anrl the pile has had time
to stabilize. The FS indicated that the piles would reach
equilibrium in approximately seven weeks. The Agency will
assess degree of pile equilibrium after monitoring pile gas
generation. The Agency will design and implement a monitoring
plan capable of measuring the rate of pile stabilization by
observing gas flow rate and gas concentration. The monitoring
shall continue until the Agency can adequately determine which
gas treatment alternative will be the most efficient and cost
effective and provide a long term odor emission remedy. During
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installed to minimize or eliminate the potential release of
obnoxious odors. Prior to a final decision the Agency shall
make available the data and rationale for the gas treatment
option selection and an explanation supporting the Agency's
decision.
A major engineering concern during design and implementation
of alternative A-2 or A-3 is preservation of the environmental
integrity of a shallow pond and associated wetlands. The
wetlands are approximately four acres in area and are located
between the East and West Hide Piles. Either alternative as
illustrated in the FS requires that these wetlands and pond be
filled and a drainage system installed to dewater the pond,
wetlands and the local groundwater. The destroyed pond would
be filled and provide more area to establish three to one
side slopes on the East and West Piles. A primary reason for
draining the pond and wetland is to lower the local ground-
water table to lower the groundwater mound within the hide piles.
The FS concluded that fluctuation of the groundwater mound
complicated gas treatment process operation. The FS also
concluded that the greatest reduction of the groundwater mound
would be accomplished by dewatering and lowering of the
groundwater table. It concluded that installation of a synthetic
membrane to cap the pile would not effectively result in a
significant mound reduction and destruction of the pond and wetlands
needed to be part of successful implementation of the recommended
remedial alternative.
The Agency disagrees with the conclusion for the need to dewater
the pond and its associated wetlands. Executive Order 11990
concerning wetlands prohibits the elimination of wetlands
except in specific and limited circumstances. The Agency,
through this Executive Order and ~ 404 of the Clean Water Act
recognizes the value and importance of wetlands and the need to
protect them from destruction. It is the Agency opinion that
the circumstances and data concerning the wetlands and hide
piles do not support the need for wetlands elimination. The
Agency agrees that the approach outlined in alternatives A-2,
and A-4 would ensure maximum dewatering of the piles. In
addition, the Agency agrees that the proposed dewatering would
enhance remedial action reliability as well. Rowever, the
Agency believes that other techniques employing common engineering
practices that will provide adequate protection, meet the odor
control needs, and provide protection of welfare will not
substantially impact the wetlands. The Agency will modify the
FS recommended alternatives during the Remedial Design process
to balance the need to eliminate odors and to protect wetlands.
As part of the supplemental FS, Stauffer submitted a Wetlands
Assessment in which an alternative to minimize the impact on
the wetlands using sheet piling was evaluated. The use of
sheet piling to stahilize the side slopes while minimizing the
impacts to the wetlands was deemed to be an appropriate method
for addressing the requirements of ~404(b) (1). However, Stauffer
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that dewatering the piles by eliminating the groundwater mound
was the most important criterion. As noted previously, the
Agency rejected Stauffer's conclusion and as a result believes
that the use of sheet piling is an effective technique for
implementing more aggressive slope stablization techniques in
order to protect the wetlands. A moderate increase ih the
sizing of the treatment system will accomodate any additional
gas production resulting from the increased moisture containerl
within the pile. Figures 15 and 16 show the details of the
sheet piling technique.
In addition, as part of the remedial design, the Agency will
design and implement a monitoring plan capable of accurately
measuring the rate of stabilization, the gas flow rate, and the
gas concentration. Action levels and a contingency plan will
be established in the design phase. If concentrations approach
the action levels, the contingency plan will be implemented to
protect the public health. The monitoring shall continue until
such time as the Agency can adequately predict which alternative
will provide the most efficient, cost effective long term remedy
to the emission of odors. In the interim, a temporary treatment
system (such as activated carbon) shall be installed to minimize
or eliminate the potential release of obnoxious odors during the
monitoring program.
Alternative A-l, the no action alternative was rejected because
it did not meet the remedial objectives to eliminate ador or
to conform with the applicable or relevant and appropriate
public health and environmental requirements. No action at
the pile would maintain current Site conditions with wastes at
or near the surface of the Pile and wastes brought to the
surface by the continued sloughing and erosion of the Pile. These
conditions would continue to pose a direct contact hazard to
the public. The unabated emission of odors from the Site
would continue to threaten the public welfare. Allowing
continued release of odors would violate relevant and appropriate
state standards for the control of air pollution. The continued
sloughing and eroding of contaminated material into the wetland
and surface water would violate the applicable or relevant and
appropriate requirements of the CWA and Executive Order llQqO.
The FS did not present and the Agency has not been
able to identify a remedial alternative addressing the Hide Pile
problem that does not adversely impact the wetland because
Hide pile wastes were deposited directly in the wetland. In
the absence of any alternative that can avoid wetland impacts,
an alternative that minimizes these adverse impacts would
conform with the Executive Order 11990.
Alternative A-2 recommended stabilization of pile side slopes
and trapping the odorous gases under an impermeable membrane
cap. This alternative was rejected hecause it did not adequately
protect public welfare or mitigate threats to the environment.
Slope stabilization and the impermeable cover will substantially
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that generates gases; however, gas production would continue
after installation of an impermeable cover and would remain
a significant concern. Numerous investigations of municipal
landfills have provided information concerning gas production
rates and possible uses for the gas generated at municipal
landfills. Methane gas production at several landfills is
sufficient to justify extraction for commercial uses. Gas
production, negative impacts and the associated odors are not
adequately addressed by alternative A-2. Methane gas (a
major component of the gases) can be generated in significant
quantities in the pile to result in decreased cap integrity
due to physical ballooning or cover distortion and gas may reach
explosive concentrations.
Alternative A-5, proposed excavation of the pile and disposal
in an on-site RCRA landfill. This alternative was rejected
because it cost Sl5.5 million and its impacts on the environ-
ment and the public welfare are unacceptable. Excavation of
the pile will necessarily release intense, obnoxious odors
into the environment, adversely impacting the public welfare.
Neither the Agency nor the DEOE knows of any method which will
reliably control or eliminate the odors generated by excavation.
The odors are so intense, the problem so long-standing and the
community opposition to the odors so high that the Agency
would face strong community opposition and possibly litigation,
if this alternative were chosen.
Implementation of A-5 would adversely impact wetlands, surface
water quality and possibly groundwater quality. Releases of
waste to surface and groundwater as well as destruction of the
wetlands by access roads built and sheet piling installed in
the wetland would occur during implementation of this alternative.
Further, worker safety would be a major concern as a result of
the attendant releases of hydrogen sulfide and methane gas,
presenting the possibility of poisoning or asphyxiation.
The Agency finds that alternative A-5 is not protective of the
public welfare nor in conformance with relevant and appropriate
regulations. Further, the Agency has rletermined that this
re~edy is not more cost effective because it is five times more
costly than the recommended remedial actions.
Alternative A-6 proposed excavation of the Hide pile and its
disposal at an off-site RCRA facility. This alternative was
rejected because it costs S35.8 million and its
adverse impacts to the environment and public welfare are
unacceptable. This alternative would include negative environmental
impacts similar to those discussed for alternative A-5 and the
impacted public would expand to include those people along the
waste transport route and near the disposal facility as well
as those near the Site. The cost of this alternative is more
than double that of alternative A-5 and an order of magnitude
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-95-
RECOMMENDED REMEDIAL ACTION FOR GROUNDWATER
Listed below are the four alternatives evaluated for remediation
of the groundwater contamination.
Alternative
Present Worth
Costs
GW-l
No Action Alternative
Quarterly Monitoring only
5850,000
GW-2
Groundwater interception/recovery
of on-site "hot spot" areas,
treatment with subsurface discharge
52,960,000
GW-3
Groundwater interception/recovery
at Site boundary, treatment with
surface water discharge
54,220,000
GW-4
Groundwater interception/recovery
at leading edge of plume, treatment
with surface water discharge
511,150,000
Of the four alternatives, only GW-4 meets the applicable or
relevant and appropriate Federal public health and environmental
requirements. 8y capturing all the contaminants found in the
groundwater from the Site, this alternative would theoretically
restore the aquifer to a pristine condition. Selection of
alternative GW-3, capture and treatment at the Site boundary
might also be protective of the public health and welfare and
the environment as well as potentially complying with the
applicable or relevant and appropriate requirements. Alternative
GW-3 would capture and treat approximately ninety percent of
the plume, allowing the remaining ten percent to further migrate
off-site and downgradient. The remaining concentrations might
meet RCRA standards by establishing an ACL for the groundwater
at the Site boundary.
Pursuant to ~300.68(i)(5) (i) of the NCP, the selected remedy
for groundwater is alternative GW-2. This remedy is an
interim remedy until a determination as to the most effective
solution to an area-wide groundwater contamination problem can
be made. As briefly summarized in the Current Site Status
section, the Agency has knowledge of a number of actual and
potential sources adversely impacting the groundwater surrounding
the Site. Upgradient of the Site are several active industial
operations, each with an ongoing groundwater problem. Abutting
the site to the west and northwest are a large municipal landfill,
two barrel reclamation operations, two chemical manufacturers
and two large trunk sewer lines with a long history of surcharging.
In addition to these actual and potential groundwater impacts,
southwest of the Site is a company with a fuel oil problem
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-96-
Each of these problems is contributing to the general degradation
of the groundwater quality in this portion of the aquifer.
Farther downgradient, the portion of the aquifer serving Wells
G and H has a separate groundwater contamination problem.
Investigations into the potential impacts on groundwater from
the above noted sources are ongoing.
Because the scope, direction and pace of each of these
investigations if different, there is a potential that decisions
regarding groundwater remediation may be inconsistent with the
overall goals of the Ground Water Protection Strategy. Current
CERCLA guidance recognizes that specific decisions about ground-
water remedial actions resulting from a CERCLA site should be
made in conjunction with the resolution of the larger area-wide
groundwater problem. As a result, CERCLA guidance permits the
selection of an interim remedy until a more comprehensive
investigation of the area-wide groundwater prohlem can be
completed. This investigation is referred to as a Multiple-
Source Ground Water Response Plan (MSGWRP).
The Agency believes that the implemention of a MSGWRP is required
prior to a final decision as to the extent of the groundwater
remediation at the Site. The Agency further believes that the
MSGWRP is the most efficient response to the remediation of
the groundwater problems associated with the Site as well as
the larger problems within the aquifer.
Based on the preceding determination the Agency believes that
implementation of alternative GW-2 is the most cost effective
response to minimize the impacts to the public health, welfare
and environment while resolving the larger regional problem.
Under this alternative the FS estimated that eighty percent of
the benzene and slightly less of toluene would be captured within
a six to nine month period through careful placement of recovery
well systems. Three of the four alternatives seek to control
and minimize the impact on groundwater resulting from the
benzene plume. Alternative GW-l, the no action alternative,
does nothing to minimize the potential impact on the downgradient
aquifer supplying Wells G & H, it only seeks to monitor the
plume's downgradient migration. Depending on the length of
time necessary to design, implement and reach a decision on
the multiple source groundwater response plan this alternative
may be an appropriate response to the on-site groundwater
problem. The implementation of GW-2 appears to be the most
appropriate interim remedial action under the present Site
conditions. Alternative GW-2 seeks to capture and treat
approximately 80% of the contaminant of concern (benzene)
within a relatively short time frame (less than 6 months).
Using GW-2 as the interim remedy take positive steps in a cost
effective manner to minimize the impacts to the off site public
health and environment while permitting the MSGWRP to create a
long term response plan for remediation of the aquifer. The
ease of implementation, its short operation period, and its
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-97-
interim groundwater remedy.
While GW-3 and GW-4 provide a greater degree of protection for
the public health and welfare and the environment than the
previous two alternatives, they are not appropriate as interim
remedies. The primary purpose of an interim remedy is to
undertake an action which will provide the maximum degree of
protection at the least cost while additional studies are
undertaken to ensure that any long term remedial action at a
site is consistent with the larger environmental goals associated
with the aquifer. In the case of GW-3 and GW-4 the substantial
period of operation (10+ years) and increased capital and
operation and maintenance costs make them unsuitable as interim
remedies.
VIII.
OPERATION AND MAINTENANCE (O&M)
A key component of any remedial action is the development and
implementation of an effective operation and maintenance (O&M)
program. This program will ensure that the effectiveness of the
remedial actions is maintained through periodic monitoring,
inspection and preventative maintenance. A major part of any
effective O&M program is a sampling and analysis effort. The
sampling plan is intended to provide the basis for determining
the effectiveness of the remedial action and to serve as an early
warning system should the remedial action begin to fail. In
addition, the monitoring program helps to track the rate of
remediation (when applicable) and assists in the decision to
modify the operating parameters of a remedial action to provide
for a more efficient clean-up or better protection.
For each remedial action selected, there are proposed O&M and
monitoring costs associated with it. Costs for the soils
alternative 5-11 are on Table 42, those for air are on Table 49,
50 and 51, while costs for groundwater are located on Table 22.
Monitoring costs associated with the overall Site are summarized
on Table 43. Summarized briefly below is a description of the
O&M tasks associated with each recommended remedial alternative.
SOILS
The O&M tasks associated with the soils alternative are simple
and straightforward to implement. Basically, the costs include
an annual inspection to visually determine that the cap's integrity
is intact. Any area requiring repair would be covered with
additional fill material in order to eliminate the potential for
direct contact. This annual inspection would typically be
performed in the spring in order to determine the effects on the
cap from from the freeze-thaw cycle. This detailed inspection
would record in writing the physical integrity and condition of
the cap. Records of these inspections would be retained in order
to evaluate the long-term performance of the remedial actions and
to identify areas potentially requiring future preventative
maintenance. Less intensive periodic inspections would be
conducted as needed, such as after a particularly severe rainfall
-------
-98-
when the erosion potential is high.
Costs associated with maintenance include a twice yearly mowing
of the vegetative cover, patching and repairing erosion gullies
and covering areas subjected to the effects of the freeze-thaw
cycle. Periodic bush and tree removal, as well as r~-seeding
portions of the vegetative cover will be performed as necessary.
Responsibility for periodic O&M on developed areas would lie with
the existing property owner. Ensuring compliance with the terms
of the O&M will be the responsibility of the controlling regulatory
agency.
The actual nature and scope of the O&M plan will be developed and
approved as part of the Remedial Design process: however, the
general outline of the program will comply with requirements set
forth in RCRA Part 264 Subpart G - Closure and Post Closure and
Subpart N - Landfills.
AIR
Operations and maintenance for the recommended remedial action
are broken into three parts: maintenance of the impermeable
cover, O&M of the gas collection system, and the O&M of the
gas treatment system.
For the first part, O&M will include periodic inspections of the
impermeable cover system. Specifically, actions will include
detection of subsidence and slope stability poblems. As proposed,
the western toe of the slope will be secured using sheet pilings
driven into the bottom of the pond. The area behind the pilings
will be backfilled with clean material which serves as a base to
anchor the synthetic membrane. Periodic maintenance of the
sheet pilings will be required to ensure that the toe of the slope
resists the effects of sheer failure resulting from the relatively
steep side slopes. Similar to periodic maintenance requirements
under the soils alternative, mowing the vegetative cover as well
as repairing seeded areas are included in the cost of the O&M
plan.
The second part of the O&M under this alternative is the periodic
maintenance associated with the gas collection system. Costs
and actual maintenance on the below cap collection system is
projected to be minimal: however, there are electrical and
maintenance expenses associated with the blower system. The
blower system is designed to actively withdraw gases from the
pile: this requires a positive induction fan. These fans are
very common, are widely used and are easy to maintain and operate.
Projected maintenance would include periodic inspection,
lubrication and adjustment.
The final phase of the O&M requirements under this alternative is
the operation and maintenance of the gas treatment system itself.
Specific requirements are dependent upon the selection of either
-------
-99-
on Table 50 for A-3 and Table 51 for
either treatment system will require
operator. Costs associated with the
are illustrated with the groundwater
A-4. It should be noted that
a part-time treatment plant
treatment plant operator
alternatives.
GROUNDWATER
The operation and maintenance (O&M) requirements for the treatment
of groundwater include the periodic maintenance of the interceptor
well system. Costs primarily associated with this portion of the
system are the electrical utility costs for operating the pumps.
Periodic maintenance for the pumps may include occasional rebuilning
or replacement of the pumps themselves and maintaining the piping
system and flow meters.
A part time plant operator will be required to ensure that the
treatment system is operating properly and in compliance with
established operating parameters. Tasks include periodic
replenishment of chemicals used in the odor control process,
adjustment of flow rates to maximize the efficiency of the air
stripping system and periodic inspection and maintenance of the
subsurface discharge system. other costs associated with the
treatment system include chemical and electrical costs as well as
plant operator salary.
MONITORING
A comprehensive sampling and analysis program will be developed
and implemented as part of the Remedial Design process. The
primary purpose of this program is to monitor the overall
effectiveness of the implemented remedial actions. Economy of
scale can be attained by developing a single program maximizing
the number and locations of monitoring points to address more
than one media. This approach provides the added advantage of
integrating the three proposed remedial actions by looking at
sampling results in light of the entire site. The program will
include sampling and analysis of ground and surface waters, soils
and air. Also included will be sampling and analysis of various
points within the groundwater and air treatment systems to assist
the Agency in maximizing the efficiencies of the systems.
Table 43 illustrates the level of effort and costs associated
with the sampling plan. The table indicates a semi-annual
frequency rate: however, the Agency believes that quarterly
monitoring for the environmental parameters and more frequent
monintoring for the process analysis is required. The actual
development and implementation of the monitoring plan will he
-------
-100-
IX.
SCHEDULE
Listed below are key milestones and dates for successful
implementation of this project.
o
Approve remedial action (sign ROD)
Complete Enfor'cemen t Negot ia t ions
September 30, 1986
o
January 1, 1987
o
Send Interagency Agreement (IAG) to
Army Corps of Engineers for Design
January 15, 1987
o
Start Remedial Design
February 15, 19B7
o
Start pre-design field studies
March 1, 1987
o
Complete Remedial Design
November l~, 19B7
o
Amend IAG for construction
November 15, 1987
o
Start construction
December 1, 1987
o
Complete construction
October 1, 1989
This schedule is dependent on the availability and obligation of
funds to implement the project design and construction. The time
lag before obligation of final remedial action funds will protract
the schedule for implementation by an equal length of time.
X.
FUTURE ACTIONS
This Record of Decision encompasses all remedial actions
necessary to protect the public health, welfare and environment.
However, a number of additional actions necessary to ensure the
successful implementation of the remedies will be undertaken.
Additional field investigations as part of the Remedial Design
will need to be undertaken to resolve the following issues.
o Additional soil borings and test pits to more accurately
characterize the extent and distribution of waste deposits
within the developed areas requiring remedial actions and
areas receiving institutional controls only.
o Additional soil borings and test pits south of the original
Site area (as defined by the Consent Order). Specifically
the Right of Way Number 9 owned by Roston Edison will he
the focus of this additional effort. Data collected will
be used to calculate quantities of fill material necessary
to implement a remedial action.
o Additional soil borings and monitoring wells in the vicinity
of the East Hide Pile. This additional effort will be used
-------
-101-
to identify the exact requirements necessary to establish a
firm base at the toe of the East Hide Pile to minimize the
effects of the slope failure. This additional information
is critical to ensuring that the impact to the wetlands is
kept to an absolute minimum. The installation of the
monitoring network will develop a better base of monitoring
data on the impacts resulting from the East Hide Pile.
o Additional groundwater sampling and monitoring to more
accurately characterize the "hot spot" areas.
This additional testing will be used in pilot studies on the
treatability of the groundwater as well as assisting in the
development of operating parameters such as pumping rates,
location of interceptor wells and period of performance.
Because the Agency has selected an interim groundwater remedy
prior to resolution of the area-wide problem it is important
that the development and implementation of the Multiple Source
Ground Water Response Plan (MSGWRP) begin as quickly as time
and funding will allow. The actual form of the MSGWRP is not
yet fully defined. The Agency believes that the formalization
of the plan will come as a result of ongoing discussions with
the DEOE and the City of Woburn. This formalization perod is
expected to take approximately six months; however, implementa-
tion of the actual plan is dependent on the reauthorization of
CERCLA.
A subsequent decision by the Regional
term groundwater remedial action will
envisioned that this decision will he
of Decision and will be based in part
the MSGWRP.
Administrator on the long
be required. It is
in the form of a Record
on the conclusions from
As noted previously, a subsequent decision by the Regional
Administrator on the air treatment system will be required.
This document will briefly summarize the results of the monitor-
ing program conducted on the venting system from the East Hide
pile and recommend either A-3 or A-4 as the more cost-effective
alternative. The document will not be a ROD document, but a
memo documenting the selection of one of two equally acceptahle
alternatives based on field data.
The Agency selected a soils remedial action which requires the
placement of thirty inches of clean fill materials to eliminate
the potential for direct contact. As part of the public comment
period, Monsanto Chemical Company, a responsible party submitted
a lengthy document critiquing the RI/FS. While Monsanto gener-
ally agreed with the overall approach and extent of the proposed
remedy, it felt that thirty inches of cover material was
unnecessary and excessive. Monsanto in its public comments
indicated that twelve inches of cover material was more appro-
priate and has subsequently increased its estimated thickness
-------
-102-
options based on experience gained by the covering of asbestos
. landfills to eliminate the potential for direct contact in
Southern New Hampshire.
The Agency recognizes that other engineering solutions to
eliminating both the short and long term problems exist for
application at the Site. These other engineering solutions may
in fact be equivalent to the selected remedial alternative
pending additional investigation and evaluation. The additional
documentation and rationale for the fifteen inch engineered
cover proposed by Monsanto was not available prior to close of
the public comment period. As a result, it is premature for
the Agency to comment on the efficacy of Monsanto's proposal.
If subsequent review and evaluation of the Monsanto proposal
determines that it is equally protective of the public health,
welfare and environment, meets the criteria established in the
ROD and is more advantageous to implement in terms of costs,
implementability and reliability the Agency would request
subsequent approval by the Regional Administrator prior
to completion of the Remedial Design process.
Future actions also include monitoring the effectiveness of the
cap, groundwater and air treatment systems as well as assuring
future effectiveness of ~hese actions through proper operation
and maintenance. Monitoring for cap effectiveness is required
under 40 C.F.R. Part 264 Subparts F and G and Subpart N
-------
FIGURES
INDUSTRI-PLEX SITE
WOburn, Massachusetts
-------
WIL.MINGTON
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SOURCE DETERMINATION
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REMEDIAL ACTION
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WOBURN I
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POSSIBLE SOURCES IN AREA OF STUDY
j;'
Sources for this information are included in the notes following this table
"~
Source.
of Poten-
Hap Suspected Infor- tial
Code Location Description Wastes mation Conduit (a)
-
1 Stepan Chemical Chemical Mfg. Formaldehyde. 1 r"S,A
Hexamine
l-A Stepan Chemical Lagoon A Acid Wastes 1.2,3 !1,S
l-B Stepan Chemical Lagoon B Acid Wastes 1.2.3 G,S
l';'C Stepan Chemical Lagoon C Acid Wastes ".2.3 G,S
l-D Stepan Chemical Lagoon D Acid Wastes 1.2,3 G ~
.-
l-E Stepan Chemical Sludge Dump Unknown 3 (;.S
Whitney Barrel Co. Drum Reclaiming Unknown 2,3 G,S,A
2-A South of Whitney Barrel
3 Lipton Pet Food Sediments Unknown 2.3,4 G.S,A
4 Ritter Trucking Co. Tank Trucks G! S , A
5 Merrimac Chemical Co. Factory Leaking 2,3 r"S,A
(now New England Barrels
Chemical Resins) (~ontents unknown)
5-A Merrimac Chemical Co. Pond Chromium, 2.3 G,S
Arsenic. Zinc,
Lead
6 Woburn Town ,Landfill G.S
6-A Woburn Town Landfill Leachate Pond 2.3 G.S
.. See notes following Table.
-------
Source
of Poten-
~1ap Suspected Infor- t i al
~ location Description Wastes mation Conduit (a)
7 Industrial AI"ea Factory Building 2,3
7-A Inpoundment A 2,3
7-B Si te B 2,3
8 Consolidated and Glue-Making Fac- ChromiuM and Other
Stouffer Chemical tory Heavy Metal Wastes
8-A lagoon A Unknown 2,3 G,S
8-B Deposit B (sampled) 2,3 G,S
8-C Pond C . Unknown 2,3 G,S
..8-D Arsenic lagoon D Arsenic, Zirconium, 2,3,4 G,S,A
Lead and Other
Heavy Metals
S-E Crescent Depo- Arsenic, Zinc
sit E ".:
8-F Dcpos~t F Arse"ic 2,3 G,e;
8-G' Hill G{b) Tannery Wastes (?) 2,3
8-H Pit H Unknown 2,3 G,S
8-1 Pit I Unknown 2,3 G,S
8-J Dragline Excava- Tannery Wastes (Ar- 2,3 G,S
tion J senic, Lead and
Other Heavy Metals)
8-K Tanks K Unknown 2,3
8-L Hide Treatment 2,3 G,S
Area
-------
.
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,
'.\ Source
of Poten-
Map Suspected Infor- tial
Code Location Description Wastes r.1ation conduit (a
B-Ll Lagoon Ll Tin, Lead, Anti- 2,3,4 G,S
r.1ony, Chror.1iul11
8-L2 Lagoon L2 Tin, Lead, Anti- 2,3,4 G,S
r.lony, Chromium
8-L3 Lagoon L3 Tin, Lead, Anti- 2,3,4 G,S
many, Chromiul'1
..
8-~t Hill M (sludge See Note c 2,3
dewatering)
8-N Pool N Tin, Lead, Anti- 2 , 3 ,4"
l!Iony, Chror.1iur.1
8-0 Deposit 0 White Material 2,3 -
(sar.1pled)
9-A "Hide Pile" Hide Pile '1 Chrontum, Zinc, 2,3,4
Lead '
- '
9-8 -Hide F ilel! Hide Pile 12 Chroni un, Zi nc, 2,3,4
. Lead
NOTES:
b.
.
G, groundwater; S, surface water; A, air
Since the hill was mined for sand and gravel, the area may no longer be a source of
contamination.
a.
c.
The one remaining hill behind Ohm's Mayflower Building, cOr.1posed of materials of
various colors has been sampled, (see Reference 3).
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-------
.--....---....
summary of Phase II Soil "cavy Metal Analysis
1065 Samples Ana 1 yzed IHstr j bution of Samples >100 PPH
25 Perce 50 Perc. 15\ Perc.
Element 0-100 PPH >100 PI'M >500 PPH > 1000 PPM Concent. Concent. Conccnt.. Max UntO Avcr~~~
A["scnic 105 360 121 56 188 344 100 30nOO 809
Chrun ilan 144 321 283 111 195 5H 1890 80600 2]on
Copper 625 440 202 106 19B 418 940 2]300 1042
(.cad 511 548 346 249 ))0 819 2380 54400 2126
Merc\I["y 1058 1 2 1 I«)On
:<'.inc 1131 628 310 191 214 49() U50 12(.(,00 2012
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-------
~_. - ~ ~
MONITOR WELL ANALYSIS
IIEAVY Cr.6 TOTAL
METAI.S pll CONDUCTIVI':'Y CYANIDE PIIENOLS ORGANIC C~POUNUS
tOCATION 119/1 Ilaho/c. ,,<]/1 11«)/1 11<]/ I 11«)/1
---------.--
nW-1 8e-8 6.55 950 N.D N.D N.D. BE]9(napthalene)-61
BEl](bls(elhyl huyl) pM ha lal.e) - 12'.)
"BE29(dl-N-octyl phtha hte J -II
trlchloropropene 144
trl.ethyl benzene 45
ethenyl .ethyl benzene 45
brollocyclo hexene-84
hexahydro Azeplnone 114
OW-IA Oe-8 6.12 520 N. D. N.D. 62 OEJ)-IBI
Zn-55 D£29-14
hexahydro Azeplnone 60
OW-2 Zn-J1 6.68 110 N.D. N. D. N.D. V022(lIethylene chlorldeJ-]}
BEU-l!;
OW-] Zn-)2 1.06 900 N. D. N.D. N.D. V022-)1
Bf:1J-l1
hcxahydro Azeplnone 202
uW-4 8e-6 1.12 410 N. D. N.~. N.D. 8EI)-II2
In-26
OW-5 Zn-50 6.19 ]80 N. D. N.D. N.D. V022-IH
BEl )-50
8£)9-15
trlchloropropene 5)
lrllllelhyl hexene 100
Orolllocyclo hexene 18
hellahy.!ro Az(!plnonc 11
ow-r. In-J'.) 6.5) 440 N.D. N. D. N. i). V022-'12r.
1\1:]9-14
IIW -"' Ao-Ie 6.nl 150 N.O. N.D. N. D. V022-HI
In- "16 IIE)9-20
OW-8 A9-2 1.')) 590 N.O. N. D. N.D. V022-11
1n-4I 01:1]-'1"16
OW-'J Cu-2n 1.5 J 1250 N.D. N.D. 1J 111:]9-20
Zn-28 01:1)-691
0E19-10
-I ' I I" hi.. r- 0 I'r- n ...." 0 - ',n
1 rime' Ilyl h,! II ('ntl- 011
. hell ..hy... 0 ALel,1 n"lIe I I
m BE 39 (NAPHTHALENE)
r- I I
m
-------
-
HEAVY Crt6 TOTAL
Mt:TAL5 pI! CONDUCTIVITY CYANIDE PIIENOLS ORGANIC COMPOUNOS
LOCATION ,,«]/1 Ilmho/c. ,,«]/1 11«]/1 11«]/1 119/1
----- ---- - -
OW-IO "8-2 5.20 ]90 N.D. N.D. N.D. V0221.ethylene chlorlde)-IO
CIl-ltO BE I] IBis lethylh..)'1 ) phlh... lale) - 42
%n-5100
OW-II "5-1 6.01 610 N.D. N.D. N.D. V022-28
Zn-15 BEl )-21
OW-12 Aq - 10 1.61 >noo 94 N. D. )90 .ethylene chlorlde-19
A5-26 VO)fBenzene) 491
8a-2)0 '/025(Toluene) 1100
Cr-120 AEIOlphenol)-2)6
CII-tO 8£)9Ineplhelene)-61
NI-IO BE1]lphthelate)-1090
Zn-51 ..et h)' 1 phenol-689
Oe-5 cyclo heplalrlene-1910
II. l-bI11hen)' I J -] -0 1-90
Sui fonvl bls benzene - 984
11.1 bilihenvil -2.2-dlol 54
OW-I] "9-1 1.52 1400 N.D. N.D. N.D. dlehlorotrlfluoro ethane-190
1'81-120 B£I ]-2J10
Zn-8 IIF.29101-N-Ocl)'1 phlhahle'9-2)
Be-1 sill fonyl bls benzene 81
OW-J4 A5-9 6.1) 1600 N.D. N.D. N. 0. Toluene 114
Zn-540 BEI)-l2tO
De-8 DE)9-H
O£29-U
trlehloropropene-12
tr I.elhvl henzene-21
ethenvl .ethyl henzene 11
bro.ocyelo heMene ]8
sill fon)' I bls benzene )1
OW. I 5 Zn-]I 6.50 510 N.D. N.D. N.O. BEI)-108
110-8
OW-16 A6-5 1." ) 1500 10 N.D. 1900 Acetone - 2110
lIa-200 MEK 216
Cr-IOO 4-8Iethyl pentanone-242
NI-60 tolllene-950
Zn-In Br. )9-1 J2
11£-6 M:I 0-95
-t IIEI]-204
~ DE29-1S5
OJ henzalftehVde-64
,.. cVelo hCI'lal r lene 2').0
m ....Ihyl 10111111'" I c IIel.1 ~I]
..elhvl "hen,,1 808
~
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0
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rot:,
-------
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riH'C 1 of 1
IlEAVY Cr'6 TOTAl.
METALS pH CONDUCTIVITY CYANIDE PIIENOLS ORGANIC COHPOUNDS
LOCATION 8'C) II "..hole. 8.C)/1 ! 81C) /I 8'C)/1 81«,1/1
------ - ----- 4..
OW - 11 A5-16 6.90 ) 1500 )1 N.D. 1840 8enzene-141
NI-60 Tetraehloro ethane-16
Pb-10 Toll/ena 111
Sb - 16 AEI0-45)
%n-112 B£IJ- H I
I\e-9 8£29-126
DU9-1)
bro.o eyel~he.ene )5
II,I-blphenyll 2-01 91
unknown 119
Bul tonyl bls benzene 221
II,I-blphenyll-J-OI 121
OW-18 Cu-I!»O !».S8 950 N.D. N.D. N.D. V026(Tran8-1,
%n'-6090 2-dlehloroethylenet-10
De-1 V029(lrlehloroethylene)-16
0t:15(Dulyl 18cnzyl I'hl~.alalt!) -1)
8EI)-2200
0£29-180
phthalales-61
lrilielhyl trldecatrlcnc /I'lrlle-.6J
OW- 88a Cu-80 6. tJ 1000 N. D. N.D. 0£1)-)52
%n-126
88-1
IIw-I' 1\8-1 6.19 540 N.D. N.D. ILD. N.D.
~n-41.000
OW-I').. "'s-)I 6.~" 480 N.D. N.D. N.D. IIclCahycl'"oil z'~p t nonC! - 7.1.
Z/l-16 Unknown clClrdclthle 14
. I"
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H.
. I
14
H.
... 22
» ow - 20 "'9-14 8.42 640 N.D. N.D. N.n.
OJ Zn-20
r-
m oW-20., "'nuIOf. 6.1J ')00 11.0. N.O. N.n.
I\) Zn- 24
n
0 I I
:::I
...
-------
ICATION
-----
OW-12
OW-14
ow - 16
nW-11
-t
:a:-
m
r-
m
c,.)
PRIO ITY
POI.LUTAHT - "9/1
DEJ9-IS
o
Hot Inst.lied
Nol Instal led
1/82
OTIIER
COHPOUNDS - 111)/1
Methyl Butanoic
acid 121
lenzoldehyde 22
Dlhydrotetrazlne
102
lenzene Acet Ie
Acid 18S0
lis Sulfonyl
Benzene 6S I
o
--.-"
Monitor Wells with £levateJ VOC Ana!J~~
1/16/8) or 8/]0/8)
PRIORITY OTIIER
POLLUTANT - Ilg/l COHPOUNOS - 111)/1
Benzene
toluene
1£11
BEJ9
.,1
1100
1090
68
Toluene
II.
To I uene
9S0
Benzene 141
To luene 111
Tel rachloro-
etl~ne 16
I I
bls sulfonyl
benzene 989
cycloheptatrlene-
1910
Trlchloropropene
12
Trl_ethyl benzene
21
Elhenyl .ethyl
benzene 11
Brolllocyclohexane
. )8
Bls sulfonyl
henzene
Acetone
ME\(
4-lIIothyl
11
2110
216
pentanone
242
voc PRIORITY
POLLUTANTS - .. 1)/1
Benzene
toluene
20]
)SS
Toluene
1)
"Toluene )2600/)1900
Benzene
Toluene
"dnpllcate 8allll)le
9/29/8)
402
20)
OTIIER-YOC-- --r
COHI'OUNOS- 111)/1 I
Acetone
11
phtha Iale9 - 42
""celonu 1410/14~O
"2-propanol 4Q/40
."~K :.>lfi/211
. )-lIIulhyl fllJdn
14/:'>11
4-lIIelhyl .."nldll"I"~
unO
-------
r
EP Toxicity Tests of 5011 Composites
Heavy Metal Concentration Percent of
Sample Sample Heavy Soil Composite EP Ex.tr act Sol1 Metal
Composi te Location Depth-Ft Metal PPM (~g/g) PPB (~g/ 1) Ex tr ac ted
'1 29450 1 As 169 N. D. N.D.
29450 3 cr (total) 229 1 1 0."
29450 5 cr+6 Not Anal yzed N.D. N.D.
30360 1 Cu 200 50 0.5'
Hg 1.8 N. D. N.D.
Pb 738 110 0.3'
Zn 314 1630 10.4S
'2 30360 5 As 306 N. D. N. D.
30360 7 Cr (&otal) 798 N.D. N.D.
39210 1 cr+ Not Anal yzed N.D. N.D.
39210 3 Cu 298 29 0.2S
Hg 2. 1 N. D. N.D.
Pb 991 N. D. N.D.
Zn 462 363 1.6'
13 39210 5 As 621 N. D. N. D.
42360 1 Cr (6otal) 119 N. D. N.D.
42360 3 cr+ Not Anal yzed N. D. N. D.
42360 5 CU 881 226 0.5~
Hg 1.7 N. D. N.D.
Pb 1943 20 0.02
Zn 729 2920 8'
As N. D. N. D. ~
'4 43330 1 43
52300 1 Cr (&otal) 943 11 0.021
52300 11 cr+ NOt. Anal yzed N.D. N.D.
52300 26 CU 101 N. D. N.D.
Hg 0.5 N. D. N.D.
Pb 533 N. D. N.D.
Zn 208 581 5.6~
N.D. - Indicates less than instr\Jllental detection levels
As
Cd total)
cr +6
Cu
Hg
Pb
Zn
<30 PPB
<3 PPB
<14 PPB
<2 PPB
<0.5 PPB
<20 PPB
<1 PPB
-------
Borehole Gas Emission Rates
(Vol ume of Collection Bag = 4.2 Cubic Feet)
Meter Read ing s
Bore Combustible H~S Time to Fill Bag Generation
Hole Test Gas - I . P M minutes Rate (cfm)
9 1 34 >250 18:00 0.23
2 52 >250 16:45 0.25
3 42 >250 13:00 0.32
Avg. 0.27
10 1 40 >250 2:55 1.44
2 46 >250 3:45 1. 12
3 44 >250 3:30 1.20
Avg. 1.25
11 1 44 >250 21: 30 0.20
2 52 >250 26:30 0.16
3 47 >250 22:15 0.19
Avg. 0.18
12 1 30 >250 48 0.091
2 24 >250 41 O. 11 0
Avg. 0.101
13 1 24 >250 182 O. 023
2 28 ' >250 210 0.021
Avg. 0.022
20 46 0/115 1114 0.0038
21 1 56 0 6:35 0.64 ,
2 52 0 7:50 0.54
3 48 0 5:35 0.76
Avg. 0.65
-------
Borehole Air Analvsis
-
Bore Hole I.ocation CCmI,)ound Conc. (PPM)
Bft 9 52451 hydrogen sulfide 5700/5530 (1)
2-propanethiol 180
methanethiol 64
2-butanethiol isomer 3.4
ethanethiol 3.1
methyl fur an isomer 1.3
trichlorofluoromethane 0.59
BH 10 51411 hydrogen sulfide 1.8\12.1\ (1)
methanethiol 50
2-propanethiol 42
ethanethiol 8
carbon oxide sulfide 6.3
benzene 1.1
I BH 11 52431 hydrogen sulfide 5800/5600 (1)
2-propanethiol 42
I
I DI~thanethiol 20
ethanethiol 6.S
J carbon oxide sulfide 5.4
2-butanethiol isomer 2.2
BH 12 52381 hydrogen sulf ide 1.9\11.9\ (1)
methanethiol 150
2-propanethiol 55
ethanethiol 17
carbon oxide sulfide 13
benzene 11
carbon disulfide 11
dimethyl disulfide 7.5
methyl luran isaner 1.4
2-butanethiol isomer 1.1
toluene 1.1
Bft 13 53423 hydrogen sulfide 2.0\12.1\ (1)
2-propanethio1 180
methanethiol 110
ethanethiol 19
carbon oxide sulfide 12
dimethyl disulfide 7.8
2-butanethiol isomer 5.5
carbon d isulf ide 3.3
benzene 1.5
trichlorofluoromethane 0.63
(1) duplicate analyses, same sample
-------
,
.."...-.,....-- --' .... ¥.
~
.
.
Bore Hole Location Compound Conc. (PP~)
BH 14 36532 hydrogen sulfide 2000/1900 (1)
2-propanethiol 9
methanethio1 2.4
BH 16 37521 hydrogen sulfide 51/43 (1)
2-propano1 20
2-propanethio1 6.6
methanethiol 4.3
carbon oxide sulfide 4.1
ethanethiol 4
dimethyl disulfide 1.1
BH 17 39551 2-propanethio1 11
methyl furan isomer 2.8
ethanethiol 2
BH 19 51301 hydrogen sulfide 200/200 (1)
2-propanethio1 17
benzene 2.3
toluene 1.6
trichlorofluoromethane 1.6
BH 20 52301. hydrogen sulfide 710/690 (1)
toluene 0.73
BH 21 51291 hydrogen sulfide 58 IS 0 (1)
benzene 1.2
tctuene 0.76
SH 22 40601 (nothing detected)
BH 23 29412 hydrogen sulfide 5300/4600 (1)
2-propanethio1 47
methanethiol 18
toluene 3.9
ethanethio1 2.5
bis (2-methylpropyl) disulfide 1.9
BH 24 44521 (nothing dete-=ted)
BH 25 43571 hydrogen sulfide 240/250 (1)
methanethio1 220
ethanethiol 77
dimethyl disulfide 1.6
(1) duplicate analyses, same sample
-------
~-
-
-
.. .-. ... ....,.'. -.
1
!
DIUCT SENSORY EVALUATION or IOU ROLl CASES
Dose/Response Ansl,sis(2)
;
Ion r Dtlutiona
Hol. Dilutions it -A I Ite 8r . to
110. Thresholcl( Slope Int. Caef. TtA - 1 Odor Characteristica
- -
9 64,000 1.23 6.12 0.910 14,000 H2S, X-SR, sour, fatty acid, fecal,
ontony-SH, solventy
10 )1 x 106 1.40 8.81 0.91] 430,000 H2S
11 256,000 1.12 6.29 0.994 50,000 H2S, rubbery, sulfide, oniony
12 512,000 1.66 9.89 0.993 230,000 H2S
13 512,000 1.21 6.99 0.941 86,000 R2S
14 128,000 1.31 1.30 0.994 40,000 H2S, trace fecal, trace sour
16 128,000 0.83 4.49 0.914 15,000 Cheesey sour, dirty sour, burnt aweet,
trace fecal (butyric, propionic, and
isovaleric acids)
17 8,192 0.73 3.35 0.989 2,000 Ani_I, aweet fralrance, fecal,
OKS, ..sty, auUldy (WTP)
19 4,096 1.16 4.55 0.981 1,'00 Sulfidy, aour, oniony-SR, tarry,
feeal
20 32,000 0.91 4.53 0.994 4,200 Sour, oniony, SR, vepubl. aulflde,
~ rubbery, sl18htl, fecal a~cI R25,
naphthalene (80th balls)
~i .
21 4,096 1.04 4.22 0.993 1,200 Oolony, aulfid" anl..1, herse"
rubbery, tarry, fecal
~t'
Gle:
~F I I
-------
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-4
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-
DIRECT SENSORY EVALUATION 01' IOU ROLl CAS!S
Dose/Responae Analyaia(2)
lore r Dilutiona
Hole Dilution.(f, -A I Re Br . to
~ threahold Slo,. Int. Coe f . TIA - 1 Odor Characteriatica
22 2,048 1.07 3.73 0.992 350 Horsey, an1881, fecal, leathery,
aulfide, oniony
23 512,000 0.99 6.06 o. 946 135,000 H2S, trace oniooy, oniooy-SR, rubbery,
ani_l, fecal
24 2,048 0.83 2.93 0.967 200 Fecal, rubbery .ulfide, ftletable
aulfide, ~ni881, 8U.ty, VWTP
25 512,000 0.99 5.71 0.982 55,000 Fer.ented aour, cheeaey, larbaeey
(1)..cophed 'y 1001 of the panel participant a .
. (2)...u1ta 01 ".t fit for all data, TIA - A (101 Dilution.) + I.
I I
-------
lore
IIole 110.
,
10
u
12
13
14
16
17
19
20
21
22
23
24
2S
SENSOR! EVALUATIONS 07
ADSORBED lORE BOLE OoolS
Air 11 uud
Odor Character18tica
Solvent Eluted
Oniony, aour, 8Ulf1dy,
laurut on1ol1Y
Oo1ol1Y, horaey, aDtmal,
fecal
Oo1ol1Y, fecal, rubbery,
8Ulf1de, DHS or DHDS
Oo1ol1Y, horaey, ~MS,
an1.ul
Coruy (DMS)" beray, fecal,
veaetable 8Ulf1de
recal, burnt .".et,
al1Uaal
./1..
RIA
0010111, .arl1cky, rubbery
.'1..
Trace acetic acid, 8Ulf1dy,
horaey, al11aa1
If/A
Oo1011Y, .our, rubbery,
aD1JDal, horaey, fecal
BfA
Putrid, cheese" aarbaae,
fermented .our, trace
fecal, coffee-like-SI
Ooiol11 (PI' or al11l-SI)
fecal (,ketole), 80lve11t1
l1aphthalene)
(Me or IT)-SB, Pr:"SB, fecal
aDd fatt1 acid, rubbery
Ooi0l11, (Pr or allyl-SB),
fecal, ,-dichlorobel1zel1e
Ooiol1y-SI, rubbery-51 (TIM),
multy-elrthy. borley. trace
.ketole
-SB (TIM'?), mu.ty, aniul,
fecal, .katole
Rubbery-51 or aulfide, ~ty-
earthy, fecal ~)
./1.
.'1..
-SI (Me or IT), tarry,
0111011Y, WTP
III..
Sulfidy, fuel oil, WTP
If/A
-SB, fuel oil VWTP, fecal
. .'1.
Cheese" burnt, auimal,
fecal (WWTP), benzene-tarr,
(trace ..thyl benzene)
-------
GROUND WATER REMEDIATION METHODS
mlITTED FROM FURTHER EVALUATION
Ground Water Interception/Recovery
Remedial Method
1.
Containment barriers, slurry
walls or grout curtains with/
without ground water pumping
2.
Water table adjustment to min-
imize flow through waste mat-
erial
Omission Rationale
Feasibility and Reliability,
Environmental Effectiveness, Cost:
A slurry wall/grout curtain around
entire site is not feasible as a result
of the integrity of the bedrock floor
underlying the site. The bedrock
to the east, west, and south is fre-
quently fractured, permeable and dips
steeply under the site. This will not
be suitable as a floor for a slurry wall
or grout curtain. A slurry wall would
significantly heighten the water table
at the site and ground water pumpage
would be required anyway. Permeabilities
of sediments underlying the site and
adjacent to the buried valley are low,
so many wells would be required.
A slurry wall/grout curtain upgradient
of the site to reduce inflow of ground
water is not feasible because most
ground water flowing in the unconsol-
idated deposits under the site
originates as precipitation on the site.
Very little flow into the site Occurs
from unconsolidated deposits upgradient
of the site. This would, therefore, have
no effect on the migration of the benzene
plume.
"
Environmental Effectiveness:
Ground water flowing through the uncon-
solidated deposits underlying the site
originates as precipitation. Very
little water enters the site through
unconsolidated deposits upgradient, so
upgradient pumpage would a have neglig-
ible effect on total flow rate.
-------
GROUND WATER REMEDIATION METHODS
OmnED FROM FURTHER EVALUATION
,
t
Ground Water Treatment
Remedial Method
1.
Treat recovered ground water
with ion exchange resins
2.
Treat recovered ground water
with reverse osmosis
3.
Treat recovered ground
water with PAC
4.
Permeable treatment bed for
VOC, solids removal
Omission Rationale
Feasibility and Reliability,
Environmental Effectiveness, Cost:
Treatment via ion exchange requires
pretreatment to remove. solids, competi-
tive ions and other resia fouling
agents. Additionally, multiple exchange
resins would be required to remove
potential range of ions identified in
soils and ground water. Pretreatment
requirements, number and life expectancy
of resin columns increases capital cost
significantly above other alternatives
without equivalent increase in environ-
mental effectiveness.
Feasibility and Reliability,
Environmental Effectiveness: Reverse
osmosis has extremely stringent
' pretreatment requirements to avoid
immediate failing. The pretreatment
steps will improve water quality to
acceptable levels (with the exception
of arsenic removal) without incorporation
of reverse osmosis or the costs inherent
in the process. Therefore, increased
cost with no significant increase in
environmental effectiveness renders
this process unnecessary for attaining
required low effluent concentrations.
Environmental Effectiveness, Cost:
PAC offers no advantage over GAC for
treatment efficiency in WOburn-type
application. Filtration required prior
to discharge and disposal of spent PAC
after filtration increase O&H require-
ments and cost far in excess of GAC
with no practical environmental benefits.
Feasibility, Reliability,
Environmental Effectiveness: Effective-
ness of this technology is not well
developed due to short circuiting!
channeling and nondistributed contact.
TABLE 10
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,
[
~
GROUND WATER REMEDIATION METHODS
OMITTED FROM FURTHER EVALUATION
Ground Water Discharge
Remedial Method
1.
Treatment, discharge to MDC
sewer
Omission Rationale
MDC cannot accept additional flow
until court-ordered mandates are in
place
Same as above.
Feasibility and Reliability:
Technically feasible only for small
volumes of water such as would be
generated by hot spot pump out.
Greater than 50-75 gpm would overload
the shallow aquifer and cause surface
flooding. This is particularly a
problem in developed areas.
Same as above except a slightly
greater (100 gpm) quantity might
be accomodated. However, extensive
development in the area north of
Mishawam Road limits space for recharge
facility. Flooding of adjacent devel-
oped area is likely.
Might accomodate up to 400 gpm and
avoid flooding and land availability
problems, but additional well costs
and treatment (to avoid plugging)
without any significant advantages.
TABLE 11
2.
Direct discharge to MDC
sewer
3.
Tre~tment, discharge to aquifer
u~gradient via trench, pond or
leach field
4.
Treatment, discharge to aquifer
downgradient via trench, pond
or leach field
5.
Treatment, discharge to aquifer
-------
FUNCI'IONAL ANALYSIS ""TlIX -- 'UNCnONAL AREA:
"elghting On-Site Hot Spot Recovery
Evaluation Criteria factor Rating COII1IIIent
1. Reliability 1.1 .. Difficult to de fine hot
lipot
2. Con.tructibility 0.6 5 lasielt to install due
to .inm.. nUlllber of
wells installed at
Ihallover depth
3. llIIple.entation 0.5 5 Pu8ping duration .horter
Tille Frue due to relatively undi-
luted cont..inant plume
4. EnvirolWental 2.0 3 "ill reduce the potential
Effectivenes. risk to the dovngradient
receptor population
Total 15.9
Note:
Ratings range fr08 I (poor) to 5 (e.cellent).
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N
GROUND WATER INTERCEPTION/RECOVERY
Dovnqradient of Site Dovnqradfent of Plu.e
Recovery of Ground Water Recovery of Ground Water
Raling COimlent Raling COIIIIIent
5 Would collect the .ajor- 5 Would ensure that no ben-
ity of presently known zene .igrate. downgradient
concentration. of benzene
4 'ever well. than full down- Z up to 5 recovery well.
gradient recovery to withdraw the entire
plllllle
3 "ay require a. 10nq aa 2 Long period to let up,
11 years due to variable operate and complete
fJovutes recovery of .igratinq
benzene
4 "ill .in18ize the poten- 5 will nullify the potential
tial risk to the down- risk to the dovngradient
gradient receptor population receptor population
-------
~
,
-
FUNCTIONAL ANALYSIS ItATRIX -- FUNCTIONAL AREA: GROUND WATER TREATMENT
Biological
Biological Treatm~nt, Trea~nt, Air Stripping,
Weighting Air Stripping Air Stripping Odor Control, Air Stripping Precipitation/Flocculation
Evaluation Criteria Factor Rating Comment Rating Conwnent Rating Comment Rating Comment
1. Reliability 1.1 4 Impacted by 3 Biological treatment 4 Impacted by alkalin- 2 Dependent on con-
alkalinity and requires additional ity and iron tinual process
iron operator attention lIIonitoring of mix-
ing speed, chemical
addition rate and
overflow rate
2. Constructibility 0.6 5 Easily constructed 3 Biological aystem re- 5 Easily conatructed 2 Construction in-
ss package system quires additional as package system volves mixing, floc-
unit, although pack- culation, sedimen-
age systea is avail- tation, sludge with-
abb drawal and storage
areas
J. Implelllentat ion 0.5 4 Can be on- Une 3 Increased number 4 Can be on-line 3 Iaplelllentation time
Tu.e Frallle within 2 or J IIOntha of process CQ81- within 2 or J IIOnths fr8llle ia longer due
ponenta increasea to the complexity
implementation tiae of the process and
fralle the number of pro.
cesa COlllponents
4. Environmental 2.0 4 Should alleviate 4 Biological treat8ent J Odor control with 4 Provides IIIOSt
Effectiveness ground water proble.s required only for hydrogen peroxide thorough treatment,
~f clean background water discharge would reduce organ- but sludge d/!o
air is available and ic content of waste watering and dis-
no other organic com- atream making subse- posal practices
-f pounds other than quent stripping easier. must be managed
~ benzene and toluene Phenol removal difficult properly to
identified ' prevrnt contami-
OJ nant re lease
r- Total 11.4 14.4 15.4 12.9
m
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'-
FUNCTIONAL ANALYSIS MATRIX -- FUNCTIONAL AREA: GROUND WATER DISCHARGE
Pump, Treat,
Weighting Pump, Treat, Recharge Discharge to Surface Water
Evaluation Criteria Factor Rating Comment Ra ting Comment
1. Reliability 1.1 1 Reliability of 3 Potential for
the process varies process upsets and
with the site sub- degradatioh of
surface conditions receiving ~aters requires
to be determined. Hay more complicated treat-
not be feasible without .. ment
flooding and direct
discharge to surface
water
2. Constructibility 0.6 2 Hay require deep injec- 3 Involves less com-
tion wells to prevent plex construction
flooding of developed than either recharge
areas option
3. Implementation 0.5 3 Extensive due to 3 Implementation
Time Frame required SDWA/UIC time less than
permit, Subsur- the recharge
face investigation options
and construction of
recharge system
4. Environmental 2.0 4 Recharged water 4 Requires treatment
Effectiveness would meet DWS to a level that
ensures maintenance
of surface water
quality standards
Total 11.8 14.6
....
~ Note: Ratings range from 1 (poor) to 5 (excellent).
m
,...
m
....
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U1
..~....
COST COKPARISON OF SELECTED ALTERNATIVES FRO"
GROUND WATER FUNCTIONAL ANALYSIS RESULTS
Remedial Total Implemen- Recommended
Alternative/Description Capital Cos t O&tt Cost tat ion Cost Ranking Ranking Rationale
I. Hot spot recovery, $0.8 " $0.14(2) $0.94" 3 - Least stringent
treatment with odor treatment required,
control, air stripping, roughly one-fourth
recharge on-site the cost of high-
est ranked alter-
native
II. Downgradient of site, $1.25 " $2.4 "(3) $3.65 " 1 - Stringent treatment
recovery, treatment with required to meet
odor control, air surface water
stripping, discharge to criteria.
surface water
III. Downgradient of plume $4.S " $6 . 5 H ( 3) $11.0 H 2 - "ore than triple
recovery, treatment with the cost of high-
odor control, ROC, air est ranked alter-
stripping, metals removal native without
discharge to surface water significant bene-
fit
Notes:
1.
2.
3.
See Appendix for detailed Cost Estimates.
6-Honth o&tt period for Alternative I
IS-Year O&M period for Alternatives II and III.
-------
WASTE DEPOSIT AND CONTAMINATED SOIL/SEDIMENT CONTROL
RE1-IEDIAL METHODS OHITTED FROM FURTHER CONSIDERATION
Omission Rationale
Remedial Method
Soil/Sediment Treatment
1.
Stabilization/solidification/
reburial .
2.
Encapsulation/reburial
3.
Incineration/residue
reburial
4.
Wet air oxidation/residue
reburial
s.
Land fanning
6.
7.
In situ microbial degradation
In situ solution mining
8.
In situ neutralization/
detoxification
Cost, Environmental Effectiveness,
Negative Environmental Impact Potential,
Feasibility and Reliability: Cost of
encapsulation/reburial of any or all of
the wastes on-site is an order of
magnitude greater than burial alone.
Wastes must undergo thorough analytical
characterization and pilot stabiliz-
ation testing to ensure compatibility
with a specific waste. The hetero-
geneous nature of the hide piles renders
this technique infeasible.
Feasibility and Reliability: The
~ncapsulation process has yet to be
applied on a large commercial scale
under actual field conditions.
Feasibility and Reliability:
Incineration is infeasible for
heavy metal removal.
Same rationale as No.3 above.
Feasibility and Reliability:
Landfarming infeasibile for heavy
metals removal.
Same rationale as No.5 above.
Feasibility and Reliability: Requires
homogeneous waste that is mobile and
that can be entrained in a solvent
phase, contaminants in the soils have
proven immobile over time and hide
piles present a very heterogeneous
environment.
Feasibility and Reliability, Negative
Environmental Impact Potential:
Heterogeneous nature of wastes resu~t
in the potential for poor contact wlth
neutralization medium. Toxic by-
products could be generated as a result
of the heterogeneous mixture of
wastes and presence of heavy metals.
-------
...
~
m
r-
m
...
.....
Evaluation Crl~~r~~
1.
Reliabilit,
2.
Construetability
3. 1~I8entatlon
Ti- Fr-
.. Envlron8ental
!Effectiveness
5. future Land V..
Total
Note:
fUNCTIONAL ANALYSIS MTRIX -- FUNCTIONAL AUA:
CONTMINATI!D SOILS
Wel9htin9 Alternative I
Factor Rating Coement
Alternative II
Rating Comment
Alternative III
Rating COII8IIent
Alternative IV
Rating COIIIIIIent
IN
RIfFS
IN
ROD
I.
,
~.
I
~
1.1
Reduce. both . Reducu both . Reduces both . Reducu both I
potential for potential for potential for potential for II
contact and contact and contact and contact and III
rainwater infU- rainwater inUI- rainwater infll- rainwater infll- IV
tration tration tration tration
V
c- c:1vU en- . C-n civU en- . C0880n civil en- . C_n c:1vU VI
9ineerlnl) tech- I)ineerinl) tech- gineerinl) tech- engineerinl) VII
nique nique nique technique VIII
CDlllpac:tlon re- 3 C~action re- . Lell layen 2 IIore layen IX
quired for larl)e quired for larl)e than Altern- than A It ern- X
soil vol\884! soil volW1le atives I and II at ives I and II
XI
.
0.6
.
0.5
3
2.0
SOM portions of 3
lite .ay be dif-
ficult to c08pletel,
seal
Addi tional in-
filtration COll-
pared to Alter-
natives I and I'
Would treat
.etals In ground
water if neces-
sary
SOM portion.
of site lIay be
difficult to
cOilpletely sui
.
.
.
0.5
1 Precludes I Precludes
deve10pstent develOplllent
on 70 acre. on 70 acres
16.8 1..8
3
Precludes
developllent
on 70 acres
Doe. not pre-
clude develop-
_nt. Require.
deed restrict-
ions.
1
18.3
16.3
Ratings range frOll 1 (poor) to 5 (eRcellent).
Alternative I - 24" clay. '" cover, vegetate.
Alternative II - 6" clay, 18" fill, '" cover, vegetate.
Alternative III - 24" offsHe fill. '" cover, vegetate
Alternative IV - 20 .11 PVC liner, 12" sand beds, 1'2" fill, 6- cover, vel)etate
f
r
,
S-2
S-3
S-4
S-5
S-6
S-7
S-8
S-9
S-10
S-11
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...
.
m
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fUNCTIONAL ANALYSIS MTRII -- fUNCTIONAL AREA: CONTANINAT!D SOILS (Continued)
Weighting Alternative V Alternative VI Alternative VII Alternative VIII
Evaluation Criteria factor Rating COI1IIIIent Rating Conunent Rating COIIIIIent Rating Comment
1. Reliability 1.1 ] Reduces potential 4 Allows future 5 Allows site 5 Allows site
for contact _site develop- development on developlllent
on portion of large portion on large
property and of property portion of
.ini..ius poten- property
t ional for
contact
2. Construct1bility 0.6 S Cu..on Civil engin- 2 Requires access 2 Requires safety 2 Requires safety
eering .ethods roads, reloca- precautions and precautions and
tion syste.. coordination coordination
design and
leachate collec-
tion system
]. IlIple.entat10n 0.5 S Short-te... due to I Long-te... due to Long-te... due 2 Less U..e than
Ti..e fra.e .in1..1 earthwork large vol- of to large vol- Alternative VII
required soil be ing of soil be ing since no back-
excavated and excavated, relo- fill required
and relocated cated and back-
fill required
4. Enviro~ntal 2.0 ] Would treat .etal. ] Excellent 10ng- 4 Would li.it infil- 4 Would Ii.it in-
Effectiveness in ground water if ter. efCective- tration and filt...Uon and
necessary ness due to gaseous emissions gaseous e.issions
odor
5. future Land Ule 0.5 4 Does not preclude ] . Precludes ] Precludes ] Precludes
developaent of site. develo.-ent developlllent developlllent
Requires deed re- on 13. (, acres on 15 acres on 15 acres
strictions.
Total 16.8 13.6 16.7 17.2
Note:
Ratings range frOCll I (poor) to 5 (eKcellent) "
Alternative V - (, inch cover, vegetate, deed restriction.
Alternative VI Construct RCRA landfill
Alternative VII Cor,solidate and cover with 24" backfill, 6" soH
',ernative VIII - Consolidate a"et cover with 24" backfill. 6" so'
~acllfill
backfill
-
--
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-I
:.-
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......
n
o
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0:
Evaluation Criteria
1. lIeliabilit,
2. Conatruct1billt,
3. J8ple8entatlon
Tiae fr8lle
4. Envir~ental
EffecUvenus
5. 'utur. Land Ua.
Total
Not.:
.atin9s ranqe from
Alternative IX
Alternative X
AlternaUv. II
fUllCTJONAL ANALYSIS 1lA1R11 -- fUNCTIONAL AREA:
WdCJhUOCJ
Factor
AltemaUve II
lIating Coanent
Alternative X
Rating Comment
Alternative II
Rating COIIIIIent
1.1
3
Reduces poten-
tid for con-
tact
0.6
5
Lial ted excava-
tion, fence and
deed restrictions
0.5
4
Readily
iap I rtae nted
2.0
2
Would treat
.etale in ground
vater if necea-
asary. Less cover
than other options.
0.5
5
Doel not pre-
clude develop-
.ent. Required
deed restrictiona
14.8
18.8
--
......
16.J
C'ONTMINATED SOILS (ConUnued)
3
Reduces po-
tential for
contact
4
Allows future
site develop-
ment on par t ion
of property and
minimizes poten-
tial for contact
5
COIII'IOn dvU
engineering technique
4
COIII'IOn civil
engineering
technique
4
Short-te,. due
to less earthwork
required
4
Readily
implemented
]
Would treat
.dell in
ground vater
if nece..ar,
4
Would treat
.ehll in
ground vater
if necus.rr
4
Doee not pre-
clude develop-
.ent. Required
deed restrictions
4
Doea not pre-
clude deve lop-
_nt. Required
deed rutric-
tions.
. (poor) to 5 (excellent)
Limited excavation and relocation
LiMited excavation and relocat'op
Cover areas in top 2 feet greater
fill/loil. . .
- Limited excavation and relocat~on of ditch elong Nev Boaton Street, fence and deed restrictions.
Cover areaa in top Z feet greater than either 300 ppa Aa, 600 ppa Pb or 1,000 p~ Cr vith 6"
1111/1011
of ditch along Nev 8oston Streets, fence and deed restrictions
of ditch alon9 Nev Boston Street, fence and deed restrictions.
-------
- --.... -.....-
COST COIIPUISOII or SELI!CTlD ALTERNATIVES noli
CONTAnINATED SOILS fUNCTIoNAL ANALYSIS RESULTS
runcUon81
Analysis Total IlIpl_n-
I_dial Alternative/De.crlption value Capital co.t 0&11 co.t tation Cost lankinq Ranking Rationale
I 24" clay, 6" cover. vegetate 16.8 t22.7 " $1 " $23.7 " 8 - Good functional ana1y.i.
- High cost
II '" cIa,. 18" fill. 6" cover. vegetate 14.8 U2.3" $1 " $13.3 " 10 - Low functional anal,si.
- "odente cost
III 2." fill. 6" cover. vegetate 18.3 $ 8.2" U" . 9.2 " 2 - High functional ana1ysi.
- "oderate cost
IV 20 .11 rYC liner. 12" .and. 12" 16.3 811.4 " $1 " '12.4 " 7 - Good functional anal,.I.
fill, 6" cover. vegetate - "odente cost
V 6" cover, .egetate. deed 16.8 $ 4.1" U" $ 5.1 " 3 - Good functional ana1,.i.
reuricUon. - Lov cost
VI .CIA landfill 13.6 $79.0" U" 880.0 " 11 - Lowest functional.ana1,.i.
- Highest cost
VII Consolidate, cover with 30" fill, 16.7 $18.0" U" $19.0 " 9 - Good function.l anal,ai.
20 .11 PVC, backfill of excavated - High cost
area.
VIII Con.olidate. cover with 30" fill, 17.2 . 9.0 " $1 " $10.0 " 5 - Hiqh functtonl1 Inl1y81.
-f 20 _il PVC, no backfill of excavated - "ode rate cost
~ areas
m "
r- IX Li-ited excavation and relocation 14.8 $ 2.3" $1" $ 3.3 " 6 - Low functional analysi.
m of ditch along Hev Boston Street, - Lowest cost
fr deed restriction.
..&
-------
. ,
-4
~
m
r-
m
...
Q)
n
o
.~
...
-
Q.
ae8ediel <ern8tive/Deecription
X Cover erees in top 2' greeter then
either ]00 pp8 As, 600 Pp8 Pb or
1,000 pp8 Cr with ]0 inch fill/eoil
XI Cover ereee in top 2' greater than
either ]00 Pp8 as, 600 pp8 Pb or
1,000 pp8 Cr with 6 inch fill/soil
-
-'
COST COIIPUISON 0' SILlCT!D ALT!RNaTIVIS noli
CONrAltINATI!D SOIL FUNCTIONAL ANALYSIS RESULTS (Continued)
functional
balyd. Totel I..l_n-
Value Cepitel Co.t 0&It Co.t tatlon Cost aenUng aenking aetionele
18.8 . 5.] II 81 " 8 6.] " 1 - Higheet functionel analyde
- "oeler.te cost
16.] . ].0 '1 . . ..0 . . - Good functional a.ely.i.
- Low cost
-------
,----- -
--
4.
AIR EMISSIONS METHODS OMITTED
FROM FURTHER CONSIDERATION
Remedial Method
Omission Rationale
Gas Control
1.
Urea-Formaldehyde barriers
Feasibility and Reliability: Effec-
tive permeability of foam can be
unreliable due to frequently encountered
installation problems.
2.
Tall Stack Dispersion
Feasibility and Reliability: Under
current policy, tall stack dispersion
is not acceptable to Massachusetts
DEQE for odor control.
Gas Trea tment
1.
Chemical Oxidation
Environmental Effectiveness: Chemical
oxidation using ozone or hydrogen per-
oxide has potential to generate haz-
ardous waste.
2.
Ion Exchange
Feasibility and Reliability: Not as
reliable as more commonly used carbon
adsorption.
3.
Excavate and Remove East
Hide Pile
Cost, Negative Environmental Impact
Potential: Cost would be an order of
magnitude greater than other feasible
alternatives. In addition, tremendous
odor generation would result from
unearthing decomposing waste material.
Stabilization
Environmental Effectiveness: Stabi-
lization using lime or sodium
biocarbonate has not been proven
effective for reducing emission rates
in landfills.
-------
-I
~
OJ
r-
m
I\)
n
fUNCTIONAL ANALYSIS ttATRIX -- FUNCTIONAL AREA:
EAST HIDE Plur
Evaluation Criteria
"eil)htin9
factor
Alternative A-4
Rating ~
Alternative A - 2
RaUng ~
Alternative A - 3
Rating ~
1.
Reliability
1.1
2
Pressure buildup aay
jeopardize cap
4
Carbons beds will re-
quire regular aaln-
tenance to assure
reliability
4
Ther.al oxidation
requires inspection
and .aintenance to
assure reliability
2.
Constructlbillty
0.6
5
C~n civil engineer- ,)
ing aethods
Treatllent unit
reduces construct-
ibility
,)
Treataent unit con-
nection to gas col-
lection piping reduces
constructibi 11 ty
.J.
lap lellen taU on
Tiae fra.e
0.5
5
Easiest to install
due to minimal
earthwork and lack
of collection pipes
4
Installation of 9a.
collection .ystea and
synthetic liner .ay
involve slight delay
4
Installation of 9a.
collection systea and
synthetic liner aay
involve slight delay
4.
!nvir_ntal
Effectivene..
2.0
I
Hydrogen sulfide 98S
.ay escape via ground
water or fissure.
4
.,ill treat eai..ions
and assure negligible
internal pressure
buildup
4
Will treat eai..ions
and as.ure negligible
intenl ptessure
buildup
Total
9.7
16.2
16.2
Note. :
Ratings range from I (poor) to 5 (excellent).
AlternativeA-2- "odify slope with new fill, install .ynthetic membrane liner cap, cover with topsoil, and establish vegetation
AlternativeA-3- "odify slope with new fill, install gas collection syste. piping, install synthetic membrane liner cap,
cover with topsoil, establish vegetatip~, carbon adsorption unit and 12-foot stack
AlternaUveA-4- "odify slope with new fill, install gas collection .yste.. piping, install ayntheUc III!8Ibrane liner cap,
cover with topsoil, establish vegetation, ther.al oxidation unit and JO-foot stack, propane storage.
--
-------
....
~
OJ
r-
m
N
....
COST COKPARISON OF SELECTED ALTERNATIVES FRO"
EAST HIDE PILE FUNCTIONAL ANALYSIS RESULTS
Remedial
Alternative/Description
Capital
Cost
".
A-2 "odify slopes with new,. $1,86 "(1)
fill, install synthetic
membrane liner cap,
cover with top soil
and establish vegetation
A-l "odify slopes with new
- fill, install gas col-
lection system piping,
install synthetic membrane
liner cap, cover with
topsoil and establish
vegetation, blower system,
carbon adsorption unit,
12 foot stack
$2.36 "
A- 4 "odify slopes with new
fill, install gas
collection system
piping, install
synthetic membrane
liner cap, cover
with topsoil and
establish vegetation,
blower system,
ther8al oxidation unit,
3,000 gallon propane
storage tank, 20 foot
stack
$2.50 "
Notes:
1.
2.
O&tt
Cost
Total
Implementation Cost
RecOlNllended
Ranking
..--
Ranking Rationale
Questionable reliabil-
ity and environmental
effectiveness
To be evaluated during
pilot testing
To be evaluated during
pilot testing
Cost includes air monitoring. See Figure 3-7 for air monitoring flowchart.
O&H costs for Alternative I are considered zero because these costs are absorbed
in the overall site monitori'nq.,
O&H costs for Alternatives II and III are based on a IS-year life.
3.
$0(2)
$1.86 "
2
$0.30 "(3)
$2.66 "
I
$0.50 "(3)
$3.00 "
-------
ALTERNATIVE GW-2
CAPITAL COST INTERCEPTOR WELL SYSTEM - HOT SPOT RECOVERY
DRILL FIVE INTERCEPTOR WELLS
SUPPLY AND INSTALL FIVE 1J-20 GPM SUBMERSIBLE
316SS IMPELLOR PUMPS
$
24,000
SUPPLY AN~ INSTALL WELL MANIFOLD AND DISCHARGE LINE
ELECTRIC SUPPLY 'FOR PUMPS
5,oJ:)
17,00:)
1,00')
MISCELLANEOUS
2,'JOO
INSTALL EIGHT 2" dia. PIEZOMETER WELLS
~.. ° , ° 0 °
GROUNDWATER CONSULTANTS
Intercept~r Wells
Pie zometer Well s
Pu'Uping Test
Start-up
pu:nping Ow-16
Report Writing and
COSTS
26,000
Issue
SITE I~PROVEMENTS
.5 Acres of Land
3~' x 40' Pre-engineered Building
4~' x 50' Curbed Concrete Slabs
50' x 60' fenced En:losure
Site Lighting, Grounding
Fur~iture, Safety Supplies
53,000
76,000
11,000
5,000
4,000
1,OJO
15,:'), OJ:!
VOC STRIPPING COST
, 100 GPM Pu:np C.!.
1000 ACFM Blower FRP
Two 48"dia.x35' High
TO'..Iers 304SS
Piping, Va~ves
E1 e ~ tor i c a 1
In ~t r ume:1 tat i on
Pa1nting
Pac ked
3,000
2,000
66,000
9,000
1,000
5,01)0
1,O\)0
87,080
-------
,
"..
...0--. ....... ,,''''' . ~...... ,,",1111 -, '-""II" ....
"
ODOR REMOVAL
51 Fe C12 Tank 200 Gal. P?L
501 H~O, Tank 7000 Gal. Alum.
Grouna~ater Tnk 8~00 Gal Fiberglass
Mixer 316 SS '
Metering Pu:nps (2) 0 to 1.7 GP'1
Pu1sef~eders (2) 3 GPH 316SS
A~itator 1/3 HP 304 SS
Agit3tor 5 HP 304 SS
Piping, Valves
Electrical
Instrume:'1ta~ion
Insulation
Paint
TOTAL DIRECTS
CONSTRUC:!ON EXPENSE
6 Months Duration ~ $20,000/Month
PREMIU~ ON OVERTIME
ENGINEERING
We 11 s
Ot her
1,000
21,000
10,000
2,000
1,000
1,000
1,000
3,000
7,000
5,000
1 ,00 a
1,000
54,000
$ 376,000
120,000
5,000
50,000
$es,ooo ! 5'
$150,000 + 37,000 + 54,000 ~ 15'
PUNCH LIST
SPARE PARTS
Sub-Total
CONTIN3ENCY & ESCALATIJN
CAPITAL COST
5,000
8,0:)')
$ 554,000
226,OJO
$ 790,000 :
~'
OPERATING AND MAINTENANCE COSTS INTERCEPTOR WELLS
HOT SPOT RECOVERY
Operating and Maintenance Costs for minimum six month
Duration is esti~ated at $140,000.
"~r .--,.},,"'. ,_.~'>:S-,~,- ..."".....~t;>;., :',;-~:. ,'- ,"~.~'
... Jo-_".."-r '.. .~~::-W".I'-.:?:'."'~~-: ",',' '-~~\i ~'.""
TABLE 22 cont'd
_-....:
.
'. '.." ~........,,::;"~. ~::~;.ris:~.t.!....(-"~~ -,.
._..--""'.~J!"-~' -' .,.- .' .~~)..- 'l"~ !.,... .~.'..
. . -'..
-------
'1
I
""Lol CnNA II Va: \3VV-"
CAPITAL tOST INTERCEPTOR WELL SYSTEM - 110 GPM
COSTS OF FIVE INTERCEPTOR WELL SYSTEMS
COSTS OF:
Site Improveme~ts
VOl:. Stripping
Odor Control
TOTAL DIRECTS
INDIRECT COSTS
Constructio~ Exp~nse
Premium on Overtime
Engineering
Punc~ List
Spare Parts
Su::>-Total
CONTINGEN:Y & ESCALATION
Sub-Total
150,000
81,000
54,000
120,0~0
5,000
50,001)
5,000
8,000
BOD Removal Costs from "Handbook for
Remedial A:tion at Waste Disposal Sites"
EPA-625/6~32-~a5, June 1982, Pg. 229.
Package Plant; Activated Sludge;
EX{~:'Idej Aeration; 2 Stages; Includes
Chlorination and Se:ondary Clarification.
TOTAL CAPITAL COST
$
85,00:;
$
291,O~O
316,0:)0
188,0':)0
$
564,0:):)
226,O~)
$
190,00):
460,000
$1,250,000
TABLE 2'3
-------
,
AL TERNA TIVE GW-3 cont'd
i
~
OPERATING AND MAINTENANCE COSTS
INTERCEPTOR WELLS 110 GPM
Supplies
H 0 S4fl/day @ .45/0
Ficf2 Negligible amount
Electrical
well Pumps (5)
Stripper Pump (2)
Blowers (2)
Metering Pumps (2)
Agitator (2)
Building a~d Site Lighting
30'x40'
Heat Tracing
Assume 5 Watts/LF of Pipe
100 feet of 2"0 Pipe
6 mo. Usage Fact~r
.6 Utilization Fact~r
$13.800
per year 200
7.5 HP
6.
10.
2.
6.
31 .5 HP or 23.5 KW
5.0
1 .8
30.3 KW/HR ~
$.12/K~H
Heating
Assume 20 Gal/Day of Propa~e ~ $1.50/Gal.
for Six M~nths
Maintenance
Assume 5~ of Capital Cost ($376,000 x 51)
Operation and Supervision
Assume Eight Hour Sn~ft. 355 Days @ $30/H~ur
..-
,"
Sub Total
$14,OOJ
32,0)')
5,00J
19,000
88,O')J~'.
$lSS,OJJ
-------
.'
BOD REMOVAL SYSTEM
OPERATING AND MAINTENANCE COSTS
Supplies
Electrical
Rota~ing Disc Aerator
810 wer s
3,000
3 HP
1
4 HP or 2.9S K~/HR
@ $.12/KWH
Heating
Maintenance
Assu:T1e half
equip:T1ent.
($230,000 x
12,000
of total cost of $460,000 is
Mai~tenance costs are 5'
5~)
'Operation and Supervision
Includej wlt~ Inter:e~tor Wells
Sub Total
15,000
Sub Total
$158,000
15,000
$173,000
TOTAL INTERCEPTOR WELLS
BOD REMOVAL
J'
TOTAL OPERATING AND MAINTENANCE COSTS
52,000
$225,000
Con~ingency
TABLE 24
'~~-i." '-",'....-', ",'.-. . -......--". ." . '.-- "". ..' :'-"~'.~-4.:'~~~.'.'-
-------
AL TERNA TIVE GW-4
. I
CAPITAL COST INTERCEPTOR WELL SYSTEM - 360 GPM
COSTS OF FIVE INTERCEPTOR WELL SYSTEMS
$85,000. Costs are increased 301 to account
for larger diameter wells and installation of
t wo we 11 sin a 1 a k e in 1 i e u 0 f dry 1 and.
$
lla,SCJ
COSTS OF:
Site Imp~ove~ents
V OC S t rip pin g
Oc or Con trol
Increase Size of
Odor Control
Ageing Tank in
150,000
97,000
54,'JOO
21,000
TOTAL DIRECTS
312,000
$ 422,000
140,000
5,OO'J
53,000
CONSTRUCTION EXPENSE
7 Months @ S20,OOJ/Month
PREMIUM ON OVERTIME
ENGINEERING
Wells -
Other -
$110,000 @ 5~
$150,000 + 37,000 + 75,000 @ 15S
PUNCH LIST
SPARE PARTS
5,000
8,000
Sub-Total
$
633,OOJ
CONTING~N:Y & ESCA~ATIJN
257,000
Sub-Total
!
8 9 0 , 0 0 0 -~
460,000
BOD Removal C,sts fro~ "Handbook for Re'T1ejial
Action at Waste Disposal Sites" EPA-525/6-82-005,
June 1982, Pg. 229. Package Plant; Activated
Sludgt; Extended Aeration; 2 S:ages; Includes
Chl~rina:ion and Secondary Clarification.
TOTAL CAPITAL COST
$1,350,000
OPERATING AND MAINTENANCE COSTS INTERCEPTOR WELLS
360 GPM
Total Operating and Mai~tenance Costs
(Present worth in 1985 do11~rs)
$2,360,000
Assumed to be the same as 110 GPM
TABLE 25
~ . ~ - "."- _.~.;:.' :- :~ .-~,;> - ...;...,;; _:~.!/:*,...:~ .~.. - '4t. .~-";U:"~"':,--,:,.,,~::-,'-~~~
-------
CAPITAL COST
HEA~t METALS REMOVAL SYSTEM 110 GPM
Process Eq~~pment
Sulfex Process consisting of Single Stage
Neutraliz3tion f~ll~wed by 2-Stage Clarifica:ion, ,
Filtration and Sludge Dewat~ring $646,000
501 Caustic Storage and Feed System 5,000 Gal. 22,080
Sludge Conveyor 12,000
$680,0)0
Saf~ty and Fire Equipment
4,)8:)
Building
30"~.xSO'L. Pr'~-engineerej, Insulated Building
1;1,0)0
Rigging
Piping
50,000
26,000
Substructures
Electrical
29,000
7S,000
Ins t r um e n tat ion
22,0-)0
Insu13ti~n
3,000
Painting
6,000
TOTAL DIRECTS
$1,O~9,OOO
Construc~ion Expense
6 months duration '@ $20,000/month
Premium on Overtime
12'),1)0,:)
5,000
Engineering
. Pac kage
Other
100,000
$600,001)! 5~
$449,0,:}-) @ 15'
::
Punch List
10,000
Spare Parts'
l4,OJG
, .
,"
Sub Total
$1.298.000
392,000
Contingency and Escalation
Sub Total
$1,690,000
110,000
Allowance for .5 acre Land Purchase,
Site Improvements, Fence
Capital Cost
$1,800,000
15-Year Monitoring Costs
(Present worth in 1985 dollars)
NONE
TOTAL IMPLEMENTATION COST
$!&,OOO,OOO
CD
t'
-------
CAPITAL COST HEAVY METALS REMOYAL SYSTEM
Process Eq¥Apment
Sulfex Pr~ce33 for 110 GPM Scaled
up to ~60 GPM using .6 Scale Up Factor
Safety and Fire Equipment
Building
~O'~.xlOO'L. Pre-engineered Insulated Building
Substructures
Rigging
Piping
Electrical
In's t r um e n t. a t ion
Insulation
Painting
TOTAL DIRECTS
Constru~tion Expense
6 months duration @ $20,000/month
Premium on Overtime
Engineering
Package
Other
$1,360,000 @ 51
$ 675,000 @ 151
Punc h Li st
Spare Parts
,,'
Sub Total
,"
Contingency and Escalation
Sub Total
Allowance for .5 acre Land Purchase,
Site Improvements, Fence
Capi tal Cost
360 GPM
$1,360,000
~,ooo
250,000
95,000
5~,000
5~,000
163,000
~1,000
9,000
5,000
$2,035,000
120,000
5,000
169,000
~
20,000 -
27,000 .
$2,376,000
71~,000
$3,090,000
60,000
$3,150,000
TABLE 27
-------
OPERATING INO MAINTE.AICE COSTS HEAVY METILS REMOVAL SYSTEM
110 GPM
S;PP1~e~
ota eagents Cost
(F. Heinze 11/6/85 memo
50S caustic 10 ,Gal/Day,
$26,000
$22,400
E/ R 1600E423)
12.76'/Gal ! .07871
3,600
Electrical
Sulfex System Horsepower
Assume 5QHP or
53,000
Building and Site Lighting 30'x80'
Heat Tracing'
Assu~e 5 Watts/LF of Pipe
150 feet of 2"0 Pipe
6 mo. Usage Factor
.6 Utilization Factor
37.3 KW
10.0
2.7
50.0 KW/HR @
$.12/KWH
Heating
, Assum~ 50 Gal/Day of Propane! $l.SO/Gal.
for s1 x mon ths
14,000
/
Maintenance
Assume 5S of Capital Cost ($1,049,000 x 5S)
52,000
Operation and Supervision
Included with Operating Costs of Interceptor
Well System
Disposal Costs
~,
15,000
J'
Sub Total
$160,000
50,000
Contingency
TOTAL OPERATING AND MAINTENANCE COSTS
$210,000
TABLE 28
-------
OPERATING AND MAIITEIANCE COSTS HEAVY METALS IE"O'AL SYSTEM
J60 GPM
Supplies
Same as 110 GPM .
Electrical
Power 150 HP or
1.ighting
Heat Tracing
$26,000
112 KW
15
5
132 KW/HR @ $.12/KWH
140,000
Heating
Maintenance
Assume 51 of Capital Cost ($2,035,000 x 51)
20,000
101,000
Operation and Supervision
Same as 110 GPM
Disposal Costs
Same as 110 GPM
Sub Total
15,000
$302,000
Contingency'
TOTAL OPERATING AND MAINTENANCE COSTS
88,000
$390,000 ,
Allow for 61 annual inflation per annum discounted at 12' per
annum for 15 years to determine total monitoring and maintenance
costs (present worth in 1985 dollars).
For 110 GPP(' Ststem
Annual O&M Cost
15-year O&M Costs (Present worth)
$ 210,000
$2,200,000
$2,200,000
$210,000
Therefor. for 360 GPM Annual O&M Cost
X
= 10.5
$390,000
10.5
TOTAL OPERATIIG AID MAIITEIAICE
COSTS HEAVY METALS REMOVAL SYSTEM
360 GPM
(Present worth in 1985 dollars)
$-.100.000
TABLE 29
. .~. ..~ . . "'-'4 ,"I"!.- .;,~. .~~~."..... ....~:..': - ,. -". ". '!'.;.,,:, '..." - ~~.,.- - ""':"':".' .--~'. ..-. .:..~..~ ':"'\~..tt~...., ~ ~ .
-------
ALTERNATIVE 8-2
A. Cover all As, Cr, Pb Waste Deposits with individual 'concen:ra-
tions of one or more exceeding 100 PPM, and :over the East
Central and the West Hide Deposit.
Cut, f111, regrade the top 12" of the existing
surface to develop new contours, eliminate water
pockets, prom~te better drainage, etc.
$
707,OJJ
Cover area with.a 24" clay barrier constructed
in 6" lifts. This clay barrier is composed of
Betonite Clay mixed at a rate of four pounds per
squ~re foot with native offsite soil to achieve
10- per~eability.
9,839,sao
Cover clay barrier with a 6" layer of top soil
and vegetate.
621,000
Relocate the South Hide Pile (include 25~ swell
up factor) to reshape the West Hide Pile slope
(allow f~r .one half of costs).
292,000
Cover f~rmer S~uth Hide Area with a 6" lay~r of
top soil and vegetate.
10,000
.Resha~e the slopes of the Wes~ Hide Pile usi~g
South Hide materials (allow for one half of co~ts).
255,000
Drain Wetlan~s with 60" dia. undergrounj p~ly-
ethyl~ne pipe to stabilize hide pile slopes (all~w
for one half of c:)sts).
20'),0')0
Cover area with a 24" clay barrier constructed in
5" lifts. This clay barrier is co~p~sed of Benton-
ite Clay mixe1 at a r3te of four pounds pe~ rquare
foot with native offsite soil to achieve 10-
permeability.
530,0')')
,-
Cover clay barrier with a 6" layer of top soil and
veg~tate.
40,0')0
:OTAL DIRECTS
$12,654,00J
Site Overhead Costs
Sur v e y 1 n g and T est Bo r i n g s
Dewater in g
Mobilization and Demobilization
Equipment and Personnel Downtime
1 ,5Ju, OJO
Ind irect Costs
Site Facility Costs
Stauffer Engineering \ Research
Outside Analytical Contractors
Sub-T~tal
2,095,0')0
Personnel
Contingency and Escalation
$16,253,000
6,397,')00
o
M
W
-'
m
CI
t-
CAPITAL COST
-------
AL TERNA TIVE 5-3
A. Cover all As, Cr, Pb
tions of one or more
Central and the West
Waste Deposits with individual concentra-
exceeding 100 PPM, and cover the East
Hide Deposit.
Cut, fill, regrade the top 12" of the existing
surface to develop new contours, eliminate water
pockets, promote better drainage, etc.
Cover area with a 5" clay barrier. This clay
barrier is composed of Betonite Clay mixed at
a rate of four poun9s per square foot with native
soil to achieve 10- permeability.
Cover clay barrier with an 18" layer of offsite
fill (includes 201 compaction factor).
Cover fill a 6" layer of top soil and vegetate.
and veget.ate.
Relocate the South Hide Pile (include 251 swell
up factor) to reshape the West Hide Pile slope
(allow for one half of costs).
Cover former South Hide Area with a 6" layer of
top soil and vegetate.
Reshape the slopes of the West Hide Pile using
So u t h Hid e mat e ria 1 s (a 11 0 w for on e h a 1 f 0 f c 0 s t s) .
Drain Wetlands with 60" dia. underground poly-
ethylene pipe to stabilize hide pile slopes (allow
for one half of costs). .
Cover area with a 5" clay barrier. This clay
barrier is co~posed of Bentonite Clay mixed at a
rate of four pounds per squ1re foot with native
offsite soil to achieve 10- permeability.
Cover clay barrier with an 18" layer of offsite fill
(includes 201 com~action factor).
,,'
Cover fill with a 6" layer of top soil and vegetat.e.
TOTAL DIRECTS
Site Overhead Costs
Surveying and Test Boring~
Dewater ing
Mobilization and Demobilization
Equipment and Personnel Downtime
In d ire c t Co s'=- s
Site Facility Costs
Stauffer Engineering & Research
Outside Analytical Contractors
Personnel
Sub-Total
Contingency and Escalation
CAPITAL COST
$
707,000
2,543,Q'JO
1,695,08:J
621,000
292,000
10,0'00
255,00')
200,0')')
162,000
~
103,000
40,0')')
$ 6,643,000
995,')80
1,146,0')0
$ 8,787,000
3,513,000
.-J
W
....
m
C[
t-
-------
A. Cover all As, Cr, Pb Waste Deposits with individual c~ncentra-
tions of one or more exceeding 100 PPM, and cover the East
Central and the West Hide Deposit.
Cut, fill, regrade the top 12" of the existing
surface to develop new contours, eliminate water
pockets, promote better drainage, etc.
$
707,000
Cover area with a 24" layer of offsite fill
(includes 20' co~pa=tion factor).
Cover fill with a 6" layer of top soil and vegetate.
2,261,000
521,OOQ
Relocate the South Hide Pile (include 25' swell
up factor) to reshape the We~t Hide Pile slope
(allow for one half of costs).
292,000
Cover former South Hide Area with a 6" layer of
top soil and vegetate.
10,000
Reshape the slopes of the W~st Hide Pile using
South Hide materials (allow for one half of costs).
265,00Q
Drain Wetlands with 60" dia. underground poly-
ethylene pipe to stabilize hide pile slopes (allow
for one half of costs).
208,000
Cover area with a 24" layer of offsite fill (includes
20~ compa:~ion fa:tor).
144,000
Cover fill with a 6". layer of top soil and vegetate.
4:J,'OOO
TOTAL DIRECTS
$ 4,540,OO,J
Site Overhead Costs
Surveying and Test Borings
De water in g
Mobilization and Demobilization
Equip~e~t and Personnel Downti~e
545,0':0
Ind ir ec t Co st s
Site Facility Costs
Stau~fer Engineering ~ Research
Ou~side Analytical Contractors
764,000
Per sonnel
Sub-Total
$ 5,849,000
Contingency and Escalation
2,331,000
CAPITAL COST
$ 8,180,000
TABLE 32
-------
- .. -- . - - - - -
A. C~ver all As, Cr, Pb Waste Deposi~s with injividual concentra-
tions of one or more exceeding 100 PPM, and cover the East
Central and the Wes: Hide Dep~sit.
Cut, fill, regrade the top 12" of the existing
surface t~ develop new c~ntours, eliminate water
pockets, promote better drainage, etc.
$
707,00')
Cover area wit~ a 6" layer of compacted sand.
Install a 20 mil PVC membrane liner. Install
a 6" layer of compacted sand over the PVC liner.
2,825,,)~J
Cover liner and sand with a 12" layer of offsite
fill (includes 20' compa~tion factor).
1,131,0:)0
Cover fill with a 6" layer of top soil and vegetate.
621,0:)0
R!lo:ate the South Hide Pile (include 25~ swe~l
up factor) to reshape the West Hide Pile slope
(allow f~r one ha~f of costs).
292,,)JO
C6ver f~rmer South Hide Area with a 5" layer of
top soil and veg~tate.
lCJ,C'JCJ
R~shape the slopes of the West Hide Pile using
South Hide materials (allow for one ha~f of costs).
265,')'):)
'D r a i n Wet 1 and s wit h 50" d i a. un d erg r 0 un d p ~ 1 y -
ethyl!ne pip~ t~ stabilize hide pile sl)pes (allow
for on~ half of costs).
2'J:) ,JOJ
Co v era rea wit ~ a 5" 1 aye r ~ f cOin p 3 ::: t e d san d .
Install a 20 mil PVC me~brane liner. Ins~all a
6" layer of :::orn~act~j sand ~ver the ?VC liner.
lS:)"J:J!)
Cover lin!r and sand with a 12" layer of offsite
fill (includes 20~ comiJa:::tion fact::>r).
72,OCJ!
Cover fill with a 6" layer ~f top s::>il and vegetate.
..'
TOTAL DIRECTS
40,00Q
$ 6,343,OJQ
,"
Site Overhead Costs
Surveying and Test Borings
Dewatering
Mobilization and Dem)bilization
Equipment and Personnel Downtime
76:),')0')
Ind irect Costs
Site Facility C~sts
Stauffer Engineering & Resear:::h Personnel
Outside Analytical Contractors
1,056, '),:)0
Sub-Total
$ 8,159,000
Contingency and Escalation
3,251,080
CAPITAL COST
$11,430,000
-------
r--
I
AL TERNA TIVE S-6
A. Cover all As, Cr, Pb Waste Deposits with individual.conce~tra-
tions of one or more exceeding 100 PPM, and cover the East
Central and the West Hide Deposit.
Limited excavation at the PX Engineering site.
Cut, fill, regrade the top 12" of the existing
surface to develop new contours, eliminate water
pockets, promote better drainage, etc.
Cover area with a 6" layer of top 50il and vegetate.
Relocate the South Hide Pile (include 25' swell
up factor) to res~ape the West Hide Pile slope
(allow for ori~ half of costs).
Cover former South Hide Area with a 6" layer of
top soil and vegetate.
Reshape the slopes of the West Hide Pile using
South Hide materials (allow for one half of costs).
Drain Wetlands wi:. 6c)" dia. undergrou!'1d poly-
ethylene pipe to stabilize hide pile slopes (allow
for O!'1e hal f of costs).
Cover area with a 6" layer of top 50i1 a~d vegetate.
Excavate limited quantities of waste deposits from
the PX engineering site. Transport to East/West Hide
Deposit area (includes 25~ sw~ll-up factor).
Backfill excavated are=s (includes 20' compaction
factor) .
TOTAL DIRECTS
Site Over~ead Costs
Surveying and Test Borings
Dewatering
Mobilization and Demobilization
Equipment and Personnel Downtime
In d ire c t Co s t s
Site Facility Costs
Stauffer Engineering & Research Personnel
Outside Analytical Contractors
Sub-Total
Con~ingency and Escalation
CAPITAL COST
$
706,~OO
521,Q')0
292,000
10,000
265,000
200,000
40 "J~O
33,000
77 ,000
$ 2,249,~')O
27J,JQO
373,0;'0
$ 2,897,0,)0
l,153,000
$ 4,050,000
-------
"'- (1...,...01;;..." \ "_.....
A . Rem 0 v e a 11 As, C r, P b Was t e De po sit s wit h in d i v i d u ale 0 nee n t !'" a-
tions of one or more exceeding 100 PPM, and remove tne East
" Central, the West, and the South Hide Deposit.
Constru:t a RCRA onsite contain~ent facility.
$ 22,838,000
Remove and replace waste deposits.
13,334,0'J0
TOTAL DIRECTS
$36,l72,OOO
Site Overhead Costs
Surveying and Test Borings
Dewater ing
Mobilization anj Demobilization
Equipment and Personnel Downtime
4,102,0'JO
In d ire c t Co s t s
Site Facility Costs
Stauffer Engineering & Research
Outsije Analytical Contractors
15,554,000
Personnel
Sub-Total
$56,428,000
22,552,OJO
Contingency and Escala~ion
CAPITAL COST
$18,980,000
.."
-------
ALTERNATIVE 5-8
A. Remove all As, Cr, Pb Waste Deposits with indi~ijual concentra-
tions of one or more exceeding 100 PPMj consolidate on the East
Central/West Hide deposit areasj and cover the East Central a~d
the West Hide Deposit.
Consolidation of 460,000 CY of waste deposits on the approximate-
ly 15 acres of the East Central/West Hide Deposit area will raise
the elevation by 18 to 20 feet. Therefore, increase surfa:e area
by 15' to account for height.
Cut, fill, regrade the t~p 12" of the existing
East Central Hide Pile surfac~ to develop new
contours, eliminate water pockets, promote
better drainage, etc.
$
113,~:j
Backfill excavated areas (includes 20~ compaction
factor).
2,583,01)0
4,968,008
Excavate and relocate (includes 25' swell up factor).
Cover area with a 6" layer of compacted sand. Install
a 20 mil PVC membrane liner. Install a 6" layer of
compacted sand over the PVC liner.
750,0~0
Cover liner anj san~ with a 12" layer of offsite
fill (includes a 201 c::>"I1pa=tion factor).,
300,00.J
Cover fill with a 6" layer of top soil and vegetate.
165,O~~
Relocate the South Hide Pile (in:lude 25' swell
up ra:t~r) to reshape the West Hide Pile slope
(allow for one half of costs).
292,0)')
Cover former South Hide Area with a 6" laye~ of
top soil and vegetate.
lO,OJD
Reshape the slopes of the West Hide Pile using
So u t h Hid e ~ ate ria 1 s (a 11 0 w for 0 n e h a 1 f 0 f c 0 S t s) .
"
255,000
Drain Wetlands with 6~" dia. u~~erground poly-
ethylene pipe to stabilize hide pile slopes (allow
for one half of ~osts).
200,'')):)
Cover area with a 6" layer of compacted sanj.
Install a 20 mil PVC membra~~ liner. Install a 6"
layer of compacted sand over the PVC liner.
Cover liner and sand ~ith a 12" layer of offsite
fill (includes 20' compaction factor).
13'),00')
72,OJJ
Cover fill with a 6" layer of top soil and vegetate.
4:),C~:
"
TOTAL DIRECTS
$ 9,948,OCO
-------
Al T'ERNA TIVE 5-8 cont'd
Site Overhead Costs
Surveying and Test Borings
De wa t e r i n g
Mobilization and Demobilization
Equipment and Pers~nnel Downtime
Ind irect Costs
Site Facility Costs
Stauffer Engineering & Research Personnel
Outside Analytical Contractors
Su~-T:)tal
Contingency and Escalation
CAPITAL COST
~.
1,194,ooa
1,571,000
$12,813,000
5,127,OO:J
$11,940,000
"
TABLE 36 cont'd
-------
A. Remove all As, Cr, Pb Waste Deposits with 1n1ivijual concentra-
tions of one or more exceeding 100 PPM; consoli~ate on the Eas~
Central/West Hide deposit areas; and cover the East Central a~d
. the West Hide Deposit.
Consolidation of ~60,OOO CY of waste deposits on the approximate-
ly 15 acres of the East Central/West Hide Deposit area will raise
the elevation by l~ to 20 feet. Therefore, increase surface area
by 15' to account for heig~t.
Cut, fill, regrade the top 12" of the existing
East Central Hide Pile surface to develop new
contours, eli~inate water pockets, promote
better drainage, etc.
Excavate and relocate (includes 25~ swell up factor).
$
116,O~O
2,588,0'.)0
C~ver area with a 6~ layer of co~pactej sand. Install
a 20 mil PVC me~brane liner. Install a 6" layer of
co~pa:ted sand over the PVC liner.
758,O)J
Cover liner and sand with a l2~ layer of offsite
fill (inclujes a 20.. co~pa:tion factor).
3~:),I)')O
, .
Cover fill with a 6" layer of top soil and vegetate.
165,O~O
292,00)
Relocate the South Hide Pile (include 25' swell
up factor) to reshape the West Hide Pile slope
(allow for one half of costs).
Cover f~rmer S~uth Hide Area with a 6" layer of
top soil and vegetate.
lO,O')'J'
Reshape the slopes of t~e West Hide Pile using
South Hide materials (allow for one half of costs).
255,1)1)0
..'
Drain Wetlands with 60" dia. underground poly-
ethylene pipe to stabilize hide pile slopes (allow
for one half of costs).
20~,,)~J
Cover area wit~ a 6" layer of compacted sand.
Install a 21) ~il'PVC me~brane liner. Install a 6"
layer of compacted sanj over the PVC liner.
lS),I)~J
-------
P.... I. ""'1. ...... .411'"\0 ~ II V" ~.~..; ~
~UIILU
Cover liner and sa~d with a 12" layer of offsite
fill (includes 201 compaction fact~r).
72,1):)0
Cover fill with a 6" layer of top soil and vegetate.
UJ"JOO
TOTAl.. DIRECTS
$ 4,98),000
Site Overhead Costs.
Surveying and Test Borings
Dewatering
Mobilization and Demobilization
Equipment and Personnel Downtime
598,000
Ind irect Costs
Site Facility C~sts
Stauffer Engineering & Research Personnel
Outside Analytical Contractors
837,000
Sub-Total
$ 6,415,000
2,565,000
Contingency and tscala~ion
CAPITAL COST
* 8,9.80,000
".
,.
-------
At. TERNA TIVE 5-10
A. Fence areas of was~e deposits, dee~ restrictions. Limited
excavation at PX Engineering site. Cover the East Central anj
the West Hi1e Deposit.
Fencing Costs, Dee~ Restrictions:
Area
F~ncing Footage
PX Engineering
Chrorniu:n Lagoons
Janpet
Wedge Area
Arsenic/Phytotoxi: Area
Stafford Lot
2700 LF
1500
2000
3000
900
10100 LF
$
173,000
Janpet - Presently fenced, therefore do nothing.
Chromiu:n Lagoons - Only the triangular shaped area ~etween
the mainline railroad right of way a~j
west of the railroad siding is to be
fenced.
,.
Excavate limited qua~tities of w!ste deposits
fro:n the PX e~gineering site, transport to East/
West Hide Deposit ar~a (inclu~es 251 swell up f!:tor).
Backfill ex~avated areas (includes 28' co:npaction
factor).
Cut, fill, regrade the top 12" of the existing
East Ce~tral Hide Pile surfa:e to develop new
contours, eliminate water pockets, pro:note better
drainage, etc.
Cover fil~ with a 5" layer of top soil and vegetate.
Relocate the South Hide Pile (include 251 swell
up factor) to reshape the West Hide Pile slope
(allow for one half of costs).
Cover former South Hide Area with a 6" layer of
to~ soi1 and vegetate.
38,0:)0
77,Oc;~
llS,:)~O
10:';,000
292,OJO
10,OJO
TABLE 38
-------
ALTERNATIVE 8-10 cont' d
R~shape the slopes ~f the West Hide Pile using
South Hide materials (allow for one half of costs).
Dra1nWetlands with 60" dia. underground poly-
ethylene pipe to stabilize hi~e pile slopes (allow
for one half of costs).
Cover area with a 6" lay~r of top soi1 and vegetate.
TOTAL DIRECTS
Site Overhea~ Costs
Surveying and Test Borings
De water ing
Mobilization and Demobilizati~n
Equipment and Pers~nnel Downtime
Indirect Costs
Site Facility Costs
Stauffer Engineering & Research Personnel
Outside Analytical Contractors
Sub-Total
Contingency and Es:alation
CAPITAL COST
,,"
255,000
200,':):)0
4'),0')')
$ 1,317,~O~
157 I JJ:)
173,:)00
$ 1,657,000
663,000
. 2.320,000
-
-------
OPERATING AND MAINTENANCE COSTS
YENT GAS HANDLING
Supplies
Electricitl
Bl~wer 5HP
Lighting and Instr.
Requirement.s
$ 5,00:J
3.7 KW
1.0
~.7 K~/HR @ .12/KWH
Maintenance
Capital Cos:s ~f Blower Syst.e~ is $50,000
Assume Maintenan:e @ 51 ($60,000 x 51)
3,000
Operation and Supervision
Includej with Operd:ing Costs of Groundwater Treatment
Sub Total
$ 8,00~
2,50')
Contingency
".
TOTAL OPERATING AND MAINTENANCE COSTS
$10,500
,-
/
-------
OPERATING AND MAINTENANCE COSTS
ACTIVATED CARBON SYSTEM
IVP Carbon with Na Ott Onsite Regeneration
Supplies
Assume Replacement of Carbon Every
Five Years 12,0001 @ $2.701# = $32,~00
5
$ 6,000
-
-
'Regeneration
Soak Carbon in Dilute Na Ott
$600/Day for Truck Rental
$500 fJr 300 Gal. Na Ott
$300 for Acid' ,
2 ~en for 3 Days @ $25/Hr
Electricity
$ ~,OOO
for 24 Hours
Maintenance
Capital Costs of Carbon Adsorption System
is $31,000
Assu~e Maintenance @ 51 (SSl,OOO x 51)
4,000
Operation and Supervision
Inclu~e~ with Operating Costs of Groundwater Treatment
0#'
Sub Total
$111,000
Continge:1cy
4,000
TOTAL OPERATING AND MAINTENANCE COSTS
$18,000
TABLE 50
",''''~'~r,;.~':'~~~'$;.~~~.:.rs.,;..:.'.r:, ,-.~:i~::,;- .', '
-------
OPERATING AND MAINTENANCE COSTS
THERMAL OXIDATION
S~PPlie5
.5 Gal. of Propane per hour @ $1.90 Gal.
Elect.rical
Assu~e majority of electric costs will
be with Blower System; therefore allow
for minor electric costs
Maintenance
Use E. Stocker 3/5/85 Flare Estimate
of $132,000 Capital
Assu~e 5' ~f Capital ($132,000 x 5')
c
Operation and Supervision
.Inclujej wit~ opera..ing costs of Groundwater Treatment
Sub Tot.al
Con~inge:"lcy
TOTAL OPERATING AND MAINTENANCE COSTS
$20,OJO
1,000
7,000
$28,000
I3,OJO
$36,000
-------
OPERATING AND MAINTENANCE COSTS
YENT GAS HANDLING
Supplies
Electricitl
Bl::;)wer 5HF
Lighting and Instr.
Requirements
3 . 7 KW
1.0
4.7 Kw/HR @ .12/KWH
$ 5,00:)
Maintenance
Capital Costs of Blower Syste~ is $50,000
Assume M3inte~an:e @ 51 ($60,000 x 51)
3,000
o eration and
nc udej with
of Groundwater Treatment
Sub Total
$ 8,00~
2,50:)
o
Continge~cy
.."
TOTAL OPERATING AND MAINTENANCE COSTS
$10,500
."
-------
OPERATING AND MAINTENANCE COSTS
ACTIYATED CARBON SYSTEM
IVP Carbon with Na Ott On site Regeneration
Supplies
Assume Repla:ement of Carbon Every
five Years 12,000# @ $2.70/# = $32,400
5
$ 6,000
=
"Regeneration
Soak Carbon in Dilute Na Ott
$600/Day for Truck Rental
$500 f~r 300 Gal. Na Ott
$300 for Acid' '
2 ~en for 3 Days @ $25/Hr
$ 4,000
for 24 Hours
Electricity
Maintenance
Capital Costs of Carbon Ajsorption System
is $31,000
Assu~e Maintenance @ 5' ($Sl,OOO x 5')
4,oao
Operation and Supervision
Inclujed wlth Operating Costs of Groundwater Treat~ent
Sub Tota 1
$111,000
~'
TOTAL OPERATING AND MAINTENANCE COSTS
4,008
$18,000
Con t i ng"e:1c y
TABLE 50
~~::"" ,
',"';" ~':';J'.:.~;.~~~'$i~~:-.~";',::,~,"" ",~~:i~ "::.~,", '
-------
OPERATING AND MAINTENANCE COSTS
THERMAL OIIDATION
S~PPlie~
.5 Ga . of Propane per hour @ $1.90 Gal.
Electrical
Assu~e majority of electric costs will
b~ with Blower System; therefore allow
for minor electric costs
$20,OJO
1,0'')0
Maintenance
Use E. Stocker 3/5/85 Flare Estimate
of $132,000 Capital
Assu~e 5' ~f Capital ($132,000 x 51)
7,000
Operation and Supervision
.Inclu:lej wit~ opera..ing costs of Groundwater Treatment
Sub Tot.al
$28,000
Con:.inge:1cy
S,OJO
TOTAL OPERATING AND MAINTENANCE COSTS
$36,000
-------
. '.".
Summary of Alternatives, Capital, 0 & M and Present Worth Costs
AL '!!R'\RTI~ CA~:i;t COSi STIli:-:- ~'(I 5 ST~q'5 E?R'S ' ~: YRS. P!5:\"T ."!J:\:-~
o,~ ~----~- ....-_. 0&"': 4'; 7,; 10"
"~:I:'. . ...:~..~
(iW' .0 $45, OO~ ~n,~ ,gO, 00(. 15 ':,O«(i,6~1 '819,720 .s~~, !"'~
. -.
30 '1,556,2&0 11,116,810 ~45, 43'~
!S~ $2,Z50,~ Sl,2a:,74C $3~, 000
GiI-~ '7~,OOO '~4~,OO~ ':3V,~~O S~3~,OCC 15 S!!34i,140 12,8&4,640 S2~S!;~3E:
30 ~,757, lbC S3,W"070 $2, 9'".JC. 21 C
P';; $E.,540,OOC ' S~, Ci~, 780 S!, C's:~ ~~.
~-! ':,25C,OOO '"~,C~0 S3,£lC,00~ $3:5,000 15 54,75-2, : 70 $4,llS,~O $3, G4~, 83'j
30 IS, 69S, Sd~i S5, :5:.535 $4,2: 9, 5C!5
!t,-:' ';,12~,OO'j $::,75':, (:S: ~,"~.:, 0::':
GW-4 $4, 5:JO, 000 $E.:~, OCf.) $:O,953,&3~ $705,000 15 $~"Ua,19~ $lC',S'::1,14C $S,a:.~,~3J
30 $16,&~.8E.0 113.240.345 $11, 1~, C!:
l''F "-2, 125, 000 114,571,630 $11, ~..:., oe.;
S-l $0 ~:;, 0-:':' $4 72,2" 'Sv,OOC 1~ ':,OOC,62C $6:'3,72<1 SOS4, 5~
30 S:,:5:, adJ $1, llS, e:o $84:,430
II-F I,,~,OOO S:,~5,740 sSOC:,ooo
5-2 '",6SC,OOV S3~. 00:. 1~3,sco,oov S~3S,OOO 15 S24,lSO,S30 123, 679, 5BO $23,676,010
30 S:4, '3~,4~ 5:",325,215 $23.9?2,S4:
IN; 5~£,C:5,OOO ~4,Sia,6l0 "4, coo, ~
S-3 I:~,3O("OOO IS:, ~~. s: 3~ 25':' to(;' s: 2~, oc":~ "'i 113, QO::~ S30 S:Z,52S,SBj S:Z,32r.,Bl0
0-
30 111,,&34,420 $~3.S~.2~:; S:3.~G45
!~: S:5, E~, OX: S:I,,~E,6:0 113, 65~, o~,.)
S-i, so, : S~, o!)(. SS:. -;:': I:, :3::~ ~I::~, ,:!~. ~:-:. 'CO $:.68:.,930 $:.40':.5;:. S'? :::.£.B10
...
30 '1~, ~:I" i,.?O S3,E:S,Z:5 ss, 45~. &4:.
!~-= s::~~~,ooo SlC,lCiS, E.:O 5S, 5~, Oil.; ,
5-5 S:1,43O,OOO '%, CMXJ S12,36~,000 $135,00: 15 SlC::, S30, '330 S12,6SS,580 Sl~,4SE.,610
30 ~:3,i&4,42C 513, :C:,::S 112.7:12,;45
l~ $:4,8~,OOO S13,35t.,610 112, 760,O~~
5-£ S4, OS';, 000 S30,O'):' ':,000,000 $:~,00) 15 s:,~C,S30 SS,~iS,S60 S:~07t.e:o
30 St.,334,420 1~,725,2l5 S5, ~. &4:
I~"F 17,"5,000 15~97a,610 15,400,OOC
5-7 $16, 9&0, 000 s90,~ 179, 930, ~~o s135,000 :5 '80,460,930 '80,20;,560 S6~', O~&, e10
30 S81,314,~ S80,SS;,21S .sC,~.64S
1~'F 562, ~, 000 S8~, 900, 6:0 SOJ,33~,OV,;
5-6 117,940,000 190,000 118,890,000 1135,000 15 119,440,930 $19,169,560 ':8,900,810
30 $~,27",420 519,615,21S S!9.2:2,~5
I~ 5~1,31S,OOO $19,868,610 515,290,000
5-9 S6, 960, OOC $90, 000 IS, S3O, ooe Sl3S, 000 15 110,480,930 $10,205,580 110,OOb,S10
30 511,314,420 510,655,215 SlC, 252,645
I~ 5:',~,OOO $10,90&,6:0 Slv,330,OOC
5-10 S2,3~,0()(I IS~,OOO IZ,~70,OOO 1135,0;0 15 S3,6~O,S3Ci 13,S4S.SC~ SZ,34£,elO
-------
Summary or AnemaUVti~, ~d~ii (,,<.::.10.1/ "",,,,' - i;;\.." 0;;....181 r. Go:tGIU. .. "'I U I vuo:t ~ '-UI I" U
&L ~~~71V:: a.;::7k.- C!J$i S7w:.mR'S S;~~'S ~!s . iF VRE p~~'" W':;;-
C&~ P!E:~\- ":1':;oj O&~ 4~ 7'(. 1~
.
. 30 ",654,420 13,9~,2:S 13, 53~ GL-:
. !~ IS, ES5, 000 ",246,E:O ':,~i~,OOC
;,
s-" SS,Z70,000 19o, 000 st., 2...,:{), 000 S:35. OOC l~ SO,770,930 16,499,500 $6,2S:.,e:o
..
.' 30 $1, b~"', 420 SO,94~,~:5 $E., s.:.~, &4S
..\. IN=- se,&4s.ooo 57,196,6:0 ~,~~,ooc
5-12 12,SE~,C~ 19\00;) 52,S3v,OCO S~3S,000 15 54,460, 53(: Sit, 2<1S, SSO ", O~.€.. £1~
30 15.3:1,,4=0 14,£::,2:5 S4,~2,6L:
I!\;:: st-~ 3~, 00':; ''',SOt:,b:O ~, 33~', OX'
5-<'1 ~,68{:,OOO Ie S2(15,&ev,OOC se 15 SZOS,6S0,OOC S20S, £6'j, 000 $2('5,66:.,00<1
.~
30 1203,&80,000 12;)9,680,000 $203, &5::, 00('
1"':- 120S,E.6C,OOO 12~':. 660. 00-:. $20S, bE:, oo.~
11-1 fe, 1-' Ie 116, ~O<: 15 I?C~,23b $~04,6:5 $:~7,£~~
..
30 1312,985 1224,603 S170,52S
INr SitSE, SOO S2S6,S77 116:,OOX
A-2 I:! &50, oce 10 1:,660,000 11E,~OO 15 12,061,236 1~,o:4.e~ 1~,9S7,EE:
30 S~,:7,,~S $~,084,E03 '2,C3~.52;
I~"F I':, 31~ 500 ~, ll6,'Si7 12, 04:, OO~
~3 $2, 36:, C~ 12c,5\!0 $2, t.t,c, C~}: $':'~,£c..) ..: I,-,Eic,OS9 S2,7&4!433 $::, 7:4~4"t
hI
30 S2.1E5.BCi $:,932,2:;'3 12., 7~,Z;:
!~::' $3, s.~! 000 '3,02~, i~6 S2.,~£,O~
A-4 $~! ~, (.): $61" :CC S3,C~,OO: ~.J,. s.~o ... 13.273,"3 S3! 143,377 53, C-4S! 34E
.,j
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,,'
APPENDIX A
RESPONSIVENESS SUMMARY
INDUSTRI-PLEX SITE
woburn, Massachusetts
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INDUSTRI-PLEX, WOBURN, MASSACHUSETTS
DRAFT RESPONSIVENESS SUMMARY
This community relations responsiveness summary for the Industri-
plex site in Woburn, Massachusetts, is divided into the following
sections:
II.
I I I.
IV.
I.
Overview - This section summarizes the cleanup alternative
recommended-by Stauffer Chemical Company for remedial
action at the Industri-plex site, and summarizes briefly
public support for that alternative. Comments from
potentially responsible parties are also summarized.
Back~round on Community Involvement and Concern - This
sectlon provides a brief history of community interest and
concern regarding the Site.
Summary of Major Comments Received during the Twelve Week
Public Comment Period and EPA Responses to the Comments -
This section categorizes both written and oral comments by
the community; local, state and federal officials; and
potentially responsible parties on the proposed cleanup
approach. EPA responses to these comments are also
provided.
Remaining Concerns - This section describes community
concerns raised during the twelve week pUblic comment
period that EPA and the State should be aware of as they
prepare to undertake remedial design and remedial action
at the Industri-plex site.
In addition to the above sections, Attachment A, included
as part of the responsiveness summary, identifies the
community relntions activities conducted by EPA during
remedial response activities at the Industri-plex site.
,,'
..
A-I
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1.
~E~1~
The Cleanup Alternative
The draft feasibility study (FS) for the 1ndustri-plex site,
which examines the feasibility of various cleanup alternatives,
was prepared for EPA by Stauffer Chemical Company. The FS
recommends a remedial alternative that involves several separate
actions designed to treat groundwater contamination, treat
odors resulting from hide piles, and treat contaminated soils.
stauffer's proposed treatment of groundwater would involve
pumping all the groundwater that leaves the Site at the Site
boundary, treating the groundwater with an air stripping process
to ensure compliance with EPA criteria for drinking water, and
discharging the treated groundwater to nearby Hall's Brook.
This option will remove 99.9 percent of the benzene from the
treated water before the water is discharged. The remaining
contamination in the groundwater will disperse naturally in the
underlying aquifer to a level three times lower than EPA drinking
water standards.
Stauffer's proposed method of treating odors from hide piles
would involve: a) lowering the water table around the East and
West piles to reduce odor associated with wet hides: b)
stabilizing and grading the sides and top of the East pile,
covering it with a twelve inch layer of gravel, a synthetic
cover to prevent rain water from getting into the pile and
prevent gases from escaping without first being treated, and
twenty-four inches of soil: and c) installing a gas ventilation
and collection system in the East Hide pile to capture and
treat gases created from the decay of wastes in the pile before
releasing them into the air.
Stauffer's proposed method of treating contaminated soils woulo
involve covering 43 acres of the most highly contaminated soil
with thirty inches of soil and vegetation. About 200,000 cubic
yards of soil are estimated to be necessary for this. The soil
would b~ delivered in trucks to the Site over the course of
about one year.
Public Support for the Cleanup Alternative
Contaminated Soils: The CAC reported .that it was not prepared
to state a preferred alternative for treatment of contaminated
soil and that two alternatives seem to have merit: 1) treating
the soils where they have been found, and 2) excavating and
consolidating the soils into one smaller area. with regard to
treatment of contaminated soils, the North Suburban Chamber of
Commerce and u.S. Representative Edward Markey prefer an action
involving excavation and consolidation of soils, and relocation
to other on-site locations.
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The CAC, community members, the Chamber of Commerce, and local
officials all expressed a great deal of concern regarding the
. l?ng-term monitoring, maintenance, and use of the Industri-plex
slte.
Odors Resulting from Hide Piles: The comments received during
the public comment period indicate that the Industri-plex
Citizens' Advisory Committee (CAC), the North Suburban Chamber
of Commerce, interested members of the community, and U.S.
Representative Edward Markey concur with the proposed treatment
of hide deposits.
Groundwater Contamination: Members of the Industri-plex CAC and
members of the community also support the proposed treatment of
groundwater contamination. The Water-Soil Subcommittee of the
CAC suggests that treated groundwater be recharged upgradient
into the aquifer rather than discharging it into Hall's Brook,
as preferred by Stauffer. U.S. Representative Edward Markey
prefers treating the water downgradient of the Site in an effort
to reduce the pollutants released into surface water.
Comments from Potentially Responsible Parties
The Monsanto Company, a potentially responsible party, stated
that the preferred alternative adequately addresses public
health and environmental issues. The company elaborated on the
preferred alternatives for treatment of hide piles and contaminated
soils. The company presented a new approacch to groundwater
treatment which would involve pumping downgradient, off-site
groundwater to a biological treatment system and reinjecting
the effluent upgradient of the well system.
Section III below provides a more detailed discussion of
individual preferences concerning the proposed cleanup approaches.
II.
BACKGROUND ON COMMUNITY INVOLVEMENT AND CONCERN
Community ~wareness of what is now known as the Industri-plex
site goes back to 1863 when the Massachusetts Department of
Public Health first conducted hydrogen sulfide testing in
response to public complaints of odors emanating from the Site
area. The Site was used for manufacturing chemicals and later
for manufacturing glue which involved cooking animal hides to
extract the glue. For nearly a century, the methane and hydrogen
sulfide gases causing the "Woburn odor" were considered to be a
public nuisance. Residents also claimed that the area was
unsightly and was responsible for various health ailments.
In 1979, Site preparation for an industrial park revealed the
presence of a variety of chemical wastes from industrial
activities. At this time, the Massachusetts Department of
Environmental Ouality Engineering (DEOE) and the EPA began to
investigate the Site actively. On April 23, 19AO in accordance
with the Massachusetts Environmental Policy Act, the Massachusetts
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Secretary of Environmental Affairs authorized the formation
of a Citizens' Advisory Committee (CAC) to provide input,to and
review technical documents related to the Site.
. As a result of this, a 14-member CAC was formed. Members
included representatives from the cities of Woburn, Wil~ington,
Winchester, and Reading, as well as representatives from local
ad hoc environmental groups. For the first three years of its
existence, the CAC met on a weekly basis for the purpose of
highlighting and attempting to resolve issues of community
concern related to the Site. Non-voting representatives of
EPA, DEOE, and the U.s. Army Corps of Engineers also attended
the CAC meetings. After the CAC had been in existence for a
few years, the North Suburban Chamber of Commerce and an area
branch of the League of Women Voters also joined the CAC as
voting members.
From 1983 to date, the CAC has met less frequently but has
continued to provide substantial input to the Superfund cleanup
process. The potentially responsible party conducting the
RI/FS at the Site has actively cooperated with the group and
has incorporated many CAC suggestions into the RI/FS.
The City of Woburn, surrounding communities, and the North
Suburban Chamber of Commerce are all interested in promoting
industrial development in an effort to stimulate the regional
economy. However, a federal consent decree has been issued
requiring cleanup of the Site before any development can take
place. The City of Woburn and the Chamber of Commerce are
concerned that the cleanup is taking too long and hindering the
process of development. Several residents and the Citizens'
Advisory Committee would prefer that the Site never be developed
because hazardous wastes have been identified on-site. The
Site development issue is one of serious community concern.
III.
SUMMARY OF MAJOR COMMENTS RECEIVED DURING THE TWELVE WEEK
PUBLIC COMMENT PERIOD AND EPA RESPONSES TO THE COMMENTS
Comments raised during the Industri-plex site public comment
period ar~,summarized briefly below. The comment period was
held from May 14, 1985 to August 1, 19B5 to receive comments
from the public on th draft feasibility study. Comments are
categorized by type of commentor, (e.g., the community, local
officals, and potential responsible parties) and topic.
Comments from the Community
Each of the major community groups at Industri-plex expressed
its preferences and concerns with the proposed remedial actions.
Their comments are summarized below.
A-4
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Treatment of Groundwater Contamination
Stauffer's proposed treatment of groundwater would involve
pumping all the groundwater that leaves the Site at the Site
boundary, treating the groundwater with an air stripping
process to ensure compliance with EPA criteria for drinking
water, and discharging the treated groundwater to nearby Hall's
Brook. Nearly all of the contaminants in the groundwater will
be removed by the air stripping process. The remaining contam-
ination in the g~oundwater will disperse naturally into the
aquifer underlying the Site.
1.
The Industri-plex CAC, with the exception ot the Water-Soil
Subcommittee, endorsed the proposed treatment of groundwater
contamination but requested that a monitoring and maintenance
program be implemented to ensure that the air stripping system
operates reliably and that malfunctions are detected quickly.
EPA Response:
A major component of any remedial action selected by EPA woulrl
be the development and implementation of a plan for monitoring
and maintaining the efficiency of the remedial action. This
plan is broken into two sections. The first section deals with
designing and implementing a monitoring network to effectively
evaluate the remedial action. This would include determining
the number and location ~f monitoring wells to detect the
effectiveness of the recovery wells. It would also include
determining sampling locations throughout the treatment system
to ensure that the system is operating as designed and to
provide an early warning mechanism when and if a portion of
the treatment system breaks down. The second portion of the
plan deals with identifying areas within the remedial action
that will require periodic or routine maintenance and to plan
a course of action to provide that maintenance. Included in
the costs are plant operator salaries. These plans are required
for all remedial actions prior to their implementation.
2.
The Water-~oil Subcommittee of the Industri-plex CAC differerl
from the majority of the CAC and requested a more detailed
explana~lon as to why remedial Option I (pump "hot spots," air
strip, recharge upgradient into aquifer) is unacceptable. The
Subcommittee believes that the preferred Option II (intercept
plume at Site boundary, air strip, discharge into Hall's Brook)
may be overly-protective and expensive..
EPA Response:
The Agency agrees in part with the Water-Soil Subcommittee and
selected Option I
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public health, welfare and environment and met applicable or
relevant and appropriate federal public health and environmental
requirements. As a final long term decision the Agency would
'have to weigh very carefully alternatives GW-3 and GW-4 in
order to make the same decision recommended by stauffer.
However, the Agency believes that, based on its knowledge of
other existing and potential groundwater problems within the
aquifer, it is not cost effective and it is inappropriate to make
a final decision about on-site remediation without ensuring
that it is cons i S,tent wi th the larger reg ional aqu i fer dec is ion:
hence the selection of GW-2. The pump and treatment of the
-hot spot" areas will remove approximately eighty percent of
the contaminants within six to nine months. The Agency believes
that as an interim remedy the implementation of GW-2 is cost
effective when compared to GW-3 which would remove an additional
ten percent of the contaminants at a substantially increaserl
cost and time frame (10 years).
3.
The North Suburban Chamber of Commerce proposed that contam-
inated groundwater detected in one off-site well (OW-17) be
pumped and piped to the proposed treatment plant.
EPA Response:
The North Suburban Chamber of Commerce's proposed pumping of
only one off-site well (OW-17) would be a modified version of
GW-4, the most expensive alternative considered. The Agency
believes that this alternative is neither cost effective nor
capable of providing a significant increase in protection.
The pumping of one well would not be capable ,of capturing all
of the contaminants migrating off-site. The aquifer becomes
significantly deeper and wider as it gets further downgradient
of the site boundary. As a result, the saturated thickness of
water necessary to intercept the plume effectively becomes
much larger and requires more wells or extraction capacity than
the interception of groundwater at the site boundary. Therefore,
the pumping of one off-site well would not be practical or
effective. Stated another way, this alternative is much more
costly for~only a marginal gain in protection.
4.
In addi~lon to the above reasons, the Agency has determined
that the groundwater problems associated with the Site should
be dealt with as an area-wide groundwater problem. As a
result, the Agency will implement an interim remedy pending a
final decision on the long term remedial action for the larger
area-wide problem.
The Mystic River Watershed Association and the Industri-plex
CAC suggested that the aquifer underlying the Site be rehabil-
itated for future use in private industrial processes and
that some government authority be given responsibility for
monitoring and sampling water quality.
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EPA Response:
The aquifer underlying and downgradient of the Site is currently
being used by several industries in the area. The water is
being used as non-contact cooling water for air conditioning
purposes. The volumes required for this purpose are not large:
given the current and potential uses of the buildings within
the area, it does not appear that there is a significant demand
for large quantities of industrial process water. Therefore,
the Agency questions the need to address this specfiic issue
as part of the R~cord of Decision (ROD).
The issue of the long term uses and degree of cleanup within
the aquifer will be resolved as part of the proposed Multiple
Source Groundwater Response Plan (MSGWRP) outlined in the ROD.
This MSGWRP is designed to address the potential impacts on
the aquifer, determine the long term needs for the aquifer and
how to obtain these goals in light of current Agency guidance
and policies. Specifically, the answer to the question will
be addressed as part of the MSGWRP.
5.
Dundee Park Properties, an owner of land adjacent to the Site,
is concerned that the Stauffer study has ignored data from a
July 1982 study which indicated elevated levels of benzene and
toluene in wells on Dundee Park property within the East and
West Hide Pile. Dundee Park Properties and its engineering
consultants anticipate that a number of areas within these
piles may exceed the criteria which Stauffer used to define
contaminated soil areas.
EPA Response:
The RI/FS evaluated the impacts to the groundwater resulting
from the Site. The RI determined that the source of benzene
and toluene originates much further south than the East Hide
Pile. The RI did not detect any impact resulting from ben-
zene or toluene in the hide pile. The RI determined that the
shallow pond adjacent to the Dundee Park wells was a discharge
zone for the local groundwater. As a result, the elevated
level detected in the Dundee Park wells would most likely
discharge to the pond. Water quality sampling within and
downgradient of the pond did not detect the presence of these
volatile organic compounds. '
The recommended remedial action for,the East and West hide
Piles will address all areas mentioned in Dundee Park's comments.
Specifically, the piles will be capped to minimize any additional
leaching of material from the piles.
6.
A community member suggested
until the Wells G and H Site
tested for radiation: if any
should be identified.
that no work be done at the Site
in Woburn, Massachusetts had been
radiation is found, its source
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EPA Response:
The Wells G and H site, located in East Woburn, is a separate
and discrete site currently listed on the National Priorities
, List (NPL) which is undergoing a separate remedial investigation/
feasibility study to determine the nature and extent of
contamination. While there exists a relationship between the
two sites as a result of the Industri-plex l2R site being
upgradient hydrologically from the Wells G and H site, 'the
Agency believes that the issues relating to Wells G and Hare
most appropriate~y addressed during that investigation and
not here.
In the Record of Decision the Agency has selected an interim
groundwater remedy for the Industri-p1ex site. This decision
to partially remediate the groundwater problems resulting
from the site was based on the knowledge of actual or potential
groundwater impacts abutting the site. Prior to selecting
a permanent long term remedy, the Agency decided that the
implementation of a Multiple Source Ground Water Response
plan (MSGWRP) to adequately address these other problems
was the most efficient method to decide on the long term clean-
up goals for that portion of the aquifer. This MSGWRP will
address the general area around the Site and is not expected
to specifically encompass wells G and H, except in light of
the potential impacts to Wells G and H from the decisions
made relative to the MSGWRP study area.
Proposed Remedial Actions
7. U.S. Representative Markey stated serious doubts as to whether
the recommended method of removing benzene and toluene from
groundwater will ensure that contaminated water is not
endangering public health. As an alternative to the recommended
method, Markey proposed treating the water downgradient of the
site and monitoring treated groundwater at its point of
introduction into surface water. Markey also requested that
Hall's Brook be tested regularly to ensure that contaminants
are not being discharged from the Site.
~
EPA Response
The Agency evaluated the various options for remediation of the
contaminated groundwater. As described in the Record of Decision
(ROD), the Agency choose to implement an interim remedial action
while resolving the more widespread contamination or threat of
contamination surrounding the Site. The Agency chose to
implement an interim solution based on a number of factors
which are detailed in the ROD. One of the primary reasons
behind selection of an interim remedy was the belief that the
public health, welfare and environment would not be impacted
adversely during the period of time the regulatory agencies
were designing a comprehensive cleanup plan for the groundwater.
It should be noted that currently no one is consuming water
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from the aquifer: in fact, the industrial uses are relatively
limited as well.
The monitoring of Hall's Brook will be considered as part of the
investigation during the Multiple Source Groundwater Response
Plan.
Treatment of Odors Resulting from Hide Piles
Stauffer's proposed ~ethod of treating odors from hide piles would
involve: a) lowering the watertable around the East and West
Piles to reduce odor associated with wet hides: b) stabilizing
and grading the sides and top of the East Pile, covering it
with a twelve inch layer of gravel and a synthetic cover to
prevent rain water from getting into the piles and to prevent
gases from escaping without first being treated, and then
covering this with twenty-four inches of soil: and c) installing
a gas ventilation and collection system in the East Hide Pile
to capture and treat gases created from the decay of wastes in
the pile before releasing them into the air.
8.
Industri-plex CAC concurs with the proposed treat~ent of hide
deposits, but believes that the test period for evaluating
alternative collection and treatment systems should be longer
than the seven weeks proposed by Stauffer to ensure reliability
and suitability in various weather conditions and throughout
four seasons. The CAC also wants to ensure that the system
design will prevent adverse environmental impact should the
system malfunction and suggested that back-up systems be used
to minimize that possibility. "
EPA Response:
EPA agrees with the CAC regarding the length of the monitoring
period for determining what type of treatment, carbon adsorption
or incineration, is appropriate for the East Hide Pile. EPA
intends to monitor the volume and composition of the gases
collected for a period of one year following the installation
of the gag" collection system and the cap on the hide pile.
While t~is will delay the final solution of the "Woburn odor"
problem", it will help ensure that the solution achieves its goals.
EPA also concurs with the CAC's concerns regarding the impact
of malfunctions on the public and the environment. An essential
element of a successful remedial action is ensuring that the
action is well designed and constructed so that malfunctions
are minimized. Equally essential is providing back-up on
critical components of the system. For the incineration
option, for instance, there will be two flame ignition systems
and interlocking control devices to ensure that no gases fro~ the
hide pile enter the incinerator if there is no flame. These
safety and back-up equipment specifications will be addressed
during remedial design.
A-9
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9 .
The Industri-plex CAC urged that EPA evaluate the benefits and
problems of the proposal for using soil from the South Hide
Pile to stabilize the East Hide Pile. The group is concerned
that this action may release undesirable odors.
EPA Response:
The South Hide Pile is a comparatively small pile of wastes
that contains some hide material. The RI indicates that only
small deposits of glue manufacturing wastes are present in this
pile. The test pits, borings logs and the personal experience
of the field personnel conducting and supervising these
activities indicate that the odor potential is low. The pile
is bordered on two sides by developed properties and a portion
of the drainage channel that will be needed to redirect the
water from the pond between the East and West Hide Piles to
the Hall's Brook storage area. The third side of the pile
abuts an active railroad siding. Given these tight quarters,
it would be extremely difficult to cap this pile in place
without relocating the siding, the drainage channel and a
portion of at least one building.
EPA believes that relocating this pile is the most practicable
means of isolating it from the environment and public. EPA
recognizes, however, that the potential exists for generating
odors dUFing the relocation. EPA does not believe that
significant odor$ will be generated, but if they are, ~PA will
halt the relocation, reassess the size of the problem and develop
a plan for dealing with the problem. The plan will be reviewed
with the affected community. If the reassessment of the problem
indicates, as currently believed, that the amount of hide
material is small, work practices could be instituted that
could minimize the intensity and duration of the odors. In
this case, consulting with the community would be aimed at
gauging to what extent it is willing to endure short-term odors
in return for a long-term solution to the problem.
If the amount of hide material is large the Agency wouln have
to reassess its dec~sion and would likely cap the pile in place
using sheet piling or other methods to protect the developen
properties abutting the pile until such time as adequate equipment
can be mobilized to complete the job as fast as possihle while
ensuring that odorous materials are limed and covered in transit.
Additionally, relocating odorous materials will be acco~plished
between 9 a.m. and 4 p.m. only and all materials will be covered
daily.
10.
A community member proposed that the hide piles be covered-with
soil, rather than capped with a synthetic cover, and allowed to
aerate and decompose naturally.
EPA Response:
As evidenced in the Arthur D. Little odor specialist's report,
capping of the west and central hide piles has eliminated onor
A-ln
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emissions from these potential sources. Therefore, the community
member's proposal has merit. Capping the East Hide Pile in
itself might work. EPA is not convinced, however, that it
will. EPA prefers to have the added assurance of trapping,
collecting and treating the gases. If EPA approved this
citizen's proposal and it proved ineffective, retrofitting the
pile with the systems described in the ROD would be very
expensive.
If, on the other hand, the systems are installed as descrihed
in the ROD and the volume of gas generated by this pile drops
to the point where treatment proves unnecessary, then the
collection system can be sealed and the treatment system shut
off.
11.
The Industi-plex CAC urged EPA to seriously question Stauffer's
use of "limiting effect dose" levels (LEDs) as a measure of the
release of odor because much lower levels than the specified
LEDs would still be objectionahle to the CAC. In addition, the
CAC requested that further consideration and substantiation of
appropriate concentration levels of contaminants be undertaken.
They suggested that more than one set of limiting effect dose
levels may be necessary since there are several distinctly
different populations at risk in the area. For example, workers
in a nearby building may be exposed to contaminants during a
normal work day whereas residents some distance away from the
Site may be exposed over a longer period of time.
EPA Response:
The FS did not use "limiting eff~ct doses" (LEDS) to calculate
the level of hydrogen sulfide and other reduced sulfur compounds
at which the community would experience "objectionable odors".
The LEDs were used to calculate the level below which there
would be no health problems experienced by the community.
All decisions as to the level at which objectionable odors
would be detectable are based on the data provided by the
trained Odor Panel from Arthur D. Little, Inc. (ADL), respected
authorities on odors and their perception. The ADL Odor Panel
conducted ~urveys in field measurements and laboratory
evaluations in support of their findings.
Based on ADL's findings Stauffer calculated the worst case odor
levels based on either taking no action or implementing the
carbon adsorption remedial action. With carbon adsorption, no
detectable odors are anticipated based on Stauffer's air modelling.
In response to the comment suggesting that multiple LEDs may be
needed for each contaminant in order to evaluate the impacts on
the health of nearby workers as compared to residents some
distance from the Site, the FS points out that for a given
contaminant there is a lowest dose at which a toxic effect was
noted. By definition, there can be only one LED for a given
chemical. What Stauffer did to address the CAC's comment was
A-II
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12.
, ~
to postulate several exposure scenarios, both on-sit~ and off-
site, to address the various routes by which the public could
be exposed to these chemicals. The Agency for Toxic Substances
'and Disease Registry (ATSDR) has reviewed these scenarios and
considers them Mworst caseM exposures.
A com~unity member requested that, at the Industri-plex site and
in future work, EPA, rather than claim that hydrogen sulfide
odor is not a health hazard, instead state that it is currently
not known if hydrogen sulfide odor is a health hazard.
EPA Response:
The EPA does not now consider hydrogen sulfide' odor a hazardous
waste or hazardous substance. All of EPA's decisions on the
hazards posed by chemicals are based on the latest reliable
data. As in all cases, it is possible that new data will cause
the Agency to re-evaluate the levels at which a chemical poses
a problem. Thus, new information may arise that will force a
re-evaluation of the Agency's opinion of the hazards posed by
hydrogen sulfide. On the other hand, hydrogen sulfide is a
common chemical, has been a factor in the workplace of numerous
occupations and industries (notably petroleum refining and
waste water collection and treatment) for a long time, and
hence has a large data base on which EPA can base its
assessment of the hazard posed.
13.
Dundee Park Properties, an owner of land adjacent to the Site,
agreed with the proposed remedial action for the East Hide Pile
but requested that Stauffer take responsibility for covering all
the hide piles on-site, not just the East Pile. The company
requested that the East and West piles be graded back from
their property and that the displaced material be placed on
the central or South Hide piles and covered. The company also
recommended that the soil area along the west side of the
south pond be covered by thirty inches of soil and vegetation.
EPA Response:
..'
The remedial action for the West Hide Pile, as' well as the
remainin~ deposits containing animal hide material, is to cover
these areas with the 30-inch soil cover described in the S-ll
alternative. The East Hide pile will receive a separate remedial
action. The purpose of covering the remaining hide deposits
is the same as that for conta~inated soils, which is to eliminate
the potential for direct contact. In addition, the additional
fill material will further reduce the odor potential.
In response to the second part of Dundee Park's question, the
Agency believes that grading or removing significant portions
of the East or West Hide Piles cannot be performed without
creating a substantial odor problem. The Agency does not
believe it is necessary or prudent to remove these deposits in
order to implement an effective remedial action.
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The Agency recognizes that there are exposed waste d~posits
along the west, south and east margins of the pond. These
deposits will be addressed by the remedial action for contaminated
soils and sludges. They will either be removed from the wetland
or stream and capped or, in instances where excavation is not
practicable, the streams will be isolated from the wastes by
installing culverts.
14.
,The Industri-plex CAC requested that it be stated clearly that
the gas collection/treatment program is intended to respond to
any odors which may later develop in the West Hide Pile (which
is not slated for treatment). The CAC states that such odor
sources must be eliminated should they develop.
EPA Response:
The Agency is sympathetic to the concern articulated by the CAC
that odors emanating from the Site be eliminated, regardless
of the source. The data collected during the RI, including
the results of the Arthur D. Little Odor Panel, indicate that
the East Hide Pile is currently the only source of odors.
Based on this determination, the Record of Decision (ROD)
concluded that only the East Hide Pile required collection and
treatment for the elimination of odors.
The Agency believes that controlling odor emissions from the
East Hide Pile will protect the public health, welfare and
environment and will restore the public's ability to enjoy the
use of their property and to conduct their normal business. In
addition, the Agency believes that by placing additional soil
cover and institutional controls on the remaining hide deposits
the potential for the release of odors is minimal. However,
in the event that a remedial action is not effective or Site
conditions change so that there is a release or threat of
release, the Agency will revisit the problem and take
appropriate actions to minimize or eliminate the threat.
15. u.s. Representative Markey agreed with
treating odors from the hide piles but
discharged' gas be monitored closely to
treated..proper1y.
Stauffer's proposal for
recommended that the
ensure that it has been
EPA Response:
The Agency will, as part of the Remedial Design process, develop
and approve a comprehensive sampling and analysis plan for the
air remedial action. This plan will not only document the
efficiency of the treatment system but that the public health,
welfare and environment are protected as well.
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/
16.
The Reading Board of Health had many concerns regarding the
proposed remedial alternative for the hide piles. specifically,
the Board requested .that: a) more consistent data be provided
as to the toxicity of hydrogen sulfide and other potentially
toxic substances: b) air monitoring stations be installed
on-site and downwind (in Reading) during cleanup to provide
data on hydrogen sulfide, toluene, benzene, other gases and
particulate matter: and c) a contingency plan be developed,
with Reading officials, to address treatment system malfunctions
and measures for temporary relocation of residents with health
problems.
EPA Response:
a)
The amount of health effects or toxicity data for a
specific chemical varies widely and is very compound
specific. For hydrogen sulfide (H2S) the available data
indicates that H2S is primarily a respiratory irritant.
H2S is a naturally occurring gas, the result of decomp-
osition and typically found in dumps, swamps, sewer gases
and natural gas. In high concentrations of 500-1000
parts per million (ppm), H2S acts as a systemic poison,
potentially causing unconsciousness and death. H2S is
heavier than air and will displace air in low lying or
confined areas. At lower concentrations (less than 100
ppm) it tends to be a respiratory irritant and affects
the eyes. For additional information on this compound
and others found at the site, the reader is referred to
Appendix G of the FS.
The use of ambient air quality stations during the imple-
mentation of the remedial action will be considered as part
of the remedial design process. However it is important
to point out that the detection of the compounds of concern
using ambient monitoring techniques is very difficult, if-
not impossible at the expected concentrations. Instead
the Agency intends to use industrial hygiene monitoring
and c~osein monitoring to protect worker safety and to
quicKly detect and prevent any release from emanating
oft-site.
b)
To illustrate the above noted point, H2S can be detected
by the average individual at concentrations far lower
than typically used analytical field instruments. As a
result, a field inspector using this instrumentation will
report none detected'even through he or she may clearly
smell the H2S odor.
Therefore, it is important and practical to use construction
techniques which minimize the generation of odors in the
first place and then try to contain these odors on-site as
much as possible.
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c)
17.
As noted in a previous answer, the Agency intends to work
closely with all interested parties to ensure that the
implementation of the remedial action will not adversely
impact the surrounding communities. The Agency will wor~
with the CAC, local public health agencies, affected
businesses and the general public to ensure that their
concerns are addressed and incorporated to the extent
practicable as the remedial design progresses.
The Reading Board of Health requested that: a) ample notification
be given to the. Board and other town officials regarding the
construction and cleanup timetables, with specific dates when
odors would predictably be strong and emission levels high:
and b) data on the human health effects of hydrogen sulfide and
other substances be made available to Reading residents.
EPA Response:
As noted in previous answers, the Agency believes that ample
opportunities for input exist during the Remedial Design
process. The Agency further believes that the specific answers
to the Reading Board of Health will come as a result of the
interactions during the design process.
Treatment of Contaminated Soils
Stauffer's proposed m~thod of treating contaminated soils would
involve covering 43 acres of the most highly contaminated soil
with thirty inches of soil and vegetation. About 200,000 cubic
yards of soil would be required for this, and the soil would be
delivered to the Site in trucks over the course of about one
year.
18.
The Industri-plex CAC reported that it was not ready to state
its preferred alternative for treatment of contaminated soils.
The CAC agreed with the proposal to cover the contaminated soil.
but wants additional information about the excavation and
consolidation alternative and the relative risks of the two
options. The CAC had specific questions about the excavation
alternati~e, namely: a) What methods will be used to remove,
transport, backfill and consolidate contaminated areas? b)
How wi11 dust be minimized? c) How can it be ensured that all
contaminated soil has been excavated?
EPA Response:
The Agency considered the consolidation options very thoroughly
because they minimized the land area over which institutional
controls would be required, reduced the amount of operation,
maintenance and monitoring required, and restored presently
contaminated land to full utilization. The Agency rejected the
consolidation options proposed in the Feasibility Study because
they would remove contaminants from undeveloped land only,
leaving contaminants on already developed land. The Agency
finds this distinction arbitrary.
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Further, as proposed in the Feasibility Study, the result of
the consolidation would be a capped landfill surrounded by a
clean zone which would be, in turn, surrounded by a second,
discontinuous contaminated zone. This situation does not adrl
materially to the protection of the public health, welfare or
the environment, but does add substantially to the costs of
the remedial action.
The Agency cannot spend money from the Fund to aid the economic
development of the industrial park. The only justifiable reason
for consolidatin9 these wastes is to minimize the accidental or
intentional disturbance of the completed remedial actions by
minimizing the land area that must be controlled in perpetuity.
Toward this end, a well-defined landfill is preferable to an
amorphous collection of deposits. Therefore, if the Agency
were to endorse a consolidation option, it would be one in
which all outlying deposits were brought to a central location.
This means removing contaminants from developed properties as
well - including contaminants currently covered by building~.
The Agency does not believe that the added protection provided
by such a measure warrants the very large increase in cost.
Since the Agency has not selected a consolidation option, there
seems to be no need to discuss in detail the mechanisms by
which such a plan would be implemented.
19.
The North Suhurban Chamber of Commerce disagrees with the
proposed remedial action and, instead, prefers the excavation
and on-site relocation of contaminated soils. The Chamber
recommends capping the soils and then backfilling the excavated
areas. The Chamber claimed that the FS did not address the
long-term feasibility or reliability of the soil cover and its
maintenance at a large industrially active Site.
EPA Response:
The Agency believes that it has adequately addressed the
Chamber's concerns in the previous answer.
20.
The Indust~i-plex CAC requested that work should stop immedi-
ately if unanticipated pockets of waste are discovered during
implementation of the remedial action. This work should not
begin again until an appropriate solution is implemented.
EPA Response:
The Agency believes that the nature and extent of the waste
problems at this site are reasonably well defined and under-
stood. As part of the remedial design process certain areas
will receive additional work to better delineate the actual
extent of the waste. This is a normal part of the design
process, so that at the end of the remedial design the Agency
will know and understand exactly what to expect once construction
begins. However, during the actual course of events, situations
frequently present themselves to the construction engineer
A-16
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that he or she did not anticipate. If the situation. is such
that it does not present a particular problem, (i.e., more of
the same waste than originally calculated), the engineer makes
adjustments and the work proceeds. If, however, the situation
is such that work should be stopped until such time that a
satisfactory solution to the problem can be worked out, then
the engineer will implement the contingency plan ou~lined in
the remedial design to address the problem. The Agency believes
that the type and nature of problems which require the use of
the contingency plan will receive adequate discussion during
the remedial design process. A number of copies of the design
and contingency plan will be made available to the appropriate
community officials and the public.
21.
The Chamber of Commerce and a citizen requested that further
soil and surface water sampling be carried out i'n those areas
(both on- and off-site) most likely to be contaminated with
highly-toxic hexavalent chromium.
EPA Response:
Additional sampling during the remedial design process will he
necessary in order to adequately design the remedial actions.
This sampling may include additional surface and groundwater,
soil and air sampling. In addition, once the remedial action
is completed, an ongoing monitoring program will he implemented to
ensure the continued effectiveness of the remedial actions.
Further, the RI did not detect any hexavalent chromium.
22.
The Mystic River Watershed Association reported that some of
its members felt that providing thirty inches of soil cover for
the contaminated areas was too much soil.
EPA Response:
The Agency evaluated a number of soil covering alternatives,
including the use of a thirty inch cover. The Agency selected -
the thirty inch cover for several reasons, detailed in the
Record of Decision. The primary reasons for thirty inches was
to elimin~te the effects of the freeze-thaw cycle and to minimize
the potential for exposing wastes to erosion.. The Agency did
note that there may exist alternatives to the use of thirty
inches which are effectively equivalent to the recommended
alternative. The Agency may, as a result of the design process,
select some modified version of the selected alternative so
long as the Agency believes that the modified version is equiv-
alent or better than the existing alternative as proposed.
23.
A physican from the community
contaminated soils, chemicals
to form a gel blockage around
be monitored.
proposed that, rather than covering
should be injected into borings
the waste and that the area should
EPA Response:
The FS evaluated the feasibility of this alternative as part of
the initial screening process. The alternative was eliMinated
A-I'
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based on costs and technical impracticability for a site of
this magnitude. It should be noted that these types' of in-situ
treatment technologies are innovative processes that have-n~
been field tested extensively. As a result, the usefulness of
. some of these techniques has been limited to very specific
chemicals and Site conditions as well as small and carefully
controlled situations. As more experience is gained with
these technologies over a wider operating range, their use at
sites such as Industri-plex may become routine and cost-effective.
Furthermore, these grout curtain technologies are used in
conjunction with, not in place of, covers. A grout curtain will
not protect the public against the potential for coming into
contact with wastes at the surface of the ground. A cover is
required to accomplish this.
24. Dundee Park properties, an owner of land adjacent to the Site,
proposed that waterlines be replaced and contaminated soils
removed.
EPA Response:
The FS evaluated the feasibility of excavating contaminated
material from around the water, sewer, gas and electric lines,
and concluded that it was not necessary as part of these
remedial actions. In the course of any emergency or routine
maintenance on these utilities, special care must be taken
.' and excavated material must be replaced with clean fill. The
Agency, in evaluating the various pros and cons of each option
(containment versus complete removal), had to consider the
reasons for immediate excavation as opposed to excavation and
removal as needed. The Agency ultimately concluded that the
costs and benefits associated with immediate removal were not
sufficient to warrant such an action. Instead, the Agency
proposes to leave the existing utilities intact and implement
a strict set of requirements in the event that the utilities -
are disturbed. Under present conditions, the deposits surrounding
the utilities do not pose a threat to the public health,
welfare or environment. This determination would not hold
true in t~ event that excavation occurred around the utilities.
The direct potential contact would increase significantly as
well as~the potential for release to the environment as a
result of the excavation. However, these issues can be adequately
addressed prior to beginning the excavation. The Agency
believes that, as part of the remedial design, procedures and
associated contingencies can be adequately developed and
implemented to address the issue of utility excavation.
25. The North Suburban Chamber of Commerce believes that Stauffer's
proposal to cover and leave contaminated soils in place on-
site may result in reduced property values for many parcels
. of land on the Site thereby creating financial hardship for
some firms. Therefore, the Chamber prefers that conta~inated
soils be excavated and relocated to another portion of the
Site.
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EPA Response:
The North Suburban's Chamber of Commerce concern was evaluated
as part of the selection of the remedial alternative. The
agency ultimately rejected the consolidation option for several
reasons summarized below and detailed throughout the Record of
Decision (ROD).
The RI/FS determined that the contaminated sludges and soils
only posed a potential for direct contact threat if allowed
to remain exposed. If the material was covered to a sufficient
depth to eliminate the potential for future exposure resulting
from the effects of the freeze-thaw cycle or erosion, then the
objectives of the remedial actions would be achieved. The ROD
indicated that the existence of structures such as buildings or
parking lots were equivalent to thirty inches of clean cover
material. As a result, the need to consolidate in order to
implement an alternative that was protective of the public
health and welfare and the environment was not necessary.
As a practical matter even under the consolidation options
illustrated in the Feasibility Study (FS) the financial
hardship would still exist for the property owners. This is
because the Agency has data which indicates that waste
material may still be buried under existing buildings,
parking lots and roadways. In those instances, removal of
the waste material is not practical unless the structure is
physically removed to obtain access to the waste. As a
result, the waste material is likely to remain buried under
the structure. Because the waste material will remain
under the structure, this fact will be documented and
controlled through the use of institutional controls to
prevent its disturbance during any future building
modification or like circumstances: hence, the current property
has a liability under current federal and state statutes.
26. U.S. Representative Markey believes that Stauffer's proposal
to cover forty acres of waste deposits ignores over thirty
additiona~ acres of potentially toxic deposits on-site. Markey
proposed excavating the waste deposits and then consolidating
and disposing them in an on-site secured landfill.
EPA Response:
The Stauffer proposal as outlined in the FS indicates that,
based on their calculation, only forty acres of the seventy
acres required the application of a soil cover in order to
protect the public health, welfare and environment against the
potential for direct contact.
The recommended remedial action sele.cted in the Record of
Decision (ROD) is consistent with the initial Stauffer
recommended alternative. It is important to note that the
proposal addresses remedial actions which address the entire
Site but that only approximately forty acres would require
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some additional cover material in order to place the waste
deposits below the effects of the freeze-thaw cycle and mini~ize
. the effects of erosion. Irrespective of the depth below grade,
the ROD requires, as part of the remedial action, that all.
waste deposits containing any contaminant above the action
level have restrictive institutional controls placed on the
area. The purpose of these controls is to contain the wastes
in place, eliminate the potential for accidental disturbance
and control how the wastes will be handled in the future. The
Agency believes that this method is equally protective of the
public health, welfare and environment as any consolidation
alternative and far less disruptive.
27.
During the remedial investigation, no suitable analytical
method could be identified or developed for accurately
measuring the amount of hexavalent chromium in samples
containing high levels of trivalent chromium. The North
Suburban Chamber of Commerce (NSCC) is concerned that this
may have caused hot spots of hexavalent chromium in soils to
have gone undetected.
EPA Response
When EPA became aware that the analytical methods used to detect
the presence and concentrations of hexavalent chromium in soils
were inadequate and producing misleading results, the Agency
evaluated alternative methods. Several different methods were
employed to overcome the deficiency; however, none produced
satisfactory results. As a result, the Agency used an indirect
method to determine if hexavalent chromium could be of significant
concern at the Site. First, it is important to note that, under
conditions typically found in the environment, hexavalent
chromium quickly reduces to the less toxic trivalent form of
chromium. The other important factor to note is that hexavalent
chromium is relatively soluble in water. Hence, if a deposit -
containing hexavalent chromium were leaking to the groundwater,
the presence of the hexavalent chromium would quickly be detected
since the~unalytical problems experienced with analyzing soils
are not ,present for aqueous analysis.
Therefore, if groundwater monitoring wells are located near
areas of suspected chromium deposits, they would detect any
hexavalent chromium leaking from the soils. Wells OW-l2, OW-
13, OW-l8 and OW-18a were so located and did not detect any
hexavalent chromium.
28.
The North Suburban Chamber of Commerce is concerned with the
reliability of a 30-inch cap as a barrier between the public,
specifically construction and maintenance workers, and the
waste deposits in the developed areas of the Site. The NSCC
feels institutional controls will be an inadequate guarantee
that the cover will not be penetrated by these workers. The
NSCC recommends instead the removal of wastes from these areas
and their consolidation on undeveloped portions of the Site.
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EPA Response
The Agency has discussed the consolidation issue elsewhere in
this document and in the ROD. Here the Agency will address the
adequacy of the cap and institutional controls in preventing
workers from coming into contact with the wastes.
The NSCC's concern is valid. If the institutional controls,
which could include zoning by-laws and easements in addition
to deed restrictions, cannot be put in place in such a way that
the Agency, DEOE, the City of Woburn and the public can rely on
them, then the proposed remedial action may not be feasible.
The Agency intends to work with all parties involved to establish
adequate legal protection of the cap to prevent the kind of
exposures about which the NSCC is concerned. As discussed in
the ROD, the Agency will use the type of restrictions mandated
by the Resource Conservation and Recovery Act (RCRA) as the
model for at Industri-plex.
If such controls are unobtainable or otherwise prove unsatisfactory,
the proposed remedial action will have to be reconsidered and
alternatives, such as complete consolidation or removal, re-
evaluated. Any changes in the planned remedial actions for
the Site will be discussed with all parties and the changes
will be described in a supplemental ROD issued by the Regional
Administrator.
29.
The North Suburban Chamber of Commerce (NSCC) is concerned that
the action levels (allowable levels) proposed in the FS and
accepted by the Agency will not protect the public health.
EPA Response
The Agency disagrees with the NSCC on this issue. The Endange~ent
Assessment in the FS calculated the limiting effect doses
(LED's) based on the EPA drinking water standards for organic
lead and chromium. These drinking water standards have been
reviewed ~nd endorsed by the National Academy of Sciences.
Using t~ese LED's, the FS postulated exposure scenarios by
which the public might come in contact with the wastes. The
conclusions of this process were reviewed by the Agency and by
the Department of Health and Human Services Agency for Toxic
Substances and Disease Registry (ATSDR). Both found the levels
protective of the public health. ATSDR, in fact, concluded
that, for an industrial park, the levels could be ten times
higher and remain protective of the public health. The Agency
decided to accept the more protective levels proposed in the FS
based on the uncertainty of the future use of the Site.
Public Health and safety Issues
30. A community member suggested that area residents be checked
periodically for possible health impacts on a regular and
continuing basis.
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EPA Response:
The questions of potential health impacts and, as an outgrowth
of this concern, a request for a community health monitoring
. program, are very common and legitimate issues raised during the
course of any Superfund investigation. The need for such a
study is evaluated on a Site by Site basis. In this regard
the EPA requests from the appropriate state public health
agency and the Department of Health and Human Services' Agency
for Toxic Substances and Disease Registry (ATSDR) assistance
in the determina~ion of need. EPA provides its knowledge
of site conditions and environ~ental expertise while the health
agencies provide the expertise about the potential for health
impacts resulting from the site.
Early in the Site investigation, EPA worked closely with the
Massachusetts Department of Public Health (DPH) and the Federal
Center for Disease Control (CDC) to evaluate the need for
public health assessment as a result of possible exposure
from the Industri-p1ex 128 site. The conclusion was that the
nature of the waste and Site characteristics made it unlikely
that the surrounding community was at risk from the Site.
Subsequent on- and off-site data and the Endangerment Assessment
conducted during the Feasibility Study support the DPH and CDC .
conclusions. As a result, the Agency does not believe that
such a monitoring program is either necessary or warranted.
31.
A representative of the group For a Cleaner Environment (FACE)
questioned: a) the ability of access roads to handle the
proposed high traffic volume if trucks were to operate during
the day; b) the safety of the heavy trucks carrying soil cover
over unstable ground during late evening hours; and c) whether
measures would be taken to protect against equipment vandalism
in isolated parts of the Site. .
EPA Response:
The questions FACE raised are all questions which are most
appropriately resolved during the Remedial Design (RD) process.
It is well. known that the existing road system is at peak
capacity curing certain portions of the day. This fact has
a significant impact on the ability to implement most of the
remedial actions considered in the Feasibility Study (FS).
The selected remedial action seeks to minimize any additional
impacts on the overworked road system by minimizing the amount
of off-site fill material necessary to adequately cover the
areas requiring remedial action. When compared to the majority
of other alternatives, the recommended remedial action requires
relatively small quantities of off-site material. While it
is premature to provide a definitive answer to the first part of
this question until the RD process has accurately identified
specific areas and amounts of fill required for those areas,
several options which are being considered are: trucking during
off peak hours only, bringing fill in only on weekends, bringing
fill on-site using rail cars, or constructing special access
roads to bring materials on site.
A-22
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Again, as part of the RD process, steps involving standard
and prudent engineering practices will be incorporated into
the design to ensure that the remedial action is implemented
efficiently and safely. There are a number of techniques
available to provide a stable platform for heavy equipment
to work from. For example, techniques such as the placement of
soil stabilization fabrics followed by fill material can create
a stable base. Another technique would involve the placement
of cover material on a stable base, trucking material over the
cover and stable base to the interface, depositing the fill and,
working from the already placed cover, slowly extending the
cover using the already placed cover as a base.
In response to the last part of the question, most of the
monitoring equipment will not be permanently located in the
field but instead brought into the field by the personnel
performing the sampling. For those monitoring points (i.e.,
monitoring wells) which permanently remain on-site, techniques
involving construction of protective housings are usually
enough to protect the equipment.
The Agency would like to conclude its response to this question
by noting that questions similar to the one above will be
discussed in more detail with the public as the RD proceeds.
The Agency is committed to implementing the necessary remedial
actions while minimizing adverse impacts to the surrounding
community. It believes that this goal is best reached by
substantial interaction with the affected community through a
community relations plan.
32.
A community resident requested that, given the presence of
toxic chemicals in the area, EPA consider how to protect the
public from acts of terrorism and sabotage.
EPA Response:
EPA, whenever it becomes involved at a hazardous waste Site,
places th~ protection of the public health, welfare and
enviro~ent from any sudden releases from th~ Site as its
highest~priority. The potential for a sudden release from the
site which poses an imminent and substantial threat to the
public health, welfare and environment usually results from
the deteriorating conditions of barrels, lagoons or tanks as
the result of vandalism, not acts of terrorism or sabotage.
Site conditions at the Industri-plex 128 site do not indicate
that the potential for a sudden release is very high and, as a
result, the Agency feels that special steps to address these
issues are not necessary. As Site conditions change during the
remedial action the Agency will take the necessary steps to
ensure that a sudden release does not occur, irrespective of
the cause.
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~
Site Closure and post-Closure Activities
33.
The Industri-plex CAC, the North Suburban Chamber of Commerce,
and a few residents raised several questions regarding planning
, and preparation for Site closure and post-closure activities:
a) How and by whom will it be determined that remedial action
is completed? b) will a certificate of compliance, or similar
document, be issued to affected property owners? c) What agency
will oversee Site closure? d) What are the procedures and
legal bases for monitoring and enforcing compliance with any
restrictions tha~ may be in place? e) What will be the procedure
for alerting the public to potential danger from disturbing
covered areas? (The CAC suggested that the Federal government
acquire sealed Site areas and turn the title over to the City
of Woburn.)
a)
EPA Response:
It is the responsibility of the United States Environmental
Protection Agency (EPA) to ensure that the remedial actions
undertaken at a CERCLA site are properly designed,
effectively implemented and remain protective of the
public health, welfare and environment. Once a Record
of Decision (ROD) has been signed by the Regional
Administrator, the Army Corps of Engineers (ACE) typically
oversees the remedial design and construction process,
ensuring that it is completed to specifications. As part
of the CERCLA requirements, the Commonwealth of Massachusetts,
agrees to ensure that the remedial action is properly
operated and maintained.
b)
The use of institutional controls are an integral part of
the remedial action to ensure that the remedial action is
not inadvertently disturbed and remains effective. While
the general form of these institutional controls will follow
those required under the Resource Conservation and Recovery
Act (RCRA) it is premature to specifically state what -
exact form of post-closure restrictions will be required for
property owners at the Site. However, one method would be
throu~h a court enforced Consent Decree.
c)
As~noted in the answer to Part a, CERCLA requires that
the Commonwealth of Massachusetts be responsible for
assuring that proper operation and maintenance (O&M) is
undertaken at the Site. CERCLA does not specifically
require that the Commonwealth pay for or physically undertake
the O&M responsibilities themselves, only 'that they are
properly and effectively implemented. As a result, the
Commonwealth may utilize whatever mechanism it deems
appropriate to provide that degree of assurance to the
EPA. Typically, a state may, through a Consent Decree
with a responsible party, require the party to pay for
and implement the O&M, or may develop an agreement with a
local community or existing property owner. Presently,
at this Site the agencies are negotiating with a number
of parties on this as well as a number of other issues.
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e)
34.
G'
d)
There are a" number of alternatives available to the federal
and state agencies to ensure that the remedial action
continues to be effective. One such alternative is a
court enforced Consent Decree between the agencies and
property owner or responsible parties. It is premature to
indicate what the final form of effective controls will be.
Currently there is no adequate answer to this question,
however, the Agency believes that the contaminated soils
(not Hide Deposits) can be disturbed in a carefully
controlled manner so as not to pose any potential
adverse impact to the public health, welfare and
environment. These procedures will be developed as part
of the Remedial Design process, at which time the
potential exposure/health impacts will be detailed.
As these procedures evolve there will be substantial
opportunity for public input.
The Mystic River Watershed Association requested that EPA and
DEOE not label the fenced-off hazardous waste areas of the Site
"conservation land" because this would be misleading.
EPA Response:
The EPA and DEOE presently have no plans which would label the
property as "conservation land."
A commu"n i ty member requested that future development of the
Site be forbidden in the areas of hide deposits (in an effort
to mitigate odors) and contaminated soils (in an effort to
control contaminated dust). In the event that development is
permitted in the areas of contaminated soil, the resident
requested that the "track record" of the developer as well as
monitoring and enforcement procedures be considered carefully
before development is allowed.
35.
EPA Response:
The AgencYi"believes that the citizen's request that no future
Site development be permitted is unnecessary and not warranted.
The Agency believes that portions of the Site may be developed
in some limited fashion so that the effectiveness of the
implemented remedial action is not compromised. The Agency
proposes to control future Site development through the use of
institutional controls. These institutional controls are
designed to prevent the unauthorized disturbance of the remedial
action.
The Agency is aware of the community's concern about the potential
release of odors and contaminants and would modify any development
proposal to ensure that there were no release of odors or other
contaminants during the development.
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/
36.
37.
39.
A process to ensure consistency and public input prior to any
permission being granted will be developed as part of the
Remedial Design Process.
The Industri-plex CAC suggested that Stauffer's fifteen-year
monitoring plan include a regulatory process for reviewing
proposals to alter the Site. The CAC proposed that DEOE file a
monitoring program with appropriate officials and agencies five
years before the,end of Stauffer's fifteen year monitoring
period. The CAC proposed that the program require the filing
of annual reports by the monitoring party to provide details on
maintenance, security, and landowner alterations at the Site.
EPA Response:
The CAC comments are appropriate and will be incorporated in
detail as part of the Remedial Design process.
A citizen requested that an "odor and particulate notification
plan," including provisions for emergency evacuation and
voluntary relocation, be in place during cleanup activities and
during any possible future development activity at the site.
EPA Response:
The Agency believes that such a plan is unnecessary and
unwarranted. Techniques to minimize and contain any release or
threat of release during and after the construction of the
remedial action shall be incorporated as part of the remedial
design. The Agency will continue to work with the Citizen's
Advisory Committee, community leaders, representatives of
business and the general public to ensure that their concerns are
adequately addressed during the remedial design phase.
38.
The Industri-plex CAC stated that it wishes to review specific
remedial design plans and any plans for monitoring the Site
during the fifteen-year period for which Stauffer has monitoring
responsib~lity.
EPA Response:
The agencies have welcomed the past involvement of the Industri-
plex CAC. They have been continually impressed with the CAC's
degree of professionalism, dedication to the task and positive
suggestions for improvement in the products produced. The
agencies look forward to continued interaction with the CAC
and public. The agencies believe that the CAC will have ample
time to review and have input into all aspects of the remedial
design process, including the fifteen year monitoring program.
The Industri-plex CAC requested that the land area on which the
piles are currently located not be available for development,
for other land uses or for any type of alteration once the
remedial action is completed.
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v
EPA Response
The Agency is cognizant of the CAC's concern that future Site
activities will adversely impact the implemented remedial
actions. The Agency agrees with the basic intent of the CAC's
proposal but not the manner in which to accomplish the goal.
Subpart G, Closure and Post-Closure of the Resource Conservation
and Recovery Act, will govern how the Site is to be maintained
once the remedial action is completed. Specifically, ~ 2n4.l17(c)
states that post~closure use of the property shall not disturb
the integrity of the final cover, liner(s), or any other
components of any containment system unless the Regional
Administrator finds that the disturbance is necessary to the
proposed use of the property and will not increase the potential
hazard to human health or the environment. As can be seen from
the above section, RCRA requires careful consideration by the
Regional Administrator prior to allowing modification of the
remedial action. Presently the Agency can see conditions under
which certain Site development would be permitted under specific
guidelines and controls. A draft of these guidelines and
conditions will be developed and included as part of the remedial
design process.
Again, as part of the RD process, steps involving standard
and prudent engineering practices will be incorporated into
the design to ensure that the remedial action is implemented
efficiently and safely. There are a number of techniques
available to provide a stable platform for heavy equipment
to work from. For example, techniques such as the placement of
soil stabilization fabrics followed by fill material can create
a stable base. Another technique would involve the placement
of cover material on a stable base, trucking material over the
cover and stable base to the interface, depositing the fill and,
working from the already placed cover, slowly extending the
cover using the already placed cover as a base.
40.
Public Participation Process and Miscellaneous Concerns
The CAC a~ked EPA and DEOE to legitimize the CAC process by
formallv incorporating it into the administration of both the
Federal and Massachusetts Superfund programs.
EPA Response:
The formation of the Citizens Advisory Committee (CAC) was done
under the Massachusetts Environmental policy Act (MEPA) as a
method for citizens to advise the Secretary of Environmental
Affairs, who in turn submits his or her concern to the DEOE.
The DEOE and EPA believe that the CAC under MEPA has been and
will continue to be an effective forum for citizens to
have significant input into the process.
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The EPA community relations plan, while recognizing the usefulness
of specialized groups, such as the CAC, prefers to solicit public
input from all facets of the community and not limit itself to
the formal designation of one particular group. As a practical
matter, the DEOE and EPA intend to use the CAC as a primary
forum to hold informal discussions with the general public in
addition to the formal public hearing process.
41.
Boston Edison Company, which has two major transmission rights-
of-way (ROW) on the Site, is concerned that the proposed remedial
actions will have adverse effects on the operation and maintenance
(O&M) of ROWs and the reliability of electric service in the
area. The Company requested specifically that: a) provisions
be taken for proper O&M of ROWs in areas where soil has been
covered: b) existing utility poles be replaced with those
that can withstand the effects of contaminated soil: c) the
remedial action plan take into account all requirements of
the National Electrical Safety Code and provide financially
for maintaining utility services: and d) a specification of
work plan practices for access to and maintenance of transmission
structures be provided to the company.
The Company was concerned that the FS only considered a 250-
acre area (Part A in the May 1982 RI Plan). It was Boston
Edison's understanding that the Industri-plex Superfund Site
included both Areas A and B.
EPA Response:
The EPA and the Massachusetts Department of Environmental
Ouality Engineering (DEOE) have been responsive to the particular
needs of Boston Edison Company as a public utility company.
Pending completion of the Remedial Design, the procedures
currently in place will remain in effect.
The agencies expect to work closely with Boston Edison during
the remedial design phase to ensure that the respective
organizatrons are able to implement the necessary plans with a
minimal..impact on either's project. The agencies will make
every eOffort to allow Boston Edison easy access to its ROWs
for the purposes of routine operation and maintenance.
Boston Edison is correct in stating that the RI/FS only addressed
in detail areas specifically identified in the May 1982 Consent
Order with Stauffer Chemical Company. The Phase II study did
identify areas outside the original 250 acres, however, not in
the same level of detail as for those areas within the 250
acres. The Agency intends, with the signing of the Record of
Decision (ROD), to address all areas of contamination associated
with the original Site, irrespective of the original Consent Order.
The exact size of this additional area is not known at present:
however, during the initial phases of the Remedial Design process
additional soils investigations will be conducted not only to
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better define those areas outside the initial scope 6f the
Consent Order but the developed areas within the original area
as well. The Agency believes that these additional areas,
. including ROW #9, can easily be incorporated into and made a part
of the Remedial Design process.
42.
The North Suburban Chamber of Commerce requested a thirty day
extension of the public comment period (the original public
comment period was from May 14 to July 1, 1985), from August 1,
1985, to August 31, 1985, in order to identify property owners
at the Site and encourage them to comment.
EPA Response:
The Agency extended the close of the public comment peiod from
July 1, 1985, to August 1, 1985. It respectfully declined to
extend it until August 31, 1985.
43. State Representatives Geoffrey Beckwith and Nicholas Paleologos
and u.S. Representative Edward Markey requested that the public
comment period for the proposed remedial action be extenden
from July 1 to August 1, 1985 so that public groups and
individuals would have more time to study Stauffer's proposed
cleanup approach.
EPA Response:
The Agency agreed with the State and Federal representatives
and increased the length of time for public comment from
July 1, 1985 to August 1, 1985.
44. Mayor Rabbitt of Woburn stated that citizens and the adminis-
tration of Woburn want to be part of the decision-making process
at the Site.
EPA Response:
The Agency believes, as a result of the substantial interaction
between the city, the Citizens Advisory Committee, ad hoc
groups, the general public and the agencies, that the public
and City of Woburn have been part of the decision making process.
The formal public comment period concluded the first portion of
the public's involvement. At the close of this period, the EPA .
sifted through all the information available to it and made
a decision which is not only protective of the public health,
welfare and environment, but consistent with applicable or
relevant and appropriate federal public health and evironmental
requirements as well. This decision is summarized and articulated
in the ROD. Once the ROD is signed, the Remedial Design
process will begin, and along with it the public's opportunity
to have input in the outcome of the Remedial Design.
A-29
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Comments from Monsanto
Co~ents by Monsanto Company were entered into the public record
at the July 17, 1985 public hearing as part of the formal public
hearing process. At this hearing, Monsanto reported that it
agreed in general that Stauffer's proposed cleanup adequately,
and in some cases more than adequately, addresses the public
health and environmental concerns associated with the site.
Monsanto Company ,supports a "reasonable cost-effective remediation
of the Site which addresses the safety of the community and the
desire that the Site be returned to commercial/industrial use
as soon as possible." Monsanto submitted two detailed documents
for the record.
45.
The objective of Monsanto's first document was to determine
the maximum safe concentrations of arsenic, chromium, and lead
in the soil which would allow unrestricted use of the restored
land in the future.
The findings of Monsanto's study were consistent with the
conclusion reached by Stauffer concerning maximum safe soil
metals' concentrations. In addition, Monsanto calculated
values for an industrial setting which they believed to be
protective of the public health, welfare and environment.
EPA Response
EPA believes that this is more a statement than a question and
therefore will not respond except to note that the Agency
concurs with Monsanto's conclusion.
46.
Monsanto's second document presented the company's
recommendations for remedial actions to be undertaken at the
Industri-plex site. In particular, Monsanto claimed that its
remedial action plan would provide:
a.
A quicker return of a large portion of the site to commercial
and i~dustrial use;
A soil cover with an average coverage depth of twelve inches
that is both sufficient and practical for isolation of
heavy metals;
b.
c.
An innovative, cost-effective approach to groundwater
cleanup; and
d.
A complete long-term solution to the East and West Hide
Piles that addresses existing and future surface water
problems.
The Agency would note that the document referred to above was
an unsolicited Feasibility Study (FS) by Monsanto Chemical
Company, a major responsible party at this Site. The Agency
would further note that it believes that it has satisfactorily
addressed Monsanto's concerns within the body of the ROD.
However, a brief answer is summarized below.
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47.
a.
The objective of any remedial action undertaken at a CERCLA
site is to take the necessary remedial responses to be
protective of the public health, welfare and environment.
While it is not the intent of the Agency to unnecessarily
adversely impact abutting property owners, the Agency will
not permit personal and private interests to prevent
implementation of the most cost-effective long-term remedy
for a site. As a result, a quick return of a site to
commercial and industrial use is not a criterion against
which remedial actions are evaluated.
b.
The proposal of a twelve inch cover was rejected for the
same reasons that 5-6 of the FS was rejected. These reasons
are detailed in the ROD document itself, and the reader is
referred to the appropriate sections of the ROD.
c.
Monsanto's approach to remediate the overall groundwater
problem posed by the site has merit: however, for reasons
stated in the ROD, the Agency selected an interim groundwater
remedy until the resolution of the area-wide problem is
resolved. Therefore, Monsanto's proposal is inappropriate
for the same reasons that GW-3 and GW-4 are.
The proposal for remediation of the odors caused by the
hide deposits advanced by Monsanto was not responsive to
the actual site conditions: instead it was a more conceptual
approach to the problem. Implementation of Monsanto
alternative would not be feasible because, like A-2, A-3,
and A-4 proposed in the FS, it wished to control odors at
the expense of eliminating wetland. The Agency found this
approach unacceptable. In addition, Monsanto indicated
that substantial reworking of the piles to form one large
pile was attractive, stating that the odor release could be
dealt with. The Agency believes that there is no effective
method to accomplish both tasks at the same time and, as a .
result, Monsanto's air proposal would create unacceptable
quantities of odor emissions.
Janpet As~ociates, owner of land in North Woburn, is concerned
that, because of the slow site cleanup process and various
impediments to conducting real estate activities on-site, the
financial burden to landowners has become substantial.
d.
EPA Response:
The Agency recognizes that, as a result of either being part of
the Site or adjacent to it~ there may be an economic burden
placed on the landowner. The Agency's primary objective at any
hazardous waste site is to investigate thoroughly the nature
and extent of contamination in order to evaluate and select a
remedial action which is protective of the public health and
welfare and environment, and which is in compliance with other
applicable ot relevant and appropriate federal public health
and environmental requirements. The Agency will attempt to
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complete this process as expeditiously as possible: however,
the process is long and complicated, especially at a site as
large and old as the Industri-plex site. It is not the Agency's
intent to cause financial hardship as a result of this process:
however, the Agency will not permit personal and private
interests to prevent implementation of the most cost-effective,
long-term remedy for a site.
Wetlands Issues
In addition to the public health co~ments received
initial public comment period, the Agency received
additional comments during the supplemental public
period on the wetlands.
during the
three
comment
The first was from the Mystic River Watershed Association,
Inc., acknowledging receipt and review of the document. The
President, Dr. Herbert Meyer, indicated that the reports were
adequate.
48.
49.
The second comment was from the Woburn Conservation Commission
indicating the fo.1lowing comments and concerns:
a.
The Conservation Commission believes the report is thorough,
technically sound, and clearly written.
b.
The Commission will want to review the mitigation plan to
compensate for unavoidable impacts on the wetlands, identified
as l.C and 7.
c.
The Commission urges EPA to require that the replacement
wetlands shall be completed prior to alterations to the
existing wetlands west of Commerce Way.
The Commission is supportive of the stated intention to
take appropriate measures toward the enhancement of the
existing wetlands at Industri-plex in order to maximize
their wetland values.
EPA Respon~e
d.
a.
The Agency concurs with the Conservation Commission assessment
of the quality of the reports.
,"
b.
The Agency believes that the Woburn Conservation Commission
will play an integral and active role in any future dealings
relative to wetlands. The Agency further believes that a
community should be the primary proponent in the protection
of important natural resources such as wetlands.
c.
The Agency's decision to control the environmental impact
resulting from the East Hide pile was not to draw and fill
the pond and adjacent wetlands. As a result, this comment
is no longer pertinent.
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50.
The final comments were received from Dundee Park Properties, a
developer abutting the Site to the north. The bulk of Dundee
Park Properties' letter was devoted to the Park's belief that
the action was not necessary, infeasible to implement as proposed,
and ultimately reduces the amount of developable property
east of Commerce Way as a result of the formation of a new
replacement wetlands. Specifically, Dundee Park Properties'
questions were:
a. will the proposed creation of the 4.1 acres of wetland on the
east side of Commerce Way affect the 12" waterline that
Dundee Properties has installed across the Mark-Phillip
Trust property? If so, Dundee Park Properties feels it is
important that they also be allowed to review the proposed
wetland plans being drawn up by Stauffer's consultants as referred
to in the report.
b. What costs may be set upon Dundee Park Properties for
installation and future maintenance of any south dike flow
control device if the 4.1 acre wetland is drained?
EPA Response
a. As a result of the Agency's determination that the pond and
its associated wetlands located between the East and West
Hide Pile need not be eliminated in order to successfully
implement a remedial action, the proposed new wetlands east
of Commerce Way will not be built. As a result, Dundee Park
Properties' concern relative to their waterline is moot.
b. The costs and the responsibility for assuming these costs
have not yet been finalized. These issues will be the
subject of upcoming negotiations between the agencies and
the responsible parties.
The remainder of the Park's letter was devoted to the Park's
opinion a& to why the filling of the wetlands and the subsequent
taking of uncontaminated developable land was not required.
The Agency believes that it is inappropriate to comment on the
Park's rationale at this time.
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ATTACHMENT A
COMMUNITY RELATIONS ACTIVITIES CONDUCTED AT
THE INDUSTRI-PLEX SITE
To ensure that all interested parties are com~unicating regularly,
the EPA has conducted a community relations program at the
Industri-plex site. Community relations activities conducted
at the Industri-plex site to date include the following:
o EPA prepared a community relations plan, Summer, 19B1
o EPA and DEOE attended and participated in meetings of
the Industri-plex Citizens' Advisory Committee, ongoing
throughout the RI/FS.
o EPA released for public review and comment the draft
remedial investigation/feasibility study (RI/FS) on site
cleanup alternatives prepared by Stauffer Chemical
Company, May, 1985.
o EPA prepared and distributed an information sheet on the
draft RI/FS, May, 1985.
o EPA held a public meeting on May 21, 1985
School to describe the RI/FS study and to
citizens' questions. Approximately 30 to
attended.
at Woburn High
respond to
35 people
o EPA held a public hearing on July 17, 1985 at Woburn
High School to record comments by the public, local and
State officials and potentially responsible parties. A
transcript of this hearing is available at the main
branches of the public libraries in Woburn, Reading,
Winchester and Wilmington.
o Following one extension, the public comment period closed
on August 1, 1985. It lasted approximately twelve weeks.
A-34
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,.
APPENDIX B
Statement of Findings
Industri-plex Site
proposed Remedial Response Action
soils Contamination
~.
september 1986
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In accordance with EPA policy and Executive Orders 11988
and 11990 concerning Floodplains and wetlands, the following
statement of Finding has been prepared.
The Statement of
Finding is part of the Record of Decision (ROD) for the
Industri-plex Site and further serves to notify the general
public and affected agencies that proposed remedial response
actions for areas within the Site are in or may potentially
affect a base (100 year) floodplain and/or a wetlands.
The
statement of Findings includes the following:
1.
The reasons why the proposed action must be located in
or affect the floodplain or wetlands.
2.
A description of significant facts considered in making
the decision to locate in or affect the floodplain or
wetlands including alternative sites and actions.
3.
A statement indicating whether the proposed actions
conform to the applicable state or local floodplain
protection standards.
4.
A description of the steps taken to design or modify
..
the proposed action to minimize potential harm to or
within the floodplain or wetlands.
s.
A statement indicating how the proposed action affects
the natural or beneficial values of the floodplain or
wetlands.
The proposed remedial response action at the site consists
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of site grading, capping and removal/relocation of contaminated
soils and sludges over a seventy acre Site.
portions of
the Site contain wetlands which may be impacted by the
proposed remedial action - specifically, the wetlands
located along the northern border of the Site between the
East and West Hide piles.
In addition, two small former
waste lagoons, now considered a wetlands, may be impacted.
The decision process leading to the selection of this action
and a detailed discussion of the action are documented in
the ROD.
The reason why the proposed action must be located
in or affect a floodplain or wetlands is that the area of
contamination and contaminant migration pathway is so
located.
The proposed site grading, capping and
removal/relocation actions are not located in a base (100
year) floodplain; however, portions of these actions
are located in a wetlands and the actions could affect the same.
The decision to locate in or affect the wetland was based
on the fact that a portion of the area of contamination and
contaminati9n pathway is so located.
The decision to
propose remedial action in these areas rather than take no
action was based on the public health, welfare and
environmental risks associated with this area of contamination.
The health risks related to the potential for direct contact
of soil contaminated with hazardous substances, i.e. arsenic,
chromium and lead, was a significant factor considered in
making this decision.
The action to grade and cap the Site
is considered necessary to protect the public health and environment.
-------
The migration of toxic metals to the wetlands and surface water
resultiny from precipitation and overland flow has had an
adverse impact on the surface water and sediments in the
pond.
The release or threat of release presents a potential
hazard to public health and the aquatic species in the
pond.
Material will be excavated from the wetlands and
pond to eliminate the potential for direct contact and to
reduce the potential health risk associated with contaminants
in and migrating to these water bodies.
The proposed action at the site is consistent with the
applicable or relevant and appropriate Federal public health
and environmental requirements.
proposed actions would
also be consistent with State (310 CMR 10.00 parts I and
III) and local wetland standards.
Design and construction activities related to the implementation
of the remedial response action proposed will include the
best practical measures to minimize potential harm to or
within the wetlands.
"
Initial design has considered the
need to control adverse impacts; erosion, sediment and
contaminant migration, both during construction and resulting
from topographic and subsurface drainage changes necessary
to the implementation of this action.
Control and mitigative
measures will be considered in more detail during the final
design phase of this action.
Using the best practical measures to control potential
adverse impacts will reduce possible harm to the wetlands
-------
from siltation and further degradation from contamination.
successful implementation of this action will eliminate the
potential risk of surface water and sediment contamination
in the wetlands, pond and discharge stream, potential
adverse effects on'aquatic species and will allow, ,when
coupled with other proposed site remedial actions, for the
long term protection of the public health, welfare and enviroment.
~
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APPENDIX C
statement of Findings
Industri-plex Site
proposed Remedial Response Action
East Hide pile
~.
-------
In accordance with EPA policy and Executive orders 11988
and 11990 concerning Floodplains and Wetlands, the following
Statement of Finding has been prepared.
The Statement of
Finding is part of the Record of Decision (ROD) for the
Industri-p1ex Site"and further serves to notify the general
public and affected agencies that proposed remedial response
actions for areas within the Site are in or may potentially
affect a base (100 year) floodplain and/or a wetlands.
The
Statement of Findings includes the following:
1 .
The reasons why the proposed action must be located in
or affect the floodplain or wetlands.
2.
A description of significant facts considered in making
the- decision to locate in or affect the floodplain or
wetlands including alternative sites and actions.
3.
A statement indicating whether the proposed actions
conform to the applicable State or local floodplain
protection standards.
...
4.
A des~ription of the steps taken to design or modify
the proposed action to minimize potential harm to or
within the floodplain or wetlands.
5.
A statement indicating how the proposed action affects
the natural or beneficial values of the floodplain or
wetlands.
The proposed remedial response action at the Site consists
-------
of site grading, slope stabilization, installation of an
impermeable cap, gas collection system and the construction and
operation of a gaseous emission treatment system on the East
Hide pile.
The decision process leading to the selection
of this action and' a detailed discussion of the action are
documented in the ROD.
The reason why the proposed action
must be located in or affect a floodplain or wetlands is
that the area of contamination and contaminant migration
pathway is so located.
The proposed remedial action is
not located in a base (100 year) floodplain~ however,
the area requiring implementation of a remedial action is
located in a wetlands and, as a result, any action taken
could impact said wetlands.
The decision to locate in or affect the wetland was based
on the fact that the area of contamination and contamination
pathway is so located.
The decision to propose remedial
action in these areas rather than take no action was based
on the public health, welfare and environmental risks
associated 'ith this area of contamination.
T~e health
risks related to the potential for direct contact of soil
contaminated with hazardous substances, i.e. arsenic,
chromium and lead, was a significant factor considered in
making this decision.
The continued degradation of the pile,
including the sloughing of the sides of the pile into the wetlands
and the release of a substantial odor impacting the pUblic's
welfare were also significant factors considered.
The
C-2
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action to grade and cap the Site is considered necessary
to protect the public health and environment.
The migration of toxic metals to the wetlands and surface water
resulting from precipitation and overland flow, slope stability
problems and release of odors has had an adverse impact on
the surface water and sediments in the pond.
The release
or threat of release presents a potential hazard to public
health and the aquatic species in the pond.
To reduce the
potential health risk associated with contaminants in and
migrating to the wetlands and pond, sheet piling will be driven
at the toe of the slope to stablize the side slopes of the pile;
regrading and installation of an impermeable membrane will
eliminate the potential for direct contact.
The proposed action at the site is consistent with the
applicable or relevant and appropriate Federal public health
and environmental requirements.
proposed actions would
also be consistent with State (310 CMR 10.00 Parts I and
III) and local wetland standards.
~
Design and construction activities related to the implementation
of the remedial response action proposed will include the
best practical measures to minimize potential harm to or
within the wetlands.
Initial design has considered the
need to control adverse impacts: erosion, sedim~nt and
contaminant migration, both during construction and resulting
from topographic and subsurface drainage changes necessary
to the implementation of this action.
Control and mitigative
-------
~
~,
measures will be considered in more detail during the final
des.ign phase of this action.
Using the best.practical measures to control potential
adverse impacts will reduce possible harm to the wetlands
from siltation and further degradation from contamination.
Successful implementation of this action will eliminate the
potential risk of surface water and sediment contamination
in the wetlands, pond and discharge stream, potential
adverse effects on aquatic species and will allow, when
coupled with other proposed site remedial actions, for the
long term protection of the public health, welfare and enviroment.
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