United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPA/ROD/R01 -89/037
September 1989
&EPA
Superfund
Record of Decision
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50272.101
REPORT DOCUMENTATION 11. AEPOIITNQ, 1a.
PAGE EPA/ROD/ROl-89/037
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$UPERFUND RECORD OF DECISION
Baird' McGuire, MA
hird Remedial Action
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. The Baird' McGuire site. is a for.mer chemical manufacturing facility in northwest
Holbrook, Massachusetts; approximately 14 miles south of Boston. The 20-acre site is
situated in a w~tland area within the 100-year floodplain of the Cochato River which lies
to the east. From 1912 to 1983 the company operated a chemical manufacturing and bat ching
facility on the property. Manufactured products included herbicides, pesticides,
d~~infectants, soaps, floor waxes and solvents. Waste disposal methods at the site
,uded direct. discharge into the soil, nearby brook and wetlands, and a former gravel pj
(now covered) in the eastern portion of the site. Underground disposal systems were also
used. The South Street well field, part of the municipal water supply for Holbrook, is
within 1,500 feet of the Baird' McGuire property. The last operating well was shut down
in 1982 due to organic contamination which possibly. originating from the site. EPA'
conducted a remova:. action at the site in 1983 after a waste lagoon overflowed spreading
contaminants intu the Cochato River. The company ceased operating shortly thereafter. A
J~~c~nd removal ac~ion was .conducted in. 1985, following the discovery of dioxin in site
"s'oi1"s. : .EPA also' conducted an Initial ~emedial Measure at the site from 1985.through 1987
which involved con~tructing a new water ,main to direct. water away from the site, removing
building structure~, and installing a temporary cap. In 1986 a Record of Decision (ROD)
was signed to addr~ss onsite ground water treatment and incineration of contaminated soil.
Tl11s ROD addresse.s the Cochato River sediment contamination. (Continued on next paqe)
'11. DoCII ._d~. 8; D88cItpIIN.
" Record of Decis:Lon - Ba.ird , McGuire, MA
Third Remedial Action
Contaminated ME'dia: sediment
Key Contaminants: organics, (PAHs, pesticides), metals (arsenic}
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16.
Abstract (Continued)
EPA/ROD/R01-89/037
Baird & McGuire, MA
..~...~~ --.-
The primary contaminants of concern affecting the sediment are organics including PARs
and pesticides, and metals including arsenic.
The selected remedial action for this site includes placement of river silt curtains
downstream of the site; excavation and onsite incineration of approximately
1,500 cubic yards of contaminated sediment; backfilling excavated areas with clean fill
and onsite placement of treated sediment; restoration of wetland areas; and long term
surface water and sediment monitoring. The estimated present worth cost for this
remedial action is $1,656,000, which includes an estimated annual O&M cost of $22,000.
'*'
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RECORD OF DECISION SUMMARY
BAIRD & McGUIRE SITE/ .
SEDIMENT STUDY AREA
HOLBROOK, MASSACHUSETTS
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SEPTEMBER 14,. 1989
u. S. ENVIRONMENTAL PROTECTION AGENCY
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RBCORD OP DBCISION
RBMBDIAL ALTBRKATIVB SBLaCTIO.
Si~. Name and Loca~ion
Baird' McGuire Site/Sediment Study Area
Holbrook, Massachusetts-
S~a~ement ot PurDose
This Decision Document presents the selected remedial action for
this Site developed in accordance with the Comprehensive
Environmental Response, Compensation, and Liability Act ot 1980
(CERCLA), as amended by the Superfund Amendments and
Reauthorization Act of 1986 (SARA), and to the extent
practicable, ~he National Contingency Plan (NCP), 40 CFR Part 300
~~, 50 Federal Register 47912 (November 20, 1985).
The Commonwealth of Massachusetts has concurred with the selected
remedy. r
State.ent or Basis
This decision is based on the Administrative Record which was
developed in accordance with Section 113(k) of CERCLA and which
is available for public review' at the information repositories
located at the Holbrook Public Library in Holbrook,
Massachusetts, and at the EPA offices at 90 Canal Street in
Boston, Massachusetts. The attached index identifies the items
which comprise the Administrative Record upon which the selection
of a.remedial action is based. .
DescriDtioa ot tbe Selected Re.~dy
The selected remedial action for the Baird' McGuire Site/
Sediment Study Area consists ot source control measures.
The source control remedial measures include:
Excavation and incineration of approximately 1,500 cubic
yards of contaminated sediments for protection of public
health and the environment in this area. Sediments in 1;he
Cochato River will be mechanically excavated to an average
depth of six (6) inches, from approximately the center of
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Excavatea~sediments will be placed in specially designed
containers and trucked to the on-Site treatment facility.
The sediments will be treated utilizing a transportabla
incinerator that will be brought on-Site for the soil
excavation and incineration phase of overall Site
remediation.
"'"
The treated sediments will be placed on-Site as backfill
material, along with other treated Site soils. EPA is
currently conducting tests on Site soils at an oft-site EPA
research facility. These tests are designed to verify the
effectiveness of the incineration process on contaminated
soil from the Baird. McGuire Site, and to characterize the
wastes. streams that will be generated by the incineration
process. This testing will include verification ot the
sUitability of the material as back~ill tor the Site, and
will include a determination ot whether the material is
subject to the Land Disposal Restrictions under the Resource
Conservation and Rec:overy Act (RCRA).
Additional measures include:
Utilization of silt curtains in the river to minimize the
pos.ibility of suspended sediments being transported
downstream during excavationo Remedial design will address
the details ot the silt curtains and will examine any other
type of controls that may be appropriate during
construction. .
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Restoration ot wetiand areas adversely impacted by tt.e
remedial action, such as those impacted by excavation access
road constructiono
Placement of clean backfill in excavated areas of the river
immediately in the vicinity ot the groundwater plume
discharge to the river.
Long term monitoring of downstream portions ot the Cachato
River that will not have sediments excavated.
The estimated present worth cost for the selected remedy is
$1.,656,000. This estimate includes capital costs, as well as
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Dealaration
. The selected remedy is protective- of human health. and the
environment. The remedy satisfies. the statutory preference for
treatment: thai:. permanently and significantly reduces the volume,
toxicity and mobility of the hazardous substances,- pollutants and
contaminants as a principal element. The. selected remedy
utilizes permanent solutions anet alternative treatment
technologies. to. the maximum extent practicable, and is cost-
effective. The selected remedy also attains all federal and
state requirements that are applicable or relevant and
appropriate (ARARs).
9" vrtlu {~1' q
~
£aM/H ~y( . .
aul G. Keouqh (j
Actinq Reqional Administrator, EPA Reqion r
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Contents
I.
II.
III.
IV.
V.
VI.
VII.
VIII.
IX.
X.
XI.
BAIRD' MCGUIRE SITE
SEDIXBHT STUDY AREA
TABU 01' CONTENTS
paae Wumher
SITE NAME, LOCATION AND DESCRIPTION
. . . .
. . . 1
SITE HISTORY AND ENFORCEMENT ACTIVITIES
A. Response History. . . . . . . . .
B. Enforcement History. . . . . . . .
. . . . . 2
. . . . . 2
. . . . . 3
COMMUNITY RELATIONS
. . .
. . .
. . .
. . . .
SCOPE AND ROLE OF OPERABLE UNIT OR RESPONSE
ACTION. . . . . . .
. . . . .
. . . 5
. . . . . . .
SITE CHARACTERISTICS. . .
. . .
. . . 6
. .'.
. . .
A.
Hydrogeologic Setting and Contaminant
Migration ................. 6
Cochato River. . . . . . . . . . . . . . . . 7
B.
SUMMARY OF SITE RISKS
. . . . . . . . . . .
. . . 9
A.
B.
Public Health Risk Assessment. . . . . . .
Ecological Risk Assessment. . . . . . . .
DOCUMENTATION OF SIGNIFICANT CHANGE
. . . . . .
DEVELOPMENT AND SCREENING OF ALTERNATIVES
. . .
A.
B.
Statutory Requirtiments/Response Objectives.
Technology and Alternative Development and
Screening. . <. . . . . . . . : . . . . . .
DESCRIPTION/SUMMARY OF THE DETAILED AND
COMPARATIVE ANALYSIS 'OF ALTERNATIVES. . . . . .
A.
B.
Non-Removal eNR) Alternatives. . . . . . .
Removal (R) Alt~rnatives . . . . . . . . .
THE SELECTED REMEDY
. . . . . . . . .
. . . . .
A. Description of the Selected Remedy. . . .
B. ' Rationale for Selection. . . . . . . . . .
STATUTORY DETERMINATIONS. . . .
. . . .
. . . .. .
A.
The Selecte~ Remedy is Protective of Human
Health and t:he Environment. . . . . . . .
The Selected Remedy Attains ARARs . . . . .
The Selected Remedial Action is Cost
Effective. . . . . . . . . . . . . . . . .
B.
C.
. . 5
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10
11
11
13
13
14
15
16
18
20
20
25
26
26
28
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XII.
D.
The Selected Remedy Utilizes Permanent
Solutions and Alternative Treatment
Technoloqies or Resource Recovery
Technoloqies to the Maximum Extent
Practicable. . . . . . . . . . . . . . . .
E.
The Selected Remedy Satisfies the Preference
for Treatment as a Principal Element. . .
STATE ROLE. . . .
. . . . . . . . . e- . . . . .
31 .,..
31
31
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BAIRD' McGUIRK SITE
SEDDIENT STUDY AREA
RecoreS of DecisioD.Summary
Piaure NtJlllher
LIST 01" PIGURES
1.
2.
3.
4.
study Area Location Map
Remedial Alternative Screening
Remediation Areas
Conceptual Site Layout
LIST OJ' TABLES
Table VlJlllher
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1.
2.
3.
4.
5.
6.
7.
8.
9. .
10.
11.
Contaminants of Concern: Public Health Risk Summary
Technology Screeninq Summary
Remedial Alternative Screening Summary
Public Health Target Levels .
Site-Specific Environmental Target Levels
Comparative Summary of Remedial Alternatives
Sediment Volume Estimates.
Chemical-Specific ARARs
Location-Specific ARARs
Action-Specific ARARs
Comparative Cost Estimate for. Removal Alternatives
APPBIIDICBS
Responsiveness Summary. . . . . . . . . . . . . . Appendix A
Administrative Record Index ... ~ . . . . . . . . . Appendix B
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ROD DBCISION SUMMARY
BAIRD' KcGUIRB SITB/SEDIMENT STUDY AREA
I.
SIT!: BAMBi LOCATION AND DBSCRIPTIOH
The Baird & McGuire site is located on South Street in nortnwest
Holbrook, Massachusetts, approximately 14 miles south of Boston.
The twenty-acre Site is bounded by South Street to the south and
west, Mear Road to the north, and the, Cochato River to the east.
Approximately 2.5 miles downstream from the Site, the Cochato
River flows past. a sluice qate requlating the diversion of river
water to the Richardi Reservoir, a water supply source for the
towns of Holbrook, Randolph, and Braintree. This diversion has
been closed since 1983.
Eiqht of the twenty acres have been owned by the Baird & McGuire
Company since 191~, when chemical manufacturing operations beqan.
The Baird & McGuire property originally' included a laboratory,
storage and mixing buildings, an office building and a tank farm.
For over 70 years, Baird & McGuire, Inc. operated a chemical
manufacturing and batching facility on the property. Later. .'.
activities included mixing, packaging, storing and distributingr
various products, including herbicides, pesticides, .
disinfectants, soaps, tloor waxes and solvents. Some of the raw
materials used at the Site were stored in the tank farm and piped
to the' laboratory or mixing buildings. Other raw materials were
stored in drums on-Site. Waste disposal methods at the Site
included direct discharge into the soil, nearby brook and
wetlands, and a former gravel pit (now covered) in the eastern
portion of the Site. Underground disposal systems were also used
to dispose of wastes.
The South Street welltield, part of the municipal. water supply
for Holbrook, is within 1,500 teet ot the Baird & McGuire.
property. The last operating well was shut down in 1982 due to
organic contamination. Studies indicate that contaminants used
or stored at the site were possible sources ot contamination in
the well. In December 1982,. the Baird & McGuire Site was placed
on EPA's Proposed National Priorities List (NPL).
- .
The Baird' McGuire Site/Cochato River Sediment Study Area
extends trom Lake Holbrook north to the Richardi Reservoir. This
study area covers approximately a three-mile portion of the
Cochato River and several tributaries, encompassing areas both
upgradient and downgradient of the 20-acre Site. See Fiqure 1
tor a map ot the study area.
A more complete description of the Site can be found in the
Focused Feasibility Study at pages 1-2 through 1-5.
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II.
SIT. HISTORY AND IHPORCEXBN'l' ACTIVITIES
A.
R.SpODS. History
In 1983, EPA conducted a removal action at the Site"atter a waste
lagoon overflowed near the Cochato River and spread contaminants
into the river. Emergency activities included removing
approximately 1,000 cubic yards of heavily contaminated soils,
construction of a groundwater interception/recirculation system
to limit contaminated groundwater trom migrating into the river,
and regrading the contaminated waste disposal area and covering
it with a temporary clay cap. In response to the lagoon
overflow, the Tri-Town Water Board (Holbrook, Randolph,
Braintree) closed the sluice gate approximately 2.5 miles
downstream from the Site that diverted water to the Richardi
Reservoir. To date, the sluice gate has remained closed.
A second removal action for the Site was initiated in 1985
following the discovery of dioxin in site soils. EPA conducted
additional sampling of air, 50ils and water, and an' additional
5,600 feet ot tence was installed at that time.
.
Another major activity conducted at the Site by EPA in 1985 '
through 1987 was an Initial Remedial Measure (IRM). A new water
main was constructed along South Street to replace an existing
main that passed through the Baird & McGuire Site, and the water
main passing through the Site was abandoned by filling it with
concrete. ,The Baird & McGuire laboratory and mixing buildings
and tank farm were demolished and removed as part of the IRM, and
a temporary synthetic cap was installed over that portion of the
Site. Wood from the demolished buildings was shredded and placed
into barrels and crates that are currently stored on-Site in the
storaqe building.
A Record of Decision for the Site, signed in 1986, divided the
cleanup of the Baird & McGuire Site into operable units. An
operable unit is a discrete part of an entire response action
that decreases a release, a threat of a release, or a pathway of
exposure. EPA determined in the 1986 ROD that operable units are
appropriate for the overall remediation ot the Baird & MCGuire
Site. The 1986 ROD established two major remedial components:
extraction and on-Site treatment of groundwater (operable unit
'1); and, on-Site excavation and incineration of contaminated
soil, much of which is currently covered by temporary caps
(operable unit '2). In addition, the demolition material
remaininq from the oriqinal Baird & McGuire buildings will be
incinerated on-Site when the soil incineration portion of the
long-term remedial action program is initiated.
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EPA and the U.S. Army Corps ot Enqineers have completed the
design ot the on-Site groundwater extraction/treatment/recharga
system, and the U .5. Army Corps of Engineers is currently
preparinq to award this construction contract. Design ot the
incineration system is currently underway, as is a series of
tests to determine the operatinq procedures that will most' ,
effectively destroy' soil contaminants.. The soil incineration' ,
tests are being conducted off-site at EPA's Office ot Research,
and Development facility in Arkansas.
This Record of Decision is for the, third operable unit for the-
Baird & McGuire Site, which addresses Cochato River sediment
contamination. A fourth operable unit, addressing a potential
alternate water supply for the town ot Holbrook, is currently
underway, and a Proposed Plan for this fourth operable unit is,
scheduled for release to the. public in 1.990.
A more detailed description ot the Site history can be found in
the Focused Feasibility Study at pages, 1.-5 through 1-6.
B.
.D~orC".D~ History
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The Baird' McGuira facility had a lenqthy history o~ violatinq ,
environmental laws. From the -mid-1.950 's on, the company' received
numerous citations tor violation~ ot the Federar Insecticide,
Funqicide~ and Rodenticide Act.. Further, both the state and the
local governments took leqal actions against the company at
various times.
EPA involvement under tha Comprehensive Environmental Response,
Compensation, and Liability Act (CERCLA) beqaft in March 1983 with
the first removal action conducted at the Site. Baird & McGuire,
Inc. ceased operatinq shortly thereatter, and the company and its
' otficers took the position that they did not have sutticient
assets"to pay tor the (remedial) work necessary at the Site.
In October 1983, the United States ot America, on behalf ot the
Administrator of EPA, tiled a cost recovery action under Sections
104(a) and (b) and 107(a) ot CERCLA. The complaint sought
reimbursement tor costs incurred by the United States in
remedyinq Site conditions trom Baird & McGuire, Inc., Baird
Realty Co., Inc. (subsequently know as the AnnE'. Realty Trust,
Inc.), Cameron K. Baird, and Gordon M. Baird.
Baird & McGuire, Inc. owned and operated the Baird' McGuire
facili1:Y. Baird Realty Co., Inc. was a record owner ot part of
the 'Site:.,' "'Cameron Baird was the president, treasurer, and chief
executive ot Baird' MCGuire, Inc. Gordon M. Baird (Cameron's
brother) was the chairman ot the board ot Baird ,'McGuire, Inc..
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The government contends that both individuals exercised control
over the company's conduct, activities and operations.
The defendants to the lawsuit, as listed above, a're also the only
Potentially Responsible Parties ("PRPs") identified to date by .
EPA. .
The PRPs maint~ined from early on in discussions. with EPA both
that they lacked the financial assets to conduct the remedy and
that they were not liable. The PRPs provided some information
regarding their finances, and the United States. obtained a lien.
on a parcel of property owned by the Ann E. Realty Trust, Inc..
EPA subsequently determined that the PRPs were unable. and
unwilling to implement the full remedy at the Site.
The cost recovery action tiled in 198! was settled on an Wability
to pay'" basis in ~987. The Consent Decree that was signed by all
parties in September 1987 includes the following major
provisions:
A cash paYment of $900,000, made in two instaIlmentsr
Full 'access to the Site for the pUrposes of implementing
response actions;
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Liens on the Baird' McGuire property, which cons.tsts of 2
lots owned by the Ann E. Realty Trust and the; Bairct "
McGuire lotr and
Rights to insurance policies which may provide coverage for
costs incurred in response to the release or threat of
release of hazardous substances from the Baird & McGuire
property.
EPA is continuinq negotiations with the insurers of Baird &
HCGuirer Inc.. No settlements have yet been reached with these
. parties..
.
The PRPs have had virtually no involvement in the FFS and: remedy
selection process for this operable uni~. EPA notified the
public, including the PRPs, of the issuance of the Proposed Plan,
but received no PRP comments on the Proposed Plan.
Special notice. has not been issued in this case tor the earlier
operable units since the cost recovery case, filed in 1983, was
settled with the PRPs in 1987.
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III.'
COJlK01f%TY BUTIORS
Throughout the Site's. history, community concern and involvement
has been high. EPA has kept the: community and other interested
parties apprised of the Site activities. through Baird & McGuire
Task Force meetings, informational meetings, fact sheets, press
releases and public meetings.
In 1985, EPA released a community relations plan, which has been
periodically updated, which outlines a program to address.
community concerns and keep citizens informed about and involved
in activities during remedial activities. Throughout 1985 and
1986, EPA held a series of public informational meetings to
describe the plans for and results of the Remedial Investigation,
Feasibility Study, and other actions taken by the. Agency at the
site during this time.
In May 1989, EPA made the administrative- record available for
public review at EPA's oftices in Boston and at ,the Holbrook
Public Library. The administrative record was subeequently
updated in June 1989 'to include additional documents used by the
Agency tor this Cochato River Sediment Study decision. EPA .
published a notice and a briet analysis ot the Proposed Plan ia
The Patriot Ledaer on June 12, 1989 and made the Plan available
to the public at the Holbrook Public Library. '
For the Balrct . McGuire Cochato River Sediment s,tudy, EPAheld an
inrormational meeting on June 13, 1989 to discuss the. results 'of
the Focused Feasibility Study and the cleanup alternatives
.included in this Focused Feasibility Study and to present the
Agency's Proposed Plan. During this meeting, which was held at
the Holbrook Jr. Sr. High school, the Agency also answered
questions trom the public. From June 19, 1989 through July 19,
1989, the Agency held a thirty-day public- comment period to
accept public comment on tbe alternatives. pr.esente~ in the
Focused Feasibility Study and the Proposed Plan ana on any other
documents previously released to the public or included in the
administrative record. On July 12, 1989, the Aqenc)' held a
public m..ting to accept any oral comments. A transcript ot this
meeting and tbe comments and the Agency's response ~o comments
are include4 in the attached Responsiveness Summary'. .
IV.
SCOP. AlII) ItOLB OJ' OPBDBLB UBIT OR REBPONSB ACTIO.
As anticipated in the "Future Action" section of the 1986 ROD for
the Site, this operable unit addresses sediment contamination in
the Cochato River attributable to the Baird , M~Guire 5ite.
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The Focused Feasibility StUdy for the Cochato River Sediment
Study Area focused on the nature and extent of sediment
contamination, the associated risks, and an examination of
potential remedial alternatives. This ROD, and its incorporated
Fiqures, Tables, and Appendices, calls for excavation of .
contaminated Cochato River sediments and treatment by the same
technoloqy that was selected for the other contaminated Site
soils in the 1986 ROD.
v.
SITB CHARACTBRISTICS
Chapter 1 of the FFS contains an overview of the Remedial
Investiqation (RI). The siqniticant findinqs ot the RI are
summarized below.
A.
Bydroq801oqic S8ttinq aD4CoDtaainaDt XiqratioD
1.
Baird & McGuire Sm
The qeoloqic features of the Baird & McGuire Site area are
representative of processes associated with qlaciation. The
observed features are bedrock, till, outwash deposits of
stratified sands, qravel and silts~ orqanic soils and fill
materials. .
The bedrock underlyinq the Site is tractured and shows
indications, throuqh monitorinq well and rock core observations,
of qroundwater movement throuqh the fractu:c-eu. In qeneral, the
top of competent bedrock appears to slope acnmward from South
Street toward a closed depression or bowl in the low lyinq
eastern portion of the Site. A bedrock vallny extends
northwestward from this bowl.
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The solls overlyinq bedrock consist ot 3 qen..ral types, althouqh
a pump test conducted at the Site indicates the overburden
generally responds as one unit. .
Soil Type
.
Apprnximate Hydraulic
Cond'~ctivity (ft/day)
silty sands, sand, and silt
3
medium and coarse sands
45
10
qlacial till
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2.
contaminant Miaration
Man-made barriers are currently used to minimize the miqration of
contamination from the Site. The barriers are the qroundwater
interception/recirculation system and the temporary clay cap
installed in 1984 as a part of the first removal action, and the
temporary hiqh density polyethylene (HDPE) cap installed in 1987
as a part of the IRM. The temporary impervious cappinq was
desiqned to divert clean runoff and precipitation away from the'
Site and to limit direct infiltration. It also reduces the
potential for direct contact with contaminated soils.
contaminated substances have miqrated and continue to miqrate
from the Baird & McGuire property throuqh groundwater and surface
water routes. Groundwater discharges into the Cochato River.
However, according to the original RI/FS conducted for the 1986
ROD, this contamination is beinq effectively attenuated by
orqanic soils and sediments on the river bottom, biodegraded by
anaerobic and aerobic bacteria, and diluted by surtace water so .
as to prevent any measurable deqradation of water in the Cochato
River. '
, .
Miqration of contamination through surface water is primarily via
stormwater runoff. Uncapped contaminated soils have in, the past
eroded, and continue to do so, and are transported during storm
events.. The wetlands surroundinq the site show the qreatest
evidence of contaminated particulate transport via surt'ace water~
Sediment contamination of the Cochato River and the unnamed brook
near the Site and downstream from the Site can be attributed to
Baird & McGuire surface water runoff.
B.
COcha1:o River
1.
Sediment
Based on the results ot December 1987 screeninq, 84 sediaent
samples were collec1:ed from 44 locations throuqhout the Cocba1:o
River Sediment study area durinq June 1988. Samples wer~
collected trom three depth increments: 0 to 6 inches: 12 to lit
inches: and 18 to 36 inches. All 84 samples were analyzed tor
target compound list (TCL) inorganics and organics, and
herbicides. Twenty-seven of the 84 samples were also analyzed
tor physical characteristics, includinq grain size, moisture
, content, total volatile solids, specific gravity, and pH.
The predominant contaminants detected in the sediment durinq June
1988 sampling event were vocs, arsenic, base/neutraL organic
compounds, and pesticides. Based on environmental c~ncentrations
and toxicological properties of these contaminants, four'
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chemicals or chemical qroups were selected as contaminants of
concern: arsenic, PAKs, DOT and metabolites (includinq DDD and
DDE), and chlordane.
The maximum concentrations of Site-related contaminants in
sediments are presently located within 500 feet downstream of the
current Site fence. Elevated concentrations of arsenic,
base/neutral orqanic compounds, and pesticides are also found in
the Ice Pond and in a swampy area (Mary Lee Wetlands)
approximately 1,200 feet downstream from the Ice Pond. The
occurrence of these elevated concentrations downstream implies
that the distribution of the contaminants is controlled, at least
in part, by sediment transport and deposition of sediment-bound
contaminants in areas of low velocity. Concentrations of Site-
related contaminants in sediments decrease appreciably downstream
from the Ice Pond and remain at relatively low levels throuqhout
the larqe wetland downstream to the Braintree Golf Course. Many
of the base/neutral extractable organic compounds detected in on-
Site sediments were also detected in sediments of the major
tributaries to the Cochato River. This findinq indicates that
other sources of these contaminants exist within tha Cochato
River watershed.
.
Concentrations of contaminants in sediment were qenerally hiqheSt
in the surface samples and decreased with increasing depth. Thi~
finding indicates that sediment transport is the predominant
mechanism for contaminant transport. An additional explanation
of the decrease in contaminant concentration with depth may be
that total organic carbon (TOC) content qenerally decreases with
depth. Chlordane was an exception to the qene~al trend in that
the maximum concentration of chlordane was detected in the 12 -
18 inch depth interval and not in the surficicLl-sample. The
higher volatility and solubility of chlordane relative to DOT may
account,- in part, for the increased concentration at depth. The
hiqher chlordane concentration at depth may also hava resulted
from episodic storm deposition of chlordane-contaminated sediment
and may be related to the time, location, and method of disposal
at the Baird' MCGuire property. Relatively hiqh base/neutral
concentrations were detected in the 12 - 18 inch depth interval,
located within the base/neutral groundwater plume. .
~
. 2.
Surface Water
~-
Surface water samples were collected from the C~chato River at
seven locations upstream and downstream from th\! Baird' MCGuire
property. For each location, vnfiltered surface water was
analyzed for TCL organics and metals, and nine general water
quality parameters. Filtered surface water samples from each
location were analyzed for TCL semi-volatile organics,
pesticides, and metals.
-------
Arsenic was not detected in any of the surface water samples. No
organic compounds were detected in any of the surface water
samples, with the exception of one low phthalate concentration
present in one filtered surface water sample. This phthalate is
believed to have been introduced during filtering of the sample.
The lack of contamination detected in surface water at non-storm
flows is probably ralated to the low total suspended solids
concentration of the surface water at those flows (less than 10
millig~ams per liter (mg/l or parts per million).
3.
Groundwater
Nine groundwater samples were collected from existing seepage
meters and wells adjacent to the Cochato River to obtain an
understanding of groundwater contaminant loadings to the river.
The groundwater plume identified in the Phase I and II RIs (for
the 1986 ROD) continues to serve as a source of inorganic and
orqanic contamination from the Baird & McGuire property to the
Cochato River. Arsenic (up to 3,090 micrograms per liter (ug/l
or parts per billion), VOCs (up to 6,200 ug/l), base/neutral
organic compounds (up to 8,245 ug/l), and pesticides (up to 56 r
ug/l) were detected in various groundwater samples. Estimated
maximum groundwater discharge from the contaminant plume to the
CochatoRiver is about 0.03 cubic teet per second (cfs), and.
probably represents less than one percent of the averaqe river
flow. Any groundwater contaminants entering the river undergo
significant dilution.
A complete discussion of Site characteristics can be found in the
Focused Feasibility Study at pages 1-7 through 1-17.
VI.
SUMMARY O. SITS RISKS.
A Risk Assessment (ItA) was performed to estimate the probability
and magnitude of po~entialadverse human health and environmental
effects from exposure to contaminants associated with the Site. .
Four (4) contaminan.ts of concern, listed in Table 1, were
selected for evalu~tion in the RA. These contaminants constitute
a representative subset of the contaminants identified in the
sediments during the FFS that represent the majority of the risk
to. public health and the environment. The four contaminants were
selected to represent potential on-Site hazards based on
toxicity, concentration, frequency of detection, and mobility and
persistence in the environment.
-------
All 102 contaminants originally evaluated in the baseline Risk
Assessment conducted tor the Site were re-evaluated during the
selection ot contaminants ot concern for the Cochato River FFS.
Leve-Is ot arsenic, DDT, chlordane, and carcinogenic PAHs at the
Site were associated with elevated carcinogenic public health
risks. Noncarcinogenic compounds were also detected at the Site,
but below concentrations considered to present a public health
risk. Selected noncarcinogenic compounds, such as lead, were
quantitatively evaluated durinq the selection ot the contaminants
.of concern. Examination of historical data, in addition to the
samplinq undertaken as a part of the FFS, did not indicate the
presence of noncarcinoqenic compounds in excess of appropriate
health-based criteria. Therefore, noncarcinoqenic effects were
not evaluated further in the RA.
Potential human health effects associated with the contaminants
ot concern in sediments were estimated quantitatively throuqh the
development of hypothetical exposure scenarios. Incremental
lifetime cancer risks and a measure of the potential tor
noncarcinoqenic adverse health effects were estimated for the
various exposure scenarios. Conservative exposure scenarios were
developed to reflect the potentiaL for exposure to hazardous
substances based on the characteristic uses. and location of the
Site. A factor of note that is reflected in the public health ~
is the. assumption that a child would come in contact with the
contaminated sediments 30 times per year over ~ 10-year exposure
duration. For the ecoloqical risk assessment, benthic samplinq
was included in a bioloqical survey that was conducted as a part
at' the FFS.
The RA conducted as a part of this FFS is a supplement to the
baseline RA conducted for the Site as a part of the 1986 ROD.
The original baseline RA considered exposure to: groundwater;
muck (Cochaco River sediment); fish; surface water via drinkinq
and swimming; and dry soils.
A~
Public ..alth Risk Ass.ssm.nt.
The FFS study area ditters from the original Site study area.
Th& FFS stu(ly'area extends upstream and downstream of the Baird &
McGuire property, and it is limited to Cochato River surface
water and s~diment. Further, only the 4 contaminants ot' concern
(arsenic, PAKs, DOT and metabolites, and chlordane) were examined
under this RA. Since surface water samplinq did not identify any
detectable concentrations of contaminants, exposure to surface
water was not evaluated in the RA. Only risks associated with
direct contact exposure to sediments were evaluated.
-5 -6 d
cumulative risk estimates range between 3 x 10 and 5 x 10 an
are assnciated with direct contact exposure to sediments. These
risk es\:imates fall within EPA's tarqet risk range, and sliqhtly
-------
- - \
\' \\
,
exceed the Massachusetts Contingency Plan (MCP) risk level of
1 x 10.5. No significant risks are associated with exposure to
surface water.
Re~er to Table 1 for the Public Health Risk summary. Further
information regarding the public health risk assessment is- in the
Focused Feasibility study at pages 1-18 throug~ 1-2~.
B.
Ecological Risk Assessment
The original baseline RA did not include identification of
aquatic invertebrate organisms in the Cochato River or its
associated wetlands or lakes. The FFS included benthic sampling
during a biological survey that was conducted during the study.
Interim Sediment .Quality Criteria (SQC) are available for DDr and
selected PAHs. Mean site-specific SQC were calculated and
normalized to the organic carbon content (TOC}.
Bioassays were performed with sediment and ~ species of aquati~
teat animals to determine, the potential toxicity of the river
sediment. Sediment in. the vicinity of where the unnamed- brook.
feeds into the Cochato.River was found to be acutely toxic to r
aquatic fauna. Toxicity of sediment from this, area to bioassay
'organisms is believed to be. associated with DOT.
Based on the physical ana chemical characteristics of the
sediment, arsenic levels are not significantly bioavailable at
most locations and appear to pose little long-term risk to the
resident biota. .
Based on the degree of exceedance of the SQC, chlordane poses the
greatest risk for aqu~tic fauna in the Cochato River where it was
detected. CDr is the 'most widespread contaminant of concern.
The greatest exceedances of the respective SQC more often occur
in the top layer of sediment, where exposure is most likely..
A. complete discussion ~of. the ecological site risks- can be found,
in the Focused Feasibility Study at pages- 1-24 through 1-58~
VII.
DOCUKBRTATI0W OP 8IGHIPICAHT CBAHGK
EPA adopted a proposed plan (preferred alternative) for
remediation of the site on June 12, 1989. The preferred
alternative included.the following major provisions: .
-------
Excavation of approximately 1,200 cubic yards of
contaminated sediments; and.
Treatment of the excavated sediments utilizinq the on-Site
incinerator.
The decision set forth in this document is similar t~ the
proposed plan, with several minor changes and one significant
change. The minor changes include the following items:
The addition of a small area for excavation adjacent to the
original area delineated for excavation, increasing the
excavation volume by approximately 300 cubic yards, for a
total of 1,500 cubic yards of sediments to be excavated;
The addition of. downstream monitoring durinq sediment
excavation, the details of. which will be addressed durinq
remedial desiqn; and
The addition of bacldillinq (with clean' organic material)
that portion of the river bed in the vicinity or the
groundwater plume discharge to the r1-ver.
The Aqency has..decided to include the excavation of the 300 cubip
yards of sediment (from sample area 5D-116) in the extent of .
excavation. Although the contaminant levels in this area do not
exceed the public health target levels, the low level or organic
carbon content (TOC) indicates that contaminants are not as
l.ikely to be bound. to the. sediment, and therefore are more likely
to be available to organisms and pose an environmental risk. In
addition, this area is contiquous with the area targeted tor
public health remediation, so the additional costs associated'
with this volume increase are relatively small.
The Aqency doas no~ consider the addition of approximately 300
cubic yards ot sediment excavation and incineration to be a
significant change. The total sediment volume to be excavated
and. treated tQr this operable unit (1,500 cubic yards) comprises
approximately l' of the volume of soil to be excavated and
treated as a part ot the overall Site remediation.
However, tha ~ddition of the long-term downstream monitoring is
considered to be a significant change because it represents a
modification of the proposed alternative. The addition of long-
term monitorjnq of downstream portions of the Cochato River that
will not havo sediments excavated increases the overall remedy
costs by approximately $338,000. This addition to the remedy is
a.logical outgrowth of the proposed source remedy, and it has
been added in response to comments by the Department ot
Environmental Protection and other members of the public.
.
-------
VIII. ,
DBVBLOPMBN'l' A1ID SCREBNING 01' ALTERNATIVES
A.
statutory Requirements/Response Objective.
Prior to the passage of the Superfund Amendments and
Reauthorization Act of 1986 (SARA), actions taken in response to
releases of hazardous substances were conducted in accordance
with CERCLA, as enacted in 1980, and the revised National Oil and
Hazardous Substances Pollution Contingency Plan (NCP), 40 CFR
Part 300 (1988), promulgated in the Federal Register on November
20, 1985. Although EPA proposed revisions on December 21, 1988
to the NCP to reflect SARA, until those proposed revisions are
finalized, the procedures and standards for responding to
releases or hazardous substances, pollutants and contaminants,
shall be in accordance with Section 121 of CERCLA and to the
maximum extent practicable, the current NCP.
Under its leqal authorities; EPA's primary respons!bi1ity at
Superfund sites is to undertake remedial actions that are
protective of human health'and the environment. In addition,
Section 121 of CERCLA establishes several other statutory .
requirements and preferences, including: a requirement that EPAJfs
remedial action, when complete, must comply with applicable or
relevant and appropriate environmentalstandarcfs established
under federal and state environmental laws unless a statutory
waiver is grantedr a requirement that EPA select a remedial
action that is cost-effective and that utilizes permanent
solutions and alternative treatment technologies or resource
recovery technologies to the maximum extent practicable: and a
statutory preference for remedies that permanently and sig-
nificantly reduce the volume, toxicity or mobility of hazardous
wastes over remedies that do not achieve such results through
treatment. Response alternatives were developed to be consistent
with these congressional mandates.
A number of potential exposure pathways were analyzed for risk
and threats'to public health and the environment in the Risk,
Assessment. Guidelines in the Superfund Public Health Evaluation
Manual (EPA, 1986) regarding development of design goals and risk
analyses for remedial alternatives were used to assist EPA in the
development of response actions. As a result of these,
assessments, remedial response objectives were developed to
mitigate existing and future threats to public health and the
'environment. These response objectives are:
Reduce human exposure to arsenic, DDT, PARs, and chlordane
in sediment to concentrations corresponding to a 1 x 10.5 to
1 X 10.6 excess cancer risk level: and
-------
Reduce environmental exposure to the same 4 contaminants of
concern to concentrations corresponding to the mean SQC in
the river bed, and to the upper bound SQC in the wetland
area north of Ica Pond.
Sediment Quality Criteria (sQC) are theoretically derived
numerical standards for sediment contaminant concentrations that
are considered to be protective of aquatic life and its uses.
SQC, including mean and upper bound values, ar& explained in
detail on pages 1-46 and 1-47 and in Appendix A of the FFS.
B.
T8chnoloqy and Alternative Development and Screeninq
CERCLA, the NCP, and EPA guidance documents including, "Guidance:
on Feasibility S1::udies Under CERCLA" dated June 1985, and the
"Interim Guidance on Superfund Selection of Remedy" [EPA Office
of Solid Waste and Emergency Response (OSWER»), Directive No.
9355.0-19 (December 24, 1986), and the Interim Pinal "Guidance
for Conducting RIs and FSs under CERCLA," OSWER Directive No.
9355.3-01 (October 1988), set forth the process by which remedial
actions are eva~uated and selected. In accordance with these.
requirements and guidance documents, a range of treatment r
alternatives, a containment option involving little or no
treatment, and a no-action alternative where developed for the
Site.
Section 121(b) (1) of CERCLA presents several factors that at a
minimum EPA is required to consider in its assessment of
alternatives. In addition to these factors and the other.
statutory directives of Section 121, the evaluation and selection
process was guided by the EPA document "Additional Interim
Guidance for FY '87 Records of Decision" dated July 24, 1987.
This document provides direction on the consideration of SARA
cleanup standards and sets forth nine factors that EPA should
consider in its evaluation and selection of remedial actions.
The.nine factors are:
1.
Compliance with Applicable or Relevant and Appropriate
Requirements (ARARs).
Long-term Effectiveness and Permanence.
2.
3.
Reduction of Toxicity, Mobility or Volume.
Short-term Effectiveness.
4.
5.
Implementability.
Community Acceptance.
6.
-------
7.
state Acceptance.
Cost.
, 8.
9.
Overall Protection of' Human Health and the Environment.
Chapter 4 of the Focused Feasibility study identified, assessed
and screened technologies based on screening criteria such as
engineering feasibility, implementability, effectiveness,
technical reliability, and cost. Refer to Table 2 for a
technoloqy screening summary, as well as an explanation of any
site-limiting or waste-limiting characteristics.
These technologies were combined into alternatives. Chapter 5 in
the Focused Feasibility study presented tha 14 remedia~
alternatives developed by cOmbininq the technoloqies identified
in the previous screening process in the categories required by
OSWER Directive No. 9355.0-19. The purpose of the initial
screening was to narrow the number of potential remedial actions
for further detailed analysis while preserving a range of
options. Each alternative was then evaluated and screened in
Chapter 6 of the Focused Feasibility study. In summary, of the
14 remedial alternatives screened in Chapter 6, six (6) were r
retained for detailed analysis. Table 3 identities the six (6)
alternatives that were retained through ,the screening process, as '
well as those that were eliminated from further consideration.
Fiqure 2 presents tor each alternative the reasons why either the
alternative was retained for detailed analysis or screened out.
IX~
DESCRIPTION/SUMMARY OP TBBDETAILED AND COMPARATIVE
ANALYSIS OP ALTBRNATIVES
This section presents a narrative summary and brief evaluation of
each alternative according to the evaluation criteria described'
above.' A detailed tabular assessment of each alternative can be
found in Chapter 7 of the Focused Feasibility study.
The alternat~ves analyzed for the site include a no action
alternative (NR-l); institutional action (NR-2); in-situ capping
(NR-3); and three removal alternatives with varying levels of
treatment (R-l, R-2, R-3).
To address the additional items that are discussed in section VII
of this ROD, the cost estimates for only the three removal
alternatives have been revised upward to include these items.
Although some of these additional costs (e.g., long term monitor-
ing of downstream portions of the river) would be incurred by the
public health remediation under Alternatives NR~2 and NR-3, these
-------
non-removal cost estimates have not been adjusted from the FFS
estimates. Since cost-effectiveness is examined only amonq
equally protective remedies, the revised costs for the three
removal alternatives only are presented in Table 11.
The additional costs for public health remediation for the three
removal alternatives include the followinq items:
..
An additional 300 cubic yards of sediment for treatment
and/or disposal and residuals management, for the total of
1,500 cubic yards;
The addition of downstream monitoring during excavation;
The addition of approximately 200 cubic yards of clean
backfill material for that portion of the river bed in the
vicinity of ~e groundwater plume discharqe to the river;
and,
The addition of lonq term monitoring of downstream portions
of the Cochato River that will not have sediments excavated.
A.
Hon-a_oval (D) Alternatives
.
r
Alternative 0-1: Ho Action
Analysis of the No Action alternative is required by federal law
and is included for comparison with other alternatives. In this
alternative, no treatment of contaminated sediments would be
conducted. In addition, no institutional controls would be
implemented to reduce the potential for exposure to sediments.
The possibility of further downstream contamination ot sediments
would remain. Because contaminants would remain, reviews of the
Site would be required every five years to determine if risks to
public health and the environment have chanqed.
.
The No Action alternative would not be protective of public
health and the environment. No reductions in the toxicity,
mObility, or volume of Site contaminants would be achieved.
Estimated Five-Year Review Costs: $28,000
Estimated Total Cost [Net Present Worth (NPW)J: $28,000
..
Alternative 0-2: Institutional Action
In this alternative, no treatment of contaminants would occur,
but institutional controls would be implemented to restrict
future Site use and development. These activities would include:
-------
conducting a public education program to inform citizens 'of the
risks associated with the Site: installing Site fencing and
warning signs along the river where contact with sediments would
pose a risk to public health: implementing deed and land
restrictions: monitoring sediment and water quality yearly: and
performing Site reviews every five years. The potential for
further downstream movement of contaminated sediment would
remain.
Alternative NR-2 would provide short- and long-term protection of
public health by limiting direct contact with contaminated
sediments, but would not be protective of the environment because
contact with contaminated sediments by area biota would not be
eliminated. This alternative would not meet EPA's cleanup goals:
there would be no reduction of toxicity, mobility or volume of
contaminants and ARARs would not be met.
Estimated
Estimated
Estimated
Xstimated
Estimated
Period Qf Operation: 30 years
Construction Cost: $88,000
Five-Year Review Cost: $56,000
Operation and Maintenance. Costs
Total Cost (NPW): $628,00\
(NPW): $484,000
.
r
Alternative HR-3: In-situ Containment
In this ,alternative, contaminated sediments in the Cochato River
and adjacent wetlands would be covered in-place (in-situ), with a
mUlti-layer cap to prevent contact with contaminated sediments.
The cap would be constructed of a p&rmeable synthetic material
covered with stones that would allow groundwater and surface
water flow to pass though, but would prevent sediment movement
. and contact. Because the identified potential risks are
different for public health than for the environment, EPA has
identified a different level of response to address each
potential risk. In order to protect public health, the cap would
have to extend downstream from the Site to where the river is
crossed by Union Street. To be protective of the environment,
the cap would have to continue downstream t~ beyond the Mary Lee
Wetlands. Both the Ice Pond and the Mary Lee Wetlands would be
capped to address potential long-term environmental risk.
In implementing this alternative, vegetation would be removed for
fifteen feet from each side of the river (and pond and wetland
areas) to construct permanent roadways that would be required to
allow placement and maintenance of the cap. An extensive
wetlands replication program, which would be determined during
the remedial design phase of the cleanup, would be included in
this alternative to compensate for the extensive destruction of
-------
wetlands that would occur. This proqram would require extensive
cooperation from local, state and Federal aqencies.
Alternative NR-3 would not reduce the mObility, toxicity or
volume ot Site contaminants because no treatment would occur.
This alternative would be effective in protectinq public health
and the environment over the short- and lonq-term, because
contact with contaminants would be prevented. However, extensive
destruction of wetlands and the river-bottom environment would
result from the cappinq operation. Cappinq would not comply w~th
EPA's preference tor a permanent remedy. This alternative would
require Site reviews every five years.
Estimated
Estimated
Estimated
Time for Construction: 6 months
Period ot Operation: 30 years
Construction Cost: Public health - $145,000
. Environmental risk - $2,318,000
Five-Year Review Cost: $56,000 .
Operation and Maintenance Costs (NPW):
Public health - $560,000
Environmental risk - $870,000
Public health - $761,000
Environmental risk - $3,244,000
Estimated
Estimated
Estimated Total Cost (NPW):
.
r
B.
Removal (R) Alternative.
Three alternatives requirinq excavation ot contaminated Cochato
River. sediments were retained by EPA tor final evaluation.
Secause the identified potential risks are different for public
health than for the environment.. I:PA has identified a different
level of response to address each potential risk, in a 'manner
similar to that for AlternativeNR-3 above. To protect public
health, approximately 1,500 cubic yards ot se~iment would be
excavated to a depth of 6 inches And treated. To address the
risk to biota livinq in Cochato River, EPA would excavate
sediments to different depths dependinq upon the area ot the
river and the depth at which the contaminants are found.
Approximately 18,600 cubic yards of sediment would be excavated
to address environmental risk, in addition to the 1,500 cubic
yards that would be excavated to address public health. The cost
estimates in this ROD for pUblic health risks address 1,500 cubic
yards of sedimenti the estimates for environmental risks address
the total volume ot approximately 20,100 cubic yards ot sediment.
A detailed explauation of the excavation activities common to all
three removal alternatives is presented on paqes 7-45 throuqh
7-50 ot the Focused Feasibility study.
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Alternative R-1:
Removal and ott-Site Disposal
In this alternative, contaminated sediments would. ba excavated
and transported off-site to a federally-approved hazardous waste
landfill. The sediments wouJ.d be dewatered prior to shippinq,
and the extracted water would be treated at the on-Site water
treatment system to remove contaminants prior to discharge.
Specially-designed trucks would be used to prevent the release of
contaminated sediments during shipping.
This alternative would significantly reduce potential risks to
public health and would address' environmental risks. However,
because there would be no treatment of contaminants, no reduction
in toxicity, mobility or volume of the contaminants would result.
Oft-site disposal without treatment is considered a least favored
action under the Superfund law. This alternative would. be
difficult to implement because of the limited landfill capacity
available to dispose of hazardous waste.
Estimated Time for Construction: 6 months
Estimated Total Cost (NPW):. Public health - $1,822,000
Environmental' risk - $18,220,000
.
r
Altenative. R-2: Removal and Incineration
This alternative has been chosen as the preferred alternative for
addressinq Cochato River sediment contamination. ~ee pages 2Q
through 26 for a discussion of the selectea remedy.
Alternative R-3: Removal and Solvent ~ztraction
This alternative would involve the removal of contaminated
sediments, dewatering, and treatment by asoivent extraction
process. In sol vent extraction., contaminated sediments are mixed
in a closed container with a solvent that separ.ates contaminants
from the sediments, leaving clean soil and a sOlvent/contaminant.
This mixture is then heated ,to separate the soJ~ent from the
contaminants. An additional treatment process would be used to
separate arsenic from the organic contaminants. The concentrated
organic contaminants would be destroyed in th&on-Site
incinerator that would be used to treat sedimsnts. Arsenic would
be taken off-site for treatment at a federally-approved facility.
This alternative would achieve a reduction in toxicity, mobility
and volume of contaminants and would comply with ARARs. This
alternative would be protective of public health and the
environment, .though the dredging would result in damage to
wetlands and the river bottom environment. Solvent extraction is
-------
an innovative technology, but it has not been proven effective
for all of the contaminants found at the Site. Separate tests on
Cochato River sediments would be required to develop the most
effective use of this technology. Additionally, this technology
would require the use of equipment on-Site (in addition to the
on-Site incinerator already undergoing "testing and design for the
second operable unit) with associated mobilization capital costs,
thereby making this alternative more ex~ensive than the removal
and incineration (R-2) alternative.
..
Estimated Time for Construction: 6 months
Estimated Total Cost (NPW): Public health - $2,449,000
Environmental risk - $16,291,000
x.
THB SELECTED REMEDY
As anticipated in the "Future Action" section of the 1986 ROD for
the Baird & McGuire Site, this (third) operable unit addresses
sediment contamination in the Cochato River attributable to the
Baird & McGuire Site. As such, this remedy consists of a source
control component only, since only the Cochato River sediments.
are addressed in this operable unit. r
A.
Description of the Selected Remedy
1.
Remedial Action Obiectives/CleanuD Goals
The selected remedy was developed to satisfy the following
remedial objectives, which will guide the design of the remedy
and will be used to measure the success of the remedy. The
objectives include: .
R_duce human exposure to arsenic, DOT, PARs, and chlordane
in sediment by excavating to an av~rage depth of six (6)
inches and by achievinq the follow.Lnq levels of
contaminants: 250 ppm for arsenic: 19 ppm for DOT: 5 ppm for
chlordane: and 22 ppm ~or PARs. T~ese concentrations
correspond to a 1 x 10. to 1 x 10.'" excess cancer risk
leve~: and
Reduce environmental exposure to ~he same 4 contaminants of
concern to concertrations corresponding to the mean SQC in
the river bed, and to the upper bound SQC in the wetland
area north of Ice Pond.
-------
These' objectives for sediment cleanup levels were then translated
into Site-specific cleanup levels on the basis of public health
and environmental protection. (Refer to Section VI of this- ROD,
the summary of Site risks, for a discussion of the assumptions
that were used for estimating public health and environmental
risks.) Refer to Table 4 for the public health tarqet levels for
the 4 contaminants of concern, and to Table 5 for the Site-
specific target levels for environmental risk. Figure 3 depicts
the areal extent of these two remediation areas based on the
public health and the environmental target levels.
While the target leve~s derived for protection of public health
are based on a 1 x 10' excess cancer risk level, the remediation
will actually achieve a greater level of protection for three of
the four contaminants of concern. For the contaminants arsenic,
DCT and metabolites and chlordane, a 1 x 10'6 excess cancer risk
level will be achieved by the remediation. These levels are
250 ppm for arsenic; 19 ppm for DCT, and 5 ppm for chlordane.
The only contaminant of concern that will achieve the 1 x 10.5
level is PARs, which are found widely throughout the Cochato
River dr~inage basin. It is likely, however, that natural -
degradative, depositional, and dispersal processes will gradually
reduce contaminant concentrations in the sediment without r
engineering measures being taken. The rate at which these
natural processes will occur is difficult to quantify. However,
sampling in the areas of excavation, in conjunction with long
term monitoring of downstream portions of the Cochato River that
will not have sediments excavated, will confirm theiremaining
contaminant levels and their behavior over time.
2.
DescriDtion of Remedial ComDonents
After evaluating all of the feasible alternatives using the nine
criteria for remedy selection, EPA has selected Alternative R-2
to addres~ the contaminated Cochato River sediments for
protection of public health. Because the potential public health'
and envirl)nmental risk areas differ from each other, EPA examined
the level of response required to address each potential risk.
For protection of public health, sediments will be excavated to
an average 'depth of six inches from the area where the unnamed
brook joins the Cochato River (approximately the center of the
fenced Site area), downstream to approximately where the river
crosses Union Street. Approximately 1,500 cubic yards of
sediments will be excavated and treated. The environmental risks
in this area will also be addressed by the sediment excavation.
Refer to Figure 4 for a conceptual Site layout for public health
risk ~emediation. .
-------
This alternative will involve removing the sediments using a
mechanical dredge, and then incinerating the sediments using a
rotary kiln incinerator. An incinerator ot this type will be
operating on the Site as part of the overall remedial action
currently being desiqned to address soil contamination, as
stipulated in the 1986 ROD for the second operable unit for the
Site. The incinerator will utilize Best Available Control
Technoloqy, such as air Scrubbers, and it will be monitored to
control air emissions during operation.
Contaminated sediments will be removed using a mechanical
excavator. Temporary gravel access roads will be constructed
along one side of the river to enable the equipment to reach the
contaminated areas. Since the need .for excavation access roads
will involve disruption of the wetland .areas adjacent to the
river in certain areas, wetlands restoration will be conducted in
these disrupted areas once construction is complete.
Approximately 200,cubic yards of clean backfill will be placed in
the excavated portion of the river bed where the groundwater
plume discharges to the Cochato River.
"
Since sediments may become resuspended in the river during
excavation operations, silt curtains will be placed in the river
downstream prior to the initiation ot excavation. These silt r
curtains will trap suspended sediments and minimize the
possibility ot downstream transport. Any sediments trapped in
the silt curtains will be incinerated with the excavated
sediments. Remedial design will address the details of the silt
curtains and will examine any other type ot controls that may be
appropriate during construction.
The excavated sediments will be placed in specially designed
containers and trucked to the on-Site incinerator for treatment.
All trucks will be decontaminated prior to returning to the
e~cavation area for additional sediment. Prior to incineration,
excess water in the excavated sediments will be reduced using a
b~lt tilter press to improve the efficiency of the incinerator.
The extracted water trom the sediments will be treated by the on-
S~te groundwater treatment plant prior to discharge.
EJ~ is currently testinq on-Site 80i1s at EPA's Office of
Rf!search and Development tacility in Arkansas to verify the
e1~fectiveness ot the incineration process for destroying the
or.ganic contamination particular to the Baird & McGuire Site.
The treated soil will be tested to determine if any further
treatment is required to prevent migration of any contaminants
remaining in the treated material, particularly arsenic. EPA
will determine if the treated sediment is subject to the Land
Disposal Restrictions ot the Resource Conservation and Recovery
Act (RCRA). It EPA determines that the ~reated sediment is
subject to such restrictions, the treated material will be
managed in accordance with such restrictions. Treated sediment
-------
will be placed on-Site with the other treated on-Site soils, once
it has been tested to ensure the material is suitable for
backfill.
Long term monitoring of downstream portions of the Cochato River
that will not have sediments excavated will be conducted. See
the following subsection on the evaluation of wetland remediation
for potential environmental impacts for further discussion.
The estimated time of operation of 6 months does not include the
time requ'ired for items such as remedial design and contract
bidding and award.
Removal of the sediments will result in some environmental
degradation of area wetlands, but the extent of these areas are
limited, and overall short and long term protection of the
environment will be met. This alternative will permanently
reduce the toxicity, mobility and volume of the waste, and it
will comply with "ARARs. Controls will be implemented to protect
site workers during excavation and treatment activities. .
Incineration is a proven technology that has been used
successfully at a number of hazardous waste sites.
Estimated Time of Operation:
Estimated Construction Cost:
Estimated Total Cost:
6 months
Public Health - $1,656,000
Public Health - $t,656,000
.
r
3.
Evaluation of Wetland Remediation for
Potential Environmental ImDacts
Because of the sensitivity of aquatic organisms to the Site
contaminants, a much larger area of the Cochato River,' as well as
associated ponds and wetlands, would require remediation to
completely oliminate the potential long-term'risks to aquatic
organisms in the river. To address the potential risk to biota
living. in the Cochato River, sediments would be excavated to
different depths. Remediation for potential chronic
environment~l impacts would extend from the Baird & McGuire
property, past Union street, to approximately 1/3 of a mile
downstream ~f the Ice Pond, including the Mary Lee Wetland.
Approximately an additional 18,600 cubic yards of sediment would
be excavated and treated to address these potential chronic risks
to biota. .
In the course of evaluating the cleanup alternatives for these
downstream sediments, the EPA assessed whether or not the adverse
environmental impacts associated with the excavation of these
areas wCluld be greater than the benefits of removing contaminated
sediments. These downstream areas include forested and shrub .
-------
3.
4.
swamp. Without complete remediation of these areas, the
potential exists for a: long-term threat to the organisms that
inhabit the area. However, excavation of these downstream
contaminated sediments for treatment would require extensive
clearing and grubbing operations, which would disrupt the habitat
and feeding grounds. of a wide variety of wildlife in the area.
EPA considered the advantages and disadvantages of the options
for remediation of these downstream sediments. EPA believes that
the benefits obtained by excavating the additional 18,600 cubic
yards of sediments are outweighed by the adverse environmental
impacts associated with extremely disruptive excavation.
Therefore, the EPA has decided that no action shall be taken for
the sediments beyond Union street for the protection of long term
environmental risks in this area.
EPA believes that there are a number of reasons that remediation
of these downstream areas is not warranted.
1.
The levels of contamination downstream of Union Street are
distinctly lower than those near the Baird & MCGuire
property.
2..
.
Excavation of these areas is predicated on theoretical r
predictions of chronic, sublethal impacts to biota (Sediment
Quality Criteria; SQC). Limitations of the SQC, including
the inability to describe cause and effect relationships for
specific chemicals, contribute to the theoretical nature of
the values. Additionally, observation of the current
wetland characteristics and biota population indicate that
there are no observed adverse impacts in these downstream
areas to date.
.
Remediation of these downstream areas, particularly the Mary
Lee Wetlands, would entail serious known adverse
environmental impacts. While the Agenc~ recognizes the use
of SQC on a site-specific basis as a useful tool, for this
Site the known adverse impacts from excavation outweigh .the
theoretical impacts predicted by the SQC.
There are other sources ot contamination in the Cochato
River drainage basin. The Cochato River is an urban basin
with a variety of point and non-point sources of
contamination, and tributary sampling indicates a number of
contaminants exist in the area that are not attributable to .
the Baird & McGuire Site.
Therefore, since no action will be taken in these downstream
areas, EPA will include long term monitoring of these areas on an
annual basis. To the extent required by law, EPA will review
this monitoring data at least once every five years to assure
that the remedial action continues to protect public health. EPA
-------
will also evaluate the risk posed by the Site at the completion
of the overall Site remedial action (i.e., before the Site is
proposed for deletion from the NPL).
B.
R.~ioD.l. for S.lec~ioD
The rationale for choosing the selected alternative is based on
the assessment of each criteria listed in the evaluation of
alternatives section of this document. In accordance with
Section 121 of CERCLA, to be considered as a candidate for
selection in the ROD, the alternative must have been found to be
protective of human health and the environment and able to attain
ARARs unless a waiver is granted. In assessing the alternatives
that met these statutory requirements,' EPA focused on the other
evaluation crite~ia, including short term effectiveness, long
term effectiveness, implementability, use of treatment to
permanently reduce the mobility, toxicity and volume, and cost.
EPA also considered nontechnical factors that affect the
implementability of a remedy,' such as state and community.
acceptance. The State and the Baird & McGuire Task Force have.
indicated their acceptance of the remedy. Both the State and the
Task Force requested that additional monitoring be conducted as a
part of the overall remedy, and this provision has been added to
the selected remedial alternative. Other community concerns are
focused on the operation of the incinerator. EPA believes these
concerns are addressed by specifying compliance with the RCRA .
incinerator standards, as well requiring air monitoring to ensure
that all federal and state air standards are attained. Based
upon this assessment, taking into account the statutory
preferences of CERCLA, EPA has selected the remedial approach for
the Site.
Table 6 presents a comparative summary of the six remedial
alternatives that were carried through detailed analysis. Of the
six alternatives, NR-l, NR-2, and NR-3 do not attain ARARs, and
also do not satisfy CERCLA's preference for permanent remedies.
Of the three. (removal) alternatives which attain ARARs, all three
alternatives are similar in terms of short-term effectiveness.
Regardinq long-term effectiveness, the reliability of the solvent
extraction technology (Alternative R-3) is uncertain for the
variety of Baird & McGuire Site contaminants. Both Alternatives
R-2 and R-3 .are more likely to have residual on-Site risk than
Alternative R-l; however, these two alternatives are much more
effective than Alternative R~l in the reduction of 'mobility, .
toxicity, or volume of the contaminants. Regarding .
implementability, Alternative R-3 is unproven on the Baird & .
McGuire Site contaminants and would require treatability testing;
also, Alternative R-l would require transportation of saturated
-------
sediments over long distances and disposal permits for off-sit~ .
RCRA landfilling. Of the three alternatives, R-2 is less
expensive than either Alternatives R-l or R-J.
While all three removal alternatives satisfy ARARs, the off-site
land disposal without treatment. in Alternative R-l is the least
favored remedial action under CERCLA. The State and the
community, through its public comments, have indicated general
agreement with the selection of Alternative R-2, and the State
has concurred with the selection of Alternative R-2 as the
remedial action for this operable unit.
Incineration is a demonstrated treatment technology, while the
fUll-scale reliability of solvent extraction is uncertain for the
variety of contaminants found at the Baird & MCGuire Site..
Additionally, since the second.operable unit for the Site, calls.
for on-Site incineration, Alternative R-2 benefits from the
ongoinq testing and capital equipment costs that will be borne by
that phase of activity. Alternative R-J would require additional
testing and capital equipment expenditure, thereby makinq .
Alternative R-2 more cost effective. The additional equipment
and resultant space required tor the operation ot a solvent
extraction unit would have to compete with the incinerator for.
:limited space on-Site in which to operate. r
Therefore, ror the reasons stated above, EPA believes that
Alternative R-2, the selected remedy, is the best balance among;
the nine criteria that were used to evaluate allot the
alternatives.
ZI.
STATUTORY DETERMINATIONS
The remedial action selected for implementation at the Baird &
McGuire Site/cochato River Sediments is consistent with CERCLA
and, to the extent practicable, the NCP. The selected remedy is
protective of human health and the environment, attains ARARs and
is cost etfective. The selected remedy also satisfies the.
statutory preference for a permanent solution and for treatment
which reduces the mObility, toxicity or volume as a principal
element.. Additionally, the selected remedy utilizes alternate.
treatment technologies to the maximum extent practicable..
A.
The Selected R..edy i. Protective ot HWlum H.altb and
tile EnviroDJIent
The selected remedy is protective of human health and the
environment. The remedy at this Site will permanently reduce the
risks presently posed to human health and the environme~.t by
26
-------
excavating and treating the contaminated sediments. Removing
sediments to an average depth of six inches will protect public
health, and the environmental risks in this area will also be
addressed.
EPA examined the sediment volume that would be associated with a
public health excess cancer risk level of 1 x 10.6. The sediment
volume would increase to approximately 7,325 cubic yards over a
two-mile reach of the Cochato River (volumes for tributaries are
not included), covering an area more extensive than that for
chronic environmental protection, due predominantly to the PAH
target cleanup level. Extensive wetland disruption would occur,
considering the discontinuous nature of the remediation areas.
Refer to Table 7 and the affiliated map for volume calculations.
While the target leve\s derived for protection ot public health
are based on a 1 x 10' cumulative excess cancer risk level, the
remediation will actually achieve a greater level of protection.
for three of the four contaminants of concern. For the
contaminants arsenic, DDT and metabolites and chlordane, a
1 x 10.6 excess risk level will be achieved by the. remediatio~.
The contaminant of concern that will achieve only the 1 x 10.
levei is PABs, which are. tound widely throughout the Cochato . .
River drainage basin. It is likely, however, that natural r
degradative, depositional, and dispersal processes will gradually
reduce contaminant concentrations in the sediment without
. engineering measures being taken. The rate at which these
natural processes will occur is difficult to quantify. However,
sampling in the areas ot excavation, in conjunction with long
tern monitoring ot downstream portions of the Cochato River that
will not have sediments excavated, will confirm the remaining
contaminant levels and their behavior over time.
Although environmental risks will be addressed by the excavation
of,sediments to approximately Union street, sediment downstream
of Union street will not be addressed. The four primary reasons
for the decision not to remediate areas downstream of Union
St~ee~ are as tollows:
",
2.
contamination levels downstream of Union street are
distinctly lower than those within 500 feet of the Baird &
McGuire property.
Excavation ot these areas is predicated on theoretical
predictions of chronic, sublethal 'impacts to biota (Sediment.
Quality criteria: SQC). Limitations of the SQC, including
the inability to describe cause and effect relationships for
specific chemicals, contribute to the theoretical nature of
the values. Additionally, observation of the current
wetland characteristics and biota population indicate that
there are no observed adverse impacts in these downstream
areas to date.
1.
-------
3.
Remediation of these downstream areas, particularly the Mary
Lee Wetlands, would entail serious known adverse
environmental impacts. While the Agency recognizes the use
of SQC on a site-specific basis as a useful tool, for this
Site the known adverse impacts from excavation outweigh the
theoretical impacts predicted by the SQC.
4.
There are other sources of contamination in the Cochato
River drainage basin. The Cochato River is an urban basin
with a variety of point and non-point sources of
contamination, and tributary samplinq indicates a number of
contaminants exist in the area that are not attributable. to
the Baird & McGuire Site.
Therefore, in an attempt to balance the need t~ remediate the
more severely contaminated zones of sediment contamination while
minimizinq damaqe.to the existinq environmental value of the
area, the Aqency has determined that excavation will extend only
to Union Street.
B.
The Select.4 R...4y Attains ARARs
.
r
The selected remedy will attain all federal or state requirements
that are applicable or relevant and appropriate. Environmental
laws which are applicable or relevant and appropriate to the
selected remedial action at the Baird & McGuire Site/cochato
River Sediments are:
Resource Conservation and Recovery Act (RCRA)
Clean Water Act (CWA)
Executive Order 11988 (Floodplain Manaqement) .
Executive Order 11990 (Protection of Wetlands)
Clean Air Act (CAA)
Occupational Safety and Heaith Act (OSHA)
310 CMR 30.00
310 om 6.00
-
Hazardous Waste Manaqement Requirements
Ambient Air Quality Standards for the
Commonwealth of Massachusetts
Air Pollution Control Requlations
Wetlands Protection Requirements
Employee and Community Riqht To Know
Requirements
Surface Water Quality Standards
Certification for Dredqinq and Fillinq
Inland Wetlands Orders
310 om 7.00
310 CMR 10.00
. 310 CMR 33.00
314 CMR 4.00
314 CMR 9.00
302 om 6.00
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Tables 8, 9, and 10, taken from Chapter 2 of the Focused
Feasibility study, list the potential chemical-, location-, and
action-specific ARARs, criteria, advisories, and guidance
identified in the FFS, respectively. Tables 8 and 9 indicate the
requirement and its status, a brief synopsis of the requirement,
and the consideration the requirement was given in the FFS.
o Table 10 lists the action-specific ARARs and a summary of the
requirement. Of those potential ARARs identified in the FFS, the
above-listed requirements are applicable or relevant and
appropriate to the selected remedial action. A brief narrative
summary of the ARARs for the selected remedy follows.
The Resource Conservation and Recovery Act (RCRA) and the State
Hazardous Waste Management Regulations (310 CMR 30.00) are
considered applicable to the Site. As such, the on-Site
incinerator will be required to operate in accordance with these
requirements. Additionally, remedial activities may be subject
to the Land Dispasal Restrictions under RCRA. EPA is currently
conducting tests of the treated material. If EPA determines that
the material is subject to these restrictions, the material will
be handled in accordance with these requirements, and further
treatment may be needed. If not, the treated material will be
used as backfill on the Site. .
.
Regarding the floodplains, the remedy will comply with Executiv~
Order 11988 - Protection of Floodplains. EPA finds that there is
no practicable alternative to excavation of the contaminated
sediments, some of which are, located in the floodplain, since it
o is the sediments themselves that are contaminated.
Implementation of the remedy will utilize measures to minimize
potential harm to the floodplain. However, excavation and
filling are temporary disruptions, and any filling will match
preconstruct ion topography. Thus, there will not be any
permanent disruption of the floodplain values.
Similarly for the wetlands, the remedy will qomply with Executive.
Order 11990 - Protection of Wetlands, the Clean Wa~er Act Section
404(b) (1) guidelines, and the state Surface Water Quality
Standards (314 CMR 4.00), wetland Protection Requirements (310
CMR 10.00), Inland Wetlands Orders (302 CMR 6.00) and
Certification for Dredge and F1ll (314 CMR 9.00). The Cochato
River sediments have been affected by the Site activities, and
they will be affected by the remedy. Because the river sediments
exceed the cleanup goals, these sediments will be excavated for
thermal treatment. EPA finds that there is no practicable
alternative to these actions since it is the sediments in the
river themselves that are contaminated. Implementation of the
remedy will ucilize measures to minimize potential harm to the
surrounding areas and wetlands. The backfill that will be placed
in the vicinity of the groundwater plume discharge to the river
will be placed at approximately a six-inch depth to approximate
the original contours of the river bed. Additionally, the area
-------
is expected to silt in quickly with the surrounding sediments.
Any till activity is considered to be in compliance with the
" Executive Order, and is a part of the restoration and preserva-
tion ot the beneficial values of wetlands and floodplains.
During excavation and treatment of contaminated sediments, air
emissions will be monitored and all relevant federal and state
standards will be attained. Specifically, the National Ambient
Air Quality Standards (NAAQS), and the State Ambient Air Quality
Requlations (310 CMR 6.00) and the Air POllution Control
Requlations (310 CMR 7.00) will be met through specified
techniques for the excavation activities, as well as required air
emission controls and monitoring for the incinerator, to ensure
that Site-specific ambient action levels are not exceeded.
During the excavation and treatment ot contaminated sediments,
Occupational Health and Safety Act (OSHA) requlations will be
followed, as well, as the Employee" and Community Right To Know
Requirements (310 CMR 33.00). In particular, 29 CFR 1910.120 of
OSHA specifies standards for handling hazardous wastes and 29 CFR
1910.1000 sets allowable ambient air concentrations for
activities which involve release of VOCs in the workplace. This
is not expected to be a problem during remediation, since the
sediments will be excavated while they are submerged and then r
brought to the Site for dewatering prior to incineration.
However, air monitoring will be conducted to ensure that
allowable levels are not exceeded.
c.
Th. 8.1ec~.d Remedial Ac~ioD is COS~-Bttec~iv.
The selected remedy is cost-effective. Once EPA has identified
alternatives that are protective and attain ~s, EPA analyzes
those alternatives to determine a cost-efficient means of
aChieving the cleanup.
. "
The-estimated cost ot e~cavation and incineration is cost
effective when compared with all of the Removal Alternatives, and
particularly Alternativ~ R-3, the one other (removal) alternative
that provides "an equivalent level ot protectiveness and attains
ARARs. The non-removal alternatives all are less protective than
Alternative R-2, since they do not adequately reduce the risks
posed to human health nnd the environment by the site.
Additionally, EPA believes that the remedy is cost effective due
to th~ tact that incineration will permanently destroy the
organic contamination. Future remedial action with associated
costs for the non-removal alternatives may be needed if the
contaminated sediments are left in the river.
-------
Further, since. the second operable unit.for the Site calls for
on-Site incineration, Alternative R-2 benefits from the onqoinq
testinq and capital equipment costs that will be borne by that
phase of activity. Alternative R-3 would require additional
testinq and capital equipment expenditure, thereby makinq
Alternative R-2 more cost effective.
The actual costs for on-site incineration are difficult to
estimate precisely. However, the $325 per cubic yard estimate is
within the ranqe provided by quidance and vendor quotes. Refer
to Table 11 for a comparison of the cost estimates for the
removal alternatives. Unit costs and supportinq calculations are
included in Appendix D of the FFS.
D.
The Selected Remedy utilizes Permanent Solutions
and Alternative Treatment Techno1oqies or Resource
Recovery Technoloqies to the Maximum Extent
Practica})le
The selected remedy utilizes permanent solutions and alternative
treatment technoloqies to the maximum extent practicable.
.
Incineration is a treatment technoloqy that will provide a r
permanent solution to the contaminated sediment problem in the.
Cochato River due to the Baird & McGuire Site. Excavation of the
top six inches of sediment and treatment by incineration will
reduce the risks posed to public health from direct contact with
contaminated sediments in this area, as well as addressing the
environmental risks in this area.
B.
Tbe Selected Remedy;Satisfies tbe Preference for
Treatment as a Principal Element
The remedy satisfies the statutory preference for treatment that
permanently and siqnificantly reduces the volume, toxicity or
mobility of the hazardous substances as a principal element.
The principal element of the selected remedy is the excavation
and on-site incineration of the contaminated sediments. This
element addresses the primary threat at the Site, contaminated
river sediments, by utilizing thermal treatment.
XII.
STATZ ROLB
The Massachusetts Department of. Environmental Protection (DEP)
has reviewed the various alternatives and has indicated its
support for the selected remedy. The State has also reviewed the
-------
Record ot Decision to determine if the selected remedy is in
compliance with applicable or relevant and appropriate State
environmental laws and requlations. The Commonwealth ot
Massachusetts concurs with the selected remedy for the Baird &
McGuire SitejCochato River Sediments. A copy of the declaration
of concurrence is attached as Appendix C. In accordance with
Section 104 of CERCLA, Massachusetts is responsible for 10
percent of the cost of the remedial action and for operation and
maintenance costs. In the case of the selected remedy, the
Commonwealth's share is estimated at approximately $165,000.
.
r
,.
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-------
~G OlP ALTZIIl'fATIft NR-l: NO ACTION
COCBATO RIVER II:I)Da:IIf'I' 1ft
IIADU) a IIc:GU1118 srm
BOUlllOOIE. "'''..0\111\1_11.
FIGURE 2
RIVER
DI'VDSIOl'f
Df4unrn01'fAL
AoCTIOl'f
Il'f. SITU
con AI1'fII:E1ft
NR.t No..ACTION
The no-action alternative involves no remedial or institutional action to treat contaminated sediment or
reduce the potential for expolure. A reassessment of site conditions would be conducted every five years.
r
EFFECTIVENESS
IMPLEMENTABILJTY
COST
Advantales
Advant.a18
. Negligible effort to implement
Advanta,es
. Negligible costs; five-year review
- None
Disadvantales
rnudvantales
Disadvantales
- No reduction in existing risks
- Fails to reduce potential for
exposure
- Fails to achieve reduction in
mobility, toxidty, or volume
of conwninants
. Not consiltent with CERCLA/SARA
goals/intent to select remedial actions
which permanently and significantly
reduce toxicity, mobility or volume
of hazardous substances, poUutants,
or e»ntaminantl
. Hi&!, potential for future remedial
action costs
~
~
. Would not meet chemica1-specific
TBCs
- Potential exists for future
remedial action
Protection of PubU~ Health and the ~nyfronmenl:
This alternative offers no additional protection of public health and the environment over existing conditions.
Rnnftlial Action Objectives Achievftl:
This alternative fails to achieve sediment remedial action objectives.
Condusion:
This alternative will be retained for detailed analysis because it wiU serve as the base conditions alternative to which
other alternatives will be compared.
-------
SCREENING OF ALTERNATIVE &.2: INSTlTtrrlONAL ACTION
,'. ..::~ "':-"'N:9
I'IOIUIDIOV'AL :!
;;~..;.::~:..;.;;. ~~t~:f
ItIVI:It
DlV'l:ll8lOII
coc:BATO JUYI:It .."....~ ....
8ADID a 118Gm:R8 11ft
B<)( ~ IIIMMC:':BUAft8
l'IO.\CTIOII
.. .. ...
IR..1TV .
CORTAlllllaT
IMPLEMENTABIU1Y
AdV8ft"'"
- Fencing relJably restricts site 8C'Cesa
by hWNUIS UId large tareltrial
orpnisma in the short-term.
- Fence iNtallation MI'Yices available:
institutional controls obtaiNble tJuough
legal channels.
- Does not ilderfere with ability to
perform futww Nm8dial ac:tic)n.
Df_dV8ftt8r-
- Coordination NqUiNd to Identify puti8 .
responlib. £Or 18CUMS iNtitudonal
control8 ud conduc:tms InonitoriftS.
- Not col8ilt8nt with CERaA/SARA pilI
iDtent to I8Iec:t remedial actioft8 whidt
pennanendy and significantly reduce
toxidly, mobility or volume of hazardous
substanr:e, poUutants, or cont:allWl8nts.
PrntHtfmt tJf Puhli~ Hnlth 8"d th@ ~I!ftt!
- WouJd not meet cheaUcal-specific TBCs.
I..81T1'VnONAl,:.
~~l~~~.:.~~.~jl{
. PafCES/SlCNS
. IDUCAT1OIW. PIIIOaRAMS
. LAND US& RIIOUlA11ONS
. DMRDNMEHrAL MOIIrt'ORlIIG
NR.2 INSTmmONAL AcnON
This alternative includes site fencing and posting wamirlS sips. Long-term enviloruzwatallllGnitoring wouJd be performed
to .evaluate site conditions over tiD\&
COST
.
r
EFFECTIVENESS
AdV8fttlt.,.
AdV8fttlt.,.
. Reduce potential £Or expo81U8
through site 8CCIISII and land use
restrictions.
puadv."bI,-
- Fails to achi8Ye reduction in
mobility, toxicity, or VOIWM
of cOntl.1NnafttL .
- Potent'- I exists £Or future
remedit 1 action.
. Minimal constnadionUld capita!
CCItL
rHadvaftt8ltM
- Long.-rm CleM COlts £Or
enYironm8ntalmonitoriDg.
- Fiv.yeu IWYiew costs.
. Potential £Or future remedial
action COlts.
Minimal prot8Ction to public health UId the envirolUMftt provided by c.nc. and institutional controls.
RftftHlal At."tImt OhiHtlva Adlift'.d!
This alter-dative rec:baC88 to potential for ingestion/conl8Ct with sediment through institutional contrala.
{-cmrlu!lillft!
i. 'his alternative will be retained Cor detailed analysis sinal it requires aUnimal expenditures and reduce the
potential Cor exposure to contalninants.
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. SCREEl'fING 01' ALTEMATIVE 0.3: Ilf-srru CONTAINllENT
COCIIA'I'O 8IftII 8D1IaiWI''' .
MI8D . 118Q~ .,.,.
8O&.88008.~. ..
. CAPPIMQ wrnc
snmtJ:nC
MD/CIt
N1M IN-SrTU CONTAINMENT =':Aa. .
IlHitu containm8ftt inYOlv. covering the contalftin.lt8d Mdimentt.i... pIacI with daD .yfttheduad/ or natunHnert
IIW8ri&I to redUC8 the pot8nt:ia1 for expaIUI'& LonS-18nII -Virocun_taI ~ would be -..y to ~1Dr cap
intlpity over time. .
EFPEcnVENESS
. .
"""':':~':':""":'::7
lfttl'l1l8llOY AI. :
"",:,':::':;:::':'7"::~:'::~:~.r.~:::;
81ft.
DIVa8IOJl
IMI'UMENTAII1J1Y
COST
r
Ad¥8II..-
AdvaIlD...
Ad¥IIlIbr
- Sod co".- and rweptldon Nlldl1y
COftICNCIibI&
- R8duC8I apoIUI'8 risk to pubUc
h881th and the _Ytronm8ftt by
covwtftS-im8ftt.
- Public health rIIIIIediailCdon
obi8ctiv. achiewd in
approximal81y OM Y".
- Equipm8ftt pIIIOIUI8I and malllriall for
I06J CD¥8r N8dI1y aY8ilabI&
DI.advanta,..
Dludv88t8I-
. Fails II) achieve reduction in.
Iftobilil.y, IDcidty, or volume
0I1ed1.lften..
- PoeIntiai aiIt8 for future
rllllledial 8ctian.
- Not COII8iIt8ftt with aRetA/SARA goaIa/
intllnt to I8Iect r111118diaJ KtionI that
pM'1R-I8IIdy and lipiftcandy redUC8
IDIIidty,lIIObiIity or ¥OIuaw 01 huardOUI
1UbItanc8, pallut8a.. or contaaUnan..
. Would DOt -- ~...,.aRc 1'BC&.
- CnnI--ra8ds to ..... in pI8C8 for
cap tup...:1ia81ftd 1IIIia- pwpoIIIo
- POtIIntiai for conuinal8d
IedllMnt III b8cIIme I811p8ftdId
and Iftip- doWftSll'8a\ . .
r8U.1t 01 Clpptns activili&
- l g [.-:iun 'F Bille ARAJIa so-NnS wedMda
and f1aad"'" II\8Y require 8fth8nc8ft8ftt.
~ or CN8don 01 wedlnds or
ftoodpiIUII dlllrOyld or Mptiwly Impacl8d
by CIIW8r placam8ftt and ICC88 ra8d
11118811ab.
- IAacaldy th8Ilr8188t
~
- CansIrudiaa and capital and
0tIM aaIt8 weIMIlfiMd.
DI..dvallur
- Lon..- aaIt8 for co...
~
. Lon,.e8nn aaIt8 (or _¥iron-
1Mft1lll1llOfti1Drinf.
- R..,..8ftWw CII8I8.
- PoeInIial for fubn r'IIMdlal
action CDIII.
PmtKria.. tJf Puhllr H.alth and 1M EmriftlftftWft.
For AJlilrNtive NR-3, rilb from dirlct cont8Ct would be conlrOllId by COVW II\8I11ria1 above sedlm8ftto however, negative impacts
of COVW syslllll on b8ftthic caIIIlftunity UftC8I18Ia.
R......tlal A~ftIt Oh&.rttv.. Adti8vMt
This alt8"Mtiw achi8¥8 N1118diailCdon objIcdv. relal8d III public health plQtectioft &oat ledilMftt. Reln8dial action ob;8cIi-
.tablilMd III pt'OI8ct environment not comp1et8.
rlll""I...,..,
This allllrnative wiD be retained for detailed analysi.liftC8 it MUC8I the pot8ntial for diNCt conl8ct with lediment and oIfen a
... CC8t1y allilrNtive than tlUtm_t allllrnativ..
-------
" '~,: ..«~::;~"":""."...*..." ~ "::;:::.:t..~.
IIOJIIItaIOVAI. ii:
;:~,::~::::~":~::::~~~:
:'i''i~am;. dPw
~, DrnuloN'i
~;:~~~~~~~~~:;::~:;:~~:~::
. PElUlANan'
01l-5ITB
COIIDurrs
8C11a:1U!fG or AL'I'ZIIIIrA1'I'n m.a.l
III'VIa lAY - -EItI/ffO Ai1C'DCB
COCllAtO 8Ift8 8D1IDII'r ...
MDID . 118GU1118 81ft
8D1.UOOK. IlA88tC11U18ft8.
1118,; A& uT1U1IAL
AoC'ftO.
rw-81TV
COlftAlJOl81ft
RD-1IfR.t RIWR. D~IONlNo.AcnON
This altlftUltive c:a11a for dewatlrUtlJ of contamizlated MdimerIt by rwoudnlJ riwr _..flow away &om the contalllirlated areas,
dlanby reducilllJ the potllltW for contalnirlaftt migration via .m.c.wa.. The I8CiimIIIt -uld reWa irt-place with no
furth. acdon taMn. .
&'FEcrIVENESS
IMPI.EMENT A81UTY
r
COST
AdnB~
AdY8IItar
. PlftNll8t Q1vll'lion prodUC81
a reduction in pol8ltW for
contalnirlaftt migration via surface
Wit. flow.
DII.d..fltap.
. Fai1a to red UC8 potllltW risk lor
pubUc and biota d8'IN1 contact
and Inpldon.
. Fai1a to ac:hieve reduction In
IIIObility , toxicity, 01' vallUIW 01.
contar:rllNnC8.
. Polillltia1 uis. lor future
rwmedW action.
. KiWI' Q1vll'lion and ~adion
compoft8\. not effctive 1111
reducinS polillltia1 - apoIUI8
to Mdimlllta (1CItI8~)
AdwAlltar
. None.
. Ncme.
Dlud..flta..
OI..lIIy."ea..
. Campi.. to ill'lplelnmt" with no risk redUdiDn.
. Not COIIIist8It with theCER~1SAIA pal
intant to ..«t18Wdia1 actionI which
pII'II1INftdyand sipiJiculdy I'8dUC8 the vabuM.
toJlicity, or adIi1ity 01. the h8urdau8aubMmc:8.
poUUtul. 01' CDntamiNn..
. Sub8tantial constnaction ('08.
plu monitDrisls and l'WYiew.
. Hip potential- future remedial
8CtiGa COI" '. .--
. KiWl'divwsion cornpla to impIeaw.t would ...
to be cioMty coordinal8d with olHiII8lOi1a
f'8t8Itiation activitieL
. Locadar.-6~ AHARa sovwNns ~ and
!oodpaiN may Nquire ~ I'8tantion
or Cl'8tion 01. wedlnd. Oft f100dpIaiN d8troyed
01' neptiwAy impacted &om the CDNtnac:tion 01.
a~ road and diYll'lion of the Cochato Ki~.
Pmtlllrtfitft it' Puhlil! H..lth .IId tIw ~wfl'B"III...1!
. Cb8nical1p8Ci8c TBCa will not be met.
This IltllNtive offen'l reduction in the potential for CDntaIrIinant migration via swflce WI- flow, how8\W it also provide
for a ~_w pottntial for dmnal contact and inpation by ~ the contalninal8d sedimiIn. more ICC8aibIe to I8rr8trW . '.
orpNSII\I. .
....dlal Adlaft o~~ A.d."'"
Thi8 alt8ftative lai1lto acN8¥8 sediawnt f8'o8dia1 action oDjctiva
~ndu.ian.:
Thi8 a1t8I'Ntive will be eWninated from lurtMr colllid..tion beau.. it oIlers no additional reduction in risk ow. Alumative
NR.t, No Action, and involv. -pensive CDnatnIctIon activili-.
-------
IICIUZIIDIG or AI. n:8IU.1'J9'8 III).NR.2
JUYD JXVI:II8IORfDIf-.,&u vuOllo\L ACnOIl
".y~y:...::.::::::":w., :(':::. ::.:.<
OOCIIATO IIIft8 ~ ....
8AI8D. ....... 11ft
-1800.. ..&"...~ ...
Dlo8ITIr
COftAlJlaft
RD-N1I.2 ~ DIWnlONJINS1TI"UnONAL ACTION
This alt-ti". i8 a comlriNtion of All8mativ. NR-2 and JU).N]t. 1. Thia alt8Nli". .;.as. d_18M1 01 canl8lrlillat8d MdilMnt u8n1
l10w div8niOl\ I8CMiqu. coupled With lile f8llems. poluS 01 waminS sip. impl8lNnlaQon oIedu~ and rep!a1iGll 01 land
IIH 10 proI8Ct the public &viii poI8fttial upoII&I'8. Lon8"18nft -torinl wOllld be perfonned to evaluate lite ~ OWl' tiaI..
Ef1'ECT1VENESS
1'108 UMOYAI. i,
,', ::;:~::::::::.:::.::::~..~::::.::~:.::::~~:'
. I'aIWfDII'
0II.sn
CIOIIDUn'8
IMPUMENTAIII.Irt
COST
Ad"...~
A8-~I","
- R8dUC8 potmtial far apI*&N
t1uvush ... -- and lad 1118
I'8tr1~
. P8nIwI...t rtv. diY8'lllan
red- the poI8fttial far
CIOI'Il8IrIiIIaItt Illip8tion YUI
lurf- -- fiow.
Dlaadv.ftt~r
. Flill 10 achi- reduction in
!nObility. tl8lic1ty. or val-
of cantamiNntl.
. PotIIItial aiatl lor future
r'8III8dia1 actian.
A_-", V-
. F8IIcift, NIiabIy I'8tIItC1l.. -- by hum8w
aM Wp tlll'lltrili GI'pIIi8III in the llat-18nII.
. Fece iII8ta11ation .... av8ilablc INtttUdGNI
cantroII obt8iMbIe tNaup 1epI m--.
. eo. not int8rm8 with allWty to p8fana futIIN
I'8II8dia1 ac:Iian.
Dfudw_~..
. Coordinatian rwquind to id8Itily puU.
IWpGNibie for MalMI iNlitutiOlla1
canaala and c:and1&Ctil'l,1nCIIIi1Orirls.
. NotCllll8lt8'lt wttlt CEICLAISA,1tA pII/im8'It 10
I8I8d NIII8diIIi --- whidt p----dy and
Iipi8cuIdy redllC8 addty.1IIObiIty orwIuDw 01
haard_--.... paUlII8" or~
. Loc:atiolHp8dc AIWta a-Nn'wetIatdI ancI
fJoodpUiN -y NqUiN~,....tioa,
or --. 01""" or fioodplaizw d...,... or
nepttwly iatp8cIId &viii the COIIICnIctian 01--
I'OIIdIIIIII di¥8llan 01 die Codta8o Riwr.
. ~11ICa wtI NIt be !lilt.
. Hi".. diwnian CIIIIIpia to implelMn\ wwId MId
to be cla8!y caardinat8d with OIHitelGil8
l'IDI8diatian activitia .
PrDt«tta8 af Puhlk H""'~ ad 1M ~.villl8"'"
-N-
r
Dt&adV"~I"
. Lart8"18nft 0tiA cmta for
.."iI'llftMlttallllOllitorins.
- Flv.~ r rwt- CGIt8.
- p~ for futIIN I'8INdiaI
acIIaD cma
. Hi-- di,...on COlt hip.
wwI4 ~ tII8izIt8Ianm. .
~ protection to pubiic Iw81Ih and the ...~b__t provided by (1I\C8o and inItituIianaI cantrolL p~ di'v8'llion reduC8 pountial
(or COfttamiNnt lllisraaan Via lurf.. wa. f],gw. No redUctian oIliOXic1ty.lI\CIbWty or voiWM 01 c:antllrtiNfttlad\Wwd.
a...MW ,,~ Oh&.dt... Adil.--
Thia allC'ftativelWduC8the pountial lor huzNn inpllian/can!Kt with Mdilneftt tJuaup inllitulianal cantnNs caizlponent.. SIIouJd inllituliaNl
conlJ'01a fail ("&0 ftllC8 int8p"ity). apaMd Mdizn8llti-ald be - eaRly 8ClC88ible for CIIIIt8Ctlillpottan potlfttIaL ~ I'IC8ptIIIft IIIWIhiIIitlldby
inltitutional canaala ("&0 birda aM IINIlI8n'8trIa& w-Ia ) wOllld aplNnce inCftU8d risk due to apaMd Cllllt8llliNt8d 18dia18IIti. . .. . ....
c...d......
Thia all-Ii". Will be elinnat8d &oat ~ CIIIIIid..tion beaU88 it iI- COIIIpla to iIIIp~ and it ctff.. no additional reduction in risk
ov. all-live NR-2. .
-------
8CJtD1111fG OP ALTl:lUfA1n8 ~lUt4
IIIVD DIVZII8IOR/Df 8I'I'V COIftAl1UllZft
-:. .:;".:c; .' '..:'~:::::.:'-::,;;:'~:::~;:;:
COCIIA1'O IUft8 UDIIIIIII'r ,..
MIIID .. I88GUm8 un
BOLDao&.~
111018 UJIO..A&. "
:~l~:~:W;:::ttt~~rm:1r~::
JIIOoM:'ft018
..
~!5!~j!:
UQt &. & v1'IOIIAI.
AoC'ft018
. 1DP01IAIII' oa
PUMNlEIft'
ON..srrE
CONDUns
. CNI'II'O wrrH
.:t.Hrn.l-'
MO/OR
!CA1UM&.
MAt"UIAL
RD-NR-~ RrVFR Drvn~rON/rN-SrTU mNTArNM9lT
This altlllUllive i8 . hybrid of Alt8maIiV8 NR-3 and RD-Nlt-t. 11Ua al--dw IJ*i18 d...-ills of CODtIIIIIiMt8d 88dimIn& via riwr.
diV8'lion. and the iNtalJalion of . cap 0- the contaminate Mdiln«lt. up mat8ia1may beuyntb8dc ....tiIIIoor natuft1 iD8t 1IW8riaI..
or . combinalion of the tWO. The ri- diY8Dian component of this a1I8maQ"emay be -- JI8III8nII'i or 18npOIUy.
EFncnvEN!5S
IMPLEMENT AlIUn'
r
Advanu,..
COST
- R8dUC8 ~ure riIk to public
health Iftd thl8IWiroNNnt by
cownaS S8IiimeL .
. Public h8l1th r'III8iia1 action
objcliV8 achi8wd In
approxUNt8iy one year.
Oi88d..8fttapN
- Fails to .c:hirIw reduction in
IIIobility. toxicity. or wllUM
of 18diaw\t.
.
. POI8nIia1 eJtilts for future
r8Mdia1 action.
-Jij". diwnion dOlI not
inCN8M co- Iysttm
eff8Cti-
Ad.....,..
- Soil COY8' and IW8pI8Iian N8di1y constr'llc:tible.
- EquiJllll8't p8IOMli and 1118t11ta18 N8di1y .YIi1ab18.
. LewI C demaL D rwpintory wan. r-oNctioI\
durillS co- op8'81iaN 1iWy.
DI..d.."~r-
- DiVWlion campIa to Imp""""
- CI¥8lillln constnldilm would l'8lluUe dale
CDOI'diNtiaa with 0IHit81Oi1a NlMdJatiDa Ktivi....
- Not CONiI-t with CERCLAISAKA goaI8/ln.r to
I8I8:t .-.dial acIiaN which plllNMl'dy and
sipi8candy reducellOxiGty. adliJity or wlumeof
huudoua lubItanc8. pollulantl. CII' contuninantl.
- LocatUln ~ 1:Uk AIARa so-NnS wedand8 and
floodplaiN I118Y l'8lluUe ~t. r8tDr8tiDn.
CII' c:raliaft of wedar1d8 CII' t100dpIaiN d8troyed CII'
nesali"'" 1Inp8d8d &am the construction 0I8CC818
roads and diV8llion of the CodIato Ii"...
PmNlrtiftlt 8fPuhli~ H..Jth aftd th8 £nViIlllUll8lt!
- Ch8NcaI-tpci8c nc. wiD not be IMt.
AdY--.,..
- IA8 COItiy than diV8Sion UId
tr8UD8It ab8nali...
. CoaatIuctMm and capila1 and
o.MCOIts ~.
Df"""""V-
- J.ans-t8nn COlts for co".
INinI8lnC&
- LonS-- COlts for div4lSion
III8inI8InC&
- R".y.. N¥i8W coe-. .
- Po_1ia1 for future ND'\Jdia1
8CIiaft CIOI88.
For Alternative NR-3. riaka from ~ conl8Ct would be controU8d by co- mat8ial above I8diIMnt.
"",...i.aI Adiaft o~.... Al'h-...e
This alt8mati"e adUe¥8 r8II8dial action obj8cIiV8 Nlat8d ID public health prolilCtiion &am MdiJn8tt. R8Mdial actioft ot:j8ctiV8 .tablished
~ prot8d enviraNNnt not entirely INt. ..
~ GI"rtu.ictn.:
This alt8m8tive wiD be liilninat8d from furtJw CCIIIIid..tiDn b8cause it provid8 no pot8fttialapolUN reduction 0V8' Allllmative NR-3.
-------
SCUENING 01' ALTERNATIVE ReI: UIIOVAL/DISPOSAL
COC8A!'O 1IIftII 88D1II8IIf'I' ..
MIItD . II8GVIIt8 un
1IOI800K. IIMMCIIU88'rI8
e~
II88I'OlIAnCllf .
e -CAnCllf
18M1'
arucr
11-1 R~OV AL DISPOSAL .
'I'hia all8maDve Specifi8 III8dwUca1 aavalicm of contalniNl8d I8dim8It. ACC8U to die Ii... adj8c8nt to the Baird &r McCuir8 site will have
... provid8d IS part ol the ongoillg source control NImdia1 action. aNt tMnIore.. wi11 not M8d to be done - this Klivity. ACIC8a to down-
stream conlamil'lal8d Mdiawnt would be proY1d8d by the izlstalladon of a grawi road adjlctat to thole p.xti.aas 01 the liwrto bel'8ft8diat8d.
If ft8C8IU')'. the sedizMnt would be d8Wattnd on-siI8 by gravity or 1IIIdIaNca111188111. IIId tnNpOI't8i via tnIck to ... off..t8 RCRA 1uIdfiIL
lor dispoNL Watw atnctioa &0111 the MdiDlet dewaceru,g proc- would be coU8ct8d IIIdtnat8d at theOlHit8-IJI'OUIId-- tn8bNIlt
plant specifi8d in the 1981 Baird &r McCuir8 site SOI.U'C8 control-ROD.
EFFECTIVENESS
~A.IUTY
COST
Advuo..,..
Adw8fttap-
r
- Reduc8lDObi11ty 01
-t'aIftiIIaft. iD s8dim8tt by
comolidatialt in a I8C'UN
I8ndfiIL
- R8duwaisdzlg and IDnlJ'hrIft
Iiska U80CiaI8d with direct
_tact with MdilNnt.
ni..d".n~I"
- Exavation ani w... handlinS
,.. s8orH8m risk risk to warII8L
-laad dispoIaI replalioaa NqUire
......... of acavat8d'Wast8
..- DdIspaIaL
- NatCGNilt8tt with SARA
rA.-'" for o~te 1'8Ift8di8.
-I" ~\.. action objectiWi achi8wd
.m;.ct to oa..aI8 r8II8dW action
sdll8lh&l&.
Ady~..
- Equi~t. p8rIODMI. IIId mat8'lal8lor acavation
d8Wat.mg. lnnlportadon of d8Wattnd I8diaI8t
IIId tnataMnt of extnct w.- avai1abl..
- CoftlOUdat8 waste in a sil'lgilllocatlGft.
- Off-sit8 RCRA 1811dfi1l coatpalible lor cliapol81 of solid
wate mat8ia18.
- Mak8 11M of cm-liI8 wa- tnatln8\t plant provid8d
by 1986 Baird .. M~uir8lite IOW'C8 CDNraI ROD.
DI.adw...bt,..
- SipiOcuIt wale .wlUIM .....ta.. 11M ollarp
RCIA IandaJ1to cantaiD IOticWI8d matI8W.
- Not canIi8t8tt with CERCI.\/SARA pl8/iN8tt D
-*t I'8I8Iti81 actio.. which Jlllll'8ft8'tIy ani
uFiflcaady r8dUC8 toIIici&y, IftIIbi1ity or w&uIae of
buardouI.bItataI, poUutanll, or coatIIIUI-
- Off1il81and dilpolal without tnatlNftt 18 th8
.... favand rmwdia1 actioI'I ~ CERCI.\I
SARA.
..~ 1~ elPbhl1r H..lth 8ft" 1M ~wilDlllltlftt~
-1.imiI8d potImtial for New.
I" 'I", adiaD CGI&
- Loa,.,.. -viranaMI\ta1
IIIIDnitoriIISI maiI'It88nce .
rwponsibi1ity of RCRA ~an
I8I8ct8d.
- No 8S8OCia18d Ions-tem
.~tallllCmi8Dringl
INiDt1NDC8 CGI&
Dlud"tnttar"
- 1m...". rc18dia1lCtivili8
." n.quilw won. prot8dioa IIId
iftcnue~
- Sipificant cost lor tnlllpona-
tIr.a IIId di8pola1 at a RCKA
IaIdfilL .
-
...... AdiB. 0Iti8di- Adt--..
4-.~- R-t r8d- risk &0111 ctina _tact by consoUdadl\g all w...matcia1 in an off-liI8 RCRA landfilL
1!!ia alt8118ti". achieY8 the S8dia18nt NImdia1 action ob;ctiva
,.......t..ilMl!'
,.
'1IIIIit allIIIDa~ will be retained for d.wl8d analysis. While AltllNtive R-t d08 not provide tr8t1n8\t.to reduC8 eM IftObiIity. toxicity. or
..... oE cantaIninants in ~ it proVid8 coftlOiidalioa IIId contaiNNnt ill . RCRA landau. 'I'hia alt8INti". may be COIIIpared with
AbIImaIiY8 1-2 and 1.3 80 weigh the b81efi. IIId COl. of s8dilMnt treatment IIId INII8g8118ftt of treI tmIIftt naiduaJa.
-------
SCREEN1NG 01' ALTElUIATIVE 2.2: REMOVAL/INCINERATION
COCIIATO IIIfta ADD181ft' ...
MI8D a IleGU1a8 .rn
IIO~&. IIMM1CIIIIUft8
.~D8
III88I'OM'ftCIII
. IISVSOKfA11C111
I
I
.=r' ,
R-2 R~OV AIJIN~TlONIDISPOSAL'
ColI\pon8'ta of this alt-tive iJtdude contamiNted MdisNnt 8llClvaaon IIId 0IHi18 cl8Wali8Uts. if ftIIC8IUY. a cIeIcrib8d iJt Alt8madw
R-t. aJons with' tnatlrl8nt of the dew.1IINd sediJ:Mnt 10 _11m IDxicity. The tnatlnBlt ~ would iJtvolw iDciMntioD UIins the C8HiI8
soUtceconaoll'8ft8dia1adion inciJMrator. R_dual zn.w. and ash would beso1idifi8II on .laprior 10 di8poML
EffECTIVENESS
IMPLEMENTA81UTY .
COST
AdY_~r
AdY~..
r
- R8duC811\ObWty aNi wlwne of
conlaDliNldl in I8IiinIIa throup
iJtcin..tI.olL
- P8nNI\8ftdy d8l1l'OYl organic
constitu8l11 iJt MdiIn8IL
- ReduC88 aistinSIlld lonS-t-
riliu UIOCiat8II with d1nct contact
with 58dUNltt.
nl...d..llu"
- ExClvation IIId wala IwtdJins .
poI8 short-18m risk riIJr. 10 wortI.8'I.
- 1rIcin8adon I118Y irIa8M the
IDxicity of IJtorganic exntitu8ft1l1n
r8lidual lib which I118Y NquiN
solidification IIId off1ite RCRA
WId&Wns.
- Onsite Incincation of I8CI1DwW i8
subject to soil r8Md1adon KMduJ-..
AdY8ftblr
- Eq'Jiplft8lt. p8IOM8l.111d t8chnoIosi- for
iIIcin..tion available throup 0IHi18 lOil
nIIII8I:Iia1 ~n.
- O&M CG8ta Inc:wNd anIy durinS
r8n8dia1iaa.
. - tncin8'ation f881ib18 for tza--.t of lOUd wut&
- No &v~.. rwiew.
- Conail18t with CEKCLA/SARA paI8/i.nt8tt to
seIa:t I'IIft81ia1lCt1.orw whiCh p8INII8Idy aNi
sigrWicandy _uce the voblln8. IDxiday. 01'
InOtUity of the hazardoua subl88ftC8. poUutanta.
or cont8l.ninaDt8.
- No inciD8a1Dr IftDbiliution f..
nl..dw.n~I"
OI_d.8IIt8pt1
- PollmtialJy Nquinl Mamdary walalND8s--'t
of _dual uh from iftdI8ation.
- PoIIIntia.i 8CbniNItntive Ie88ibi11ty prob--
- r8IIWn8 coordination with M¥W8l f8d_/
Ita.. a;8IKi&
- Invuiw rcwIial acliviti8
. lWlluiN won. proI8Ction and
ma- CIIIItI.
- Multiple p~ sc:h8In8 10 Ax
r8iduallnlta1laNi lib will
~ CG811 (jf lWlluiNd).
- Incr'8II8II alAI due 10 tnrwport
IIId diapD8al of so&idi&8II _1Iic8
iJt RCRA IaNiJiU OllWlluiNd).
PratK'tieil It' Puhllr K..Jth ...d th8 ~.,imftlll...t: :
'1Ns alt8mative oR.. pro_daft 10 public h.l~ .md the 8IvUolUlWlt by NdveinS pot8Itial for dintt cont8Ct with conlalninanll. Excavating
wut- would Nduce the pot8ItI.a1 for contallliNnt ll\igration. .
RIflftHIai AdiD.. Obl«ti- Adtift.d: . . .
Altmlative R-2 &Chi- the 1OUn:. conaoll'8lNdial donob;8ctivw. but prop8' watelNNplNftt of Nlidual ash &om incinIration IN&It
be p8fonMd if the lib contaiN toxic IIId IBKhabl1li InIta1I. .. -' . ..... .. .
Glndu.ia~
Thia .ltmlative wW be retained fof detailed analYG The significant Nduction iJt waN IDllicity IIId IIMIbility I118U tNI a1t8mative consistet
with the iJtlent of SARA Nquirwlnlnll. .
-------
SCREENING 01' ALTERNATIVE R.3
REMOVAL/SOLVENT EXTRACTION
coc:IIaO IIIft8 I8DIIII8Ift ..
MIItD . II8GUI88 8ft'8
8O(FW"'IL ~
.~
1UI:ftO--
. Its¥WDcr-
R.3 ~ov AUSOL vnrr 'EXTRAC'110N
Contaminat8d sediment acavation ia a COmpaNllt 01 this alt8mative u d8aibld ill previously pr88ItIId alt8ftl8tiWi. A dewat... st8p
may not be ncl8SU)' prior to solvent 8XI:nIction due to treatmtftt pI'OC8MI. Sedim8lt wW be treatlld by solvwm atnction pra "11. with
extract r8Siduaia also undll'gC.inS trutmtftt. Wat.. would be drawn off from the proc.. and treat8d at the 0IHi.. SOUR8 cOI\trol waw
treatment pLmt. Extnc:tIId seXV8It would be cUwnIn8d and Ir8t11d and/or dispoMd of at an ofHU8 RCRA 1'5D l:IciI1ty or Yta 0IHi18 .
source control inciII8'8tion (ad IOUcWlcation of rwidua1 DIItaII and uh il ~).
- .
r
EfFECTIVENaS
IMI'UMENTA81U1Y
COST
Advan.....
Ady8fttA..
- ImIovati". alt8mati". treat:Dl8lt t8chn0iosr
(solvwm -b-d...1).
AdY_~
- K8dUC8 mobility and volU1ft8 01
contalftinanll in MdiIn8It throup
inanention.
. O&M CIII8t:I incurnd -y durirlS
rca8dJatica.
- R8duc. aistins and Iong-t.m
risks UIOCiatlld with dinct ccmtac~
with Mdimtftt.
- I'roVtft 8ffecd". treatm8lt ~ for p8ticide
and P AH atnc:lian from IOi1I.
- No 8".,.. N¥i8w.
. Trwtlld IIIdiIn8It may be .uil.bIII for b8ckf1WnS
at the Baird ar l.kCuire .ita
- No diapo881 C08tI should treatlld
MdiIn8nII be suitable for bedl&linS
at Baird ar l.kCuin sit&.
nl..d"8fttal~
. eo...... with CEKa.AISARA pIa/ln_t to
MI8c:t r8n8d18I8diaN which p8III8ft8'tIy and
sipiJlc:andy reduce the voIUIft8" toxidty, or
DlDbWty 01 U. huudoua subItanc8. po11ulaftll,
01' contalNNa&
DlucI......-
. Excavation and w.... hand1i11S
paM short-ttnn risk to work8rs.
- R8n8diAl action ob;Iqiv. achi....t
subject to olHite I'8n8dia1 action
Kh8du1&
. IDYUive r8n8d18I activitill l'81l'i--
wortr.c prol8diAm and ma- C08tt.
DludY.,,~
. MultipleplOC88 schc8 Nqun
INIllMlt or rteyclifts and will
m-COItI.
- PoI8ntia1 for NtIU'e r8t8dia1 action
COlli ilIOIV8It.....«t ...1ion proc..
fai1I to eff8ctiwly nmo". all8\ic.
. SaI_t atnctiGn I8chnoIop8 not fu11y
d8Nm88ntlld for UMNC.
. T,.tabiJity NIt nqWnd.
Praf8ldiaft o~ Puhlir K-.lth 811~ 01. mvu...",...t!
AltCNtive 1(.3 provid. pl'Ol8Ctian to public hea1th and the tft¥inmln8lt by r8ducinS polllNial for direct contact with contamiNntt.
--dial Adimt OItWti- A~wch.. ... .
This all8mati". ac:hiewli fIIINd1a1 cdian ob;8ctiv-.
~nftWlinft.
This allilmati". wW be retained f2 detailed anaJysia. This alt8Nti". ia CONisttftt with the Inttftt of SARA. This alt8mati". involWi an
innovati". technolasy tNt QIlers pot<iaI for extnctins contalftinants from MdIm8nIl.
-------
SCREENING 01' ALTERNATIVE It-4:
REMOVAL/SOLIDIFICATION
coc::BATO 8Ift:It ADIUBft',.
BAIRD . II&GtDB SI1'B
BOLIIJtOOII[. JIMMCIIt1S&ftS
~,
.~
~M1UI"
. I18't8GCI'A1101f
11... Rt::MOV Ausolromr---A. TTON
This ahemative iI siJllilar to ahlmative R-2. The exc:eptiOll iI that the indncation stlp illfit out of the tnltmIrIt proc:8SL The dewatlreel
excavated sediDwnt iI sol1cWiad OIHite to r8iuc. contaminant mobility. UId dlsposeci of by olf-slt8 RCRA 1andfi11irIg. .
EFFECTIVENESS
IMPUMENT ABIUTY
COST
. Adyanbp-
. ReduC81 mobility of IMtaIa in MCiiINI\t
by sol&dilication tnltlNftt UId pllC8ft8\t
in a secun 1uIdfi11.
A.d....~..
Adv."t.8I-
- SoU solidification pro... tchnology at other
site for SOIM awWt.
- Reduce ailtiftS aftd IonS-t8m riskI
associated with diNCt contact with
sediln8\t.
. Equipawnt, JMIION'II. aNI ~ n8dily
available.
- SoJidified _te _18iaI8 laIIdfil1 CDlftpatibl..
. Offll"l tnltlNftt of wa- prior to
WId dispoNL
- CoNOUda- w.... in a IiDpeloc:ation.
OI..d.8"tas.-
Dlud"8"t.8,..
- Excavation and waste handlinS poI8
short-term risk to WOl'Un.
. SignifiC:lftt wate VolUIM nec..ua-larse
scalelNNpOl'tation to large Wuifi11 to
conWft solidified INt8ia1.
- ReD'Iedi.allC'tion objectiV8 8Chieved subject
to on..it. r8Ift8Iiia1 action objlctiva.
. Alt.mdve CONtitu- an .off-site" solution.
- Solidification tnltlNftt sipWicandy
ina-aMI volwne UId \Weight 01
contaDliaalild 1Nt8ria1.
- Organicl (P AliI UId pelddd8) may
sigNlkandy in... with banding pI'OC8IIo
. Fine inIolubie INt8iaI caD delay UId
w.un bonds.
. !'I;ot consistent with SARA', pr881'8ftC8
for on.,ite rem«iies.
Pmt.rtittn ft' Puhlir Hnlth and tIw ~YI""",,...t!
- Snli.tifi....tion costI are low.. than
for ou. tnatm81t alt8mativ..
r
. Limited pot8ntia1 !or Nan NDl8di.al
action COlli.
D iudY8IIbI,..
. Invasive r8Mdi.allCtivitie require
worker protctiDn and incruM costs.
- Signi&ant COlt for transporting Uld
.dispoIalat a larg'8 RCRA 1andfil1.
. .
This alternative oIfll"l protection to public health and the environment by reduans potential for direct contact with contaminants. By
incorporaq waste in a solidified INN UId 1andfilling the INtII'ial. 1M potential for contaminant llliption iI reduced in two ways.
Waste are alIo consolidated oif-site in one area.
R......t;.aI &l"Iiftft o~.,.. AAI~
Alternative a-4 achi8v. the sourn control remedial action objectiva
Cnftdu.iDn:
This Ilternatiw wiD be eliminated from furth.. conside:ation. Rational. for e1iD\irIating thilalternative includes (1) the st.tutory
prften!nCl for on-site remedie rather than off-sit... disposal; (2) aceasive costs associated with off.,i. disposal of alarg. volume of
material; and (3) other altll'NtiV8 off. equal or better treatment perfol'lll8nc. at sim&1ar or reduced costs.
-------
SCREENING OF REMOVAL ALTERNATIVES
WITH RIVER DIVERSION
COCIL\l'O mva ......-.... ""-1 ...
BADID a IleGUDm srrs
BOLDOOL IIIA8ACBU8&TT8
1aAT
saucI'
\
. 'T1U8IT1'AlUES
. 1W1fFAU.
.0lIl SDP
.~
RaI'ORAttON
. Al:VCc&'tAttON
RIVm DrvBSION
Build hydraulic barriers upstream and downstream of stretch of river to be diverted; dar, grub, build gravel road where necessary
to provide access for consnuction activities in areas where access is not provided by on-site remediation activities; install divenion
conduits in coordination with on-site excavation activities; b8c:kimaround conduits with d_n tr8teIi lOiJs from on-eite treatment
proc..; divert river flow through conduits; re8tablish vesetaticm in a,... not COII\InDD with Oft1ite rell8iiation activities.
r
EFFECTIVENESS
IMPLEMENTABIIJ1'Y
COST
AdvUlt.'M
Advalltar
- Efficiency and acxuncy of contaminat8d
sediment reD'lDval increaMd by river
divenion.
Advall~r
- Potential for contaminant migration
via swface water effectively eliminated
by river diversion.
- Construction, capital, and O&M
COltS well d8fiMd.
Oi..dvallta.-
Diaad'V811t.,..
Diaadv8"t.,"
. River divenion will have a negativ.
impact on the aquatic eco8ystem.
. Diversion CONtn.1ction would requin
clale coordination with on-eite lOil
NJNdiation activiti8L
- Expensive UDdertaking, similar
benefit could be provided by less
C08tly IIW8M.
- ~Iex undertaking; simiJar benefit
be provid8d by .. complex awans.
- Lacation..pecific ARARs pemins wetlandt
and flaodplairll ~.. enhanctmll\t,
I'8toration, or Cftlltion of wetland. or
Oaodplains destroyed or negatively impacted
from the construction of acC88 ro8ds or
diversion of the Cochato River.
Pmtemaft of Puhlir H.alth 8IId th. ~viran1llftlt!
Removal alternatives with river diversion effectively eUminate the potential for containment migration downstream via surface
wa~er flow. The aquatic eca8Y'tem will be negatively imp8ded by removal of now from river bed.
RIm'I.diaJ Aman Obj~B AdIi_d:
Removalaltematives with ri"er div~ion would achieve mnedial action objectives related to potential expe8U1'e to risk via
containment migration and f, ,il'objectivel to protect the environlNftt.
Ulftrlwaioft:
The removal alternatives wir.h river divmion will be eliminated from further consideration because removal alternatives
involving no river divenion are feasible, have I... impact on aquatic ecosystem. provide similar protection to expc8.UI'e risks,
and are less complex and COItly.
-------
. t
. . I
..' It
FIGURE '+
. SEDIMENT DEWATERING
. INCINERATION OR SOlVENT
EXTRACT1OM. ANO'OR
STORAGE FOR DISPOSAL
. WATER TREATMENT
.
r
,~
.
UGEIND
"
.~~...
SIU Cl.l'TAINS
EXTENT 01'
~~TION
ALTERNATIVE
SCALE- . feT
......
EJCAVATION ACCUS
AOo\DS . EXISTWIG
EJllCAVATION ACCUS ROADS .
TO III CONSTRUCTED
tWA. ROUTES, EXISTWIG OR
TO III CONSTRUCTED
SEDIMENT REMOVAL ALTERNATIVES
CONCEPTUAL SITE LAYOUT
PUBUC HEALTH RISK REMEDIATION
COCHATO RIVER SEDIMENT FFS
BAIRD' McGUIRE SITE
.....
«<
-------
. . I FIGURE 3
I"t
LEGEND
':- .:;.;:."
-
AREAS REOUIAtNG REMEDIATION
TO MEET PUBLIC HfALTH
TARGET LEVELS OF 10)
AREAS REQUIRING REMEDIATION
TO MEET ECOLOGICAL TARGET
LEVELS (INCLUDfS ALL AREAS
REOUIRING REMEDIATION FOR
PUBlIC HEALTHI
~
SEDIMENT eXCAVATION 'VOLUMES
Foq PI.8L1C HEALTH 1200 CI.8IC YARDS
AISI( REMEDIATION
Foq ECOLOGICAL
RISK REMEDIATION
20,100 CUBIC YARDS
r
o
SCALE It FEET
500
1000
REMEDIATION AREAS
COCHATO RIVER SEDIMENT FFS .
. BAIRD' McGUIRE SITE
-------
DIIECT CONTACT WITN AllD/Oil IIIGESTIOK OF COCIIATO IIiVU SEDltlIlIT
CARCI~NIC EFFECTS
IEALISTIC WO~T CASE EXPOSURE SCENARIO'
COCHATO I.VEII &EDIII£IIT &1QIY
. 1A11D' IIcGUIIl SITE
HOL",". tlASSACIlUSEnS
AIIOIIIT or AIIOIIIT OF DllleT CAG
ItAIIIftII SOIL SOIL lOllY NO.or NO. OF INGESTIOK CONTACT Poteacr
COIICElTIAT 101 COIITACUD INGESTED.. DEIUlAL 11 INGESTION w: I GIf EVEIITS TEA 115 lOOT DOSE 800' DOSE F.ctor IIICI£II[IITAL
COttI'OUIID (~I/a) fa/evnt) b'neat) FACTOII 11 FACTOII (.a) rEI YEAR EXPOSED (81/.1'01.,) (81'.1/01&,) (8I,,,,d.y)-1 liS.
I
Annic 4040.0 1.0 0.1 0.00 1.00 4S 30 10.0 I.OSE-04 O.OOUOO I.SOE-OI 1.51&-05
,AI. 22.' I.' '.1 0.05 1.00 45 30 10.0 1.06£-05 2. UE-01 I.IU.OI I.OE-OS
(Card.o,e.ie) 5.9SE-01
DOT 4'.0 1.0 0.1 0.50 1.00 45 30 10.0 1.2SE-06 6.26E-06 3.40E-01 2.5SE-06
Chlar'a.. '.1 1.0 0.1 0.50 1.00 45 30 10.0 2.31E-01 1.19£-06 1.30E.00 I. '5E -OJ
5UKKARY CAlCIIOGENIC 115. 3.0£-05
IIOTES:
11 . Ta.ico.iaetic ractor
Tbl. t.ble calculate. eati..te' bodr 'o.ea aad i.creaeatal carcino,eaie ri.~a.
Tbe equ.tioa. to calculate bodr 'o.e le.el a" i.creae.tal careiao,e~ic ri... are:
Soil
Io'y Do.e = Coaeeatra'ioa . '(A80uat eo.tacte' . De~l 11 rac'or) . (A80uut la,e.,ed . lale.tioa 11 raetor»)
(8I'.l/d.,) (UI"). (I/eve.') . (1/,veat)
.
I
Io'r Wei,bt.
(.,)
. 10. Eveat.
rea ...
110. a' ,ear.
. . elpo.e'
JO rea...
. -1!1...-
1000 ul
.
I yr
365 d.,.
1000 ul
..er...a'al Ii.. . Iody Do.e . GAG Poteacy Factor
8".I,d.., . (8.1..lday) --I
-i
]:a
m
,...
m
.'
I ".e' 08 ...iDUD con,..inaot coaceatratioa. 'etected la .edl..a' ..~Ie. collecte' 'urlnl Juoe 1981 a.d Nove8ber 1988 .&apllnl eveat..
.~
..
3.19.41
0001.0.0
..,.
-------
DIRECT CONTACT wnw AlD/oa INGESTION Of COCHATO RIVEII SEDIItUT
CARCINOGENIC EffECTS
IIDST '110"11£ EXPOSURE SCEIARIO
COCIIATO llVEII SEDI/tEIIT STUDY
lAIRD. ItcGUIRE SITE
IIOLIllOOI, IlASSACllUSEns
AVERAGE IODY NO. or 10. or
COIICENTRATIOII BEiliU 11 I NGESTI OIl WE I GIfr lVENTS YIAIIS I HCIWtENTAJ.
COIfPOlllD rACTOR TJ( rACTOR k PElIEAR EXPOSED' IISK
AneDlc :U.O 1.0 0.1 0.00 1.00 45 30 10.0 '.09£-07 6.oo£tOO 1.50E-01 1.21:-07
'AlIa 10.2 1.0 0.1 0.05 1.00 45 30 10.0 2.66E-07 1.33E-01 1.IUtOI 4.6E-06
(CudDo,nle:)
DOT 1.2 1.0 0.1 0.50 1.00 45 30 10.0 3.131-0' I. 51E-07 3.40E-01 6.4£-0'
Cblordo.. 1.2 1.0 0.1 0.50 1.00 45 30 10.0 3.I3E-08 1.51E-01 I. 30Etoo 2.4£-07
SUItItAIII CARCINOGENIC RISK 5.01-06
IIOTU :
TJ( . To.icoklnctlc roctor
"Ia toblc calculotea catl..tc. .od, ~aca aD. lacre.eDtal corclno,cnlc rilka.
"- equatloDo to calculate bod, ~ae Icvel ODd iacrc..~tal clrcino,eaic rlaka .re:
SoU
Iod, Doac : CODceotrotioD. I(A8ouDt CODtactcd . Dcr881 11 ractor) . (A80uDt I.,eatcd . In,eatloD TK ractor).
(.,/k,/da,) (u,I,) (,/eveDt) (,/eveat)
.
I
Iod, Wei,....
(ka)
. 10. EveDta
,cara
.
10. a' ,eara
..poud
70 ,un
II --1~
IGOq ul
.
I yr
365 da,a
1000 u,
lacre.e8tol liak . Iod, Dole. CAG 'oteDc, roctor
.,/k,/da, (.,/k,/dl,).-1
].89.48
0002.0.0
-------
TABLE 2
. ' I
I' ..
-.,--~
TECHNOLOGY SCREENING SUMMARY
COCHATO RIVER SEDIMENT FFS
BAIRD & MCGUIRE SITE
HOLBROOK, MASSACHUSETTS
-
RETAINED
YES NO
TECHNOLOGY
No Action/Institutional Action
. Institutional Controls
. Fencing/Posting
. Environmental Monitoring
x
X
X
Containment
. Cap In-situ
X
Removal
. Mechanical Excavation
. Hydraulic Excavation
. Pneumatic Excavation
X
X
X
.
r
Treatment
Acid Leaching
. Advanced Biological Treatment Methods
. Incineration
. Molten Glass Electric Reactor/Vitrification
. Thermal Aeration
. Solidification/Stabilization
. In-situ Solidification/Stabilization
. In-situ Vitrification
. Solvent Extraction
X
x
X
X
X
x
X
X
.x
Disposal
.. On-site Disposal
. Off-site RCRA Landfill
. On-site RCRA Landfill.
x
~
X
8o.~9
-------
, ' I
t ~
TECHNOLOGY
(continued)
TECHNOLOGY SCREENING SUMMARY
COCHATO RIVER SEDIMENT FrS
BAIRD & MCGUIRE SITE
HOLBROOK, MASSACHUSETTS
..
RETAINED
YES NO
Ancillary
. Hydraulic Barriers
. Clearing/Grubbing
. Pumping
. On-site Water Treatment
. Screening
. Dewatering
. Chipping
. Silt Curtains
. Trucking
. Grading
. Revegetation
x
X
X
X
X
X
X
X
X
X
X
.
r
.88.29
-------
TECHNOLOGY
NO ACTION/INSTITUTIONAL ACTION
.8
Institutional Controls
8 Fencing/Posting
8
Environmental Monitoring
CONTAINMENT
8
Cap In-situ
3.89.48
0014.0.0
SCREEN I NG 0" S~.n.~ENT TECIiNOl.Ol~ I ES
COCHATO RIV~g SEDIMENT FfS
BAIRD & McGUIRE SITE
HOLBROOK, MASSACHUSETTS
SITE-LIMITING
CHARACTERISTICS
Long-ter. responsibility
for controls uncertain.
None.
None.
Large irregular areas to be
capped. Permeable cap material
would allow groundwater to
enter river water through
bottom sediments ~nd
floodplain wetlands.
WASTE-LIMITING
CHARACTERISTICS
None.
None.
None.
Future contaminant
leaching not
addressed.
..,.
WASTE
RESIDUALS
Untreated
contaminant
concentrati.pns
left to decrease
through natural
attenuation.
Not applicable.
Not applicable.
Contaminated
media capped
but remains
untreated.
STATUS
Retain. 14enlify
parties responsib
for institutiona I
controls .
Retain. Effectiv
institutiona I
control (continue
fencing/posting
may also be apvli
as a support lech
nology during .
remedial action). .
Retain. Effectiv
monitors changes
in site conditio..
with time (re-
quired when waste
remain on-site).
Retain. Address~
some remedial
-------
(continued) .
SCREENING OF SEDIMENT TECHNOI~GI[S
COCHATO RIVER SEDIMENT STUDY
BAIRD & McGUIRE SITE
. HOLBROOK, MASSACHUSETTS
TECHNOLOGY
SITE- LIMITING
CHARACTERISTICS
WASTE-LIMITING
CHARACTERISTICS
STATUS
\
Removal
.
Mechanical Excavation
Access roads would be required
adjacent to re.oval areas
(source control RO/RA will
provide for access to river
alool Baird & McGuire site).
Mechanical excava-
tion technologies
well-suited for
effective, efficient
remov~l of cootami-
nated materials.
.
Hydraulic Excavation
Insufficient water depths for
successful operation; hydraulic
dredle action not as easily
controlled as .echanical
excavators.
Would be necessary
to use a cutter-
head to loosen
Iravels and hard-
packed sediments
for hydraulic
lifting, thus
increasinl poten-
tial for contami-
nant resuspension
and ailration
downstream.
.
Pneumatic Excavation
Insufficient water depths
for effective operation, .
smallest production rates
of removal technololies.
Sands and gravels
difficult to lift
at shallow depths.
3.89.48
OO!5.0.0
.....
WASTE
RESIDUALS
Would require
comparatively little
dewatering ~rior
to disposal or
treatment.
Would require an
extensive dewater-
ing procedure
prior to disposal
and most treatment
processes.
Often less water
is conveyed with
pneumatic equip-
ment compared to
hydraulic equip-
ment.
Retain. Best-
suited removal'
technology for
site wastes
present.
Eliminate. Use
of hydraulic
excavation
equipment nol
feasible for
site conditions.
Eliminate. Othel
excavation tech-
nologies more
effective and
easily i..ple-
-------
lcont tnuedJ
SCREENING OF SED' '1T TECHNOl.OGIES
COCHATO RIVER SEDIMENT STUDY
BAIRD & McGUIRE SITE
HOLBROOK, HASSACIIUSETTS
fECHNOLOGY
SITE-LIHITING
CHARACTER.ISTICS
fREATtlENT
.
Acid:'Leaching
Excavation and dewatering of
sediments would be required
prior to treatment.
.
Advanced Biological
Treatment Hethods
Excavation and dewatering would
be required prior to treatment.
.
Incineration
Excavation and dewatering
required.
3.89.48
0016.0.0
WASTE-LIHITING
CHARACTERISTICS
Arsenic not
effectively
leachable under
acidic conditions,.
would not address
pesticide or PAHs
contamination.
Not effective on
low concentrations
of PAHs or arsenic
present. Pesti-
cides may be toxic
to microorganisms.
Incineration would
destroy organics
but may leave
inorganic constitu-
ents untreated.
..,.
WASTE
RESIDUALS
Corrosive leachate
would require treat-
ment (neutra~ization)
prior to disposal.
Potential for waste
residuals to be of
same concentration
as untreated waste
feed.
Ash from incinera-.
tion may require
secondary waste
management for
inorganics. Arsenic
compounds may be
present in flue
gases or bottom ash
and would require
further treatment.
STATUS
Eliminate. Not
effective for
contaminants of
concern.
Eliminate. Not
effective for
inorganics,
effectiveness on
organics compound:
uncertain. Re-
sponse objectives:
may not be satis-
fied.
Retain. Accomp-
lishes reduction
in sediment volum.
-------
(continued)
SCREENING OF SEDlttENT TECIiNOI.OGIES
COCHATO RIVER SEDIMENT STUDY
BAIRD & ttcGUIRE S"ITE
HOLBROOK, ttASSACHUSETTS
TECHNOLOGY
S ITE- LI"ITING
CHARAC'lERISTICS
STATUS
.
ttolten Glass
Electric Reactor/
Vi lri fication
"oisture content adversely
affects flow rate of process.
Extensive dewatering
of excavated sediment
required.
.
Thermal Aeration
. Excavation required.
.
Sol idification/
Stabi liza lion
Excavation required.
3.89.48
OOH .0.0
WASTE-LIttITING
CHARACTERISTICS
Will require long-
term management
for potential
contaminant
leaching.
Aeration would not
treat inorganic
compounds. poten-
tially ineffective
on large PAH com-
pounds and
carcinogenic.
pesticides due to
low vapor pressure.
Vendors claim
success on inor-
ganics and some
organics.
....
WA~TE
RESIDUALS
Organics volatilized.
inorganics encapsu-
lated in dense
vitrified mass with
low leachatiility
would require
disposal.
VOC/SVOC off-gases.
Solidified/
stabilized wastes
require disposalj
contaminants
incorporated into
solidified matrix
may leach over time.
Eliminate. lias
advantage over
other more well-
developed thenna
oxidation tecta-
nologiesj not ye
demonstrated on
a full-scale
operation.
Eliminate. Fajl
to treat inorgan
contaminants, nn
and carcinogenic
PAHs present.
Retain. Address
some remedial
action objectivt
could be used i I
conjunction wilt
other treatmenl
-------
(co'~"~\nued)
,
SCREENING OF SI ,ENT l'ECIiNOI.OGIES
COCHATO RIVER SEDIMENT STUDY
BAIRD & McGUIRE SITE
IIOLBROOK, MASSACHUSETTS
TECHNOLOGY
SITE-LIMITING
CHARACTeRISTICS
STATUS
.
In-situ Solidification
In-situ applic~tion likely
to require p~~~anent river
diversion; groundwater dis-
charge will keep potentially
contaainated water ponded/
flowing through this area.
.
In-situ Vitrification
Cannot be performed in
subaqueous conditions; would
require hydraulic barrier for
both surface and groundwater.
vitrified areas would require
significant time to cool-cover
would be necessary
3.89.48
0018.0.0
WASTE-LIMITING
CHARACTERISTICS
Intimate mixing of
reagents with
contaminated
sediment may be
difficult. effect-
iveness on pesti~
cides/PAlis must be
determined by
treatability tests.
Organics are ther-
mally destroyed
inorganics are
immobilized within
glass. This system
operates most
efficiently on soils
with low moisture
and high silica
content, Cochato
River sediments
typically exhibit
high moisture, high
organics, and low
~ilica contents.
~.
WASTE
RESIDUALS
Solidified sediments
requiring cap to
minimize infil-
tration in order
I ,
to reduce potential
for long-term
leaching of con-
taminants.
None.
Eliminate. Sile
conditjons not
favorable for
application of
in-s i tu solid i-
fication
technology in
streambed due
to groundwalcl'
di scharge in
streambed.
Eliminate. Sile
conditions not
appropriate for
in situ appli-
cation of this
technology.
Excavation and
removal of
sediment mOre
feasible and
implementable
than dewatering
river bed' and
in-situ
-------
(continued)
SCREENING OF SEDIMENT TECIINOLOGJES
COCHATO RIVER SEDIMENT STUDY
BAIRD & McGUIRE SITE
HOLBROOK, MASSACHUSETTS
TECHNOLOGY
~!TE~LHt!!:NG
CHARACiERISTICS
STATUS
.
Solvent Extraction
Excavation required.
. DISPOSAL
..
On-site RCRA Landfill
Special considerations may be
required to CDnstruct landfill
on-site.
.
On-site Disposal
(Baird & HcGuire site)
Special considerations may be
required to dispose at the
Baird & HcGuire site.
3.89.48
0019.0.0
WASTE-LIHIT ING
CHARACTERISTICS
Effective in re-
ducing the volume
of the contamina-
ted substance;
several steps may
be requi red for'
lower contaminant
concentrations and
to remediate both
organic and inor-
ganic contaminants;
most effective on
low-moisture content,
low-plasticity soils
with contaminants
that ar~ not tightly
bound to soil grains.
Volume and handle-
ability of high
organic content
sediment
None.
.,.
WASTE
RESIDUALS
Concentrated waste
stream of extracted
organics require
aqueous phase treat-
I
ment; process
economies requires
extractant recycling.
Leachate from land-
fill.
Potential leachate
from disposal.
Retain. Addressf
some remedia I
action objectives
Eliminate. EPA
source control
ROD (1986)
precludes this
disposal option.
Retain. Potenti.
disposal techno-
logy if used in
conjunction with
treatment method
for wlltel
-------
TECHNOLOGY
(co,.--. 'uued)
SCREENING OF sF. ,iNT TECIINOLOGIES
COCHATO RIVER SEDIKENT STUDY
BAIRD & McGUIRE SITE
HOLBROOK, MASSACHUSETTS
SITE-LIMITING
CHARACTERISTICS
WASTE-LIMITING
CHARACTERISTICS
WASTE
RESIDUALS
.
Off-site RCRA Landfill
STATUS
ANC I LLARY
.
Hydraulic Barriers
(dikes. levees, canals.
culverts. conduits)
.
Clearing/Grubbing
.
Surface Water Pumping
3.89.48
0020.0.0
Capacity and location of
existing off-site RCRA
landfills.
None.
Heavily-wooded site requires
clearing and grubbing to
improve existing access to river;
ongoing source. control RD/RA
includes significant amount
of clearing/grubbing at the
Baird & McGuire site.
None.
Ability to store
and transport
substantial volume.
None.
None.
Potential for sub-
stantial volume
of surface water
from rainfall
tributaries and
groundwater dh~
. charge.
~.
Not applicable.
I
I
Not applicable.
Wood chips. stumps,
and logs will
require disposal.
Water requires
treatment.
Retain. Assess
cost for trans-
porting and land-
filling waste or
treat materia I
off -s i tee
Retain. Hay be
temporary or .
permanent; may
be used in
conjunction
with other
technologies.
Retain. Clearin~
grubbing necessa.
for site prepara-
tions prior to
remedial con-
struction.
Retain. Initial
activity prior t(
-------
(continued)
SCREENING m' SEDIMENT TECIlNOI.OGIES
COCHATO RIVER SEDIMENT STUDY
BAIRD & McGUIRE SITE
HOLBROOK, MASSACHUSETTS
TECHNOLOGY
SITE-LIMITING
CHARACTERISTICS
WASTE-LIMITING
CHARACTER (STICS
STATUS
. .On-site Water Treatment
At.present being designed
according to 1986 source
control ROD.
Potential for sub-
stantial volume
of surface water
from rainfall
tributaries and
groundwater dis- .
charge requiring
treatment.
.
Screening
None.
Basic screening
likely to be
necessary to avoid
damaging treatment
units.
.
Dewatering
None.
Excavated contami-
nated sediment
may require
dewatering acti-
vities, depending.
on treatment and/or
disposal scenario
selected.
.,
.
Chipping
None.
Wood and other
. solid waste in
river area will
require separa-
tion/screening
before chi pping
soUd waste.
3.89.48
0021.0. (}
~.
. WASTE
RESIDUALS
Sludge.
I'
May require
further handling
to incorporate
into waste stream.
Water requiring
appropriate treat-
ment.
Not applicable.
,
Retain. . Ponded
water would be
pumped frolD
riverbed prior to
excavation or
covering; may be
necessary in con-
junction with
hydraulic
barriers.
Retain. Necessary
for several treat-
ment technologies.
Retain. Poten-
tially necessary
for treatment/
disposal techno-
logies.
Retain. Necessar~
support technolog~
to manage solid
-------
(CO" "uued)
SCREENING OF S£ iNT TECKNOI~GJES
COCHATO RIVER SEDIHENT STUDY
BAIRD & HcGUIRE SITE
HOLBROOK, HASSACKUSETTS
TECKNOLOGY
SITE-LIHITING
CHARACTERISTICS
STATUS
. . Silt Curtains
None.
.
Trucking
Access roads required, on-
going source control RD/RA
provides access for on-site
portions adjacent to river.
.
Grading
(river access areas)
Heavily wooded site requires
clearing/grubbing to open
access for grading equipment.
On-site source control RD/RA
will provide equipment access
to river adjacent to Baird &
HcGuire site.
.
Revegetation
(river access areas,
wetlands)
Complete restoration may take
several years.. On-site source
control RD/RA will do wetlands
restoration at Baird & HcGuire
site.
3.89.48
0022.0.0
WASTE-LIHITING
CHARACTERISTICS
None.
Substantial waste
volume r~quires
trucks to transport
waste.
None.
None.
....
WASTE
RESIDUALS
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Retain. Use!ul
for temporary
control of migra-
tion of suspended
sediments.
Retain. Neces~ar:
support technolo~
for off-site land
disposal and on-
site treatment.
Retain. Likely t.:
be necessary for
some access areas I
after remedial I
acti vi ties.
Retain. Likely t
be necessary for
some access area~
after remedial
-------
TABLE 3
REMEDIAL ALTERNATIVE SCREENING SUMMARY
COCHATO RIVER SEDIMENT STUDY
BAIRD & McGUIRE SITE
HOLBROOK,MASSACHUSETTS
RETAINED ELIMINATED
FOR FURTHER FROM FURTHER
ALTERNATIVE EVALUATION CONSIDERATION
NR-l No-Action X
NR-2 Institutional Action X
NR-3 In-situ Containment X
RD-NR-l River Diversion/No-Action X
RD-NR-2 River Diversion/Institutional Action X
RD-NR-3. River Diversion/In-situ Containment X
Removal/Disposal X .
iR-l r
;R-2 Removal/Incinerate/Disposal X
R-3 Removal/Solvent Extract/Disposal X
R-4 Removal/Soli4ify/Disposal X
RD-R-l River Diversion/Removal/Disposal X
RD-R-2 River Diversion/Removal/Incinerate X
RD-R-3 River Diversion/Removal/Solvent Extract X
RD-R-4 River Div~rsion/Removal/Solidify X
3.89.48
-------
TABLE 4
PUBLIC HEALTH TARGET LEVELS FOR CONTAMINANTS OF CONCERN
COCRATO RIVER SEDIMENT STUDY
BAIRD & MCGUIRE SITE
HOLBROOK, MASSACHUSETTS
TARGET LEVEL 1 TARGET LEVEL 1
COMPOUND (10-5 RISK) (ppm) (10-6 RISK) (ppa)
Arsenic 2500 250
PARs 22 2.2
DDT 190 19
Chlordane 50 5.0
1 These concentrations correspond to the indicated risk based on exposure to a
singl~ compound and do not assume concurrent exposure with other contaminants.
.
r
3.89.48
-------
TABLE 5
TARGET LEVELS FOR SAMPLING LOCATIONS
REQUIRING REMEDIATION DUE TO ENVIRONMENTAL RISK
COCHATO RIVER SEDIMENT STUDY
BAIRD & MCGUIRE SITE
HOLBROOK, MASSACHUSETI'S
-
SAMPLE
TARGET LEVEL
(mg/kg)
1.030
0.417
0.252
0.539
0.118
0.022 .
0.009
0.071
0.190
0.028
0.051
0.439
0.066
0.457
0.309
0.246
0.152
0.004
0.356
0.378
0.060
0.536
0.670
0.053
0.922
0.798
0.760
.1. 379
0.927
SD-I07-2
SD-I07-3
SD-llO-l
SD-ll1-1
. SD-1l1-2
SD-l12-1
SD-1l2-2
SD-112-3
SD-113-1
SD-1l3-2
SD-1l3-3
SD-1l4-1
SD-114-2
SD-1l5-1
SD-l15-DUP
SD-115-2
SD-115-3
SD-116-1
SD-1l6-2
5D-1l7-1
sr-117-2
sr-120-DUP
5[;-120-2
5D-121
5t-122-1
5D-124-1
SD-124-2
SD-125-1
SD-125-2
I
TARGET
COMPOU1f1)2
Pben~nthrene
Phen~nthrene
Phen~nthrene
DDT
DDT
DDT
DDT
DDT
DDT
DDT
DDT
DDT
DDT
DDT
DDT
DDT
DDT
DDT
DDT
DDT
DDT
DDT
DDT
Chlordane
DDT
DDT
DDT
DDT
DDT
TARGET LEVEL
CALCULATION BASIS
SQC1
SQC
SQC
SQC
SQC
SQC
SQC
SQC
SQC
SQC
SQC
SQC
SQC
SQC
SQC
SQC
SQC
SQC
SQC
SQC
SQC
SQC
SQC
SQC
SQC
Upper CIV3
Upper CIV
Upper CIV
Upper CIV
.
. r
1 Sediment Quality Criterion
Z DDT = DDT and met~bolites (DDD and DDE)
~ Upper CIV = Upper Confidence Interval Value
3.89.48
-------
..
CRITERIA
SHORT-TEM EFFECTIVENESS
P~otectioD of C088UQity
Uu~iDI Re.edial ActioD
ProteetioD of Workerl
D~~iDI Re.edial ActioD
ID9i~0D8eDtl~ laplctl
fr08 le.edill ActioDI
).89.82T
0016.0.0
COtfPARATiVE SUHKARY or COCHATl
0-1
NO-ACTION
10 Idditiooal iDc~e.le
ove~ preleDt ~il"
vo~ld b. poaed.
110 additioDl1 ioc~eal.
ove~ preleDt rilkl
vo~ld be poaed.
CODtaaiDaDtl vould
~e_iD iD tb. ledi_Dt
of tbo Cocbato liveri
DO additioDal iapactl.
0-2
I 1ST I TUT I ONAL
ACTION
10 iDc~eale over
p,reaeDt ria"
voulcl be poaed.
10 acldiUoDal
iDcrea.a over
preleDt ~ilkl
would ba poaed.
CooUaioaDtl
vo~l. reaalD ili
tb. .ecli8eDt of
tb8 COChto
.helri alDtaal
i..,actl dll8 to
feDc.
CODltcucCloD.
,£8 SEDltwrr RDtIDIAL ALTERNATIVES
COCHATO RIVER SEDltlENT FfS
BAIRD' tleGUIRI SITE
HOLBROOK. tlASSACHUSEnS
n.;.]
IN-SITU
CONTAINMENT
110 iDereaae over
p~eleDt riaka
vould be pOled.
Pe~loD.l protective
equiplleDt vould
cODtrol de nul
eKfOlure pat~vaYi
celpintoq
protecUoD Dot
..,.etecl due to
lubaqueou. Clp
iD.tIUltioD.
IKfOlur. dlk would
ba aitilatad but,
vatllodl aDcI beDtblc
blbltat would'be
claltro,acl.
R-I
IWtOVAL AND DISPOSAL
Poteotial de~l
cODtaet tbreatl to
public iRbereDt vith
excavltioD aDd trlDI-
po~tatioD of eODtla-
iDlted lediaeDtl over
public rOlda. Rllkl
aiDiaized by iapleacD-
tatioD of Ipproved work
lod belltb , Ilfety
planl. DUlt expolure
Dot expected II
lediaent il aoilt.
PerlODIl protective
equip.eDt vould
cootrol deraal aDd
ioblletioD ."olura
pltbvlYI duriol
exel.ltioD. trlDI-
portaUoD. lod
clewlteriDI letivitiel.
leaovll would aitillte
rilkl to public aDd
futura beDtbic biotl
but vould dil~upt
vetllodl. Iqultic
aDd beDthic babitltl
iD proceaa.
....
R-2
INCINERATION
PoteDtil1 lir iapleta
cootrolled by
eailliooa cODtrol
devie...
Perlooll protective
equipaeoc woulcl
cODtrol de~l IDd
iobllltioD e.,olura
pltbwlYI duriol
exelvltioo. trln.-
portatioo. dewlteriol.
lod iDeioerltioD
(IDd 10lidificltioD
if oeee..lry)
openUool.
leao.ll lod treltacot
wo~lcl aiti,lta ri.k.
to public lOci future
beDthic biota b~t
wo~ld dilrupt wet-
llodl. Iq~atic Incl
beotbic hl~itltl
io procell.
1-)
SOLVENT
EITRACTIOII
'Pollible DuialDce
odor probl~
"Iodlted witb
10lveDt e~tr.ctioD
procell.
PerloDl1 proteeUvl
equipaeot woulcl
cootrol de~l IDd
iobllltioD axpol~rl
pltbwl,1 dUriD,
exel.ltioD. trlol-
po~tIUOD. Ind
'Iolveot extrlction
IcUviUel.
leaovll 10d t~elt-
acDt wo~ld aiti,lt,
ria" to public 101
f~tu~a beDthic bioi
b~t vould clilr~pt
wetllodl. Iqultic
aDd beDtbic blbitl'
iD p~ocell.
.....
~
m
r
m
-------
CRITERIA
Ti.. Uatil Re88dial
Actioa Objectivel
Aclaieved
lONG-TIM EFl'ECTIVEJlESS
tlalaitude of leddual
ltak
Adequacr 01 Coat~oll
to "Ial,. leliduall
lelilbi1itr 01 Coat~oll -
'~otecUoD fco.
..ddu"l
3.89.827
0017 .G.O
I
(coaUaued)
COttPARATIVI SUtIIARY or COCIIATO RIVU SEDIIlEHT IWflDIAL ALTERHATIVES
COCIIATO llVEI SEDIIIEHT FrS
BAllO' "cGUIIE SITE
8018I0OI. tlASSACHUSETTS
. D-I
NO-ACTIOII
raill to acbi.ve
I.di...t ~...dial
actioa objectivel.
lilkl would ~...ia ..
at p~eleat.
No additioal1 coat~DI.
would be p~ovidedi
lecu~it, feac. l~oUDd
lai~d , "cGui~e lit.
vould re..ia.
. dowDlt~ea.-coat..ia.ted
a~eal vould ~...ia
ualeaced.
10 additioDal cODt~ol.
vould b. p~ovid.d.
lecu~ity feDc. Irouad
IiiI'd , "cGui~. lit.
vould nui..
dovaltrel.-coDtl.ialt.d
Ire.1 vould r..li.
uafeaced.
0-2
IISTITUTIONAL
ACTION .
raill to Icbieve
ledi..at re..dia1
Ictioa objectivel.
'oteaUIl fo~
coat..iDlat
.i.raUoa vii
ludlCIl vlter
flov aot
ladre.led.
1.o..-tel8 d.k
~e.dDl .
poteaUIl lo~
It... ..,o.u~.
~.quhed .
a.li.. .olaly OD
'.ac. aDd
ialUtuUODlI
coatro" to
,~.v.at ..,o.ur..
raddu" rilk
vould r...ia
bi.b.
0-]
II-SITU
COHTAIIOfEHT
leduce. poteati.l
fo~ di~ect coatact.
objective. could
be acbieved i.
6 8Oatbl.
aapo.ure ~i.k. to
coatl.iaated
. ledi..at would b.
.iai..l .. loal
II CI, iate.dt,
i8 .dotaio.d.
n. ..IUII,u
Clp would ~.duc.
48181. ."olu~e lad
would Idequltely
aiDtei.. pot.atial
coat..ialat
ailrlUoo via
lu~fIC. vltee flow.
CI, tl lattcipltad
to ~...ia tatact
fo~ 30 Y.lr. Iltae
vbicb tat..dt,
i. quaIUoalbl..
I-I .
IImYAL AND DISPOSAL
le..dill IctioO
objective. Icbieved.
eacavltioa would tlke
Ipproai..tely 3 80atbl .
to coaplete. but
.edi..at reeovll
ti.ia. .ubje~t to
oa-I ite lource
coatl'ol ~...dill
activity .cbedule.
"iDi..l reddull
riak ia off-.ite
~CRA iaadfUl.
ICRA Iladfill offerl
Idequlte coatl'ol. to
..al.e..at 10a.-tel8
d.ki lucblt.
colleettoD .y.tea
ialt8ll.d ia Iladfili.
aCKA Iladfill t. I
~eli.bla t.cbaoloIJi
.0 fu~tba~ cODtroll
vould b. O.C...II'J.
.,..
1-2 .
UICINERATION
I...dhl IcUoa
objective. Icbievedi
eacI"ltioa vould tlke
Ipproai..tely 3 8Oatb.
to coaplete. but
.edi..a~ ~eeovil
tiaiD, lubject to
oa-lite lource
cODtl'ol re_dill
Ictivity Icbedule.
Relidual .Itel'i.l.
froe tactaerltioD
proce.1 ltkely to be
blzirdoul lad vould
require .ppropl'ilte
"ol.e_ot (.ol!difi-
clttoa). boveve~.
vllte. coololtdlted
It IiiI'd , HcGui~e
lite lod eun,
"DI.ed.
Relidual .Ial....ot
cootro" fo~
iactOGrltioD veil
developed.
10ciDlritioo il a
v.ll-da8Qoltrltad
rll11bla traa~Dt
tlcbRoloay lor oraa.te
cODe1aiDIDe11 ..I&d&-
fieleto. 0' ~".rdou.
iAor,.AIc r"Iduat.
reUlble.
,,-]
SOLVEHT
EXTRACTION
I...dill uUoa
objective. Icbieved
eaclvltioD vould
tlk. Ipp~o.i..tely
:I eoDtb. to coaplett.
but ledl...t ralD"a
ti.i.. .ubject to
OD-.Ue 10Ul'ce
coatrol ~e..di.l
activity .cbedule.
lelidual I'i.k ..,
l'e..iD .bould
trelt8eDt fail to
acbieve eatrlctioa
level. bovevel'.
wI.te. vould be
cOD.oUdlted It
Ilhd , HcGuhe
lit. IDd euUy
"DI.ed.
SolveDt e.t~actioD
proce.1 control
I'equh'e..atl
difficult to define
a.UabUity of
lol...t ..trectio.
tlclua.'o.,
-------
J.
CRITDIA
REDUCTIOII or ItOBILln.
TOXICITY. AND VOLUHI
4.
ItfPLEHEHTABILlTY
TecbAical Feaaibilit,
AdaiDiatnUve
FeadbiUt,
3.89.82T
0018.0.0
(Dued)
conrARATIVI SUIetAIY OF COCHA~,_.\fE8 SEDltWIT IWtEDIAL ALTERNATIVES
COCHATO llVEI SEDltWIT FrS
BAIRD' HcGUIRI SITE
IIOUROOI. tlASSACHUSEn&
lilt-I
NO-ACTIOII
110 ~ed~ctioA8'iD
8Obility. toxicit,. aD'
YolU8e aiDce DO t~eat-
_Dt ia iDvolve'.
rive-yea~ ~eviev
Deceaaa~.
110 peraUa ~e,~he'.
0-2
I IISTITUTIOMAL
ACTIOII
110 ~eductioDa iD
8ObUity.
toaidty. aDd
volU8e aiDce DO
tnat8eDt 18
iavolved.
reDCe readUy
CODlt~~cUblei
five-,ea~ ~eviev
Dece.aacy.
Lela! aenice.
fo~ iDatit~tioDal
cODt~ola
Deceaaary.
"
"'-3
III-SITU
COHTAINHEHT
110 ~ecluctioD iD
lObi lit,. toxicity.
aDd volu.e. aiDce
DO treatileDt i8
iavolvecl. cove~
..kea coataaiA8ata
Ie.. acce..ible
oDl,.
Cover .,.te.
readU,
cOD.t~~ctible
vitb .taacla~'
coa.truc:tioD
activitie_. five.
,ea~ review
aece..acy .
110 peraita
Dece...cy.
iDatit~tioDal
cODtrola vould
be Decea.aq to
preuNe cap
. iateldty.
R-l
IEItOVAL AND DISPOSAL
CODtaaiaaat
accelaibility reduced
tbroulb eXClvaUoa .
apd RCIA laocifilliDI.
DO nducUoo ia
toxicity. 8Obility.
o~ volU8e rellized.
aioce DO treat_at
iI iovolved.
Excavatioa. traDa-
portatioo. devate~iol.
water t~eat8eDt aod
off-aite dilPo.al
...il, i8ple8eDtable.
TraDlportatioa aad
diapo.al peraita
Deceala~ for off-
.ite RCIA laodfillial.
....
R-2
INCINEIATION
lociDeratioa reducea
toxicity, .obilitf.
aod volU8e of aedi-Dt
aDd deatroya orlaaic
CODIUtueota.
looe.aoic coota.ioaot
.obilitv.:aod toxicity
..y be ioc~ealecl aod
reaidual ..teeial
would eequire
lecoDdary w.ate
_oaae_ot.
TecbAolo.y de80a-
ate.ted for orlaaici.
queaUoDable fo~
teeat_ot of
ioo~laoica. .tack
800itodol
Dece..ary.
Ho peraita Deceaaary.
~e,uieea cooediDatioo
witb oo-aite lource-
cooteol r-dial
cooteactor for
iocioeratioa aad
vatelt treat_Dt
opeutiooa.
1-)
SOLVEHT
UTRACTIOII
CODt..iA8at
acce..ibiUty
red~ced tbltoUlb
excavatioD aDd
cOAaoUdatioA i
aolveAt eatraclioD
proce.. would
decrea.e coat..i-
Dated ..tedal
8Obility. toaicity
aod volU8e. but
wOl&l. leDerate
otber coot..iDated
..dia tbat would
requilte treat_At.
Solveot extltactioa
procea. aot provea
for coata.ioated
..leltial ..tria.
would Itequilte pro~
clevelop8Cot tbroul
treatability .
teaUAI.
110 pemUa
Deceaaa~. tlteat-
proceaa could
operate.
iAdepeadeAtly of
oa-aite treatmeDt
-------
CRITERIA
(continued)
COttPARATIVE SUtUtARY OF COCIIATO RIVER SEDlttENT R£Itl:.DIAL ALTERNATIVES
COCIIATO RIVER SEDIMENT n's
BAIRD' HcGUIR£ SITE
HOLBROOK, HASSACHUSETTS
NR-I
NO-ACTION
NR-2
INSTITUTIONAL
ACTION
NR-J
IN-SITU
CONTAI NH£NT
R-I
REHOVAL AND DISpOSAL
R-2
INCINERATION
R-)
SOLVENT
EXTRACTION
Anihbility of
Equipaent and
"de r h 11
COST
PH/E
**
Con.truction COlt
O&H (annual)
Five-year Review COltl
Prelent Wortb
(Toul Cost)
COKPLIANCE WITH ARAKS
OVERALL P~l.''!''!!:!!~ "I'
PUBLIC" HEALTH AND
THE ENVIRONMENT
).89.82T
0019.0.0
No equipaent or
.ateriall necel.ary.
$0
" $0
$28,000
$28,000
Doel not 8eet loall
or intent of CERCLAI
SARA or tbe NCP for.
pea.anent re8edy,
cbe.ical-Ipecific
ARABI not acbieved.
No protection of public
. bealtb or enviro~n~
over exhtiDI
conditloD~ ~ther tbao
tbroulb natural
delradative and
dispersal processel.
Services,
equipaent, and
..teriah
avanable
locally.
Services,
equip.ent, and
.ateriah
anihble
locally.
Excavation, trans-
portation, ilnd
dewilterinl equipaent,
services, and
.ilterial. available
reaionaUy. "
$881
$4841
$561C
$6281
$145K/$2.3"
$560K/$810K
$56K/$561
$7611/$).2"
$1.2H/18.2"
$0
$0
$1. 2"/18. 2H
Doel not aeet
loa h 01' intent
of CERCLA/SARA
or tbe NCP for
a pel'88nent
reaedy, che.ical-
apecific ARABI
not Icbieved.
Doel not .eet loa 11 Off-lite land dilpolal
or intent of CERCLAI witbout treilt.ent,
SARA or tbe NCP least favored action
for a peraanent under CtRCLA/SARA;
reaedy, cbe.ical- ie.oval actionl would
speciUc ARAKI " trtller location-
not acbieved. specific ARAKI.
Hini..l protection Conta.inated
to public healtb ledi.ent reaainl
prov_ded by Dut expolure
fence and silnificantly
inltitutional reduced.
cont.roh, no
protectioD of
enviroD8eot over
existinl conditions
otber tbaa tbrouab
natural delrildative
procesles.
Public bealtb
ailnific"Ptly
env i rOD8ental
addreued.
rtata
reduced,
i.pactl
Same iI. R-I. In
ilddition, incineriltor
and water treat.ent
plant provided by
on-iite lource-
control activity.
I
$1.0"/$16"
$0
$0
$1. 0"'$16H
Meets &oala and intent
of CtRCLA/SARA and
NCf; .eeta cbe.ical-
apecific ARAKI; aeets
or justifies waiver
of action-Ipecific
ARAKs for incineration
of bazardous waites;
re80val actions would
triller location-
specific ARAKI.
Public healtb
stlnifiuntly
environaental
addressed.
dlks
reduced,
i.pacts
Costs listed here do not
addition of monitoring.
alternative.
include the additio~of 300 cubic yards of sediment, nor the
Please see the ROD for a discussion of the (ost of each
**
SiI.e a. R-I. In
addition, .obile
solvent extraction
unit anilable
relionally.
$1.8"/$16"
$0
$0
$1.8"/16H
Heets loa hand
intent of CtRCLAI
SARA and tbe NCP,
.eets action-
specific ARAK. for
.ilceUaneoul unit:
under RCRA, re.OYiI
actions would tria:
location-Ipecific
ARAKs.
Public bealth rilll
silnUiuntly
reduced, environ-
.ental i.pactl
-------
(, ....-iaued)
. COtIPARATIVI SIIttIARY or COCIIATO liVER SEDlttEIIT IWIEDIAL ALTERNATIVES
COCNATO liVER SEDlttEHT FFS
BAIRD. "cGUIIUt, SID
HOLBROOK, ttASSACHUSETTS
CRITERIA
.. STAT! ACCIPfANCE
0-1
NO-ACTIOJI
0-2
IIISTITUTIONAL
ACTIOII
B-3
IN-SITU
. CONTAINHEIIT
I-I
REHOVAL AIR) DISPOSAL
1-2
INCINERATION
I-J
SOLVENT
EXTRACT I ON
To be iaco~~ated iato tbe 100.
9. COtlMUn ACCIPTANCE
To be iacocpocated iato tbe "apoDaiveaeaa SU888ry of tbe 100.
:1
....
. J..9.82T
-------
TABLE 7
. ".J... JI
-
*,~.«r
CONTAMINATED SEDIMENT EXCAVATION VOLUME ESTIMATE1
COCHATO RIVER SEDIMENT STUDY
BAIRD & MCGUIRE SITE
HOLBROOK, MASSACHUSETTS
SAMPLING
LOCATIONS
SEDIMENT EXCAVATION VOLUME (cy) BASED ON REMEDIATION TO:
PUBLIC HEALTH PUBLIC HEALTH TARGET
TARGET LEVELS CORRESPONDING TO 10-5 LEVELS CORRESPONDING TO 10-6
SD-I07/108/109
SD-ll0/111
200 200
300 300
325 325
375 375
875
.
r
425
SD-112
SD-113/114
SD-115
SD-116
SD-117
SD-120
SD-121
SD-122
775
SD-124/125/126
2,250
SD-.l30
750
1,625
SD-133/134
TOTAL VOLUME
1200 **
7,325
1
2
Volume e3timated by multiplying calculated in-place contaminated sediment
volume by 1.5 to account for over-excavation and bulking of sediment
during e:xcavation.
Public health target levels for contaminants of concern are listed in
Table 1.
** Note that this volume does not include the addition of 300 cubic yards of sediment
from: area 5D-116. Plea~e see the ROD for a discussion of this increase, for a
total of 1,500 cubic yards of sediment for removal.
7..89.27
-------
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101..01
--
--------
SITE LOCAT10N MAP
COCHATO RIVER SEDIMENT FFS
BAIRD AND McGUIRE SITE
HOLBROOK MASSACHUSETTS
-------
tlEDIA
Slirfac:e W.ter
Federal lellilatory
lequi reMota
State lelulatory
lequireMot.
..
Air
~./!III' ~.3
~! .0
it UIREtlENT
SDWA -' "CL. (40 cn
141.11 - 141.16)
SOO.A - HCLG.
(40 CFa 141.SG -
141.51)
Federal '-bieot
Water Quality
Criteria (A~)
"...achu.eU.
DriAkiol Water
Staoderd. (310
CHR 22.00)
"aa..chu.ett.
Sudace Water
Quality Staodard.
(314 CIII 4.00)
"aa.achu.ett. Air
Polilition Cootrol
leaulatioaa (310 CHR
6.04)
POTENTIAL CHI"JCAL-S~EClfIC ARAKS, CRITERIA, ADVISO~IES, ANO GUIDA~C~
COCIIATO lIVER SEDlttENT STUDY
BAIRD' "cGUIRE SIT£
HOLBROOK, tlASSACHUS£nS
STATUS
Idevaat
aod
Approp~iate
Idevaat
aOG
Appropriate
RdevaDt
aod
Appropdate
lelevaot
aad
Appropdate
AppUcable
lelevaat
aad
Appropdate
.
RE UIREttENT SYNOPSIS
".xi.u8 coota.iaaot levela (ncL.) bave
beeo pr08Ul,ated for a aU8ber of C0880a
orlaoic aad ioorlaoic coota.ioaota.
Tbe.e level. relulate tbe cpoceotratioo
of coota.ioaota io public driokiol water
.uppliea, but ..y al.o be COOl ide red
relevaDt aDd appropriate for arouDdwater
aquifera uaed for driDkiDa w.ter.
ncLGI are health-baaed criteria tbat are
uled for tbe protectioD of driDkin, water,
.ourcea aa a reault of SARA. Tbeae
uaeaforceable loala are available for a
aU8ber of orlaDic aDd iDor,anic
cooh.iaaota.
leMdial actiona involvinl coata.inated
aurface water or Irouadwater .Ult consider
tbe uaea of the Water aod tbe circU8-
ataocea of the releaae or tbreatened
releaae, tbia dete~ioe. the relevaace
and appropriateDea~.
"aaaacbuaett. adopted tbe federal SOWA
neXi8U8 Contl.iDlot Levela (HeLa) aa
it. driokinl water .tlndarda. "CL.
relulate tbe coaceotratioa of coata.iaaDt.
ia public driDkiDI water .uppliea.
Surface water qualit, .taDdard. are
apecified for tbe ..Jor .urface water
bodfe. of tbe C088oDwealtb. Surface
water. are cla..ified witb reapect to
deliloated u.e.. E.cb cl... of .urface
Water ba. a criteria a.aociated witb it
(e.I., dia.olved O.YleD, te8perature, pB,
total colifo~).
"aaalcbll.etta baa pr08UI,ated a.bieat air
qllality .taodarda for aix polllltaot.
(e.,., .ulfur oxtde., particulate ..tter,
carbon, o&oae, oitrolen, aod lead).
....
COHSIDERATION IN THE FFS
Wben tbe ri.ka to public bealth due to coa8U8pt
of aurface water were a.aealed, coaceatratioal I
conta.iaaat. of coacerD were c08pared to fedeta
HeLa. ,
"CLGa will be u,ed wbea an extraordinary ria. if
al.ocilted witb conta.ialnta ia tbe tochato Rivl
.urface water and aedi.ent.
Tbia requireMnt will be con.idered wbeD
dete~iniDI clela-up levela or poteatial
diacbar,e li.itl.
Wbea ria.. to public healtb due
of .lIrface water were aa.e..ed,
of coata.iaaata of CODcera were
to na..achu8ett. "CL..
to coaa..,Uoa
coaceatraUoa8
C08pared to
Tbe Cocblto River ia de.i,nated a. a Cia.. .
River. Action. will ta.e iato accouat tbe
de8ilalted lI.e(.) lad will c08ply with .pecified
Water qllllit, It.ndlrd..
Durial .xcavatioo Ictivitie. tbe.e .tla4Ir4. wil;
c08pUed witb.
-i
>
m
r
m
oa
-------
KEDIA
REQUIREKENT
Federal
.Criteria. Adviaoriea. aDd GuidaDce
3.89.48
~007.0.0
EPA RefereDce Ooaea
(lfDa)
EPA CarciDo.eD
Aaaeaa8eDt Group
PoteDcy Factora
Acceptable IDtake -
CbroDic (AIC) aod
SubcbroDic (AIS) -
EPA Healtb Aaaeaa-
8eDt Doc-Dta
EPA Office of Water
GuidaDce. Water-
Related Fate of 129
Priority PollutaDta
(1979) .
EPA Office of
DriDUD, Water.
Healtb Adviaoriea
AaericaD CODfereDce
of Gover_ntal
IDduatrial Hy.ieDiata
(ACGIH). Tbreabold
Li.it Valuea (TLV).
Ti8e We1.bted
Aver!!.e.. (TVAa).
aDd Sbort Tel'll
Expoaure Li.ita
(STELa).
POTENTIAL CHE"ICAL-SPECIFIC AKA
STATUS
To Be
CODa ide red
To Be
CODaidered
To 8e
CODaidered
To Be
CODaidered
To 8e
CODaidered
To Be
CODaidered
;RITERIA. ADVISORIES. AND GUIDANCE
COCRATO lIVER SEDIHENT STUDY
BAIRD' "cGUIRE SITE
HOLBROOk. tSASSACHUSEn5
REQUIIWfENT SYNOPSIS
RCDa are doae levela developed by EPA
for DODcarciDo.eDic effecta for lifeti8e
expoaure.
CaDcer PoteDcy Factora are developed by
tbe EPA fr08 Healtb Effecta A.ae.a8eDt
(HEA) (EPA. 1985). 01' evaluatioD by
CarciDo.eD Aa.ea.8eDt Group (CAG) (EPA.
1985).
AIC aDd AIS valuea are developed fr08
RCD. aDd HEAa for DODcarciDo.eDic
c08pouDda.
Tbia .uidaDce .aDual ,ivea tran.port aDd
fate iDfor88tioD for 129 priority
pollut8Dta.
Healtb Adviaori.. are eati..tea of riak
due to cODaU8ptioD of cODta.iDated
driDUD, vater.
TLVa-~Aa aDd TLV-STELa are iaaued aa
CODaeD.ua .taDdarda for cODtrolliDI
ail' quality iD workplace eDviroD8eDta.
....
CONSIDERATION IN THE ITS
Theae criteria were CODa ide red durio. the riak
aaaeaa8eDt.
Tbeae criteria wFre CODa ide red duriD, the riak
alae.a8eDt. I
Tbeae criteria were cODlidered duriD, tbe rilk
..aeaa8eDt.
Tbeae criteria were COD' ide red durio. the riak
a.aeaa8eDt.
Tbeae criteria were cOD.~dered duriD, tbe riak
aaaea'8eDt.
Tbeae criteria were cODaidered duriD. the riak
-------
MEDIA
REQUIREMENT
EfA future Interi.
Sedi8ent Criteria
Valuel for Nonpolar
Hydrophobic Oraanie
Conta.inantl (SCD
No. 17; "ay 1988)
State
"asuchuleUa
DrinUna Water
Healtb Adviaoriea
"aauchuletu
Guidance on
Allowable A8bient
Levels (AALI), cited
in Che.ical Healtb
Effects Assesl.ent
HethodololY and
HethodololY to
Derive Allowable
A8bient Leveh.
Dratt, DEQE, 1987.
(continued)
POTtNTIAL CHE"ICAL-SPECIFIC ARAftS, CRITERIA, ADVISORIES, AND GUIDANCE
COCIIATO RIVER SEDIMENT STUDY
BAIRD' HcGUIRE SITE
HOLBROOK, HASSACHUSETTS
STATUS.
To Be
Considered
To Be
Considered
To Be
Cons i dered
REQUIREMENT SYNOPSIS
These criteria have been recently
developed by [PA for 16 oraanic
co.pounds. These criteria represent
levels protective ot aquatic life.
DEQ£ Health Advisories are auidance
criteria tor drinkinl water.
This auidance evaluatea acute and chronic
toxicity and aeta dratt AALa tor 106
che.icals. Final AALs will be iaaued
in 1989.
CONSIDERATION IN THE FFS
Tbese criteria were used to aenerate aedi8ent
quality criteria values durinl the risk
alleal.ent.
I
I
Thele advisories were cOnsidered durinl the risk
assels.ent.
These levels will be considered when evaluatina
excavation and treat8ent tecbnoloaies that have
potential hazardous air e.issions.
3.eg.4~
0008.0.
.
-------
.CME~ICAL-S ,FIC ARARS
CR ITER J A. ADV J SOR u:S, AND GU IHANC~
FOR CONl'AH I NANTS OF CONCtRN
COCHATORIVER SEDIMENT STUDY
BAIRD & McGUIRE SITE
HOLBROOK, ttASSACHUSETTS
SDWA r
MCLs MCLGs
(mB/!) ~
0.50
.Massactiusetts
MCL2
~
0.050
CWA-AWQC3
Acute Chronic
~ (tJg/f)
850 48
(pentavalent)
360 190
(trivalent)
Rf04
(mg/kg/day)
1.0xl0_3
CPF5
(mg/kg/day)
1.75xl0-1
Sediment Criteria6
Mean' Values
(tJg/gC)
Arsenic
:1
Chlordane
0.000057
2.4
0.0043
1.3
DOT
1.1
0.001
3.4xl0-10
1. 15xl0"'1
0.828
PAHs8
(Phenanthrene)
139.0
NOTES:
1
EPA Safe OrinkingWater Act National Primary Drinking Water Regulations Maximum Contaminant Levels (MCLs) and MCL
Goals. Source: 40 CFR 141.
Massachusetts Department of Environmental Quality Engineering Haximum Contaminant Levels. Source: 310 CHR 22.0.
EPA Clean Water Act Ambient Water Quality Criteria for the protection of aquatic organisms. Summarized in:
Quality Criteria for Water, 1986; EPA 440/5~86-001. .
EPA Reference Dose Response for noncarcinogens. Source:
online database.
EPA Carcinogenic Assessment Group Cancer Risk Potency estimates. Source: IRIS online database.
Interim Sediment Quality Criteria Values for Nonpolar Hydrophobic Organic Contaminants. EPA Office of Water Regulations
and Standards Division, May 1988; SCD 017. .
Massachusetts Groundwater Protection Standards. Source: 314 CHR 6.07.
Polycyclic Aromatic Hydrocarbons; values given for Phenanthrene.
EPA Integrated Risk Information System (IRIS)
2
3
4
5
6
7
8
3.89.48
0005.0.0
-------
SITE FEATURE
Wetlands
Federal Relulatory
Requi re-nts
Shte Relulatory
Require_ntl
::1.419.1.,'
0010.0.
REQUlREHENT
CWA - Section 404
Fish and Wildlife
Coordination Act
06 U.S.C. 661)
Hitional Environ-
.ental Policy Act
(42 U.S.C. 4321;.
40 CFR Put 6)
Wetllnds Executive
Order (EO 11990)
"a..achusett.
Enviro08eohl
Policy Act (KEPA)
Reaulations (30J
CHi J 1.00)
I'OT£NTIAL LOCATION-SI'£ClnC AKANS, CNITt:HIA. AnVISUNIES, ANn GUIDANCE
COCIIATO RIVER SED I tfEN1' STUDY
. BAIRD' "cGUlRE SITE
HOLBROOK. HASsACHUSETTS
STATUS
Applic;able
Applicable
Applicable
Applicable
Applicable
REQUIREH£HT SYNOPSIS
Under thi. require.ent, no Ictivity
(dischlrle of dredle or fill .ateriil)
thit adversely affect. a wetlinds shall
be pef8itted if I practicable.alteroative
with leuer effects is lVailable. Per8ih
are required to be obtlined fr08 the U.S.
Ar8J Corpi of Enlineers for dredle Ind
fill activities in off-aite wetlinds.
This ICt require. tbat any federil
alency propolinl to .odify a body of
witer .uat consult witb tbe U.S. Fish and
Wildlife Services.
Sets fortb EPA policy for clrryina out the
. provisiona of the Wetlanda Executive Order
(EO 11990).
Under this order. federll aaencies are
required to .ini.ize the destruction.
losl, or dearadltion of wetlanda. and
prelerve Ind enhance nltural and'
beneficial value. of wetland..
These reaulltion. require tbat all
exceedina .pecified tbrelhold. eltabli.bed
under HEPA. requirina fundina. or requirina
a ...Jor pef8it. prepare Ind file an
EnviroR8ental Notification FOf8 (ENF). HEPA
ba. detef8ined tblt the report. lenerated
durinl Baird' "cGuire ioveltialtion.
ellentially constitute In EnviroD8ental
J.pICt Report.
..,.
CONSIDERATION IN THE FFS
Durinl the identification. screeninl. Ind
evaluation of Ilternative.. the i.,acts of
dilchlrlea of dredle and fill .aterial to the
Cocbato River Ire eVllulted. The HEPA Office
will receive copies of reports aenerlted durinl
the eVllultion Ind selection of Ire-dial
alternitive.
I
I
Requirement Iddressed under CWA Section 404.
Thi. require.ent will be considered durinl the
development of Ilternltives.
Hany of the requirements of this EO will be
Iddrelsed under CWA Section 404. Any re..inina
require.ent. will al.o be con.idered durina
the identificltion. screeninl, ind evalUltion
of Ilternative..
Durinl develop.ent of alternative. i.,.ct. to
wetlanda and floodplains will be evaluated.
-i
~
m
r
m
-------
SITE FEATURE
Wetlands (continued)
Floodplains
Federal Relulatory
RequireMnts
3.89.48
oon.o.o
REQU I REtt£NT
Wetlands Protection
(JIO CttR 10.00)
Depart_nt of
EnviroPllental
ManaleMnt (OEM)
Inland Wetland Orders
(302 CKR 6.00) .
HCRA - Locat ion
Standards (40 CFR
264.18)
National Environ-
Mntal Policy Act
(42 U.S.C. 4321.
40 CFR Part 6)
Floodplain Executive
Order (EO 11988)
STATUS
Applicable
Applicable
Relevant and
Appropriate
Applicable
Applicable
cocnATO ftl ;EDltU:NT STUDY
BAIRD & n~GUIRE SITE
HOLBROOK, tt.\SSACnUSEnS
REQUIREtt£NT SYNOPSIS
Pursuant to these reaulations, DEQE a~d
the local conservation co..issioo have
the ability to control and li.it develop-
.ent so the sianificant enviroPllental .
areas(u' outlined 10 310 CKR 10.02) will
not be adversely affected. Areas pro-
tected by the act are veaetated wetlaods
and landfor.s. land under bodies of
water. and land subject to tidal action. .
coastal stOr8 flowaae. or flooding.
Any activity proposed within one of
these areas .ust file a Notice of
Intent (NOI) with tbe Municipal
Conservation Co.-is5ion and obtain a
final Order of Condition before pro-
ceedinl with the activity.
Pursuant to tbese relulations. DE" has
authority to adopt orders restrictina
activities or uses of inlead wetlands in
order to preserve and pro80te public
~Q!:~Y. property. wildlife and w~ter
resources. and floodplain areas.
A facility located in a 100-year flood-
plain 8Ust be desianed. constructed,
operated. and .aintained to prevent
washout of any hazardous wastes by a
100-year flood.
This require_nt sets forth the policy
and auidance for carryina out the
provisions of the Floodplain Executive
Order (EO 11988). .
This order requires federal aaencies
to .ini.ize potential har8 to or within
floodplains and to avoid the lona- and
short-ter. adverse i.pacts associate~
with the occupancy and .odification
of floodplains.'
~.
CONSIDERATION IN THE FFS
Re8edial actions with associated i.,acts to
wetlands will be reviewed by the local
Conservation Co.-ission and Orders of Condition
co.plied with.
II
DE" will be appraiaed .of reMdial actions whid.
.ay i.pact inland wetlands.
lapacts of the construction and operation fro.
on-site hazardous w.ste treat_nt. storaae or
disposal facility on the floodplain 8Ust be
considered durinl the develop.ent of
re_dial alternatives.
NEPA will be considered durina the develop8ent 01
alternalives.
The require.eots 01 this EO will be considered
durina the identification. screeninl. and
-------
"T£ fUT~
floodplainl (Continued)
State R~aulatory
R~quirellenu
3..119.43
00'2.0
R£QUIREHENT
"aluchl.setta
Haurdoul Waate
"anaae.ent Rulea,
facility Location
Reaulationl (310
CKR 30.700-30.707)
"a8lachuletta
EnviroR8len~a.
rolicy Act (KEPA)
leaulaUon (301
CKR 11.00)
Wetlandl Protection
(310 CKR 10.00)
DE" Inland Wetland
Orderl (302 CKR 6.00)
(fRJI~'fllI~"J
I'OUNTlAb ~ATJON=8PgC.J"'C AMAIUi, OJTiIlJA, AIJVltiOIUU, AND GUIUANC&
CDeNATO JlI~R IEPltliNT .TUDY
lAIRD' ",GUIRE SITE
HOLBItOOI(, ttASSACtfUSETTS
STATUS
Ie levant
aad
Appropriate
Applicable
Applicable
Applicable
REQUIR£tlENT S\1fOPSIS
No new facility .ay be located in an
area ,ubject to Iloodina, within the
watershed of ,lal' A Or cla'i SA lea8ent
of a lurface water body (unless PEQ£
detef8ines these il no fealible
alternative), on la~d overlyina an actual
planned, or potential public or private
drinkina water lource, or in the flow
path of aroundwater .upplyina water to
an exi.tina well. Variance. and
exception,. are noted in the reaulations.
Thejc ie,uJationl require that all
a~tivitiel exceedina specified thresholds
established under KEPA, requirina lundina,
or requirin. a .ajor pef8it, prepare and
file an EnviroD8ental Notification fOf8
(ENT). The Secretary of Enviro,.ental
Affairl h.1 deter.ined that the reportl
aenerated durina 8aird , "cGuire
investiaatiQnl essentially constitute
an EnviroR8ental I.pact Report.
Purluant to these reaulation" DEQ£ and
the local conlervation c088il,ion have
the ability to control and Ii. it develop-
8ent 10 the ,ianificant enviroR8ental
areal (a. outlin,4 in 310 CKR 10.02) will
not be advertely .ffected. Area. pro-
tected by the act are ve,etated wetlandl
and landfof8', land under bodiel of
water, and land lubject to tidal action,
coaltal ItOf8 flowaae, or floodina.
Any 8ctivity propoled within one of
thele area. ault file. Notice of
Intent (NOI) with the "unicipal
Conservation C088i.lion and obtain a
. final Order of Condition before pro-
ceedinl with the activity.
Purluant to thele re.ulationl, DE" baa
~uthority to adopt order. reltrictin.
activitiel or Ulel of inland wetland. in
urder to prelerve and pro80te public
5.f~ty, property, wildlife and water
resources, and floodplain Itfa..
CONSIDERATION IN THE FFS
The i.pact of the cODstruction and operation of
an on-site hazardous waste treat.ent, Itora,e
or dilpolal facility on tbe floodplain 8Ust be
considered durin. the devel0Pllent of re8edial
alternativel.
,
I
Durinl develop.ent of alternatives i8pacta to
wetlands and floodplains will be evaluated.
The HEPA Office will receive copiel of reports
aenerated durina tbe evaluation and aelection
of a re.cdial alteroative..
Relledial actioos with al.ociated i8pact wetlands
will be reviewed by tbe local Cooservation
C088ilsion and Orders of Condition c08plied
with.
DEH will be apprised 01 relledial actionl that
-------
S lYE FEATURE
REQU I REtf£NT
floodplains (Continued)
Wate..ways
Re,ulalion
Pro,ra. (310 CHI
9.00)
Certification for
Dred,in" D..ed,ed
"aterial Di.posal
and Fil1in, in
Watera (314 CKR
9.00)
\
STATUS
Applicable.
.
Applicable
*Applicability pend in, "a..achusetts DEQE dete...ination.
3.89.48
0013.0.0
COCtlATO J\ . SEDItlEN1 STUDY
BAIRQ ~ ncCUIRE 511E
HOLBROOK, ~SSACHUSETT5
REQUIR£tf£NT SYNOPSIS
Any place8ent of atructure. and fill,
cban,e. in use of exi.tin, licensed
.t..uctures and fill, and dredainl in
.tate waterways .uat be reviewed and
pe...ined by DEQE (i.e., nGL C.91
Waterway. License). .
A water qualitY ce~tification ia
..equi..ed fo.. any activity tbat involve.
.dred,ina in a waterway 0.. wetland in
"as.acbusett. tbat i. al.o .ubject to
. U.S. Ar.y Corps of En,inee... Per.it,
. EPA NPDES pe...it. 0.. a na..acbusett.
Wetland. or Waterway. Orde.. of Condition.
or License. Application .ust be .ade
to DEQE to ceftify tbat a proposed
project will attain or .aintain tbe
"a..achusetta Wate~ Quality Stand...ds
and .ini.ize adverse i.,act. to
water quality.
-.-1,;,"
....
CONSIDERATION IN THE rrs
A Cbapte.. 91 License will be obtained f..08
DEQE for any activity in tbe Coebato Kiver tbat
ia ..e,ul.ted by the Waterw.y. Pro,ra..
Neee.....y applications will be filed witb DEQE
for any p..opose~lactivity that fall. unde..
-------
POTENTIAL ARAR
RCRA Hazardous Waste
Facility Hanagement
Regulations (40 CFR 260
through 268)
Clean Air Act (CAA)
Regulations. rAAQs for
Particulates (40 CFR 50)
OSHA General Industry
Standards. Recordkeeping
and Reporting. and
Standards for Hazardous
~d5Le 5iLe u~c&ations
1926. 1904. 1910 (29 CFR)
Hassachusetts Uazardous
Waste Hanagement Rules
(HHWHR) (310 CKR 30.00)
Hassachusetts
Contingency Plan
(HCP) (310 CKR 40.00)
3.89.48
"Q29.0.0
POTENTIAL ACTION-SPECIFIC ARARs
COClfATO RIVER SEDIHENT STUDY
BAIRD & HcGUIRE SITE
HOLBROOK. - HASSACIIUSETTS
.
REQUI REHENTS SUHHARY FOR FFS
If a facility operated pursuant to RCRA regulations. RCRA requirements are applicable.
If conta.inated substances at CERCl.A sites are determined to be sufficiently similar to
RCRA hazardous wastes. technical aspects of RCRA requirements are considered relevant
and appropriate. If removed froa their existing location. hazardous ~ubstances should be
handled. transported. and treated as RCRA hazardous waste. Remedial :alternatives such as
capping or incineration should be conducted consistent with RCRA landfill closure and
RCRA incinerator require.ents.
Site re.ediation activities. including excavation and treatment. must comply with
NAAQS. The .ost relevant pollutant standard at remedial response sites is for
particulate .atter.
These standards specify the type of safety equipment and other worker safety procedures
to be followed during all remedial activities.
"assachuselts is aULnorized by EPA to administer the federal RCRA prograa (up to the
HSWA aaend.ents). If a facility operated pursuant to RCRA regulations. RCRA requireaents
are applicable. Si.ilar to the RCRA regulations. these rules will be considered relevant
and appropriate at CERCl.A sites where the hazardous conta.inants have been determined to
be sufficiently si.ilar to the designated hazardous wastes. and proposed
re.edial actions are similar to hazardous waste treat.ent. storage. and/or disposal.
The HCP establishes requirements and procedures for the discovery, notification,
assessment of. and response to, releases and threats of release of oil or hazardous
.aterials.- Pursuant to HCL c21E and the HCP, the Commonwealth of Hassachusetts
publishes a list of confir.ed oil or hazardous .aterial to be tRv.ati.ated. Beelu.e the
Baird & HcGuire site h I confimed state hazardous ..terhl aft" anel lht.d on t.h"
National Priorities List. joint federal and state juri.4t~tiQR exip~M. CQgp~f-ijy~
agreements and contracts with the federal Bovcrnment sha.. iR~~rpQr~t@. ~Q ~h, ~.~.nt
possible. thedeadlin.. and Jp~cif.~atiQns of HGL ~21K and th, H~P.
... . .
~
>
m
r
m
~
a
-------
TABLE 2-5
(cootioued)
POTENTIAL ACTION-SPECIFIC ARAKs
COCHATO RIVER SEDltlENT S11JDY
BAIRD & "cGUIRE SITE
HOLBROOK. tlASSACHUSEns
POTENTIAL ARA.R
REQUIREHENTS SUKtIARY FOR FFS
I
Tbese relulatioos outline ~be staadards and require.eats for air pollutioo control in
"a.sacbusetts. Specific ~e.ulatioos lenerall, coasidered ARABs at CERCLA site. include
tbe particulate .atter Itandard (for excavation ~od treat.eot activi'ies), aDd plan
approval aod e.issioo li.itationl (for treat.eot activities, such a. iocioeratioo.
leneratinl pollutaat emi.sions).
.
"as.acbusett. Air
Pollution Control
Reauhtion.
(310 CItI 6.00
tbrouab ,.00)
I
3.89.48
0030.0.0
-------
TABLE 11 .
COHPARITIVE COST ESTIMATES FOR REMOVAL ALTERNATIVES
PUBLIC HEALTH RISK LEVELS - 1,500 CUBIC YARDS
COCHATO RIVER SEDIMENT FFS
BAIRD & MCGUIRE SITE
HOLBROOK, MASSACHUSETTS
R-I R-2 R-3
ACTIVITY COSTS ($) TOTALS ($) COSTS ($) TOTALS (f) COSTS (f) TOTALS (fl
1. CONSTRUCTION COSTS
A Site Preparation $ 21, 800 . $ 21, 800 $ 21,800
B Sediment Excavation 2 5 ,000 2 7 ,000 . 32, 600
C Monitoring During Ex-
cavation 30,000 30,000 30,000
D Sediment Dewatering 114,600 114,600 . 8,100
E Water Treatment 219 , 500 155,800 141,000
F Treatmentand/or Dis-
posali Residuals Manage-
ment, Mobilization (R-3
only) 561,900 512,900 1,156,900
G Backfill Excavated Area 4,900 4,900 4,900
H Road Closure 11 ,900 11 ,900 11 , 900
TOTAL DIRECT COSTS $ 989,600 $ 878,900 $1,407,200
I Health and Safety (10%) 98,960 87,890 140,720
J Legal, Administration,
and Permiting (5%) 49,480 43,945 70,360
K Engineering (10%) 98,960 87,890 140,720
TOTAL INDIRECT COSTS 247 , 400 219,725 351,800
SUBTOTAL 1 ,2 37 ,000 1,098,625 1,759,000
CONTINGE.NCY (20"L) 247 , 400 219,725 351,800
TOTAL CONSTRUCTION COSTS 1,484,000 1,318,000 2,111,000
II ANNUAL OPERATING COSTS
A Annual Monitoring 22,000 22,000 22,000
TOTAL ANNUAL COSTS 2 2 ,000 22,000 22,000
PRESENT' WORTHIOF ANNUAL COSTS 338,000 338,000 338,000
(30 YEARS) ~.
III TOTAL PRESENT WORTH $1,822,000 $1,656,000 P 449,000
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APPENDIX A
RESPONSIVENESS SUMMARY
.
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RESPONSIVENESS SUMMARY
BAIRD & McGUIRE SUPERFUND SITE/
qOCHATORIVER SEDIMENT STUDY AREA
HOLBROOK, MASSACHUSETTS
SEPTEMBER 1989
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U.S. ENVIRONMENTAL PROTECTION AGENCY
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BAIRD & McGUIRE SUPERFUND SITE
COCHATO RIVER SEDIMENT STUDY AREA
RESPONSIVENESS SUMMARY
TABLE OF CONTENTS
PREFACE. . .
. . . . . . . . . . . . . . . . . .
. . . .
. . . 1
I.
OVERVIEW OF REMEDIAL ALTERNATIVES CONSIDERED IN THE
FOCUSED FEASIBILITY STUDY, INCLUDING THE PREFERRED
ALTERNATIVE. . . . . . . . . . . . . . . . . . .
. . . . 3
II.
BACKGROUND ON COMMUNITY INVOLVEMENT AND CONCERNS
. . .
. .. 5
III. SUMMARY OF COMMENTS RECEIVED. . . . . . . .
. . .
. . . . 7
Comments Regarding Incineration. . . . . . .'. . . . 7
Comments Regarding Sediment Excavation. . . . . . . .14
Comments Regarding Health Concerns. . . . . . . . . .19
General Comments. . . . . . . . . . . . . . . . . . .23
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REMAINING CONCERNS. . . . . . . . . . . . . . . . . . . . 23
A.
B.
C.
D.
IV.
ATTACHMENT A - COMMUNITY RELATIONS ACTIVITIES CONDUCTED AT THE
BAIRD & McGUIRE SUPERFUND SITE .
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PRBPACB
The U. S. Environmental Protection Agency (EPA) held a 30-day
public comment period from June 19, 1989 through July 19, 1989 to
provide an opportunity for interested parties to comment on the
draft Focused Feasibility Study (FFS) and the June 1989 Proposed
Plan prepared for the Baird & McGuire Superfund SitejCochato
River Sediment Study Area in Holbrook, Massachusetts. The draft
FFS examines and evaluates various options, called remedial
alternatives, to address sediment contamination in the Cochato
River Sediment Study Area. EPA identified its preferred
alternative for the cleanup of the contaminated sediments in the
Proposed Plan issued on June 13, 1989, before the start of the
public comment period.
To facilitate cleanup of the Site, EPA has divided its
investigation of 'the Baird & McGuire Site into four segments,
known as operable units. A Remedial Investigation (RI) and a
Feasibility Study (FS) for the first two operable units
(groundwater and on-site soil contamination, respectively) was
conducted between 1983 and 1986. EPA held a formal public
comment period on its preferred alternatives for addressing these
contaminated areas and, in 1986, signed a Record of Decision r
(ROD) that established EPA's plans for Site cleanup. Extraction
and on-Site treatment were the technologies chosen by EPA to
address groundwater: excavation and on-Site incineration were the
approaches chosen to address soil contamination. The third
operable unit for the Site focuses on Site-related contamination
found in the Cochato River sediments. A fourth operable unit,
scheduled for completion in 1990, will evaluate. remedial
alternatives to replace municipal water suppliE:s lost as a result
of Site-related contamination.
The purpose of this Responsiveness Summary is to document EPA
responses to the questions and comments raised during the public
comment period on the third operable unit, the Cochato River
Sediment Study Area. EPA considered all of these questions and
comments before selecting a final remedial alte~4tive to address
sediment contamination in the Cochato River Sediment Study Area
of the Baird & McGuire Site. .
This Responsiveness Summary is divided into the following
sections:
I.
Ove~i~w of RemedtAj Alternatives ;~~:~~:~e~ ~: t~~ Focused
Feas1b1litv StudY. Includina the P 1 rn ive-
This section briefly outlines the remedi.~l alternatives
evaluated in the FFS and the Proposed Pl:!n, including EPA's
preferred alternative.
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II.
Backqround on Community Involvement and Concerns - This
section provides a brief history of community interest and
concerns regarding the Baird' McGuire Site.
III. SummarY of Comments Received Durina the Public Comment
Period and EPA ResDonses - This section summarizes and
provides EPA responses to the oral and written comments
received from the public during the public comment period.
IV.
Remainina Concerns - This section describes issues that may
continue to be of concern to the community during the design
and implementation of EPA's selected remedy for the Baird &
McGuire Site. EPA will address these concerns during the
Remedial Design and Remedial Action (RD/RA) phase of the
cleanup proqess.
In addition, two Attachments are included in this Responsiveness
summary. Attachment A provides a list of the community relations
activities that EPA has conducted to date at the Baird' MCGuirF
Site. Attachment B contains a copy of the transcript from the
informal public hearing held on July 12, 1989.
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I.
OVERVIBW OF REMBDIAL ALTBRNATIVES CONSIDBRED IX TBB FOCUSBD
FBASIBILITY STUDY, IXCLUDING THB PREFBRRED ALTBRNATIVE
Using the information gathered during the Focused Feasibility
study (FFS), including the Risk Assessment (a study that assesses
the potential risks to public health and the environment
associated with Cochato River sediment and surface water
contamination),. EPA identified specific objectives for the
cleanup of the Baird & McGuire SitejCochato River Sediment Study
Area. The response objectives are:
1.
Reduce human exposure to contaminants in Cochato River
sediments; and
2.
Reduce environmental exposure to sediments in the Cochato
river bed, the Ice Pond located north of the Site, and the
Mary Lee Wetland area north of the Ice Pond.
Compounds for which specific cleanup goals have been set include:
arsenic; the pesticides chlordane and DOT; and polynuclear.
aromatic hydrocarbons (PAHS), a group of compounds associated r
with burning of fossil fuels commonly found in urban areas.
EPA has screened and evaluated several potential' cleanup
alternatives for the Baird & McGuire SitejCochato River Sediment
Study Area. This evaluation, the FFS, describes alternatives for
addressing remediation of contaminated sediment, as well as the
screening criteria used to narrow the list to six potential
remedial alternatives: three alternatives that would not requiru
removal of contaminated sediments from the river area and three
alternatives that would require sediment removal. Each of these
alternatives is described briefly below. Additional information
on each of the remedial alternatives can be found in the Record
of Decision (ROD), copies of which are located in the Holbrook
Public.Library and the EPA Records Center at 90 Canal Street in
Boston, Massachusetts.
Non-Removal fHR) Al~.rna~iv.s
-
-
NR-l: No Act~. Under this alternative, no treatment of
contaminated sediments would be conducted. In addition, no
institutional controls (such as fencinq, wa~inq siqns, and
deed restrictions) would be implemented to reduce the
po~ential for exposure to contaminants. Site reviews would
beconducted,e"ery five years to determine if risks to
public health and the environment have chanqed.
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....
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NR-2: Institutional Action. This alternative requires no
treatment of contaminated sediments, although institutional
controls would be used to reduce the potential for exposure
to sediments. site reviews would be conducted every. five
years.
-
NR-3: In-Situ Conta!nment. This alternative would entail
construction of a multi-layer cap over the bottom of
sections of the Cochato River and certain associated
wetlands, to prevent contact with contaminated sediments.
Construction and maintenance of the cap would require the
construction of permanent roads adjacent to the river.
Removal (R) Al~erna~ives
-
R-l: Removal and Off-Site DisDosal. This alternative would
entail excavation of sediments from sections of the Cochato
River and associated wetlands. Excavated sediments would pe
transported-off-site to a federally-approved hazardous waste
landfill.
-
R-2: Removal and Incineration. Under this alternative,
excavated. contaminated sediments would be incinerated at a
specially-designed hazardous waste incinerator that would be
located on-Site as part of the overall cleanup of the Baird
& McGuire Site. .
In the Proposed Plan issued prior to the public comment
period, EPA recommended this alternative as its preferred
remedy for addressing Cochato River sediment contamination
'at the Baird & McGuire Site. .
R-3: Removal and Solvent Extract~. This alternative
would treat ex~avated sediments using a chemical process,
called solvent extraction, that would separate the
contaminants from the sediments. The concentrated
contaminants would be destroyed by burning them in an
incinerator that would be located on-Site as part of the
overall cleanup of the Baird & McGuire Site.
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II.
BACKGROU1U) ON COMMUNITY IIfVOLVBXBN'l' AND CONCERNS
The Baird & McGuire Site is located on South Street in the town
of Holbrook, Massachusetts, approximately 14 miles south of
Boston. For over 70 years, Baird & MCGuire, Inc. operated a
chemical mixing and batching facility at the Site, formulating
household and industrial products such as floor waxes, wood
preservatives, pesticides and solvents. Widespread contamination
by a variety of organic and inorganic chemicals, including
dioxin, exists at the Site.
The Baird & McGuire property is approximately eight acres in
size, and originally consisted of an office building, storage
building, tank farm, laboratory building, and mixing building.
The last three facilities were demolished by EPA during 1987
Initial Remedial'Measures (IRK) which were conducted to address
aspects of Site contamination prior to implementing long-term .
remedial measures. The 20-acre Superfund Site includes the 8-
acre Baird & McGuire property, and is located approximately 1,500
feet away from the Holbrook South Street well field. The last
operating well was closed in 1980 due to chemical contaminatio~.
. r
Approximately 2.5 miles downstream of the Site, the Cochato River
flows past the Richardi Reservoir, which serves as a secondary
surface water reservoir for the towns of Holbrook, Randolph, and
Braintree, Massachusetts. Prior to a release of Site-related
contamination into the river, water from the Cochato River was
diverted into the Richardi Reservoir through surface water
intakes. These intakes have been closed since March 1983.
The Baird & McGuire Site was added to the National Priorities
List (NPL) in December 1982, making it eligible to receive
federal funds for investigation and cleanup under the Superfund
program. In 1983, EPA conducted a removal action after a waste
lagoon overflowed into the Cochato River: a second removal action
was conducted in 1985 when dioxin was discovered in Site soils.
Further work was conducted at the Site during the 1987 IRK,
including the removal of certain site buildings and placement of
a temporary synthetic cap over site soils to prevent contact with
contaminants.
Community concern surrounding contamination at the Baird &
McGuire Sit.e has been high since the early 1980s when drinking
water well contamination in the vicinity of the Site was first
detected. Regional media coverage of Site-related activities has
been extensive. Community involvement heightened in early 1985
when a national environmental organization became active at the
Site, and over 250 letters from residents expressing their
concernu were received by EPA. In addition, a local citizens'
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\' It
qroup, People United to Restore the Environment (PURE), was
tormed at that time.
Followinq release ot the 1985 RI, EPA held a public meetinq to
present the results of the RI on June 10, 1985. OVer 200 people
attended the meetinq and presented a petition containinq over
1,000 siqnatures. Principal concerns expressed in the petition
included requests for fencinq of the Site; a comprehensive health
study: removal of Site buildinqs; diversion of the town water
main passinq throuqh the Site; testing of Cochato River water
quality; a meeting with the EPA Regional Administrator; and
citizen involvement in the development of Site cleanup plans.,
EPA promised to respond to these requests, and also invited
citizens and officials to establish an informal citizens advisory
committee to work with the Aqency. This committee, known as the
Baird & McGuire Task Force, was orqanized soon afterwards with
broad representation from both residents and local officials.
EPA has met and continues to meet reqularly with the Task Force
to present Site information and discuss issues of concern to the
community.
Public interest increased again in July 1985, when EPA discovered
low levels of dioxin in Site soils. EPA and the Massachusetts r
Department ot Environmental Protection (DEP), formerly the
Massachusetts Department of Environmental Quality Enqineerinq,
subsequently held a briefing for officials and citizens on the
implications of this discovery and the steps EPA would take to
address potential risks associated with the discovery of dioxin.
This briefinq and subsequent Site-related events received
extensive media coveraqe. '
Public involvement in the Superfund'process has continued at a
hiqh level throuqhout the vario~s steps in the remedial process,
and the EPA continues to meet on' a regular basis with the Baird &
McGuire Task Force. A public meetinq:held i~June 1989 on the
Cochato River Sediment Study Area FFS~and the Proposed Plan was
attended by approximately 30 residents, and included a
presentation by the Task Force. The principal community concerns
expressed at that time are broadly s~rized below.
On-Site Incineration. Residents expressed concern about the
safety of operatinq an' incinerator on the Site. Residents
also requested information on po~sible locations of the
incinerator and on EPA's plans for incinerator ash disposal.
Wetlands. 'Residents and officials expressed a 'stronq
interest in beinq involved in the remedial desiqn phase of
the Cochato River cleanup, an~ stressed their concerns about
potential impacts on wetlands alonq the river.
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Drinkina Water Ouality. Residents stated that they wished
to be involved in. the decision-makinq process reqardinq
future use of the Cochato River as a drinkinq water source.
Residents stated that the practice of divertinq the Cochato
River into the Richardi Reservoir should not be renewed.
III. SUHKARY OP COHKBNTS RBCBIVBD DORING 'l'HB PUBLIC COHKBNT
PERIOD AND EPA RESPONSES
This Responsiveness Summary addresses the comments received by'
EPA concerninq the FFS and Proposed Plan for the Cochato River
Sediment Study Area of the Baird & McGuire Superfund Site in
Holbrook, Massachusetts. Five sets of written comments were
received durinq the public comment period (June 19 - July 19,
1989). Six oral .comments were presented at the July 12, 1989
informal public hearinq held in Holbrook. One of these comments
was reiterated in writinq in a letter received by EPA durinq the
public comment period. All of the commenters were local
citizens, includinq one representative of the Baird & McGuire
Task Force and the Holbrook Conservation Commission. A copy of
the transcript of the hearinq held on July 12, 1989 is includedr
as Attachment B. Copies are also available at the Holbrook
Public Library, the information repository that EPA has .
established for the Site: and at the EPA Records Center at 90
Canal Street, Boston, Massachusetts, 02114 as a part of EPA's
Administrative Record.
The comments from citizens, alonq with EPA responses, are
summarized and orqanized into the followinq cateqories:
A.
B.
C.
D.
Comments Reqardinq
Comments Reqardinq
Comments Reqardinq
. General Comments.
Incinuration:
Sedim~nt Excavation:
Health Concerns: and.
A.
1.
Two commenters requested that EPA inform the Town of
Holbrook about the resul~s of the test burn as quickly as
possible. One commenter requested that EPA conduct a public
meetinq to discuss the test burn results. .
EPA's ResDonse 1:
EPA is currently conductinq a "test burn" on soil from the
Baird & McGuire Site at EPA's Office of Research and
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Development facility located in Arkansas. The test burn is
scheduled to be completed in September 1989, with results.
becoming available approximately 2 months later. The test
burn will provide information regarding optimum operating
conditions for the incinerator, and characterization of the
waste streams generated by the incineration. process for
proper handling. The test will also determine the fate of
arsenic, a metal that is not destroyed by the incineration
process, in the treated soil.
As soon as the information becomes available, EPA will
provide the information to interested citizens. The
information will also be placed in the local information
repository located at the Holbrook Town Library.
For the past several years, EPA has regularly attended the
Baird & McGuire Task Force meetings that are held evenings
at the Holbrook Town Hall on an as-needed basis. These
meetings, which are open to the public, have been found to
be an effective forum for providing information to the
community and for discussion purposes, and the Task Force
members are familiar with the Site and its history.
Although EPA does not envision holding a separate formal EPA
public meeting regarding the test burn results, EPA will.
continue to attend the Task Force meetings as a means of r
information dissemination to the community, in addition to
keeping the local information repository current.
2.
One commenter requested thatEPA provide additional
information about the noise generated by the incinerator.
EPA's Resconse 2:
EPA is aware. of the desirability of minimizing impacts, such
as noise, from remedial activities. However, any
construction activities will inherently ~e disruptive to
some degree. The design and subsequent construction will
attempt to minimize the short term impacts to reach the long
term goal of overall protection of public health and the
environment. Although the implementation of a permanent
remedy will have greater short term impacts than a "no
action" or minimal action alternative, the fact that
. contaminants will no longer be able to migrate further
downstream following completion of a permanent remedy must
be considered. .
Any remedial activity will generate some degree of noise.
However, variables such as hours of operation for
particularly noisy activities may be limited to certain
times of the day. Techniques to minimize noise and other
specific concerns will be examined during the remedial
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desiqn process. However, it is impossible for the Aqency to
predict the noise level that will be qenerated by the
incinerator, since the specific piece of equipment has not
yet been selected for the project.
Once the desiqn process is completed, the contract for
conductinq the soil and Cochato River sediment incineration
will qo out for bid. Once all of the bids are evaluated,
the contract will be awarded. It will then be the
responsibility of the contractor that is selected to brinq
an incinerator on-Site to treat the contaminated soils and
sediments. The contractor will be required to conduct a
"trial burn" on-Site to confirm that the equipment is
capable of meetinq the performance standard of decontaminat~
inq the soils and sediments and meetinq all air pollution
control requirements. Only after this capability has been
demonstrated will the contractor be qiven approval to
proceed wit~ incineratinq the (remaininq) soils and
sediments.
3.
Five commenters asked EPA to provide information about the
types of chemicals emitted from the incinerator stack, and
two commenters specifically asked to be referred to studie.
about chemical output from hazardous waste incinerators .and
health problems related to incineration. The commenters
asked EPA to provide the public with stack and air quality
test results.
EPA's ~esDonse 3:
The fundamental concept of incineration is the utilization
of extreme heat to volatilize and destroy orqanic compounds.
An afterburner on the incineration unit is used to destroy
the volatilized contaminants. The ash (decontaminated soil)
is tested to ensure that the material no lonqer meets the
definition of a hazardous waste. .
The Resource Conservation and Recovery Act (RCRA)
incineration standards, which the incinerator at the Baird &
McGuire Site will be required to tollow, specify three major
requirements reqardinq incinerator performance:
a.
The principal orqanic hazardous constituents (POHCs)
must be destroyed and/or removed to an. efficiency' of
99.99t. POHCs are hazardous orqanic substances present
in the waste which are representative ot tho~e
constituents most difficult to burn and most abundant
in the waste. The incinerator's performance in
treatinq POHCs is considered indicative ot overall
performance in treatinq other wastes.
,
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'a.
b.
, ' \
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b.
The particulate emissions must not exceed 180
milliqrams per dry standard cubic meter, corrected to
" oxyqen in the stack qas. Compliance with the
performance standard for control of particulate
emissions is documented by measurinq the particulate
load in the stack qas'durinqthe trial burn.
Gaseous hydroqen chloride (HC1) emissions must be
,reduced either to 1.8 kiloqrams per hour or at a
removal efficiency of 99%. Compliance with the
performance standard for control of qaseous HCl
emission is documented durinq the trial burn by
measurinq HCl in the stack qas. '
c.
There will also be requirements for waste analysis (before
and after treatment), operation of the incinerator,
monitorinq, and inspections.
Two published technical articles on incineration of
contaminated soils are included in the Administrative Record
for this Site. These articles describe the results of
process and emissions samplinq and analysis. ,2
The first article, nInciner~tion of a Chemically .
Contaminated Synthetic Soil Matrix (SSM) Usinq a Pilo~-
Scale Rotary Kiln System," describes the- results of two
tests conducted on soils containinq a ranqe of
concentrations, of contaminants typical ot those found
at Superfund sites. A complete series of pilot-scale
test burns was conducted and a battery of process and
emission samples were collected and analyzed. The
results from two tests indicate that the ash (treated
soil) produced by incineration met proposed requlatory
limits for all orqanics and metals, whereas the
untreated soil exceeded the requlatory limits for
orqanics. '
The second article, "ENSCO MWP-2000 Transportable,
Incinerator," describes the results of several tests
, usinq three full-scale mobile.rotary kiln incinerators.
The first trial burns were compliance tests for a State
of Florida air permit. The kiln was tested at a feed
rate of 9,600 pounds per hour of solids over a wide
ranqe of operatinq conditions. Combustion efficiency
, Esposito, M.P., M.L. Taylor, C.L. BrUffey, and R.C.
Thurnau; "Incineration of a Chemically Contaminated Synthetic
Soil Matrix (SSM) Usinq a Pilot-Scale Rotary Kiln System," 1988.
2 Lanier, J.H.; "ENSCO MWP-2000 Transportable Incinerator,"
1988.
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was consistently above 99.9', and particulate emission
levels were less than one-halt of the regulatory (RCRA)
standard. The second set of three trial burns included
PCB-contaminated soils and liquid PCBs. Destruction
and removal efficiencies (DREs) were consistently
hiqher than the Toxic Substances Control Act (TSCA)
requirement of 99.9999%. Particulate loadinq was
approximately one-quarter to one-half of the RCRA
standard. The third set of trial burns was conducted
at a site in Mississippi with dioxin-contaminated soil.
The dioxin surrogates hexachloroethane and trichloro-
benzene showed DREs greater than 99.9999', the RCRA
standard for dioxin. The particulate emission levels
were less than one-half the RCRA standard.
A third article, "Assessing the Risks o.f Incinerating
Dioxin-Contaminated Soil," published in the JUly-August 1989
edition of Hazardous Materials Control, is also included in
the Administrative Record. This article describes the
calculation of emission rates, air quality modellinq,
exposure assessment, and risk characterization in the
vicinity of incinerators operating at dioxin-contaminated
sites. The excess lifetime cancer risk predicted is several
orders of magnitude below the levels considered to be of r
concern by EPA.
It should be noted that incineration of municipal solid
waste (MSW) is a different process than high temperature
incineration of soils. Although dioxins are sometimes
generated in low levels by MSW incinerators, dioxins have
not generally been reported from testing of hazardous waste
and PCB incinerators. There are several reasons why dioxins
are not usually detected in hazardous waste incinerators,
such as. the one that has been selected in this remedy for
the Baird & McGuire Site soi1 and sedim~nt.
a.
.
Hazardous waste incinerators are desianed ~~. ~~;~mize
mixina of the waste material with combusti .
Oxyqen is required to destroy orqanics. When
sufficient oxyqen is not available, orqanics may only
be partially destroyed, resulting in emissions of
compounds such as dioxins. Hazardous waste,
incinerators are operated with excess oxyqen and are
desiqned to maximize the mixinq of oxyqen with the
waste qases. This design ensures efficient combustion
and reduces the likelihood that dioxins will be
qenerated.
b.
Hazardous waste incinerators are desianed with long
aaseous residence times. When compounds are
volatilized (evaporated) f~om the soil, the resultinq
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gas is mixed with oxygen at high temperatures to .
oxidize the organics. Hazardous waste incinerators are
designed to have at least two seconds of mixing time
for the gases at extremely high temperatures. This.
residence time is sufficient to minimize the amount of
uncombusted organics released in the incinerator
emissions.
c.
Hazardous waste incinerators are desianed to ocerate at
hiah temceratures. In addition to the long residence
times for the gases, incinerators are also designed to
operate at high temperatures in the primary combustion
zone. Gases are exposed to temperatures in excess of
2,OOOoF for two seconds in PCB incinerators. These
high temperatures, combined with good mixing and
sufficient residence time in the primary combustion
chamber, destroy any organics in the incinerator
emissions. The sophisticated design considerations
employed for hazardous waste incinerators minimize the
possibility of emissions not meeting all of the
requlatory standards.
Test burn results and final plans and specifications
developed during the design phase, as well as results of
sampling during actual incinerator operation, are public
information. EPA will share this intormation with the
public as it becomes available. EPA will provide this
information to the local information repository at the
Holbrook Town Library, as well as present the findings to
the Baird & McGuire Task Force which has been the major
vehicle for community involvement over the past several.
years. .
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4.
One commenter asked where else the parti~ular type of
incinerator proposed for use at the Site has been used.
EPA's Resconse 4:
EPA's preferred alternative calls for use ~of a.rotary kiln
incinerator for treatment of the contaminated sediments. A
rotary kiln unit was recommended because the preliminary
design of the incinerator for the Site soil incineration has
found that a rotary kiln may be the most applicable to the
Baird' McGuire Site.
There are several. types of incinerators, including
circulating or fluidized beds and infrared units. However,
these types of units generally require a smaller size feed,
(1 to 2 inches in diameter), as opposed to approximately 4
inches for a rotary kiln. Because of ,the nature of the
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contaminated Site soil and sediment, EPA believes that
callinq for a larqer feed diameter may help alleviate some
of the materials handlinq problems that may be encountered
by the other types of units.
Incineration has been used at several hazardous waste sites
nationwide. A transportable rotary kiln was used at the
Nyanza Site in Ashland, Massachusetts; the Naval
Construction Battalion Center in Gulfport, Mississippi; and
the Times Beach dioxin Site in Times Beach, Missouri. Other
sites that have used incineration include: the Arco Swanson
River oil fields in the Kenai Wildlife Refuqe, Kenai
Peninsula, Alaska; Tillie Lewis Food Cannery Site in
Stockton, California; the Cornhusker Army Ammunition Plant
in Grand Island, Nebraska; the Louisiana Army Ammunition
Plant in Shreveport, Louisiana.
5.
One commenter asked how lonq the incinerator would be used
at the Site, and expressed CQncern that toxic waste from
. other areas would be brouqht to Holbrook and incinerated.
EPAls ResDonse 5:
It is impossible to predict the lenqth of time the
incinerator will need to be on-Site, since the specific
equipment with its particular feed rate has not yet been
selected. The larqer the unit and therefore the qreater the
feed rate, the less time it will take for the contaminated
soils and sediments to be treated. It should be noted that
the incineration .of approximat&ly 1,500 cubic yards of
sediments called for in this Record of Decision is only a
small percentaqe (approximately ~') of the overall soil
incineration project.
The desiqn and subsequent contract for ~e incineration will
explicitly be only for the on-Si~e contaminated soils and
sediments attributable to the Baird' McGuire Site. Wastes
from other locations will not be shipped to the Site for
treatment.
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6.
One commenter asked EPA to provide information about the
composition of incinerator ash, ~s well as information about
plans for on-Site ash storaqe.
EPA's ResDonse 6:
A major reason for conductinq the test burn at EPA's Office
of Research and Development facility is to characterize the
incinerator ash (treated soil). Since portions of the Site
contain elevated levels of mutals which are not destroyed by
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the incineration process, extensive sampling will be
conducted to determine the levels of contaminants and how
they behave both before and after treatment. For instance,
if the mobility of the metals is increased such that the
material fails the leaching test (used to determine whether
or not a material is considered to be a hazardous waste
under RCRA), additional treatment: (such as sOlidification)-
may be required for the treated soil. The tests currently
being conducted at EPA's research laboratory will determine
whether or not any further treatment is needed, and the
results of these tests will be made available to the public
as soon as they are available.
It is assumed that the treated soil and sediment will no
longer be considered a hazardous waste under RCRA, and this
treated material will be used to backfill the site where the
contaminated soils are excavated. This assumption will be
verified by the test burn results, as well as by confirma-
tory sampling that will be required as the incineration
process proceeds. The sediment that is excavated from the
Cochato, River for treatment will be placed on-site with the
other treated soils, and will. not be used as backfill' in the
river.
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B.
Comm8Dtl-J8aar4jDq S8~ Ixcavati2g
7.
Three commenters stated that EPA should use backfill in "
excavated river bank areas and other sediment removal areas
to prevent the movement of contaminants and sediments '
downstream in the Cochato River and to prevent contaminated
sediments from getting stirred up or dissolving in the:
River. Several commenters also requested that: EPA use
backfill to cap excavated areas.
,EPA's ResDonse 7:
EPA considered the advantages and disadvantages of capping
those portions of the river where excavation will occur. In
the original preferred alternative, no capping nor
backfilling was included.' However, upon further
consideration, EPA has modified its preferred alternative
and has included limited backfilling in this Record of
Decision. '
There were several reasons EPA did not include capping or
backfilling in its original proposal. These include:
a.
I
Excavation of contaminated sediments and adjacent '.Site
soils removes the source of contamination to the "
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sediments. Once the top 6 inches ot river sediments
are excavated, the area is expected to silt in quickly
with the surrounding sediments.
b.
The groundwater extraction and treatment system will
capture the contaminated groundwater that flows toward
the 'Cochato River. (Bids have been received and award
of the construction contract is scheduled for September
25, 1989.) Additionally, groundwater flow constitutes
less .than l' ot the river flow.
Impermeable capping was not allowed as an alternative
during the 1986 Record of Decision. Capping is a
disruptive activity to the area, requiring permanent
roads along the river banks for maintenance purposes,
and making it difficult tor the river channel to
normalize. A permeable cap would not provide a barrier
to the flow of groundwater.
However, EPA has found that backfilling the excavated area
in the vicinity of the groundwater plume discharqe to the
river will not be detrimental, and has decided to include
this limited backfill as part ot the selected remedy.
Approximately 200 cubic yards ot clean backtill material
will be placed in excavated areas ot the river in the
vicinity of the groundwater plume discharge to the river.
c.
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8.
One commenter stressed the importance of ensuring that none
of the river banks are damaged or disturbed during the
cleanup. .
EPA's Resconse 8:
As stated in Response 2, remedial activities are necessarily
disruptive to some degree. However, the design process will
examine ways ot minimizing damage to the adjacent river
banks during construction.
As is shown in the FFS, an excavation'access road will need
to be constructed along one side of the river to reach the
remediation areas. A portion of this access road is in the
industrial area on the eastern side of the Cochatci River, an
area that is already developed. Another portion nf the
access road is within the Baird & McGuire property. ,
Excavation access roads will utilize existing secondary
roads to the extent possible. However, the limited areas
that will be developed for new e~cavation access roads will
be restored once construction is complete.
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9.
Two commenters requested that EPA install a monitorinq
system to detect the downstream movement of sediments and
the presence of dissolved contaminants in water.
EPA's ResDonse 9:
The remedial desiqn will include provisions for monitorinq
the surface water of the Cochato River when excavation is
conducted. Excavation will be conducted with a mechanical
excavator, and operations will attempt to minimize sediment
resuspension. In addition, silt curtains (barriers to
prevent downstream miqration of sediments) will be utilized
in several locations throuqhout the excavation area to
minimize any potential downstream transport of sediments.
With reqard to dissolved contaminants, no Site-related
orqanic nor inorqanic contaminants of concern were detected
in the surface water samplinq that was conducted as a part
of the FFS. Based on the observed concentrations of orqanic
contaminants in sediments and their associated distribution
coefficients, the total concentration of dissolved orqanic
c~ntaminants that may exist in solution durinq dredqinq is
estimated to be less than approximately 2 microqrams per
liter (uq/l or ppb). This dissolved concentration is r
calculated assuminq conservative sediment concentrations and
that maximum concentrations of contaminants of concern are
cO-located, which they are not. Calculated concentrations
of individual contaminants of concern ranqed from 0.45 uq/l
for chlordane to approximately 1.1 uq/l for DOT and
metabolites. There are no Maximum Contaminant Levels (MCLs)
for any of these contaminants of concern. The calculated
concentrations are less than or equal to the acute u.S. EPA
Ambi~nt Water Quality Criteria (AWQC) for protection of
aquatic life. These calculations are included in the
Administrative Record.
The inorqanic contaminant of concern, arsenic, was not
detected in December 1987 or April 1988 surface water.
samplinq of theCochato River. The environmental fate of
arsenic is described in the "Technical Memorandum: Summary
of 1988 Sediment and Water Samplinq Proqram" included
located in the Administrative Record. The discussion on the
fate of .arsenic is summarized below.
Arsenic is considered to be mobile in the environment and
capable of cyclinq throuqh.the atmosphere, water, sediments,
and biota by several mechanisms. Arsenic can be stable in
natural waters in four oxidation states, but qenerally
occurs either as arsenate (+5), arsenite (+3), or in
methylated species.. Arsenate predominates in most natural
surface. waters, but arsenite is more likely to predominate
in mildly reducing conditions.
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10.
Sorption and desorption of arsenic to sediments dominate the
cyclinq of arsenic in the environment. Sorption to or co-
precipitation with hydrous oxides of iron is the major
process in the removal of dissolved arsenic. Conversely,
reducinq conditions which convert iron (+3) to iron (+2) may
indirectly increase arsenic by dissolution of hydrous iron
oxides to which arsenic is bound. Arsenate ions are readily
fixed by clay and humic content of soils, and by iron and
aluminum oxides. Adsorption is most important in aerobic,
acidic, freshwater conditions such as those likely to exist
in the Cochato River. Arsenic is less likely to be adsorbed
and more likely to remain dissolved as conditions become
increasinqly reducinq, alkaline, or saline.
The adsorption of arsenic to sediment is not an entirely
reversible process and the sediment usually acts as a sink
for arsenic~ Available information indicates that the
distribution coefficient for soil desorption is
siqnificantly qreater than that expected if only adsorption
were involved, and is a function of soil chemical. .
composition, includinq soil pH and iron oxide concentration.
. .
Calculations of dissolved arsenic concentrations in the r
portion of the Cochato River beinq remediated were estimated
usinq a ranqe of desorption partition coefficients and
averaqe sediment arsenic concentrations; these are included
in Administrative Record. These calculations indicate that
dissolved arsenic concentrations will be less than the MCL
of 0.050 mq/l and the acute freshwater AWQC tor protection
ot aquatic life of 0.36 mq/l. Calculations usinq one half
of the maximum arsenic concentration detected in the
remediation area indicate that dissolved arsenic
concentrations may exceed the MCL and AWQC values when the
area of maximum arsenic concentration is excavated. These
exceedances should be transient and will be mitiqated by
reabsorption and dilution.
The Massachusetts Department of Environmental Protection
(DEP) stated that it concurs with the choice of remedial
action selected for the Cochato River Sediment portion of
the Baird' McGuire Superfund Site. The DEP expressed
concern that EPA has not considered environmental effects
resultinq from the use of silt curtains durinq sediment
removal activities, and requested that EPA provide
additional information reqardinq how well the proposed
curtains will minimize downstream impacts durinq dredqinq.
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EPA's ResDonse 10:
silt curtains are a construction technique used to help
minimize sediment transport. However, there is little
specific information on the use of silt curtains in river
settings. silt curtains are not recommended for use in
current velocities greater than 1.6 feet per second, in
areas with high winds and large breaking waves, or in
situations where frequent curtain movement is required.
None of these conditions exist in the Cochato River.
The Army Corps of Engineers (COE) concluded that silt
curtains were an appropriate sediment control technique for
use in the upper New Bedford Harbor. The COE found an
anchored filter-fabric silt curtain to be effective in
minimizing sediment transport during pilot dredging in the
harbor. COE information on silt curtains for turbidity
control and. a design schematic for silt curtain deployment
in New Bedford Harbor are available in the Administrative
Record. Suspended sediment controls will be considered
during the design phase for this operable unit, and
additional or alternative techniques will be examined and
deployed, as appropriate. .
The silt curtains will be removed at the completion of
excavation activities, and any captured sediment will be
incinerated with the other excavated sediments.
Additionally, monitoring will be conducted during excavation
activities. .
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11.
One commenter noted that high levels of contamination are
present in wetlands,-and requested that EPA maintain ongoing
communication with the Holbrook Conservation Commission and
notify the Commission before conducting any activity that
might affect the wetlands area. .
EPA's ~esDonse 11:
The major mechanism by which EPA keeps local officials and
interested citizens informed of Site activities is through
the periodic Task Force meetings that are held in Holbrook.
A member of the Holbrook Conservation Commission attends
these meetings on a regular basis, and all interested
parties are encouraged" to attend.
In addition, EPA periodically conducts public ~eetings and
mails fact sheets and/or Site updates to interested
citizens. The Holbrook Conservation Commission is on the
EPA mailing list for the Baird' McGuire Site, and will
continue to receive information updates from the Agency
regarding Site activities.
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12.
The same commenter asked EPA to explain what activities
would be conducted in wetland areas and when these
activities would take place.
EPA's ResDonse 12:
This Record of Decision explains the activities that are
planned for the Cochato River portion ot Site activities.
The remedial desiqn process will provide much qreater detail
on activities that will impact wetland areas.
Generally, any necessary clearinq and qrubbinq for the
excavation access roads will be conducted alonq one side of
the river. Upon completion ot sediment excavation, these
temporary access roads will be closed and the area will be
reqraded to approximate the oriqinal contours. Reveqetation
of these areas may also be warranted.
Please see Response 2~ for a discussion of when Site
activities may occur.
C.
Comments R8aar4ina Health Concerns
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13.
One commenter stated that there have been tive cancer cases
in the neiqhborhood borderinq the Site and requested that
EPA provide information about health problems that may
result from air pollution and water contamination at the
Site. .
EPA's ResDonse 13:
The only intornation that the EPA is
health effects are two epidemioloqic
Town ot Holbrook. These two reports
AdJbinlstrative Record tor the Site.
aware of reqardinq
reports that cover the
are included in the
a.
The first report, "Epidemioloqic Analysis: Holbrook,"
analyzed cancer mortality data for the IS-year period
from 1969 to 1983. Durinq the first two five-year
periods, there were no statistically siqnificant .
elevations in cancer mortality. For the third five-
year period, the "all cancers" mortality rate was not
siqnificantly elevated, but statistically siqnificant
elevations were evident in males for both cancer of the
bronchus and lunq and bladder cancer, as well as other
female organs. The primary risk factor for cancer of
the bronchus and lunq is ciqarette smokinq, but
possible occupational exposures would also need to
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evaluated. In the other elevations, the number of
cases is small and it is unlikely that an environmental
association could be made.
Available cancer incidence data from 1982 and 1983
reveal that no significant elevation exists in any type
of cancer in Holbrook. Although the cancer incidence
rates for the Town of Holbrook as a whole were not
significantly elevated, further analysis of residential
data was conducted. The place of residence for all of
the incident cases were plotted. The geographic
location of these cases appears to be evenly
distributed throughout the Town of Holbrook, which does
not suggest an association with the Baird & McGuire
Site.
b.
The second report, "An Epidemiologic Investigation of
Adverse. Birth Outcome Data for Holbrook and Surrounding
Communities: 1980 - 1984," examined adverse pregnancy
outcome data for Holbrook and the six communities
surrounding Holbrook: Abinqton, Avon, Braintree,
Brockton, Randolf, and WeYmouth. The investigation was
undertaken in response to concern over contamination at
the Baird & McGuire Site. .
r
Adverse pregnancy outcomes, including congenital
anomalies, fetal deaths, neonatal deaths, infant
deaths, and low birth weights were examined for the
. period 1980 - 1984. No statistically significant
elevations in the rate of adverse pregnancy outcomeS
were observed for Holbrook. A plot of fetal, neonatal,
and infant deaths did not reveal any unusual geographic
clustering surrounding the Baird & McGuire site. No
time-related clustering of adverse pregnancy outcomes
was found. . .
Additionally, a Health Assessment is currently underway for
the Site, which is being conducted by the Massachusetts
Depart of Public Health (DPH), on behalf of the Agency for
Toxic Substances and Disease Registry (ATSDR). This
Assessment will update the information in the two reports
listed above, as well as examine the need for a health
study. Once this Health Assessment is completed, it will be
made available to the public.
~ .
14. . One commenter stated that the Baird & McGuire Site is
directly responsible for the sickness and deaths of
residents bordering the site.
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EPA'S ResDonse 14:
Please see Response 13 for information regarding the
epidemiologic investigations that have been conducted to
date for the Town of Holbrook.
15.
One commenter expressed concern about the health effects
that have resulted from Site contamination, and asked that
"no furthe): harm" be caused by cleanup methods used at the
Site.
EPA's ResDonse 15:
Remediation will be conducted in a manner that minimizes
impacts to surrounding areas. Air monitoring will be
required to ensure that allowable levels of contaminants are
not exceeded. Potential techniques to minimize air releases
include the use of sophisticated air pollution control
devices on the incinerator (stack), and limiting the extent
of excavation at anyone time, particularly for the on-Site
soil "excavation portion of the remedial activity.
Excavation activities will be controlled so that releases of
soils will not occur. Work areas will be designated as r
either contaminated, a decontamination zone, or as clean
unrestricted areas. Site activities will be conducted such
that these designations are maintained.
16.
DEP stressed that, to achieve a permanent solution, the
remedial action must reduce significant risk to below a 1 in
100,000 (10.5) risk of cancer, and reduce contaminant levels
to an estimated daily dose equal to 20 percent of the
acceptable intake of the contaminants.
EPA's ResDonse 16:
All 102 contaminants originally evaluated in the Baseline
Ri~k Assessment for the Site were re-evaluated during the
selection of contaminants of concern for the Cochato Rivel'
FFS. The levels of arsenic, DDT, chlordane, and
carcinogen~c PABs at the Site were associated with elevatE!d
carcinogenic public health risks.
The remedial action called for in this Record of Decision
will reduce the Site risk to a 1 in 1,000,000 (10.6) e>:ceus
risk of cancer for three of the four contaminants of
concer~. The only contaminant of concern that will achieve
the 10. risk level is PABs, which are found widely
throughout the Cochato River drainage basin. See Sect.ion
X.A.1 of " the ROD for further discussion. "
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It should be noted, however, that the 1986 ROD extent of on-
site excavation was influenced by the surrounding wetlands
and concern for their impacts. The areal extent of
excavation was scaled back such that remaining areas will
approach the 10-4 risk level. Therefore, only until the
excavation and confirmatory sampling is conducted will the
Agency be able to document the level of cleanup that is
actually achieved. .
Noncarcinogenic compounds were also detected at the Site,
but below concentrations considered to present a public
health risk. Selected noncarcinogenic compounds were
quantitatively evaluated during the selection of the
contaminant of concern process. Exposure to lead via the
ingestion of surface water was examined as a part of this
process. The highest lead concentration detected in the
unfiltered surface water of the Cochato River was 0.008 ppm
(8 ppb). This value is below the MCL for lead of 0.050 ppm.
Examination of historical data and additional sampling
undertaken as a part of this FFS does not indicate the
presence of lead in surface water in excess of appropriate
health-based criteria. Since exposure to lead was not
considered to present a public health risk, it was not
evaluated further in the risk assessment.
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17..
One commenter stressed that EPA should "ta~e the site
cleanup seriously" and indicated his concern that EPA is
evaluating cleanup options by focusing on costs instead of
public health issues.
EPA's ResDonse 17:
EPA has already committed extensive resources to the Baird &
McGuire Site, and the Agency continues to do so. To address
the public health issues, EPA has conduc~ed a variety of
activities, including: the installation of fencing, a
groundwater recirculation system, and temporary capping; the
demolition of two Site buildings and the tank farm; and the
rerouting of a water main that used to pass through the
site. The remedy selected in this ROD calls for protection
of public health through the excavation of contaminated
sediments.
EPA's primary focus is to achieve adequate protection of
public health and the environment. However, Congress also
requires the EPA to select a cost-effective remedy.
Therefore, the Agency must consider a number of factors in
its assessment of alternatives for a given site. These
factors are discussed more fully in the Record of Decision,
~articularly in Section XI.
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D.
General Comments
18.
One~ommenter requested that Site activities be publicized
more widely and requested more reporting and advertising in
the Holbrook Sun and Brockton Entercrise. This commenter
also requested specifically that future meetings be
advertised on cab~e television.
EPA's ResDonse 18:
The Holbrook Sun and the Brockton Entercris~ are on EPA's
mailing list for the Baird & McGuire Site, as are other
local newspapers. EPA periodically issues press releases
when major milestones are reached at the Site. In addition,
the Baird & McGuire Task Force meetings are covered by the
local cable television station. .
The commenter may wish to contact the newspapers of interest
directly to express their interest in continuing coverage of
the Baird & McGuire Site activities.
19.
.
One commenter stated that she would not support a cleanup. r
plan that allows water flowing through the Site to be used
as part of Holbrook's drinking water supply.
EPA's ResDonse 19:
Prior to the release of contaminants into the Cochato River
-in 1983, the Cochato was diverted into the Richardi
Reservoir approximately 2.5 miles downstream of the Site.
Since the 1983 release, this diversion has 'been closed.
Several rounds of surface water sampling conducted by EPA at
various times have not indicated any detectable levels of
Site-related contaminants. .
Any decision on the use of the Cochato River for drinking
water purposes rests with the local authorities and with
CEP.
IV.
RBKAIlfIlfG COKCBDS
Issues raised during the public comment period that will continue
to be of concern as the Site moves into the RD/RA phase are
described briefly below, along with EPA's responses. EPA will
continue to address these issues as more information becomes
available during the RD/RA.
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20.
One commenter requested that EPA establish a long-term
environmental monitoring program at the site to ensure that
risks to the environment and public health are no longer
present.
EPA's ResDonse 20:
Monitoring will be included as a part of the remedial
activities conducted at the site. For example, as a part of
the groundwater extraction and treatment system (first
operable unit), monitoring of a series of wells surrounding
the site is included until the cleanup standards are
attained for a period of time.
Additionally, for this operable unit, monitoring during
excavation and long-term monitoring was added in response to
public comments. Long-term monitoring will be conducted for
the downstream portions of the Cochato River that will not
have sediments excavated. Data will be collected and
analyzed on an annual basis, and 5-year reviews will be
conducted in accordance with the statute.
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21.
One commenter expressed concern about the possibility that
the water treatment plant would be operatinq before the
incinerator is brought on-site. The commenter explained
that this sequence would result in on-Site storage and
dewatering of sediments prior to incineration.
EPA's ResDonse 21:
There will be a number of remedial activities ongoing at the
Site, and these activities will be integrated throughout the
course of remediation of the Site. Reme~iation of Cochato
River sediments will be scheduled after the groundwater
treatment has begun, and so as not to interfere with on-Site
actions. .
Sediment remediation will rely to the extent practicable on
facilities that will exist and operations that will be
conducted on-Site. On-Site facilities that may be utilized
include the groundwater treatment plant for treatment of
dewatering effluent, the on-Site incinerator for sediment
treatment, and the haul roads, decontamination facilities
and soil staging area. Additional operations that are.
important for sediment remediation include the ,relocation of
unnamed brook, clearing and grubbing, construction of
temporary haul roads, and flood control measures.' '
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b.
Inteqration of the schedules of the sediment remediation and
the other on-Site remediation activities is important for
two reasons. .
a.
Timinq of the sediment excavation relative to the
initiation of other on-Site activities will impact the
effectiveness of the sediment remediation.
The orqanic-rich sediment in the Cochato River
apparently serves as a filter for contaminants in
qroundwater, reducinq concentrations as qroundwater
discharqes to the river. Excavation of river sediment
will not occur prior to the startup of the qroundwater
extraction and treatment system.
The contract for the qroundwater treatment system is
pendinq.award. Assuminq an award date of fall 1989
with a one and one-half year construction period, the
on-Site qroundwater treatment would be operational in
the sprinq of 1991. This allows time for the remedial
desiqn, contract biddinq and award for the sediment
remedial activities.
. .
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Sediment remediation activities will need to be
undertaken to take advantaqe of facilities to be
constructed or operations to be conducted as part of
overall remediation activities. .
The scheduie that is developed as the remedial desiqn
proceeds will attempt to factor in the timinq of the
various activities. In particular, the desiqn ot the
on-Site incinerat~r is scheduled for completion in the
summer of 1990, with contract biddinq and award
occurrinq subsequ~nt to the completion of the desiqn
and the receipt of remedial action fundinq.
Should the on-site incinerator not be operational prior
to excavation of the sediments, excavated sediments
would be stockpil~d on-Site in a secure manner until
the treatment system was available.
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ATTACHMENT A
COMMUNITY RELATIONS ACTIVITIES
CONDUCTED AT THE
BAIRD & McGUIRE SUPERFUND SITE
.
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COMMUNITY RELATIONS ACTIVITIES
CONDUCTED AT THE BAIRD & McGUIRE SUPERFUND SITE
Community relations activities conducted at t.he Baird & McGuire
Superfund Site include the following:
March 1983 - EPA, DEQE and local
Superfund remedial action plans.
mandatory cleanup and preventive
Baird & MCGuire, Inc. by EPA and
officials met to discuss
This meeting resulted in
measures being imposed on
the Town of Holbrook.
April 1983 - EPA released a preliminary site assessment.
May 1983 - EPA released a Remedial Action Master Plan
(RAMP), a work plan to address emergency conditions at the
Site.
May 1983 - EPA issued'a Community Relations Plan for the.
Site.
1983 - Information repositories were established at the
Holbrook, Braintr~e and Randolph Public Libraries. .
August 23, 1983 - EPA issued a press release announcing that
an additional $165,000 in funding was approved to conduct
cleanup and planning work at the Site. .
.
r
October 5, 1983 - EPA issued a press release stating that
the Agency had filed suit against Baiz'd & McGuire to recover
past and future Site cleanup expenses. .
December 12, 1983 - EPA announced the approval of $295,000
in additional funds to conduct waste removal and grading
activities at the Site. The funds would also be used to
update hydrogeologic studies.
. .
April 20, 1984 - EPA issued a press release announcing the
public availability a Remedial Investiga~ion (RI) Work Plan
which details studies to be conducted th,lt would lead to the
selection of a long-term remedy for the Site.
May 1985 - EPA released a draft RI tor t~he,Site.
June 1985 - EPA held a public meeting a~d accepted pUbiic
comments on the RI. EPA also announced that a Phase II RI
would be conducted.
July 1985 - EPA assisted in the orga:}ization of the Baird &
McGuire Task Force. This Task Force has continued to meet
regularly to review technical documents and Site activities.
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concerned citizens and qovernment aqencies. EPA
representatives have attended these meetinqs since the Task
Force was first established.
July 1985 - EPA issued a press release statinq that low
levels of dioxin had been detected in Site soils. The
release further explained that EPA is workinq closely with
the federal Centers for Disease Control, DEQE and the
Massachusetts Department of Public Health to assess the
public health impacts of these findings.
1985 - EPA announced that Initial Remedial Measures (IRK)
conducted at the Site would include demolition of Site
buildings, relocation of an on-Site water main and
additional capping of soil "hot spots."
August 15, 1985 - EPA announced the results of dioxin
sampling from the Site. EPA solicited input from local
officials and residents regardinq sampling locations and
incorporated local sugqestions into the Aqency's samplinq
plan.
October 2, 1985 - EPA announced the results of pesticide,
herbicide and dioxin samplinqfrom Site soils. .
.
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June 30, 1986 - EPA issued a press release announcinq the
completion of the Phase II RI. EPA also provided
notification of an August public informational meetinq and
an August hearing to review the results of the RI. The
release stated that copies of the RI are available for
public review. .
July 22, 1986 - EPA issued a press release statinq the
availability of the final Feasibility Study (FS) for the
Site.
July 1986 - EPA sent copies of a fact sheet summarizinq the
RI/FS to concerned citizens and to the information
repositories for the site.
August 6, 1986 - EPA issued a press release statinq that the
dates for the RI/FS public meetinq and public hearinq would
be chanqed. The release stated that the public
informational meetinq would be held on August 20; the public
hearing would be held on September 3; and the public comment
period would take place between August 13 and September 8,
1986.
August 20, 1986 - EPA held a public informational meeting to
present the results .of the RI/FS,.etnd to discuss proposed
cleanup plans for the Site~ . ..... ... ... .
September 3, 1986 - EPA held an informal public hearinq to
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the RI/FS and the remedial alternatives that are beinq
evaluated for the Site.
September 30, 1986 - EPA siqned a Record of Decision (ROD)
outlininq a phased remedial action plan for the Site.
January 6, 1987 - EPA
EPA and the PRPs have
public comment period
decree.
issued a press release announcinq that
siqned a consent decree. A 30-day
follows the siqninq of the consent
February 1987 - EPA allocates $500,000 for a new water main
at the Site as part of the IRK initiated in 1985.
May 1987 - EPA allocates fundinq for buildinq demolition at
the Site; demolition activities are initiated.
July 1987 - ~PA issued a revised Community Relations Plan
for the Site.
1988 - Remedial desiqn of the on-Site qroundwater extraction
and treatment system proceeds; various desiqn documents are
provided to the Task Force for review and comment. The
Focused Feasibility Study (FFS) for the Cochato River r
Sediment Study Area continues; various technical memoranda
are made available.
June 1, 1989 - EPA issued a press release announcinq that a
public meetinq would be held June 13 to discuss cleanup
alternatives to address theCochato River Sediment Study
Area.
June 1989 - EPA distributed a fact sheet summarizinq the
results of the FFS for the Cochato River Sediment Study Area
and describinq the Proposed Plan to address sediment
contamination to concerned citizens and local officials in
the Site area. ..
Jyne 13, 1989 - EPA held a public informational meetinq to
present the FFS report and Proposed Plan to address
contamination in the Cochato River Sediment Study Area. EPA
announced that a public hearinq would take place on July 12
reqardinq the Proposed Plan, and a 30-day public comment
period on the Proposed Plan would beqin on June 19.
July 12, 1989 - EPA held an informal public hearinq to
accept comments on the FFS and the Proposed Plan for the
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ATTACHMENT B
TRANSCRIPT FROM THE INFORMAL PUBLIC HEARING
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5 II In the Matter of:
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6 I PROPOSED PHASE III CLEANUP PLAN FOR THE
BAIRD & MCGUIRE SITE/COCHATO RIVER SEDIMENT
7 I: STUDY AREA, PUBLIC HEARING
UNITED STATES OF AMERICA
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ENVIRONMENTAL PROTECTION AGENCY
REGION ONE
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Wednesday
July 12, 1989
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HOlbrook High School
Franklin Street
Holbrook, Massachusetts
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The above-entitled hearing was held pursuant
15 Ii to Notice, commencing at 7:45 p.m.
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RICHARD CAVAGNERO, Chairman
u.S. E.P.A.
Superfund Section
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MARY SANDERSON
U.S. E.P.A.
Remedial Project Manager
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APEX Reporting
Rtgisttrtti Proftssiona/ RtfJorttrs
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f_B_Q_~_5_5_Q_I_~_@_3
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(7:45 p.m.J
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THE PRESIDING OFFICIAL:
G,:II:.d evening.'
4
I guess we have everyone who is coming and
5
we should be getting started.
6
My name is Richard Cavagnero.
I w':.r k f 0::"-
7
EPA and the Chief of the Massachusetts Superfund
8
Section, and I'm responsible for managing the site
9
managers, like Mary Sanderson, who manage the Superfund
10
sites within the State of Massachusetts.
And I'm g,:.ir,g
11
t.:o be
the Chairman, I guess, of this meeting tonight.
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And, again,
I want to welcome you
a:' 1.
13
Thank you for coming.
14
The purpose of this hearirig tonight is to
15
a c c:ept
c.:,mments ':,n the
reme~ial investigati~~ aMd
16
feasibilit/ study and proposed plan for the remediation
17
01 a portion of the Baird~ McG~ire site,
located ,here
18
in Hc.l br'j,:.k.
19
Specifical:'y,
what we are looking for
20
comments is on the proposed plan for
the remediation o~
the Cochato River sediments as opposed to other as~ects
of the cleanup which are ongoing, including the
groundwater tr~atment, the incineration of soils, et
cetera.
~ith me on my left, to your right, I guess,
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is Mary Sanderson, who is the site manager or remedial
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project manager for the ~ite.
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I'd first like to talk about the format for
4
the hearinc;.
5
Mary will be giving you a brief overview of
6
the proposed plan for the Cochato River sediment
7
remed ia t ic.n.
8
As I hope many of you know, EPA was down
9
here c.n JI.lne 13,
along with our contractor, E. C.
10
J.:.rdan,
and gave a fairly detailed presentation of this
11
plan, along with some of the other alternatives that we.
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12
looked at and held a question and answer period.
13
Mary is just going to recap that, will not
14
be going into a great deal of detail.
15
There were
han~out5 on your
'.Jay irl ir. the
16
sign-I.lp a'l"sa,
I gl.less.
There is a one pa~er that had,
17
r gl.less,
the press release for the original public
18
....
mee..J.i.;.
And therE also was ~
c.:.py .:.f the
pr ':. ;:.:'5ec
19
plan, 15 or 20 pages, I guess,
whi ch ':Igain o:,IJt 1 ines the
20
alternatives we
looked at and the one tnat we are
21
reco:.mmending.
S.:., again,
Mary will be giving a very brief
,:.verv iew.
But the main purpose is then for us to take
any ,:,ral
comments you wish to make for the
rec.:,rd.
I have been given a list. pu.:.ple wh.:. signed
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up and indicated that they wished to make comments, and
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we'll be going through that, basically in the order we
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have them.
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If, once we get through that, other people
5
decide they want to make them,
you're certainly welcome
6
to do so.
We just need
to get
your name so that we get
7
the proper spelling for the transcript.
8
Once you make your comment, Mary
or ! or
9
both mai ask you some questions, j~st to make sure that
10
we understand exactly what your comment is, because
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once we finish the hearing tonight, essentially we have
12
to go back and write what's called the record of
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decision.
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This is a document that will be signed by
1~
our boss,
the Regional Administrator, and it will be
16
the "document that legally describes what the remedy
17
will be
for this portion of the site.
18
This will be based essenfially
on our
19
proposed plan and any comments we received from the
public, either that we receive at tonight's meeting
orally or any written comments that you wish to submit.
The comment period did start on June 1~th
and will run through July 1~th, which I believe is next
Wednesday.
So if you do wish to make any written' "
comments, either instead of oral
comments tonight or in
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addition to those,
I would encourage you to do so.
And
2
we need to have you postmark them no later than
3
July 19th and mail them to us.
4
The appropriate address is found on Page 2
5
':' f the
p'!":'p.:,sed
plan that,
again, was available a month
6
ago and also is available on the table in the sign-up
7
area.
8
At the conclusion of the meeting, I would
9
ask you ~o either
check
with
myself or Mary if you have
10
any questions about the process f6r making comments.
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We want to make sure that you fully understand what you
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need to do to get your comments on the record.
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We will be preparing, as I said, the
rec,:,rd
14
of decision for the site.
And as part of that record
15
cf decision, we'll prepare & document called the
16
response of the summary,
and essentially this is going
17
to be a statement of all the comments that were made on
18
t 1'". ere c ':' r d , e i t 1'". e I" ':' rail y 0 r in w r i t.i n 9 ,
and 01.(1"
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resp.:.nse,
the agency's ~esponse to those comments.
Are there any questiQns on the format of the
hearing before we start?
Okay.
Witt'. that,
again,
I would like to encourage
you to make your comments tonight and/or get them to us
in writing before July 19th.
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And with that,
I will turn it over to Mary
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Sanderson, who again will give you a brief overview of
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EPA's proposed plan.
4
I'd also like to mention, which I haven't
5
already, we have with uS,Eric from APEX Reporting, who
6
will be transcribing your comments, and he tells me you
7
can make them from your seat and his mike will pick
8
tt".em '.Ip.
So you simply stand or sit, if you want, and
9
make them.
10
5.:. with that,
I would like to thank you and
11
turn it over to Mary.
12
MARY SANDERSON:
I wl:.n' t g':'
r
As Rich said,
13
the long version that
,:,ve'(
I did a couple of weeks ago
14
when we were down here.
5.:1 I'll
give you just a very
15
brief recap about
the site and about the focus of this
16
ev.:ning's
t,:,pi 9s and
c.:,mments.
17
We ~;..,lked
very briefly ab~ut the history of'
18
t ~i e sit e
and o~eration of Baird ~ MiGuire for
,:.ver
19.
70 years at,the site and the other items that are going
20
e,n in terms of :the gl"':O'.lndwater treatment plant, the
21
soil incineration of the overall
site soils and a
22
separate water-supply study that is also underway.
We then talked a little bit about the
results of' the feasibility study in terms of
app~oximately 84 sediment samples that were taken,
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surface water samples and groundwater samples.
And
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most contaminants are found approximately within 500
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feet of the site.
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We then spoke abo~t the risk assessment
5
p,:,y t i,:,n ,:.f
the study that the agency conducts and the
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potential risks, both to public health, assuming
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various exposures to the sediments in the river and
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potential environmental risks.
9
We then reviewed the feasibility study
10
proc~ss that the agency goes through.
The agency must
11
balance nine cYiteria in selecting a remedy overall on
12
a var iety ,:,f
items that we must examine.
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On the basis of that criteria, we developed
14
six alternatives,
and those aye given in much greater
detail in you~ proposed plan.
16
There are three nonremoval
alternatives I
17
kn.:,1.. .
~ction alternative and institutional action and
18
then an
in-place capping alternative-
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And we also examined thr.eeremoval
alter~a~iYes that involve excavating sediments in the
y iver arId ei tt-.er sc.l idi fying them C'I" incinerating them
or just ~ovi~g them off site for disposal.
Using those nine cYiteYia that the agency
must use, we then have selected a preferred
alternative.
And that's what we'd like to focus on a
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little bit here.
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We have propo~ed the alternative of
3
'excavating the sediments within the vi~inity of the
4
site foi protection of potential public health risks
5
and the environmental risks in that area.
That goes
6
from the site approximately
down to
Union Street, about
7
500 feet
down
from the site.
And we would incinerate
8
those sediments, utilizing the incinerator that will be
9
brought on the site for the incineration of the overall
10
site soils.
11
There is more detail given in the proposed
12
plan.
There is a layout given on the layout of the
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ha~l roads,
avoiding of the residential areas with any
14
truckin~ of the materials and various silt cartons and
15
such to minimi;e any impacts from that excavation.
16
We also have proposed' not to remo~e any
17
contaminated sediments further downstream, much lower
18
levels of contaminants that woul~ pose potential
19
, en~ironmenta:
risks,
because of the disruption to the
wetlands down there, and we have not seen any impacts.
So, therefore, in sum~ary, to give a very
long and colorful history of a site in a very brief
way,
for this part of the study, which I would like to
try to focus our comments tonight on, is on this
portion of the site.
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The Cochato Riyer sediments that have been
2
impacted by the site, we're proposing to excavate the
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sediments in the Yicinity of the site, utili:ing the
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'on-site incinerator that will be brought on for
5
incin~ration of those sediments,
e~,;' cava te
and t.:, n.:,t
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the sediments further downstream at the lower levels of
7
c,:,ntaminants.
8
And we
""'1:.1.11 d we 1 -=,:,me
your comments on any of
9
the alternatiyes, the preferred alternative, in
10
particular, and that is it.
11
s.:. I
will turn it back to Rich, who will
12
field questions -- comments from your folks,
really.
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We will not be responding to them formally.
14
We'll be just simply accepting your comments,
as Rich
15,
said,
then asking any clarification questions if we
16
have t ~,Iem.
But we will not be responding ~o them here
17
t,:.ni gh t.
18
I will be ayailable after~ards.
We bc.th
19
will,
inf.:.rma11"'l,
once the hearing is concluded, to
give you some responses and to talk with you later.
,"
T~lank YClu.
THE FRESIDING OFFICIAL:
Thank YCII.!, Mary.
I will now start taking comments from the
audiente.
And the first commentor on my list is .
Dr. Conrad Jankowski, a member of the Baird ~ McGuire
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Task F.jrce.
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CONRAD JANKOWSKI:
Thank yc.u.
3
I'm 'r"epresenting, the Tas,k F,:.yce t.:,night.
4
I'm the Vice-Chaiyman of the Task Foyce.
5
OI.lr Chairman,
Emmet Hayes is held up at the
6
State
H.:.I.lse.
They had a late session tonight and I
7
don't think he'll be here.
And theye weye seveyal
8
things he wanted me specifically to enter into the
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yecoyd. .
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Before I do that, though, I'd like to ~ay
11
that these are not cyitical co~ments.
By and layge,
12
the Task Force has been very pleased with the
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responsiveness of the EPA and their
cooperation in most
14
of the suggestions that we've made.
15
Well, to start these off,
.:.ne of ';:'1.1'('
16
c.;:.ncerns,
and this would be in the operational aspect
17
01 this, is when they actually get out there and dredg~
18
things, t:-,ere's
goi~g to be activit~ on the banks and
19
.:,n c,:,ntaminQ ted
$,:,11.
And on the record, we would like
20
very much to ~e su~e that none 01 the banks are bro~en
21
down and run into the river.
N6ne of the soil on the
Baird' McGuire site,
as tr~ffic goes up and down, ends
up in the river.
And this was one of OUy concerns.
The second concern is, as we start stirYing
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'up the sediments on the bottom, there is a possibility
that some material may solubili=e, actually dissolve in
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the water.
We want to be certain that there is going
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to be a monitoring system in place that will
n,:,t cln 1 y
5
check for the possibility of sediments going
6
downstream, but also to look at the possibility of
7
dissolved materials, which couldn't be trapped by any
8
of the booms or ~nything like that.
9
And then a third concern is there may be a
10
possibility that the incinerator won't be up and
11
running and the water treatment plant may be up and
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running when they're actually doing this, which means
13
they would have to store the sediments and dewater then
14
,:,n si tee
15
S.:.,
ccnsequently, in the operational aspect
16
,:.f this,
the Task Force would like to be certain that
17
this is done in such a way that they won't increase Our
pr.:.blem,
ra tJ-ier
than decreasing our problem.
19
And then I have one last
I'll pl.l t
cc.mment.
':,n a
different
I'm on the Conservation Commission
~,at .
for th~ Holbrook Conservation Commission.
And the Conservation Commission knows that
the EPA and their contractors are going to be working
in wetlands, and these wetlands are very, very much
cc.ntaminated.
And, certainly, probably the experts,
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the wetland experts, and EPA are more cogni%ant of the
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damage that could be done than perhaps even the
3
Holbrook Conservation Commission is.
However, we would
4
like to leave communications channels open in such a
5
way that anything that impinges or affects the
6
wetlands, we could be notified about before it happens
7
and what will be done and when it will be happen.
8
Do you need any answers from me on any of
9
these? .
10
THE PRESIDING OFFICIAL:
Very clear.
11
CONRAD JANKOWSKI:
Okay.
Thank you.
12
THE PRESIDING OFFICIAL:
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That
was an
13
excellent speech and I thank you for it.
14
Thank
you.
15
The next commentor is Mike Levangie,
who is
16
also on the Task Force and also a Selectman from the
11
Town of Randolph.
10
MICHAEL LEVANGIE:
I~ll be very brief.
19
I just wanted to concur with everything that
Emmet had said through Conrad and I think that
everything that we had brought up at the last meeting
pretty much spelled out exactly what was said here
earlier with Conrad.
The only thing that I had major 'problems
with was the preferred alternative that the EPA has
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established, especially with regard to the
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Mary Lee Swamp (phonetic) in the Town of Randolph.
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My major concern is that there, NO.1, are
4
pollutants in that particular area,
al thc.ugh it has
5
been spelled ~ut in the EPA report that the pollutants
6
are such that they are not a danger to the public
7
health.
However, they are an environmental danger.
8
My C,:,r, cer n
centers primarily on the fact
9
that we were not able to establish any kind of
g':.c,d ,
10
warm feeling that there would not be long-term effects,
11
~dverse environmental and/or health effects in that
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parti c:.llar area.
13
5.:, my
main concern is that we take a serious
14
1.:II:,k at
that area, mainly because I think that we might
15
~e starting to look at what it costs to really
clean l.lp
16
as opposed to just do the clean up.
And my main
17
concern is that we're probably starting to look at
18
d.:,llars
as .:.pp.:.sed
to health, and that is a major
19'
concern tc' me.
I think that if there is to be no clea~ up
in that particular area, that we should certainly set
up some sort of a long-term monitoring service or
something in some way that we are assured over the long
haul that we have taken care of things that may be
adverse to both the environment and/or the health.
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Because that's,
I think, the main drive in the focus
2
that we want to be looking at as seeing to it that
3
th"ere is a
t,:,tal
clean IJp.
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Tt'lank
yc,IJ.
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THE PRESIDING OFFICIAL:
Thank YCII.I.
6
Next we have Beatrice Taggart, President of
7
the Holbrook Grove Association.
8
BEATRICE TAGGART:
evening.
G.:..:.d
9
I would just like to introduce me to
10
everyone before I said anything, if that's okay.
11
THE PRESIDING OFFICIAL:
That's fine.
Oka.y.
12
Then we'll have Andy Pra~nal, another Task
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Force member from the Town of Holbrook.
14
ANDREW PRASNAL:
G.:oo:.d evening.
15
I'm also in favor of "the proposed EPA
16
s .:' ll.i t i ':. r.
to the" cleanup of the Cochato in the immediate
17
area of the Baird ~ McGuire site with the following
18
c.:i:id i t ~ I:'ri~.
19
I feel that we should have sbme further
study and consideration on the use of back fill while
the porti~n of the Cochato River is bei~g cleaned for
the use of using this back fill as a future recreation
of the sediment that is now keeping a 10t of the
contaminants from being carried downstream.
Early ~n in this, there ~as a concern that
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removing portions of
the banks of the river would
2
disturb the sediment and, in fact, portions 01 the
3
sediment are going to be removed during this process,
4
and this is still a gray area as to whether or not
5
capping is the scientific way to go, but certainly
6
there was some feeling that a back fill replacement
7
w':'I.ll d
certainly not harm the situation and actually
8
create an additional safety factor, in terms of the
9
river h61ding any kind of, let's say, future creation
10
of a sediment to hold any processing of the
11
contaminants from being swe~t down the Cochato during
12
pr.:,cess.
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this
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Anc this is actually -- the use of
back
this
14
fill is actually going to be put in place for a future
15
concern of ensuring that
be held
wha t we dc.
n,:,w 10,1.:.1.11 d
16
for future years to come in terms of what we're doing
f ':0 r t t", eel e a n ;.1 p .
The other point that's mo~e important is, I
think,
portions of the incineration process and the
need to communicate a little bit better to the Town of
Hc.l brclI:,k.
Based on the test b~rn that is going to .be
occurring in the near future at your Alabama test site,
we really do need to know the earliest possible results
of that test burn, because ~hat test burn will actually
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determine the extent, a lot of the timing, in which it
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will take to actually deal with the amount of sediment
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that we are g01ng to process.
4
After that occurs,
there are also other
. 5
communication needs here.
the T';:'loIn .:,f
As a citi:en e,f
6
Holbrook, I think my concerns loIould be the noise of the
7
incineration, the chemical output from the stacks of
8
the incineration and some hard plan for monitoring the
9
act 1.1 a 1
~hemical output of this incinerator.
10
There loIill
also be a certain composition of
11
ash,
will be rendered after this process, and I would
12
like to know more about where this ash is going to be ~
13
stored in a plan and a hard plan for the storage, even
14
th.:II.tgh at
this p.:.int
we're looking at some sort of
15
capping proposal.
16
And I think that during this -- during
this
17
period of time, my hope is that loIe could have the
18
~I:'nt i nl.led
open communication along ~he lines of this
19
project and that loIe could actually see more citi=ens o~
the Town of Holbrook present at these future meetings.
Because as we go down the line,
it's going to be
important to have everybody reali=ing what is happeni~g
and to have all the information and not hearsay and a
rumor to run rampant in the town as to what, in fact,
we are doing.
. .
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Those are the points that I wanted to make.
2
Thank
Y':".t.
3
THE PRESIDING OFFICIAL:
Thank Y':".t.
4
Well, Beatr ice, r gr.less
I.lriless
it's t,:. Y':".l
5
anyone else wants
There were a few
to make a comment.
6
ql.les t i.:.ns ma r k s.
7
Other
than Beatrice Taggart, would anyone
8
else like to make a comment for the record?
9
Yes.
10
SALLY HERTZ:
I'm a resident
Sally Hertz.
11
here in Holbrook.
12
.
r
And my main concern at this point is, just
13
as this fellow said,
the chemical output from this
14
incineratio~, I reac and
heard talk of this
15
incineration and that's our miracle
cl.tre.
16
But I'm not sure that I've heard
..,;"j a nSl..ler
17
of what it is we're going to be putting into the air
18
and what we're ~oing to be breathing,
and I'm
19
uncomfortable with' that.
And I don't know wheth~r I
misunderstand it or whether there's something.I :an
read to be assured.
It says here in this press release,
incineration is a proven techn~logy and has been used
successfully for a number of years at hazardous waste
sites.
APEX REPORTING
Registered Professional Reporters
-------
20
21
22
23
24
25
18
HQW long has it been in
use:
W~lat kind ,:,f
2
studies dQ we have:
People in the area know there was
3
an unQfficial study done at East Braintree and that
4
there were -- from that study, there were higher skin
5
diseases, respiratQry diseases, for peQple in that
6
ne i gh b,:, r h ,:":.d .
7
And that's really my main
c,:.ncern
at this
8
p':,int,
is what are we gQing to be putting in the air
9
and where can I learn something on it to make me feel
10
more comfortable that
just making it more
we're n,:.t
11
Pi:' i S,:' n,:'I.I s:
12
.
r
THE PRESIDING OFFICIAL:
Ok a)l.
13
As Mary said, we're not really going to
14
c71nsWe","
q~estion5 tonight.
15
We will get that
incll.lde
into t~e re:ord a~d
16
. ~
.. ",
b ".. t I
just did want to let you know that we did
17
indicate at our last meeting here that, as the
18
ge~tleman indic~ted,
we are presently about to get
19 . ready to ship some soil out to -- where exactly is it?
-- Arkansas -- thank you -- for a trial burn.
And I:,ne
of the purposes of this is,
n,:,t .:.nly to set
inc inera t.:,r
de~ign parameters,
but also to look at what is going to
~e in the ash or soil as it
c.:.mes ':'I.lt,
what is going to
be in the air, what kind of, you know,
gases and any
other side streams, and we fully plan to, you know,
APEX REPORTING
Registered Professional Reporters
-------
24
2S
1E'
19
20
21
2~
23
19
come back to Holbrook once we've gotten all this
2
information and digested it, so we can let you know
3
that.
4
SALLY HERTZ:
My other concern I have is,
5
once this incinerator is in place, is this going to
6
bec.:.me a,
quote, unquote, temporary permanent situation
7
where we then start bringing in toxic waste from other
8
areas to incinerate in Holbrook?
An incinerat i,:on
9
plant'7'
10
UNIDENTIFIED MALE:
Yes, we're available
."
after ---
12
.
r
THE PRESIDING OFFICIAL:
Tha t' s a no:"
13
t h':".1 gh .
14
Yes,
sir.
15
~/,.~:: DEN;'" I FIE:>
I live on Washington
MA:"E:
Hi
Circle.
Put the sewer in and hit an underground stream
17
and come up in a
circle and flow into the swamp d'~wn
bel O:'\oi,
was that water ever tested t,:o see where it ~ame
fr.:.m?
THE PRESIDING OFr-ICIAL:
I'm ncot really
sl.Jre.
If Y':'LI c,:ol.lld
we :: l.:ose
-- o:once
this meeting
t':'ni gh t,
if y,:,I.1 want t,:,
c.:.me l.Jp and talk
t.:o M~lr\l ab,:ol.1 t
it, sto,e ---
UNIDENTIFIED MALE:
Can't we have an answer
APEX REPORTING.
Registered Professional Reporters
-------
20
21
22
23.
24
25
.20
to that,.
T,:,m'7-'
2
THOMAS CUMMINGS:
Yeah.
3
Basically the water that we get on
4
Washington Circle is just ba~ically groundwater and
5
i 1; , s rea I 1 y , Y I:: IJ
know, downgraded from the site.
S,:, I
6
don't see any -- YOIJ
k n.:.w, it
is flowing on the roadway
7
it's going into a stream that defers it, it
n':lw,
g.:.es
8
int,:,
the Cochato, but the. groundwater there, you
k r,.:."""
9
appears ~e're just hitting the table and we're running
10
int.;. it.
11
THE PRESIDING OFFICIAL:
did YCII.l
Beatrice,
12
.
r
say you wanted to make a s~atement?
13
EEAiRICE TAGGART:
basically I'd like
Well,
14
to reiterate wh&t this lady said and the gentleman,
15
what he said, as far a~ being very
a ~ ':11.11: t ~, e
c,:.n ::er ned
16
gases that would be emitted i~ the ashes and that type
17
~ ~...
I:'. v . I .1 n 9 .
18
. .
is there
And I
WI:".I~~ like-
t.:;. ask,
g,:,i ng t.:.
19
~e another meeting aft.r we have the results
fr.:.m the
samples
that you sent Qut?
THE PRESID!NG OFFICIAL:
Yes, we will have
.:.ne.
I can't give you the date now.
BEATRICE TAGGART:
All right.
THE PRESIDING OFFICIAL:
But definitely, we
will have
,:.ne.
APEX REPORTING.
Registe.red Pr,:,fessi.:.nal Rep.:.rte'fs
-------
17
18
19
20
21
22
23
24
25
1
21
Yes,
ma'am.
2
.JOAN IKASALO:
I live in
I'm Joan Ikasalo.
3
Revere Acres and I've lived in Holbrook 36 years.
,4
I'm jl.lst
f'(,:,frt
C '.\ yo i ':01.\ s .
Is there a reporter
5
the Holbrook Sun?
6
I just feel we just get
S '.1 C h P':":,r-
7
advertising,
reportinG in the Holbrook Sun, Our
p,:,or
8
.:.wn t':,wn paper.
Like it comes out yesterday, there was
9
an article, why not remind it to the people,
last
10
riight.
I don't see it in the Brockton Enterprise.
11
r mean,
I .
r
maybe it's in the Quincy Ledger.
12
c,:.n't
k n.:,w.
BI.\t !
get the Brockton,
! get the Holbrook
13
Sun anc I don't feel there is enough advertising or
14
rep.:'r t ing
for important things like
this, because other-
15
pe.:.~ 1 e i r.
H.:. ~ b r .:..:. ~:: sr. ,:01...1 C
be here.
But there re~lly
16
isn'~
g,:,':,d ~. ejj':.~.'; i ng.
. ;j':E PRESIDING OFFIC:AL:
So your request is
that arlY
f '...~ t ;.t i"- -=
meetings of this type be adverti5ed C~
cable ;V"?
Oka,;'.
We'll get that On the record.
W':,I.l:ld
any,:.ne
else like to make a statement?
Okay.
I't~ like t,:"
again,
thank you all for
c,:.mi ng
out here again and remind
again,
y .j 1.1 ,
that you can also
make'writte'n e.:.mments, it y,:,I.\'d like,
even if y.:,u' ve
APEX RE:PORTING
Registered Professional Reporters
-------
13
14
15
16
17
~
19
20
21
22
23
24
25,
1
~~
~-
spoken tonight.
And you need to send them to Mary's
2
attention.
3
The address is listed in the handout.
And
we need to get them postmarked by July 19th.
4
5
~s~ring,
6
And with that, I guess we~ll close the
but we will be hanging around for a little
while, if peopls ~ant
to come and ask us anyth~ng else
7
~hile we're here.
8
9
10
entitled
11.
12
Thank you very much.
rWhereupon, the hearing in the above-
m~tter
was con~luded.J
r
APEX REPORTING
Registered Professional Reporters
(€~7)41€-3077 .
-------
CERTIFICATE OF REPORTER AND TRANSCRIBER
before:
.
This is to certify that the attached proceedings
Richard Cavagnero, Chairman
in the Matter of:
BAIRD & MCGUIRE SUPERFUND SITE
Place:
Holbrook, Massachusetts.
Date:
July 12, 1989
were
hele as herei~ appears, and ~~at ~~is is the true,
acc~=ate ane ccmplete t=a~scri?t
pre?ar~d from the notes
a!'lc/o=
:-eco~c::i~gs
t ' -..~. . 1 . . .
a.
-------
APPENDIX B
ADMINISTRATIVE RECORD INDEX
.
-------
BAIRD AND MCGUIRE, INC.
SEDIMENT STUDY
NPL SITE ADMINISTRATIVE RECORD
TABLE OF CONTENTS
VOLt7HE I
4.0 Feasibility Study (FS)
4.2
4.4
VOLt1HE II
4.4
4.6
VOLt1HE III
4.6
VOLUHB IV
4.6
VOLt1KB V
4.6
VOLt1KB VI
4.7
4.9
5.0
Sampling and Analysis Data
Interim Deliverables
Interim Deliverables (continued)
Feasibility Study (FS) Reports
Feasibility Study (FS) Reports (continued)
Feasibility Study (FS) Reports (continued)
.
r
Feasibility Study (FS) Reports (continued)
Work Plans and Progress Reports
Proposed Plan for Selected Remedial Action
Record of Decision (ROD)
5.1
5.2
5.3
5.4
5.8
VOLtJHB VII
Correspondence
Applicable or Relevant and Appropriate Requirements
(ARARs)
Responsiveness Summaries
Record of Decision (ROD)
ROD Briefing Documents
10.0 Enforcement
10.8 EPA Consent Decrees
13.0 Community Relations
13.2 Community Relations Plan
13.3 News Clippings/Press Releases
13.4 Public Meetings
-------
BAIRD AND MCGUIRE, INC.
SEDIMENT STUDY
NPL SITB ADMINISTRATIVB RECORD .
TABLB OP CONTENTS (cont'd)
VOLUME VII (cont'4)
f . .
17.0 Site Management Records
17.7 Reference Documents
18.0 Initial Remedial Measure (IRK) Records
18.4 Initial Remedial Measure (IRK) Reports
.
r
-------
Introduction
This document is the Index to the Sediment Study
Administrative Record for the Baird & MCGuire, Inc.
National Priorities List (NPL) site. Section I of the Index
cites site-specific documents, and Section II cites guidance
documents used by EPA staff in selecting a response action
at the site.
The Administrative Record is available for public review at
EPA Region Ir$ Office in Boston, Massachusetts, and at the
Holbrook Public Libra~, 2 PlYmouth Street, Holbrook,
Massachusetts,02343. This Administrative Record includes,
~y reference only, all documents included in the
Administrative Record for the Sept~er 30, 1'" Record of
Decision. Questions concerning the Administrative Record
should be addressed to the EPA Region I site manager.
.
r
The Administrative Record is required by the Comprehensive
Environmental Response, Compensation, and Liability Act
(CERCLA), as amended by the Superfund Amendments and
Reauthorization Act (SARA).
-------
J
SECTION I
SITE-SPECIPIC DOCUMENTS
.
r
-------
ADMINISTRATIVE RECORD INDEX
tor the
Bair4 an4 MCGuire, Inc. HPL Site
(Se4iment Stu4y)
4.0 Feasibility Study (FS)
4.4
4.5
4.6
.
4.2
Sampling and Analysis Data
1.
"Technical Memorandum - Low Flow Phase I Field
Investigation Cochato River Sediment Focused
Feasibility Study Holbrook, Massachusetts," E.C.
Jordan Company for Ebasco Services, Incorporated.
(May 1988). NOTE: OVersized maps are available
for review, by appointment only, at EPA, Region I,
. Boston, Massachusetts.
"Technical Memorandum - Summary of 1988 Sediment
and Water Sampling Program,~ E.C. Jordan Company
for Ebasco Services, Incorporated (January 1989).
NOTE: Oversized maps are available for review, by
appointment only, at EPA, Rp.gion I, Boston,
Massachusetts.
2.
.
r
Interim Deliverables
"Field Operations Plan Cochato River Sediment
Focused Feasibility Study," E.C. Jordan Company
for Ebasco Services, Incorporated (April 1988).
"Technical Memorandum Cochato River Diversion,"
E.C. Jordan Company for Ebasc::o Services,
Incorporated (October 1988).
Applicable or Relevant and Appropri~te Requirements
1.
2.
1.
Cross Reference: "Final Focuse~ Feasibility Study
- Volume I," E.C. Jordan Company for Ebasco
Services, Incorporated (June 1989). [Filed and
cited as entry number 2 in 4.6 Feasibility Study
(FS) Reports].
Feasibility study (FS) Reports
1.
"Draft Focused Feasibility sturty - Volumes I and
II," E.C. Jordan Company for Eoasco Services,
Incorporated (May 1989).
"Final Focuse~ Feasibility Study - Volumes I and
II," E.C. Jordan Company for Ebasco Services,
Incorporated (June 1989).
2.
-------
5.0
v
4.6
4.7
4.9
Feasibility Study (FS) Reports (cont'd)
3.
Memorandum from Tim Conway, EPA Region I to Baird
and McGuire Administrative Record (June 6, 1989).
Concerning inclusion of the Draft Focused
Feasibility Study in the Administrative Record.
Comments on the Peasibility study received by 2PA
Region I during the formal public comment period on the
Peasibility study and Proposed Plan are filed and cited
in 5.3 Responsiveness Summaries.
Work Plans and Progress Reports
1.
"Final Work Plan Focused Feasibility Study," E.C.
Jordan Company for Ebasco Services, Incorporated
(February 1988).
Proposed Plan for Selected Remedial Action
1.
"EPA Proposes Phase III Cleanup Plan for the Baird
, McGuire SitelCochato River. Sediment Study Area,"
EPA Region I (June 1989).
.
. . r
Comments on the Proposed plan received by BPA Region I
durinq the formal public comment period on the
reasi~ility study aDd Proposed PlaD are tiled aDd cited.
in 5.3 Responsiveness Summarie..
5.'1
Record of Decision (ROD)
5.2
.-
Correspondence
1.
Memorandum from Jonathan Z. Cannon, USEPA to
Regional Administrators Regions. I-X (May 25,
1989). Concerning delegation of remedy selection
authority for all Records of Decision scheduled
for signature during the third and fourth quarters
of fiscal year 1989.
Applicable or Relevant and Appropriate Requirements
(ARAb )
1. .
Letter from Helen Waldorf, Massachusetts
Department of Environmental Protection to Mary
Sanderson, EPA Region I (July 19, 1989).
Concerning the Department of Environmental
Protection's concurrence with EPA on the
remediation selected for this portion of the Baird
, McGuire site and the submittal of comments to be
considered by the EPA in designing this plan.
-------
5.4
5.8
.
5.3
Responsiveness Summaries
1.
Cross-Reference: Responsiveness Summary is
Appendix A of the Record of Decision (Filed and
cited as entry number 1 in 5.4 Record of Decision
(ROD)].
The following citations indicate documents received by .
EPA Region I during the formal public comment period.
2.
Letter from Francoise Chalvire, Holbrook resident,
to Mary Sanderson, EPA Region I (June 30, 1989).
Concerning questions and concerns related to the
Baird' McGuire Superfund Site.
Comments Dated July 14, 1989 from Andrew Prasnal,
Holbrook resident, on the June 1989 Baird'
McGuire Proposed Plan - "EPA Proposes Phase III
Cleanup Plan for the Baird' McGuire Site/Cochato
Riv.er Sediment Study Area," EPA Region I. ..
Comments Dated July 17, 1989 from Denise Perrault,
Holbrook resident, on the June 1989 Baird'
McGuire Proposed Plan - "EPA Proposes Phase III
Cleanup Plan for the Baird' McGuire Site/Cochato
River Sediment Study Area," EPA Region I.
Comments Dated July 19, 1989 from Mrs. Donna r
Quinn, Holbrook resident, on the June 1989 Baird'
McGuire "Final Focused Feasibility Study," Ebasco
Services, Incorporated and Proposed Plan - "EPA
Proposes Phase III Cleanup Plan for the Baird'
McGuire Site/Cochato River Sediment Study Area,"
EPA Region I.
Record of Decision (ROD)
3.
4.
5.
1.
"Record of Decision Summary - Baird' McGuire
Site/Sediment Study Area, Holbrook,
Massachusetts," EPA Region I (~eptember 14, 1989).
ROD Briefing Document
1.
"Record/of Decision Briefing Document," EPA Region
I (September 14, 1989).
"
-------
10.0 Enforcement
10.8 EPA Consent Decrees
. . .
1.
Consent Decree, United states v. Baird' McGuire.
United states District Court for the District of
Massachusetts, Civil Action No. 83-3002-Y (January
6, 1987) (via transmittal letter from Andrew S.
Hogeland, U.s. Department of Justice to Katherine
Hart, U.S. District Court (January 6, 1987».
-
13.0 Community Relations
13.2 Community Relations Plan
1.
"Baird' McGuire site - Community Relations Plan,"
EPA Region I (May 1989).
13.3 News Clippings/Press Releases
"EPA study Will Investigate Cochato River
Contamination," The Enterprise - Brockton,
Massa~husetts (November 19, 1987).
"EPA may reroute part of river at Baird 'McGuire
Site," The Patriot Ledger - Quincy, Massachusettsr
(April 22, 1988).
"EPA May Reroute River Near Pollution Site," The
Patriot Ledger - Quincy, Massachusetts (April 23,
1988).
"Cochato contamination a Focus of Cleanup study,"
8raintree Forum and Observer - Braintree,
Massachusetts (February 22, 1989).
"Task Force Favors Burninq Cochato Sediment," The
Patriot Ledger - Quincy, 'Massachusetts (May 24,
1989).
"Baird' McGuire task force qets EPA study on
cleanup options," The Enterpris~ - Brockton,
Massachusetts (May 24, 1989).
"Task force receives EPA report on Cochato River
cleanup," The Sunday Enterprise - Brockton,
MassDchusetts (May 28, 1989).
"Residents urged to attend Cochato cleanup
hearinq,. The Braintree Forum and Observer -
Braintree, Massachusetts (May 31, 1989).
"EPA Announces Public Meeting to Discuss Proposed
Plan for Cleanup at the Baird' McGuire Superfund
Site/CochatoRiver Sediment Study Area," EPA -
Environmental News (June 1, ,1989).
"Burning of soil advised by EPA," The Patriot
Ledger - Quincy, Massachusetts (June 8, 1989).
1.
2.
3.
4.
5.
6.
7.
8.
" 9.
..
10.
-------
13.3 News ClipPings/Press Releases (cont'd)
11.
"EPA Schedules meeting Tuesday on Baird-McGuire
cleanup steps," The Enterprise - Brockton,
Massachusetts (June 8, 1989).
"Burning of soil advised for Baird site," The
Patriot Ledger - Quincy, Massachusetts (June 9,
1989).
"The United States Environmental Protection Agency
Invites Public Comment on the Focused Feasibility
StUdy and Proposed Plan for the Baird & MCGuire
Site/Cochato River Sediment Study Area in
HOlbrook, Massachusetts and Announces the
Availability of the Site Administrative Record,"
The Patriot Ledger - Quincy, Massachusetts (June
10, 1989).
"EPA Proposes Cleanup Plan for the Baird'
MCGuire/Cochato River Sediment StUdy Area," EPA -
~nvironmental News (June 13, 1989).
"EPA to explain Cochato cleanup," The Patriot
Ledger - Quincy, Massachusetts (June 13, 1989).
"EPA outlines its incineration option at Baird-
MCGuire site," The Enterprise - Brockton,
Massachusetts (June 14, 1989). .
"Few residents attend Cochato cleanup meeting," r
The Patriot Ledger - Quincy, Massachusetts (June
14, 1989).
"Rep. Hayes concerned about future contamination,"
The Avon Messenger - Avon, Massachusetts (June 14,
1989).
~Rep. Hayes concerned about future contamination,"
The Holbrook Times - HOlbrook, Massachusetts (June
14, 1989). .
"Rep. Hayes conc~rned about future contamination,"
The Brockton News Tribune - Stoughton,
Massachusetts (June 14, 1989).
"Cochato Opposed as source of water," The Sunday'
Enterprise - Brockton, Massachusetts (June 18,
1989).
"Hayes urges people to review EPA's proposed
plan," The Holbrook Times - Holbrook,
Massachusetts (June 21, 1989).
"Residents urqed to comment on Cochato cleanup,"
The Braintree Forum and Observer - Braintree,
Massachusetts (June 21, 1989).
"Incineration process worries residents & non-
residents," The Holbrook Times - Holbrook,
Massachusetts (June 21, 1989).
"Cochato River comment period ends July 19," The
Randolph Mariner - Marshfield, Massachusetts (July
6, 1989).
12.
13.
14.
15.
16.
17:
18.
19.
20.
21~
22.
23.
24.
25~
.
-------
13.3 News Clippings/Press Releases (cont'd)
26.
27.
v
28.
'-
29.
30.
31.
"EPA seeks bigger turnout for river cleanup
hearing," The Patriot Ledger - Quincy,
Massachusetts (July 11, 1989).
"Public meeting set to review Cochato River
cleanup plan: EPA's $1.04M proposal to be
discussed," The Enterprise - Brockton,
Massachusetts (July 11, 1989).
"Small turnout at hearing is satisfied with EPA's
cleanup plan for river," The Enterprise. -
Brockton, Massachusetts (July 13, 1989).
"Only 15 at hearing on cleanup cf Cochato: Last
chance to make oral comments to EPA," The Patriot
Ledger - Quincy, Massachusetts (July 13, 1989).
"Few residents commented on EPA incineration for
~ochato River," The Holbrook Times - Holbrook,
Massachusetts (July 19, 1989)..
"EPA Finds No Evidence of Dioxin in Lake," The
Patriot Ledger - Quincy, Massachusetts.
13.4 Public Meetings
1.
2.
'-
"Summary of the Public Informational Meeting on
the Focused Feasibility Study and Proposed Plan
for the Baird & McGuire Superfund SitelCochato
River Sediment. Study Area," ICF Technology
Incorporated (June 13, 1989). .
Transcript, Public Hearinq on the Proposed Phase
III Cleanup Plan for the Baird & McGuire
Sitelcochato River Sediment Study Area, Holbrook,
Massachusetts (July 12, 1989).
.
r
17.0 Site Management Records
17.7 Reference Documents
1.
"
2.
3.
#
"An Epidemiologic Investigation of Adverse Birth
Outcome pata for Holbrook and Surrounding'
Communities: 1980 - 1984," Massachusetts
Department of Public Health (December 1985).
"Report of Fisheries Investigation to screen for
2,3,7,8 Tetrachlorodibenzo-p-dioxin Associated
with the Baird & McGuire Hazardous Waste Site,
Holbrook, Massachusetts, 1985," John J. Jonasch,
Massachusetts Department of Environmental Quality
Enqineering (1985).
"Assessing the Risks of Incinerating Dioxiri-
Contaminated Soil," Paul C. Chrostowski, Sarah A.
Foster, Andrea Fogg, }{MCRI' S HAZARDOUS ~TERIALS
CONTROL, Volume 2, Number 4 (July-Auqust 1989).
-------
17.1 Reference Documents (cont'd)
4.
"Silt CUrtain Reference Materials," EPA Region I
[via Memorandum from Mary Sanderson, EPA Region. I
to File (September 11, 1989)].
"Calculation ot Dissolved Contaminant
Concentrations; Cochato River Sediment Study," EPA
Region I [via Memorandum trom Mary Sanderson, EPA
Region I to File (September 11, 198~)].
"Incineration of a Chemically Contaminated
Synthetic Soil Matrix (SSM) Using a Pilot-Scale
Rotary Kiln System," M.P. Esposito, M.L. Taylor
and C.L. Bruffey, PEI Associates, Inc., and R.C.
Thurnau, USEPA.
"ENSCO MWP-2000 Transportable Incinerator," John
H. Lanier, Environmental Systems Company.
"Epidemiologic Analysis: Holbrook," Massachusetts
Department of Public Health, Center for Health
- Promotion and Environmental Disease Prevention.
5.
6.
7.
8.
18.0 Initial Remedial Measure (IRK) Records
18.4 Initial Remedial Measure (IRK) Reports
#
1.
.
"Project Closeout Report," EPA Region I (January r
1988).
~
-------
c
SECTION II
GOIDANCB DOCUMENTS
.
r
"
-------
6.
7.
8.
9.
10.
BAIRD' MCGUIU., INC.
SEDIMENT STUDY
NPL SITS ADMINISTRATIVE RECORD
GUIDAHCB DOCt1HE1fTS
EPA guidance documents may be reviewed at EPA Region I, Boston,
Massachusetts. .
General SPA Guidance Documents
1.
"Appendix D - Protection of Wetlands: Executive Order
11990," 42 Federal Reaister 26961 (1977).
U.S. Environmental Protection Agency. Office of Emergency
and Remedial Response. Communitv Relations in Sucerfund: A
Handbook (Interim Vers~ (EPA/HW-6), June 1988.
2.
3.
. .
U.S. Environmental Protection Agency. Environmental
Res~arch Laboratory. EPA Guide fO~ ~~n~mi;i~~ the :dve~se
Env1ronmental Effects of Cleanuc 0- __c_nt_o__e~ Ha_ard_us-
Waste Sites (EPA-600/8-85/008l, June 1985. .
"National Oil and Hazardous Substances Pollution Contingenct
Plan," Code of Federal Reaulat~ (Title 40, Part 300),
November 20, 1985.
4.
5.
U.s. Environmental Protection Agency. Office ot Emergency
and Remedial Response. Sucerfund Remedial Desian and
Remedial Action Guidance (Oswer Directive 9355.0-4A), June
1986.
U.S. Environmental Protection Agency. Office of Research and
Development. Hazardous Waste Engineering Research
Laboratory. Handbook for Stab~on/Sol~on of
Hazardous Wastes (EPA/540/2-86/001), Jun~ 1986.
U.S. Environmental Protection Agency. Office of Solid Waste
and Emergency Response. Mobile Treatment Technoloaies for
Sucerfund Wastes (EPA 540/2-86/003(t», September 1986.
~
ComDre~ronmentA1 ReSDonse. ComDensation. and
Liabilitv Act of 1980, amended October 17, 1986.
U.S. Environmental Protection Agency. Otfice of Emergency
and Remedial Response. SUDerfun4 Public Health Evaluat~
Manual (OSWER Directive 9285.4-1), October 1986.
U.s. Environmental Protection Agency. Office ot Solid Waste
and Emergency Response. Interim Guidance on Sucerfund
Selection of Remedy (OSWER Directive 9355.0-19), December
24, 1986.
..
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General BPA Guidance Documents (cont'd)
11.
C/
12.
L
f . .
13.
14.
15.
16.
17.
\,
18.
u.s. Environmental Protection Agency. Office of Solid
and Emergency Response. Data Oualitv Obiectives for
Remedial Resconse Activities: Develocment Process
(EPA/540/G-87/003), March 1987. .
Waste
Memorandum from J. Winston Porter to Addressees ("Regional
Administrators, Regions I-X; Director, Waste Management
- Division, Regions I, IV, V, VII, and VIII; Director,
Emergency and Remedial Response Division, Region II;
Director, Hazardous Waste Management Division, Regions III
and VI; Director, Toxics and Waste Management Division,
Region IX; Director, Hazardous Waste Division, Region X;
Environmental Services Division Directors, Region I, VI, and
VII"), (July 9, 1987). Concerning interim guidance on
compliance with applicable or relevant and appropriate
requirements. .
u.s. Environmental Protection Agency. Office of Solid Waste
and Emergency Response. Additional Interim Guidance for
Fiscal Year 1987 Record of Decisions (OSWER Directive
9355.0-21), July 24, 1987. ' .
.
r
u.s. Environmental Protection Agency. Office of Health
Environmental Assessment. A ComDendium of Tec~ies
jn the Treatment ot Hazardous Waste (EPA/625/8-87/014),
September 1987.
U.S. Environmental Protection Agency. Technoloqy Screenin9
Guide for Treatment of CERCLA Soils and Sludaes (EPA 540/2-
88/004), September.1S188. .
and
Useq
u.S. Environmental Protection Agency. ottice ot Emergency
and Remedial Response. Guidance for Cond~ctina Remedial
Investiaations and Feasibilitv Studies Under CERCLA
(EPA/540/G-89/004) (OSWER Directive 9355.3-01), October
1988.
u.S. Environmental Protection Agency. Office of Emergency
and Remedial Response. Guidance on Remedial Actions for
contaminated Ground ~ater at Sucerfund Sites (EPA/540/G-
88/003) (OSWER Directive 9283.1-2), December 1988.
"Summary of the Requirements:
Rule," EPA Region I.
Land Disposal Restrictions
.
-------
4.
-5.
6.
Baird' McQuire (Sedi.eDt Study) HPL site Specific QuidaDce
DocumeDts
1.
"Guidelines for Ground-Water Classification Under the EPA
Ground-Water Protection Strategy," USEPA, December 1986.
U.S. Environmental Protection Agency. Office of Solid Waste
:~:l~::~~~n~~o~~:~~ns;;~a;~:ss~~~ri~~~m~~~~~:=~~: Technoloay
(EPA /540/5-88/001), February 1988.
2.
3.
"Evaluation of the B.E.S.T.* Solvent Extraction Sludge
Treatment Technology Twenty-four Hour Test," Gerard W.
Sudell, Enviresponse, Incorporated.
"Guidance for Compliance with Requirements of the Safe
Drinking Water Act," Chapter 3 of the Draft Clean Water
Act/Safe Drinking Water Act (CWA/SWDA) Volume of the
Superfund .Compliance Manual.
U.S. Environmental Protection Agency. Office of the
Administrator. Recort of the S:d~~~:; ~~Ud~ ;~~te~~a
Subcommittee - Evaluation ~f th i;-~teo~ ~i~--_s __reshold
(AET) Accroach for Assesss1na Sed__e_- __a__-¥
(SAB/EETFC/89/027), July 1989.
.
r
Department of the Army. U.S. Army Corps of Engineers. New
Bedford Harbor Sucerfund proiect. ~cus~net ~~ve~ ~s=uary
Enaineerina Feasibiljtv Study of D eda'na au D e_a d .
Material Discosal Alternatives - Reco~ 10; Evaiuation of
Dredaina and Dredaina Control Tech~~l~~i;s (Technical Report
EL/88/15), November 1988.
..
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APPENDIX C
, '
STATE CONCURRENCE LETTER
.
r
If
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~iel s. Greenbaum'
Commissioner
.9k (l~ '?/
~~P/6~~
~~P/6~~bY;6~
gjtU'eOa p/'W~ J@ (j'~
~ 'Wt/1Lo- J'~ qj~ ~ 0.2;10&
September 13, 1989
Paul Keough
Acting Regional Administrator
U.S. EPA
JPK Pederal Building
Boston. Massachusetts 02203
Dear Mr. Keough:
RE:
State Concurrence
with Record ot
Decision for Baird.
6 McGuire Pederal
Supertund Sitel
Cochato River
Sediment Study
Operable Unit .3
.
r
The Depart.ent ot Environ.ental Protection (The Depart.ent) has reviewed
the preferred re.edial action alternative reco.mended by the u.S. EPA tor the
Baird 6 McGuire Federal Superfund Site/Coc:hato River Sedi.ent study in Holbrook,
Massachusetts. The Depart.ent concurs with the choice ot remediation selected
for this portionot the Baird 6 McGuire site.
The Depart.ent has evaluated EPA's pret~rred alternative tor consistency
81th the Massachusetts General Law Chapter 21E as aaended in 1986 and the
llassachusetta Contingency Plan (MCP). The pl'eterred alternative addresses the
cont88inated Cochato River sedi.ents tor the third operable unit ot the Baird &
McGuire site. The re.edial action co.prlses the toll0.1nl co.ponents:
,
1.) Re.oving contaainated sedi.ents trolt the Cochato River:
2.) Incinerating the sedt.ents In an on-site incinerator to destroy the
conta.inants.
The EPA states that tor this operable unit, the re.edial action will reduce
-'e eXf:ess cancer risk to a 1 in 1.000,000 \10-6>. attributable to this disposal
site. This is consistent with the overall per.anency require.ents at MGL
Clal)ter 21E as defined in the MCP. The EPA has, however, stipulated that exca-
wation and contir.atory sa.pling are required to docuaent the level ot cleanup
HQIr
DIllOW
1IIaDD.\8'rMaft'0f'
~""ftO'''"ouif
-------
Paul Keough
Page Two
September 13, 1989
o
whioh is aotually aohieved. It a permanent solution cannot be attained, a tea-
porary solution will be proposed which eliainates slgniticant risk to public
health and the environaent, and a plan to develop a peraanent solution would
then be required.
~.
The total site cancer risk tOllowing the coapletion ot all operable unit reaedial
actions aay not eXCeed a signiticant risk level ot IXIO-5 during any toreseeahle
period ot tiae for the preferred alternative to be Considered a peraanent solu-
tion.
During the last operable unit tor this disposal site, the Deportaent will
evoluate whether or not all reaedial actioos will reduce sianitlcant residual
oite risk for any toreseeable period ot tiae, and it a peraanent solution will be
achieved.
The proposed reaedy appears to aeet all ARARs. The Departaent will Con-
tinue to evaluate the ARARs as reaedial design progresses and during lapleaen-
t~tion and operation ot the remedy.
.
r
The Departsent look. torward to working with you In lapleaentlne the pre-
terred alternative. It you hove any questions, please contact Evelyn Tapani at
556-1125.
.
el S . reenbau.,
Commissioner
Department ot Environ.ental
Protection
ET/tlt:sc
cc:
Ed~ard Kunce. RD
Richard Chalpln. DREE
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