United States Office of
Environmental Protection Emergency and
Agency Remedial Response
EPA/ROD/R01 -90/049
September 1990
f/EPA
Superfund
Record of Decision
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REPORT DOCUMENTATION 1" REPORT NO. I ~ 3. Reclpient'a Acceulon No.
PAGE EPA/ROD/R01-90/049
4. TI1Ie and Subtitle 5. Report Dat.
SUPERFUND RECORD OF DECISION 09/27/90
Baird & McGuire, MA
a.
Third Remedial Action - Final
7. Author(a) .. P8rfonnlng OrganlZlltion ~ No.
O. P8rformlng OrgalnlZlltlon Name and Addl..a I 10. ProjactlTaaklWork Unit No.
11. ContNcI(C) 01' arant{O) No.
(C)
(0)
1~ ~orIng Organization Name and AddI... 13. Type 01 Report & Period Covered
U.S. Environmental Protection Agency
401 M Street, S.W. 800/000
Washington, D.C. 20460 14.
15. Supplementary No"'a
15. Abalract (Unlit: 200 worda)
The 20-acre Baird & McGuire site is a former chemical manufacturing facility in
Holbrook, Massachusetts. The South St reet well field, part of the municipal water supply
for Holbrook, is located within 1,500 feet of the property. Bordering on the east of
the site, the Cochato River, which flows down past a sluice gate, is the major water
supply source for the towns of Holbrook, Randolph, and Braintree. Products mixed and
stored at the Baird & McGuire site included herbicides, pest icides, disinfectants,
soaps, floor waxes, and solvents. Waste disposal methods at the site included direct
discharge into the soil, nearby brook, and wetlands, as well as a former gravel pit (now
covered) in the eastern portion of the site. In 1983, EPA conducted a removal action
after a waste lagoon overflowed near the Cochato River and spread contaminants into the
river. A second removal action was initiated in 1985 when dioxin was discovered in site
soil. Between 1985 and 1987, EPA conducted an Initial Remedial Measure to construct a
new water main to replace the main passing through the site and to place temporary caps
over some of the site. The 1986 and 1989 Records of Decision (RODs) addressed all of
the previous remedial activities at the site including pumping and onsite treatment of
ground water (OU1), as well as onsite excavation and incineration of contaminated soil
1
(See Attached Page)
17. Document Analyaia L o.acllptor8
Record of Decision - Baird & McGuire, MA
Third Remedial Action - Final
Contaminated Media: none
Key Contaminants: none
b. Idantlfler8l0pen-Enc»d Terma
c. CooA TI Reld/G,oup
18. "vlilabllty Statement 10. Secwity CIa.. (Thia Report) 21. No. 01 Pagee
None 90
~ 20. s.c..ity CIa.. (Thia Page) 22. PrIce
Nnnp
272 4-77
50272-101
'()
(See ANSl-Z30.18)
See In.trucuon. on RevertNI
(Formerty NTlS-35)
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EPA/ROD/ROl-90/049
Baird & McGuire, MA
Third Remedial Action - Final
Abstract (Continued)
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c
(OU2), and remediation of the sediment of the Cochato River (OU3). This remedial action
addresses the fourth operable unit, provision of an alternate water supply to compensate
for the loss of the South Street wellfield and provide an additional 0.31 million
gallons/day. Since the previous RODs have addressed all of the site-related
contamination, there are no contaminants of concern associated with this remedial
action.
The selected remedial action for this site includes future reactivation of the Donna
Road aquifer, by obtaining Federal and local permits to increase the allowable capacity
of water withdrawal; constructing a new well, performing pre-design tests required to
obtain the permits, ground water filtration and disinfection, and piping the water to
the current distribution system. The estimated present worth cost for this remedial
action is $1,188,000, which includes an annual O&M cost of $23,000 for 20 years.
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DECLARATION FOR THE RECORD OF DECISION
~
Baird & McGuire/Alternate Water Supply
Holbrook, Massachusetts
statement of Puroose
This Decision Document presents the selected remedial action for
this site developed in accordance with the Comprehensive
Environmental Response, Compensation, and Liability Act of 1980
(CERCLA), as amended by the Superfund Amendments and
Reauthorization Act of 1986 (SARA), and to the extent
practicable, the National contingency Plan (NCP), 40 CFR
Part 300, 5S Federal Register 8666 (March 8, 1990).
The Commonwealth of Massachusetts has concurred with the selected
remedy.
statement of 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.
Description of the Selected Remedy
A.
Description of Remedial Components
After evaluating all of the feasible alternatives using the
criteria for remedy selection, EPA has selected AW-1, the
reactivation of the Donna Road aquifer, as the' alternate water
supply to replace the lost demand resulting from contamination of
the South Street Wellfield. AW-1 can be broken into four.
components: (1) permitting/pre-design studies, (2) groundwater
extraction, (3) treatment, and (4) delivery to distribution
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1.
permittinq/Pre-Desian studies
Since the Donna Road Aquifer is not part of the Baird & McGuire
Site, section 121(e), which waives the administrative permitting
requirements for remedial actions conducted on-site, is not
applicable; therefore all necessary federal, state and local
permits must be obtained for this remedial action. Two permits
which will be critical to the timely implementation of this
remedy will be a water withdrawal permit as required by the
Massachusetts Water Management Act and a new source approval as
required by the Massachusetts Department of Environmental
Protection's (DEP) "Guidelines and Policies for Public Water
Supplies" document.
.,
The Randolph-Holbrook Joint Water Board currently has a water
withdrawal permit which authorizes them to withdraw a total of
3.27 mgd from the following four points: South Street Well No.1
(which was closed in 1982), Donna Road We11fie1d, Richardi
Reservoir and the Great Pond/Upper Reservoir. The Joint Water
Board is currently operating close to that 3.27 mgd capacity; the
addition of 0.31 mgd will exceed the permitted capacity thus
requiring a new permit. In addition to a new permit for total
volume of water, under the Massachusetts Water Management Act the
addition of a new well constitutes a new withdrawal point and
will also require a new permit.
The "Guidelines and policies for Public Water Supplies" guide
provides for a nine-step procedure for seeking Massachusetts
Department of Environmental Protection (DEP) approval of a
drinking water source. The process is a phased approach which
include exploration and preliminary testing, a five day pump
test, and a summary hydrologic report.
Although all studies and historical data indicate the Donna Road
Aquifer should be able to meet the 0.31 mgd Lost Demand under the
Source Approval Process, DEP may limit the pumping of the wells
based on the safe yield (the maximum rate at which the system can
be expected to deliver water continually under a defined set of
drought conditions) of the aquifer. Should the Donna Road
Aquifer be unable to provide the entire Lost Demand of 0.31 mgd,
any incremental difference between 0.31 mgd and the amount of
water the Donna Road Aquifer provides will be obtained by
increasing the diversion of the Farm River. If however, the
production of ground water from Donna Road is insufficient to
support the balance between the remedy selection criteria, EPA
will reexamine the remedy. EPA anticipates that a water
production from Donna Road of less than 0.21 may prompt such a
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2.
Groundwater Extraction
h
~
The extraction system is conceptualized as two 12-inch diameter
wells approximately 40 feet deep, and 800 to 1,000 feet apart,
aligned perpendicular to groundwater flow. Submersible pumps
located in each well will extract water and pump it directly to
treatment units. It is anticipated that the pumps will be turned
on and off by pressure/demand. The exact number and location of
the wells will be refined during the hydrogeologic investigations
necessary for the DEP's Source Approval Process.
3.
Treatment
National Primary Drinking Water Regulations (NPDWR) (40 CFR
141, Subpart H) require that public water systems supplied by a
groundwater source under the direct influence of surface water
provide filtration and disinfection treatment processes, unless
the supplier can demonstrate that the raw water source meets
stringent criteria for bacteria and other microbiological
contaminants. The filtration treatment steps proposed for iron
and manganese control and the subsequent disinfection step will
satisfy the requirements of 40 CFR 141, Subpart H.
As levels of iron and manganese in the Donna Road Aquifer exceed
federal drinking water standards, included in this alternative,
as with all the possible alternatives, is a potassium
permanganate treatment system. The iron and manganese treatment
system consists of adding potassium permanganate to the extracted
water. The potassium permanganate then causes the iron and
manganese to precipitate out of the water. The process is then
followed by greensand filtration. The greensand acts as a filter
to further remove precipitate.
Although the treatment method is well established, a pilot test
will be performed to assure its effectiveness before design and
implementation. .
4.
Distribution System
Treated groundwater will be piped to the current distribution
system which is within a few hundred feet of the Randolph-
Holbrook water distribution main. No modifications to the
distribution system are anticipated.
Declaration
The selected remedy is protective of human health and the
environment, attains Federal and state requirements that are
applicable for this remedial action and is cost-effective. The
selected remedy utilizes permanent solutions and alternative
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statutory preference for remedies that utilize treatment as a
principal element to reduce the mobility, toxicity, or volume of
hazardous substances is not applicable.
JI: 7/90
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EPA Region I
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ROD DECISION SttMHARy
BAIRD' McGUIRE SITE/ALTERNATE WATER SUPPLY
H
I.
SITE HAME, LOCATION AND DESCRIPTION
Q
The Baird & McGuire site is located on South Street in northwest
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 gate regulating the diversion of river
water to the Richardi Reservoir, a water supply source for the
towns of Holbrook, Randolph, and BLaintree. . This diversion has
been closed since 1983.
Eight of the twenty acres have been owned by the Baird & McGuire,
Inc. since 1912, when chemical manufacturing operations began.
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 distributing
various products, including herbicides, pesticides,
disinfectants, soaps, floor 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 Baird & McGuire site includes a portion of the Cochato River
sediments. This area begins at approximately the center of the
site fence along the Cochato River and extends north to Union
Street.
The South Street wellfield, 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. Studies indicate that contaminants used
or stored at the site were possible sources for contamination of
the well. In December 1982, the Baird & McGuire Site was placed
on EPA's Proposed National Priorities List (NPL).
A more complete description of the Site can be found in the
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II.
SITE HISTORY AND ENFORCEMENT ACTIVITIES
A.
Land Ose and Response History
In 1983, EPA conducted a removal action at the site after 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 from migrating into the river,
regrading the contaminated waste d~sposa1 area and covering it
with a temporary clay cap. In response to the lagoon overflow,
the Tri-Town Water Board (Holbrook, Randolph, and Braintree)
closed the sluice gate located approximately 2.5 miles downstream
from the site that diverted water to the Richardi Reservoir. To
date, the sluice gate remains closed.
v
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, soils and water, and an additional
5,600 feet of fence 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. The water
main passing through the Site was abandoned and filled 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
storage building.
A Record of Decision (ROD) 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 of the-Baird & McGuire
site. The 1986 ROD selected 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
remaining from the original Baird & McGuire buildings will be
incinerated on-Site when the soil incineration portion of the
long-term remedial action program is initiated.
EPA and the U.S. Army Corps of Engineers have completed the
design of the on-site groundwater extraction/treatment/recharge
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awarded the construction contract to Barletta Engineering
Corporation in February 1990. In August 1989, a series of tests
was conducted at EPA's Office of Research and Development
facility in Arkansas aid in determining the operating procedures
that will most effectively destroy soil contaminants. .
Preparation of the incineration system specifications is
currently underway, and the solicitation of bids is expected to
take place during the fall of 1990.
A second ROD for operable unit 13, which addressed Cochato River
sediment contamination, was signed~n september 14, 1989. The
design is expected to begin in the fall of 1990.
This ROD is for operable unit t4 and addresses an alternate water
supply/replacement of lost demand which resulted from the
contamination and subsequent shutdown of the South Street wells.
A more detailed descriptio~ of the site history can be found in
the Focused Feasibility S~diment Study at pages 1-5 through 1-6.
B.
Enforcement History
The Baird & McGuire facility had a lengthy history of violating
environmental laws. From the mid-19S0s on, the company received
numerous citations for violations of the Federal Insecticide,
Fungicide, and Rodenticide Act. Further, both the state and the
local governments took legal actions against the company at
various times.
EPA involvement under the Comprehensive Environmental Response,
Compensation, and Liability Act (CERCLA) began in March 1983 with
the first removal action conducted at the Site. Baird & McGuire,
Inc. ceased operating shortly thereafter, and the company and its
officers took the position that they did not have sufficient
assets to pay for the remedial work necessary at the site.
In October 1983, the united states of America, on behalf of the
Administrator of EPA, filed a cost recovery action under Sections
104(a) and (b) and 107(a) of CERCLA. The comp~aint sought
reimbursement for costs incurred by the united states in
remedying site conditions from Baird & McGuire, Inc., Baird
Realty Co., Inc. (subsequently know as the Ann E. Realty Trust,
Inc.), Cameron M. Baird, and Gordon M. Baird;
Baird & McGuire, Inc. owned and operated the Baird & McGuire
facility. Baird Realty Co., Inc. was a record owner of part of
the Site. Cameron Baird was the president, treasurer, and chief
executive of Baird & McGuire, Inc. Gordon M. Baird (Cameron's
brother) was the chairman of the board of Baird & McGuire, Inc.
The government contends that both individuals exercised control
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The defendants to the lawsuit, as listed above, are also the only
Potentially Responsible Parties ("PRPs") identified to date by
EPA.
The PRPs maintained from early on in discussions with EPA both
that they lacked the financial assets to conduct the remedy and
that they were not liable. The PRPs 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 filed in 1983 was settled on an "ability
to pay" basis in 1987. The Consent Decree that was signed by all
parties in September 1987 includes the following requirements of
the Defendants:
A cash payment to EPA of $900,000, made in two
installments;
. Full EPA access to the Site for the purposes of
. implementing response actions;
Liens on the Baird & McGuire property, which consists
of 2 lots owned by the Ann E. Realty Trust and the
Baird & McGuire lot; 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.
Pursuant to the Baird's assignment to EPA of their rights
regarding insurance policies, EPA has negotiated with insurers of
Baird & McGuire, Inc for cost recovery. To date, no settlements
have been reached with these parties.
The PRPs have had no involvement in the Focused Feasibility
(FFS) and remedy selection process for this operable unit.
notified the public, including the PRPs, of the issuance of
Proposed Plan, but received no PRP comments on the Proposed
Study
EPA
the
Plan.
Special notice has not been issued in this case for the earlier
operable units since the cost recovery case, filed in 1983, was
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III. COMMUNITY RELATIONS
q
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 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 offices in Boston and at the Holbrook
Public Library. The administrative record was updated in June
1989 to include documents used by the Agency for the Cochato
River Sediment Study decision and again in June 1990 for the
Alternate Water Supply/Lost Demand Study. In June 1990 EPA
published a notice and a brief analysis of the Proposed Plan for
this operable unit in The Patriot Ledqer on June 22, 1990 and
made the Plan available to the public at the Holbrook Public
Library.
On June 26, 1990, EPA held an informational meeting to discuss
the alternatives presented in the Alternate Water Supply Focused
Feasibility Study and to present the Agency's Proposed Plan.
Also during this meeting, the Agency answered questions from the
public. From June 27, 1990 to July 26, 1990, the Agency held a
30 day public comment period to accept public comment on the
alternatives presented in the Focused Feasibility Study, the
Proposed Plan and on any other documents previously released to
the public. On July 17, 1990, the Agency held a public hearing
to discuss the Proposed Plan and to accept any oral comments. A
transcript of this meeting, the comments, and the Agency's
response to comments are included in the attached responsiveness
summary.
IV.
SCOPE AND ROLE OF OPERABLE UNIT OR RESPONSE ACTION
As anticipated in the "Future Action" section of the 1986 ROD for
the Site, an Alternate Water Supply Focused Feasibility Study was
performed to select a potential water source that could replace
the lost demand which occurred when the South Street wells were
shut down due to possible contamination resulting from Baird &
McGuire industrial practices. This remedial action will address
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V.
SUMMARY OF SITE CHARACTERISTICS
This ROD does not address Site related contaminants, rather it
involves selecting an alternate water supply to replace the South
Street wells lost demand which occurred because of contamination
from Baird & McGuire. The 1986 and 1989 RODs for operable units
II, 12 and '3 addressed all sources of contamination from the
Baird & McGuire Site. A description of those Site
characteristics can be found in Section 5.20-5.21.5 of the
Remedial Investigation (RI) and Section 5.4-5.42.5 of the
Addendum to the RI and pages 1-12 through 1-17 of the Cochato
River Focused Feasibility Study. No further investigation of the
, Baird & McGuire site was done in connection with this Focused
Feasibility Study or ROD.
VI.
SUMMARY OF BITE RISKS
The Alternate Water Supply FFS study area differs from the RI and
RI Addendum site study area (operable units #1 and #2) and the
FFS Sediment study area (operable unit #3). The risks associated
with each of these operable units were addressed in the 1986 and
1989 RODs. Risks associated with drinking of the groundwater in
the South Street well area, the Lost Demand of which this
alternate water supply will replace, is 4 X 10.3, outside EPA's
risk range of 1 x 10.' to 1 X 10.6. The South Street wells were
closed in 1982 and therefore, no one is currently drinking water.
A complete description of the Baird & McGuire Site risks can be
found in the 1987 Feasibility Study at pages 2-1 through 2-32 and
the Sediment Focused Feasibility Study at pages 1-18 through
1-58.
As this operable unit does not address contamination from the
Baird & McGuire Site, there were no site risks associated with
this fourth operable unit. Therefore no risk assessment was
performed in connection with this study.
VII. DEVELOPMENT AND SCREENING 01' ALTERNATIVES
A.
statutory Requirements/Response Objectives
Under its legal authorities, EPA's primary responsibility 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
EPA's remedial action, when complete, must comply with all
federal and more stringent state environmental standards,
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ff
invoked; 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 preference
for remedies in which treatment which permanently and .
significantly reduces the volume, toxicity or mobility of the
hazardous substances is a principal element over remedies not
involving such treatment. section 121 also provides that if EPA
selects a remedy not appropriate for the above preferences, EPA
is to publish an explanation as to why a remedial action
involving such reduction was not selected. Response alternatives
were developed to be consistent with these Congressional
mandates.
Based on preliminary information such as constraints of the
present water system and known available water sources, a
remedial action objective was developed to aid in the development
and screening of alternatives. The response objective for
operable unit #4 is:
to identify a candidate water sour~e that will replace
the 0.31 million gallons per day (mgd) Lost Demand in
an environmentally sound, cost-effective manner without
placing additional stress On the Great Pond Reservoir
system or existing water treatment facilities.
B.
Technology and Alternative Development and screening
CERCLA and the NCP set forth the process by which remedial
actions are evaluated and selected. In accordance with these
requirements, a range of alternatives was developed for the site.
As discussed in Chapter 3 of the Focused Feasibility study,
alternate water supply sources were identified, assessed and
screened based on implementability, effectiveness, and cost
(Figure 1 and Tables 1 and 2). 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 3 of the Feasibility Study.
In summary, of the 13 alternate water supply sources screened in
Chapter 3, three plus the no action alternative were retained for
detailed analysis. Tables 1 and 2 identify the three
alternatives that were retained through the screening process, as
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VIII.
DESCRIPTION OF ALTERNATIVES
This Section provides a narrative summary of each alternative
evaluated. A detailed tabular assessment of each alternative can
be found in Table 5-3 of the Focused Feasibility Study.
~
A.
Alternate Water (AW) Supply Sources
Alternative NA: No Action lAW-NA)
Analysis of the
and is included
alternative, no
demand would be
No Action alternatLve is required by federal law
for comparison with other alternatives. In this
alternative water supply to replace the lost
developed.
ESTIMATED FIVE-YEAR REVIEW COSTS:
ESTIMATED TOTAL COST (NPW): $ 0
$ 0
Alternative 1:
Reactivation of the Donna Road Aauifer lAW-1)
This alternative has been chosen as EPA's preferred alternative
for the Alternate Water Supply/Replacement of Lost Demand. See
pages 15 through 19 for a discussion of the selected remedy.
Alternative 2:
Increased Farm River Diversion lAW-2)
In this alternative, an additional 0.31 mgd of water would be
diverted from the Farm River into the Richardi Reservoir to
replace the Lost Demand. The Farm River currently provides an
undocumented volume of water to the Richardi Reservoir through a
diversion channel located at the north end of the reservoir.
Currently, water drawn from the Richardi Reservoir is treated and
disinfected at the Randolph-Holbrook water treatment facility.
This facility operates beyond capacity at times, and expansion of
the facility would be necessary if the flow from the reservoir
and, hence to the treatment facility, were increased. The
Randolph-Holbrook Joint Water Board is planning to expand the
capacity of the water treatment plant to address its current
overload situation; implementation of this alternative would be
possible only after completion of the expansion.
Additionally, since levels of iron and manganese in the Farm
River exceed federal drinking water standards, included in this
alternative is a potassium permanganate treatment system to be
installed at the Randolph-Holbrook treatment facility. This iron
and manganese treatment system consists of adding potassium
permanganate to the extracted water; the potassium permanganate
causes the iron and manganese to precipitate (form a solid and
drop out of the solution) out of the water. The process is then
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"
to further remove precipitate. The water would then be
disinfected at the Randolph/Holbrook Water Treatment Plant.
Implementation of this alternative would require compliance with
the Massachusetts Water Management Act (obtaining a water
withdrawal permit) and obtaining a Source Approval under the DEP
"Guidelines and Policies for Public Water Supplies" document.
(See Section X.A.1, page 15, 16 for a description of these
. processes) .
ESTIMATED TIME FOR DESIGN AND CONS~RUCTION: Dependent upon
expansion of the Randolph-Holbrook treatment facility and
DEP permits and approvals.
ESTIMATED CAPITAL COST: $306,000
ESTIMATED 0 & M (Present Worth): $68,100
ESTIMATED TOTAL COST (Present worth): $374,000
Alternative 3:
Diversion of Cochato River (AW-3)
In this alternative, the diversion of the Cochato River into the
Richardi Reservoir would be re-established. The Cochato River is
capable of supplying the 0.31 mgd Lost Demand. Water quality in
the Cochato River was extensively analyzed during this FFS and
during the Cochato River Sediment FFS. The results of these
studies indicated that, like the Farm River and the Donna Road
Aquifer, the only contaminants which exceed federal drinking
water standards are iron and manganese.
Like alternative AW-2, water from the Cochato River would be
currently drawn from the Richardi Reservoir is treated and
disinfected at the Randolph-Holbrook water treatment facility.
This facility operates beyond capacity at times, and expansion of
the facility would be necessary if the flow from the reservoir
and, hence to the treatment facility, were increased. The
Randolph-Holbrook Joint Water Board is planning to expand the
capacity of the water treatment plant to address this current
overload situation; implementation of this alternative would be
possible only after completion of the expansion.
Additionally, since levels of iron and manganese in the Cochato
River exceed federal drinking water standards, included in this
alternative is a potassium permanganate treatment system to be
installed at the Randolph-Holbrook treatment-system. This iron
and manganese treatment system consists o.f adding potassium
permanganate to the extracted water. The potassium permanganate
causes the iron and manganese to precipitate from the water. The
process is then followed by greensand filtration. The greensand
acts as a filter to further remove precipitate. The water would
then be treated at the Randolph/Holbrook water treatment
facility. .
Implementation of this alternative would require compliance with
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2.
3.
4.
5.
6.
7.
8.
9.
10
withdrawal permit} and obtaining Source Approval under DEP
"Guidelines and Policies for Public Water Supplies" document.
(See Section X.A.1, page 15, 16 for a description of these
processes).
ESTIMATED TIME FOR DESIGN AND CONSTRUCTION: Dependent upon
expansion of the Randolph-Holbrook treatment facility and
DEP permits and approvals.
ESTIMATED CAPITAL COST: $306,000
ESTIMATED 0 & M (Present Worth): $68,100
ESTIMATED TOTAL COST (Present worth): $374,000
IX.
SUHMARY OF THE COMPARATIVE ANALYSIS OP ALTERNATIVES
Section 121(b} (1) of CERCLA presents several factors that, at a
minimum, EPA is required to consider in its assessment of
alternatives. Building upon these specific statutory mandates,
the National Contingency Plan articulates nine evaluation
criteria to be used in assessing the individual remedial
alternatives. In addition, for this operable unit, the criteria
from "Guidance Document of Providing Alternate Water Supplies"
(OSWER Directive 9355.03-03) were also used. These criteria
allow for a more focused and detailed analysis of an alternate
water supply alternative than would the nine criteria alone.
Those criteria are consistent with the nine criteria and can be
interchanged in the FFS as follows:
1.
Overall Protection of Human
Health and the Environment
Public Health Analysis
and Environmental
Analysis
Compliance with ARARs
Long-Term Effectiveness and
Permanence
Compliance with ARARs
Performance and
Reliability
Reduction of MObility, Toxicity
or Volume through Treatment
Short-Term Effectiveness
Not Applicable
Timeliness and Safety
Cost
Cost
Imp1ementabi1ity
Imp1ementabi1ity/
Constructabi1ty
State Acceptance
Community Acceptance
state Acceptance
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"
"
11
A detailed analysis was performed on the
evaluation criteria in order to select a
following is a summary of the comparison
strengths and weaknesses with respect to
These criteria and their definitions are
alternatives using the
site remedy. The
of each alternative's
the evaluation criteria.
as follows:
Threshold criteria
The two threshold criteria described below must be met in order
for the alternatives to be eligible for selection in accordance
with the NCP.
1.
Overall protection of human health and the environment
addresses whether or not a remedy provides adequate
protection and describes how risks posed through each
pathway are eliminated, reduced or controlled through
treatment, engineering controls, or institutional controls.
2.
compliance with Applicable or relevant and appropriate
requirements (ARARS) addresses whether or not a remedy will
meet all of the ARARs of other Federal and State
environmental laws and/or provide grounds for invoking a
waiver. .
PrimarY Balancina criteria
The following five criteria are utilized to compare and evaluate
the elements of one alternative to another that meet the
threshold criteria.
3.
4.
5.
6.
Long-term effectiveness and permanence addresses the
criteria that are utilized to assess alternatives for the
long-term effectiveness and permanence they afford, along
with ~he degree of certainty that they will prove
successful.
Reduction of toxicity, mobility, or volume through treatment
addresses the degree to which alternatives employ recycling
or treatment that reduces toxicity, mobility, or volume,
including how treatment is used to address the principal
threats posed by the site.
Short-term effectiveness addresses the period of time needed
to achieve protection and any adverse impacts on human
health and the environment that may be posed during the
construction and implementation period, until cleanup goals
are achieved.
Implementability addresses the technical and administrative
feasibility of a remedy, including the availability of
materials and services needed to implement a particular
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12
Cost includes estimated capital and operation and
Maintenance (O&M) costs, as well as present-worth costs.
Modifvina criteria
7.
~
The mOdifying criteria are used on the final evaluation of
remedial alternatives generally after EPA has received public's
comment on the RI/FS and Proposed Plan.
8.
state acceptance addresses the State's position and key
concerns related to the preferred alternative and other
. .alternatives, and the state's comments on ARARs or the
. proposed use of waivers.
Community acceptance addresses the public's general response
to the alternatives described in the Proposed Plan and RI/FS
report.
9.
A detailed tabular assessment of each alternative according to
the criteria can be found in Table 5-3 of the Feasibility study.
. Following the detailed analysis of each individual alternative, a
comparative analysis, focusing on the relative performance of
each alternative against the criteria, was conducted. This
comparative analysis can be found in Table 3.
The section below presents the criteria and a brief narrative
summary of the alternatives and the strengths and weaknesses
according to the detailed and comparative analysis.
1.
Overall Protection of Human Health and the Environment
AW-1, AW-2, and AW-3 would all be protective of human health and
the environment by providing clean drinking water by treatment.
Each of these alternatives is equally protective since Maximum
Contaminant Levels (MCLs) will be achieved for all compounds
after treatment.
2.
ComDliance with ARARS
Each alternative was evaluated for compliance with ARARs,
including chemical-specific, action-specific, and location
specific ARARs. AW-1 and AW-3 meet their respective ARARs. AW-2
may not meet the requirements of Executive Order 11990
(Protection of Wetlands). Since the present volume of water
being diverted from the Farm River is unknown, it is not possible
to quantify the impact that an additional 0.31 mgd diversion
would have on downstream wetlands. AW-NA would meet ARARS when
the Randolph-Holbrook treatment facility is upgraded to include
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13
3.
. Lona-Term Effectiveness and Permanence
~
Alternative AW-l offers the greatest degree of long-term
effectiveness and permanence. AW-l is expected to be capable of
supplying 0.31 mgd based on previous usage of Donna Road Aquifer
at 0.5 mgd.
Alternatives AW-2 and AW-3 also offer long-term protectiveness
and permanence but, not to as great a degree as AW-l. As noted
above, diverting an additional 0.31 mgd from the Farm River may
have negative impacts on downstream wetlands: therefore, it is
possible that withdrawal might need to be limited at times of low
flow. This potential reduces the degree of certainty that AW-2
will prove successful, and thus makes alternative AW-2 less
effective in meeting EPA's goal of providing a water source to
meet the lost demand. For Alternative AW-3, since no water is
currently being diverted, it is less likely than AW-2 that a low
flow condition would occur.
Alternative AW-NA will not replace the Lost Demand, and will
result in continued reliance on existing water supply and
treatment systems: it is neither effective in the long-term nor
will it provide a permanent replacement of the lost water demand.
4.
Reduction of Mobilitv. Toxicitv. or Volume throuah Treatment
The reduction of mobility, toxicity and volume "through treatment
was determined not to be applicable to this operable unit since
site contaminants are not being treated under this operable unit.
5.
Short-Term Effectiveness
As noted above, since this ROD does not involve treatment of site
contaminants, the short-term effectiveness criteria can not be
evaluated using the time frame for protection of human health and
the environment. This criterion can, however, be used to
evaluate the time frame necessary for implementation.
Alternatives AW-l, AW-2 and AW-3 all require issuance of a
withdrawal permit under the Massachusetts Water Management Act
and each must also go through the Massachusetts Department of
Environmental Protection (DEP) Source Approval Process. It is
estimated that two to three years will be required to develop
Alternatives AW-l, AW-2 or AW-3. Although it appears that AW-2
and AW-3 are equivalent in short-term effectiveness to AW-l,
there are two factors which impact the start of implementation of
alternatives AW-2 or AW-3 that are outside the control of either
EPA or DEP, which make it impossible to predict when the process
would begin. Those factors are: (1) the schedule for increasing
the capacity of the Randolph-Holbrook water treatment facility,
and (2) the schedule for upgrading the Randolph-Holbrook water
treatment facility to achieve the Secondary Maximum Contaminant
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14
implementation of alternatives AW-2 and AW-3 are considered less
timely than AW-1.
Alternative AW-NA does not require performance of any activities,
and will not require any time to implement. However, it is
considered ineffective in the short-term since it does not meet
EPA's objective to provide a water source.
6.
ImDlementabilitv
No engineering problems are foreseen for construction of the
wellfield and required water treatment facilities for AW-1 or
diversions under alternative AW-2 and AW-3. For AW-l the
estimated 16-bY-30-foot treatment building will fit within
available space at the end of Donna Road, and access for facility
construction and for O&M personnel would be via existing streets.
As for Alternatives AW-2 and AW-3, structures are already in
place for diverting the Farm and Cochato Rivers; therefore AW-2
and AW-3 are easily implementable from a technical standpoint.
The major concern with implementability of alternatives AW-2 and
AW-3 is EPA's lack of control over the plans and schedule of the
Randolph-Holbrook Joint Water Board to increase capacity and
. upgrade treatment.
. Since no new construction would be necessary to implement
Alternative AW-NA, the implementability of the no-action
alternative is high. This alternative can be considered already
implemented. .
7.
Cost
The estimated present worth value of each alternative is as
follows:
COST COMPARISON
capital 0'" costs' Present
Costs IS/year) Worth
AW-NA No Action $ 0 0 0
AW-1 Reactivation 992,000 23,000 1,188,000
of Donna Road
Aquifer
'O&M costs are not EPA's responsibility, and EPA will not
provide O&M funds; however, O&M costs for a twenty year period
were included in the estimates to enable comparison of total
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15
capital
Costs
O'K costs2
(S/vear)
Present
Worth
AW-2 Increased
Diversion of
~ the Farm River
AW-3 Cochato River
Diversion
8. state Acceptance
306,000
8,000
374,000
306,000
8,000
374,000
.
The DEP has been involved with the Site from the early 1970's and
throughout the CERCLA process. At the request of DEP, EPA has
included an additional provision in this alternative. This
additional provision involves the use of the Farm River diversion
should the Donna Road aquifer be unable to provide the entire
0.31 mgd. The DEP has reviewed the Alternate Water Supply
Focused Feasibility Study and concurs with the selected alternate
water supply alternative.
9.
Community Acceptance
The comments received during the public comment period and the
discussions during the Proposed Plan and Feasibility Study public
meeting are summarized in the attached document entitled "The
Responsiveness summary" (Appendix A). Generally, all commenters
agreed with EPA's proposed remedy. Commenters did want
assurances, however, that 0.31 mgd of water would be provided.
As outlined in section XI, in response to comments received
during the public comment period, EPA has included in the
selected remedy a provision to supplement the water pumped from
the Donna Road aquifer if Donna Road is unable to produce 0.31
mgd. Commenters, particularly the Baird & McGuire Task Force,
were strongly against AW-3 (Cochato River) as an alternate water
supply, due to a perception that the Cochato River surface water
contains contamination from the Baird & McGuire Site.
x.
THE SELECTED REMEDY
As indicated in section II.A above, this ROD is for operable unit
#4, Alternate Water supply: operable units '1 and '2 were
addressed in the 1986 ROD and operable unit #3 was addressed in
the 1989 ROD.
20&M costs are not EPA's responsibility, and EPA will not
provide O&M funds; however, O&M costs for a twenty year period
were included in the estimates to enable comparison of total
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, 16
A.
Descriotion of Remedial Comoonents
After evaluating all of the feasible alternatives using the
criteria for remedy selection, EPA has selected AW-1, the,
reactivation of the Donna Road Aquifer, as the Alternate Water
Supply to replace the Lost Demand resulting from contamination of
the South Street We11fie1d. AW-1 can be broken into four
components: (1) permitting/pre-design studies, (2) groundwater
extraction, (3) treatment, and (4) delivery to distribution
system. Each component is described below.
1.
PermittinQ/Pre-Desian Studies
Since the Donna Road Aquifer is not part of the Baird & McGuire
Site, Section 121(e), which waives the administrative permitting
requirements for remedial actions conducted on-site, is not
applicable: therefore all necessary federal, state and local
permits must be obtained for this remedial action. Two permits
which will be critical to the timely implementation of this
',remedy will be a water withdrawal permit as required by the
Massachusetts Water Management Act and a new source approval as
required by the DEP "Guidelines and Policies for Public Water
Supplies" document.
The Randolph-Holbrook Joint Water Board currently has a water
withdrawal permit which authorizes them to withdraw a total of
3.27 mgd from the following four points: South street Well No.1
(which was closed in 1982), Donna Road we11fie1d, Richardi
Reservoir and the Great Pond/Upper Reservoir. The Joint Water
Board is currently operating close to that 3.27 mgd capacity; the
addition of 0.31 mgd will exceed the permitted capacity thus
'requiring a new permit. In addition to a new permit for total
volume of water, under the Massachusetts Water Management Act the
addition of a new well constitutes a new withdrawal point and
will also require a new permit.
The application process for the withdrawal permit consists of:
o
Preparation of an application package" including but not
limited to:
general system information
historic and projected withdrawals
water demand estimates
preparation by the Town of Holbrook of a water
conservation program and timetable of
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17
alternatives to the withdrawal
~
potential effects of the withdrawal on surrounding
water based users (e.g., wetlands, ash and
wildlife, recreation)
acceptance by Massachusetts Department of Water
Supply under the source approval guidelines
Notification of abutters and publication of notice of
intent to withdraw water;
o
o
Response to any public comments
DEP also requires a Source Approval for any public drinking water
supply over 100,000 mgd. The Source Approval Permit process is
outlined in the "Guidelines and policies for Public Water
Supplieslt document. The process includes the following nine
steps:
1. Exploratory Phase;
2. site Exam Request;
3, Site Exam;
4 . Pump Test Approval;
5. Pump Test Proposal Review and Approval;
6. Pump Test;
7. Pump Test Report;
8. Final Report; and
9. Approval.
This process is expected to take six (6) month~ to one year.
Further details of each of the nine steps can be found in
Appendix A of the FFS.
Although all studies and historical data indicate the Donna Road
Aquifer should be able to meet the 0.31 mgd Lost Demand under the
Source Approval Process, DEP may limit the pumping of the wells
based on the safe yield (the maximum rate at which the system can
be expected to deliver water continually under a defined set of
drought conditions) of the aquifer. Should the Donna Road
Aquifer be unable to provide the entire Lost Demand of 0.31 mgd,
any incremental difference between 0.31 mgd and the amount of
water the Donna Road Aquifer provides will be obtained by
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18
production of ground water from Donna Road is insufficient to
support the balance between the remedy selection criteria, EPA
will reexamine the remedy. EPA anticipates that a water
production from Donna Road of less than 0.21 may prompt such a
reevaluation.
~
2.
Groundwater Extraction
The extraction system is conceptualized as two 12-inch diameter
wells approximately 40 feet deep, and 800 to 1,000 feet apart,
aligned perpendicular to groundwater flow. Submersible pumps
located in each well will extract water and pump it directly to
treatment units. It is anticipated that the pumps will be turned
on and off by pressure/demand. The exact number and location of
the wells will be refined during the hydrogeologic investigations
necessary for the DEP's Source Approval Process.
3 .
Treatment
National Primary Drinking Water Regulations (NPDWR) (40 CFR
141, Subpart H) require that public water systems supplied by a
groundwater source under the direct influence of surfa.ce water
provide filtration and disinfection treatment processes, unless
the supplier can demonstrate that the raw water source meets
stringent criteria for bacteria and other microbiological
contaminants. The filtration treatment steps proposed for iron
and manganese control and the subsequent disinfection step will
satisfy the requirements of 40 eFR 141, Subpart H.
As levels of iron and manganese in the Donna Road Aquifer exceed
federal drinking water standards, included in this alternative,
as with all the possible alternatives, is a potassium
permanganate treatment system. The iron and manganese treatment
system consists of adding potassium permanganate to the extracted
water. The potassium permanganate then causes the iron and
manganese to precipitate out of the water. The process is then
followed by greensand filtration. The greensand acts as a filter
to further remove precipitate (Figure 2).
Although the treatment method is well established, a pilot test
will be performed to assure its effectiveness before design and
implementation.
4.
Distribution System
Treated groundwater will be piped to the current distribution
system which is within a few hundred feet of the Randolph-
Holbrook water distribution main. No modifications to the
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19
%1.
STATUTORY DETERMINATIONS
The remedial action selected for implementation at the Baird &
McGuire Site 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 effective.
Additionally, the selected remedy utilizes alternate treatment
technologies or resource recovery technologies to the maximum
extent practicable.
A.
~
Tbe Selected Remedy 1. Protective of Human Healtb and tbe
Environment
The remedy at this site will permanently reduce the risks posed
to human health and the environment by eliminating, reducing or
controlling exposures to human and environmental receptors
through treatment, engineering controls, or institutional
controls; more specifically, since water from the Donna Road
Aquifer meets all MCLs, and Massachusetts Maximum contaminant
Levels (MMCLs) except sodium, and can meet all Maximum
contaminant Level Goals (MCLGs), Secondary Maximum contaminant
Levels (SMCLs) with treatment the remedy is considered protective
of human health and the environment. Implementation of the
selected remedy will not pose unacceptable short-term risks or
cross-media impacts, since any wetland impacts will be mitigated,
if necessary, by the source approval process limiting pumping
rates.
B.
Tbe Selected Remedy Attains Applic~l. Requirements
This remedy will attain all applicable federal and state
requirements that apply to the site. Since this remedy is being
conducted entirely off-site only applicable requirements,
including obtaining all applicable permits will be required.
Environmental laws from which applicable requirements for the
selected remedial action are derived, and the specific applicable
requirements include:
Chemical SDecific
Safe Drinking Water Act
Massachusetts Drinking Water Regulations
Location Specific
Executive Order 11990 (Wetlands Protection)
Fish and Wildlife Coordination Act
Clean Water Act
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20
Resource Conservation and Recovery Act (Land Ban)
Massachusetts Wetlands Protection Act
Massachusetts Waterways Act
Massachusetts Surface Water Quality Standards
Massachusetts Ground Water Quality Standards
Massachusetts Water Quality Certification and Certification of
Dredging
Massachusetts Water Management Act
Massachusetts Supervision of Inland Waters
,
Action Specific
Occupational Safety and Health Act
Massachusetts Guidelines & Policies for Public
Water Systems
A discussion of why these requirements are applicable may be
found in the FFS Report at pages 2-1 through 2-23 and pages 5-33
through 5-55.
1.
Chemical-specific Applicable Reauirements
a.
Safe Drinkinq Water Act
Since the purpose of this FFS was to develop a drinking water
source to replace the lost demand from the South Street wells,
the National Primary Drinking Water Regulations (NPDWR) which
establish Maximum Contaminant Levels (MCLs) that specify the.
maximum permissible level of a contaminant in water used as a
public water supply are applicable.
National Secondary Drinking Water Regulations establish Secondary
Maximum contaminant Levels (SMCLs), are also applicable and can
be met with treatment.
b.
Massachusetts Drinkinq Water Reaulations
As with the National Primary Drinking Water Regulations, since
the purpose of this remedy is to establish a drinking water
source for the Town of Holbrook, the Massachusetts Drinking Water
Regulations (310 CMR 22.00) are applicable to this remedy. Data
indicate that water from the Donna Road Aquifer meets all MMCLs
except for sodium (27 mg/L versus 20 mg/L). The MMCL for sodium
is based on the amount of sodium recommended from drinking water
for individuals on a reduced-sodium diet. DEP generally does not
shut down a water supply because sodium levels slightly exceed
the MMCL: rather, it requires the water supplier to notify
persons served by the water supply of the sodium levels and
possible ways of correcting the situation (310 CMR 22.16), thus
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21
2.
Location-specific Applicable Reauirements
a.
Executive Order 11990 (Wetlands Protection}
Executive Order 11990, Wetlands Protection, is applicable to
actions involving construction of facilities in wetlands or
alterations of wetland property. Since AW-1 is located in a
wetland, the Wetland Executive Order is applicable.
b.
Fish and Wildlife Coordination Act
,
The Fish and Wildlife Coordination Act (16 USC 661 ~ sea.)
requires that before issuing a federal permit or undertaking any
federal action that causes the impoundment (with certain
exemptions), diversion, or other control or modification of any
body of water, the applicable federal agency must consult with
(1) the appropriate state agency exercising jurisdictions over
wildlife resources; (2) the u.s. Fish and Wildlife Service.
(USFWS) and the National Marine Fisheries Service, within the
Department of Interior; and (3) the National Marine Fisheries
Service, within the Department of Commerce. Since AW-1 is to
take place in the Trout Brook bottomland this Act is applicable.
c.
Clean Water Act
section 402 of the Clean Water Act (CWA) regulates the discharge
of pollutants into navigable waters of the U.S. A National
Pollutant Discharge Elimination System (NPDES) permit must be
obtained from EPA or a delegated state agency for such a .
discharge. The discharge of filter backwash from a water
treatment facility to a surface water body would require an NPDES
permit. .
section 404 of the CWA regulates the discharge of dredged and
fill materials to waters of the U.S. Filling wetlands would be
considered a discharge of fill material to waters of the U.S. If
construction of access roads in the Trout Brook bottomland are
deemed necessary during the permitting process or pre-design
studies, it would be considered a disturbance 9f a wetland and
section 404 of the CWA would be applicable.
d.
Rivers and Harbors Act of 1899
section 10 of the Rivers and Harbor Act of 1899 requires
authorization from the Secretary of the Army, acting through the
U.S. Army Corps of Engineers (USACE), for the construction of any
structure in or over any "navigable water of the U.S.," the
excavation from or deposition of material in such waters, or any
obstruction or alteration in such waters. Should additional
diversion be needed to supplement the Donna Road supply by using
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22
e.
Resource Conservation and Recoverv Act (Land Ban)
Since this ROD does not involve the disposal or treatment of
hazardous substances, land ban requirements are not applicable.
f.
Massachusetts Wetlands Protection Act.
At the state level, similar to the Wetlands Executive Order,
wetlands and land subject to flooding are protected under the
Massachusetts Wetlands Protection ~ct (MGL, Chapter 131) and
wetlands regulations at 310 CMR 10.00. Since AW-1 involves work
in the wetlands, the Act is applicable.
g.
Massachusetts Waterways Act
The Massachusetts Waterways Act (MGL, Chapter 91) and regulations
at 310 CMR 9.00 require that a license from DEP be obtained for
any work in or over any tidelands, river or stream (with respect
to which public funds have been expended), or great pond, or any
outlet thereof. Farm and Cochato Rivers are considered to be
subject to these regulations. Should additional diversion be
needed to supplement the Donna Road supply by using the Farm
River, this Act would be considered applicable. .
Massachusetts Surface Water Ouality Standards and
Ground Water Ouality Standards
The Massachusetts Surface Water Quality Standards and Ground
Water Quality Standards (314 CMR 4.00 and 314 CMR 6.00,
respectively) set forth procedures to be used by the state in
classifying surface water and groundwater according to the uses
which the class is intended to protect. For each class, the most
sensitive beneficial uses are identified and minimum criteria for
water quality are established. The regulations establish three
classes for inland surface waters according to the most sensitive
and therefore governing uses the classes are intended to protect.
In accordance with 314 CMR 4.04 and 6.04, the quality of surface
water will be maintained and protected to sustain existing
beneficial uses. In addition, water whose quality is or becomes
higher will be maintained at that higher level of quality unless
limited degradation is authorized. Since AW-1 involves surface.
water discharge permits, the standards are applicable.
h.
i.
Massachusetts Water Ouality Certification and
Certification of Dredaing
For activities that require a DEP Wetlands Order of Conditions to
dredge or fill waters or wetlands, a Chapter 91 Waterways
License, a US ACE permit, or any major permit issued by EPA (e.g.,
CWA NPDES permit), a Massachusetts Division of Water Pollution
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23
required. As in Section XI.B.2.c above, if an additional access
road is necessary then this certification is applicable.
j.
Massachusetts Water Manaaement Act
Under the Massachusetts Water Management Act (MGL Chapter 21G)
and regulations (310 CMR 36.00), DEP, in conjunction with the
Executive Office of Environmental Affairs Water Resource
Commission, implements a program to assess and regulate the use
of water in the state, plan for future water needs, and assess
the safe yields of all river basins.
The program requires registration with the DEP Division of Water
Supply (DWS) of withdrawals of ground or surface water in
Massachusetts above an daily average of 100,000 gallons for a
quarter year. A permit must be obtained prior to making a new
withdrawal in excess of the threshold volume from a water source
or constructing the means to make the withdrawal. A new
withdrawal also includes an increase above the registered
withdrawal in excess of the threshold value of 100,000 gallons
per day. Alternative AW-1 includes a withdrawal over the.
threshold, a new withdrawal and an increase above the registered
withdrawal, thus the Water Management Act is applicable.
k.
Massachusetts Supervision of Inland Waters Act
Section 111, MGL Chapters 159 and 160, gives general oversight
and care of all inland waters and of all streams, ponds and
underground waters used by any city or town in the commonwealth
as sources of water. The provision requires recordkeeping by
DEP. Since the Donna Road aquifer is an underground water, this
Act is applicable.
3.
Action-specific Applicable Requirements
a.
Occupational Safetv and Health Act
The Occupational Safety and Health Administration (OSHA)
standards (i.e., 29 CFR 1910, 1904, and 1926) apply to worker
safety, and require employers to communicate risks at the
workplace to employees. OSHA standards must be complied with
during all site work.
b.
Massachusetts Guidelines & Policies for Public
Water Systems
The DEP DWS published a document that provides guidance for the
exploration, evaluation, treatment, storage/distribution, and
protection of new public water supply sources (DEP, 1990). For
all groundwater withdrawals, the document specifies an
exploration phase, site exam, five-day pump test, requirements
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24
C.
The Selected Remedial Action ia Coat-Effective
In the Agency's judgment, the selected remedy is cost-effective,
i.e., the remedy affords overall effectiveness proportional to
its costs. In selecting this remedy, once EPA identified
alternatives that are protective of human health and the
environment and that attain, or, as appropriate, waive applicable
requirements, EPA evaluated the overall effectiveness of each
alternative by assessing the relevant three criteria--Iong term
effectiveness and permanence; reduction in toxicity, mobility,
and volume through treatment; and short-term effectiveness, in
combination. The relationship of the overall effectiveness of
this remedial alternative was determined to be proportional to
its costs. The costs of this remedial alternative are: $992,000
in capital costs, and $23,000 annually for 20 years for operation
and maintenance, resulting in a total net present worth of
$1,188,000.
Each of the alternatives evaluated is protective of human health
and the environment; however, when evaluated in conjunction with
short- and long-term effectiveness and permanence, Alternative
AW-1 is the most cost-effective. AW-1 will provide a separate
water source that has been shown to be able to produce in excess
of the 0.31 mgd lost demand. Alternative AW-1 is most effective
in the short-term since, unlike AW-2 and AW-3 it is not dependent
on the Randolph-Holbrook Joint Water Board for upgrade of the
treatment plant. Alternative AW-2 may impact downstream wetlands
which could cause water withdrawal to be restricted. As noted
above, the reduction of mobility, toxicity and volume was
determined not to be applicable to this operable unit because
site contaminants are not being treated under this remedy.
D.
The Selected Remedy utilizes Permanent Solutions and
Alternative Treatment or Resource Recovery Technologies
to the Maximum Extent Practicable
Once the Agency identified those alternatives that attain or, as
appropriate, waive applicable requirements and that are
protective of human health and the environment, EPA attempts to
identify which alternative utilizes permanent solutions and.
alternative treatment technologies or resource recovery
technologies to the maximum extent practicable. This
determination was made by deciding which one of the identified
alternatives provides the best balance of trade-offs among
alternatives in terms of: 1) long-term effectiveness and
permanence; 2) reduction of toxicity, mobility or volume through
treatment; 3) short-term effectiveness; 4) implementability; and
5) cost. The balancing test emphasized long-term effectiveness
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25
through treatment; and considered the preference for treatment as
a principal element, the bias against off-site land disposal of
untreated waste, and community and state acceptance. The
selected remedy provides the best balance of trade-offs among the
alternatives. As the scope of this operable unit does not
include treatment of site contaminants, each alternative,
including the selected remedy, utilizes permanent solutions and
alternative treatment technologies or resource recovery
. technologies to the maximum extent practicable.
~
E.
The Preference for Treatment Which Permanently and
significantly Reduces the Toxicity, Mobility or Volume
of the Hazardous Substances as a Principal Element is
Not Applicable to the Selected Remedy
The reduction of mobility, toxicity and volume was determined not
to be applicable to this operable unit since treatment of site
contaminants is not an objective of this operable unit.
XII. DOCUMENTATION. OF SIGNIFICANT CHANGES
EPA presented a proposed plan (preferred alternative) for
remediation of the site on June 26, 1990. The alternate water
supply preferred alternative was AW-l Reactivation of the Donna
Road Aquifer. This Alternative included the following four
elements: (1) permitting/pre-design studies, (2) groundwater
extraction, (3) treatment, and (4) delivery to distribution
system. Based on public comment, the following two components
were added to the selected alternative:
1.
should the Donna Road Aquifer be unable to provide the
entire lost demand of 0.31 mgd, any incremental difference
between 0.31 mgd and the amount of water the Donna Road
Aquifer provides will be obtained by increasing the
diversion of the Farm River. If however, the production of
ground water from Donna Road is insufficient to support the
balance between the remedy selection criteria, EPA may
reexamine the remedy. EPA anticipates that a water
production from Donna Road of less than 0.21 may prompt such
a reevaluation; and
2.
in addition to the routine monitoring required at public
drinking water supplies, a yearly round of sampling, full
TCL organics, TAL inorganics and pesticides will be
-------
26
XIII. STATE ROLE
The Massachusetts Department of Environmental Protection has
reviewed the various alternatives and has indicated its support
for the selected remedy. The state has also reviewed the
Alternate Water Supply Focused Feasibility Study to determine if
the selected remedy is in compliance with applicable or relevant
and appropriate State Environmental laws and regulations. The
State of Massachusetts concurs with the selected remedy for the
Baird & McGuire Site Alternate Water Supply Study. 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.
In the case of the selected remedy the Commonwealth's share is
estimated to be 118,800.
-------
BAIRD' MCGUIRE SITE
ALTERNATE WATER SUPPLY
TABLE OF CONTENTS
Contents
Pac:re Number
I.
SITE NAME, LOCATION AND DESCRIPTION
. . .
. . . .
. . .
II.
SITE HISTORY AND ENFORCEMENT ACTIVITIES. . . . . . . .
A. Land Use and Response HistorY. . . . . . . . . . .
B. Enforcement History. . . . . . . . . . . . . . . .
III. COMMUNITY RELATIONS
. .' . .
. . .
. . .
. . . . .
. . .
IV. SCOPE AND ROLE OF OPERABLE UNIT OR RESPONSE ACTION . . .
V. SUMMARY OF SITE CHARACTERISTICS . . . . . . . . . . . .
VI. SUMMARY OF SITE RISKS . . . . . . . . . . . . . . . . .
VII. DEVELOPMENT AND SCREENING OF ALTERNATIVES. . . . . . .
A. Statutory Requirements/Response Objectives. . . .
B. Technology and Alternative Development and
Screening. . . . . . . . . . . . . . . . . . . . .
VIII.
A.
DESCRIPTION OF ALTERNATIVES. . . .
Alternate Water CAW) Supply Sources
. . . .
. . . .
. . .
. . . .
IX.
SUMMARY OF THE COMPARATIVE ANALYSIS OF ALTERNATIVES
X.
THE SELECTED REMEDY
. . . . . . . . .
. . . . . . . . .
XI.
STATUTORY DETERMINATIONS. . . . . . . . . . . . . . . .
A. The Selected Remedy is Protective of Human Health
and the Environment. . . . . . . . . . . . . . . .
The Selected Remedy Attains Applicable
Requirements. . . . . . . . . . . . . . . . . . .
The Selected Remedial Action is Cost-Effective
The Selected Remedy Utilizes Permanent Solutions
and Alternative Treatment or Resource Recovery
Technologies to the Maximum Extent Practicable. .
The Preference for Treatment Which pe.rmanently and
Significantly Reduces the Toxicity, Mobility or
Volume of the Hazardous Substances as a Principal
Element. . . . . . . . . . . . . . . . . . . . . .
B.
C.
D.
E.
XII. DOCUMENTATION OF SIGNIFICANT CHANGES. .
. . . .
. . . .
XIII. STATE ROLE
. . . . . . . .
. . . . . .
. . . .
. . . .
1
2
2
3
5
5
6
6
6
6
7
8
8
10
15
19
19
19
24
24
25
25
-------
LIST OF TABLES
Summary of Groundwater Source Screening. . . . . . . . Table 1
Summary of Surface Water Source Screening. . . . . . . Table 2
Comparative Summary of Water Supply Alternatives. . . Table 3
C'
LIST OF PIGUUS
Candidate Site Locations. . . . . . . . . . . . . .
Donna Road Conceptual Treatment Schematic. . . . . .
.Figure 1
.Figure 2
APPENDICES
Responsiveness Summary. . . . . . . . . .
Administrative Record Index. . . . . . . .
State Concurrence Letter. . . . . . . . .
. . .
. Appendix A
. Appendix B
. Appendix C
. . .
. . .
i
,
.
..
-------
TABLE
1
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..IIID . ttCOUI.
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-------
TABLE
2
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-------
CUI1IRIA
DONNAIIOAD MKIIPIIII.
POIHIIPJlINO A.NA.LYSIS
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TABLE
3
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WA'ID IUffLY I'BAII8IUfY ITUDY
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-------
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pvaOHM2HI'AL ANALYSIS IC-1-
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TABLE
3
(~
CQM.Al.A11Y8 IIJIiIMA8Y OP WA'ID SUPPLY AL1"DNA11V8I
8AI8D. MCQUiaB
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-------
r'
.
...
..-..,
8000
CANDIDATE SITE LOCATIONS
BAIRD & McGUIRE
WATER SUPPLY FEASIBILITY STUDY
Ec.x:;mA.NCO
teAL! IN FUT
~
~u.oe
-------
POTASSIUM
PERIIAIIGANATEl
. ~:W WATER
0.3' ...
SUPERNATANT
EXTRACTION WELLS
FIGlJRE 2
GR£ENSAND fLTERS (3)
CtLORINE
...
SETTLING TANK.J'
I
fLTEA BACKWASH
SETTLED SOLIDS
.... TO DISPOSAL
CtLOR8E CONTACT TANK
r: CLEARWELL
I I fHSHED WATER
TO DISTRIBUTION
0.31 ...
DONNA ROAD CONCEPTUAL TREATMENT SCHEMATIC
BAIRD & McGUIRE
-------
APPENDIX A
RESPONSIVENESS SUMMARY
-------
4
BAIRD & McGUIRE SUPERFUND SITE
WATER SUPPLY FEASIBILITY STUDY
RESPONSIVENESS SUMMARY
TABLE OF CONTENTS
I.
OVERVIEW OF REMEDIAL ALTERNATIVES CONSIDERED IN THE
DRAFT FEASIBILITY STUDY, INCLUDING THE PREFERRED
ALTERNATIVE. . . . . . . . . . . . . . . . . . . . . .
II.
BACKGROUND ON COMMUNITY INVOLVEMENT AND CONCERNS.
. . .
III. SUMMARY OF COMMENTS RECEIVED DURING THE PUBLIC COMMENT
PERIOD AND EPA RESPONSES. . . . . . . . . . . . . . . .
A. Comments Regarding the Donna Road Aquifer. . . . .
B. Comments Regarding the Cochato River Diversion. . .
C. Comments Regarding Health Concerns. . . . . . . . .
IV.
REMAINING CONCERNS. . .
. . .
. . . . .
. . .
. . . . .
ATTACHMENT A - COMMUNITY RELATIONS ACTIVITIES CONDUCTED AT
THE BAIRD & MCGUIRESUPERFUND SITE
ATTACHMENT B - TRANSCRIPT OF THE JULY 17, 1990 INFORMAL
PUBLIC HEARING
3
4
6
7
9
9
-------
PREFACE
The U. S. Environmental Protection Agency (EPA) held a
30-day public comment period from June 27, 1990 to July 26, 1990
to provide an opportunity for interested parties to comment on
the Water Supply Focused Feasibility Study (FFS) and the June
1990 Proposed Plan prepared for the Baird & McGuire Superfund
site in Holbrook, Massachusetts. The FFS examines and evaluates
various options, called remedial alternatives, to replace the
Lost Demand arising from Baird and McGuire industrial activities.
EPA has defined the Lost Demand as the daily rate of groundwater
production that the town of Holbrook historically imposed on the
South Street wells for use within uhe town, and subsequently lost
as a result of Baird and McGuire industrial activities. EPA
identified its preferred alternative for replacing the Lost
Demand in the Proposed Plan issued in June 1990, before the start
of the public comment period.
To facilitate an efficient 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 Feasibility Study 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 alternative for addressing these
contaminated areas and, in September 1986, signed a Record of
Decision (ROD) that established EPA's plans for cleanup of the
first two operable units. 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 focused
on site-related contamination found in the Cochato River
sediments and adjacent wetlands. In 1989, EPA completed a FFS
for the third operable unit and held a public comment period on
it's preferred alternative for addressing these contaminated
areas. In September 1989 EPA signed a ROD that established
another step in EPA's plan for Site cleanup: contaminated
sediments will be excavated and incinerated at the incinerator
that will be located on-site for soil treatment at the Baird &
McGuire Site. This ROD for the fourth operable unit and
evaluates remedial alternatives to replace municipal water
supplies 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 fourth operable unit, the Proposed
Plan, and the Water Supply Focused Feasibility Study. EPA will
consider all of these questions and comments before selecting a
final remedial alternative to address replacement of the Lost
Demand.
-------
This Responsiveness Summary is divided into the following
sections:
I.
~I.
overview of Remedial Alternatives considered in the Draft
Focused Feasibility Study, Includinq the Preferred
Alternative-This section briefly outlines the remedial
alternatives evaluated in the FFS and the Proposed Plan,
including EPA's preferred alternative.
Background 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 During the Public Comment
Period and EPA Responses-This section summarizes the oral
and written comments received from the public during the
public comment period and provides EPA responses to these
comments.
IV.
Remaining 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 replacing
the Lost Demand at the Baird & McGuire Site. EPA will
address these concerns during the Remedial Design and
Remedial Action (RDjRA) phase of the replacement process.
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 & McGuire Site. Attachment B contains a copy of the
transcript from the informal public hearing held on
July 17, 1990.
I.
OVERVIEW OF REMEDIAL ALTERNATIVES CONSIDERED IN THE DRAFT
FEASIBILITY STUDY, INCLUDING THE PREFERRED ALTERNATIVE
EPA has identified a specific objective for the Water Supply
Focused Feasibility Study. The objective is to identify a
candidate water source that will replace the 0.31 million gallons
per day (mgd) Lost Demand in an environmentally sound, cost-
effective manner without placing additional stress on the Great
Pond Reservoir system or existing water treatment facilities.
EPA has screened and evaluated several potential replacement
alternatives for the Baird & McGuire site in the Water Supply
Focused Feasibility Study. The FFS describes alternatives for
replacing the Lost Demand, as well as the screening criteria used
to narrow the list to four potential remedial alternatives. Each
of these alternatives is described briefly below.
-------
.
No Action (AW-NA). In this alternative, the Lost Demand
would not be replaced.
Alternative 1 (AW-l): Reactivation of the Donna Road
Aquifer. In this alternative, the Donna Road Aquifer would
be reactivated by installing new wells: water would then be
brought to the surface using submersible pumps. The water
would then be treated in an on-site treatment plant to
remove iron and manganese. Treated water would be
disinfected prior to being pumped to the existing Holbrook
water distribution system.
.
In the Proposed Plan issued prior to the public comment
period, EPA recommended this alternative as its preferred
remedy for addressing the Lost Demand.
.
Alternative 2 (AW-2): Increased Farm River Diversion. In
this alternative, an additional 0.31 mgd would be diverted
from the Farm River into the Richardi Reservoir to replace
the Lost Demand. Water would be treated to remove iron and
manganese and then be disinfected at the Randolph-Holbrook
Joint Water Treatment Plant.
.
Alternative 3 (AW-3): Cochato River Diversion. In this
alternative, the diversion of the Cochato River into the
Richardi Reservoir would be re-established to supply the
0.31 mgd Lost Demand. Water would be treated to remove iron
and manganese and then be disinfected at the Randolph-
Holbrook Joint Water Treatment Plant.
Additional information on each of the remedial alternatives can
be found in the Focused Feasibility study for the Water Supply
Operable Unit, copies of which are located in the Holbrook Public
Library and the EPA Records Center at 90 Canal Street in Boston,
Massachusetts.
II.
BACKGROUND ON COMMUNITY INVOLVEMENT 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, Incorporated
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 Site is located near the western bank of the Cochato River,
-------
~
and is approximately 1,500 feet away from the Holbrook South
Street well field.
~
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 breach in the
Baird & McGuire creosote lagoon in 1983, 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 ~82, 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 dioxins were discovered
in Site soils. Further work was conducted at the site during the
1987 IRM, including the removal of certain site buildings and
placement of a temporary cap over site soils to prevent contact
with contaminants. The tank farm and mixing buildings were
demolished by EPA during a 1987 Initial Remedial Measure (IRM)
which was conducted to address aspects of site contamination
prior to implementing long-term remedial measures.
Community concern surrounding contamination at the Baird &
McGuire site 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
concerns were received by EPA. In addition, a local citizens'
group, People united to Restore the Environment (PURE), was
formed at that time.
Following release of the 1985 RI, EPA held a public meeting
to present the results of the RI on June 10, 1985. Over 200
people attended the meeting and presented a petition containing
over 1,000 signatures. Principal concerns expressed in the
petition included requests for fencing of the Site: a
comprehensive health study: removal of site buildings: diversion
of the town water main passing through 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 agency. This committee, known as the
Baird & McGuire Task Force, was organized soon afterwards with
broad representation from both residents and local officials.
-------
EPA has met regularly with the Task Force to present new 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 Department of Environmental Protection (DEP),
formerly Massachusetts Department of Environmental Quality
Engineering, 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 briefing and subsequent Site-related
events received extensive media coverage.
In 1989, EPA held a public comment period and a public
meeting on the Cochato River Sediment Study Area FFS and Proposed
Plan. The meeting included a presentation by the Baird & McGuire
Task Force.
EPA conducted a ground-breaking ceremony on May 11, 1990 to
begin construction of the groundwater treatment plant authorized
in the 1986 ROD. The event was attended by local residents and
officials and received extensive media coverage.
Public involvement in the Superfund process has continued at
a high level throughout the RI/FS process, and the Task Force
continues to meet on a regular basis with EPA. A public meeting
held in June 1990 on the Water Supply Focused Feasibility Study
and Proposed Plan was attended by approximately 15 persons
including representatives of the Town of Holbrook and the Baird &
McGuire Task Force. The principal community concerns expressed
at that time are as follows:
.
Residents and officials expressed overall support for
development of the Donna Road Aquifer, EPA's preferred
alternative, but stated that EPA should conduct extensive
groundwater testing to verify that nearby industrial
activities are not likely to contaminate the Donna Road
Aquifer.
.
Residents and officials stated their concern that
implementation of the Lost Demand Replacement be conducted
as soon as possible.
.
Meeting attendees overwhelmingly stated their opposition to
reactivation of the Cochato River diversion.
III. SUMMARY OF COMMENTS RECEIVED DURING THE PUBLIC COMMENT
PERIOD AND EPA RESPONSES
This Responsiveness Summary addresses the comments received
by EPA concerning the draft FFS and Proposed Plan for the Water
-------
supply Operabl~ Unit for the Baird & McGuire Superfund Site in
Holbrook, Massachusetts. Four sets of written comments were
received during the public comment period (June 27-
July 26, 1990). Eight oral comments were presented at the July
17, 1990 informal public hearing. Commenters included
representatives of the Baird & McGuire Task Force, the Holbrook
Board of Selectmen, the Holbrook Conservation Commission, and a
resident. A copy of the transcript is included as Attachment B.
Copies for the transcript 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, as a part of EPA's
Administrative Record. '
The comments from citizens, along with EPA responses, are
summarized and organized into the following categories:
A.
Comments Regarding the Donna Road Aquifer;
B.
Comments Regarding the Cochato River Diversion; and
C.
Comments Regarding Public Health Concerns.
A list of commenters can be found on page? of this
document.
1.
Comments Regarding the Donna Road Aquifer
Four commenters requested that EPA adequately
characterize groundwater quality of the Donna
before construction of groundwater extraction
facilities.
test and
Road aquifer
and treatment
A.
EPA's Response 1
The Massachusetts Guidelines and Policies for Public Water
Systems document defines a detailed testing and evaluation
program that must be followed in order for the Donna Road
aquifer to be approved as a public water supply. The
guidelines include requirements for testing the groundwater
for the presence of both organic and inorganic substances.
As is required under CERCLA, EPA must comply with all
applicable laws, and therefore will follow the Massachusetts
guidelines in implementing the remedy.
2 .
Two commenters requested EPA evaluate additional diversion
of the Farm River, if further testing indicates the Donna
Road aquifer can not replace the entire 0.31 million gallons
per day (mgd) Lost Demand.
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EPA's Response 2
EPA believes the Donna Road aquifer is capable of replacing
the 0.31 mgd Lost Demand. This is based not only on recent
aquifer modeling, but also on the fact that the Town of
Holbrook historically withdrew 0.5 mgd from the formerly
used we11fie1d. However, if evaluations conducted during
the Source Approval process indicate that the entire 0.31
mgd is not available from the Donna Road aquifer, EPA may
supplement the aquifer by diverting the incremental
difference from the Farm River to the Richardi Reservoir.
If however, the production of ground water from Donna Road
is insufficient to support the balance between the remedy
selection criteria, EPA may reexamine the remedy.
3 .
One commenter requested EPA outline a schedule to "fast-
track" the water supply New Source Approval process.
EPA's Response 3
EPA's estimate of the time needed to obtain New Source
Approval for the Donna Road aquifer is based on the
extensive requirements of the Massachusetts review and
approval process. The Superfund Amendments and
Reauthorization Act (SARA) requires that EPA follow all
applicable requirements such as the Massachusetts
regulations that govern public water supplies. Since the
Source Approval process is a State and not a Federal
program, EPA has no control over its duration or
requirements. EPA will however, work with MA DEP in order
to implement the alternative in a timely manner.
4 .
One commenter requested EPA estimate the future cost of
operating the Donna Road wellfield to enable the Town of
Holbrook to evaluate the cost and benefits of the proposed
alternative.
EPA's Response 4
The Water Supply Focused Feasibility Study document prepared
by EPA's technical contractor, which was available during
the public comment period, estimates the annual operation
and maintenance costs to be $23,000. Copies of the document
are available to Town officials and citizens at the Holbrook
Public Library.
5.
One commenter requested EPA define a testing program in the
Record of Decision to monitor treated water quality after
construction and start-up of the proposed water treatment
facility at Donna Road.
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EPA's Response 5
The proposed Donna Road facility wi~l be subject to
operational testing programs already defined in the National
Primary Drinking Water Regulations (40 CFR 141, Subpart C)
as well as in Massachusetts Drinking Water Regulations (310
CMR 22.00). These regulations define the type and frequency
of required testing at Donna Road. Based on this comment,
EPA has added a provision "in the ROD which requires full TCL
organics, TAL inorganics and pesticides testing annually.
6.
An aquifer pump test will need to be performed at the Donna
Road Site during the design phase to comply with
Massachusetts Division of Water Supply regulations.
EPA's Response
An aquifer pump test is planned as part of the detailed
evaluation to obtain Source Approval for the Donna Road
aquifer.
B.
Comments Regarding the Cochato River Diversion
7.
Two commenters requested that EPA not consider reactivation
of the Cochato River diversion for replacing the Lost
Demand.
EPA's Response 7
EPA chose the reactivation of the Donna Road Aquifer to
replace the Lost Demand rather than the Cochato River
diversion based on the remedy selection criteria. During
EPA's evaluation and subsequent selection of the Donna Road
alterative, EPA considered public attitudes regarding future
use of the Cochato which EPA had heard during EPA public
meetings and Baird & McGuire Task Force meetings.
C.
Comments Regarding Health Concerns
8.
One commenter requested that impacts from releases of
hazardous substances at two businesses located on South
Franklin Street southeast of the Donna Road site should be
reviewed during the evaluation process.
EPA's Response 8
The Massachusetts Division of Water supply requires in the
Source Approval process that part of the evaluation of the
Donna Road aquifer include delineation of a Zone II aquifer
protection zone. This is the area of an aquifer that
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contributes water to a well under the most severe pumping
and recharge conditions that can realistically be
anticipated (i.e., 180 days of pumping, with no recharge
from precipitation). The Zone II delineation will evaluate
anticipated impacts, if any, from the businesses on South
Franklin Street.
9.
One commenter asked if the contaminant plume from the Baird
& McGuire Superfund Site might reach and contaminate the
Donna Road aquifer as it did the South Street wells.
EPA's Response 9
EPA believes, based on the current understanding of area
hydrogeology, contamination of the Donna Road aquifer by the
Baird & McGuire Site is unlikely. Groundwater flow in the
vicinity of Donna Road and the Baird & McGuire Site moves
downgradient in a general northerly direction. The Donna
Road site is more than one mile south of the Baird & McGuire
Superfund Site, approximately four times further than the
South Street wells. The proposed pumping rate of 0.31 mgd
is not considered adequate to induce the Baird & McGuire
contaminant plume into the capture zone of the Donna Road
wellfield. Lake Holbrook, located midway between the Donna
Road Site and the Baird & McGuire Superfund Site, serves as
a hydrologic flow boundary and would help prevent
contaminant migration toward Donna Road. The computer
mOdeling and Zone II delineation required as part of the New
Source Approval process will provide additional insight into
the northerly flow of groundwater past the Donna Road Site.
10.
One commenter requested EPA limit movement of large
construction vehicles on neighborhood streets during
periods when children are going out to, or returning
school.
the
from
EPA's Response 10
EPA will instruct contractors to exercise.extra caution
whenever driving on neighborhood streets and, to limit
traffic during periods when children are going out to, or
returning from school.
IV.
REMAINING CONCERNS
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. EPA will continue to address these
issues as more information becomes available during the RD/RA.
-------
1.
Residents and officials strongly urged EPA to conduct
extensive groundwater sampling to ensure that contaminated
groundwater and potential sources of groundwater
. contamination are not located in proximity of the Donna Road
Aquifer.
As indicated above, the Massachusetts Division of Water
Supply requires in the Source Approval process that part of
the evaluation of the Donna Road aquifer include delineation
of a Zone II aquifer protection zone. The Zone II
delineation will evaluate anticipated impacts, if any, from
the potential sources within ~hat zone. EPA does not feel
that sampling, in addition to this, is necessary to assure
the integrity of the Donna Road Alternative.
Additionally, as is outlined in Response 5 above, EPA has
added the additional provision of full TCL organics, TAL
inorganics and pesticides annually to the selected remedy.
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. .
ATTACHMENT A
COMMUNITY RELATIO~ ACTIVITIES
CONDUCTED AT THE
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.. - ..
COMMUNITY RELATIONS ACTIVITIES
CONDUCTED AT THE BAIRD & McGUIRE SUPERFUND SITE
Community relations activities conducted at the 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, Braintree 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.
October 5, 1983 - EPA issued a press release stating that
the Agency had filed suit against Baird & 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 Investigation (RI) Work Plan
which details studies to be conducted that would lead to the
selection of a long-term remedy for the Site.
May 1985 - EPA released a draft RI for the site.
June 1985 - EPA held a public meeting and accepted public
comments on the RI. EPA also announced that a Phase II RI
would be conducted.
July 1985 - EPA assisted in the organization of the Baird &
McGuire Task Force. This Task Force has continued to meet
regularly to review technical documents and £ite activities.
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- . . - ,
concerned citizens and government agencies. EPA
representatives have attended these meetings since the Task
Force was first established.
July 1985 - EPA issued a press release stating that low
levels of dioxin had been detected in Site soils. The
release further explained that EPA is working 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 (IRM)
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 regarding sampling locations and
incorporated local suggestions into the Agency's sampling
plan.
October 2, 1985 - EPA announced the results of pesticide,
herbicide and dioxin sampling from site soils.
June 30, 1986 - EPA issued a press release announcing the
completion of the Phase II RI. EPA.also provided
notification of an August public informational meeting 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 stating the
availability of the final Feasibility Study (FS) for the
Site.
July 1986 - EPA sent copies of a fact sheet summarizing the
RIjFS to concerned citizens and to the information
repositories for the site.
August 6, 1986 - EPA issued a press release stating that the
dates for the RIjFS public meeting and public hearing would
be changed. The release stated that the public
informational meeting 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 RIjFS, and to discuss proposed
cleanup plans for the site.
September 3, 1986 - EPA held an informal public hearing to
-------
,0
Groundwater Treatment Plant contract to Barletta Engineering
corporation of Roslindale, MA.
June 26, 1990 - EPA held a public informational meeting to
present the Alternate Water Supply FFS report and the
Proposed Plan. EPA announced that a public hearing would
take place on July 17 regarding the Proposed Plan, and a 30-
day public comment period on the Proposed Plan would begin
on June 27.
July 17, 1990 - EPA held an informal public hearing to
accept comments on the FFS and the Proposed Plan for the
-------
the RI/FS and the remedial alternatives that are being
evaluated for the Site.
September 30, 1986 - EPA signed a Record of Decision (ROD)
outlining 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 announcing that
signed a consent decree. A 30-day
follows the signing 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 funding for building demolition at
the Site; demolition activities are initiated.
July 1987 - EPA issued a revised community Relations Plan
for the Site.
1988 - Remedial design of the on-Site groundwater extraction
and treatment system proceeds; various design documents are
provided to the Task Force for review and comment. The
Focused Feasibility Study (FFS) for the Cochato River
Sediment Study Area continues; various technical memoranda
are made available.
June 1, 1989 - EPA issued a press release announcing that a
public meeting would be held June 13 to discuss cleanup
alternatives to address the Cochato River Sediment Study
Area.
June 1989 - EPA distributed a fact sheet summarizing the
results of the FFS for the Cochato River Sediment Study Area
and describing the Proposed Plan to address sediment
contamination to concerned citizens and local officials in
the Site area.
June 13, 1989 - EPA held a public informational meeting to
present the FFS report and Proposed Plan to address
contamination in the Cochato River Sediment Study Area. EPA
announced that a public bearing would take place on July 12
regarding the Proposed Plan, and a 30-day public comment
period on the Proposed Plan would begin on June 19.
July 12, 1989 - EPA held an informal public hearing to
accept comments on the FFS and the Proposed Plan for the
Sediment Study Area.
September 14, 1989 - EPA signs second ROD for Site which
outlines the remedy for the cleanup of the Cochato River
Sediments.
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ATTACHMENT B
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I
1 -
UNITED STATES OF AMERICA
ENVIRONMENTAL PR01ECTION AGENCY
2
BOSTON REGION
3
4
In the Matter of:
5
"6
INFORMAL PUBLIC HEARING
BAIRD & MCGUIRE SUPERFUND aITE
7
8
9
10
Aud i tc.r i IJm
Holb~ook S~./J~. High School
Holbrook, Massachusetts
11
12
Tuesda.y
J u 1 y 17, 1 <:1'30
13
14
came on for hearlng,
15
The above entitled matter
pursuant to Notice at 7:12 p.m.
16
BEFORE:
RICHARD CAVAGNERO
PAULA FITZSIMMONS
17
18
19
20 ,."
21
22
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APEX REPORTING
Reglstered Protesslonal Reporte~s
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PRO C E E DIN G S
7:12 P.M.
2
MR. CAVAGNERO:
Good evening.
My name is Richard
3
~
Cavagnero.
I'm Chief of the Massachusetts Superfund Section
of EPA and we're here tonight to have a public hearing on
5
'6
EPA's proposed plan for provision of ,alternate water supply
for the Baird And McGuire site, this being the fourth phase
7
of the remediation at Baird and McGuire.
8
~ith me on my left is Paula Fitzsimmons who's the
9
Remedial Project Manager for the site and we also have,
frc.m
10
the state DEP in the audience, Evelyn Tapeny who's Paula's
11
cc.unter par t.
12
The purpose of tonight's meeting, again, is to
13
take formal comment for the record to help us come
to:' our
14
ultimate decision on what to do to provide alternate water.
15
A meeting was held here on June 26th at which Paula
16
explained in some detail the feasibility study that was
17
conducted and also EPA's proposed plan.
I believe there is
18
a tl a nd '=".1 t
sLlmmari:ing
both the feasibility study flndings
19
20
and ;PA's recommended alternative.
Also included in that
21
han~out would be addresses for you to send any comments you
may have on either the proposed plan or any of the other
22
alternatives that were studied.
23
The public comment period runs from June 27tt.
24
through July 26th.
We have a repc.rter t.ere tc,nigt,t wtlC' I..Ii 11
25
APEX REPORTING
Registered Professlonal Reporters
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be transcribing any comments you want to make and we also
2
will be accepting any written comments which you can either
3
hand in tonight or send to Paula postmarked no later than
~
July 26th.
After we receive All these comments we will
5
obviously give them consideration And we will sign the
fourth re~ord of decision for the Baird and McGuire site.
.6
7
Once we do that, which hopefully will take place sometime in
September,
I believe, we will issue some kind of press
8
release informing you of that.
9
So, with that introduction let me just tell you
10
about the meeting format tonight.
Again, this is a hearing
11
as opposed to a question and answer session and we would
12
like to confine the hearing to statements for the record
13
either in support 01 the preferred alternative or some other
14
alternative.
Once we close the hearing we will be happy to
15
16
stay around if people have other questions they would like
to ask.
17
Paula was going to give a brief recap 01 the
18
19
proposed
clan which she described in some detail at the
20
public meeting on June 26th unless all the same people are
21
her~ tonight who were at that meeting ahd I guess they we
thought they were all
If you don't want to hear it
here.
22
23
again tonight we will forego that part of it but if someone
wants to again have a brief recap we can certainly do that.
24
Is there anyone who would like to hear that aga1n~
25
APEX REPORTING
Registered Professional Reporters
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.c
2
3
4
5
"6
t
,
4
(Pause.)
MR. CAVAGNERO:
Okay.
Fine.
Then, again,
I wi 11
turn this over to Paula who will give,
I guess, a little
brief histor~ of the site, how this phase fits into the
other three phases of Baird and McGuire, and a brief summary
of the proposed alternative and the other Altern~tives.
(
I 41so have, by the WAY, three cards from three
7
individuals who indicated -- four now, I
1 r, e .,. 10.' ~ I' t e d
guess.
8
to make statements and if there are other people I would ask
9
that you would fill out a card so we make sure we get
ye,ur
10
name right for the record.
11
And with that I'll turn it over to Paula.
12
We'd also ask that you, when you make a statement
13
later,
you come to this general vicinity so that we can pick
14
15
you up on the mike.
Tt'lank
Y ':0 U .
MS. FITZSIMMONS:
Okay.
Once again,
tt'lis is kind
16
of a
t 0:01.1 g t'l
sp,:ot.
If I stand here can everyone see me or if
17
I blocking everybody's view?
Yes?
No?
You're the only one
18
w t'1':' c a I" e s?
19
20
.>'
I'll go through this very quickly.
As we've said, this is the lost demand of
21
alternate water supply, fourth operable unit feasibility
22
What we're looking to
study for the Baird and McGuire site.
23
do is replace the lost demand that was lost when the South
24
Street wells were knocked out because of contaminat1on from
25
APEX REPORTING
Registered Professional Reporters
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13
( 14
15
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5
Baird and McGuire.
2
Most of you know this as well as I do, probably
better.
It's a 20 acre site and it's a former manufacturing
3
4
-- chemical ~anufacturing facility.
Contamination at the
'5
site is -- extends to ground water, soil and sediments.
We
'6
talked About operable units.
For people who don't know what
7
operable units are, that the term's kind of foreign, when
8
can split the site up into nice distinct pieces we sometimes
do that in order to make it easier to clean up or to do
9
parts sooner than others.
In this case we did do this.
The
10
first operable unit we called ground water and
ttl.:.se of yr.:.u
who have gone by the site have seen the groundwater
treatment plant under construction.
The second operable unit is the soils and both the
f1rst and second operable unit were dealt with as far as a
selecting a remedy ~~~f
~ :. ~ SS:.
The third operable unit has to do with the
sediments at the Cochato River which the record of decision
18
was signed last September.
And, as we said,
t t. i s is t tl e
19
fourth operable unit for the alternate water supply.
20
In 1982 the site was placed on the National
21
Priorities list which made it eligible for federal funding
22
which is what we are using to clean up this site since the
23
responsible parties are not viable, we're not able to get
24
ttlem to fund it.
The government is, under the Superfund
25
APEX REPORTING
Registered Professional Reporters
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12
'3
( '4
15
16
'7
18
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20
21
22
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,
6
Program,
is paying for the remedy.
In 1983 EPA took its first action at the site
2
which was a removal action when ttle creosote lagoon
3
overflowed and in 1985 we took A second removal action when
4
dioxin was found at the site and they also added some extra
5
fence and. did some more extensive soil sampling.
"6
;
In 1985 to 1987 we did what we called initial
7
remedial
The tank farms were demolished and
~easures.
B
removed.
There was a temporary path installed and a new
9
water main was put in.
As I said earlier, in 1986 there was
10
the first record 01 decision for the site which dealt with
operable units one and two, ground water and soils, and in
1989,
last summer at this time, we dealt with the third
operable unit having to do with the Cochato sediments.
In 1989 many 01 you were on site on May 11th when
we had a ground breaking ceremony for the ground water
treatment plant which is now under construction and also
1990 we are here to talk about the focus feasibility study
and the third record of decision for the fourth operable
unit. which is the alternate water supply.
As fast as I can do it; it ha~ a long history.
We put together what we call a remedial action
objective and that's what we're trying to accomplish at t~e
site in this operable unit, this phase, and what we're
24
try~ng to do is identify a candidate water sourc~ L:,~~
, .
25
APEX REPORTING
Registered Professional Reporters
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7
replace the .31 million gallons a day lost demand in an
2
environmentally sound,
cost effective manner without placing
additional stress on the Great Pond Reservoir system or the
3
4
existing water treatment facilities.
Alternatives.
We evaluated four different
5
'6
alternatives, reactivation of Donna Road which is EPA's
.'
7
preferred alternative; diversion of the Cochato River into
the Richardi Reservoir,
increas~ng the d~version of the Farm
8
River which is going on now, and EPA always looks at the no
9
action alternative and that's the baseline that we look at
10
to compare the other alternatives to.
11
As I said, EPA's preferred alternative is Donna
12
Road, is reactivation of the Donna Road aquifer.
It w,:'IJld
13
require installing new wells and pumps,
treating the wat~r
14
15
to drinking water standards,
really requires the removal of
both iron and manganese which are present in levels -- in
16
17
higher levels in the water and then delivering the water to
the Existing Holbrook water distribution system.
And, as it
'8
19
says here, the cost is Sl.lS-million.
20
,.,"
Real quick, many of you have seen these before, we
tlav~ tCI
look at nine criteria which in'our national
21
22
contingency plan -- these are the things we try to balance
when we select a remedy.
We look for something that's
23
overall protecting this -- human health and the environment
24
in tompliance with ARARs, one of our favorites
25
APEX REPORTING
Registered Professional Reporters
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-- Applicable and Relevant Appropriate Requ1rements.
It's
2
got to essentially comply with other environmental laws.
Long term effectiveness and permanence is pretty
3
4
self explanatory.
How long will it last and will it stay
arolJnd?
Not very operable.
:0; trli: olternative this
5
'6
operable unit, by reduction of mobility .nd toxicity in
volume.
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alternate water supply you look at how long it takes to
2
implement, how long will the alternative last as far as
3
performance.
Do we think it will give us what we need
it t,:,
..
give us.
That falls right into reliability.
And t~len t~le
5
safety of the actual supply itself.
. Okay.
Next step's what happens from here was, as
'6
"
Rich said, we are in the public comment period.
We will be
7
8
taking comments until the 26th, postmarked by the 26th and
mai led tCI me.
There's an address in the proposed plan.
9
After that we put together a responsiveness summary.
We do
10
not respond to individual comments as in writing back to
11
someone in telling them as in a personal response.
12
Sometimes we get two comments, sometimes we get 200
13
: .: ;7, .-: ~ ~ . '.. .:" ,
sometimes we get 500
It's jus t n ':' t
ccomments.
14
15
possible so we put 1t together in the document that's
attached, the record of decision,
it's c all e d t tl e
16
Responsiveness Summary,
and that will be availacle at EPA in
17
Boston and at the Holbrook Town Library.
And, as I said,
18
that folds into and that's part of the record of decision.
19
20
.>"
After the record 01 decision is signed we go on to
21
act~al designing the system and then finally implementation
01 the remedy.
22
Quick, and I'll leave this one up here.
Public
23
involvement, public comment.
We are, as I said, we are 1n
24
the Dublic comment period.
Here we are today for the
25
APEX REPORTING
Registered ~rofess10n~1
(617 -4'::t. -3()77 )
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t 14
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informal public comment period and I'll leave the address up
there in case you need to mail me comments if you don't ~ant
to read them into the record tonight.
That's it.
MR. CAVAGNERO:
Thank you, Paula.
For those of you who arrived after we began, Paula
Fitzsimmons, the Site and the Project Manager has just given
.
a brief summary of the proposed alternative and the other
alternatives that were looked at in the feasibility study
which was essentially a rehash of her public meeting here on
June 26th.
And ~ith that ~e ~ill no~ open the formal
comment period.
I have cards from those people wishing to
11
make statements.
If there are others who also wish to make
12
them we need to get you to fill out an index card so we can
get your name right for the record.
We will only take statements during the record not
questions and ans~ers.
Once the record is closed we ~111
again stay and take questions and ans~ers either on the
preferred alternative, other alternatives looked at.
Once
we get beyond that other 1ssues relative to the site or the
process for making a decision or getting your comments in.
So with that I will call on the first person here
wh~ ~~
~n~, ;.r~snal from the Baird and McGuire Task Force.
And if you ~ould, could you come at least to this area
so we
can make sure we pick you up on the mike.
Thank you.
MR. PRASNAL:
As a member 01 the Baird and McGUlre
APEX REPORTING
Registered Professional
l617-426-3077)
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1 1
Task Force I am in favor of the Donna Well -- or the Donna
2
Road aquifer project ~ith the stipulation that ~e do have
3
careful pre-engineering during this ph~se of construction.
MR.. CAVAGNERO:
Will you 5peak up a little,
.
s
please?
. MR. PRASNAL:
As a Task Force member of the
Sure.
°6
.
Baird and McGuire Committee my comments would be that I
7
~ould be in favor of the Donna Road project with the
8
following conditions.
That there be enough pre-testing
9
before the serious monies are spent to ensure that we do not
10
have a past history of contamination on this well field
11
12
project and that really is my major major source of concern
13
~ith the project since we cannot entertain questions and
ans~ers at this point.
Thank yc.u.
14
MR. CAVAGNERO:
Again, after
t 1". r c. u 91", wit 1",
we're
15
the statements Paula will be happy to answer any questions
16
we I",ave.
Or you have or others.
Thank YOI.I.
17
Next we have Mr. Mort Bro~n from the Conservation
18
C.jmmi ss icon.
19
20
.>~
MR. BROWN:
Okay.
Paula has mailed you a copy of
21
tI'",i~ letter.
These are the official comments of the
Conservation Commission.
22
This Commission wishes to be recorded as favor1ng
23
the EPA's proposal to develop the Donna Road aquifer to
24
25
replace the ~ater demand lost by the activities at Baird an~
APEX REPORTING
Registered Professional Reporters
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McGuire.
We are concerned, however,
by the fact t~,at a
known sc.ur ce of
contaminants located up
,-' of t t-, e
; 1- .:.'\:. .:.. :....: ~: '",
2
Donna Road site is Apparently not going to be considered
3
when evaluating the zone of influence.
And as you read,
4
s
Taylor's at Fourth and North Street in Hingham has been
.6
issued an. enforcement order by this Commission as a result
of hAving released contami~ants into the Qround water at tt-Ie
7
site located at 845 South Franklin Street in Holbrook.
At
e
this time they are deemed to be in non-compliance and have
9
not instituted any program to investigate the e~tent of this
10
sphere of influence which might be involved.
11
Since there are sufficient reasons to suspect that
12
the extended contamination could very well affect the
13
quality of the water to be recovered from the Donna Road
14
wells, we strongly urge that a thorough investigation be
15
made pr~or to final acceptance of the Donna Road site.
yc,ur
16
17
proposal to investigate only the zone of influence
immediately adjacent to the well site does not address the
18
possible future migration of contaminants and could
19
invalidate all the effort and expense invested if post-
20
21
con~truction testing revealed such off site effects.
Basically, that's the way we feel
abc, IJ tit.
T ~I ere
22
are other sites in the town in the same position.
T~lis
23
particular site has been well documented; the others have
24
n,='t .been as well d,~cumented.
We're cc,ncer ned
at),:.tJ t t ~Ic'se
25
APEX REPORTING
Registered Professional
(617 -4:::6 -3()TI.I
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and afterwards,
if you wish, I'll give you the addresses of
2
thc,se places.
3
We are really concerned because all these things
are n,:.t
very.far away from Donna Road.
close enolJgl"1
They're
4
5
that they could have an impact.
Se:, far
We dc.n't knc.w.
'6' we've had' no investigation by any organization or any state
7
office to tell us whether there will be an impact and I
e
would really urge that before we go and spend any great
9
amounts of money on this,
let's find out if we have more
10
problems than we presently know about.
And t 1", at's tI", e
Y' e as,:. :-,
:: I:~ i- "t i i ~ 5 .
11
MR. CAVAGNERO:
I ~ill now have Representative
12
13
Emmet Hayes, Chairman of the Baird and McGuiY'e Task Force.
MR. HAYES:
As Chairman of the Task
Ge:.c,d even~ng.
14
15
Force I'm here to testify in favor and in agreement with the
16
preferred alternative that EPA has outlined and also to
elaborate further with a couple of points that the Task
17
Force has discussed and we would like to include in our
18
comments.
19
We would like to be recorded in favor, as I've
20
21
ind~cated, of the preferred alternative, the Donna Road well
field.
We'd like to be strongly recorded in opposition to
22
the alternate number three, the potential diversion of the
23
C c' C ~, a t ':' R i vel" .
Due to the extent and level of contamination
24
in close proximity we think it's important to be on the
25
APEX REPORTING
Registered Professlonal
(£17 -4'::f.-307:'.I
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ol
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7
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t 14
1S
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23
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2S
.
14
record as being in strong opposition to that alternative, as
2
y':''-I revieIJ them.
Additionally, IJe would request that the record of
3
decision include provisions for the increased diversion of
4
the Farm River in the event that the Donna Road well field
does not produce the expected gallonage.
We feel that the
record of decision should provi~e for that as a remedy in
the event the Donna Road well field doesn't produce the
amount of water that we're looking for.
Additionally, because of the comments voiced by
the Conservation Commission and others, we believe it's
important that the EPA include a comprehensive program of
organic chemical testing for the Donna Road well field in
t t"1 ere c ':' r d ':' f
d e cis i ':' n .
And finally, that the record of decision include a
schedule for implementation, a very clear scheCule for
implementation with particular provisions being maCe on how
to short circuit the implementation of this alternative due
to the fact that Holbrook and the member communltlEs are
faci9g very serious water shortages right
now a nd ~:-.....; ."::.: - ,-
is needed desperately.
So we IJould ask that the EPA pay particular
attention to the implementation of this alternative and that
they outline in the record of decision the schedule and what
steps are going to be taken in order to shorten the brin9:~;
APEX REPORTING
Registe~Ed Professional Reporters
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this alternative on line.
And with that I conclude my remarks.
2
MR. CAVAGNERO:
Next we have Nancy Anne Noone from
3
the Board of .Selectmen.
4
MS. NOONE:
My name is Nancy Anne Noone.
I'm c. n
5
the Board- of Selectmen.
I'm .lso Chairman of Precinct 4
'6
which is where this proble~ is.
I would ask that you do as
7
you have done in the past, that you not have any trucks go
e
out or any of the, you know, moving in any of the materials
9
during the time that the children are going out to school.
10
That has been a problem in the past and I know when you were
11
12
doing the test sites you were aware of that and we did have
problems eyen though they said the trucks wouldn't
gc. C'I-lt
13
when the kids were
g':' i ng
t ':' s c ~,,::'I:;' I .
We did have trucks
14
15
c ':' m i n g CII.! tat
t~lat time.
SC1, we w,:.u I d ask t ~Ia t YCII.l mak e a
16
particular note of that and make sure that that
d,:.es n.:,t
17
happen at this time.
T ~I a n k
YC1U.
MR. CAVAGNERO:
Michael Hunt1ngton. Board of
18
Selectmen.
19
20
.>'
MR. HUNTINGTON:
I would just llke to add one
21
t ~I i r1 g .
I'd like to see in the record of decision, if
possible, would you include an estimate ot ~he future
c c. s t s
22
of running the Donna Road well field so the town later on
23
can determine whether it is cost effective for us to run
24
thi. plant in the future compared to the amount of water
25
APEX REPORTING
Registered Professional Reporters
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~upply that we're going to gain from it.
1
MR. CAVAGNERO:
And next we have
Joarine Koval trom
2
the Board of Selectmen.
3
MS. r~OVAL :
For the record my name is Joanne
4
s
Koval, Selectman.
There may not be many people here yet my
'6
phone has rung of1 the hook and it add~esses the statement
.
of Mr. Prasnal, is that there is a great concern to make
7
sure that the water has been tested and retested and since
8
there would not be any future problems that you would come
9
back and you would say, well,
we should have done this, or
10
101 e s h 0:' t_t 1 d
I"lave dcone tt"lat.
I'm not as up to date,
I'm n.:ot --
11
I've been briefed but I'm not uo to date.
I 101 a s the r e 101 1"1 e n
12
the original -- IoIhen Baird and McGuire site was d1scovered
13
and kn':.1.1 a bi t.
14
But I'm certainly not completely savvy or up to
15
date but I think that I need to speak for
peo:,p Ie tt"la t
t 1"":0 se
16
t,ave
called me at home.
Their concern is still that the
17
water is okay and I don't knolol how we now monitor that
18
except to follow the direction of the Task Force that has
19
20
dcone.,. a
good job and probably the people trust the Task Force
21
and :tt.at's wtlY tl",ey're ncot tlere tonigt"lt.
So, basically my statement is just that the safety
22
oft t. e 101 ate r ,
that it's drinkable,
that it's usable is st~:l
23
a concern for the people that have called me.
Tl"lank yo:oI..I.
24
MR. CAVAGNEHO:
Ttlank ycou.
25
APEX REPORTING
Registered Profess1onal Reporters
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And next we have David Holden from the Board of
Selectmen.
2
MR. HOLDEN:
David Holden, Board of Selectmen.
I
3
would
just like to express my support for the Task Force and
4
5
the work that they have done to support Mr. Brown and the
Conservation Commission _nd reiterate their comments and
.6
.
their concerns And state that I would support the project
7
with those concerns.
Thank you..
8
MR. CAVAGNERO:
Thank you.
9
I'm to the end of my index cards.
Is there anyone
10
else whc ~~ulc ~~k2 to make a statement?
Conrad?
11
MR. JANKOWSKI:
I'd like to.
Yes,
12
MR. CAVAGNERO:
Sure.
Conrad
Jankowsk1,
also from
13
the Baird and McGuire Task Force.
14
MR. JANKOWSKI:
Well,
I'll speak as a pr1vate
1S
citizen because they've already stated my posit10n as far as
16
the Task Force is concerned.
17
MR. CAVAGNERO:
Okay.
MR. JANKOWSKI:
I would like to reemphasize the
test~ng procedures because the Donna Road well fields are
goi~g to be an independent water source that is not
going to
go through the Randolph Pumping Station where there are all
~
kinds of tests and procedures in place already.
So I woulC
like to see somewhere in the record of decision a system of
checks and balances so you just don't have one man tak1ng ~
APEX REPORTING
Registered ProTessional
(617-4~~-~077)
Heporters
,
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sample of water and testing it down at the Donna Road well
fields.
I would like to see a comprehensive testing program
2
which would really be right for an independent water source.
3
MR. CAVAGNERO:
Thank you.
.
If no one else wishes to make a formal statement
5
I'd like ~o thank you all for coming ~ere tonight and for
'6
,
giving us this feedback .nd hope that you also, those of you
7
who chose not to speak tonight, send us in a letter giving
B
us either your comment or questions or preferences one way
9
Believe me, it's somettling ttlat we definitely
0:. r t tl e c. t t. e r .
10
take into consideration before we make a final remedy choice
11
and it's always easier to make a choice when we have more
12
comments than if we only have a handful, although I think
'3
14
you've been fairly well represented tonight by both your
elected officials and ttle Task Force.
15
And with that I will close the formal public
16
meeting tonight, reminding you that any comments will be
17
accepted, postmarked before July 26th, sent to Paula
18
Fitzsimmons at our EPA's office in Boston.
We a 1 so:. tlave,
19
ag~~9' the public repository of information including all
20
the ~tudies that would support this and copies of the
21
proposed plan at the Holbrook Town Library.
22
Is that it?
23
MS. FITZSIMMONS:
That's it.
24
with that we will
MR. CAVAGNERO:
And so, again,
4:5
APEX REPORTING
Registered Professional Reporters
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'6 .
7
e
9
10
11
12
13
( 14
15
16
17
18
19
20
21
22
23
24
25
(
19
close the public hearing tonight but we will be happy to
stay here for a while 011 the record to Answer any questions
you might have about this or other aspects of our activities
at Baird and .McG' .re, if there are any.
(Whereupon, at 7:40 P.M., the above hearing was completed.)
,
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APEX REPORTING
Registered Professional Reporters
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M. Farley
16 Reporter
17 E. Bartlett
Transcriber
18
19
20 <,..
.
21
22
23
24
25
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{
2
CERTIFICATE OF REPORTER AND TRANSCRIBER
2
This is to certify that the attached proceedings
3
before: U.S. ENVIRONMENTAL PROTECTION AGENCY
4
in the Matter of:
5
INFORMAL PUBLIC HEARING
BAIRD & MCGUIRE SUPERFUND SITE
~
.
7
8
Place:Holbrook, Massachusetts
9
Date: July 17, 19~0
10
11
were held as herein appears, and that this is the true,
12
accurate and complete tr~ns~lipt prepared 1rom the notes
13
of t~le above entitled proceeding.
and/or recordings taken
14
7-17-90
Date
7-23-90
Date
APEX REPORTING
Registered Professional Reporters
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J
CERTIFICATE OF REPORTER AND TRANSCRIBER
2
This is to certify that the Attached proceedings
3
before: U.S. ENVJRONMENTAL PROTECTION AGENCY
4
in the Matter O~~
5
INFORMAL PUBLIC ~EARING
BAIRD ~ MCGUIRE SUPERFUND SITE
..
-6
.
7
8
Place:Holbrook, Massachusetts
9
10
Date: July 17, 1990
11
were held as herein Appears, and that this is the true,
12
accurate and complete tranS~1 ipt prepared from the notes
13
and/or recordings taken
of the Above entitled proceeding.
14
15
M. Farley
16 Reporter'
17 E. Bartlett
Transcriber
18
19
20 -:\'
...
21
22
23
24
25
7-17-90
Date
7-23-90
Date
APEX REPORTING
Registered Prof~ssional Reporters
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"
APPENDIX B
ADMINISTRATIVE RECORD INDEX
-------
BAIRD' MCGUIRE, INC.
WATER SUPPLY STUDY
NPL SITE ADMINISTRATIVE RECORD
(.-
TABLE OF CONTENTS
VOLUME I
4.0
Feasibility Study (FS)
4.4
Interim Deliverab1es
VOLUME II
4.6
4.7
4.9
Feasibility Study (FS) Reports
Work Plans and Progress Reports
Proposed Plan for Selected Remedial Action
5.0
Record of Decision (ROD)
5.1
5.3
5.4
Correspondence
Responsiveness Summary
Record of Decision (ROD)
13.0 Community Relations
13.3 News Clippings/Press Releases
-------
'-'
INTRODUCTION
'"
This document is the Index to the Water Supply 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 the EPA staff in
selecting a response action at the site.
The Administrative Record is available for public review at EPA
Region I's office in Boston, Mass~chusetts, and at the Holbrook
Public Library, 2 Plymouth Street, Holbrook, Massachusetts, 02343.
This Administrative Record includes, by reference only, all
documents included' in the September 30, 1986 Administrative
Record (September 30, 1986 Record of Decision) for this NPL site.
Also included, by reference only, is the September 14, 1989
Sediment study Administrative Record (September 14, 1989 Record of
Decision). Questions concerning the Administrative Record should
be addressed to the EPA Region I site manager.
The Administrative Record is required by the Comprehensive
Environmental Response, Compensation, and Liability Act (CERCLA),
as amended by the Superfund Amendments and Reauthorization Act
-------
SECTION I
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v
4.0
ADMINISTRATIVE RECORD INDEX
for the
BAIRD' MCGUIRE, INC. NPL SITE
WATER SUPPLY STUDY
Feasibility study (FS)
4.4
4.6
4.7
Interim Deliverables
1.
"Field operations Plan, Baird & McGuire Water Supply
Feasibility Study," E.C. Jordan Company for Ebasco
Services, Incorporated (November 1988).
"Draft Final Phase I/Task 2 Alternate Water Supply
Evaluation, Baird & McGuire Water Supply Feasibility
Study, Holbrook, Massachusetts," E. C. Jordan Company
for Ebasco Services, Incorporated (November 1988).
"Final Technical Memorandum Evaluation of Surface
Water Sources, Baird & McGuire Water Supply
Feasibility study," E.C. Jordan Company for Ebasco
Services Incorporated (January 1990).
"Final Technical Memorandum Evaluation of
Groundwater Sources, Baird & McGuire - Water Supply
Feasibility Study," E.C. Jordan Company for Ebasco
services Incorporated (March 1990).
2.
3.
4.
Feasibility Study (FS) Reports
1.
"Draft Final Baird & McGuire Water Supply
Feasibility Study, Holbrook, Massachusettes," E.C.
Jordan Company for Ebasco Services, In=orporated
(May 1990).
Comments on the Feasibility Study received by EPA Region
I during the formal public comment period on the
Feasibility Study and proposed Plan are filed and cited
in 5.3 Responsiveness Summaries.
Work Plans and Progress Reports
1.
"Work Plan, Baird & McGuire Water Supply Feasibility
Study," E. C. Jordan Company for Ebasco Services,
Incorporated (February 1988).
-------
5.0
4.9
Proposed Plan for Selected Remedial Action
"EPA Proposes Replacement for Lost Water Demand at
the Baird & McGuire Site," EPA Region I (June 1990) .
Comments on th£ Peasibility study received by EPA Region
I during the formal public comment period. on the
peasibility study and Proposed Plan are filed and cited
in 5.3 Responsiveness Summaries.
1.
'-'
Record of Decision (ROD)
5.1
5.3
5.4
Correspondence
1.
Cross Reference: Letter from Medallion Snow,
Massachusetts Department of Environmental Protection
to Paula Fitzsimmons, EPA Region I (July 20, 1990).
Concerning the State's comments on the Proposed Plan
for the Donna Road Aquifer, Baird & McGuire
Superfund Site. [Filed and cited as entry number
2 in 5.3 Responsiveness Summaries].
Responsiveness Summaries
1.
Cross-Reference : Responsiveness Swmnary is Appendix
A of the Record of Decision. [Filed and cited as
entry number 1 in 5.4 Record of Decision (ROD) as
Appendix A].
The following citations indicate documents received by
EPA Region I during the formal public comment period.
Letter from Medallion Snow, Massachusetts Department
of Environmental Protection to Paula Fitzsimmons,
EPA Region I (July 20, 1990). Concerning the
State's comments on the Proposed Plan for the Donna
Road Aquifer, Baird & McGuire Superfund Site.
Record of Decision (ROD)
2.
1.
"Record of Decision Summary - Baird & McGuire/
Al ternate Water Study, Holbrook, Massachusetts, II
EPA Region I (September 27, 1990).
-------
(-
13.0 community Relations
v
13.3 News Clippings/Press Releases
2.
"EPA to Propose Alternate Water Supply for Town of
Holbrook at June Public Meeting," EPA
Environmental News (June 14, 1990).
"The United states Environmental Protection Agency
Invites Public Comment on the Proposed Plan and
Focused Feasibility Study for Replacing the Lost
Demand at the Baird & McGuire Superfund site in
Holbrook, Massachusetts," The Patriot Ledger
Quincy, Massachusetts (June 22, 1990).
1.
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-
SECTION II
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BAIRD' MCGUIRE, INC.
WATER SUPPLY STUDY
NPL SITE ADMINISTRATIVE RECORD
GUIDANCE DOCUMENTS
l)
EPA guidance documents may be reviewed at EPA Region I, Boston,
Massachusetts.
"
General EPA Guidance Documents
3.
4.
Executive Order 11990,"
1.
"Appendix D - Protection of Wetlands:
42 Federal Register 26961 (19?7).
U.S. Environmental Protection Agency. Office of Emergency
and Remedial Response. Communitv Relations in Superfund: A
Handbook (Interim Version) (EPA/HW-6), June 1988.
2.
"National oil and Hazardous Substances Pollution Contingency
Plan," Code of Federal Requlations (Title 40, Part 300), as
amended March 8, 1990.
U.S. Environmental Protection Agency. Office of Emergency
and Remedial Response. Superfund Remedial Desiqn and Remedial
Action Guidance (OSWER Directive 9355.0-4A), June 1986.
5.
U.S. Environmental Protection Agency. Office of Solid Waste
and Emergency Response. Mobile Treatment Technoloqies of
Superfund Wastes (EPA 540/2-86/003(f», September 1986.
6.
Comprehensive Environmental Response. Compensation.
Liability Act of 1980, amended October 17, 1986.
and
7.
u.S. Environmental Protection Agency. Office of Emergency
and Remedial Response. Superfund Public Health Evaluation
Manual (OSWER Directive 9285.4-1), October 1986.
8.
U.S. Environmental protection Agency. Office of Solid Waste
and Emergency Response. Interim Guidance on Superfund
Selection of Remedy (OSWER Directive 9355.0-19), December 24,
1986.
9.
U.S. Environmental Protection Agency. Office of Solid Waste
and Emergency Response. Data Oualitv Obiectives for Remedial
Response Activities: Development Process (EPA/540/G-87/003),
March 1987.
10.
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,
-------
General EPA Guidance Documents (cont'd)
11.
12.
13.
Region IX~ Director, Hazardous Waste Division, Region X~
Environmental Services Division Directors, Regions 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 Health and
Environmental Assessment. A Compendium of Technoloaies Used
in the Treatment of Hazardous Waste (EPA/625/8-87/014),
September 1987.
U.S. Environmental Protection Agency. Technoloav Screenina
Guide for Treatment of CERCLA Soils and Sludaes (EPA/540/2-
88/004), September 1988.
U.s. Environmental Protection Agency. Office of Emergency
and Remedial Response. Guidance for Conducting Remedial
Investigations and Feasibilitv Studies Under CERCLA (EPA/
540/G-89/004) (OSWER Directive 9355.3-01), October 1988.
Baird' McGuire (Water Supply Study) NPL site Specific Guidance
Documents
1.
2.
3 .
"Guidelines for Ground-Water Classification Under the EPA
Ground-Water Protection Strategy," USEPA, December 1986.
U. S. Environmental Protection Agency. "Guidance Document
for providina Alternate Water SUDDlies" (EPA 540/G-87/006),
(OSWER Directive 9355.03-03), February 1988.
"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.
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u
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APPENDIX C
STATE CONCURRENCE LETTER
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Julie Belaga
Regional Administrator
u.s. EPA
JFK Federal Building
Boston, Massachusetts
Daniel S. Greenbaum
Commissioner
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September 19, 1990
02203
RE: state Concurrence
with the Record of
Decision for the
Baird & McGuire
Federal Superfund
Site/Alternative
Water Supply
Operable Unit #4
Dear Ms. Belaga:
The Massachusetts Department of Environmental Protection has
reviewed the preferred remedial action alternative recommended by
the U.S. EPA for the Baird & McGuire Federal Superfund Site
(Site) Alternate Water Supply in Holbrook, Massachusetts and the
draft Record of Decision (ROD) that incorporates the State's
comments submitted on July 20, 1990. The Department concurs with
the decision to reactivate the Donna Road Aquifer as an alternate
water supply to replace the lost water demand due to industrial
activities at Baird & McGuire.
The remedy comprises the following components:
Permitting/pre-design studies
a. Massachusetts Water Management Act permit
b. Source Approval
2.) Groundwater extraction
3.) Treatment
a. Potassium permanganate
b. Greensand filtration
4.) Delivery to the Randolph-Holbrook water distribution
system
1.)
Since the Donna Road Aquifer is not part of the Site, but is
off-site, all federal, state and local applicable permits must be
obtained.
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Page 2
state concurrence
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This concurrence is conditional upon the Donna Road Aquifer
alternative remaining the basic foundation of the Lost Demand
remedy. Should that alternative water supply not provide the
full 0.31 mgd Lost Demand, we do not believe the entire operable
unit should be re-evaluated. Rather, only the incremental amount
which Donna Road may not be able to supply safely should be re-
examined. The State also would like to reiterate that the
diversion of the Cochato River is an unacceptable alternative to
meet the Lost Demand.
The Department has evaluated EPA's alternative for
consistency with the Massachusetts General Law Chapter (MGL) 21E
and the Massachusetts contingency Plan (HCP). However, since
this ROD does not address site related contaminants, but rather
selecting an alternate water supply to replace the South Street
Wells lost demand, the Department also evaluated this remedy for
consistency with the MGL Chapter 111.
The proposed remedy appears to meet all ARARs.
The Department is pleased that a decision has been made on
the final operable unit. If you have any questions, please
contact Evelyn Tapani, State Project Manager at 556-1125.
Very Truly Yours, .
~M~enbaum
Commissioner
cc:
James Colman, Assistant Commissioner
Dave Terry, Division Director of Water Supply
Gregory Vasil, Office of General Counsel.
Richard Chalpin, Regional Engineer NERO
Emmet Hayes, State Representative
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