United States Office of
Environmental Protection Emergency and
Agency Remedial Response
EPA/ROD/R01-91/057
June 1991
& EPA Superfund
Record of Decision
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50272 101
.
REPORT DOCUMENTATION 11. REPORT NO. ' I ~ 3. A8cIpIenI'8 ~ No.
PAGE EPA/ROD/ROl-91/057
... 11tI8 - ...... 5. Report D8t8
SuPERFUND RECORD OF DECISION 06/27/91
Iron Horse Park, MA I.
Second Remedial Action
7. AuIhor(8) I. I'WIonnkIg Org8nIzdon A8pL No.
I. I'WIonnkIg OrpInIzatIon ....... - ~ 10. Proj8ctITMlclWOItI UnIt No.
11. c-ct(C) 01' GNnI(O) No.
(C)
(0)
12. Span80rIng 0rg8IIIz8II0n ....... - AdmH8 13. TrJ18 of Report. P8IIod CoWt'8d
U.S. Environmental Protection Agency 800/000
401 M Street, S.W.
Washington, D.C. 20460 14.
15. ""rr'UlI8III8ry No-
11. Ab8nct (limit: 200 _nle)
The 552-acre Iron Horse Park site is an active industrial complex and railyard with a
long history of activities that have resulted in contamination of soil, ground water,
and surface water in North Billerica, Massachusetts. The site includes open storage
areas, landfills, and lagoons. This Record of Decision (ROD) addresses the onsite
60-acre landfill, known as the Shaffer Landfill, that was used for disposal of
residential and commercial solid waste from 1946 until its closure in 1986. The
Shaffer Landfill is surrounded by wetlands and lies within the 100-year floodplain of
Middlesex Canal and Content Brook, which border the site to the east and south,
respectively. Land use outside the surrounding wetlands areas is predominantly
industrial and residential. As a result of State investigations in 1980, EPA
identified onsite contamination in ground water, surface wa,ter, and soil; and the
presence of asbestos. In 1984, EPA, under its removal authority, covered an onsite
asbestos-contaminated landfill. After further investigation, EPA divided the site
into operable units (OU s) to facilitate remediation. A 1988 ROD addressed the B&M
Lagoon site as OU1, which includes the contaminated waste lagoons located on another
portion of this site. This ROD addresses OU2, final remediation of the Shaffer
(See Attached Page)
17. Doc:unen1 An8Jy8I8 .. D88crtpIora
Record of Decision - Iron Horse Park, MA
Second Remedial Action
Contaminated Media: soil, gw, air
Key Contaminants: VOCs (benzene, TCE, toluene, xylenes), other organics (PARs),
metals (arsenic, lead)
b. IdentI88r8/Op8nEndlld T8f1118
Co COlA 11 Fl8kUGroup
18. AVllil8blfty SIIII8mInt 18. Sea8i1y CI- (ThI8 Allport) 21. No. of Pall"
None 266
20. S8c:u1ty a- (ThI8 Page) ~ Pric:8
, Nnn",
See ANSl-Z38.18 See",. on Ie- 272 (4-77)
1IUcIi-
(FCII'III8IIy NTlS035)
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EPA/ROD/ROl-91/057
Iron Horse Park, MA
Second Remedial Action
Abstract (Continued)
Landfill, including leachate and ground water. A future ROD will address surface water
contamination as part of OU3. The primary contaminants of concern affecting the
landfill materials, ground water, and air are VOCs including benzene, TCE, toluene, and
xylenesi other organics including PAHSi and metals including arsenic and lead.
The selected remedial action for this site includes reconstructing the GO-acre existing
landfill capi maintaining the cap, the existing surface drainage system, and the
existing landfill gas collection/flare system; constructing, operating, and maintaining
a leachate collection system; treating and disposing of leachate offsite; monitoring
ground water, surface water, and the gas cOllection/flare system; and implementing
institutional controls, including deed and ground water use restrictions. The
estimated present worth cost for this remedial action is $12,553,524, which includes a
present worth O&M cost of $3,541,426 for 30 years.
PERFORMANCE STANDARDS OR GOALS: Interim chemical-specific ground water clean-up goals
are based on SDWA MCLs, and include arsenic 50 ug/l (MCL), benzene 5 ug/l (MCL), and
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,
RECORD OF DECISION SUMMARY
SHAFFER LANDFILL,
IRON HORSE PARK SITE
BILLERICA, MASSACHUSETTS
JUNE 27, 1991
U.S. ENVIRONMENTAL'PROTECT!ON AGENCY
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION I
KENNEDY FEDERAL BUILDING, BOSTON, MASSACHUSETTS 02203
J.F.
DECLARATION FOR THE RECORD OF DECISION
SHAFFER LANDFILL, IRON HORSE PARK
BILLERICA, MASSACHUSET~S
STATEMENT OF PURPOSE
This decision document represents the selected remedial action
for the Shaffer Landfill, Iron Horse Park site in Billerica,
Massachusetts, 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, and to the extent practicable, the
National Oil and Hazardous Substances Contingency Plan (NCP) , 40
CFR Part 300 et sea., as amended. The Regional Administrator has
been delegated the authority to approve thi~ Record of Decision.
The Commonwealth of Massachusetts has concurred on the selected
remedy.
STATEMENT OF BASIS
This decision is based on the Administrative Record which has
been developed in accordance with section 113 (k) of CERCLA and
which is available for public review at the Billerica Public
Library in Billerica, Massachusetts and at the Region I Waste
Management Division Records Center in Boston, Massachusetts. The
Administrative Record Index (Appendix F to the ROD) identifies
each of the items comprising the Administrative Record upon which
the selection of the remedial action is based.
ASSESSMENT OF THE SITE
Actual or threatened releases of hazardous substances from this
site, if not addressed by implementing the response action
selected in this ROD, may present an imminent and substantial
endangerment to the public health or welfare or to the
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o
,-~
'DESCRIPTION OF THE SELECTED REMEDY
This ROD sets forth the selected remedy for the second operable
unit at the Iron Horse Park Site, which addresses the Shaffer
Landfill, which is just one part of the overall site.
The selected remedial action for the Shaffer Landfill Operable
unit described in this ROD consists of source control measures
which will also control the continuing migration of co~taminants
from the landfill.
The major components of the selected remedy include:
o
Reconstruction of the cap over the entire 60 acres of
landfill surface;
o
Maintenance of cap, surface drainage system and
landfill gas collection/flare system;
o
Monitoring of gas collection/flare system;
o
Monitoring of groundwater and surface water quality;
o
Construction, operating and maintenance of the leachate
collection facilities;
o
Offsite treatment and disposal of leachate;
o
Construction of site perimeter security fence;
o
Institutional controls; and
o
Post Closure Plan.
DECLARATION
The selected remedy is protective of human health and the
environment, attains Federal and State requirements that are
applicable or relevant and appropriate for this remedial ~~ti0~
and is cost-effective. This remedy satisfies the statutory
preference for remedies that utilize treatment as a principal
element to reduce the toxicity, mobility, or volume of hazardous
substances. In addition, this remedy utilizes permanent
solutions and alternative treatment technologies to the maximum
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As this remedy will result in hazardous substances remaining
on-site above health-based levels, a review will be conducted
within five years after commencement of remedial action to ensure
that the remedy continues to provide adequate protection of human
health and the environment.
,y
-~ ~w~, Aflinv
Julie Belaga 0
Regional Administrator
u.s. EPA, Region I
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()
/~
REG:J:OB :J:
RECORD 01' DBC:J:S:J:OB
SBU'I'BR LUlDI':J:LL OPBRABLE mn:~
:J:ROB BORSB POX, B:J:LLBUCA, DSSACBUSBftS
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contents
I.
II.
III.
IV.
V.
VI.
VII.
VIII.
IX.
x.
XI.
XII. .
XIII.
APPENDIX
SBAPFER LANDFILL OPERABLE UNIT
IRON HORSE PAlUt
TABLE OF CONTENTS
SITE NAME, LOCATION AND DESCRIPTION. . . . . .
. . .
SITE HISTORY' ENFORCEMENT ACTIVITIES
. . .
. . . . .
A.
B.
Land Use' Response History .
Enforcement History. . . . .
. . .
. . . . . . .
. . .
. . . . . . .
COMMUNITY PARTICIPATION.
. . . .
. . . .
. . . . . .
SCOPE' ROLE OF OPERABLE UNIT OR RESPONSE ACTION
. .
SUMMARY OF SITE CHARACTERISTICS.
. . .
. . . . . . .
SUMMARY OF SITE RISKS. .
. . . .
. . . . . . . . . .
DEVELOPMENT AND SCREENING OF ALTERNATIVES.
. . . . .
A.
B.
statutory Requirements/Response objectives
Technoloqy and Alternative Development
and screening. . . . . . . . . . . . . .
. . . .
. . .
DESCRIPTION OF ALTERNATIVES. . . . .
. . .
. . . . .
SUMMARY OF THE COMPARATIVE ANALYSIS OF ALTERNATIVES.
THE SELECTED REMEDY. . . . . . . .
. . . . . . . . .
A. Cleanup Levels. . . . . . . . . . . .
B. Description of the Remedial Components
. . . . .
. . . . .
STATUTORY DETERMINATIONS
. . .
. . .
. . .
. . . . .
A.
The Selected Remedy is Protective of Human
Health and the Environment. . . . . . . . . . .
The selected Remedy Attains ARARs . . . . . . . .
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 Selected Remedy Satisfies the Preference
for Treatment as a principal Element. . . . . .
B.
C.
D.
E.
DOCUMENTATION OF SIGNIFICANT CHANGES
. . .
. . . . .
STATB ROLE
. . . . . . . . . . . . .
. . . . . .
',/
\,'
paoe Number
3
4
4
6
7
8
8
11
16 ,
16
18
18
25
33
33
36
39
40
41
44
45
46
46
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o
v
IRON HORSB PARK, SHAFFBR LANDFILL SUMMARY
J1mB, 1'91
I.
SITB NAKE, LOCATION AND DBSCRXPTIOB
This Record of Decision (ROD) is for the cleanup of the Shaffer
Landfill (the Landfill) at the Iron Horse Park Superfund site (the
site) in North Billerica, Massachusetts. The Shaffer Landfill is
located on 106 acres of land east of Pond Street and south of
Richardson Pond within the boundaries of Iron HQrse Park. The
Landfill itself covers approximately 60 acres ana was used for
disposal of residential and commercial solid waste for a period of
more than 30 years. .
The Shaffer Landfill is divided into two physically distinct sections.
The western section includes approximately 24 acres of landfill and is
referred to as the "Residential Section". The eastern section
includes approximately 36 acres of ~andfill and is referred to as the
"commercial section". A more complete description of the Shaffer
Landfill can be found in the Phase lA Remedial Investigation Report
for Iron Horse Park (July, 1987), and the Phase 1C Remedial
Investigation Report for the Shaffer Landfill, Iron Horse Park
(November, 1989).
The Shaffer Landfill comprises just one part of the Iron Horse Park
Superfund site. The entire site consists of approximately 552 acres
of land in North Billerica, near the Tewksbury town line. The Site is
an active industrial complex and railyard with a long history of
activities that have resulted in contamination of soils, groundwater,
and surface water. The site includes open storage areas, landfills,
and lagoons. A more complete description of the Site can be found in
the Phase 1A Remedial Investigation Report (See ~aps in Appendix A of
this Record of Decision).
LOCATION AND ADDRESS OF THB S:rD
The Shaffer Landfill is accessed through a gate on Pond Street located
approximately 1 mile north of the intersection of Route 129 and Pond
Street.
.
GEOGRAPHICAL AND TOPOGRAPHICAL OVERVIEW OF THE SITE AREA
The Shaffer Landfill is situated in what was primarily a wetland area
and is, at present, surrounded by wetlands and surface water bodies.
Richardson Pond is located to the north of the Shaffer Landfill,
across the Boston and Maine railroad tracks. Content Brook drains
Richardson Pond at its southeast corner. Content Brook runs generally
north to south, east of the commercial section of the Landfill, and
merges with the Middlesex Canal in the southern portion of the Site.
The Middlesex Canal forms the southern boundary of the Site. The
eastern and southern portions of the Landfill are located within the
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Shaffer Landfill is industrial to the west across Pond Street and
primarily residential past the bordering wetlands to the north, east,
and south.
-/
,.
Groundwater in the area around the Landfill is not currently being
used for drinking water. Some fishing is known to occur in both
Content Brook and Richardson Pond. In addition, there is evidence
(tire tracks, shot-qun shells) that the Shaffer Landfill and
surrounding areas are used for recreational purposes.
The summit of both the Commercial and Residential sections are at
approximately 180 ft. above sea level. The base of the Landfill lies
at 110-120 ft. above sea level. The area immediately surrounding the
Landfill is relatively flat with a low profile. The twin flat-topped
mounds of the Landfill are the highest elevation features in the area.
.
GEOLOGIC-HYDROGEOLOGIC CHARACTERISTICS
Underlying the Landfill is bedrock composed of schist and granite with
a varied profile. This bedrock runs unevenly beneath the Landfill at
a depth of roughly 5 to 60 feet below the surface. The overburden is
mainly glacial outwash, consisting primarily of medium-grained sand
with occasional fine gravel lenses. The overburden deposits range up
to about 60 feet in thickness and in general become thinner from
northwest to southeast. The uppermost portion of the overburden
deposit is organic topsoil with a thickness of-1 to 3 feet.
Groundwater in and around the Landfill flows generally from west to
east, with some local sub-trends within the Landfill area itself. In
the western portion of the Landfill (the western portion of the
Residential Section to Pond Street), groundwater flows northeast
toward Richardson Pond. In the central portion of the Landfill,
groundwater flows northeast and southeast at a very low gradient.
In the eastern portion of the Landfill, groundwater flows southeast
toward Content Brook. Richardson Pond and Content Brook are
hydrologically connected to groundwater, and receive discharge from
near-surface groundwater. The Middlesex Canal does not appear to be
hydrologically connected with groundwater with the exception of a
possible area of interaction near the confluence of the Middlesex
Canal and Content Brook.
II.
SITE HISTORY AND ENFORCEMENT ACTIVITIES
A.
Respons. History and Land Us.
Response History
i.
The site was placed on the National Priorities List in september 1984
following investigations by the Massachusetts Department of
Environmental Quality Engineering (now the Massachusetts Department of
Environmental Protection or MADEP) in the early 1980's and a Site
Investigation Report completed by the NUS Corporation for EPA in
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o
,
u
August 1984.
In August 1984, EPA, under its removal authority, covered a portion of
the site known as the John-Manville Asbestos Landfill with gravel and
topsoil to prevent asbestos in the landfill from becoming airborne.
In 1985, EPA began investigations of the Site to determine the nature
and extent of contamination. Under the first phase of the evaluation,
EPA conducted a broad study of the site to define the potential
problem areas. This study was entitled the Phase 1A Remedial
Investigation (RI). As a result of the Phase 1A RI, EPA concluded
that the size and complexity of the Iron Horse Park site necessitated
using a phased approach to study it and to determine what cleanup work
may be needed. Under this approach, the site was separated into a
number of different problem areas. Where possible, the areas studied
and the decisions on how to clean them up are made as operable units.
An operable unit is a discrete portion of an entire response action
that, by itself, manages migration or eliminates or mitigates a
release, threat of release, or pathway of exposure.
The B & M Lagoons were the first operable unit addressed at the Site.
In August 1987, EPA began work on a second remedial investigation that
focused on the nature and extent of contamination in and around the B
& M Lagoons. EPA completed this study, referred as the Phase 1B RI,
in May 1988. In addition to the Phase 1B RI, the Feasibility Study
(FS) of potential remedial alternatives for the cleanup of the B & M
Lagoons was issued in June 1988. A Record of Decision for this first
operable unit was issued in September 1988. Work is currently
underway on this portion of the site.
The Shaffer Landfill is the second operable unit at the site. In
1989, EPA completed a study of the nature and. extent of contamination
at the second operable unit of the Site in a report referred to as the
Phase 1C RI. In January 1991, EPA completed a Feasibility Study that
describes the potential remedial alternatives for the Shaffer
Landfill. The Shaffer Landfill is the subject of this Record of
Decision.
The Landfill is currently being closed pursuant to a judicial
settlement (Final Judgment) entered into on June 12, 1984 between the
Commonwealth of Massachusetts and the owners of the Landfill. The
closure activities which have taken place thus far include
construction of a two layer cover system or cap consisting of a low
permeability layer and a topsoil vegetative layer, and a gas
collection/flare system. There are problems with the cap, the gas
collection/flare system, and the operation and maintenance of the
facility. In addition, no leachate collection system has been
installed. For a more complete description of closure work which has
taken place to date see Section 2.5 of the Phase 1C Feasibility Study.
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ii.
LaD4 Va.
~/.
The Shaffer Landfill is located on property originally owned by the
Boston & Maine Corporation. Records from the MADEP and the Town of
Billerica indicate that the property was used for rubbish disposal
beginning in 1946 and was operated as an open burning dump for over 20
years. Records indicate that throughout most of its history the
Landfill accepted a wide variety of commercial and residential refuse.
In 1966, the Boston & Maine corporation sold the Landfill to the
Shaffer Realty Corporation. Title to the property was then
transferred to the Graypond Realty Trust. Graypond Realty Trust is
the current owner of the Landfill.
Aerial photographs show that until at least the early 1960's, the area
used for landfilling was restricted to the westernmost portion of what
is now known as the Residential Section. By 1969, the Residential
Section had reached roughly its current areal extent, while to the
east, the Commercial Section did not exist (the site of the Commercial
Section was still primarily wetland). The Commercial section began to
appear in aerial photographs in 1970, and appears to be near full
areal development in a 1976 photograph. As part of the 1984
settlement with the Commonwealth of Massachusetts, the Landfill ceased
operation in 1986.
B.
EDforcemeDt History
To dQ~e, EPA has notified approximately nine parties of their
potential liability for response actions taken and to be taken at the
site.
Prior settlements have been negotiated with some of these potentially
responsible parties (PRPs) for the Johns Manville asbestos removal
action and the B & M Lagoons first operable unit. Negotiations with
the PRPs for implementation of the Shaffer Landfill operable unit
remedial action will not commence until after the remedy selection
process is complete.
The PRPs have been active in the remedy selection process for the
Landfill. Technical and general comments presented by the PRPs in
writing during the public comment period were summarized by EPA, and
the summary, as well as responses to those summarized comments are
included in the Responsiveness Summary which is in Appendix E of this
Record of Decision.
In addition to the federal enforcement efforts, Massachusetts has been
actively involved at the Landfill in enforcement of state
environmental requirements. After issuing a series of violation
notices and administrative orders citing noncompliance with numerous
Massachusetts regulatory requirements, Massachusetts filed suit in an
attempt to obtain compliance at the Shaffer Landfill. A settlement
was reached by the parties in 1984. This settlement required the
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a
Landfill to close and prescribed the terms of closure. Work is
proceeding under this settlement and is discussed in section II.A.i,
above.
III. COMMUNITY PARTICIPATION
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 informational meetings, fact
sheets, press releases and public meetings.
During August 1985, EPA released a community relations plan which
outlined a program to address community concerns and keep citizens
informed about and involved in activities during remedial activities.
since 1985, several informational and public meetings have been held
with the community to discuss the original site-wide investigation,
the asbestos removal and the B & M Lagoons cleanup.
On August 17, 1989, EPA held an informational meeting in Billerica, MA
to discuss the results of the Phase 1C Remedial Investigation for the
Shaffer Landfill.
On January 16, 1991, EPA made the administrative record for the
Shaffer Landfill available for pUblic review at EPA'S offices in
Boston and at the Billerica Public Library. EPA published a notice
and brief anal\F;is of the Proposed Plan in the Lowell Sun on January
10, 1991 and made the plan available to the public at the Billerica
Public Library. In addition, EPA has sent several hundred parties
potentially interested parties letters, that provide parties that may
have some association with the Landfill an opportunity to participate
in the remedy selection process.
On January 15, 1991, EPA held an informational meeting to discuss the
results of the Remedial Investigation and the cleanup alternatives for
the Landfill presented in the Feasibility Study and to present the
Agency's Proposed Plan. Also during this meeting, the Agency answered
questions from the public. From January 16, 1991 to March 16, 1991,
the Agency held a 60 day public comment period to accept public
comment on the alternatives presented in the Feasibility Study and the
Proposed Plan and on any other documents previously released to the
public. On February 5 and 19, 1991, the Agency held public meetings
to discuss the Proposed Plan and to accept any oral comments.
On May 16, 1991, EPA issued the supplement to the Proposed Plan which
described a new preferred alternative for the cleanup of the Landfill.
From May 17, 1991 to June 17, 1991, EPA held an additional 30-day
public comment period to accept public comment on the supplement to
the Proposed Plan and on any other documents previously released
to the public. A transcript of the February 5, 1991 and February 19,
1991 meetings, a summary of comments submitted during the comment
period, and the Agency's response to these summarized comments are
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c)
included in the attached responsiveness summary.
i/
IV.
SCOPE AND ROLE OP OPERABLE UNIT OR RESPONSE ACTION
The Selected Remedy for the Shaffer Landfill is the second operable
unit of at least a three operable unit approach to the remediation of
the Iron Horse Park Superfund site. Because of the complexity of the
site and the discrete nature of the problem at the Shaffer Landfill,
cleanup as an operable unit is appropriate and consistent with the
entire response at the Site. The Selected Remedy is, similar to the
asbestos removal and the B & M Lagoon remedial action, an incremental
step toward comprehensively addressing the problems at the site. The
third operable unit will address the other areas of concern at Iron
Horse Park that were identified during the Phase 1A RI.
The Selected Remedy was developed by combining components of different
source control and management of migration alternatives to obtain a
comprehensive approach for remediation of this operable unit. In
summary, the remedy provides for: reconstruction of the Landfill cap:
collection, treatment and disposal of leachate: an air quality study:
monitoring the gas collection/flare system and making improvements if
necessary: and monitoring surface water and groundwater quality.
This remedial action will address the following principal threats to
human health and the er " ':'ronment posed by the Landfill:
1) Leachate migration contaminating aquifer (not a current drinking
water source) and surface waters:
2)
3)
Degradation and loss of surrounding wetlands: and
Air emission quality.
v.
SUMMARY OP SITE CHARACTERISTICS
Chapter 2.0 of the "Final Draft Phase 1C Feasibility Study for the
Shaffer Landfill" contains an overview of the Phase 1C RI. The study
area included the Shaffer Landfill property as described earlier, as
well as the groundwater, surface water, sediments, and wetlands in the
area surrounding the property. The significant findings of the Phase
1C RI are summarized below:
A.
Groundwater
Groundwater flows in three directions in and around the Shaffer
Landfill area. West and southwest of the Landfill, groundwater flows
north toward Richardson Pond. In the central portion of the Landfill,
groundwater flow is both north toward Richardson Pond, and south
toward the Middlesex Canal. In the eastern portion of the Landfill,
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(j
~\...
groundwater flows to the east and southeast. As part of the process
of reaching these conclusions on flow, EPA installed 12 new monitoring
wells and used 37 existing monitoring wells in its study of
groundwater at the Shaffer Landfill (See map in Appendix A of this
Record of Decision).
Biochemical oxygen demand (BOD), chemical oxygen demand (COD), total
dissolved solids (TDS) , iron, manganese, and conductivity levels in
groundwater are indicators that, when elevated, are typically
associated with landfill leachate. The highest levels of these
indicators and the highest levels of priority pollutant volatiles and
metals, some at levels above Maximum Contaminant Levels (MCLs) have
been found in groundwater directly adjacent to the eastern, northern
and southern toes of the Landfill. In addition, elevated levels have
been detected east of the Landfill toe in the direction of Content
Brook. Based on the elevated levels of BOD, COD, TDS, iron, manganese
and conductivity, leachate is flowing from the Landfill to the east
and southeast. This is consistent with the direction of groundwater
flows, and with the observation of leachate breakouts at the Shaffer
Landfill. Beyond Content Brook to the east, samples from wells GZA-
9A, 9B, lOA, and lOB did not show evidence of leachate constituents at
levels above those observed upgradient of the Landfill. Somewhat
elevated levels of TDS have been found at well GZA-9B indicating that
migration of landfill contaminants may have occurred beneath and
beyond Content Brook in the lower portion of the aquifer.
The most significant contaminat' . observed in the groundwater has
been found along the eastern to~ of the Landfill. Elevated levels of
chloride, manganese, iron, arsenic and VOCs have consistently been
detected in wells GZA-3 and KE both screened into the lower portion of
the overburden aquifer. Concentrations of arsenic and VOCs found in
well GZA-3, which are considered representative of the worst
contamination, are as follows:
CONTAMINANT
CONCENTRATION
Arsenic
Benzene
1,2-Dichloroethane
1,2-Dichloroethene
Ethylbenzene
Methylene Chloride
Toluene
1,1,2-Trichloroethane
Trichloroethene
Vinyl Chloride
xylene
258 ppb
91 ppb
55 ppb
120 ppb
350 ppb
500 ppb
840 ppb
16 ppb
6.1ppb
130 ppb
1500 ppb
Shallow wells KW, GZA-4 and M, located near KE and GZA-3, have shown
lower levels of contaminants, possibly indicating that dilution of
shallow groundwater is occurring from local recharge. The only
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significant levels of acid/base/neutral (ABN) compounds were found in
well MW-7 downgradient from the Landfill along Gray street. However,
analysis of samples from other downgradient wells closer to the
Landfill did not detect ABN compounds.
Inorganic contaminants other than arsenic (lead, chromium) have been
detec~ed at elevated levels in groundwater upgradient of Shaffer
Landfill. These locations are west and south of the Landfill.
Chromium was detected in downgradient well MW-6A, but at a level well
below the MCL and below the levels detected upgradient of the
Landfill. Lead was not detected in any downgradient wells.
B.
surface Water
Surface water samples were collected from 19 locations in the area
surrounding the Shaffer Landfill to determine the nature and extent of
contamination present within this media. Samples collected from the
southern edge of Richardson Pond (SW-22), and from Content Brook
(SW-30, SW-102, and SW-117) contained low levels of volatile organics,
with the highest levels being detected at SW-22. No significant
levels of ABN compounds were found in surface water samples.
Inorganic contaminants were detected above MCLs both upgradient and
downgradient of the Shaffer Landfill. Inorganics detected above
Ambient Water Quality criteria (AWQCs) at downgradient sampling
location SW-117 (Content Brook) include: . :"'.
CONTAMINANT CONCENTRATION AWOC(s) EXCEEDED
barium 3690 ug/l Water & Fish Ingestion
mercury 2.2 ug/l All except Fresh Water Acute
(Protection of Aquatic Life)
lead 1260 ug/l All
nickel 564 ug/l All except Fresh Water Acute
arsenic 54 ug/l Fresh Water Chronic
chromium 811 ug/l All
Although the geographic distribution of these inorganic contaminants
did not seem to follow any particular pattern, SW-117, immediately
downgradient of the Landfill, exhibited a higher number and generally
higher levels of inorganics above MCLs than any upgradient location.
In addition, SW-117 was the only location where the AWQCs for nickel
were exceeded. The remedy for this operable unit addresses the
landfill, leachate and groundwater only. Surface waters will be
looked at in the next operable unit to determine if Superfund is the
most appropriate mechanism to deal with this medium.
C.
Sediment
Sediment samples were collected at 33 locations in the Shaffer
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D.
Landfill area. Low levels of VOCs were detected in sediments found on
the southern edge of Richardson Pond. Comparing the VOCs detected in
these sediments with those detected in surface water at the same
location, shows that only acetone and toluene were detected in both
media.
ABN compounds were widely detected in sediments both upgradient and
down gradient of the Shaffer Landfill. The highest concentrations of
ABNs by far, were found upstream of the Landfill, on the far western
edge of Richardson Pond (SD-lll) and west of Pond Street south of the
Middlesex Canal (SD-115).
In general, ABNs and a variety of metals such as arsenic, lead and
zinc were found in the sediments along the Middlesex Canal, Content
Brook and Richardson Pond both upgradient and downgradient of the
Shaffer Landfill.
A complete discussion of site characteristics can be found in the
Phase lC Remedial Investigation Report in sections 2, 3, and 4.
Air
As part of the Landfill's gas collection system, the owners have
installed a gas vent/flare system for air pollution control. MADEP
required that a permit be issued for operation of the gas vent/flare.
As a part of the process of obtaining a permit to ;~rate the
flare/vent system, testing of emissions was condu~~cd. The results of
these tests were used to perform computer modeling to estimate
potential off-site exposures to emissions. This modeling effort,
completed in November, 1988 predicted emission concentrations off the
Landfill property orders of magnitude below a~lowable levels.
In 1990, following complaints of odors by local residents, MADEP
conducted some additional sampling at the Landfill to identify the
specific source of odors (fissures in the existing cap or gas
collection wells), and to do some identification and quantification of
specific airborne contaminants. This testing found a number of
contaminants at elevated levels. These samples were taken in the gas
extraction well heads and at collection system vents at the surface of
the Landfill. Although not found at all sample locations, these
contaminants include: benzene, toluene, xylenes, 1,1,1-
trichloroethane, and trichloroethylene. MADEP had determined that
there was a risk associated with continuous exposure to these levels
to people on-site but that there was no indication that anyone off-
site was being exposed to elevated levels of these contaminants. No
further work to determine off-site exposure scenarios has taken place.
VI.
SUMMARY OF SITE RISKS
An Endangerment Assessment (EA) was performed to estimate the
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probability and magnitude of potential adverse human health and
environmental effects from exposure to contaminants associated with
the Landfill. The EA is found in Chapter 6 of the Phase 1C Remedial
Investigation Report (RI). The public health risk assessment followed
a four step process: 1) contaminant identification, which identified
those hazardous substances which, given the specifics of the Landfill,
were of significant concern; 2) exposure assessment, which identified
actual or potential exposure pathways, characterized the potentially
exposed populations, and determined the extent of possible exposure;
3) toxicity assessment, which considered the types and magnitude of
adverse health effects associated with exposure to hazardous
substances; and 4) risk characterization, which integrated the three
earlier steps to summarize the potential and actual risks posed by
hazardous substances at the Landfill, including carcinogenic and non-
carcinogenic risks. The results of the public health risk assessment
for the Shaffer Landfill are discussed below followed by the
conclusions of the environmental risk assessment.
.~
Twenty-six contaminants of concern, listed in Appendix B of this
Record of Decision were selected for evaluation in the Endangerment
Assessment.
These contaminants constitute a representative subset of the more than
thirty-eight contaminants identified at the Landfill during the Phase
1C RI. The twenty-six contaminants of concern were selected to
represent potential site related hazards based on toxicity,
concentration, frequency of detection, and mobility and pe" 'stence in
the environment.
Potential human health effects associated with exposure to the
contaminants of concern were estimated quantitatively through the
development of two hypothetical exposure pathways - ingestion of
ground water and direct contact with sediment. These pathways were
developed to reflect the potential for exposure to hazardous
substances based on the present uses, potential future uses, and
location of the Landfill. For each pathway evaluated and, where
possible, an average and a reasonable maximum exposure estimate was
generated corresponding to exposure to the average and the maximum
concentration detected in that particular medium. The following is a
brief summary of the exposure pathways evaluated. A more thorough
description can be found in sections 6.3 and 6.4 of the Phase IC RI.
Groundwater
The groundwater is not currently being used as a drinking water
source. Therefore, only future use of the groundwater as a drinking
water supply was evaluated as a potential exposure pathway. Separate
risk assessments were calculated for groundwater at the Landfill
perimeter (well GZA-3) and for five downgradient wells (wells MW-4,
MW-S, MW-6, MW-7 and RFW-1). Well GZA-3 is the most contaminated well
at the Landfill and risks exceed EPA's acceptable risk range.
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contaminant levels and associated risks in the downgradient wells are
very low with the exception of pentachlorophenol, a chemical which was
not detected in the Landfill perimeter well. Reasonable maximum
exposure scenarios were developed for the Landfill. perimeter well and
the downgradient wells. An average exposure estimate was developed
for the downgradient wells. The risk assessments assumed a lifetime
of consuming 2 liters of water per day.
Sediment
The potential present and future exposure of children playing along
the Middlesex Canal and Content Brook to contaminated sediment via
dermal contact and incidental ingestion was evaluated. One exposure
scenario was developed to describe both the present and future
potential exposures. It was assumed that children aged 6 to 15 years
could be exposed daily from June to September via wading in the Canal
and Brook.
Potential adverse health effects from exposure to lead in sediment
were evaluated using a uptake/biokinetic model to estimate blood lead
levels.
Surface Water
contaminant concentrations in surface water were so low that a form?~
quantitative Endangerment Assessment was not performed. In this
medium, exposure via dermal contact and incidental ingestion while
wading or swimming were not considered to be of concern.
Baseline Risk Assessment
Excess lifetime cancer risks were determined for each exposure pathway
by multiplying the exposure level with the chemical specific cancer
potency factor. Cancer potency factors have been developed by EPA
from epidemiological or animal studies to reflect a conservative
"upper bound" of the risk posed by potentially carcinogenic compounds.
That is, the true risk is very unlikely to be greater than the risk
predicted. The resulting risk estimates are expressed in scientific
notation as a probability (e.g. 1 x 10-6 for 1/1,000,000) and indicate
(using this example), that an individual is not likely to have greater
than a one in a million chance of developing cancer over 70 years as a
result of site-related exposure as defined to the compound at the
stated concentration. Current EPA practice considers carcinogenic
risks to be additive when assessing exposure to a mixture of hazardous
substances.
The hazard index was also calculated for each pathway as EPA's measure
of the potential for non-carcinogenic health effects. The hazard
index is calculated by dividing the exposure level by the reference
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dose (RfD) or other suitable benchmark for non-carcinogenic health
effects. Reference doses have been developed by EPA to protect
sensitive individuals over the course of a lifetime and they reflect a
daily exposure level that is likely to be without an appreciable risk
of an adverse health effect. RFDs are derived from epidemiological or
animal studies and incorporate uncertainty factors to help ensure that
adverse health effects will not occur. The hazard index is often
expressed as a single value (e.g. 0.3) indicating the ratio of the
stated exposure as defined to the reference dose value (in this
example, the exposure as characterized is approximately one third of
an acceptable exposure level for the given compound). The hazard
index is only considered additive for compounds that have the same or
similar toxic endpoints (for example: the hazard index for a compound
known to produce liver damage should not be added to a second whose
toxic endpoint is kidney damage).
Results of Baseline Risk Assessment
Tables A through F, found in Appendix B of this Record of Decision,
summarize the adverse human health effects for the exposure pathways
identified above.
The estimated reasonable maximum exposure carcinogenic risk for future
potential ingestion of Landfill perimeter groundwater was 2 cancer
cases in 100. In other words, for a population drinking two liters of
the Landfill perimeter groundwater per day for 70 years, 2 cancer
cases would be expected for every 100 people. Arsenic comprised 50%
of this risk estimate and vinyl chloride 43%. Other chemicals which
contribute a risk of greater than one in a million included benzene,
1,2 dichloroethane, methylene chloride and 1,1,2 trichloroethane.
Because one well was considered representative of the Landfill
perimeter contamination and was used in estimating risk, an average
value cannot be calculated.
For noncarcinogenic effects, the reasonable maximum Hazard Indices
estimated for the potential future ingestion of groundwater at the
Landfill perimeter exceeded one for three adverse health effects:
keratosis (skin discoloration), fetotoxicity (fetal effects), and
adverse liver effects. A Hazard Index greater than one means that
there may be concern for these adverse effects occurring to residents
drinking Landfill perimeter groundwater over 70 years. Arsenic,
benzene and vinyl chloride are the major contaminants for these toxic
endpoints, respectively. Because one well was considered
representative of the Landfill perimeter contamination and was used in
estimating risk, an average value cannot be calculated.
The estimated carcinogenic risk for future potential ingestion of
downgradient groundwater ranged from an average of one cancer case in
ten thousand to a reasonable maximum exposure of 4 in ten thousand.
In other words, for a population drinking two liters of the
downgradient groundwater per day for 70 years, an average of 1 cancer
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case, and a maximum of 4 cancer cases would be expected for every ten
thousand people. Pentachlorophenol contributes 100% of this risk.
The Hazard Indices for similar toxic endpoints for the future
ingestion of the downgradient groundwater was less than one for both
the average and reasonable maximum exposures. This means that there
is not a concern of non-carcinogenic adverse health effects in people
who may potentially drink this downgradient groundwater over a 70 year
period.
contaminant concentrations in the Landfill perimeter well used for the
Baselined Risk Assessment (GZA-J) exceeded EPA's goal for carcinogenic
and noncarcinogenic effects. The concentrations in the downgradient
wells did not meet EPA's goal for carcinogenic health effects but met
the goal for noncarcinogenic effects.
contaminant concentrations in sediment were well below EPA's goal for
carcinogenic and noncarcinogenic health effects, respectively. The
estimated blood lead level was below levels believed to cause adverse
health effects.
Environmental Assessment
An Environmental Risk Assessment was conducted to determine the
environmental effects due to leachate seeps to surface water and
wetlands surrounding the Landfill. The area examined for the purpose
of this assessment was the Richardson Pond wetland. A review of
historical information and field surveys confirmed the presence of
visible leachate seeps in this wetland which may have originated from
the Shaffer Landfill. The Environmental Assessment can be found in
section 6 of the Phase 1C Remedial Investigation, pages 6-1 to 6-10.
The assessment included a qualitative vegetation" survey, a semi-
quantitative fish survey, fish tissue analyses, a quantitative
macro invertebrate analysis and sediment analysis.
The vegetation and fish surveys showed little if any effect
attributable to the Landfill. The fish tissue analyses show the
presence of pesticides and PCBs; however there are more compounds and
at higher levels in tissue samples obtained from Long Pond which is
upstream of Richardson Pond. In addition, of the contaminants
detected in fish tissues, only heptachlor was found in Richardson Pond
sediments. Sediments are the normal expected source of pesticides
found in fish tissue.
The macro invertebrate analysis showed a significant reduction in
species diversity and abundance when comparing Richardson Pond to Long
Pond, although this was not accompanied by conditions indicative of
severe water quality deterioration. Immediately downstream of
Richardson Pond the macro invertebrate population showed significant
evidence of recovery. The sediment analysis detected a large
inventory of PAHs in Richardson Pond. There is evidence of
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significant reductions of contaminants immediately downstream of
Richardson Pond which is consistent with the observed recovery in the
macro invertebrate community. In conclusion, there is a clear adverse
effect to macro invertebrates in the Richardson Pond wetland. Whether
this effect is solely a result of contaminant contribution from
Shaffer Landfill or other sources is unclear. Also, the source of the
pesticides and PCBs found in fish tissue is unknown, though they
appear to not be attributable to the Landfill.
The assessment also examined the potential adverse effect of erosion
of the Landfill cap into the surrounding wetlands. As has been
documented in the Phase 1C RI and earlier in this ROD, the creation
and expansion of the Shaffer Landfill has been accompanied by the loss
of wetlands. Wetlands inspections have shown that the Landfill cap,
separate from expansion projects, has had erosion episodes into the
surrounding wetlands, causing filling and thus loss of wetlands. The
assessment concluded that proper construction and long-term
maintenance of the side-slopes, surface drainage system, and erosion
control facilities would be needed to minimize further loss of
wetlands around the Landfill.
Conclusion
Consequently, the Shaffer Landfill remediation will strive to minimize
actual or threatened releases of hazardous substances to the
groundwater in order to achieve cleanup levels that are protective of
human health and the environment and eliminate the Shaffer Landfill as
a source of contamination to surface waters. Actual or threatened
releases of hazardous substances in groundwater from the Landfill, if
not addressed by implementing the response action selected in this
ROD, may present an imminent and substantial endangerment to public
health, welfare or the environment. .
The study and potential remediation of surface waters at Iron Horse
Park as a whole, will be a part of the work conducted in the 3rd
Operable Unit. The Remedial Investigation for the 3rd operable unit
is expected to commence later this summer.
VII. DEVELOPMENT AND SCREENING OF 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,
requirements, criteria or limitations, unless a waiver is
invoked; a requirement that EPA select a remedial action that
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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. Response alternatives were developed
to be consistent with these congressional mandates.
Based on preliminary information relating to types of contami-
nants, environmental media of concern, and potential exposure
pathways, remedial action objectives were developed to aid in
the development and screening of alternatives. These remedial
action objectives were developed to mitigate existing and future
potential threats to public health and the environment. These
response objectives are:
-,
.
Preven~ inqes~ion/direc~ con~ac~ wi~h Landfill was~e
con~amina~ion.
.
Preven~ miqra~ion of con~amina~ion via leacha~e which
would resul~ in qroundwa~er concen~ra~ions in excess of
federal HCLs, non-zero HCLGs, proposed HCLs and HCLGs,
and Hassachuse~~s Groundwa~er Quali~y S~andards.
Preven~ miqra~ion of con~amina~ion via leacha~e ~o
surface waters and sediments to ensure that AWQCs are
no~ exceeded due ~o ~he Landfill.
.
.
Preven~ damaqe and loss of we~lands caused by erodinq
soil from ~he Landfill cap, and mee~ all federal and
s~a~e we~lands pro~ec~ion ABARs.
Preven~ inqes~ion of wa~er havinq con~amina~ion in
excess of federal HCLs, non-zero HCLGs, proposed HCLs
and HCLGs, and Hassachuse~~s Groundwa~er Quali~y
S~andards.
.
.
Res~ore qroundwa~er aquifer beyond ~he poin~ of
compliance ~o con~aminan~concen~ra~ions below federal
HCLS, non-zero HCLGs, proposed HCLs and HCLGs, and
Hassachuse~~s Groundwa~er Quali~y S~andards.
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B. TechDo1oqy 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 were developed for the
site.
with "respect to source control, the RIfFS developed a range of
alternatives that involve little or no treatment but provide
protection through engineering or institutional controls and a no
action alternative.
With respect to the groundwater response action, the RIfFS
developed a limited number of remedial alternatives that attain
site specific remediation levels and a no action alternative.
As discussed in Chapter 4 of the Feasibility Study, the RIfFS
identified, assessed and screened technologies based on
implementability, effectiveness, and cost. These technologies
were combined into source control (SC) and management of
migration (MM) alternatives. Chapter 4 of the Feasibility Study
presented the remedial alternatives developed by combining the
technologies identified in the previous screening process in the
categories identified in section 300.430(e) (3) of the NCP. The
purpose of the initial screening was to narrow the number of
potential remedial actions for further detailed analysis while
pres .ing a range of options. Each alternative was then
eval~~ted and screened in Chapter 4 of the Feasibility Study.
In summary, of the' source control and 5 management of migration
remedial alternatives screened in Chapter 4, 4 source control and
4 management of migration remedial alternatives were retained for
detailed analysis. These retained alternatives were. then
combined into developed alternatives which provide a range of
overall effectiveness, implementability and protectiveness.
These developed alternatives then underwent detailed analysis in
Chapter 5 of the Feasibility Study. Table 4-5 in the FS
identifies the 8 alternatives that were retained through the
screening process, as well as those that were eliminated from
further consideration. Table 4-6 in the FS identifies the
developed alternatives which underwent detailed analysis in
Chapter 5 of the Feasibility study.
VIII.
DESCRIPTION OP ALTERNATIVES
This Section provides a narrative summary of each alternative
evaluated in the FS. The alternatives analyzed reference closure
activities that have taken place pursuant to the Final Judgment
entered into on June 12, 1984 between the Commonwealth of
Massachusetts and the owners of the Landfill. The closure
activities that have taken place to date include: construction
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of a two layer cap which is comprised of a low permeability layer
and topsoil vegetative layer, and installation of a gas
collection/flare system. These closure activities are discussed
more completely in section 5.0 of the Phase lC RI, and Section
2.0 of the Phase lC FS. A tabular assessment of each alternative
can be found in Table 4-6 of the Feasibility Study.
Alternatives ADaly.ed
The alternatives that underwent analysis for the Landfill
include:
No-Action Alternative (Alternative 1):
A Landfill Cap Completion/Repair Alternative
(Alternative 2):
A Landfill Cap Completion/Repair with Leachate
Collection Alternative (Alternative 3):
A Landfill Cap Completion/Repair with Leachate
Collection and Groundwater Extraction and Treatment
Alternative (Alternative 3A):
A Partial Reconstruction of Landfill Cap with Leachate
Collection Alternative (Alternative 4);
A Partial Reconstruction of Landfill Cap with Leachate
Collection and Groundwater Extraction and Treatment
Alternative (Alternative 4A):
A Total Reconstruction of Landfill Cap Alternative
(Alternative 5) and:
A Total Reconstruction of Landfill Cap with Groundwater
Extraction and Treatment Alternative (Alternative SA).
Alternative 1: No-Action
This alternative was evaluated in detail in
Study to serVe as a baseline for comparison
remedial alternatives under consideration.
alternative, no treatment or containment of
leachate would occur and no effort would be
potential exposure to site contaminants.
Alternative 2: Landfill CaD ComDletion/ReDair
the Feasibility
with the other
Under this
waste or
made to restrict
This alternative would include:
Repair of the top portions (approximately 16 acres) of
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the existing cap on both sections of the Landfill by
addition of fill, and regrading to achieve minimum 5%
slopes followed by reconstruction of the low
permeability and topsoil layers over those areas:
;",
Maintenance of cap, surface drainage system, and
landfill gas collection/flare system. If necessary,
improvements will be made:
Monitoring of gas collection/flare system:
Monitoring of groundwater and surface water quality,
and:
Construction of a site perimeter fence.
Under this alternative, the approximately 5 million cubic
yards of waste would be contained.
Under this alternative as well as the other alternatives,
EPA intends to initiate an off-site groundwater monitoring
program in order to monitor and evaluate the effectiveness
of the remedy, and to insure that the Tewksbury wellfield
does not become contaminated due to the Shaffer Landfill.
The placement of wells for the monitoring program, will be
determined during the design process.
ESTIMATED TIME f~. DESIGN and CONSTRUCTION: 6 months
ESTIMATED PERIOD for OPERATION: 30 years
ESTIMATED CAPITAL COST: $1,330,000
ESTIMATED OPERATION and MAINTENANCE COST (net present
worth): $901,000
ESTIMATED TOTAL COST (net present wortn): $2,231,000
Alternative 3:
Collection
Landfill CaD ComDletion/ReDair with Leachate
Alternative 3 contains the same features as Alternative 2 in
terms of completion and maintenance of the Landfill cap and
site security. In addition, Alternative 3 calls for:
Improvements to the existing surface drainage system:
Construction, operation, and maintenance of leachate
collection facilities, and:
Off-site treatment and disposal of leachate.
Implementation of the leachate collection toe drains may
require excavation through refuse. If so, health and safety
precautions for workers will be necessary. Erosion control
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measures are also necessary during the toe drain
construction for the protection of wetlands.
It is estimated that initially approximately 4600
gallons/day of leachate will be collected for off-site
disposal. This estimate of leachate volume will be further
refined during design. The volume of leachate is expected
to decrease over time as the landfill is de-watered.
section l2l(d) (3) of CERCLA must be met for all materials
shipped off-site.
ESTIMATED TIME for DESIGN and CONSTRUCTION: 1 year
ESTIMATED PERIOD for OPERATION: 30 years
ESTIMATED CAPITAL COST: $1,649,000.
ESTIMATED OPERATION and MAINTENANCE COST (net present
worth): $3,541,000
ESTIMATED TOTAL COST (net present worth): $5,190,000
Alternative 3A: Landfill CaD ComD1etion/ReDair with Leachate.
Collection and Groundwater Extraction and Treatment
Alternative 3A contains the same features as Alternative 3
in terms of completion and maintenance of the Landfill cap,
improvements to the surface drainage system and leachate
collection and treatment. .~ addition, Alternative 3A calls
for:
Construction, operation, and maintenance of a
groundwater extraction system along the eastern side of
the Landfill;
Construction, operation, and maintenance of an on-site
system for treatment of groundwater and leachate, and;
Discharge of treated groundwater and leachate to
surface water.
National Pollutant Discharge Elimination System (NPDES)
requirements under the Clean Water Act are applicable to the
discharge of treated water to surface water. Additional
testing during the design phase is required for treatment
plant design.
ESTIMATED TIME for DESIGN and CONSTRUCTION: 2 years
ESTIMATED PERIOD for OPERATION: 30 years
ESTIMATED CAPITAL COST: $8,842,000
ESTIMATED OPERATION and MAINTENANCE COST (net present
worth): $4,310,000
ESTIMATED TOTAL COST (net present worth): $13,152,000
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Alternative 4: partial Reconstruction of Landfill CaD with
Leachate Collection
Alternative 4 was EPA's preferred alternative in the
January 15, 1991 Proposed Plan. This alternative consists
of improvements to the Landfill cap, and collection,
removal, treatment, and disposal of leachate. Alternative 4
.ca1ls for:
.~
Reconstruction of the top portions (approximately 16
acres) of the existing Landfill cap. This will improve
its ability to prevent precipitation from leaching
through the Landfill. Reconstruction would be achieved
by removing the existing topsoil layer, adding fill and
regrading to achieve a minimum 5% slope, installing
additional low permeability material (either an
additional 12-inches of soil with a maximum
permeability of 1x10-7 em/see or a flexible membrane
liner), installing a new 6-inch drainage layer,
reinstalling the topsoil layer to a depth of 12-inches,
and reseeding the disturbed areas:
Improvements to the existing surface drainage system:
Maintenance of cap, surface drainage system, and
landfill gas collection/flare system. If necessary,
improvements will be made:
Monitoring of the gas collection/flare system:
Monitoring of groundwater and surface water quality:
Construction, operation, and mai~tenance of leachate
collection facilities:
Off-site treatment and disposal of leachate, and:
Construction of a site perimeter security fence.
Implementation of the leachate collection toe drains may
require excavation through refuse. If so, health and safety
precautions for workers will be necessary. Erosion control
measures are also necessary during the toe drain
construction for the protection of wetlands.
It is estimated that initially approximately 4600
gallons/day of leachate will be collected for off-site
disposal. This estimate of leachate volume will be further
refined during design. The volume of leachate is expected
to decrease over time as the Landfill is de-watered.
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section 121{d) (3) of CERCLA must be met for all materials
shipped off-site.
ESTIMATED TIME for DESIGN and CONSTRUCTION: 1 year
ESTIMATED TIME for OPERATION: 30 years
ESTIMATED CAPITAL COST: $2,095,000
ESTIMATED OPERATION and MAINTENANCE COST (net present
worth): $3,541,000
ESTIMATED TOTAL COST (net present worth): $5,637,000
Alternative 4A: Partial Reconstruction of Landfill CaD with
Leachate Collection and Groundwater Extraction and Treatment
Alternative 4A includes all of the landfill cap
reconstruction features, improvements to the surface
drainage system, and leachate collection and treatment,
which are also part of Alternative 4. In addition,
Alternative 4A includes:
Construction, operation, and maintenance of a
groundwater extraction system along the eastern side of
the Landfill;
Construction, operation, and maintenance of an on-site
system for treatment of groundwater and leachate, and;
Discharge of treated groundwater and l~~~hate to
surface water.
National pollutant Discharge Elimination System (NPDES)
requirements under the Clean Water Act are applicable to the
discharge of treated water to surface water. Additional
testing during the design phase is required for treatment
plant design.
ESTIMATED TIME for DESIGN and CONSTRUCTION: 2 years
ESTIMATED PERIOD for OPERATION: 30 years
ESTIMATED CAPITAL COST: $9,257,000
ESTIMATED OPERATION and MAINTENANCE COST (net present
worth): $4,310,000
ESTIMATED TOTAL COST: $13,567,000
Alternative 5:
Total Reconstruction of Landfill CaD
This alternative involves a complete reconstruction of the
Landfill cap but does not include leachate collection and
treatment. The components of Alternative 5 are:
Reconstruction of the entire Landfill cap to meet EPA's
recommended final cover design standards for hazardous
waste landfills;
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Maintenance of cap and landfill gas collection/flare
system. If necessary, improvements will be made:
Monitoring of gas collection/flare system:
Monitoring of groundwater and surface water quality,
and:
Construction of a site perimeter fence.
The cap reconstruction is extensive, and would include the
following activities:
Excavation of the existing vegetated topsoil:
Temporary storage of the excavated soil:
Removal of existing surface drainage facilities:
Protection and raising of existing gas collection
manholes:
Regrading to establish required slopes:
upgrading the existing low permeability soil layer to
achieve 24 inches of soil with a maximum permeability
of 1 xlO-7 em/see:
Testing of the upgraded low permeability layer to
assure design standards are achieved:
Installation of a flexible membrane liner {FML)
component directly above the upgraded low permeability
soil layer:
Installation of a soil drainage layer above the FML to
drain the immediate and upgradient areas of the
landfill:
Installation of a geotextile filter between the
drainage layer and upper vegetative layer;
Installation of the vegetative support layer consisting
of a minimum 24-inch layer of soil:
Re-establishment of vegetative cover:
Construction of required surface water runoff control
facilities, and:
Erosion control during construction activities
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ESTIMATED TIME for DESIGN and CONSTRUCTION: 2 1/2 years
ESTIMATED PERIOD for OPERATION: 30 years
ESTIMATED CAPITAL COST: $12,799,000
ESTIMATED OPERATION and MAINTENANCE COST (net present
worth): $901,000
ESTIMATED TOTAL COST (net present worth): $13,700,000
Alternative SA: Total Reconstruction of Landfill CaD with
Groundwater Extraction and Treatment
Alternative SA contains all components of Alternative 5.
In addition, Alternative SA includes:
Construction, operation, and maintenance of a
groundwater extraction system along the eastern side of
the landfill:
Construction, operation, and maintenance of an on-site
groundwater treatment system, and:
Discharge of treated groundwater to surface water.
National Pollutant Discharge Elimination System (NPDES)
requirements under the Clean Water Act are applicable to the
discharge of treated water to surface water. Additional
testing during design is required for treatment plant
design.
ESTIMATED TIME for DESIGN and CONSTRUCTION: 2 1/2 years
ESTIMATED PERIOD for OPERATION: 30 years
ESTIMATED CAPITAL COST: $19,992,000
ESTIMATED OPERATION and MAINTENANCE COST (net present
worth): $4,310,000
ESTIMATED TOTAL COST (net present worth): $24,302,000
IX.
SUMMARY OF THE COMPARATIVE ANALYSIS OF 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.
A detailed analysis was performed on the alternatives using
the nine evaluation criteria in order to select a site
remedy. The following is a summary of the comparison of
each alternative's strengths and weaknesses with respect to
the nine evaluation criteria. These criteria and their
definitions are as follows:
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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.
2.
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.
Compliance with Applicable or relevant and appropriate
requirements (ARABS) 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.
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 the degree of certainty that they will prove
successful.
4.
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.
s.
6.
Implementability addresses the technical and
administrative feasibility of a remedy, including the
availability of materials and services needed to
implement a particular option.
7.
Cost includes estimated capital and Operation
Maintenance (O&M) costs, as well as present-worth
costs.
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Modifvina criteria
The modifying criteria are used on the final evaluation of
remedial alternatives generally after EPA has received
public comment on the RIfFS 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.
9.
community acceptance addresses the public's general
response to the alternatives described in the Proposed
Plan and RIfFS report.
A detailed narrative assessment of each alternative
discussed in the FS according to the nine criteria can be
found in section 5 from page 5-5 to page 5-81 of the
Feasibility Study.
Following the detailed analysis of each individual
alternative, a comparativ~ analysis, focusing on the
relative performance of each alternative against the nine
criteria, was conducted. This comparative analysis can be
found in Table 5-11 of the Feasibility Study, and a more
complete version that includes the selected remedy can be
found in Appendix C of this ROD.
The section below presents the nine 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
Alternative 1 (No-action) does provide some limited
protection since there is already a cap in place. However,
as there is no perimeter security fence, and no operation
'and maintenance plan, any protection provided by this
alternative would diminish over time. As a result, this
alternative will never achieve reliable protection of human
health and the environment. '
Alternatives 2, 3, 3A, 4, 4A, 5, 5A, and the Selected Remedy
all would provide some protection, but to varying degrees.
In general, cap effectiveness and erosion protection
increase from Alternative 2 to Alternatives 5 and 5A. The
Selected Remedy is very close to Alternatives 5 and 5A in
terms of cap effectiveness and erosion protection. The cap
utilized in Alternatives 2, 3, and 3A provides improvements
to the cap which is currently in place, specifically, by
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increasing the grade on the top, flatter section of both the
Residential and Commercial portions of the landfill
(approximately 16 acres total). Alternatives 3 and 3A also
call for improving the surface drainage system. The cap
utilized in Alternatives 4 and 4A, further improves the cap
performance by reducing permeability and adding a drainage
layer thereby providing greater protection than Alternatives
2, 3, and 3A by reducing both infiltration through the
Landfill, and erosion of the cap. The cap utilized in
Alternatives S and SA provides even greater overall
protection by totally reconstructing the cap and installing
a composite cap which meets EPA's recommended final cover
design standards for hazardous waste landfills. The
Selected Remedy calls for the reconstruction of the entire
Landfill surface and the installation of an additional
impermeable layer and a drainage layer over the entire 60
acres of the Landfill. These measures, while not involving
the same degree of cap reconstruction as is required in
Alternatives S and SA, enable the Selected Remedy to very
closely approach the overall protectiveness provided by
Alternatives S and SA. The increase in cap effectiveness in
the alternatives considered generally provides an
increasingly stable and permanent cap and so is accompanied
by a decrease in the need for maintenance.
Alternatives 1, 2, and S contain no measures to provide
additional protection regarding leachate or groundwater.
Overall protection is enhanced in Alternatives 3, 3A, 4, 4A
and the Selected Remedy by the addition of leachate
collection, and in Alternatives 3A, 4A, and SA by the
addition of groundwater extraction and on-site treatment.
Collection and treatment of leachate will greatly reduce the
risk associated with the leachate and prevent further
contamination of both groundwater and surface water from the
Landfill due to leachate seeps. Groundwater treatment will
eliminate the risk associated with contaminants in the.
groundwater east of the Landfill. Alternatives 3, 4, and
the Selected Remedy call for leachate to be transported off-
site for treatment and disposal and there is a risk
associated with this transportation. This risk will be
minimized by adherence to regulations governing the storing,
handling, transporting, and manifesting of hazardous
materials (leachate), if applicable.
2.
Como1iance with Aoolicable or Relevant and Aoorooriate
Reauirements (ARARs)
The Alternatives were evaluated for compliance with ARARs,
including chemical-specific, action-specific, and location-
specific ARARs. Alternatives 1 and 2 would not meet ARARs
(MCLs and Massachusetts Groundwater Quality Standards).
Alternatives 3, 3A, 4, 4A and the Selected Remedy would meet
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all ARARs. Alternatives 3 and 4 would take considerably
longer than the Selected Remedy to meet chemical-specific
ARARs because the Selected Remedy has a much more effective
cap. The addition of groundwater extraction and treatment
in Alternatives 3A and 4A would significantly reduce the
time before chemical-specific ARARs would be met.
Alternatives S and SA require the placement of a significant
volume of fill material in wetlands and the floodplain. In
doing so, these alternatives do not comply with wetlands and
floodplain ARARs because there are other practicable
alternatives to filling the wetlands and floodplains that
would have a less adverse impact on the aquatic ecosystem
and do not have other significant adverse environmental
impacts.
3.
Lona-~erm Effec~iveness and Permanence
Alternative 1 will probably never achieve reliable
protection of human health and the environment. In
addition, the effectiveness and permanence of Alternative 1
would be expected to diminish over time. Because there is a
relatively unstable cap and no maintenance plan under this
Alternative, an i~crease in the infiltration of water
through the cap and waste material will result in an
increasing flow of contaminants to groundwater and leachate.
In addition, the cap itself will deteriorate over time
exposing both the public and the environment to direct
contact with the waste material. Finally, the magnitude of
residual risk remaining at the Landfill is highest because
this Alternative has the least effect on the volume,
mobility and toxicity of contaminated leachate.
Alternative 2 provides increased long-term effectiveness and
permanence through improvements to the cap, and the addition
of an operation and maintenance plan and a site perimeter
fence. Because this Alternative addresses neither leachate
nor groundwater, the magnitude of residual risk is high.
Alternative 3 contains the same cap, operation and
maintenance plan, and fence improvements as Alternative 2,
but provides additional effectiveness and permanence through
improving the surface drainage system and the collection of
leachate for off-site treatment and disposal. Improvements
to the surface drainage system will enhance the permanence
and reliability of the cap by reducing infiltration and
erosion. Alternative 3A is identical to Alternative 3, but
with the addition of a groundwater extraction and treatment
system, and would provide the same degree of long-term
effectiveness and permanence. The magnitude of the residual
risk is smaller for Alternatives 3 and 3A than for
Alternatives 1 and 2 because contaminants in groundwater
and/or leachate have been addressed under these
Alternatives.
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Alternative 4 provides a more effective cap in terms of
inhibiting water infiltration. In addition to the surface
drainage system improvements which are also a part of
Alternatives 3 and 3A, Alternative 4 contains a thicker
vegetative layer, and a drainage layer beneath the
vegetative layer. This drainage layer, coupled with the
improvements to the surface drainage system, greatly enhance
-the permanence of the cap and further reduce the potential
for erosion. Alternative 4 also contains the provision for
collection of leachate for off-site treatment and disposal.
Alternative 4A is identical to Alternative 4 with the
exception that it adds a groundwater extraction and
treatment system and would provide the same degree of long-
term effectiveness and permanence. The magnitude of
residual risk at the Landfill is smaller than Alternatives 1
and 2 because these Alternatives provide for collection and
treatment of leachate and/or groundwater thereby reducing
contaminants in these media to acceptable levels. In
addition, the residual risk for these Alternatives is lower
because the cap is more effective, thereby reducing the
mobility and volume of contaminants to a greater extent than
Alternatives 1 through 3.
The Selected Remedy provides the same type of cap
construction as that contained in Alternative 4. However,
long-term effectiveness and permanence are enhanced with the
~lected Remedy by extending the coverage of the
-~econstructed cap to include the entire Landfill.
Alternative 4 would reconstruct the cap over only the top 16
acres of the Landfill, while the Selected Remedy will cover
the full 60 acres of the Landfill surface. Alternatives 1,
2, 3, 3A, 4, and 4A, all rely exclusively on the existing
cap with regard to protection of the Landfill side-slopes.
The Selected Remedy remediates side-slope deficiencies
through reconstruction of the entire Landfill. Total
coverage of the Landfill will provide an even more
protective cap in terms of inhibiting water infiltration.
The Selected Remedy calls for a drainage layer underlying
the vegetative layer of the entire cap, and this layer,
coupled with the rebuilt surface drainage system, further
enhances the permanence of the cap and provides for
additional protection against erosion. The Selected Remedy
also contains the provision for collection of leachate for
off-site treatment and disposal.
, )
Alternative 5, through complete reconstruction of the cap,
provides a high degree of permanence and effectiveness. The
cap is very stable and greatly limits the infiltration of
water. Alternative 5 does not contain provisions for the
collection and treatment/disposal of leachate, so there is
no reduction in the volume of residual waste remaining at
the Landfill. Alternative SA is identical to Alternative 5
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4.
with the exception that it includes a groundwater extraction
and treatment system and therefore provides a high degree of
reliability. The residual risk at the Landfill under this
Alternative is the lowest of all Alternatives because
contaminants in groundwater are treated to acceptable levels
while this highly efficient cap greatly reduces the mobility
of the remaining contaminants at the Landfill.
Reduction of Toxicitv. Mobilitv. or Volume Throuah Treatment
Alternatives 1, 2, and 5, do not provide a reduction of
toxicity, mobility, or volume through treatment.
Alternatives 3, 4, and the Selected Remedy, reduce toxicity,
mobility, and volume through treatment by collecting
leachate and treating and disposing of it off-site.
Alternatives 3A, 4A, and SA, reduce toxicity, mobility, and
volume through treatment by extraction and treatment of
groundwater. In addition, Alternatives 3A, and 4A also
contain a provision for leachate collection and treatment.
5.
Short-term Effectiveness
6.
There are no short-term impacts associated with Alternative
1 as there is no work involved in implementing this
Alternative. with all the remaining Alternatives, the
potential exists for erosion and associated damage to
wetland~. .'Irinq landfill cap repair and reconstruction
activit~-~. Erosion control precautions would limit adverse
impacts during implementation. The alternatives with
leachate collection (Alternatives 3, 3A, 4, 4A, and the
Selected Remedy) require excavation through areas of known
leachate outbreak. Because of the potential risk associated
with these activities, engineering precautions would be
needed to minimize the risk of contaminant emissions and
ensure short-term protection of workers, residents and the
environment. The transportation of leachate off-site
contained in Alternatives 3, 4, and the Selected Remedy
involves some short-term risk. Alternatives 5, SA, and the
Selected Remedy require significant new cap material. As a
result there would be significant daily truck traffic in the
community throughout the relatively long implementation
period of these Alternatives. Alternatives 1 and 2 would
have no short term impact on the floodplain. Alternatives
3, 3A, 4, 4A, and the Selected Remedy would have short term
impacts on the floodplain during limited construction
activities which would need to take place within the
floodplain. Implementation of Alternatives 5 and SA would
result in permanent loss of floodplain through extension of
the base of portions of the Landfill in order to meet slope
requirements.
ImD1ementabi1itv
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Except for Alternatives 5 and 5A, all alternatives retained
for detailed analysis are technically and administratively
implementable. In order to provide the necessary slope for
the Landfill under Alternatives 5 and 5A, a portion of the
Boston & Maine railroad tracks would be covered and wetlands
and floodplains would be filled, making these alternatives
technically and administratively difficult to implement.
Alternatives 5 and 5A also present implementation concerns
because they require the procurement, hauling, and handling
of large volumes of materials necessary for cap
reconstruction. The Selected Remedy would also require a
significant volume of material although it requires less
material than Alternatives 5 and 5A.
7. Cost
Capital O&K Total Present
Costs Costs Worth
Alternative 1 0 0 0
Alternative 2 $ 1,330,021 901,590 $ 2,231,611
Alternative 3 $ 1,648,729 3,541,426 $ 5,190,155
Alternative 3A $ 8,841,772 4,310,090 $ 13,151,862
~, :-.
Alternative" ~':l,095,753 3,541,4'26 $ 5,637,179
Alternative"A $ 9,257,206 4,310,090 $ 13,567,296
Alternative 5 $12,798,759 901,590 $.13,798,759
Alternative SA $19,991,802 4,310,090 $ 24,301,892
selected Remedy $ 9,012,098 3,541,426 $ 12,553,524
Additional information regarding costs for each alternative
is located in Section 5.0 of the Feasibility Study.
8.
state AcceDtance
The Commonwealth of Massachusetts through the Department of
Environmental Protection has concurred in the selection of
this remedial action.
9.
Community AcceDtance
EPA received over 130 comments from Billerica residents,
community organizations, and town officials regarding the
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cleanup of the Shaffer Landfill. There was virtually
unanimous support for choosing a remedy which provided for
capping of the entire Landfill. There was also widespread
support for the collection and treatment of leachate.
x.
THE SELECTED REMEDY
EPA has selected a comprehensive remedy consisting of the
following alternative.
The Selected Remedy is a modified version of Alternative 4.
The design components of the Selected Remedy are very
similar to Alternative 4, however the areal extent of the
cap reconstruction will extend as much as feasible over the
entire surface of the landfill. This is a substantial
difference. Where Alternative 4 calls for approximately 16
acres of cap reconstruction, the Selected Remedy requires
reconstruction of the entire 60 acres of Landfill surface.
It is expected that the feasibility of extending this cap
over the entire landfill may be limited in a minor way by.
steep side slopes.
EPA believes this remedy is comprehensive as it contains
both source control and management of migration components
and uses treatment to address the principal threat and
engineering controls to a: ~ss relatively low long term
threats identified at the ~ite. A detailed descrip~ion of
the cleanup levels and the Selected Remedy is presented
below.
A.
Interim Groundwater CleanuD Levels
Interim cleanup levels have been established in groundwater
for all contaminants of concern identified in the baseline
risk assessment found to pose an unacceptable risk to either
public health or the environment. Interim cleanup levels
have been set based on the appropriate ARARs (e.g. Drinking
Water MCLGs and MCLs) if available, or other suitable
criteria described below. Periodic assessments of the
protection afforded by the remedial action will be made as
the remedy is being implemented and at the completion of the
remedial action. At the time that all the interim cleanup
levels described below have been achieved, a risk assessment
shall be performed on the residual groundwater
contamination. This risk assessment of the residual
groundwater contamination shall follow EPA procedures and
will assess the cumulative risks for carcinogens and non-
carcinogens posed by consumption of groundwater based upon
knowledge of these risks at the time this risk assessment is
conducted. If the risks are not within EPA's risk
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management goal for carcinogens and non-carcinogens, then
the remedial action will continue until protective levels
are attained, or the remedy is otherwise deemed protective.
Because the aquifer at the edge of the Landfill, the point
of compliance, is classified as a Class II aquifer which is
a potential source of drinking water (MADEP has classified
this aquifer under the Massachusetts classification system
as Class I groundwater, a source of potable water supply),
MCLs and non-zero MCLGs established under the Safe Drinking
Water Act are ARARs.
Interim cleanup levels for known and probable carcinogenic
compounds (Class A and B) have been set at the appropriate
MCL. The MCLG is set at zero for all Class A and B
compounds and, therefore, is not used as a target cleanup
level. The MCLG is nonzero for all other compounds.
Cleanup levels for the Class C compounds (possible
carcinogens) have been set at the MCLG.
Table I below summarizes the interim cleanup levels for
carcinogenic and non-carcinogenic contaminants of concern
identified in groundwater.
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1ABLE I: GROUNDWATER INTERIM CLEANUP LEVELS
carcinogenic Cleanup
contaminants of Level Level
of
Concern (Class) (DDb) Basis mgt . b Risk
Arsenic (A) 50 MCL8/risk 2.0E-04
Benzene (A) 5 MCL 4.1E-06
1,2 Dichloroethane (B) 5 MCL 1. 3E-05
Methylene Chloride (B) 5 pMCLc 1.0E-06
pentachlorophenol (B) 1 pMCL 3.4E-06
1,1,2 Trichloro- MCLGd
ethane (C) 3 8.1E-06
Trichloroethylene (B) 5 MCL 1.6E-06
vinyl Chloride (A) 2 MCL 1. 3E-04
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Total Risk = 3.6E-04
a - Maximum contaminant Level, Safe Drinking Water Act
b -
c -
The cleanup level for arsenic has been set at the MCL of 50
ppb. The carcinogenic risk posed by arsenic at 50 ppb in
groundwater will approximate 2 in 1,000. However, in light
of recent studies indicating that many skin' ~ors arising
from oral exposure to arsenic are non-lethal" and in light of
the possibility that the dose-response curve for the skin
cancers may be sublinear (in which case the cancer potency
factor used to generate risk estimates will be overstated),
it is Agency policy to manage these risks downward by as
much as a factor of ten. As a result, the carcinogenic
risks for arsenic at this site have been managed as if they
were 2 in 10,000. (See EPA memorandum, "Recommended Agency
Policy on the Carcinogenic Risk Associated with the
Ingestion of Inorganic Arsenic" dated June 21, 1988.)
proposed Maximum contaminant Level
d -
Proposed Maximum contaminant Level Goal
In the Baseline Risk Assessment, hazard indices greater than one
were calculated for arsenic, benzene and vinyl chloride.
carcinogenic effects of these compounds are the overriding
concern and cleanup levels have been set as shown in the above
table.
These cleanup levels must be met at the completion of the
remedial action at the point of compliance which is the edge of
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the waste management unit (i.e. beyond the area where waste is
left in place).
These cleanup levels are consistent with ARARs for groundwater
and attain EPA's goal for remedial actions.
B.
Descriotion of Remedial Comoonents
The remedy will consist
cap. What follows is a
effective measures will
into the final design.
of reconstruction of the entire landfill
conceptual design only. Equal or more
be considered and may be incorporated
Reconstruction will be accomplished by:
1 -
2 -
3 -
4 -
5 -
6 -
7 -
8 -
9 -
Removing the existing topsoil layer exposing the existing
in-place low-permeability soil;
Raising gas collection vell heads as necessary up to
reconstructed cap surface level;
Adding additional low-permeability soil;
Grading of low-permeability soil to:
a)
Provide a 5% grade on the top of the landfill lobes,
and
b)
Provide a consistent smooth sub-grade on the 1a..wii1l
side slopes;
Installing an impermeable textured membrane liner over the
entire landfill area;
Installing a 6-inch drainage layer on top of the textured
membrane liner over the entire landfill area;
Installing a non-woven filter fabric between the drainage
and topsoil layers;
Reinstalling the topsoil layer and adding additional topsoil
to acbieve a topsoil deptb of 12 incbes:
Reinstalling an upgraded surface drainage system;
The surface drainage system will be designed during remedial
design to optimize the removal of surface water from the landfill
cap.
10 - Reseeding of the disturbed areas.
In areas where stability proves to be an engineering concern
because of excessive side-slope incline, either a geo-grid or
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crushed stone will be utilized in addition to the synthetic liner
and in place of reseeding (i.e. vegetative cover) to provide
adequate stability. It is estimated that this may effect
approximately 2.5 of the 60 acres involved in the capping. The
actual area affected will be determined during remedial design.
The remedy will also include:
Maintenance of cap, surface drainage system, and
landfill gas collection/flare system. If necessary,
improvements will be made based upon the protectiveness
and effectiveness of these components,
It is expected that over time the Landfill will experience
surface subsidence. How much subsidence is expected, how much
subsidence the cap, the surface drainage system, and the gas
collection system can withstand, specifics regarding the
frequency and requirements of inspections, and, corrective
actions required, will be determined during remedial design.
Monitoring of the gas collection/flare system,
EPA believes that the reconstructed landfill cap coupled with the
maintenance of the gas collection/flare system will greatly
mitigate or eliminate the odor and emission problems which have
been associated with the Landfill. In addition, EPA believes
that these improvements to the cap (and if necessary, gas
collection/flare system) will eliminate any unacceptable risk
from air emissions. The gas collection/flare system will be
monitored to insure that public health and the environment are
not at risk due to emissions from the Landfill. This long-term
monitoring program will be established during remedial design,
and will be designed to monitor Landfill emissions entering and
exiting the flare system, and from components of the gas
collection system. In addition, an air quality study will be
undertaken to confirm that there is no risk to area residents or
workers at the Landfill from exposure to airborne contaminants
which were detected during air surveys conducted in 1990 or other
contaminants which may be emitted from the Landfill in the
future. EPA believes these emissions were the result of
inadequacies in cap design as well as lack of adequate
maintenance of the gas collection/flare system. To effectively
conduct this study, the following shall, at a minimum, be
required:
1.
On and/or off-site meteorological station:
2.
Sampling at the Landfill gas collection system
manhole/manhole covers, at the entry and stack of the
existing flare, at the Landfill perimeter and property
boundaries, and at other removed sampling stations to
determine amounts and concentrations of hazardous
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Landfill gas emissions and to differentiate Landfill
source contribution from background levels of
contamination;
3.
Approved sampling and analysis techniques suitable for
quantitative risk evaluation;
4.
Approved Quality Assurance/Quality Control Plan;
Sampling for air quality study to begin upon completion
of cap reconstruction. Sample locations and
methodology to be determined during design phase.
5.
If EPA determines that residents or Landfill workers are at risk
from exposure to emissions from the Landfill, EPA may also
determine that additional treatment of gas emissions from the
flare system or from the Landfill itself is necessary. If that
is the case, EPA will consider an array of appropriate treatment
technologies to treat these emissions. During cap reconstruction
an approved Health and Safety Plan must be in place to insure
that workers at the Landfill are protected from risk due to
exposure to emissions from the Landfill.
Monitoring of groundwater and surface water quality;
A long term monitoring program for groundwater and surface water
quality will be designed and implemented. The intent of this
program is to monitor the effectiveness of the remedy in meeting
clean-up levels, to monitor the effectiveness of the remedy in
preventing the migration of contamination to groundwater, to
eliminate Shaffer Landfill as a source of contamination to
surface water, and to insure that contamination from "the Shaffer
Landfill is not endangering or migrating towards the Tewksbury
Municipal Wells. The design of the monitoring program, surface
water sampling points, integrity of existing wells, the need for
new wells, and sampling frequency, and the corrective action to
be taken if the remedy is not effective will be determined during
remedial design.
construction, operation, and maintenance of leachate
collection facilities;
Leachate collection toe-drains will be sited above the water
table and designed to collect the maximum volume of leachate
feasible. Final design and siting of toe-drains will take place
during remedial design. It was determined in the Floodplain
Assessment that there is no practical alternative to locating the
leachate storage tank within the lOO-year floodplain. This will
have a limited short-term impact on the floodplain because the
leachate storage tank will be placed underground. Because of
this, pre-construction grades and topography can be restored and
there will be a minimal net loss of floodplain. Final sizing and
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siting of leachate storage facilities will be accomplished during
remedial design, and will be in accordance with applicable state
and federal laws.
Off-site treatment and disposal of leacbate;
Collected leachate will be tested to determine treatment and
disposal requirements. Route and method of transporting leachate
off-site will be determined during pre-design.
construction of site perimeter security fence;
A site perimeter security fence will be constructed in order to
prevent unauthorized access to the Landfill property. The
specifications and design of the perimeter security fence will be
determined during pre-design. Inspection of the fence condition
and determination of its effectiveness in preventing access to
the Landfill property, will be made a part of the operation and
maintenance plan.
xnstitutional controls, and;
Institutional controls. in the form of deed restrictions will be
placed on the property to ensure that groundwater beneath the'
Landfill and within the contaminated groundwater plume will not
be used for drinking water and that no activities will be
conducted on the Landfill surface which compromise either the
integrity of the cap, or the protection of human health and the
environment.
Post Closure Plan
A Post Closure Plan will be prepared during remedial design.
This plan will encompass all operation and maintenance,
monitoring, and inspection activities associated with the
Landfill.
EPA will conduct a statutory review of the Landfill at least once
every five years after the initiation of remedial action at the
Landfill to assure that the remedial action continues to protect
human health and the environment. EPA may also evaluate risk
posed by the site at the completion of the remedial action (i.e.,
before the site is proposed for deletion from the NPL).
xx.
STATUTORY DETERKXNATXONS
The remedial action selected for implementation at the Shaffer
Landfill 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.
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The selected remedy also satisfies the statutory preference for
treatment which permanently and significantly reduces the
mobility, toxicity or volume of hazardous substances as a
principal element. Additionally, the Selected Remedy utilizes
alternate treatment technologies or resource recovery
technologies to the maximum extent practicable.
A.
The Selected Remedy i. Protective of Human Health and the
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, and institutional
controls.
Reconstruction of the Landfill cap will eliminate the potential
for direct contact with refuse, providing protection of human
health and the environment. The reconstructed cap, and more
specifically the impermeable layer, the drainage layer, and the
surface drainage system will greatly reduce the infiltration of
water thru the refuse, thereby controlling the production of
leachate and the migration of contamination to surface water and
groundwater. The drainage layer and surface drainage system will
serve to enhance the stability and permanence of the Landfill
cap, preventing erosion of the cap itself and the migration of
cap material into the surrounding wetlands. The site perimeter
fence will prevent trespassing on-site, and, as a result, will
eliminate potential erosion and exposure problems caused by
unauthorized, uncontrolled site access. A leachate collection
system will insure that contamination from the Landfill does not
impact the groundwater or surface water due to leachate seeps.
Treatment and disposal of leachate will provide a reduction of
toxicity, mObility, and volume of contaminants remaining on-site.
Monitoring of the Landfill gas collection/flare system will
insure that public health is not at risk from the emissions of
the flare system or the Landfill. A study of air quality in the
area, and an associated risk assessment will show any possible
on-site and off-site risk which exists due to these emissions.
This risk assessment, performed by EPA, will confirm that there
is no risk which must be addressed in order for the remedy to be
fully protective of human health and the environment.
A long-term monitoring program will insure that the Selected
Remedy for the Landfill remains protective of human health and
the environment. This program will include local groundwater
monitoring and surface water monitoring in Richardson Pond and
Content Brook. Institutional controls in the form of deed
restrictions and groundwater use restrictions, will be used to
control the future use of the Landfill. The institutional
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<:>
,',
controls will be focused on preventing the disturbance of the
physical integrity of the components of the remedy, and
preventing the use of groundwater beneath the Landfill and
throughout the contaminated plume for drinking water. The
Selected Remedy will meet groundwater clean-up levels and bring
contaminant levels within the EPA established risk range by
isolating the source of contamination with a highly impermeable
cap, collecting contaminated leachate for treatment and disposal,
and allowing groundwater contamination to naturally attenuate.
Implementation of the Selected Remedy will achieve groundwater
clean-up levels, and, by so doing, will reduce the carcinogenic
and non-carcinogenic risks to human health to the goals required
by EPA.
Finally, implementation of the Selected Remedy will not pose
unacceptable short-term risks or cross-media impacts. The only
disturbance to the Landfill cap during implementation will be
for removal of the topsoil layer. During this time, engineering
controls will be implemented to prevent cap erosion. The
leachate collection toe-drains will be excavated through areas
of known leachate outbreak. Because of the potential risk
associated with these activities, strict engineering precautions
would be needed to minimize the risk of contaminant emissions and
insure short-term protection of workers, residents and the
environment. Complying with RCRA and DOT regulations in the
handling, transportation and disposal of leachate, if determined
applicable, will minimize any short-term risk arising from these
activities. The transportation of leachate off-site does present
some short-term risk. Short-term risk will be minimized by
adherence to applicable laws. The procurement of the large
volume of material required for cap reconstruction, will have
short-term impacts on the community mainly do to an increase in
truck traffic involved in transporting cap materials.
B. The Selected Remedy Attains ARARs
This remedy will attain all applicable or relevant and
appropriate federal and state requirements that apply to the
Landfill. Environmental laws and regulations from which ARARs
for the selected remedial action are derived and the specific
ARARs include:
Chemical Specific
Safe Drinking Water Act (SDWA) - Maximum contaminant Levels
(MCLs) and non-zero Maximum contaminant Level Goals (MCLGs)
40 CFR 141.11-141.16 and 40 CFR 141.50-141.52
Mass Groundwater Quality Standards - 314 CMR 6.00
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"
Location - SDecific
Clean Water Act (CWA) - 40 CFR part 230
Endangered species Act - 16 U.S.C.1531 et seq: 50 CFR parts 81,
225, and 402
Executive Order 11990 - Protection of Wetlands
Executive Order 11988 - Floodplain Management
National Historic Preservation Act - 16 U.S.C.470: 7 CFR part 650
Hassachusetts Wetlands protection Law - 310 CMR 10.00
40 CPR Part I, Appendix A
Hassachusetts Hazardous Waste Requlations - Land Subject to
Flooding - 310 CMR 30.701
Action - SDecific
RCRA Hazardous Waste Requlations - Subtitle C
Groundwater Monitoring
RCRA Post Closure Care Requirements
Clean Air Act (CAA)
National Ambient Air Quality standards (NAAQS) for
Seven criteria Pollutants for Particulates - 40 CFR
part 50 .
National Emissions standards for Hazardous Air
Pollutants (NESHAPs) for Benzene - 40 CFR part 61
DOT Rules for Hazardous Haterials Transport - 49 CFR parts 107,
171, and 172
Hass Hazardous Waste Requlations - 310 CMR 30.00
Hassachusetts Ambient Air Quality standards for Particulates -
310 CMR 6.00
Hassachusetts Air Pollution Control Law - 310 CMR 7.00
Hassachusetts Solid Waste Requlations - 310 CMR 19.00
To-Be-Considered
Hassachusetts Air Toxics Program (Hay 1987)
proposed HCLs and HCLGs
A more inclusive listing of ARARs can be found in Appendix D of
this Record of Decision. This Table lists all potential ARARs
identified for the Landfill and gives brief synopses of the ARARs
and explanations of the actions necessary to meet the ARARs. The
Table also indicates whether the ARARs are applicable or relevant
and appropriate to actions at the Landfill. In addition to
ARARs, the Table describes standards that are To-Be-Considered
(TBC) with respect to remedial actions.
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o
, "
Major requirements at the Shaffer Landfill are discussed below.
1.
Chemical - Soecific Reauirements
The groundwater aquifer at and beyond the compliance boundary of
the Landfill is classified as Class IIB, a potential drinking
water source. (MADEP has classified this aquifer under the
Massachusetts classification system as Class I groundwater, a
source of potable water supply.) SDWA MCLs and MCLGs are
standards that apply to public water systems. Because the
groundwater in the vicinity of the Landfill is classified as a
potential drinking water source and not a public water system as
defined by the SDWA, MCLs and MCLGs are relevant and appropriate
rather than applicable, and proposed MCLs and MCLGs are To-Be-
Considered.
2.
Location - soecific Reauirements
40 CFR Part 6, Appendix A, requires EPA to implement Executive
Order 11988 (Floodplain Management) and Executive Order 11990
(protection of Wetlands). To comply with Executive Order 11988,
a remedial action must reduce the risk of flood loss and restore
and preserve the natural and beneficial values served by
floodplains. Executive Order 11990 requires EPA to minimize the
destruction, 'oss or degradation of wetlands.
.-!!' .
Portions of the Landfill lie within the 100-year floodplain.
wetlands are located immediately adjacent to portions of the
Landfill. The Selected Remedy will result in minimal impacts to
the wetlands and floodplain on and immediately adjacent to the
site. Portions of the leachate colJection system will be located
within the 100-year floodplain in order to collect contaminated
leachate and store it for treatment and disposal. The collection
and storage tanks for leachate must be located within the 100-
year floodplain in order to allow the collected contaminated
leachate to flow into the tanks, via gravity for storage. There
is no other practicable alternative to this construction. The
Selected Remedy does not include any remedial activities in the
adjacent wetlands. All on-site construction activities will be
performed to minimize any potential impacts to the adjacent
wetlands.
3.
Action - soecific Reauirements
EPA has determined that RCRA Subtitle C is not an applicable
requirement because RCRA listed or characteristic hazardous waste
has not been disposed of at the Landfill nor has any treatment,
or storage of hazardous waste occurred at the Landfill since the
effective date of RCRA Subtitle C.
Portions of RCRA Subtitle C are relevant and appropriate based on
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current site specific information including: Groundwater
Monitoring, Tanks, contingency Plans and Emergency Procedures,
Locational Standards and RCRA Post Closure Requirements.
contingency Plans and Emergency Procedures, Manifesting and
Record Keeping, Tanks, Tank Closure and Locational Standards may
be applicable to leachate collection and disposal depending on
the results of leachate testing. The leachate will be tested to
determine if any of the RCRA requirements, including land ban are
applicable. The offsite leachate treatment and disposal must
meet all Federal and State requirements. References to these
provisions in Appendix D are to the State hazardous waste
regulations that have been approved by EPA pursuant to RCRA.
,)
C.
The selected Remedial Action is cost-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 ARARs, EPA
evaluated the overall effectiveness of each alternative by
assessing the relevant three criteria--long 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 deter ...ed to be proportional to its costs. The
costs of this remedia~-alternative are:
Alternative Capital O'M Total Present
Costs Costs Worth
Alternative 1 0 0 0
Alternative 2 $ 1,330,021 901,590 $ 2,231,611
Alternative 3 $ 1,648,729 3,541,426 $ 5,190,155
Alternative 3A $ 8,841,772 4,310,090 $ 13,151,862
Alternative 4 $ 2,095,753 3,541,426 $ 5,637,179
Alternative 4A $ 9,257,206 4,310,090 $ 13,567,296
Alternative 5 $12,798,759 901,590 $ 13,798,759
Alternative SA $19,991,802 4,310,090 $ 24,301,892
Selected
Remedy $ 9,012,098 3,541,426 $ 12,553,524
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-0
Of the alternatives evaluated, both the Selected Remedy and
Alternative 4 are considered to be cost effective with the
Selected Remedy the most cost effective. The Selected Remedy
provides benefits similar to Alternative 4, but greatly magnifies
these benefits by extending the area of the Landfill cap
reconstruction over the whole Landfill surface thereby providing
a significantly more effective remedy. As a result, the Selected
Remedy is the most cost effective in that its costs are most
proportionate to the overall protection provided. Alternative 4
provides for a more stable, less permeable cap than currently
exists, but only addresses 16 of the 60 total acres of Landfill
'surface, thereby providing significantly less overall
effectiveness than the Selected Remedy. The Selected Remedy
increases the stability of the cap provided in Alternative 4
particularly by addressing the stability and permanence of the
side-slopes, greatly reducing the potential for infiltration of
water, and reducing maintenance requirements.
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 ARARs and that are protective of human health
and the environment, EPA identified which alternative utilizes
permanent solutions and altern' ..ve treatment technologies or
resource recovery technologies' co 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. In accordance with the NCP, the balancing test
emnhasized long-term effectiveness and permanence and the
reduction of toxicity, mobility and volume 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.
Alternatives 1, 2, 5, and 5A will not meet ARARs. In addition,
Alternatives 1 and 2 are not protective of human health and the
environment. Of the Alternatives remaining that meet ARARs and
are protective, the Selected Remedy was chosen because its long-
term effectiveness, permanence and ability to reduce toxicity,
mobility, and volume of contaminants through treatment was most
efficient with respect to implementability, short-term
effectiveness and residual risk concerns. Because of the limited
extent of the cap reconstruction, Alternatives 4 and 4A do not
provide the same level of long-term effectiveness and permanence
as the Selected Remedy. Alternatives 4 and 4A reduce toxicity,
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~
mObility and volume through treatment, with 4A providing a
greater level of reduction with the addition of a groundwater
extraction and treatment system. However, this increase in
treatment is accompanied by a significant increase in cost.
Alternatives J and JA each provide significantly less long-term
effectiveness and permanence than the Selected Remedy, although
Alternatives J and JA do reduce toxicity, mobility and volume
through treatment.
E. The Selected Remedy satisfies the. Preference for Treatment
Which Permanently and significantly reduces the toxicity,
Mobility or Volume of the Hazardous substances as a principal
Element
A principal element of the Selected Remedy is the collection and
treatment and disposal of leachate. This element addresses
partially the primary threat at the Site, contamination of
groundwater. The Selected Remedy satisfies the statutory
preference for treatment as a principal element by collecting,
treating, and disposing of leachate.
XII. DOCUMENTATION OF SIGNIFICANT CHANGES
EPA presented a Supplement to the Proposed Plan for
remediation of the Landfill on May 16, l' There are no
significant changes from the Supplement ~~ the Proposed Plan
contained within this Record of Decision. It should be noted
that some discrepancies in analysis exist between documents that
comprise the Administrative Record, but that this Record of
Decision represents EPA's final position with regard to these
discrepancies. This position was reached after carefully
reviewing and considering all information presented to EPA. Any
discrepancies noted would not effect EPA's decision on the
remedy.
XIII. STATE ROLE
The Commonwealth of Massachusetts, Department of Environmental
Protection has reviewed the various alternatives and has
indicated its support for the Selected Remedy. Massachusetts has
also reviewed the Remedial Investigations, Endang~nt
Assessment and Feasibility Study to determine if the selected
remedy is in compliance with applicable or re~evant and
appropriate State Environmental laws and regulations. The
Commonwealth of Massachusetts concurs with the selected remedy
for the Shaffer Landfill, Iron Horse Park Site. A copy of the
declaration of concurrence is attached as Appendix F.
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o
APPENDIX A
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J'-~":.,.z...
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NORTH
lIon
nl
:
..
FIGURE 1
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FIGURE
IRON HORSE PARK AND
SHAFFER LANDFILL SITE
2.
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CONTAMINANTS OF CONCERN
INORGANICS
Arsenic
Barium
Lead
ORGANICS
Benzene
1,2 Dichloroethane
Methylene Chloride
1,1,2 Trichloroethane
Trichloroethylene
vinyl Chloride
1,4 Dichlorobenzene
1,2 Dichloroethene
Ethylbenzene
Toluene
Xylene
4,4' DDE
3,3' Dichlorobenzidene
PAH
Acetone
Benzoic Acid
2-Butanone
Pentachlorophenol
Di-n-octyl Phthalate
Di-n-butyl Phthalate
Butyl Benzyl Phthalate
Diethyl Phthalate
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<.-
TABLE A
CARCINOGENIC RISK FOR THE POTENTIAL FUTURE
INGESTION OF GROUND WATER AT THE LANDFILL PERIMETER
REASONABLE MAXIMUM EXPOSURE
Contamin-
ant of
Concern
Maximum
Concentration
(ug/l)
Cancer
Potency
(mg/kg/d)-l
Exposure
Factor
(l/kg/d) Risk Estimate
--------------------------------------------------------------
Arsenic 2.58E+02 1. 75E+00 2.90E-02 1.31E-02
Benzene 9.10E+01 2.90E-02 2.90E-02 7.65E-05
.1,2 dichlor- 5.50E+01 9.10E-02 2.90E-02 1.45E-04
oethane
Methylene chlor- 5.00E+02 7.50E-03 2.90E-02 1.09E-04
ide
1,1,2 trichlor- 1. 60E+Ol 5.70E-02 2.90E-02 2.64E-05
ethane
Trichlor- 6.10E+00 1.10E-02 2.90E-02 1.95E-06
oethylene
Vinyl 1. 30E+02 2.30E+00 2.90E-02 8.67E-03
chloride
TOTAL 2.2E-02
NOTE: Risk estimates are based on concentrations from one well
and on cancer potency factors available in 1989.
Exposure Factor = 2 liters/day/70 kg body weight = .029 liters/kg/day
Risk Estimate = Concentration * Cancer Potency Factor * Exposure Factor
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TABLE B
NON-CARCINOGENIC RISKS FOR THE POTENTIAL
FUTURE INGESTION OF GROUND ~ATER AT THE LANDFILL PERIMETER
REASONABLE MAXIMUM EXPOSURE
Contemin-
ant of
Concern
Maximum Reference
Concentration Dose(RfD)
(ug/l) (mg/kg/d)
Exposure
Factor Hazard
(l/kg/d) Index
Target
Endpoint
of
Toxicity
...---------------------------------------------------------------------
Arsenic 2.58E+02 2.86E-03 2.90E-02 2.62E+OO keratosis
Bariun 1. 20E+03 5.70E-02 2.90E-02 6.11E-01 fetotoxicity/
incr. blood pressure
Benzene 9. 10E+01 7.00E-04 2.90E-02 3.77E+00 fetotoxicity
1,4 dichlo- 4.90E+01 1.0DE-01 2.90E-02 1.42E-02 liver/kidney toxicity
obenzene
1,2 dichlor- 5.50E+01 7.43E-03 2.90E-02 2.15E-01 liver/kidney effects
oethane
1.: 1ichlor- 1.20E+02 1.00E-02 2.90E-02 3.48E-01 decreased hematocrit
~thene and hemoglobl in
Ethylbenzene 3.50E+02 1. OOE -01 2.90E-02 1.02E-01 liver and kidney toxicity
Methylene 5.00E+02 6.00E-02 2.90E-02 2.42E-01 liver toxicity
chloride
Toluene 8.40E+02 3.00E-01 2.90E-02 8.12E-02 Central nervous
system; respiratory irritant
1,1,2 Trichlor- 1.60E+01 2.00E-01 2.90E-02 2.32E-03 clinic~l chemistry alteration
oethane
Trichlor- 6.10E+00 7.35E-03 2.90E-02 2.41E-02 liver/kidney effects
oethylene
Vinyl chloride 1.30E+02 1.30E-03 2.90E-02 2. 90E+00 li ver
Xylene 1.50E+03 2.00E+00 2.90E-02 2.18E-02 decreased body weight
Hazard Indices for Similar Toxic Effects:
Keratosis 2.62E+OO
Fetotoxicity 4.38E+OO
Liver/Kidney Effect 5.96E-01
Hematocrit/hemoglobin change 3.48E-01
Exposure Factor = 2 liters/day/70 kg body weight = .029 liters/kg/day
Hazard Index = (Concentration * Exposure Factor)/RfD
NOTE: Risk estimates are based on concentrations from one
well and on toxicity infonnation available in 1989.
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o
G
TABLE C
CARCINOGENIC RISKS FOR THE POTENTIAL FUTURE
INGESTION OF DOWNGRADIENT GROUND WATER
AVERAGE AND REASONABLE MAXIMUM EXPOSURE
Concern AVG MAX (RIg/leg/d)-1 (l/leg/d) AVG RME*
Bis(2-ethyl 0.60 0.60 1.40E-02 2.90E-02 2.4E-07 2.4E-07
hexyl)phthalate
Pentachloro- 29.00 110.00 1.20E-01 2.90E-02 1.0E-04 3.8E-04
phenol
Trichloro- 1.00 2.00 1.10E-02 2.90E-02 3.2E-07 6.4E-07
ethylene
1,1,2 trichlor- 2.60 3.00 5.70E-02 2.90E-02 4.3E-06 5.0E-06
oethane
TOTAL 1.06E-04 3.89E-04
*Reasonable Maximum Exposure
Exposure Factor = 2 liters/day/70 leg body weight
Risle Estimate = Concentration * Exposure Factor * Cancer Potency Factor
.
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~;:,.
TABLE D
NON-CARCINOGENIC RISKS FR~ POTENTIAL FUTURE
INGESTION OF DOWNGRADIENT GROUND WATER
AVERAGE AND REASONABLE MAXIMUM EXPOSURES
Contamin-
ant of
Concern
Exposure Reference
Concentration Factor Dose(RfD)
AVG MAX (l/kg/d) (mg/kg/day)
Hazard Index
AVG RME*
Target
Endpoint
of
Toxicity
------..-.....--.-..-.-.------.-....-.------------------------------------------------------------------------
Bariun 27.00 198.00 2.90E-02 5.70E-02 1.37E-02 1.01E-01 fetotoxicity/
Bis(2 ethylhexyl) 0.60 0.60 2.90E-02 2.00E-02 8.70E-04 8.70E-04 incr. blood pressure
phthalate system; respiratory irritant
Pentachlor- 29.00 110.00 2.90E-02 3.00E-02 2.80E-02 1.06E-01 fetotoxicity
ophenol
1,1,2 Trichlor- 2.60 3.00 2.90E-02 2.00E-01 3.77E-04 4.35E-04 clinical chemistry alteration
oethane
Trichlor- 1.00 2.00 2.90E-02 7.35E-03 3.95E-03 7.89E-03 liver/kidney effects
oethylene
Hazar~ Indices for similar toxic effects:
Fetotoxicity
Liver/kidney
Blood
Clinical chemistry
AVG
4.18E-02
3.95E-03
8.70E-04
3.70E-04
MAX
2.07E-01
7.89E-03
8.70E-04
4.35E-04
* Reasonable Maximun Exposure
Exposure Factor = 2 liters/day/ 70 kg body weight
Hazard Index = (Exposure Factor * Concentration) / RfO
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....;
\.
TABLE E
CARCINOGENIC RISKS FOR POTENTIAL PRESENT AND FUTURE
CONTACT WITH SEDIMENTS
AVERAGE AND REASONABLE MAXIMUM EXPOSURES
Contanli n- Concentration Cancer Exposure
ant of (mg/kg) Potency Factor Risk Estimate
Concern AVG MAX (mg/klil/d)-1 (mg/kg/day) AVG RME*
------------------------------------------------------------------------------------------
Arsenic 2.10E+01 8.20E+01 1 .75E+OO 1.26E-07 4.62E-06 1.80E-OS
Benzene 3.00E-03 1.40E+02 2.90E-02 1.60E-07 1.39E-11 6.49E-07
Bis(2ethyl hexyl) 1.11E+00 S.10E+00 6.80E-0I, 1.60E-07 1.21E-10 S.S4E-10
phthalate
4,4' DOE 1.1DE-02 6.70E'D2 3.40E-01 1.60E-07 S.97E-10 3.64E-09
3,3'-Dichloro- 9.80E-02 9.80E-02 1 .70E+00 1.60E-07 2.66E-08 2.66E-08
benz i dene
PAH(carcinogenic) 8.75E-01 1.23E+00 6.1n 1.60E-07 8.S3E-07 1.20E-06
TOTAL: S.SOE-06 1. 99E-OS
Health risks from exposure to contaminated sediment are based on the following assumptions:
Exposed Population: Children aged 6
Exposure Frequency: 122 days/year
Exposure Duration: 10 years
Body Weight: 38 kg
Ingestion Rete:100 mg/day
Dermal Contact Rate: 1.S mg/cm2
Absorption Factors
Derma I :
Organic Compounds: 0.02
Inorganic Compounds: 0.0
Ingestion: 1.0 (all compounds)
- 1S years
* Reasonable Maximum Exposure
Exposure Factor = «SIR + DIR) * F * 0)/ (BW * AT* 36S)
Where: SIR = soil ingestion rate * absorption
DIR = dermal contact rate * absorption
F = frequency
o . duration
BW = body weight
AT = averaging time = 70 years
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TABLE F
NONCARCINOGENIC RISK FOR THE POTENTIAL PRESENT
AND FUTURE EXPOSURE TO SEDIMENT
AVERAGE AND REASONABLE MAXIMUM EXPOSURES
Contllll1inant
of Concern
concentration
(ug/kg)
AVG MAX
Reference
Dose(RfD)
(RIg/kg/d)
Exposure
Factor
(RIg/kg/d)
Huard Index
AVG RME*
Toxic
Effect
----------------
-----------------------------------------------------------------------------
Acetone 7.10E+01 2.80E+02 1.00E-01 1.60E-07 1.13E-07 4.47E-07 Liver/kidney
Benzoic Acid 9.00E+02 1.50E+03 6.00E-02 1.60E-07 2.40E-06 3.99E-06 I rri tat i on
Bis(2 ethylhexyl) 1.11E+03 5.10E+03 2.00E-02 1.60E-07 8.87E-06 4.07E-05 Liver
phthalate
2-Butanone 1.50E+01 7.50E+01 5.00E-02 1.60E-07 4.79E-08 2.40E-07 CNS*/Fetotoxicity
Butyl benzyl 8.30E+01 1.40E+02 2.00E-02 1.60E-07 6.63E-07 1.12E-06 Body wgt
phthalate
4,1,' DDE 1.10E+01 6.70E+01 5.00E-04 1.60E-07 3.51E-06 2.14E-05 Liver
3,3'-Dichoro. 9.80E+01 9.80E+01 8.00E-04 1.60E-07 1.96E-05 1.96E-05 Blood
benzidene
Oiethyl phthalate 1.00E+02 1.00E+02 1.30E+00 1.60E-07 1.23E-08 . 23E-08 Body wgt.
Oi-n-butyl 1.32E+03 9.40E+03 2.00E-02 1.60E-07 1.05E-0 '.51E-05 Liver
phthalate
Oi -n-octyl 5.6OE+01 5.60E+01 2.00E-02 1.60E-07 I,.47E-07 4.47E-07 Liver
phthalate
PAH(total) 8.81E+02 2.26E+03 I,.00E-02 1.60E-07 3.52E.06 9.03E-06 Eye/lung
Xylene 1.10E+01 1. 10E+03 4.I,OE-01 1.60E-07 3.99E-09 3.99E-07 CNS/intesti~e
Hazard Indices for Similar toxic effects:
Liver
CNS
Eye/lung
Blood
Other
AVG
2.35E-05
5.19E-08
3.52E-06
1.96E-05
3.07E-06
MAX
1.38E.04
6.39E-07
9.03E-06
1.96E-05
5.12E-06
Blood lead levels for lead were estimated to be 6.4 ug/Ol
Exposure Factor = «SIR + OIR) * F * 0)/ (BW * AT* 365)
Where: SIR = soil ingestion rate * absorption
OIR . dermal contact rate * absorption
F . frequency
o = duration
BW 8 body weight
AT = averaging time = 70 years
Hazard Index = (concentration * Exposure Factor)/RfO
* Reasonable Maximum Exposure
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"V
APPENDIX C
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D
CXIIPAIIISIB CW SOUIICB CDmIDL AI.'I'EIIM!'IVE
Cdteda
SC-l
80 JIcU-
SC-Z
Luldfill Cap Co8pletiClll,/
Jlepair
SC-]
Luldfill Cap OIIIIIletiClll,/'
Jlapah with Leachate Collecti-
SC-lA
LaDdfill Cap Co8pleUCIII,/
llepab with Leachate
CDllec:ti- and GrDlDMNater
Eatracti- and 'rr_t8BDt
1. Sbort-teOi Effecti veuess ...
o Protaction of co..unity No ri.k., sinca no ramedial Convantional construction Convantional construction Convantional construction
during ra..dial action. action. tachniquas ara not axpectad to tachniquas ara not expected to techniqua. ara not axpected to
produca advara. affacta. produca advarse affact.. produce advar.a affact..
Additional truck traffic will Additional aini..l truck Additional aini..l truck
be requirad. traffic will be requirad. traffic will ba requirad.
Enginaaring pracaution. to Enginaering pracautions to
raduca risk to coaaunity reduce risk to comaunity
during installation of during installation of
leachata collection toa laachata collaction toa drains
drain.. and groundwater axtraction
tranche..
0 Potantial iapact. to No risks, .inca no remedial Convantional construction Convantional construction Convantional construction
workar. during ra..dial action. tachniques ara not axpected to techniquas ara not expected to techniqua. ara not axpectad to
action., and tha produca advar.a affacts. produca advarsa affect., produca advar.a affact.,
affactivanass and howavar, additional howevar, additional
raliability of pracautions ara requirad for pracaution. ara requirad for
protactiva measuras tha installation of tha tha installation of tha
laachata collection toa leachata collaction toa drain.
drain.. Thesa pracautions ara and groundwatar axtraction
considarad raliabla and trancha.. 'rha.a precaution.
affactiva. ara considarad raliabla and
affactiva.
0 Environmental iapact. No illlp4ch sinca no re..dial Additional aro.ion control Additional arosion control Additional arosion control
and affactivaness and action. ..asuras will be requirad to ..a sura. will ba requirad to ..asuras will be requirad to
raliability of aitigata iapact. to wetlands aitigate impact. to watlands aitigata iapacts to wetlands
aitigative ..asuras and .urfaca watars during cap and surfaca watars during and aurfaca watars during
reconstruction and repair. construction of laachata construction of leachate
'rhesa ..asuraa ara considerad collaction toa drains and cap. collaction toa drains and cap.
raliabla and affective. 'rhese ..asures ara considered 'rhasa ..asuras ara considerad
reliabla and affactiva. reliabla and affactiva.
o Ti.. until protaction No action doas not achiava the 6 aonths for imple88ntation. I year for imple..ntation. 2 yaars for impla..ntation.
achiaved. ra..dial rasponse objectives. Protection will not be Protaction will be achiaved in Protection will be achievad in
-------
edteria
SC-l
80 acti-
CDlPAllISt8 or SOUIIa CDDIIOL AL'rBRIIIATIVES
SC-1
LaDdfill Cap ~leUoo,I
l18pai ~
SC-1
LaDdfill Cap CoII(»leUoo,I
l18pai~ with LIIacbate Collec:ti-
SC-1A
LaDdfill Cap CoII(»leUoo,I
aepah with LIIacbate
Collec:ti- aDd G~OUDCIMate~
kt~acUOD aDd T~..t:8eDt
1.
~aE8 Sffec:tiveoes.
aDd l'eE88D8IICe
o ltagnitude of ~e..ining
~..idual ~hk
o Adequacy and
~aliabi1ity of
controls
:J
'j
If anticipated adverse effects
reduce the cap's
affectiveness, then on-going
leachate gene~ation vill
continue to degrade vater
quality. Residual risk ve~
hi
-------
:;
.I.}
criteria
CDlPAIWDI or SCUIC8 CDIIROL AI.'rEIIII1.ftV
SC-I
80 Actioa
SC-z
L8Ddfill Cap OI8pleti-.l
llepah
SC-3
L8Ddfill Cap OI8pleti-.t
liepaii' with r.ac::llate Collectioa
SC-)A
L8DdfUI Cap CoIIpleti-.l
liepaii' with r.ac::llate
Collec:tioa aDd GrOUDCMter
btrac:tioa aDd orr..,=-t
...
3. Jl8cb:tioa of Todcity,
lIobility, or Vol-
o Traat..nt or recycling
proce..e. and remedy
o A80unt of hazardous
..terial de.troyed,
treated or recycled
. 0 Degree of expected
reduction in toxicity
80bility or voluae
o
Irrever.ibility of the
treat..nt
o Type and quantity of
re..ining treat..nt
residuals
o Degree to which
treat..nt reduces
inherent hazards posed
by principal threats
No treat88nt, except for
flaring landfill gas
None by treat..nt, however
natural .tabilization and
attenuation take. place.
Doe. not reduce IIObility,
toxicity or voluae through
treat_nt.
No treat..nt
No treat..nt
No treat..nt of hazards that
pose principal threats.
No treat..nt, except for
flaring landfill gas
None by treat..nt, however
natural .tabili.ation and
attenuation take. place.
Doe. not reduce IIObility,
toxicity or vol- through
treat..nt.
No tnatHnt
No treat.ent
No treat..nt of hazards that
po.e principal threats.
Off.ite treat..nt and disposal
of collected leachate, and
flaring of landfill gas.
Esti..ted .600 gpd of
leachate. rinal vol-
deter8ined during de.ign.
Reduction of toxicity and,/or
vol- i. depandent on t~ of
treat..nt which is depandent
on leachate c08pO.ition.
Vol- is e.ti..ted to be .600
GPO of leachate.
Irreversible
No re.iduals-offsite
treat.ent.
Treat..nt of leachate
eli.inates principal threat.
Oosite treat..nt of collected
leachate and extracted
groundwater, and flaring of
landfill g8&.
Esti..ted .600 gpd of leachate
and 158,.00 gpd of
groundwater. Final volU88
dater8ined during de.ign.
Reduction of toxicity and,/or
voluae ia depandent on type of
treat..nt which depandent on
leachate and groundwater
c08pOsition. Vol- i.
e.ti..ted to be 4600 gpd of
leachate and 158,400 gpd of
groundwater.
Irreversible
Sludge fro. groundwater
treat..nt to be dispo.ed of
oftsite.
Treat88nt of leachate and
groundwater ali.inatas
-------
edt.da
SC-l
110 Acti-
CDG'JIIIXSIII CW SOIIIICK CX8IBJL ~
sc-z
taDdfUl Cap CoIIItleUCD,/
Jl8pah
SC-J
LaDdfill Cap ~l.tiCD,/
Jl8pab with Laadlat. c::ollacti-
SC-JA
taDdfUl Cap ~leUCD,/
Jl8p8ic with ...adlat.
c::ollac:ti- aDd GcOUDChlatec
btcacti- aDd Tcaat8ent
--
4.
I8pl_tability
A.
Technical feasibility
o Ability to construct
and operate technology
.0 aeliability ot
technology
o Saae ot undertaking
additional re..dial
action
o Monitoring
eftectiveness
o
"
No technology.
No technology.
Dependent upon the
deterioration that takes place
betore additional actions are
undertaken.
No 8Onitoring theretore not
ettective.
rence construction, landtill
repair, and regrading are
easily iaple..nt.d.
aeliable with proper
_intenance.
Cap design should not
intertere with any tuture
re..dial action. Future cap
repair should be a shpl.
operation.
Monitoring involv.s periodic
visual inspection ot the cap,
saapling surtac. and
groundwater do_gcadient ot
the landtill, and 8Onitoring
the gas collection/tlare
syste.. This should be
adequate to 8Onitor
ettectiveness.
rence construction, surtace
drainage improve..nts,
landtill repair, and regrading
are easily iaple..nted.
construction ot leachate
collection syste. can be
easily implemented with
additional health and satety
..:ontrols .
aeliable with proper operation
and _intenance.
Cap design should not
intertere with any tuture
re..dial action. rutur. cap
repeir should be a simple
operation.
Monitoring involves periodic
visual inspection ot the cap,
sa8Pling surtace and
groundwater do_gradient ot
the landtill, and 8Onitoring
the gas collection/tlare
syste.. This should be
adequate to 8Onitor
etfectiveness.
rence construction, surtace
drainage improvements,
landtill repair, and regrading
are easily iaple..nted.
Construction ot leachate
collection syste. can be
easily iaple..nted with
additional health and satety
controls. Additional study is
needed betore iaple..ntation
ot the groundwater extraction
syste.. pilot testing is
needed tor design ot the
groundwater treat..nt system.
aeliable with proper operation
and ..intenance.
Cap design should not
intertere with any tutur.
re..dial action. Future cap
repair should be a siaple
operation.
Monitoring involves periodic
visual inspection ot the cap,
saapling surtace and
groundwater do-gradient ot
the landtill, and 8Onitoring
the gas collection/tlare
syste.. This should be
adequate to 8Onitor
-------
-
eriteda
CDlPARISaI OF SCIUIICK CXIIftIDL ALTEBIIArIVBS
SC-l
80 Actioo
SC-z
~ill Cap CoIIpleUOD,/
Jl.epair
SC-)
taDdfill Cap CoIIpleUOD,/
Repair vith Leachate CollactiCID
SC-1A
LaDdfill Cap CoIIpleUOD,/
Repair with Leachate
Collactioo aDd GromMtvater
Klttractioo 8Dd Treat8eDt
4.
I8pl888Dtability (Cont'd)
B.
Adainstrative reasibility
o Coordination with other
agencies
o Ability and ti.. to
obtain approvals and
puaita
C.
Availability of services
and utedals
o Availability of
adequate off-site
treataent, storage
capacity, and disposal
capacity and services
o Availability of equip-
aent and specialists
prospective technolo-
gies, provisions to
ensure additional
resources.
o Availability of
services and ..terials
No coordination.
Coordination with u.s.r. ,
N.S. and 0.0.1. required.
Not required.
Not required.
None required. .
None required.
None required.
Equip..nt readily available.
None required.
services and ..terials are
readily available.
Coordination with u.s.r. ,
N.S. and 0.0.1. required.
Nut required.
Disposal of leachate can be
contracted with a nuaber of
qualified co...rcial
operators.
Equipaent readily available.
services and ..terials are
readily available.
.
Coordination with u.s.r. ,
N.S. and 0.0.1. required.
Not required.
Leachate and sludge disposal
can be contracted with a
nuaber of qualified commercial
operaton.
Equipaent readily available.
Groundwater extraction
treataent systea will be built
to specification after s pilot
study.
Services and ..terials are
-------
criteda
CDlPAUSt8 CW SDUIICK CDftROL AI.IrERIIATIVES
SC-l
80 Acti-
SC-2
l.aDclfi11 Cap ~htiOD,/
I18pab
SC-]
Laadfi11 Cap Ccl8pletiOD,/
l18pair vitia r-daate Co11ec:ti-
SC-3A
l.8Ddfi11 Cap Ccl8pleUOD,/
I18pab vitia LNdaate
Co11ec:ti- aDd GrOUDdlater
btracti- aDd Tr..~t
..
5. £!!!
o Capital cost
o Operation and
Maintenance Cost -
present worth
o Total
6.
eo.p1i8DC8 vitia AllAR'.
o Che.ical specific
AllAR's
o Location specific
AllAR' .
o Action-.pecific AllAR's
o C08pliance with
critaria, advisories
and guidances
?
No costs.
Continuing violation of HCLa
and Massachusetts Groundwater
Quality Stda. will result fro.
leachate conta.inating surface
and groundwaters.
Not applicable.
Not applicable.
Alternative will not meet
proposed HCLa and KCLGs~
$1,]30,021
$901,590
$2,231,611
Continuing violation of MCL5
and Massachusetts Groundwater
Quality Stda. will result fro.
leachate conta.inating surface
and groundwaters.
Alternative ..et. all location
specific AJIARa.
Alternativa will comply with
all pertinent regulations.
Alternative will not ..et
proposed HCLa and KCLGs.
$1,648,729
$3,541,426
$5,190,155
Kill be met after a very long
ti.. period. Future violation
of HCL's and Massachusetts
Groundwater Quality stda. is
unlikely with leachate
collection, and natural
attenuation of surface and
groundwatera .
Alternative ..et. a11 location
specific AllARs.
Alternative will c08ply with
all pertinent regulations.
Alternative will ..et proposed
HCLa and MCLGs after a very
long ti.. period.
$8,841,772
$4,310,090
$13,151,862
will be ..t after a relatively
long ti.. period. Future
violation of HCL's and
Massachusetts Groundwater
Quality Stda. is unlikely with
leachate and groundwater
collac:tion and treat..nt.
Alternative ..ets all location
apecU ic AJIARa.
Alternative will c08ply with
all pertinent regulations.
Alternative will .eat proposed
HCLa and MCLGs after a
-------
b
Cdteda
SC-l
110 ktiCID
CDG'ABIStB CW SOOIIa CDmIDL AUEIIIIA1'IVES
SC-2
taDdfill Cap ~letiClll,/
llepail"
SC-J
LaDdfill cap ~1.tiGD,/
l18pail" with Leac:bata CollecUCID
SC-3A
LaDdfi11 cap ~letiClll,/
llepail" with Laac:bat.
CollactiCID aDd GI"OUDdIIatel"
Ibtl"ac:tiCID aDd TI"..t:8eDt
..
1. 01/81"811 pl"otactioD of
a- ...alth aDd
EDvil"_t
o Risks are eliminated,
reduced or controlled
50.. liaited protection .ince
landfill containaent
eliainete. contact witb
refuse, and reduce. so..
leachate generation. No
overall protection regarding
leachate and groundwater.
Operation and ..intanance
provides a .ustained level of
protection over Alternative 1.
Landfill cODtainaent
eliminates contact with
refuse, and reduce. .0..
leachate generation.
Potential phy.ical ba.ard to
trespasser., and potential
erosion of wetlands i.
mitigated by a .ecurity fence.
Landfill gas collection/flare
sy.tem controls release of
airborne contaminants.
Groundwater aonitoring warns
of offsite migration. No
overall protection regard1ng
leachate and groundwater.
A leachate collection syst..
provides a greater degre. of
protection over Alternativ. Z
as leachate generation will be
further reduced. Offsite
transport of leachate pl"oduce.
a .inor risk of contaainant
release which can be
controlled by coapliance with
D.O.1'. regulations. Landfill
containaent eli.inate. contact
with refuse, and reduce a 8088
leachate generation.
Potential physical ha.ard to
trespassers, and potential
erosion of wetlands is
mitigated by a security fence.
Landfill gas cOllection/flare
syst.m controls release of
airborne contaminants.
Groundwater aonitoring warns
of offsite migration.
A GETS capture. and treat. the
contaainanta that reach
groundwater and treat. those
collected by the l.achate
collection .yste. providing
increa..d protection over
Alternatives I, 2 and J.
Compliance with NPDES
require..nts protects .urface
water quality. Landfill
containaent eliminate. contact
with refu.e, and reduces
.0.. leachate generation.
Potential physical ha.ard to
tre.pa..er., and potential
erosion of wetlands is
mitigated by a security fence.
Landfill gas collection/flare
.ystem controls release of
airborn. conta.inants.
Groundwater aonitoring warns
-------
cdteria
sc-t
Partial II8ccmIItncU-
of LaDdtill Cap witb
"acbate Collecti-
CDlPAUStB CW SOUBCB a:wrIK)L AI.TEIIIIM"IVE
sc-u.
Partial II8ccmIItnacti-
of I.-dfill Cap witb
r-daate Collecti- aDd
GrClUDllllater btracti-
rreat881t
SC-5
'!'otal Jl8c:aaatnacti- of
L8Ddfill Cap
SC-5A
Total Jl8ccmatructi- of
LaDdfill Cap witb
Grouadllater btnlcU-
aDd rr..~t
Selected --.dy
LaDdfill cap Jl8ccmatructi-
witb "'c:bate Collecti-
1.
Sbort-tem Bffecti_a
o Protection of
co~ity during
re..dial actions
o Potential iapact.
to workers during
re..dial actions,
and the
effectiveness and
reUability of
protctive ..asures
o EnviroR818ntal
i8lp8cta and
effectiveness and
reUability of
aitigatin
..ssures
')
'.)
Con.truction activities
pose aini..l public
health risks. Additional
truck traffic ..y
aini..lly iapact the
c088URity. Engineering
precautions to reduce
risk to co..unity during
construction of leschate
collection toe drain.
conventional construction
techniques are not
expected to produce
adverse effects. however.
additional precautions
are required for the
installation of the
leachate collection loe
drains. '!'tIese
precautions are
considered reliable end
effective.
Construction activiti'ls
will reduce the
effectivenass of the
existing cap during
iaple..ntation which
could have a negative
iapact on adjacent
wetlands and water
bodies absent aitigative
..asures. Erosion
controls are required to
..intain the existing
soil layer covering the
refuse and should be
reliable and effective.
Construction activities
pose aini..l public
hesltb risks. Additional
truck traffic ..y
aini..lly i8lp8c:t the
co~ity. Engineering
precautions to reduce
risk to coaaunity during
construction of leachate
collection toe drains and
groundwater extraction
trenches.
Conventional construction
techniques are not
expected to produce
adverse effects. however. .
addi tional precautions'
are required for the
installation of the
leachate collection toe
drains and groundwater
extraction trenches.
These precautions are
considered reliable and
effective.
Construction activities
will reduce the
effectiveness of the
existing cap during
iapleaantation which
could have a negative
i8lp8ct on adjacent
wetlands and water
bodies absent aitigative
..asure.. Erosion
controls are required to
..intain the existing
soil layer covering the
refuse and should be
reliable and effective.
Construction activities
pose aini..l public
health risks.
Significant truck traffic
will be associated with
this alternative.
Conventional construction
techniques are not
expected to produce
adverse effects.
Construction of 3:1
slopes requires
aignificant wetlands to
be filled and covered.
Strict erosion control
..ssures are required to
.itigate iapacts to
:eUands and surface
~ater bodies but will
still result in
significant adverse
impact on wetlands.
Construction activities
pose aini..l public
health risks.
Significant truck traffic
will be associated with
this alternative.
conventional construction
techniques are not
expected to produce
advers. effects. bowever.
additional precautions
ar. required for the
installation of the
groundwater extraction
trenches.
Construction of 3:1
slopes requires
significant ,wetlands to
be filled and covered.
Strict erosion control
aeasures are required to
aitigate iapacts to
wetlands and surface
water bodies but will
still result in
significant adverse
impact on weUands.
Construction activities
pose aini..l public
health risks.
Significant truck traffic
will be associated with
this re..dy. Engineering
precautions to reduce
risk to coaaunity during
construction of leachate
collection to. drain.
...
Conventional construction
techniques are not
expected to produce
adverse effects. however.
additional precautions
sre required for the
installation of the
leachate collection toe
drains. These
precautions are
considered reliable and
effective.
Construction activities
will reduce the
effectiveness of the
existing cap during
imple..ntation which
could have a negative
impact on adjacent
wetlands and water
bodies absent aitigative
..asures. Erosion
controls are required to
..intain the existing
soil layer covering the
refuse and should be
-------
eriteda
SC-l
Partial I18amatlUCti,a
of taDdfill Cap with
Laac:bate eollacti-
CDlPAIIUCII OF SOUIICK C1IIIIIOL ~
SC-IA
Partial ---tEUCti-
of taDdfill Cap with
Laac:bate eollacti- aDd
G~OUDdMate~ ..t~acti-
Tr_t8eDt
SC-5
'I'obl ---tEUCti- of
taDdfill Cap
sc-SA
'I'otal bc:cmatEUCtian of
taDdfill Cap with
G~OUDdMate~ bt;~acti-
ADd T~_~t
Salactacl a-dy
LaDdfill Cap I18amatnacti-
with Leac:bate eollacti-
o '1'i.. until
protection
achieved
2.
1 yea~ fo~
iaple..ntation. '1'i..
until protection il
achieved is less than
Alte~natives 1,2, and 3.
LoacJ-tem Effectiv_s.
ADd Par88DeDCe
o Hagnitude of
~e..ining ~esidual
risk
o Adequacy and
reliability of
cont~o18
Iap~ove..nt of the cap's
effectiveness viii
fu~ther ~educe leachate
gene~ation and .t~ength
and vith leachate
collection g~oundwater
9Uality is expected to
iap~ove. Residual ~isk
is less than Alternatives
1 and 2.
Modifications to the cap
should ~educe leachate
generation, increase the
reliability and decrea.e
..intenance ~equi~e88nts.
The iaproved surface
drainage Iyste.,
vegetative cover, and
site periaeter security
fence viii 81ni.ize
erosion. Because of
these iaprove..nt., this
Alternative is ao~e
reUable than
Alternatives 1,2,3 and
3A. A leachate
collection syste.
p~ovidel adequate control
of the li.ited leachate
generated. Active
Groundwate~ re..diation
has not been included.
2 years for iapleaenta-
tion. '1'i.. until
protection i. achieved is
leIs than Alternatives
1,2,3, 3A and t.
Iaprove..nt of the cap'.
effectiveness viii
further ~educe leachate
generation and st~ength.
Leachate collection and
groundwater t~eataent
syste.. viii 81tigate
leachate i8p8cts to
surface vater and
g~oundwater. aesidual
~isk is le.s than
Alternatives 1,2,3,
and t.
Modifications to the cap
should reduce leachate
generation, increase the
reliability and decrea.e
..intenance re9Uireaents
The iaproved surface
drainage syste.,
vegetative cover, and
site pe~i..ter security
fence viii .ini81ze
erosion. Because of
th..e iaprove..nts, this
Alternative is 80re
reUable than
Alte~nativel 1,2,3, and
3A. A leachate
collection syste.
provides adequate control
of the li.ited leachate
genuated. A GETS
provides control in
.itigating potential
leachete iapacts.
2 1/2 yean fo~
icpleaentation. '1'i..
until protection is
achieved ..y be
relatively long.
The ~econstructed cap
viii be aost effective in
~educiD9 leachate
gene~ation and strength
to a .ini-. 110
reduction in voluae of
residual vaste re..ining.
Modifications to achieve
the aost stable landfill
cap and on-going
..intenance viii reduce
leachate generation aost
)ffectively over other
alternative.. However,
leachate collection and
groundwater re..diation
have not been included
and the~e is so..
9Uestion as to the
overall reliability in
achieving acceptable
groundwate~ protection.
2 1/2 yean fo~ iapl...
aenhtion. '1'i- until
protection i. achieved is
probably les. than all
other alte~natives.
The reconstl'Uctacl cap
will be -st effectiv. in
reducing leachate
gene~ation and strength
to a .ini_. The GETS
provides iap~oved
long-ter. .ffectiveness
in 81tigating l.achate
iapact. to .u~f.ce water
and g~oundwate~.
Magnitude of ~es1dua1
risk is lo_~ than
Alte~native. 1,2,3,
and t.
The addi tion of GETS
provides greatest overall
long-ter. effectivene.s
in co8bination vith the
80st stable landfill cap.
2 years for iaple..nta-
tion. '1'i.. until
protection i. achieved is
less than Alte~antives
1,2,3, and t.
...
Iaprove..nt of the cap's
effectiveness viii
further reduce leachate
gene~ation and strength
and vith leachate
collection groundwater
,uaUty is expected to
iaprove. aesidual risk
is le.s than Alternatives
1 and 2.
Reconst~uction viII pro-
vide a highly stable cap,
~educing leachate
generation, inc~easing
reliability, and
decreasing ..intenance
requin..nt.. The
iaproved surfaca drainage
syste., drainage laye~,
vegetative cover, and
site pe~i..ter fence viii
reduce erosion. Because
of these iaprove..nts,
this cap i. 80re reliable
than Alternatives 1, 2,
3, 3A, t, and tA and is
al80lt equivalent to
Alternatives 5 and SA. A
leachate collection
syste. provides ad89Uate
control of the li.ited
leachate generated.
Active Groundwater
r...diation has not been
-------
CDU>AIUSCB CW SDIJIICS a:8DIDL ALft:IIImrIVES
c:riteda
SC-4
Partial Jl8ccmatnactiCID
of tadfill Cap vitia
Ludlate Coll8Ct.iCID
SC-4A
Partial Jl8cClDatnct.iCID
of l.aDdfill Cap vitia
Ludlate Collec:t.iCID 8Dd
GrOlmdwater btract.1CID
Trea~t
SC-5
'rotal Jl8ccmatnactiCID of
l.aDdfill Cap
SC-5I.
'I'ot:el 88cxmIItnactiaa of
LaDdfill Cap vitia
GrOUDdllater 8rtrac:UCID
8Dd Tr-~t
Selected a-dy
LaDdfill Cap JI.8caaIItnactiCID
vitia "adlate CollectiCID
J. 88cb:tiaa of 'I'oucity,
liability, or vol-
o 'I'reat..nt or offaite treatMnt and On.ite treet..nt of NO treat..nt, ezcept for On.ite treatMnt of Offsite treatMnt and
recycling disposal of collected collected leachate and flaring landfill gas. eztracted groundwater, dispo.al of collected
processe. and leachate, and flaring of eztracted groundwater, and flaring of landfill leachate, and flaring of ..
n..dy landfill g88. and flaring of landfill g88. landfill g88.
g88.
0 Mount of Esti..ted 4600 gpd of Esti..ted 4600 gpd of IiOne by treat..nt, Esti..ted 158,400 gpd of Esti..ted 4600 gpd of
hazardous ..terial leachate. pinal volu.e leachate and 158,400 gpd however natural groundwater. pinal leachate. Pinal volu..
de.troyed, treated deterained during design. of groundwater. Pinal atabili.ation and volu.. deterained during deterained during design.
or ncycled volu.e deterained during attenuation takes piece. design.
design.
0 08grae of azpected Reduction of tozicity Reduction of tozicity Does not reduce aobility, Reduction of todc:ity Reduction of tozicity
reduction in and/or volu.. is and/or volume i. tozicity, or volume and/or volu.. is and/or volu.. is
tozicity aobility dependent on type of dependent on type of through treataent. dependent on type of dependent on type of
or volu.. treataent ~ich is treat..nt ~ich is treat..nt ~ich is treat..nt ~ich is
dependent on leachate dependent on leachate and dependent on groundwater dependent on leachate
cOlllpOsi tion. Volu.e is groundwater coaposition. coaposition. Volu.. is coaposition. Volu.. is
esti..ted to be 4600 gpd Volu.. is uti_ted to be esti..ted to be 158,400 esti..ted to be 4600 gpd
of leachate. 4600 gpd of leachate and gpd of groundwatar. of leachate.
158,400 gpd of
groundwater.
0 Irrever.ibility of Irrevenible Irrevenible Ho treat..nt Irrevenible Irreversible
the traatMnt
0 Type and quantity No residuals-offsite Sludge froa groundwater 60 treataent Sludge froa groundwater No residuals-offsite
of re..ining treat..nt. treat..nt to be di.posed treatMnt to be disposed treataent.
tnatMnt of of bite. of offs1te.
residuals
0 08gree to ~ich TreatMnt of leachate 'I'reatMnt of leachate and 60 treat..nt. 'l'reatMnt of groundwater Treat..nt of leachate
treatMnt reduce. eliainate. principal groundwater eliainate eliainates threat. eliainate. principal
inherent ha.ards threat. principal threats. threat.
posed by principal
threat.
?
-------
b
cdteda
t. bpl_Ubility
A. Technical Feasibility
o Ability to
coutruct and
ope~ate technology
o Reliability of
technology
o E..e of
unde~taking
additional
~e..dial action
sc-t
.artial Jl8amatnctiCID
of l.adfill Cap witb
"'cbate CollectiCID
Fence const~uction,
su~face d~ainage
iap~ove..nts, landfill
~econatruction and
~eg~ading a~e eaaily
i8ple..nted. Const~uc-
tion of leachate
collection syste. can be
easily iaple..nted with
additional health and
aafety cont~ola.
Difficultiea a~iae in 11)
aodifying in and a~ound
existing gaa collection
syste. ..Dboles, (2)
~e-eatablishing
vegetation, and (3)
cont~olling e~osion.
Adhe~ence to quality
cont~ol du~ing
installation will ensu~e
a ~eliable cap with
p~ope~ operation and
..inUnance.
Cap design should not
inte~fe~e with any futu~e
~e88dial action. Futu~e
cap ~epai~ should be a
siaple ope~ation.
CDlPAR1SC8 or SOUIICK
-------
Criteria
SC-4
Partiel IIac:wuItmctio It
of taDdfill CAp with
...c:taate CollectiCID '
CDlPIIlaSIII or SOUIIICZ aIIft'IIOL ~
SC-4A
Partial JI8caas~nctiCID
of Ludfill Cap with
L8ac:bate CollactiCID 8Dd
GrClUDdloatu Kz~JractiCID
TIf..~~
SC-5
Youl a-atmctiCID of
LaDdfill Cap
SC-5A
'foUl I18amatnx:ti- of
LaDdfill cap with
GrOUDdllater KKtractiCID
ADd .Yr_~t
Selected a-dy
LaDdfill CAp 8acoIIatnx:tiCID
with ...c:taate CollectiCID
bpl_tabiUty (Cont'dl
t.
o Itonitodng
effectiveness
Itonitoring involves
periodic visual
inspection of the cap,
sampling surface and
groundwater downgradient
of the landfill, and
8Onitoring the gas
collection/flare syste..
This should be adequate
to 8Onitor effectiveness.
B.
Adainstrative Feasibility
required.
o Coordination with
other agencies
o Ability and time
to obtain
approvals and
peralts
C.
Availability of
services and
..tuiala
o Availability of
adequate off-site
treataent, storage
capad ty, and
disposal capacity
and services
o Availability of
equipMnt and
specialists and
prospective
technologies,
provisions to
ensure additional
resources
?
Not required.
Disposal of leachate can
be contracted with a
number of qualified
co...rcial operators.
Equipaent readily
available.
Itonitoring involves
pedodic visual
inspection of the cap,
s88pling surface and
groundvater dowogradient
of the landfill, and
_nitoring the gas
collection/flare syste..
This should be adequate
to _nitor effectiveness.
required.
Not required.
Laachate and sludge
disposal can be
contracted with a number
of qualified co.ercial
operators .
Equipaent readily
available. GETS will be
built to specificaiton
aftar . pilot study.
~nitoring involves
periodic visud
inspection of the cap,
.aapling surface and
"roundwater downgudient
f the landfill, and
8Onitoring the gas
collection/flare syste..
This should be adequate
to 8Onitor effectiveness.
in the cap toe iepinging
on adjacent wetlands and
the B~ railroad tracks.
Coordination with u.s.r.
. W.S. and D.O.I. are
required.
Possibly eKtensive due to
encroacb8ent on wetlands
and issues related to
railroad tracks.
None required.
Equipaent readily
available. Procuring,
hauling, and handling of
the additional required
aoil asterials will be
significant.
Itonitoring involves
periodic visual
inspection of the cap,
sampling surface and
groundwater downgradient
of the landfill, and
_nitoring the gas
collection/flare 8yst...
This should be adequate
to _nitor effectiveness.
in the cap toe iapinging
on adjacent wetlands and
the B~ railroad tracks.
coordination with U.S.F.
, W.S. and D.O.I. are
required.
Possibly eKtensive due to
encroacbaant on wetlands
and iasues related to
railroad tracks.
Sludge disposal can be
contracted with a nU8ber
of qualified co...rcial
opertors .
Equipaent readily
available. GETS will be
built to specification
after a pilot study.
procuring, hauling, and
handling of the
additional required 80il
asterials will be
significant.
Itonitoring involves
periodic visual
inspection of the cap,
saepling surface and
groundwater downgradient
of the landfill, and
_nitoring the gas
collection/flare syste..
This 8hould be adequate
to 8Onitor effectiveness.
...
required.
Not required.
Disposal of leachate can
be contracted with a
nU8ber of qualified
c08m8rcial operators.
EquipMnt readily
available. Procuring,
hauling, and handling of
the additional required
soil asterials will be
-------
Cdbda
sc-t
Partial l18cua8~ncti-
of LaDdfill Cap with
"adaa~e Collecti-
CDlPAIWDI or SDUIICI: CXIIIIIOL ~
sc-u.
Partial bamII~ructi-
of LaDdfill cap with
"acba~a Collacti- aDd
GrOUDdva~ar b~l:8cti-
Tr..t8eD~
18p188ODtabilitr (cont'd)
t.
o Availability of
.ervices and
..teriah
Services and ..terials
are readily available.
Services and ..terials
are readily available.
...;'¥
SC-5
Total bamII~ructioG of
LaDdfill cap
sc-~
row JIIIc:cJDS~ruct.i- of
LaDdfill Cap with
GrGUlldllatar k~racti-
8Dd Tr..~t.
procun..nt of cap
..teda18 will be
significannt.
Selectacl a-dy
LaDdfill Cap l18cua8~ructi-
with ...c:bat.a Collacti-
Alternativa will ..at
cheaical specific ~
with the reconstructed
landfill cap reducinq
leachate qeneration to a
.ini..... Ti.. to ..et
eay be relatively lonq.
Significant voluaes of
fill ..terial in wetlan~
violata. wetland
re
-------
criteda
SC-4
Partial a-atnctiCIII
of l.aDdrill Cap witb
"'ac:bate CollectiCIII
CDlPMISaI ~ SOF --: a:8IBDL ~
SC-4A
Partial ---tructiCIII
of LaDdrill Cap witb
"'c:bate CollectiCIII 8Dd
G~OUDdwate~ btractiCIII
~rea~t
SC-s
'!'obI a-atructiCIII of
lMIdrill Cap
SC-5A
'!'otal 88ca11atnctiCIII of
l.aDdrill Cap witb
GrOl8Mlllater btractiCIII
8Dd ~..~t
Selected JI88d.r
l.aDdrill Cap 88cC1118tnctiCIII
witb l.8ac:bate Collact:iCIII
OWrall l'I:otact:iCIII of
IIImaD Bnltb 8Dd
&Dvir-t
7.
o aisks ue
eli.inated,
reduced or
controlled
?
Landfill cap
reconstruction further
reduces leachate
generation over
Alternatives l-3A. A
leachate collection
syste. controls
conta.inant release.
These two ..asures
provide further
protection of
groundwater. Offsite
trsnsport of leachate
produces a .inor risk of
conta8inant release which
can be controlled by
compliance with D.O.T.
regulations.
aeconstruction provides
80re stable cap than
Alternatives l-3A,
preventing erosion into
wetlands. Landfill
containment eli.inatts
contact with refuse.
Potential physical h.zard
to trespassers, and
potential erosion in:o
wetlands is .itigate,' by
a security fence.
Landfi 11 gas
collection/flare syst.m
controls release of
airborne contaminants.
Groundwater 8Onitoring
warns of offsite
migration.
Landfill cap
reconstruction further
reduces leachate
generation over
Alternatives l-3A. A
GETS captures and treats
the conta.inants that
reach groundwater and
treats those collected by
the leachate collection
syste. providing
increased protection over
Alternatives 1-4. These
..asures provide further
protection of
groundwater. C08pliance
with NPDES require..nts
protects surface water
qualitiy. Landfill
contain88nt eliminates
contact with refuse.
Potential physical hszard
to trespassers, and
potential erosion of
wetlands is .itigated by
a security fence.
aeconstruction provides
80re stable cap than
Alternatives 1-3A,
preventing erosion into
wetlands. Landfill gas
collection/flare system
controls release of
sirborne contaminants.
Groundwater 8Onitoring
warns of offsite
migration.
The reconstructed
landfill cap is the 80st
effective in reducing
leachate generation over
Alternatives 1-4A and the
selected re..dy.
Landfill containment
eliminates contact with
refuse. Potential
physical hazard to
trespassers, end
potential erosion of
wetlands is mitigsted by
a security fen~e. Total
reconstruction provides
80st stable cap,
preventing erosion into
wetlands. Landfill g88
collection/flare system
controls release of
airborne contaminants.
Groundwater 8Onitoring
warns of offsite
migration.
The reconstructed
landfill cap is the 80st
effective in reducing
leachate generation over
Alternatives l-4A and the
selected re..dy. A GETS
captures and treats the
contaminants that reach
groundwater. Compliance
with RPDES require..nts
protects surface water
quality. Landfill
contain88nt eliminates
contact with refuse.
Potential pbysical hazard
to trespassers, and
potential erosion of
wetlands is mitigated by
a security fence. Total
reconstruction provides
80st stable cap, .
preventing erosion into
wetlands. Landfill g88
collection/flare system
controls release of
ai rbome conta8inants.
Groundwater 8Onitoring
warns of ofhite
migration.
Landfill cap
reconstruction turther
nduces leachste
generation over
Alternatives 1-4A and is
al80st equal to
Alternatives 5 and SA. A
leachate collection
system controls
contaminant release.
These two ..asures
provide turther
protection of
groundwater. Otfsite
transport of leachate
produces a minor risk of
contaminant release which
can be controlled by
compliance with D.O.T.
regulations. Landtill
contain88nt eliminstes
contact with retuse.
Potential pbysical hazard
to trespassers, and
potential erosion into
wetlands is .itigated by
a security fence.
aeconstruction provides
80re stable cap,
preventing er08ion into
wetlands better than
Alternatives 1, 2. 3, 3A,
4, and 4A. Landf i 11 g88
collection/tlare system
controls release of
airborne conta81nants.
Groundwater 8Onitoring
warns ot oftsite
81gration.
-------
RECIU I REIEIIT
I. CHEMICAL-SPECIFIC
A. FEDERAL REQUIREMENTS
1. SDWA-MaxlllUll Contaminant levels
(MCls) and non-zero maximum
contaminant level goals (MClGs) 40
CFR 141.11-141.16 and 141.50-141.52
2. Proposed MCls and Non-Zero MClGs
B. STATE REQUIREMENTS
1. Grcx.ndwater Qual I tv Standards
(314 CMR 6.00)
II. lOCATION-SPECIFIC
A.
FEDERAL REQUIREMENT
,. Clean Water Act (CWA) (40 CFR
Part 230)
2. Endangered Species Act (16 usc
1531 £! !!9) (50 CFR Parte 81, 225
and 402)
3. Wetlands Executive Order (EO
11990) (40 CFR 6 Appendix A)
?
/
POTENTIAl AllARS AlII) CRITERIA, ADVISORIES AlII) GlIDAILCE FOR THE REMEDIAL ALTERNATIVE
FOR THE SHAFFER lAIIOFlll, IIKII HORSE PARIC SITE, BlllERICA, MASSACHUSETTS
APPL I CABLE
To Be
Considered
II
II
II
II
RELEVAIIT
APPRCIPR I ATE.
II
RATUIiAlE
MCLs and MCLGs have exceeded in
groundwater. Groundwater is potential
drinking water source.
Proposed MCls and MCLGs have been
exceeded in groundwater. Groundwater
is potential drinking water source.
Groundwater Qualitv Standards have
been identified for a I'U1ber of
contaminants detected in grcx.ndwater.
When the state levels ere more
stringent than the federal levels, the
state levels will be used.
This requirement prohibits the
discharge of dredged or fill material
into a wetland.
Endangered Species Act was enacted to
conserve endangered species.
Consultation with the Department of
Interior -v be required if the site
provides critical habitat upon which
endangered or threatened species
depend.
Federal agencies are required to
~inlmlze the destruction, loss or
degradation of wetlands and preserve
and enhance natural and beneficial
value of wetlands.
(page 1 01 5)
IDI AllAR
15 lET
Capping will reduce infiltration and
subsequent ~igration of contaminants Into
groundwater so that MCls and non-zero
MClGs will be ~t. leachate collection
will enhance remediation tiN.
,
Capping will reduce infiltration and
subsequent ~Igratlon of contaminants into
groundwater so that proposed MCls and
MClGs will be ~t. Leachate collection
will enhance remediation time.
Capping will reduce Infiltration and
subsequent lIigration of cont8lllinants Into
groundwater so that standards will be met.
leachate collection will enhance
remediation ti~.
Alternative will not iqHICt wetlanda as no
dredged or fill _terial will be
discharged to the wetland.
001 has been consul ted wi th and no
endangered or threaten species have been
identified at the Site.
No activities conducted in wetlands. All
on-site construction perfo~ to .inlllize
-------
REClJIREMEIiT
4. Floodplains Executive Order (EO
11988) (40 CFR 6 Appendix A)
5. Nationsl Historic Preservation
Act (16 U.S.C. 470; 7 CFR Part 650)
B. STATE REQUIREMENTS
1. DEP - Wetlends Protection (310
CMR 10.00)
2. DEP Hazardous Waste Regulation
(310 CMR 30.00)
a. Land Subject to flooding (310
CMR 30.701)
III. ACTION-SPECIFIC
FEDERAL REQUIREMENTS
1. Cleen Air Act (42 USC 7401)
a. lIationsl Allbient Air Que I ity
Stand8rds (IIMQS) for Seven
criteria Pollutents (40 CFR Part
50)
POTEIiTiAL ARMS AlII) CRITERIA, ADVISORIES A8ID QJIDAliCE FCII THE REJlEDIAL ALTERIlATiVE
FOR THE SHAfFER lAIIDFlLL, IROII HORSE PARI( SITE, BILLERICA, IlASSACIIJSETTS
APPLICABLE
x
x
x
x
RELEVAIIT
APPRCI'IIIATE
x
x
DTU.ALE
Federal Agencies are required to
reduce the risk of flood loss, to
minimize impact of floods and to
restore and preserve the netural and
beneficial value of floodplains.
Middlesex Canel is adjacent to Shaffer
Lendfill and listed on the Nationsl
Register of Historic Places.
Consultation with State Historic
Preservation Officer is required to
ensure that no adverse effects to
cultural resources take place.
These regulations are pronuluated
under Wetlends Protection Laws, which
regulate dredging, filling, altering
or polluting inlend wetlands. Work
within 100 feet of a wetland is
regulated Inter this requirement.
Regulations also define wetlands based
on vegetation type end requires that
effects on wetlands be mitigated.
Includes regulation of work in
bordering land subject to flooding.
This regulation requires hazardous
waste facilities located in a 100 year
floodplain to be designed,
constructed, operated and maintained
to prevent washout, or that no adverse
effects on human health or the
environment will result if washout
occurs. Leachate will be tested to
detel"llline if requirements are
applicable.
Remedial al ternetive includes
earth moving, stockpiling and
spreading operations that may result
in dust and particulate releases.
(page 2 of 5)
till ARAR
IS MET
Construction of leachate collection
facilities in floodplains is necessary due
to lack of available lend area and
floodplain proximity to landfill. There
are no practicable alternetives. All
construction will be performed to minimize
potential hann to floodplains.
Massachusetts Historical Commission has
been consul ted and concurred wi th EPA
determination of no adverse effect from
remedial action.
...
Work wi II be perfonned according to state
requirements so that general perfol"lll8nce
standards are met for regulated resource
areas. If necessary, alternetlve will
provide for replacellerlt of bordering
vegetated wetlands end cllq)enSatory
storage for lost flood volume storlge.
Leachate collection system will be
des iUned, constructed, operated, and
maintained to cOQ1)ly with floodplain
requi re8ents.
Alternative will include air 8Onitorlng to
confirm conpllanc:e with relevant and
appropriate standards. All affected areas
will employ dust control llleasures during
ill1>lementation and maintenence of the
-------
REcaII RBEIT
b. National Ellissions Standards
for Hazardous Air Pollutants
(NESHAPs) (40 CfR 61)
2. DOT Rules for Hazardous
Materials Transport (49 CfR Parts
101, 11" 1-111.500)
3. Hazardous Waste Regulations
(RCRA Subtitle C, 40 CfR Part 264)
a. Groundwater Protection
(264.91 - 264.99).
b. RCRA Closure and Post Closure
Care Requirements (40 CfR 264
Slbpart G)
B. STATE REQUIREMENTS
1. DEP Hazardous Waste Regulation
(310 CMR 30.00)
a. Tanks (310 CMR 30.690 - .699)
b. Contingency Plan, Emergency
Procedures, preparedness and
prevention (310 CMR 30.520 - 524)
c. Mani festing, Record Keeping and
Reporting (30.310 - 30.340)
d. Transporters (310 eMR 30.400 -
.416)
?CJ
.)
POTEITIAl AIWIS All) CRITERIA, ADVISORIES AIm WIDAICE fOR THE REMEDIAL AlTERIlATiVE
fOR THE SHAffER LAll)fILL, IR(II HORSE PAlIK SITE, BILLERICA, MASSACIIJSETTS
APPLICABLE
x
x
x
x
x
x
RELEVAIT
APPIt(FIIIATE
x
x
x
x
x
x
RATiOIALE
Benzene has been detected in emissions
at gas vents.
Remedial alternative includes off-site
transport of leachate. Leachate will
be tested to see if applicable.
Site includes landf i II that is
leaching.
Remedial alternative includes landfill
and tank.
Remedial alternative includes leachate
collection involving storage tanks.
Leachate will be tested to determine
if applicable.
Remedial alternative includes landfill
closure and leachate collection.
Remedial alternative includes
shipments of leachate for off-site
disposal. Leachate will be tested to
determine if applicable.
(page 3 of 5)
II1II AIWI
IS lET
Alternative will include air monitoring to
confina coapliance with relevant and
appropriate standards. If necessary,
iq>rovements will be made to achieve
standards.
Alternative will coaply with DOT rules if
applicable.
..
Alternative will include groundwater
monitoring.
Alternative will coaply with relevant and
appropriate post-closure requirements for
landfill and alternative closure will
coaply with requirements for tanks, if
appl icable.
Alternative will coaply with regulations.
Alternative will include a contingency
plan and emergency procedures, etc.
Alternative will include required
manifesting, record keeping and reporting
-------
RECIJ I REJlEI'
2. DEP - Mass Air Toxics Program
(May 1981>
3. DEP - Mass Ambient Air Quality
Standards (310 CMR 6.04)
4. DEP - Mass Air Pollution Control
Standards (310 CMR 1.00)
5. DEP - Mass Solid Waste
Regulations (310 CMR 19.00)
a. landfill final cover system
(310 CMR 19.112)
b. Alternative landfill final
cover systell design
(310 CMR 19.113)
c. StOMl water controls
(310 CMR 19.115)
d. Surface and groundwater
protection (310 CMR 19.116)
e. Air quality protection systems
(310 cMR 19.111>
f. Groundwater. surface water and
ai r lIIOf'Ii torlng systems
(310 CMR 19.118)
g. landf III gas recovery
operations (310 CMR 19.121 (4»
h. leachate collection. treatment
and disposat (310 CMR 19.130 (30»
POTEITIAL ARARS AID CRITERIA. ADVISORIES AID WIDAliCE FOR THE REMEDIAL ALTERIlATiVE
Hit THE SHAFFER LAJlDFiLL. IROI _SE PARle SITE. BlllERICA. MASSACHUSETTS
AWL I CABLE
To Be
Considered
x
x
x
x
x
x
x
x
RElEVAJI'
APPROPRIATE
x
RATiCIIALE
Affected contaminants have been
detected in emissions at gas vents.
To ensure that emissions from a source
will not adverseiy affect any of the
Ambient Air Quality Standards for 1
criteria pollutants.
Remedial alternative includes air
emissions controls.
Includes requirements for the cover for
the landfill.
Provides for an alternative design for
the final cover than is specified in
the regulations.
To prevent erosion. discharge of
pollutants. and protect physical
integrity of the iandfili
To prevent direct discharge of
contaminated run-off or ieachate.
To control concentrations of explosive
and malodorous gases to maintain ai r
qual ity.
To detect and quantify release of
contaminants to the ground. groundwater
surface water or air.
Operation and l18intenance of gas
recovery system.
Requirements for leachate collection
and disposal.
(page 4 of 5)
HOW AllAR
15 MET
Alternative wiii include air monitoring
and modell ing to assess significance of
contamination. If necessary. iq»rovements
wili be made to ensure attainment of
guidel ioes.
Air emissions wUl be evaluated to
determine attairnent and If necessary.
llleasures wi i i be taken to ensure these
standards are met.
..
Aiternatlve wlii inciude air monitoring to
confirm cOlllpiiance with reievant and
appropriate standards. If necessary.
improvements wil i be III8de to
achieve standards.
The alternative wiii 8eet the requirements
of this section.
Design of cover wiil adequateiy protect
public heaith. safety and the environment.
Alternative will include ItO", water
controls that .eet these requirements.
Alternative wlli prevent run-off and
discharge of leachate.
Alternative wiil include 8ethods to
control and .onltor gases that will llleet
these requirements.
Alternative wili inciude .onitoring to
llleet these requirements.
Alternative will include operation and
l18intenance that will Ille8t these
requirements.
Alternative includes leachate collection
and di sposal that wi i l meet these
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POTE.TlAL ARMS AlII) CRITERIA. ADVISOIIES All) GlIDANCE FOR THE REMEDIAL ALTERIlATiVE
FOR THE SHAFFER LAllDFiLL. IROI HORSE PARIC SITE. BILLERICA. MASSACHUSETTS
REClUIREIE.T
APPLICABLE
RELEVANT
APPROPRIATE
RATI(IIAlE
IKII AlAR
IS MET
i. Environmental monitoring X Monitoring shall be included to Alternative will include monitoring that
requirements (310 CMR 19.132) evaluate effectiveness of the remedy. will meet these requirements.
j. Landfill post closure X Monitor to ensure integrity of closure Alternative will include monitoring that
requirements (310 CMR 19.142) lIII!asures. will meet these requirements.
k. Post closure use of landfills X The landfill shall not be used for any The alternative Includes institutional
(310 CMR 19.143) other use without prior wri tten controls.
approval of the Department.
...
(page 5 of 5)
t')
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b
'.
Responsiveness summary for the
Iron Borse Park-Shaffer Landfill
superfund site, Bi1lerica, MA
Preface
The U.S. Environmental Protection Agency (EPA) held a 60-day
public comment period from January 16, 1991 to March 16, 1991 to
provide an opportunity for interested parties to comment on the
Remedial Investigation (RI), Endangerment Assessment (EA),
Feasibility study (FS), and the Proposed Plan prepared for the
Shaffer Landfill section of the Iron Horse Park Superfund site in
Bi11erica, Massachusetts (the Site). EPA made a preliminary
recommendation of its preferred alternative for site remediation
in the Proposed Plan issued on January 15, 1991 before the start
of the comment period. On May 16, 1991, EPA issued a Supplement
to the Proposed Plan which recommended a new preferred
alternative for site remediation. EPA held an additional 30-day
public comment period from May 17, 1991 to June 17, 1991.
The purpose of this Responsiveness summary is to document EPA
responses to the comments an( ~uestions raised during the public
comment periods. EPA will consider all of the comments
summarized in this document before selecting a final remedial
alternative to address contamination at the Site.
This responsiveness summary contains the following sections:
I.
overview of Remedial Alternatives considered
in the Feasibility Study and ProDosed Plan -
This section briefly outlines the remedial
alternatives evaluated in the FS and Proposed
plan, including EPA's preliminary
recommendation of a preferred alternative.
II.
site Historv and Backaround on community
Involvement and Concerns - This section
provides a brief site history and a general
overview of community interests and
concerns regarding the site.
III. SummarY of Comments Received Durina the Public
Comment Period and EPA ResDonses to these
Comments - This section summarizes
and provides EPA responses to comments
received from residents and other
interested parties during the public
comment period. In addition, comments
received from the potentially Responsible
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'.>
Parties (PRPs) and the Massachusetts
Department of Environmental Protection (MADEP)
are summarized and EPA's responses to these
comments are provided.
Attachment A - This attachment provides a list of
the community relations activities that EPA has
conducted to date at the Site.
Attachment B - This attachment provides a
transcript of the February 5, 1991 and February 19,
1991 informal public hearings on the site, both of
which were held in Billerica, Massachusetts.
All written comments received by EPA during the
comment periods are contained in the Administrative
Record for Shaffer Landfill, which can be reviewed
at:
EPA Records Center
90 Canal Street, 1st Floor
Boston, Massachusetts 02114
OR
Billerica Public Library
25 Concord Road
Billerica, MA 01821
I. overview of Remedial Alternatives Considered in
the Peasibility study and Proposed Plan
On January 16, 1991, EPA released a Proposed Plan
for the Shaffer Landfill portion of the Iron Horse
Park Superfund site, identifying a preferred
alternative for addressing site contamination.
Subsequently, on May 16, 1991, EPA issued a
Supplement to the Proposed Plan for the Shaffer
Landfill, identifying a modified preferred
alternative. For a detailed description of the
modified preferred alternative, and other remedial
alternatives evaluated, refer to the May 1991
Proposed Plan document, and the Feasibility study
for the Shaffer Landfill. An outline of the major
components of the modified preferred alternative,
and a list of the other remedial alternatives
evaluated for the site in the Feasibility study,
are provided below.
Components of the modified preferred alternative
upon which public comment was taken include:
Reconstruction of the entire Landfill cap.
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\.
II.
This will improve its overall stability and
its ability to prevent precipitation from
leaching through the landfill. Reconstruction
would be achieved by removing the existing
topsoil layer, adding additional low-
permeability soil to; 1) provide a 5% grade on
the top of the Landfill lobes, and 2) provide
a consistent smooth sub-grade on the Landfill
side slopes, installing an impermeable
textured membrane liner over the entire
Landfill area, installing a 6-inch drainage
layer, installing a non-woven filter fabric
between the drainage and topsoil layers,
reinstalling the topsoil layer to a depth of
12-inches, and reseeding the disturbed areas;
construction on necessary surface water
drainage system;
Maintenance of cap, surface drainage system,
and landfill gas collection/flare system. If
necessary, improvements will be made;
Monitoring of the gas collection/flare system;
construction, operation and maintenance of
leachate collection facilities;
Off-site treatment and disposal of leachate:
Construction of a site perimeter fence;
Monitoring of groundwater and surface water
quality.
The seven additional cleanup alternatives evaluated in the
Feasibility study were:
No Action Alternative
Landfill Cap Completion/Repair
Landfill Cap Completion/Repair with Leachate Collection
Landfill Cap Completion/Repair with Leachate Collection
and Groundwater Extraction and Treatment
Partial Reconstruction of Landfill Cap with Leachate
Collection and Treatment
Partial Reconstruction of Landfill Cap with Leachate
Collection and Groundwater Extraction and Treatment
Total Reconstruction of the Landfill Cap
Total Reconstruction of the Landfill Cap with
Groundwater Extraction and Treatment
site History and Background on community Involvement and
Concerns:
-------
n
The Iron Horse Park site was proposed to the EPA Superfund
National Priorities List (NPL) in September 1983. The site
is located in Billerica, Massachusetts, near the Tewksbury
town line. It includes both active and inactive
industries, waste storage areas and landfills within the
Iron Horse Industrial Park complex as well as the Shaffer
Landfill, which is adjacent to the Industrial Park.
Several operable units have been identified within the Iron
Horse Park Superfund site in addition to the Shaffer
Landfill. These operable units are in different stages in
the Superfund cleanup process. As part of this cleanup
process, the Johns-Manville Asbestos Landfill has been
capped and covered and the B&M waste lagoons have had
bioremediation selected as a cleanup remedy and the
bioremediation process itself is currently being designed.
other contaminated areas of the Iron Horse Park site will
be investigated in a later Remedial Investigation. This
responsiveness summary is part of the Record of Decision
identifying a cleanup for the Shaffer Landfill section of
the Iron Horse Park Site.
When the Iron Horse Park site was first proposed as a
Superfund site in 1983, several citizen groups that had
originally been organized around individual issues merged
into the Superfund Action Coalition (SAC). This group has
been active in monitoring local, federal and statr
activities at the site, commenting on cleanup act~vities,
and building coalitions with other groups interested in
Superfund.
Media coverage of the Iron Horse Park site has been fairly
extensive since the first citizen concerns with the Site
were raised in the early 1970s. The addition of the Iron
Horse Park Site to the NPL in September 1984 was reported
widely by local radio, television and newspapers, including
the Lowell Sun. Billerica Minuteman. and Billerica News.
Citizens have shown varying levels of concern over the
years with the different parts of the Iron Horse Park Site,
but concern over the Shaffer Landfill has been relatively
consistent and focused. Local residents' interest in the
Landfill initially surfaced in 1971 when inspections by the
Board of Health revealed that the Landfill was not in
compliance with numerous environmental regulations.
"Citizens to Enforce Dump Controls" (CEDC) was formed
shortly after this discovery to bring pressure on local
officials to ensure that the Landfill met all applicable
regulations. CEDC has since become part of the SAC, which
has remained a strong proponent of Landfill closure and
capping due to perceived health and environmental impacts
from the Landfill. SAC has met with state, local and
federal officials to monitor the progress of the various
4
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v
activities at Iron Horse Park. The site Remedial Project
Manager is in regular contact with the SAC to keep it
informed of ongoing site activities.
At public meetings discussing the Remedial Investigation
(August 1989) and the Proposed Plan (February 1991) for the
Shaffer Landfill section of the Iron Horse Park site,
residents have consistently expressed concerns about
potential ground and surface water contamination caused by
leachate from the Landfill. Odors, destruction of wetlands
and site security have also been mentioned as concerns.
Local response to EPA'S proposed plan is documented in the
next section of this Responsiveness Summary.
xxx. summary of comments Received during the Public Comment
Period and EPA Responses to these Comments
This Responsiveness Summary summarizes the comments EPA
received during the public comment periods held from
January 16, 1991 to March 16, 1991, and from May 17, 1991
to June 17, 1991. 133 sets of written comments were
received from Town of Billerica officials,
representatives of state and federal governments, state
agencies, area residents, members of the superfund Action
Committee, representatives and consultants for Graypond
Realty - the owner of the Shaffer Landfill, and other
interested parties. In addition, oral comments were
received at hearings held on February 5, 1991 and
February 19, 1991. All of these comments are summarized
below.
A.
summary of resident and other interested party comments
Comments from residents and other interested parties are
summarized below, along with EPA responses. Where the
same or similar comments have been given by more than one
person they have been grouped together for the purposes of
providing a complete response. The comments are organized
in the follo~ing categories: 1) EPA's Preferred
Alternative; 2) Groundwater and Surface Water issues; 3)
Miscellaneous Comments.
.L.
EPA's Preferred Alternative
Comment a: Several residents and town officials expressed
concern that the long-term maintenance and monitoring of the
Landfill required some form of monetary guarantee. Methods
recommended by commentors include: citizen monitoring of
agreements, contracts with penalties, performance bonds,
5
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,
,}
trust funds, escrow accounts or other forms of financial
commitments.
EPA's ReSDonse: If responsible parties undertake
implementation of the remedy at the Shaffer Landfill, that
implementation would take place under a Consent Decree. A
part of that agreement would address financial assurance
mechanisms covering all work at the Landfill, including
operation and Maintenance.
Comment b: Several residents said that the existing
landfill venting/flare system should not merely be
maintained, but should be redesigned and rebuilt. According
to these residents the current system does not work properly.
One resident said that he had smelled odors from the Landfill
on the way to the February 19, 1991 hearing.
EPA's ReSDonse: At this time, it does not appear that the
existing Landfill venting/flare system needs to be redesigned
and rebuilt. Proper operation and maintenance of the
existing system will improve its performance. However, EPA
will be reviewing the effectiveness of this portion of the
remedy to ensure that it is operating properly. If
necessary, improvements will be made. Additionally, other
sources of release of landfill gas and odor exist that
contribute to the problem. These additional sources are
leachate outbreaks and gases that permeate through the
existing cap surface. The proposed installation of leachate
collection facilities and a less permeable, improved cap
should help to reduce the problems being encountered.
Comment c: Most of the residents who offered comments at
the public hearings, including residents, the local state
representative and representatives of the Billerica town
government, stated that EPA should require the reconstruction
of the entire cap of the Landfill, not just the top portion.
Several people who made this point noted that the sides of
the cap, not the top, are the places that have experienced
the most severe erosion problems, and are the places where
leachate breakouts are occurring. One resident noted that
EPA's Remedial Investigation for the site showed that the
existinq cap does not even meet the full requirements of the
1984 consent agreement between the Landfill owners and the
state, both on the top and the sides of the Landfill. Other
reasons for rebuilding the cap include that the Landfill does
not comply with state "flat" requirements and that the side
slopes of the landfill are at a 2 to 1 slope when they should
be at a 3 to 1 slope.
EPA's ReSDonse: Concerns that the side slopes were not being
reconstructed and that the entire Landfill was not being
capped have been addressed by EPA in the Selected Remedy
6
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Ij
wherein the entire Landfill cap will be rebuilt. Slopes in
excess of 3 to 1 will remain, however specific measures to
enhance the stability of these slopes are included in the
Selected Remedy.
comment d: Several residents and town officials agreed with
EPA's plans to collect leachate and treat it off-site. Most
of these commentors, expressed concern about trucking
leachate through local neighborhoods, however, and said that
leachate should be moved by railroad tank car rather than
truck.
EPA's ResDonse: Methods for transporting
will be examined during remedial design.
destination of the leachate, rail mayor
means for leachate transportation.
leachate off-site
Depending on the
may not be a viable
comment e: Several residents and the Massachusetts Department
of Public Health, said they agreed with EPA's decision to
build a site perimeter fence. One resident remarked that it
has been 25 years since residents first requested a fence
around the site, and she said that she is glad that a
site-perimeter fence is finally part of the Landfill clean-up
plan.
EPA'S ReSDonse: EPA feels that restricted site access is
necessary in order to protect pub1ic'hea1th and also to
protect the integrity of the Landfill cap.
Comment f: A resident said that EPA's reports should
explicitly address all of the leachate breakouts, and leave
none of them uncorrected.
EPA's ReSDonse: One of the purposes of total reconstruction
of the Landfill cap is to address leachate outbreaks.
Comment q: A resident said that 1966/67 state permits for
the Landfill, required a liner, which was never installed,
but the permit was not revoked. He said that this points to
the need for a completely reconstructed cap and greatly
improved monitoring of the site.
EPA'S ReSDonse: The Selected Remedy includes reconstruction
of the entire cap. A monitoring program for the Landfill
that addresses groundwater, surface water, and air monitoring
will be prepared during design of the remedial action.
comment h: Several residents said that EPA should develop
and fund in advance plans to deal with the possibility of
leachate spills, either at the site or on any planned
transportation routes, or other possible site disasters.
7
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"
EPA's ReSDonse: All applicable requirements relating to the
storage, transportation, and treatment of leachate will be
met. These requirements may be applicable depending on the
results of leachate testing. RCRA subtitle C requirements
for contingency Plans and Emergency Procedures are relevant
and appropriate based on current site specific information.
Comment i: A resident stated that EPA should schedule
routine retests of all media to monitor migration of
chemicals off-site after implementation of a cleanup
alternative. He added that threshold values for pollutants
should be set, and that the public should be notified if
these values have been met or exceeded and that EPA should
have plans in place that will allow it to respond quickly if
a problem is revealed by this monitoring.
EPA's ResDonse: As discussed above, a monitoring program
will be designed and implemented. Part of EPA's community
relations program for the Iron Horse Park Site includes
notifying affected residents, officials and news media of any
new data regarding actual or potential, current or future
site risks. EPA will also send all sampling results to the
Billerica Public Library, which is the local information
repository for the Site. One of the goals of the selected
remedy is to achieve all ARARs for groundwater quality
through natural attenuation after implementation of the
remedy (reconstruction of the cap, collection and treatment
of leachate off-site). If, upon review of monitoring data,
it is determined that the remedy is not protective, EPA may
determine that additional remedial action is warranted.
Comment ;: A resident said that EPA's preferred alternative
(Alternative 4) in the January Proposed Plan depended too
heavily on maintenance and monitoring, areas that have been a
historical weak point at the Shaffer Landfill. She suggested
that the best solution for the Landfill is the one that
requires the least amount of monitoring, precisely because
this is what can be expected from the Landfill owners. She
added that total cap reconstruction is her preferred
alternative.
EPA's Response: EPA's Selected Remedy includes
reconstruction of the entire Landfill cap. Maintenance is a
necessary component of any remedy. Additionally, any remedy
chosen would depend on monitoring in order to quantitatively
evaluate the effectiveness of the remedy as well as the
condition of the affected media.
Comment k: A resident expressed concern that the EPA's
preferred alternative from the January Proposed Plan would
not adequately protect the Town of Tewksbury's wells.
8
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o
EPA's ReSDonse: The Town of Tewksbury's wells have been shown
not to be in the migration pathway from the Shaffer Landfill,
either with or without implementation of the Selected Remedy.
This issue is discussed on pages 2-13 and 2-14 of the January
1991 Feasibility Study. In summary, the Landfill is not
considered a threat to the Tewksbury wellfield because the
natural direction of groundwater flow from the Landfill is
directed away from the well field by natural geologic
barriers. However, EPA will be monitoring groundwater
quality and will take additional response action if it is
determined that the remedy is no longer protective.
Comment 1: A representative from the Board of Health of the
Town of Billerica presented the Board's preferred cleanup
alternative for the site. The alternative "must include, but
may not be limited to the following issues. EPA must require
1) a total cap reconstruction, 2) repair and, if necessary
replace or expand the current methane collection system; 3)
containment, collection and treatment of groundwater; 4)
leachate collection and treatment; 5) proper operation and
maintenance in place and properly funded; 6) a significant
contingency fund to cover the cost of any surprises; 7)
cleanup of Richardson Pond; 8) we need a significant escrow
account for future repairs or work that may need to be
performed." (Note: These 8 points are essentially the same as
the 8 issues identified in form letters sent to EPA by
Billerica Residents during the comment period. EPA received
113 copies of this letter, with a total of 236 signatures.)
EPA's ReSDonse: The Selected Remedy includes total cap
reconstruction, repair/operation and maintenance of the
landfill gas system, leachate collection and treatment, and
overall operation and maintenance activities. The items not
included in the Selected Remedy are 1) groundwater
containment, collection, and treatment and 2) cleanup of
Richardson Pond. Regarding item number 3), the need for an
escrow account, please see the response to comment 1.a.,
above. The groundwater contamination will be addressed by
natural attenuation processes and by implementation of the
Landfill cap reconstruction and the leachate collection
system which will reduce on-going releases. There are no
known off-site receptors currently being exposed to
potentially contaminated groundwater. Although site surface
waters are targeted to be studied in the 3rd operable unit at
Iron Horse Park, Richardson Pond should benefit significantly
by virtue of the total Landfill cap reconstruction and the
leachate collection system.
Comment m: Several residents commented that EPA's preferred
alternative in the January Proposed Plan was based primarily
on cost effectiveness, and they believed EPA should be
seeking the most effective solution that provides the
9
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greatest degree of protection for human health and the
environment, not "the wallets of the polluters."
EPA's ResDonse: EPA's Selected Remedy must be based upon
finding that the remedy is protective of human health and the
environment, attains ARARs and is cost effective. All of
these factors were fully and carefully evaluated in making a
determination that the Selected Remedy is consistent with the
intent of CERCLA. A determination of cost effectiveness
requires EPA to ensure that costs are proportionate to the
overall effectiveness of the remedy. The Selected Remedy is
the most cost effective of all remedies considered and
provides a high degree of overall protection of human health
and the environment.
Comment n: One resident said that the chosen cleanup solution
should include continuous community involvement in the
monitoring process. Another noted that all information about
test results and ongoing monitoring should be made public so
that the community can monitor progress at the site. This
resident said the information should be available to the
Billerica Board of Selectmen, the Board of health, and the
Billerica Public Library. One resident suggested that EPA
should send ongoing progress reports to the same list of
recipients.
. .. ~PA 's ReSDonse: EPA encourages community involvement
throughout the cleanup at the Shaffer Landfill/Iron Horse
Park superfund Site and is committed to a proactive community
relations program that will ensure public information is
released as it becomes available. with regard to local
availability or access to Site information, EPA has
established the Billerica Public Library as a local
information repository containing all information regarding
the Iron Horse Park Superfund Site, and as discussed earlier
sampling results will be made available at the Library. EPA
also issues site updates periodically or at milestones in the
remedial process. EPA also encourages residents to utilize
the agency's designated information contacts that appear in
all fact sheets and press releases whenever they have
questions and comments regarding site activities.
Comment 0: During the informal public hearing, Billerica's
State Representative Brian M. Cangiamila said that EPA's
preferred cleanup option for the site should address existing
arsenic contamination in the groundwater by extracting and
treating groundwater. He recommended that EPA consider it's
alternatives S or SA for cleanup of the Site. In his written
comments he applauded EPA, the Town of Billerica and the
Superfund Action Committee's work. Rep. Cangiamila's written
comments mirrored those of the Town of Billerica and many
others in urging for total cap reconstruction, an on-site
10
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G
leachate and groundwater treatment facility, improvements to
the gas venting and flare system, and financial guarantees
such as bonds or escrow accounts to assure future site
monitoring and cleanup needs can be met.
EPA's ReSDonse: Arsenic contamination in groundwater in the
vicinity of Iron Horse Park is not limited to the Shaffer
Landfill area. Some degree of arsenic may be a natural
occurrence in the area, although the Shaffer Landfill may
contribute to increases in arsenic downgradient (arsenic has
been detected downgradient of the Landfill at higher levels
than have been detected upgradient). Improvements to the cap
to reduce percolation of precipitation through the refuse
would be more effective than groundwater extraction and
treatment for addressing what may to be a natural presence of
arsenic. As discussed earlier, EPA believes that no one is
currently consuming this affected groundwater.
Comment D: A resident said that EPA should develop concentric
rings of monitoring wells that could precisely locate the
speed and direction of any leachate migration. Another
resident said that there should be a series of wells adjacent
to the Landfill, and another adjacent to property lines.
EPA's ResDonse: EPA'S Selected Remedy includes groundwater
monitoring. The monitoring system will include a series of
wells po~ ~loned to provide data on migration of groundwater
and potential contamination. The final number,
configuration, and depth of monitoring wells to be included
in the monitoring network will be addressed during design of
the remedial action.
Comment a: A Billerica Town selectman commented that EPA
should require before and after stack monitoring of the gas
collection/flare system to make sure that no hazardous
chemicals are being burned at improper temperatures.
EPA's ReSDonse: Monitoring of the gas flare is a part of
EPA's Selected Remedy, as well as long-term operation and
maintenance of the gas system. EPA agrees that monitoring
should be done both before and after combustion to assess the
effectiveness of the process as well as monitor for
incomplete combustion residuals.
Comment r: A Billerica selectman said that any groundwater
treatment should be done off-site because on-site treatment
would be too costly and an on-site treatment plant could be
damaged by vandalism.
EPA's ResDonse: No groundwater treatment, either on-site or
off-site, is proposed. If reference is to leachate
treatment, the Selected Remedy requires off-site treatment.
11
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Comment s: A resident said that EPA has assumed that the
portions of the cap that won't be reconstructed have been
properly installed, an assumption that he believes is not
well founded given the Landfill owners past failure to comply
with regulatory requirements. He added that there is no
information in EPA documents that would back up this
assumption. He also said that EPA should be concerned about
whether the existing cap can adequately protect against frost
damage in the absence of a drainage layer.
EPA's ReSDonse: On pages 5-10 and 5-11 of the Feasibility'
study, it was explicitly noted that deficiencies in the cap
existed, but that the investigations needed to delineate
deficient areas would be more detrimental than helpful. In
EPA's Selected Remedy the entire Landfill cap is to be
reconstructed and will include a drainage layer.
(
Comment t: A resident suggested that EPA should include some
institutional controls to prevent future residents from
drinking groundwater near the Landfill and to protect them
from exposure to contaminated soils. The Massachusetts
Department of Public Health, in its written comments, also
suggested institutional controls as a way to restrict future
groundwater and surface water use to protect the public
against exposure.
EPA's ReSDonse: Ir ~itutional controls will be placed on the
property to prevenc future use of groundwater beneath the
Landfill as well as throughout the contaminated plume as
drinking water and to prevent activities from being conducted
on the Landfill surface that would compromise the integrity
of the cap or otherwise compromise the protection of human
health and the environment.
Comment u: A Billerica selectman suggested that EPA should
have given a cost estimate for retrofitting the Landfill with
a complete liner. He said that such an estimate would show
the true cost of proper disposal at the Landfill and would
therefore show that the selected solution is reasonable from
a cost perspective.
EPA's ReSDonse: The cost for retrofitting the Landfill with a
liner would be so large that it would have little meaning.
There would be no validity to the cost estimate because the
activities required to implement such a remedy would
effectively be impossible.
Comment v: One resident sent a written comment to EPA which
stated that site neighbors deserve the most thorough and
complete cleanup that is technologically feasible.
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o
EPA's ResDonse: EPA feels that the Selected Remedy is the
remedy which is most consistent with CERCLA; by being
protective of human health and the environment, attaining
ARARS, and being cost effective. In addition, the remedy
satisfies CERCLA's preference for treatment and utilizes
alternative treatment technologies or resource recovery
technologies to the extent practicable.
Comment w: In a written comment, Representative Edward J.
Markey, U.S. congressional representative for the Billerica
area, agreed with town officials and many other commentors
that EPA should recommend total reconstruction of the
Landfill cap. In addition, Rep. Markey supports the
implementation of a comprehensive monitoring program that
includes contingencies for treating groundwater should that
be necessary.
EPA's ReSDonse: The Selected Remedy includes total
reconstruction of the Landfill cap and monitoring of
groundwater and surface water. As discussed in the response
to comment A.l.i, monitoring data will be evaluated to
determine if further remedial action is necessary.
Comment x: The Billerica Board of Selectmen, Board of Health,
Conservation commission and the Superfund Action Committee
commented that they supported a total cap reconstruction for
the Landfill, implementatir }:~f institutional controls to
prevent exposure to site contaminants and prevent the future
use of on-site groundwater, the implementation of a Natural
Resource Damage Assessment as provided for by CERCLA ~ 107, a
groundwater extraction and treatment program, a leachate
collection and treatment system complete with extra funding
for future potential costs, off-site leachate treatment,
on-site disaster recovery procedures and equipment, emergency
groundwater containment and treatment plans (in case of
spills), the public disclosure of all cleanup plans and
procedures, independent testing and monitoring of compliance,
full up-front funding which includes an emergency contingency
plan, transportation of materials, particularly hazardous
materials, by rail, and the cleanup of Richardson Pond.
Patricia McGovern, State Senator for the Town of Billerica,
supported most of these recommendations in a separate letter
to EPA.
EPA's ReSDonse: Several of the remedial elements proposed,
such as total cap reconstruction, leachate collection and
off-site treatment, and monitoring, are included in EPA's
Selected Remedy. As noted in the response to comment A.l.l,
groundwater extraction and treatment is not included, and the
reasons are cited therein. Emergency procedures are
discussed in response to comment A.l.h. Institutional
controls are discussed in the response to A.l.t.
13
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u
Transportation of materials for the remedial action by rail
will be considered along with other options during the final
design. As discussed in the response to A.l.l, Richardson
Pond and the rest of the surface water at the Site will be
addressed as a part of the 3rd operable unit. The Natural
Resource Trustees, which include the Department of the
Interior, the Department of Commerce and the Commonwealth of
Massachusetts, are the entities that make the determination
of whether a Natural Resource Damage Assessment is warranted
at a given site, and the Trustees have not indicated that a
Damage Assessment is warranted as yet.
Comment v: In addition to its jointly submitted comments, the
Billerica Conservation Commission made the following points
in their comment letter: the source of contaminants to
Richardson Pond needs to be resolved, encroachment of
Landfill slopes into wetlands should be a last alternative to
slope stabilization (they recommend erosion blankets or other
aggressive stabilization measures), on-site leachate
collection is necessary, detailed groundwater monitoring
should be implemented with contingencies for treatment if
groundwater quality exceeds MCLs, and a representative of the
Town should participate in review of the remedial design
submittal.
EPA's Response: No further encroachment into wetlands by
Landfill slopes, on-site leachate c(~ction, and groundwater
monitoring are all included in EPA's Selected Remedy.
Regarding resolution of the source of contaminants to
Richardson Pond, the reconstructed cap in combination with
the leachate collection system will address the Landfill as a
source of contamination. However, the actions will not
resolve other potential groundwater contaminant sources
within the industrial park nor possible upgradient surface
water sources. As discussed in response to A.l.l, the study
of site surface waters will be a part of the 3rd operable
unit. As discussed in the response to comment A.l.n,
mechanisms are in place which ensure that information
regarding the Shaffer Landfill/Iron Horse Park Superfund Site
continues to be made available to the public in a timely
manner. In addition, EPA encourages representatives from the
town, local residents and other concerned parties to review
final remedial design documentation and provide our agency
with any comments or concerns they may have.
Comment z: The Billerica Board of Health, in addition to its
jointly submitted comments above, identified the following
items that it feels need to be addressed in EPA's selected
cleanup plan: a groundwater extraction and treatment system
should be installed to protect the Tewksbury wellfield, total
cap reconstruction should take place, the methane collection
system should be upgraded, Richardson Pond should become a
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o
-'
main focus of the Landfill cleanup, and EPA should require an
extensive, sufficiently funded operation and maintenance
program for at least the next thirty (30) years.
EPA's ReSDonse: As discussed in response to A.l.k, it has
been shown that Tewksbury's public water supply wellfields
are unlikely to become contaminated due to discharges from
the Landfill Total cap reconstruction and operation and
maintenance activities are to be included in the EPA's
selected remedy. Groundwater extraction and treatment is not
currently considered necessary as discussed in the response
to A.l.l. Improvements to the landfill gas control system
are discussed in response to comment A.l.b. Cleanup of
Richardson Pond is discussed in the response to comment
A.l.l. As discussed in response to comment A.l.a, financial
assurance mechanisms covering all site work would be a part
of any agreement with responsible parties. operation and
maintenance are included as part of the Selected Remedy.
Comment aa: In addition to the jointly submitted comments
noted above, the Billerica Board of Selectmen submitted
copies of correspondence between the Massachusetts Health
Research Institute, Inc. and the Agency for Toxic Substances
and Disease Registry (ATSDR) dated April and June, 1990.
This correspondence discussed a pre-application for funding
from ATSDR to conduct a health study regarding "Environmental
Exposure to Asbestos and its Impact on Healtt ~~n the
communities of Billerica and Walpole, Massacnusetts". The
Board also requested that it be given the opportunity to
comment on future phases of the cleanup throughout the 30
year remediation period.
EPA's ReSDonse: The corresponden~e submitted regarding plans
for on-site health studies are independent of any Superfund
activities at the Shaffer Landfill. Although EPA is required
to conduct only one formal public comment period during the
Superfund process, EPA's Region I office encourages the
public to submit comments and questions at any time
throughout the duration of cleanup activities. EPA welcomes
any comments or input the Billerica Board of Selectmen and
the public would like to provide.
Comment bb: The Billerica Town Finance committee submitted
written comments which stated that the Superfund Action
Committee's proposed remedial actions would best protect
residents and future generations and would save taxpayers
money in the long run.
EPA'S ReSDonse: See response to comment A.l.x.
Comment cc: The Massachusetts Bay Transportation Authority
(MBTA) stated in a written comment that it was opposed to any
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alternative cleanup plan that interfered with its existing
railroad right of ways.
EPA's ResDonse: EPA's Selected Remedy will not
with existing railroad right of ways.
Comment dd: One written comment said that EPA's selected
alternative for cleaning up the Shaffer Landfill ignored the
impacts of the dump on the surrounding environment,
specifically the impacts on fish and wildlife in Richardson
Pond, groundwater beneath the Landfill which won't be helped
by a leachate collection system built above the water table,
and downstream receptors of Content Brook - Pomps Pond in
Andover, Camp Marymeeting (Girl Scout camp in Andover) and
Dragoonian Farms.
interfere
EPA's ReSDonse: The Selected Remedy provides controls to
reduce the potential release of additional contaminants into
the environment with the reconstruction of the Landfill cap
and the installation of the leachate collection system. with
these mechanisms in place to minimize further introduction of
contaminants into the groundwater, natural attenuation
processes will be better able to mitigate any existing
groundwater contamination past the point of compliance (the
edge of the waste management unit). Because the groundwater
and surface water are dynamic systems, natural flushing and
degradation of contaminants will occur once the on-go: J
source of contamination has been controlled. Cleanup vf
Richardson Pond as well as other surface waters is discussed
in response to A.l.l.
Comment ee: The Massachusetts Dept. of Public Health said, in
its written comments, that EPA's conclusion that
contamination of the Tewksbury wells by the Landfill is
'unlikely' is supported by MADEP monitoring results at the
wells which show no significant VOC concentrations.
EPA's ReSDonse: This statement is a revision of a previous
conclusion contained in the 1988 and 1990 (amended) document
entitled "Assessment of Public Health for Iron Horse Park".
This revised conclusion supports the conclusion documented in
the Feasibility study regarding risk of contamination to the
Tewksbury wells.
h
Groundwater and Surface Water
Comment a: Several residents and Billerica Town
officials commented that the Landfill was originally
built by excavating below the pre-existing surface
topography, and that materials may have been placed
below the water table level in the Landfill. One
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. . .
(I
resident claimed that the excavation was as much as 15
to 20 feet below the pre-existing level of the wetlands.
If landfilled material was placed below the water table,
this means that a leachate collection system will not
effectively prevent all contaminants from reaching the
groundwater.
EPA's ReSDonse: Refuse previously placed below the
groundwater table was immersed in water upon placement.
Soluble contaminants would have begun leaching
immediately and, if the material has been in place for
several years, there would not be much likelihood for a
substantial source to remain. The much greater mass of
refuse above the water table in the Landfill may still
contain significant volumes of contaminants with the
potential to migrate to the groundwater as a result of
infiltration of precipitation. The proposed
reconstructed landfill cap is intended to significantly
reduce infiltration of precipitation and thereby isolate
those contaminants within the Landfill mass.
Comment b: Several residents said that EPA should
institute a groundwater extraction and treatment program
as part of its solution at the Landfill. Reasons cited
as justifying such a program were: the placement of some
landfilled materials below the water-table, the
possibility of future releases from leaking drums or
chemical sources, the existence of background levels of
arsenic, and the current and potential future use of
groundwater wells by Landfill abutters.
EPA's ReSDonse: At this time, there does not appear to
be justification for groundwater extraction and
treatment. Placement of landfilled materials below the
water table is discussed in the response to the previous
comment. There is very little evidence that suggests
that drums were placed in the Landfill. The possibility
of future releases from leaking drums is addressed by
providing adequate containment with an improved cap,
thereby minimizing the infiltration of precipitation
which is needed to transport the leaking material
through the surrounding refuse to the groundwater.
Background levels of arsenic are by definition (i.e.
"background") the result of natural conditions, cannot
be controlled through extraction and treatment of
groundwater and cannot be addressed under Superfund.
Potential use of groundwater can be prevented through
institutional controls.
Comment c: Several residents noted that leachate
breakouts on the Richardson Pond side of the Landfill
are contaminating the Pond because leachate is migrating
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<,
through existing culverts underneath the railroad.
According to one resident, the FS does not address this
hydrologic connection between the Landfill and the Pond.
EPA should block these culverts, build some containment
structure, such as vertical barriers, or do something
else to prevent landfill leachate contamination from
reaching the pond through this drainage pathway.
EPA's ReSDonse: The final design should include
permanent interruption of any old railroad culverts
buried under refuse that may be acting as conduits for
leachate to Richardson Pond. In regard to overland
migration of leachate to culverts that are still
functional, that migration should be mitigated by the
proposed reconstructed cap and addition of the leachate
collection system.
Comment d: A resident said that, in light of EPA claims
that fractured bedrock underlies part of the site, EPA
should make an attempt to stop contaminants from
migrating to the Tewksbury wellfield.
EPA's ReSDonse: The fractured bedrock is significant in
regard to the discussion of possible vertical barriers
to groundwater movement. Because the upper portion of
the bedrock is fractured, a permanent seal cannot be
provided at the base of a vertical barrier, thus making
such a barrier ineffective. However, this fracturing of
the upper portion of the bedrock does not compromise the
effectiveness of the natural geologic barrier to
groundwater movement in the direction of the Tewksbury
wellfield.
Comment e: One resident said that groundwater should be
contained on site.
EPA's ReSDonse: containment of groundwater is not
attainable due to the fractured nature of the bedrock in
the vicinity of the Landfill. (See previous response)
Comment f: A resident asked that EPA show risks from
groundwater at the Landfill in more realistic terms than
the risk to someone who drinks two quarts of groundwater
every day for seventy years.
EPA's ResDonse: By calculating risk to a person
consuming two quarts of water per day for seventy years,
EPA has tried to establish a reasonable worst case
scenario for this exposure route. Most people would
have less exposure, thereby decreasing their risk. This
method is standard EPA practice, and is consistent with
EPA guidance.
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Comment a: A resident said that there are surface waters
near the Landfill that have not been tested.
Specifically she cited a large pond between 90 and 100
Gray st. and a "goOd-sized" pond next to 113 Gray st..
EPA's ReSDonse: These surface waters are located beyond
the boundary of the site. Because groundwater data does
not indicate a likelihood of off-site surface water
contamination resulting from a groundwater/surface water
interconnection these waters were not investigated.
Comment h: A resident said that a consultant hired by
the community found radioactive tritium in pools "near
the rear of the test site" in 1989 at levels that were
seven times the ambient level for the area. This shows,
according to the resident, that something had been
dumped in the Landfill that clearly shouldn't have been,
and she asked if EPA knew of any such dumping.
EPA's ReSDonse: EPA is not aware of a dumping event
involving tritium.
Comment i: A resident expressed concern about soil and
water testing. He noted that he lived about 1 mile down
Content Brook from the site, and that he had experienced
color variations and odor problems from the Brook. He
asked if testing of the Brook has been done that far
from the Site, and he said that soil testing should be
done within a one mile radius of the site.
EPA's ReSDonse: Other than wind and water erosion, there
are no other mechanisms to naturally move contaminated
soil from the point of rele~se to off-site locations.
In regard to the Shaffer Landfill and its associated
contamination, there is no reason to expect off-site
soil contamination based on wind and water erosion, and
there would be no justification for soil testing "within
a one mile radius of the site". As such, this testing
has not been performed. Regarding color variations and
odor problems in the Brook one mile from the Landfill,
there may be some connection with the Landfill.
However, given the distance from the Landfill, there
would be the potential for other sources or causes.
Also, for surface water problems to be observed at a
distance of one mile from the site, more severe problems
would be expected in the vicinity of the Landfill than
have been found to date. In addition, as discussed in
response A.l.l, site surface waters are to be studied as
a part of the 3rd operable unit.
Comment ;: The Massachusetts Department of Public Health
noted that elevated benzene levels were detected in
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groundwater southwest of the Landfill. The Department
suggested that groundwater flow in this area should be
determined in order to assess the possibility of
environmental exposure to this compound.
,';
EPA's ReSDonse: Groundwater flow in this area (well OW-
8) is to the northeast, and is clearly upgradient of the
Shaffer Landfill.
~
Miscellaneous Comments
Comment a: A businessman said that he is attempting to
develop a landfill gas recovery system for the Shaffer
landfill that will collect methane from the Landfill,
pipe it to another site within Iron Horse Park, and use
it to produce energy that would be used for industrial
processes and to generate electricity. He said that
such a system would be environmentally beneficial, and
that it would not interfere with any plans for capping
the Landfill or collecting leachate. He also said that
he would meet all Mass. DEP and EPA permit requirements.
EPA's ReSDonse: The primary goal of the Superfund
program is to provide remedies that are protective of
human health and the environment. Any potential future
use or actions would need to support this goal in order
to be considered.
Comment b: Several residents requested EPA to initiate a
natural resource damage assessment as provided by
section 107 Paragraph D of CERCLA.
EPA's ResDonse: As discussed in the response to comment
A.l.x, the Natural Resource Trustees make the
determination of whether a natural resource damage
assessment is warranted. In addition, during the remedy
selection process, EPA has coordinated with the Natural
Resource Trustees in order to seek their input on the
Landfill remediation.
Comment c: A town selectman from Billerica said that the
lack of documentation for what was actually dumped in
the Landfill, the absence of a liner and the fact that
the Landfill was built some 15 feet below the existing
grade all create special problems for the site. He
added that the current lack of site security makes it
possible for additional unauthorized materials to be
brought to the site.
EPA's ReSDonse: The absence of documentation for what
was dumped at the Landfill has made it difficult to
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o
document the specific items and materials which were
disposed of there. There is, however, significant data
on area contamination which is a result of the material
disposed of in the Landfill. As a result, EPA has been
able to select a remedy for the Shaffer Landfill which
is protective of human health and the environment. The
issue of site security is addressed in the Selected
Remedy by the perimeter security fence.
Comment d: One resident commented that local wildlife
and neighborhood pets have been effected by
contamination in Content Brook, and said that EPA should
make an attempt to clean up the area that goes beyond
just covering the Landfill.
EPA's ReSDonse: As discussed in response to A.l.l., the
study of site surface water will be a part of the 3rd
operable unit.
Comment e: A resident commented that EPA must allow
construction plans for the Landfill to be reviewed by
the town and its engineers, and that there should be
citizen monit~ring of the cap, maintenance agreements.
and leachate collection systems and that periodic
reports should be made back to the government by citizen
monitors.
EPA's ReSDonse: As previously stated in the response to
comment A.l.y, EPA encourages citizen review of final
design plans which will be placed in the information
repository. Any information local community members can
provide EPA is welcomed by the agency. EPA invites any
periodic reports that local citizens wish to submit.
Comment f: Several residents said that there is a need
for a new round of groundwater, surface water and air
testing. They said that the 1988 and 1987 data, the
most recent data cited in the FS, are not adequate for
establishing background contaminant levels prior to
cleanup, particularly since groundwater at the site is
estimated by EPA to be moving at 50 to 100 feet per
year. One speaker noted that two-year old data was not
adequate for the purpose of designing a cleanup
solution. Residents are also concerned that containers
of hazardous substances buried in the Landfill may begin
leaking over time, causing groundwater contamination to
increase.
EPA's ReSDonse: Additional sampling will be a component
of the final design and ongoing sampling will be part of
the long-term monitoring program. The most significant
mechanism for allowing migration of contaminants to the
21
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groundwater, is the infiltration of water. The Selected
Remedy, through the implementation of a more impermeable
cap, will largely remove this mechanism.
Comment a: A resident said that in one of EPA's surface
water testing reports, methylene chloride was detected
at levels of 1300 parts per billion, and acetone was
detected at around 800 parts per billion, and that these
levels were considered to be lab or field contamination,
and were therefore downplayed or ignored. The resident
noted that 1983 testing performed for the community by
Cambridge Analytic found levels of 1100 parts per
million of methylene chloride and 850 parts per million
of toluene and that this result was confirmed by
repeating the test. The resident suggested that EPA
should review the initial data to make sure that EPA's
FS recommendations are based on correct information.
EPA's ReSDonse: Review of the test report results from
Cambridge Analytic showed that the results were in parts
per billion, not parts per million, indicating much
lower levels than stated in the comment. As noted in
the response to comment A.3,g, additional groundwater
sampling will be performed during final design.
However, results such as those reported would not change
the proposed remedial action.
Comment h: One resident said that he had consumed water
from a groundwater well adjacent to the site for 5 years
and has now developed kidney failure. While
acknowledging that he didn't know if this was caused by
drinking groundwater from the well, he said that he
wants EPA to make sure that nobody alse is exposed to
this potential hazard, even if it costs $50 million
dollars to do it.
EPA's ReSDonse: As stated in section VI of this Record
of Decision, as well as in other documents, EPA believes
that currently groundwater in the area around the
Landfill is not being used for drinking water due to the
presence of a municipal water supply. Institutional
controls will prevent the development of new drinking
water wells. The implementation of the Selected Remedy
which includes a more impermeable cap and the collection
of leachate, will combine to reduce groundwater
contamination naturally.
Comment i: A written comment stated that the commentor
is exploring plans to use space at the Landfill as a
composting facility that accepts leaves, garden and yard
waste from surrounding communities. The plan described
in the letter envisions covering the Landfill cap with
22
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v
~
considerable amounts of compost. The letter also noted
that the Landfill, with proper beautification, soil
cover and vegetation, could serve as a publicly
accessible refuge for wildlife.
EPA's ResDonse: Any future use of the Landfill would
have to be reviewed to ensure that it is protective of
human health and the environment and is not inconsistent
with institutional controls placed upon the property.
Comment ;: The MA Department of Public Health (MADPH)
said that elevated incidence of lung cancer was detected
in the census tract immediately north of the Landfill,
and that lung cancer rates for males who live within a
one mile radius of the site between 1969 and 1985 were
elevated relative to males in the remainder of the town
during this period. MADPH suggested that, prior to
1984, residents could have been exposed to hazardous
asbestos levels from the inadequately covered asbestos
landfill in Iron Horse Park. It also stated that there
is no identified ongoing exposure to lung carcinogens at
the site. To identify the actual cause of elevated
cancer rates, occupational and smoking histories of
current and former residents should be considered, radon
levels should be measured, and an effort to measure the
degree of past asbestos exposure should be made.
EPA's ReSDonse: EPA has not identified any hazard from
asbestos at the Shaffer Landfill. Additional testing of
Landfill gases with regard to composition and the
potential for on- and off-site exposure is a part of the
Selected Remedy.
Comment k: MADPH suggested that on-site and off-site
ambient air monitoring is necessary to assess whether
gasses leaking through the Landfill cap pose a health
risk. Also, because landfill gasses may migrate
laterally, it may be prudent to monitor subsurface
methane levels off-site.
EPA's ReSDonse: Air monitoring is a part of the selected
remedy. Because the Landfill is surrounded by natural
surface water barriers (Richardson Pond, Content Brook,
and the Middlesex Canal), EPA does not see the necessity
for off-site subsurface monitoring of methane levels.
Comment 1: MADPH said that barrels with unidentified
contents were observed on the Landfill during a recent
site visit, and it suggested that the content of these
barrels should be characterized and properly disposed.
EPA's ReSDonse: The determination was made by an EPA On-
23
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Ci
:;,
Scene-Coordinator (OSC) that these barrels (in a fenced-
in storage area near the property entrance), were stored
for use by heavy equipment on site (lubricants or fuel),
or were empty, and present no imminent hazard.
B.) summary of Comments from potentially Responsible parties
(PRPs)
Three sets of comments from PRPs or their representatives
were received, including:
Rick Shaffer (Suffolk Services)
Balsam Environmental Consultants (for Graypond Realty
Corp. )
Wright & Moehrke, counselors at Law (for Graypond
Realty corp.)
The main points made by the PRPs are summarized below.
The PRP comments are organized by commentor.
~ Comments from Balsam Environmental Consultants.
enqineerinq consultants for GravDond Realtv CorDoration.
Comment a: c~~'acterization of the groundwater flow
system does not adequately support the selected
alternative. Downgradient monitoring wells may also be
downgradient of the Iron Horse Park site as a whole.
Therefore, impacts solely attributable to the Shaffer
Landfill are not separated from other possible sources.
(Balsam comments, pp. 1-2)
EPA's ReSDonse: The substance of this comment contends
that there is no documentation for or understanding of
regional groundwater flow and therefore a valid
interpretation of local groundwater flow could not be
developed. The Phase lC Remedial Investigation deals
with the Shaffer Landfill specifically. The Phase 1A RI
considered the industrial park as a whole, and addressed
such topics as regional groundwater flow. Sufficient
information is available in the various studies to
arrive at the conclusions stated. In addition, CERCLA
remedies must be protective of human health and the
environment, and must attain all ARARs. The possibility
that some contaminants that contribute to risk or
violation of ARARs may be attributable to sources other
than the Landfill, does not alter the remediation
requirements of CERCLA (i.e. MCLs in groundwater must
still be met).
24
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Comment b: Characterization of sources of contamination
(within Shaffer Landfill) does not adequately support
the selected alternative. A comprehensive evaluation of
closure activities undertaken at the Landfill through
1990 is not presented in the RI/FS. Such an evaluation
would affect assessment of impacts on this operable
unit. (Balsam comments, pp. 3-4)
EPA's ResDonse: A number of data points, including well
MW-1, and well cluster OW-49, 50, 51, were used to
provided hydraulically upgradient conditions reflecting
contaminant background levels prior to impacts resulting
from the Landfill. The RI/FS does discuss closure
activities at the Landfill up through 1990. During this
time, observations were made of air quality violations
from Landfill gas, Landfill gas percolating through the
cap, erosion problems, leachate outbreaks, inadequate
slope areas, and unvegetated areas, all of which pointed
directly to adverse impacts.
Comment c: The RI/FS overestimates risks associated with
potential future use of on-site ground water. (Balsam
comments, pp. 5-6)
EPA's ReSDonse: Risk computations are based on observed
contaminant levels, aod are performed in conjunction
with standard EPA pre ice. This practice is
conservative by design, and is intended to account for a
worst case (i.e. drinking 2 liters of contaminated
groundwater per day for 70 years).
Comment d: The RI/FS does not demonstrate that an
imminent hazard exists or that future risks beyond the
site boundary exist. (Balsam comments, p. 7)
EPA's ResDonse: The NCP requires that ARARs including
. drinking water requirements, must be met beyond the edge
of the waste management unit, which in this case is the.
boundary of the Landfill. The potential risk associated
with consumption of groundwater beyond the edge of the
waste management unit (at well GZA-3) is 2.2 x 10-02
which is unacceptable.
Comment e: The Selected Remedy should contain
flexibility with respect to leachate collection,
transportation and treatment. (Balsam comments, pp.
8-10)
EPA's ReSDonse: Assumptions were used in the Feasibility
Study to provide a basis for assessing the conceptual
feasibility of leachate collection and treatment. Final
design of leachate collection facilities will consider
25
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:..J
"
several estimates including the cap design and
composition and recalculated estimates of leachate
generation. As leachate collection continues following
implementation, the quality of the leachate will most
likely change over time, and alternate disposal options
may become available. However, until a data base of
leachate volume and quality has been established, a
conservative disposal method has been assumed. Leachate
will be tested to determine the applicability of
disposal options.
Comment f: The Selected Remedy should contain
flexibility with respect to the Landfill cover design.
(Balsam comments, pp. 11-14)
EPA's ResDonse: The Selected Remedy does contain
flexibility with respect to the Landfill cover design in
areas of excessive slope. with regard to closure work
undertaken on the cap, additional investigation of the
closure work was conducted as part of the RIjFS. The
response to comment B.l.b., discusses some of the
deficiencies which currently exist in spite of closure
activities which have taken place to date. The presence
of these deficiencies as well as the requirements in
CERCLA necessitates the undertaking of additional
remedial action.
~O!
Comment a: A decision to implement a groundwater remedy
based on the assumption of future on-site groundwater
use at the Shaffer Landfill operable unit would be
inappropriate for this portion of the superfund site.
(Balsam comments, pp. 15-16)
EPA's ReSDonse: Groundwater remediation is not currently
proposed. However, if on-going groundwater monitoring
indicated that the remedy is no longer protective, then
groundwater extraction and treatment may be considered.
h
Comments from Wriaht & Moehrke. lawyers for GraVDond
Realtv COrDoration
Comment a: Challenges to the use of Superfund to deal
with this Landfill.
EPA's ReSDonse: Section l05(a) (8) (A) of CERCLA requires
that the National Contingency Plan (NCP) include
criteria for determining priorities among releases or
threatened releases throughout the united States for
purposes of taking response actions. Section
l05(a) (8)(B) requires that these criteria be used to
prepare a list of national priorities among the known
26
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releases throughout the United states. This list is the
National Priorities List (NPL). The Shaffer Landfill is
part of the Iron Horse Park site that was included on
the NPL on September 21, 1984, in accordance with the
criteria developed pursuant to the NCP. The opportunity
to challenge this listing was at the time the site was
placed on the NPL. 42 U.S.C. 9613(a) Therefore, it is
consistent with the NCP that EPA be addressing this
problem under Superfund.
Comment
limited
to land
4-7)
b: Use of Superfund is inappropriate because of
risk off-site and other institutional barriers
and water use. (Wright & Moehrke comments, pp.
EPA's ReSDonse: CERCLA requires that all remedial
actions at Superfund sites meet applicable and relevant
and appropriate requirements (ARARs). At the Shaffer
Landfill, Maximum Contaminant Levels under the Safe
Drinking Water Act are ARARs at the Site and, therefore,
for the remedy to meet the requirements of Superfund,
these drinking water standards must be met at the
boundary of the waste management unit not just off-site.
~ 40 C.F.R. 300.430(e) (2) (i), 55 FR 8713, 8753, March
8, 1990. This is also consistent with Superfund
requirements that the remedy be protective of human
health and the environment. The commer. : has also
identified a number of institutional t~~d mechanisms
that could be used in lieu of EPA's selected remedy to
ensure that there is no risk to human health and the
environment from the Site. section 121 of CERCLA states
Congress' preference for treatment and permanent
remedies as opposed to simply prevention of exposure
thru legal controls. Although institutional controls
are used by EPA in the appropriate circumstances,
institutional controls should not substitute for more
active response measures that actually reduce, minimize,
or eliminate contamination unless such measures are not
practicable, as determined by the nine evaluation
criteria in 40 C.F.R. 300.430(f)(1)(ii). See 55 FR
8706, March 8, 1990. Here, EPA has determined that
there are active remediation measures that can be taken
after full evaluation of the nine criteria.
Comment c: EPA's site characterization overstates the
landfill threat by failing to distinguish leachate
impacts from site-wide groundwater impacts. (Wright &
Moehrke, pg. 7)
EPA's ReSDonse: The response to comment B.l.b indicates
that a number of valid data points were used to
distinguish between groundwater impacts due to the
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\.i
')
Landfill and those due to other sources.
comment d: EPA'S proposed plan does not reflect recent
significant Landfill upgrades. (wright & Moehrke, pp.
7-8)
EPA's ReSDonse: Additional assessment of the previous
closure work was conducted as part of the FS because the
RI was finalized while closure activities were still in
progress. These additional investigations noted several
deficiencies in the closure work, particularly in regard
to capping materials used and thickness of materials
placed.
Comment e: The DEP approved closure plan as an ARAR.
(Wright & Moehrke, pp. 8-9)
EPA's ReSDonse: Section 121(d) of CERCLA requires state
applicable or relevant and appropriate requirements
(ARAR) to apply generally to the regulated community.
The Massachusetts closure plan is site-specific in that
it is applicable only to the Shaffer Landfill. Because
of this, EPA cannot consider this plan to be an ARAR.
Comment f: RCRA is not an ARAR. (Wright & Moehrke, pg.
9) .
EPA's ResDonse: EPA has determined that RCRA Subtitle C
is not an applicable requirement because RCRA listed or
characteristic hazardous waste has not been disposed of
at the Landfill, nor has any treatment or storage of
hazardous waste occurred at the Landfill since the
effective date of RCRA Subti~le C. Portions of RCRA
Subtitle C are relevant and appropriate based on current
site specific information including: Groundwater
Monitoring, Tanks, contingency Plans and Emergency
Procedures, Locational Standards and RCRA Post Closure
Requirements. Contingency Plans and Emergency
Procedures, Groundwater Protection, Manifesting and
Record Keeping, Tanks, Closure and Post Closure and
Locational Standards may be applicable depending on the
results of leachate testing. The leachate will be
tested to determine if any of the RCRA requirements,
including land ban are applicable. The offsite leachate
treatment and disposal must meet all Federal and State
requirements. References to these provisions in
Appendix D are to the State hazardous waste regulations
that have been approved by EPA pursuant to RCRA.
h
Comments from Rick Shaffer
28
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Comment a: Information used as the basis for the
Feasibility study is obsolete.
EPA's Response: The response to comment B.2.d indicates
that assessment of previous Landfill closure work was
conducted during the preparation of the FS.
Comment b: All potential sources of contamination at the
Iron Horse Park site must be investigated before any
final remedial plan is approved.
EPA's Response: As discussed in response to comments
B.l.a., and B.l.b., work was performed to characterize
both regional groundwater trends, and to isolate
contamination attributable to Shaffer Landfill from
contamination due to other potential sources. The Iron
Horse Park Superfund Site was divided into operable
units following the Phase lA RI precisely because it is
a large and complex site. This allows remedies to be
selected for specific, distinct contamination problems,
and ultimately allows the time prior to the start of
remedial action to be lessened.
Comment c: The selected remedy should be flexible in
terms of allowing for future use of the Landfill.
EPA's Response: The primary goal of the Superfund
program is to provide remedies that are protective of
human health and the environment. Any potential future
use/actions would need to support this goal in order to
be considered.
Comment d: Bioremediation should not be excluded as a
potential remedy for groundwater or surface waters. The
success of wetlands near the site in treating impacted
water indicates that biological treatment of water at
the site may be viable.
EPA's Response: As discussed in earlier responses, site-
wide surface waters will be addressed during the Jrd
operable unit. There is no need to consider
bioremediation of groundwater at this time as the
Selected Remedy calls for attainment of cleanup levels
through natural attenuation.
Comment e: Background groundwater, surface water and
sediment contaminants are insufficiently characterized.
EPA's Response: As discussed in response to comments
B.l.a., and B.l.b., sufficient characterization of
background groundwater, surface water, and sediments has
been provided to demonstrate adverse impacts in and
29
-------
D-
"
around the Landfill which are specifically related to
the Landfill.
c.
comments of the Massachusetts Department of
Environmental Protection (MA DEP)
The MA DEP submitted comments on EPA's Feasibility study and
Proposed Plan. These comments are grouped by topic and
summarized below.
L.
ADDlicable or Relevant and ADDroDriate Reauirements
(ARARs)
Comment a: In its comments, DEP identified the ARARs
within its jurisdiction which it believes should be
applied when evaluating remedial action at the Shaffer
Landfill Operable Unit of the Iron Horse Park Superfund
site.
EPA's ReSDonse: EPA has met with DEP and agreed upon the
state ARARs that are identified in Appendix D of this
Record of Decision. EPA disagrees with DEP's
identification of the MCP, 310 CMR 19.021, 19.150, and
19.151 as ARARs and has not included them among the
ARARs for the Landfill.
Comment b: To meet the ARAR for final landfill cover,
DEP recommends that the top portion of the Landfill
should be upgraded to include 1) a low permeable layer
of compacted material 18" deep with a permeability of lx
10-7 ~ a flexible membrane liner and 2) a filter
material layer. DEP also recommends that the side
slopes of the Landfill should be upgraded to achieve a
minimum depth of 12" of compacted low permeability
material with the maximum permeability as specified in
the 1984 DEP-approved Closure Plan. DEP also recommends
upgrading the side slopes to achieve a 12" soil layer to
support vegetative cover. DEP believes these upgrades
would be an acceptable Alternative Landfill Final Cover
System Design as described in 310 CMR 19.113, and would
address DEP's concerns about current side slope soil and
clay-cover erosion.
EPA's ReSDonse: The Selected Remedy meets or exceeds the
DEP requirements for final landfill cover at the Shaffer
Landfill.
h
ImDlementation
30
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Comment a: DEP believes that the requirement to .
construct a fence and post signs should be implemented
immediately after the signature of the ROD. DEP will
pursue the construction and posting of the fence
independently to try to expedite this segment of the
remedy. DEP also suggests that because the adjoining
wetlands and canal pose a deterrent to trespassers, EPA
should allow for flexibility in fence design and should
monitor the effectiveness of a three-sided site fence.
.i
EPA's ReSDonse: During remedial design, EPA will
evaluate the appropriateness of phasing construction of
the remedy. In addition, EPA will evaluate the
appropriateness of a three-sided site fence during the
design phase of the remedy.
Comment b: DEP believes that treatment and disposal
options for landfill leachate should be evaluated and
selected during the predesign phase after the leachate's
chemical properties and characteristics are determined.
On-site leachate treatment should be evaluated for any'
reliability, health and safety, or cost benefits it may
have. The potential for disposal of leachate, with or
without pretreatment, directly to a local POTW via sewer
connection should also be evaluated. Finally
alternative leachate transportation schemes, such as the
use of the nearby rail system, should be evaluated.
EPA's ResDonse: Leachate treatment and disposal options
were evaluated in the FS. These options will be further
evaluated in the design phase of the remedial action.
Leachate discharge to the Billerica POTW was not
retained for consideration because of a moratorium on
sewer hook-ups at that facility. Off-site options for
transportation of leachate will be evaluated during
design.
h
Technical Comments
Comment a: DEP notes that all of the substantive
requirements that would be needed for the landfill gas
collection/flare system to obtain DEP Division of Air
Quality Control (DAQC) final approval should be
implemented as part of EPA's selected remedy for the
site even though, under CERCLA, no DAQC permit must be
obtained.
EPA's ResDonse: Massachusetts has identified its Air
Pollution Control laws as ARARs that will be met at the
Landfill. In addition, testing of the gas
collection/flare system and an air quality study are
31
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(}
'I
part of EPA's Selected Remedy. Proper long-term
operation and maintenance of the system is an integral
part of the Selected Remedy, and will include activities
such as well field balancing on a regular basis.
Submittal of as-built drawings, standard operation and
maintenance procedures, and design data and calculations
for the gas collection/flare system are all considered
to be necessary elements for ensuring proper long-term
operation of the facility. Obtaining this information
will be a part of the design and implementation of the
Selected Remedy. Testing of the collection/flare system
as well as ambient air quality have been identified as
ARARs and will be met.
Comment b: While DEP agrees that the Shaffer Landfill is
not a likely threat to the Tewksbury well fields, DEP
believes that only well MW-5 may be adequately
positioned to actually monitor groundwater quality
between the landfill and the wells. In addition, MW-5
is an overburden well and will not be effective in
monitoring bedrock groundwater quality. DEP recommends
that the 30-year monitoring program include adequate
monitoring to assure continued protection of the
Tewksbury wells.
EPA's ReSDonse: The long-term monitoring program is
expected to include some existing wells and several new
wells in order to provide a complete monitoring network.
Final locations for screen depths for the wells will be
determined during the design phase.
Comment c: DEP recommends that the expected leachate
volume from the Landfill be evaluated in detail during
the pre-design phase in order to design adequate
leachate storage capacity. On-site storage volume must
allow for several days storage in order to avoid daily
truck/railcar transport.
EPA's ResDonse: As noted earlier, further evaluation of
anticipated leachate volume will be made as part of the
pre-design and design activities. Sufficient storage
capacity can be provided to accommodate a reasonable
frequency of removal. It should be noted that the
leachate collection system will be a passive system with
no chance for overflow of storage units if removal is
unexpectedly delayed.
Comment d: DEP agrees with EPA's proposal to design a
leachate collection system to collect and treat only
leachate seeps at this time, however the Department
recommends that EPA evaluate the effectiveness of the
cap in controlling leachate and protecting groundwater
32
-------
over time before finalizing any decisions on extraction
and treatment of groundwater. DEP also notes that the
FS conceptual design should be revised to include an
impermeable barrier at the base of the trench for the
leachate collection toe drain.
EPA's ReSDonse: Part of the purpose of the groundwater
monitoring program is to provide data to assess the
possible need for additional remedial action. An
impermeable barrier will be included in the final design
of the leachate collection trench.
Comment e: DEP does DQt agree that landfill slopes need
to be upgraded to meet a 3:1 slope requirement, and
references a 7-19-89 memorandum regarding the
acceptability of 2:1 slopes on the south and west sides
of the Commercial section of the Landfill.
EPA's ReSDonse: The selected remedy does not require
that all Landfill slopes meet the 3:1 slope requirement,
and provisions are made for enhancing the stability of
the 2:1 slope areas.
33
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D
~.
Attachment A
community Relations Activities at the Shaffer Landfill section of
the Iron Horse Park superfund Site
september 1984
January 1985
June 1985
August 1985
October 1985
December 1985
1985-1986
July 1987
August 1987
August 1987
May 1988
August 1989
August 1989
August 1989
December 1989
EPA press release announces that $700,000 has been
authorized for a study of the Iron Horse Park
Superfund site
EPA press release announces a Remedial
Investigation (RI) Workplan for informal public
review and comment
EPA issues a press release announcing that EPA
representatives will be attending upcoming
Superfund Action Coalition (SAC) meetings to
present information on activities at the Iron
Horse Park Superfund site.
EPA releases a community relations plan describing
citizen concerns about the site and outlining a
program to address these concerns and to keep
citizens informed about and involved in site
activities.
At two separate meetings, EPA official briefs the
Billerica superintendent of Public Works and
members of the Executive Committee of the SAC on
the status of the site.
EPA releases a fact sheet to update the public
about the initial RI activities occurring at the
site.
EPA representatives continue to attend the public
meetings of the SAC to update them on the progress
of the initial RI.
EPA issues a press release and placed a public
notice announcing the availability of the Phase 1A
RI and an upcoming public meeting to explain the
results of the RI.
EPA releases a fact sheet on the Phase 1A RI.
EPA holds a public meeting to present the results
of the Phase 1A RI and to answer questions from
the pUblic.
EPA press release announces the availability of
Technical Assistance Grants (TAGs) for eligible
local groups. (The notice was prompted by EPA' s
receipt of a letter from the SAC indicating an
interest in the TAG program. The SAC did not
complete the application process for the grant,
however)
EPA press release and ads in local newspapers
announce public meeting on preliminary RI results.
EPA produces and distributes a Fact Sheet on the
preliminary results of the Remedial Investigation
at the Shaffer Landfill.
EPA holds a public meeting
preliminary results of the
EPA issues a press release
to discuss the
Shaffer Landfill RI
announcing the
-------
July 1990
December 1990
January 1991
January 1991
February 1991
May 1991
availability of the RI for the Shaffer Landfill.
An EPA press release announces the availability of
a TAG for interested local groups (This
announcement was made because the SAC did not
follow through with it's initial application for a
TAG)
EPA issues a press release announcing a meeting
and hearing to discuss the Proposed Plan and
Feasibility Study for the Shaffer Landfill
EPA distributes copies of the Proposed Plan to its
site mailing list.
EPA holds a public meeting on the Shaffer Landfill
Proposed Plan/FS.
EPA holds two informal public hearings on the
Shaffer Landfill Proposed Plan/FS.
EPA issues and distributes to its mailing list a
Supplement to the Proposed Plan for the Shaffer
Landfill, proposing a new preferred alternative
for Shaffer Landfill. The Supplement to the
Proposed Plan also discusses impacts on
floodplains by alternatives considered by EPA. A
30-day comment period on the Supplement to the
Proposed Plan is also announced.
-------
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A'1''1'ACHKEN'1' B
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ENVIRONMENTAL PROTECTION AGENCY
'I n Re:
Superfund Program
Shaffer Landfill,
Billerica, MA
Iron Horse Park
HEARING HELD AT THE BILLtRICA TOWN HALL
AUDITORIUM, BILLERICA, MASSACHUSETTS ON
FEBRUARY S,
1991.
PANEL:
Margaret Leshen, EPA
DOI\ McElroy, EPA
Elizabeth M. Brooks
Court Reporter
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SPEAKER:
10
carl Moore
Helen Knight
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John Morris
22
David L.
Johnson
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Tony Bonacci
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(Hearing convened)
MS. LESHEN:
We're going to get
started.
Good evening.
I'm Maggie
Leshen.
I'm Section Cheif for the
Superfund Section and I'm going to be
the moderator for this meeting.
I'm
going explain the procedure we're going
to be following.
Basically the meeting
is
going to be divided into three parts.
During the first part,
Don McElroy, the
s;te manager, is going to give you a
formal presentation about the proposed
plan and preferred remedy.
Then we will
be taking formal comments into the
record.
If you are going to be making a
formal comment this evening, you need to
fill out. small index card or if at any
time during the hearing portion of this
meeting you decide you want to make a
formal comment, you need to either go
and get a card or let someone know in
the back of the room that you want to
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make a formal comment and they will get
you a card.
After everyone's done, we'll close
the public hearing and we'll open up the,
meeting to any questions and we'll try
to respond to any questions you might
have this evening.
We have extended the public comment
period until March 16.
So what that
means is,
if at any time if you have
questions or comments you can contact-
the site .-nager, but we must receive
your written comments in our office by
March 16th and they should be addressed
to Don McElroy.
The address is on back
of the proposed plan available at the
desk.
We have also made a decision to
hold a public hearing in this very room
at 7:30, February 19th.
That is two
weeks from tonight.
We are going to be
following the same format as this
evening but normally at that point we
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will have more comment. entered into the
record.
I want you to understand that all
the comments received this evening in
the formal part of the hearing, any
comments received in writing prior to
March 16th in our office and any other
comments received will be responded to
in a Responsiveness Summary which will
be attached to the Record of Decision or
decision document for the remedy at the
Shaffer Landfill qite.
Copies of this
document will be available at the
library and at the office in Boston, and
the address and information as to when
the building is open are on the proposed
plan.
We have with us this evening the
EPA project manager Don McElroy a8 well
as Dale Young,
the state project
manager.
Does anyone have any questions on
how the meeting is 90ing to be run this
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evening?
If not, I'. going to ask Don
McElroy to give a short presentation
about the proposed plan.
MR. MCELROY:
The United States
Environmental Protection Agency has
proposed a cleanup plan, referred to as
the preferred alternative, to address
contamination at the Shaffer Landfill,
Iron Horse Park Superfund Site in
Bellerica, Massachusetts.
The proposed
alternative is EPA's preliminary
selection of a remedy ar '. may be changed
if public
new information is
comments or
presented to EPA during the public
comment period that significantly
affects EPA'8 evaluation of the
alternatives.
After evaluation of all eight
alternatives developed in the
Feasibility Study, EPA proposes
reconstruction of the top portion of the
existing landfill cap and the collection
portion of the existing landfill cap and
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the collection and off-8ite treatment
and di8po8al of leachate.
Cap
reconstruction would be achieved by
adding fill and regrading to achieve a
minimum 5' slope on the top, flatter
areas; installing additional low
permeability material; installing a new
6-inch drainage layer; reinstalling the
topsoil layer; and reseeding the
disturbed areas.
Leachate collection
facilities would be constructed,
operated, and maintained.
Leach"~.e
would be transported off-site for
treatment and disposal.
Improvements
would be made to the existing surface
drainage system.
The cap, the surface
drainage system, and the landfill gas
collection/flare system would be
maintained and monitored, and any
necessary improvements would be made.
A
site perimenter security fence would be
constructed.
Groundwater and surface
water quality would be monitored.
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If public coaaent and further
information change EPA'8 evaluation of
this or any of the other alternatives,
EPA may decide on another alternative
for its final selection.
I'd like to quickly run through the
other alternatives evaluated in the
Feasibility Study.
Alternative 1 is the no action
alternative under which no further work
at the site would take place
Alternative 2 would complete the
existing cap by adding fill to achieve a
5\ grade and reconstructing the
overlying low permeability layer.
This
alternative also would include;
maintenance of the cap, surface drainage
system, and landfill g88
collection/flare system; construction of
a site perimeter fence; and monitoring
of the gas collection/flare system and
surface water and groundwater quality.
Alternative 3 contains the same
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features as Alternative 2 .in teras of
completion and maintenance of the
landfill cap.
In addition, Alternative
3 would improve the existing surface
drainage system; construct, operate, and
maintain leachate collection facilities;
and transport leachate off-site for
treatment and disposal.
Alternative 3A contains all of the
features of Alternative 3.
In addition,
Alternative 3A would construct, operate,
and maintaip a groundwater extraction
system along the eastern side of the
landfill; construct, operate, and
maintain an on-site system £-or treatment
of groundwater and leachate; and
discharge treated groundwater to surface
water.
Alternative 4A contains all of the
features of the Preferred Alternative.
In addition, Alternative 4A would
construct, operate and maintain a
groundwater extraction system along the
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eastern side of the landfill, construct,
operate, and maintain an on-site system
for treatment of groundwater and
leachate; and discharge treated
groundwater to surface water.
Alternative 5 would completely
reconstruct the entire landfill cap to
meet EPA's recommended final cover
design standards for hazardous waste
landfills.
This alternative would also
provide the same maintenance,
monitoring, and perimeter fence as the
other alternatives.
Alternative 5A contains all of the
features of Alternative S.
In addition,
Alternative SA would construct, operate,
and maintain a groundwater extraction
system along the eastern side of the
landfill; construct, operate,
and
maintain an on-site system for treatment
of groundwater and leachate; and
discharge treated groundwater to surface
water.
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MS. LESHEN.
.;
We're now going to
start the formal comment portion.
We're
going to ask that you come forward.
The first person will be Carl
Moore.
MR. MOORE:
I'd like to ask a
question first.
I'd like to ask what
you people based your decision on as far
as selecting a number, a number 4, a
number S.
Was this from an engineering
study that was done here?
MS. LESHEN:
This is the comment
period.
We're not responding to
questions right
now.
MR. MOORE:
Okay.
Well,' I have
been in contact with this landfill for a
very many years here and I am an abutter
to Content Brook.
I'd like to make it
very clear to you people that there have
been people drinking water out of the
acquifer there.
There have been fish --
like on my property, which has
deteriorated over a period of years.
CATUOGNO COURT REPORTING SERVICES. INC.
PlnlfI8Ic:I. MA (413) ~7283
88 Long Wharf HIttfonI. CT (203 52W087
Bolton. MA 0211().3810 Northampton. MA (413) 58&-3588 _1II1II
(817) 72).OM) TUECOPISI (413) 738-4221
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There have been -- there has been a
situation on my street where dogs have
gone into convulsions and have died.
In
fact, I had a dog that drank water out
of the brook, which I made public some
time ago,
that bled through the skin
before it was put away.
The effects to the wildlife in the
area,
I feel, have been greatly affected
and I feel that any attempt, any attempt
at all, would have to be the best
attempt, as far as cleaning up this site
goes,
that we can make,
that just a mere
cover over
the landfill is not adequate
under these circumstances.
Some of the trips to the landfill
that I found -- I found ,there they had
excavated materials down into the water
table, or surface water,
lying
completely visible.
We have bottles of
chemicals,
of drums which may well have
been chemicals.
Therefore I feel that
very strongly that you're going to need
1385 Main SIr8II
Springfield. MA011.1815
(413) 732~100
CATUOGNO COURT REPORTING SERVICES. INC.
PmafIIId, MA (413) 443-7283
. Long Wharf Hartford. CT (203 52S-3081
Bolton. MA 0211g,a10 Nof1tI8mpIOII. MA (413) 58&-3588 _nl..
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(_131732"100
14
groundwater extraction and just about
everything you've got on your list needs
to be elected.
I have done an awful lot of
investigation on the landfill and one of
the things that I have looked at has
been the breakout of leachate into
Richardson Pond, and I have investigated
the B , M Railroad limits, which are
record copies of drawings, as to when
and how that railroad was constructed.
I have found that there has been a
breakout into Richardson Pond.
As everybody knows,
in the past I
have seen where there has been an
erasure on the linen [sic] and I have
recently visited the B , M and looked at
the particular drawings in the past
week.
I feel that a great part of the
decision that you people have made here
has really not been done on the sound
engineering studies.
I'm looking at a
CA TUOGNO COURT REPORTING SERVICES. INC.
Plttafleld. MA (413140-7283
II Long Wharf Hlrtfofd. CT (203 525-3011
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bedrock pos.ibility here, where we talk
about fractured bedrock, and on GHR'S
report that I have here in front of me,
I believe that on -- I could give you
the page right now -- they say that we
should have bedrock boring back previous
to this, and I have seen -- as far as I
know --
I don't know if there are any
bedrock borings at this point but we do
talk about fractured bedrock.
if
Now,
we. have fractured bedrock, that's all.
that much more reason to protect Cook
Street wells.
We need to make an
attempt to stop the contaminants from
coming out of the landfill and over into
Cook Street wells.
A180 I believe that any
construction plans or drawings that are
done must and should be reviewed by the
town and its engineers.
Also I believe
that all -- that all of the people
involved here, there should be some
groups made up that -- you know, I'm
1385 MPI Str8IC
Springfield. MA 01103-1815
(413) 732-8100
CATUOGNO COURT REPORTING SERVICES,INC.
. P\ftIfIIId. MA (413) 443-7283
40 Sou1h StI8ll 88 Lon; WtIIrf HlrttonI. CT (203 52WQ87
WorOHtlr. MA 01801-201' Bolton. MA 02110-3810 NoIUIampCOn. MA (413) 588-3588 ~I"
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being honest with you.
After as many as years as I've been
involved,
I'm going to talk -- there
should be some people assigned here that
have some public interest in the town
and the landfill to see that this thing
is kept up and all of these, that the
cap is maintained,
the leachate system
is
installed for extraction, that that
is
maintained and periodic reports made
from us back to the government,
again,
~""'~cause
I ~eally feel as though ten
years down the road there are a lot of
people that are going to forget this
mess.
We have a lot of problems in that
landfill that's got to be settled and
leachate into the groundwater and I feel
it is a must.
It's not a question as to
if we should do it, we must do it. Thank
you.
MS. LESHEN:
The next person I'd
like to call is Helen Knight.
1365 Main S1r8It
Springfield. MA 01103-1815
(413) 732-8100
CATUOGNO COURT REPORTING SERVICES. INC.
Ptttaft8k1. MA (413) ~7283
86 Long Wharf Hanford, CT (203 525-3087
Bolton. MA 02110.3810 Northampton. MA (413) 58&-3588 _n1nos
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MS. KNIGHT.
I want to .tart by
talking about two of .y favorite
subjects, M ,
M's,
monitoring and
maintenance.
Both of them have failed
us in the past.
Unless we have a
contract with penalties or bonds
attached,
it isn't going to be worth
anything.
I think
a part of such
we're
a contract.
I believe I am and I want
to know that these things are going to
be monitored and that they are going to
be maintr:ned as the plan says.
We have
too many times had things promised to us
that never come about.
I agree with the
previous speaker,
Carl Moore, about the
groundwater.
For fifteen years four families
drank water out of the wells that were
in the acquifer of the landfill.
No one
knew anything about it.
One of the
problems we have in the town now is a
lot of new people here who do not read a
local newspaper.
Three neighbors I have
1385 Main S1r88I
Sprlngflald. MA 0111D-1815
(413) 732..,00
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CATUOGNO COURT REPORTING SERVICES, INC.
PmltIeId. MA (413) ~7283
88 Long Wharf HartlonS. CT (203 52W081
Bo81on. MA 0211C>3810 NotIharnpton, MA (413) 58&-3588 _I"",
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1385 Main Str88I
Springfield. MA01103-1815
(.13) 732..100
18
closest to .e do not read a local
newspaper, do not know what is going on.
There is nothing to stop anyone from
coming into the town and driving a well
on the property and drinking water out
of the well.
Unless we contain that
groundwater on-site I see no other way
to protect the health of the people of
Billerica if we cannot do that.
I'm intrigued by the write-up of
the cancer risk in here.
I'm told that
if I drank the wp.er on the dump site
that I'd have two chances in a hundred
to get a cancer, but only if I drank two
quarts for seventy years.
Maybe this is
the way these cancer risks are listed, I
don't know.
It seems incredible to me
that we have to put down two quarts and
we have to talk about seventy years.
Are we to conclude that if you drank one
quart for seventy years nobody would
have cancer?
I think what we're saying
here is that there is a slight risk of
CATUOGNO COURT REPORTING SERVICES. INC.
PlnlfIeId. MA (413) ~72G
88 Long Whatf Hlr1fonI. CT (203 52W087
Bo8ton. MA 02110-3810 NoI1tIamplOn. MA (413) 58&45118 _1"111
(817) 7DoOI4O TaECOPlER (413) 73104228
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Sprlngflald. MA 0"00-1815
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cancer and I think if you 90t it, you
wouldn't care if you were one in a
million or one in ten thousand or
whatever.
This again I think points out
that we do need that groundwater kept
on-site.
We cannot -- there are people
who use these wells for their lawns and
for thinqs like that and we cannot keep
children from playing and possibly
drinking it, and although I would like
to see these lists in a little more
realistic terms than tw~~uarts for
seventy years, I think we have to face
the fact that there is a slight cancer
risk, a risk no one wants to take.
I'm concerned too about the venting
system.
I'm beginning to be very sick
of reading that the venting system
doesn't work because, what a surprise,
it is a dump site.
Venting systems are
made for dumps, I think, and dumps
settle and isn't there any reason why we
can't plan for this or correct it or
CA TUOGNO COURT REPORTING SERVICES. INC.
PItIItI8Id. MA (413) 40-7283
88 LCIIIII Wharf Harttord. CT (203 5&3C87
Bolton. MA0211003810 NoI1t\8mptOII. MA(413) 58&-3588 _1"111
(817) 723-0840 ~L£COPIEJI (413) 75-4228 .
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periodically change it?
I'. not
8ugge8ting that it be put on ela8tic,
but it does seem to me that springs or
something would solve this problem.
Anyone who makes a venting system should
be able to do that.
We've had that
venting system now about three years and
it isn't working.
I don't understand
why the engineering can't be changed to
make it work.
I'm also disturbed too when I read
in
here that some of the tests ~~e 1987
and '88,
I believe, in the rounds of
testing.
We I-re ta 1 king abou tour 1 ives
and our welfare here.
Can we not have a
complete new set of tests?
I think we have a problem too that
we're afraid some of the containers of
the materials in that dump are
eventually going to deteriorate and
some
of that is going to get into the
groundwater or into the leachate.
Can
we not have some tests that are -- that
1315 MIJn Str8II
Sprtngfield. MA OHm-111S
(413) 732.,00
CATUOGNO COURT REPORTING SERVICES. INC.
. PlnlfIeId. MA (413) 443-7283
. Lon; Wharf HlntonS. CT (203 52W087
Bolton. MA 02110.3810 Northam,*"" MA (413) 58&-3588 -ningI
(117) 723-0&40 TELECOPIER (413) 738-4228
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1385 Main SIr88I
Springfield. MA01103-1815
(413) 732..100
21
are final?
Mow, I'm a88uming that over
the year8 they'll change but at lea8t
we'd get a better picture if we did
that.
Now,
I'm also concerned there is
surface water that has not been tested.
I've brought a sketch up here in rough
form of Gray Street, right close to the
railroad tracks.
On each side of the
street there are two ponds and I see
children playing in one of them all the
time.
I don't think these have
ever
been tested.
Surface water.
There is a
large pond in b~tween90 and 100 Gray
Street that has never been tested.
There is a good-sized pond besides 113
Gray Street that has never been tested,
at least there has never been a record
of it.
I think that should be done.
We
should know about that, I think.
I'm puzzled too about why only the
middle of the cover is going to be
repaired.
Engineering is not my
CATUOGNO COURT REPORTING SERVICES, INC.
Pmafl8lcl. MA (413) 40-7283
. Long Wharf Hartfold. CT (203 52S-3087
808Ion. MA 0211C).3810 Northampton. MA (413) 58&-3588 _1"111
(817) 723-0140 TELECOPIEA (413) 738-4228
40 South Str881
Worcelt8r. MA 01"'2018
(508) 752-4840
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1385 Main StnI8I
Sprtngfillcs. MA 011CD-1815
(413) 732"100
22
department but it does appear to .e that
the problems are on the outside of the
cover, not in the middle.
I see
leachate breakouts in different places
and I see it's out of compliance with
state plant limitations on three sides,
I believe, and I cannot really
understand why we would just correct the
middle, which looks pretty good to me.
It seems to me the only way to handle
this is a complete cover.
I'm also interested in that
breakout at Upper Middle Pond that I
know Carl Moor~- spoke about."
There's no
question about it.
The water is going
under the tracks and into the pond.
I'm
sorry, Richardson Pond you call it.
I
believe there are culverts there and
. that this should be investigated.
Under
no conditions should we allow that pond
to be as contaminated as it is.
We found -- our consultant found
tritium when he did some testing in
CA TUOGNO COURT REPORTING SERVICES. INC.
PmlfI8Id, MA (413) 443-7283
88 Lang Wharf HlrtfonI. CT (203 52W087
Bos1on. MA 02110-3810 NonhamplOn, MA (413) 588-3518 ...,.nllllll
(817) 72300840 TELECOPIER (413) 73to4228
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8hows that the landfill ie in the
wetland8, a8 we all know, and that it
was excavated and actually material was
taken out and the landfill base was
extended further into the wetlands, as
these pictures here indicate.
I believe
that excavation may have been somewhere
in
the order of fifteen to twenty feet
of fill taken out of here,
as indicated
by those maps, and that now the
landfill,
I believe,
is someplace around
elevation 178.
As you can see from these pictures
-- I don't "know.-'-~~ these from Carl.
Do they have copies of these?
HR. HOORE:
Yes.
HR. HORRIS:
I think the pictures
probably tell most of the story.
Let me
just reiterate a few things.
The board of health is very
concerned about -- the first thing that
we would prefer is a total cap
reconstruction.
As indicated earlier at
1385 Main Str88I
Springfield. MA01103-1815
(413) 732~100
CATUOGNO COURT REPORTING SERVICES. INC.
PItIafIIId. MA (413) ~7283
. Long Whlrf HIItIord. CT (203 5254087
Botton. MA 02110-3810 NoI1hImplClft. MA (413) 58&-3588 _Inga
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1385 MPi5nll
Springfield. ""'011.1815
("13)732~1C1O
25
a meeting with the board of health, the
cap that i8 currently on the landfill i8
not in compliance with the 1984 court
order.
Secondly, there is nowhere in
the CEM's plan that shows a direct
hydroelectrical connection to keep
Richardson Pond from the landfill.
Now,
it's a fact that there are several
culverts along the tracks which connect
the pond with the landfill, I believe,
and I believe that the board of health
would like to see vertical barriers
installed and the containment system in
manipulating and confining and
channeling this groundwater to an
extraction point and a greater in-depth
groundwater system than what is being
proposed under the EPA's alternatives.
We should not take any risk at all
which would contaminate Tewksbury's well
water.
I don't believe that the current
system being proposed will protect that,
will protect Tewksbury's wells the way
CATUOGNO COURT REPORTING SERVICES. INC.
PIIIafI8IcI. MA (" 13) ...,.72G
. Long Wharf Hu1fonI. CT (203 52WOI7
8081011. MA 02110-3810 NoIttIampton. MA ("13) S8&o3588 _I,.
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1385 Main Strwt
Springfield. MA 01103-1815
(413) 732~100
26
it needs to be protected.
Leachate,
again, should be treated
off-site, collected and treated
off-site.
There are several points that
several other people are going to be
making about the traffic, the use of the
transportation methods the EPA will
use.
I prefer we use the rail system.
The other things are the venting
system and the flare system.
Before we
even
begin the total cap reconstruction
that should be in place and working at
100 percent efficiency before we go
toward it.
It is obviously. not doing
the job
We should correct that
now.
problem before we go and do the cap.
The other thing that I would like
to mention or comment is that I wish
that the EPA had granted us this to be
the first meeting instead of the second
meeting.
I understand we have had a
thirty day extension.
I think several
CATUOGNO COURT REPORTING SERVICES,INC.
Plnlfleld. MA (413) 443-7283
86 Long Wharf Har1tord. CT (203 525-3087
Bo8ton. MA 02110.3810 Northampton. MA (413) 58&-3586 _nl/1118
(817) 72:HI84O TEI.ECOPIER (413) 738-4228
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1385 Mlln Str88t
Springfield. MA 011~1815
(413) 732~100
27
town officials indicated to the EPA they
were
not happy with that.
I don't know
if they are all happy with the
extension.
That's about it.
MS. LESHEN:
The next person is
David L. Johnson.
MR. JOHNSON:
The statement that
I'd like to make is relatively to the
basic data that you used in arriving at
your solution, and one of those basic
data points was the impact on the
surface water.
.A lot of the testing of
the surface water which was done was
provided in reports and I read some of
these reports and one of them says
methylene chloride was detected in the
at 1300 parts per billion and was
therefore was considered lab or field
contamination,
therefore they didn't
believe them.
That was also the case
for acetone, which I think they found
800 parts per billion or something of
that sort.
CATUOGNO COURT REPORTING SERVICES. INC.
. PtttIfI8Id. MA (413) 443-7283
40 Soulh StrMI 88 Long Wharf Hanford. CT (203 525-30117
WorClll8r. MA 01808-2018 Bolton. totA 02110-3810 Nor1hlmpton. MA (413) 58&-3588 _lngI
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I would like to point out to you
that we had testing done in 1983, and
this was done by Cambridge Analytic, a
very well known company, and we had the
testing done in accordance with law
because we intended to take the state
and town and everything to court to get
the place cleaned up.
What they did was
they ran a calibration cycle on their
equipment.
They ran the sample through
and then they re-did their equipment to
make sure that they were maintaining
~alibration during the test.
Our
results, which I'll give to you,
indicated
1100 parts per million of
methylene chloride,
850 parts per
million of qualine [phonetic].
I think that you've got to go back
and look at the very base information
that you have made your decision on
before you come out with your record of
decision and I submit these documents to
you which detail our test results.
1385 Ma'n SIrWI
Springfield. MA 01103-1815
(.13) 732"100
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PttllfI8ld. MA (.13) "'-7283
88 Long Wt\aJ't Har1forcl. CT (203 52W087
Bolton. MA0211D-3810 Noc1tI8mplon. MA (.13) 58&-3588 _nl"ll'
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1365 M81n Str88t
Sprtngfleld, MAO"~1811
(413) 732"100
29
MS. LESHBMs
I'd now like to call
Tony Bonacci.
MR. BONACCI:
My name is Tony
Bonacci and I'm an abutter of the
landfill and I just more or less would
come up here to reiterate wcat my
neighbors said, Helen, Carl a~~ Dave,
and because I've been working with Helen
with this going on ten years and trying
to correct the problem and it's been a
ten long years.
Fortunately, I'm glad
they haveqot abreast of it and kept all
the information and kept me in touch.
Unfortunately I was one of the
abutters who had a we~l.
and it was
active for five years, that I drank out
of it.
My family drenk out of it, and
in the past fourteen mDnths I have
developed kidney failure, and I can't
say it is to this or to the drinking of
the five years, but it.s something that
I've got to live with Lor the rest of my
life
I don't know, and is there
'cause
CA TUOGNO COURT REPORTING SERVICES. INC.
Pmatlelcl. MA (413) 443-7283
88 Lan8 Wharf Hartford. CT (2113 I2$-3CI81
Bolton. MA 02110.3810 NoItt\arnptOn. MA (413) 18&-3588 _1"111
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1385 Ualll $n8t
Springfield. MA 011CD-1815
(413) 732"100
30
other people around who are getting .ick
and don't know why?
And just again,
I'm a concerned
abutter and somebody -- I don't care if
it costs 50 million dollars, we want the
problem done correctly and we want it
done right and right away.
Thank you.
MS. LESHEN:
Would anyone else like
to make formal comments?
I want to again mention we are
going to be holding another public
hearing to give ~r..,u the opportunity to
enter your oral comments into the record
February 19th, two weeks from tonight,
in
this room, at 7:30.
Any comments that were received
this evening thus far that were read
into the record, any comments to be
received orally on the 19th and any
comments we receive in writing in our
office prior to March 16th will be
responded to in the document called the
Responsiveness Summary attached to the
CA TUOGNO COURT REPORTING SERVICES. INC.
PlnlII8Id. MA (413) ~7283
. Long Wharf Huttora. CT (203 5025-3087
BoI1on. MA 021 1G-3810 Northampton. MA (413) 58&-3588 _nl"81
(817) ~ TUECOPIER (413) 7:Jt.4Z!8
40 Sou1tI StrwI
Worc8I18r. MA 01808-2111.
(508) 752~
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'385 Main Str8II
Sprlngfillcl. MA 011CB-1I15
("3) 732~100
31
Record of Decision and will be
considered during our decision-making
process.
We do encourage you to submit
written comments,
to come back on the
19th and make additional comments and
for the people to make comments at that
time.
If you have any questions,
we're
going to be staying around this evening
to answer any questions, you can be
called on, and if thre
any other way
we can be of help,
let us know.
If I don't hear anyone wishing to
make any additional formal comments, we
will now close the record.
At this
point no further comments will be
entered into the record this evening.
Any comments you want addressed in the
future will have to be entered into the
record on the 19th or submitted in
writing.
The record is now closed.
CA TUOGNO COURT REPORTING SERVICES. INC.
PInafiIId. MA (4'3) ~72G
88 Long Wharf Harttord. CT (203 52W081
Bolton. MA02110.3810 NoIUIampton. MA (413)588-3588 _nl,.
(81717~ TELECOPIER (4131 ~
,
40 Sou1h StI'8ll
Won:88I8r. MA 0180&-2018
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JJ
ENVIRONMENTAL PROTECTION AGENCY
I, ELIZABETH M. BROOKS, Registered
Professional Reporter,
do hereby certify that the
foregoing testimony is true and accurate, to the best
of my knowledge and ability.
February,
WITNESS MY HAND, this 22nd day of
1991.
(
1385 Main StrwI
Sprtngfield, MA 011CD-1815
(413) 732~100
CATUOGNO COURT REPORTING SERVICES. INC.
PII18ft8Id. MA (413) ~7283
. Long Whlrf Hartford. CT (203 525-3087
8oI1on. MA 0211().3810 Not1h8mp1011, MA (413) 58&-3588 _nlnga
(817) 723-0840 TELECOPIEA (413) 73t-4ZZ8
,
40 South SII88t
W_lI8r. MA 01808-201.
-------
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2
SPEAKER:
Helen Knight
Julie Bonacci
Barbara Morrisey
Robert Williams
JoAnne Giovino
Richard Farren
John Morris
Arnold Ventresca
Brian Cangiamila
David F.
DeLorey,
Jr.
I N D E X
PAGE:
11
17
20
26
30
34
38
41
43
48
57
59
62
65
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Arthur Doyle
Christine Chisholm
Robert Donati
David F.
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CATUOGNO COURT REPORTING SERVICES, INC.
Stat.
National
Inlernotional
1365 Main Street
Springfield. MA 01103-1615
(413) 732.8100
66 Long Wharf
80lton. MA 02110-3610
(617) 723-0640
,
Pinsfield. MA (413) 443.7.263
Hartford. CT (203) 525-3097
Northampton. MA (413) 586-3586 evening:
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24
2
(Hearing convened)
MS.
LESHEN:
Good evening,
I'm
Maggie Leshen.
I'm chief of the
Connecticut Superfund section,
and I'm
going to be running tonight an informal
public hearing for the Iron Horse Park,
Shaffer Landfill Site.
I'm going to
explain very briefly how this will be
run,
and I will remind you that it will
be run in the same manner as our
February 5 hearing.
Basically tonight we will be
dividing the evening into three parts.
During the first part, Don McElroy,
the
site manager, will be giving a very
brief presentation about the proposed
plan.
We will then be taking formal
comments,
which,
if you intend to make
one, you need to fill out one of the
cards that we can get you from the back
and I will call on you and we will ask
you at that point in time to come up to
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CATUOGNO COURT REPORTING SERVICES. INC.
1365 Main SI,eei
Springfield. MA 01103-1615
(413) 732-8100
66 long Wharf
80slon, MA 02110-3610
(617) 723-0640
Pmsfield, MA (413) 443-7263
Hartford, CT (203) 525-3097
Northamplon, MA (413) 586-3586eveninc
TELECOPIER (413) 739-4226 -
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this mike which is hooked to a recorder
~
as well so we can get your
comments
entered into the public record.
We will
not be responding to those comments this
evening.
The comments that were
received February 5, the comments that
are received tonight, as well as
E
comments that are received in writing
(
prior to the end of the public comment
l(
period, which has been extended due to
1
your interest, to March 16, the comments
1~
that are received in writing in our
1
office by March 16, all the comments
1<
will be responded to in a Responsiveness
1 c
Study, which will be attached to a
IE
Record of Decision, which will be a
1.
decision made on this site based on
IE
public and state comments that have been
IS
received during the public comment
2(J
21
period.
Does everyone understand how this
22
will happen?
23
I am going to tell you that we will
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1365 Main Slreel
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(413) 732-8100
66 long Wharf
8allon. MA 0211~3610
(617) 723-0640
Pi"sfield. MA (413) 443-7263
Hartford. CT (203) 525-3097
Narthamplon. MA (413) 586-3586eyenin~
TELECOPIER (413) 739-4226
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5
limit the first round of comments,
'cause I don't really know what people
have,
to approximately ten minutes.
That way we can get to all the people
that have requested to make a comment,
so that everyone does have a chance.
In
the event someone wants to read a
lengthy comment into the record, we will
stay around for any comments that anyone
1
has,
but I'm going to limit the first
1
go-around to ten minutes so that
1
everyone will have a chance to speak
1
into the record if that's so desired
1
this evening.
1
As I said earlier,
the comments
1
also can be submitted in writing to our
1
office in Boston,
and the address
is on
1
the proposed plan that was at the front
1
desk when you came in.
If you need one
2
you can just let us know during the
2
evening,
so that you can submit these
2
comments in writing by March 16.
2
As I said,
Don will give a very
CATUOGNO COURT REPORTING SERVICES, INC.
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1365 Main Street
Springfield, MA 01103-1615
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66 long Wharf
80$1on, MA 02110-3610
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Pittsfield. MA (413) 40&3-7263
Hartford, CT (203) 525-3097
Northampton, MA (4113) S86-3586 eve'lings
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short presentation on the proposed plan,
and then we will get started with these
comments.
After we finish the formal
J.
comments,
we will stay around for
c
entertaining the questions that you
~
might have remaining.
Now Don will give you a very short
I
presentation on the proposed plan.
.
MR. McELROY:
Good evening.
I just
l(
wanted to run through the process that
1
we've gone through up to this point and
1:'
quickly run through the alternatives
in
L
the proposed plan before we open the
U
11
floor for comments.
The Environmental Protection Agency
11
has proposed a cleanup plan referred to
I"
as the Preferred Alternative to address
IE
contamination at the Shaffer Landfill,
15
Iron Horse Park Superfund Site in
2(
Billerica, Massachusetts.
The Preferred
2
Alternative is EPA's preliminary
2~
selection of a remedy and may be changed
2
if public comments or new information is
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1365 Moin 51'881
Springfield. MA 01103.1615
/413 \ 7~7.8HY'
66 long Whorl
Boslon. MA 02110.3610
1617' 7?'.1'\A4n
Pittsfield. MA (413) 443.7263
Hortfo,d. CT (203) 525.3097
No"homplOn, MA (413) 586.3586 even'''9'
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21
2
2.
2.
presented to EPA during the public
comment period that significantly
affects EPA's evaluation of the
alternatives.
After evaluating all eight
alternatives developed in the
Feasibility Study, EPA proposes
reconstruction of the top portion of the
existing landfill cap and the collection
and offsite treatment and disposal of
l,eac hate.
Cap reconstruction would ,be
achieved by adding fill and regrading to
achieve a minimum five percent slope on
the top,
flatter areas;
installing
additional,
low permeability material;
installing a new, six inch drainage
layer; reinstalling the topsoil layer;
and reseeding the disturbed areas.
Leachate facilities would be
constructed, operated, and maintained.
Leach~te would be transported off-site
for treatment and disposal.
Improvements wo~ld be made to the
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1365 Main Slreet
Springfield, MA 01103-1615
(413) 732-8100
66 long Wharf
BasIon, MA 02110-3610
(617)72~
Pinsfield, MA (413) 443-7263
Hartford, CT (203) 525-3097
Northampton, MA (413) 586-3586 even in
TELECOPIER (413) 739-4226
-------
"
8
existing surface drainage system.
The
cap, the surface drainage system, and
the landfill gas collection/flare system
would be maintained and monitored, and
any necessary improvements would be
made.
A site perimeter security fence
would be constructed.
Groundwater and
surface water quality would be
monitored.
1
Again,
if public comment and
1
further information change EPA's
1
- ~valuation of this or any of the other
1
alternatives,
EPA may decide on another
1
alternative for its final selection.
1
I'd like to quickly run through the
11
other alternatives evaluated in the
1
Feasibility Study.
Alternative 1 is the
11
no-action alternative, under which no
1 c
further work at the site would take
21
place.
2
Alternative 2 would complete the
2.
existing cap by adding fill to achieve a
2
five percent grade, and reconstructing
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CATUOGNO COURT REPORTING SERVICES. INC.
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National
1365 Main Street
Springfield, MA 01103.1615
(413) 732.8100
66 Lang Wharf
BOSlon, MA 02110-3610
(617) 723-0640
Pinsfield, MA (413) 443-7263
Hartford, CT (203) 525-3097
Northampton, MA (413) 586-3586 evening'
T1:LECOPIER (413) 739-4226
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the overlying low permeability layer.
This alternative also would include
maintenance of the cap,
surface drainage
system,
and landfill gas
collection/flare system;
construction of
site perimeter fence;
and monitoring of
the gas collection/flare system and
surface water and groundwater quality.
Alternative 3 contains the same
features as Alternative 2 in terms of
completion and maintenance of the
1 and f i 1 '. cap.
In addition, Alternative
3 would improve the existing surface
drainage system; construct,
operate,
and
maintain leachate collection facilities;
and transport leachate off-site for
treatment and disposal.
Alternative 3A contains all the
features of
Alternative 3.
In
addition, Alternative 3A would
construct, operate,
and maintain a
groundwater extraction system along the
eastern side of the landfill; construct,
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1365 Main Slreet
Springfield. MA 01103-1615
(413) 732.8100
66 long Wharf
6oslon. MA 02110-3610
(617) 723-0640
Pittsfield. MA (413) 443-7263
Hartford. CT (203) 525-3097
Northampton. MA (413) 586-3S86eveninlls
TELECOPIER (413) 739-4226
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10
operate,
and maintain an on-site system
for treatment of groundwater and
leachate,
and discharge through the
groundwater to surface water.
Alternative 4A contains all the
features of the Preferred Alternative.
In addition, Alternative 4A would
construct,
operate,
and maintain a
groundwater extraction system along the
11
eastern side of the landfill;
construct,
1
operate,
and maintain an on-site system
1.
for treatment cr~groundwater and
1
leachate;
and discharge treated
1
groundwater to surface water.
11
Alternative 5 would completely
u
reconstruct the entire landfill cap to
1
meet EPA's recommended final coverage
11
design standards for hazardous waste
1 c
landfills.
This alternative would a180
2C
provide the same maintenance,
2
monitoring,
and perimeter fence as the
2~
other alternatives.
2
Alternative SA contains all the
CATUOGNO COURT REPORTING SERVICES, INC.
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1365 Main Street
Springfield. MA 01103.1615
(413) 732.8100
66 Long Wharf
Bolton. MA 02110-3610
(617) 723-0640
pmlfield. MA (413) ~.7263
Hartford. CT (203) 525-3097
Northampton. MA (413) 586-3586 eye~,n~
TELECOPIER (413) 739-4226
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features of
Alternative 5.
In
addition,
Alternative SA would
construct,
operate,
and maintain a
groundwater extraction system along the
eastern side of the landfill;
construct,
operate,
and maintain an on-site system
for treatment of groundwater and
leachate; and discharge treated
groundwater to surface water.
MS. LESHEN:
Thank you,
Don.
And
now we will get started on the formal
hearing part.
And we
have the cards,
and I will at this point
in time read
them in order for the people that signed
up as they came in.
And the first
person 1s Helen Knight.
MS. KNIGHT:
First, we are pleased
to have another opportunity to state our
case.
I confess that I live on Gray
Street,
in the neighborhood that is
severely impacted by the dump.
I'm the
third generation in my house.
And I
very much doubt that any of my relatives
CATUOGNO COURT REPORTING SERVICES. INC.
1365 Main Street
Springfield, MA 01103.1615
(413) 732-8100
66 long Wharf
Boston, MA 0211~3610
(617) 723-0640
Pinsfield. MA (413) 443-7203
Hartford. CT (203) 525-3097
Northampton. MA (413) 580-3586 ever
TELECOPIER (413) 739-4226
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back in the family
thought the day
ever
would come when the old blueberry swamp
would be a threat to the neighborhood.
Unfortunately that day has
come.
Contaminated surface water flows
into
our neighborhood in Content Brook.
Contaminated groundwater probably flows
under our 'houses,
and contaminated air
with the westerly winds blowing into the
neighborhood entertains us periodically.
And this is through no fault of
ours.
50 we have a few demands,
think
and'
we have a right to have some demands.
First of all,
before any of this is
done,
let us talk about funds for this.
We need a bond,
a financial commitment,
with penalties, some kind of assurance
that the job will be done; and that if
problems occur that they will be
addressed.
Too many times individuals
and agencies have failed us.
It has been twenty-five years in
November since this odyssey started.
CATUOGNO COURT REPORTING SERVICES, INC.
1365 Main Street
Springfield, MA 01103.1615
(.13) 732-8100
66 Long Wharf
8oston, MA 0211Q.3610
(617) 723~
Pinsfield. MA (.13) 443.7263
Hartford, CT (203) 525.3097
Northampton, MA (.13) 586-3586 even,n!
TELECOPIE~ (.13) 739..226
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And I'm entertained that we're
congratulating ourselves now that
we've
done the paperwork that we're going to
get a fence.
Isn't that remarkable,
in
this day and age.
Twenty-five years
later we're going to put a fence around
it.
Congratulations to us.
First of all,
too,
we need
complete, up-to-date testing of surface,
groundwater,
air,
everything.
It is not
enough to base this decision on 1988
testing;
and by testing a well here an~
a well there.
Every well.
Surface
water,
groundwater, every test we can
give to the air.
Then we know where we
stand.
When we look at the proposed plan,
there's good news and bad news.
The
good news is -- the best of the news is
the leachate collection system with
off-site treatment and disposal.
That
answers a real demand.
I hope we will
think too of the railroad,
possibly tank
CATUOGNO COURT REPORTING SERVICES. INC.
1365 Main Street
Springfield, MA 01103-1615
(413) 732.8100
66 long Wharf
Boston, MA 02110-3610
(617) 723-0640
Pimfield. MA (413) 443-7263
Hartford. CT (203) 525-3097
Northampton, MA (413) 586-3586 eve~ings
TElECOPIER (413) 739-4226
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cars on the railroad for that purpose,
if it can be worked out.
And in spite
of the fact that we waited twenty-five
years,
I am glad to hear that the fence
is going to be a reality.
I hope it
will be done soon, before the
twenty-five years are up.
November is
the cut-off date.
Not only that,
I hope
it will be sufficiently labeled so that
anyone who comes to it will know that
this
is a
site they should not be in.
I am pleased to hear that there's
going to be maintenance of the cap, the
drainage system,
and the venting system,
but the bad news is,
I don't think the
venting system is working.
50 you can't
maintain it until you make it work.
Get
it working first.
Then maintain it.
It
is not working.
Tonight there is an
odor problem.
Second,
I cannot see how we can get
by complete with fixing up just the
center of the cap.
The problems are
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CATUOGNO COURT REPORTING SERVICES, INC.
1365 Main Street
Springfield. MA 01103-1615
("13) 732-8100
66 Long Wharf
Boston, MA 0211G-3610
(617) 723-06.c0
Pi"sfield, MA ("13) .c.c3-7263
Hartford, CT (203) 525-3097
Northampton, MA (413) S86-3586 eVr"ing!
TELECOPIER ("13) 739-"226
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p-
around the edges, where there are
breakouts of leachate and where it is,
on at least three sides,
far out of
compliance with state flat limitations.
1
I do not know what the federal flat
f
limitations are, but the state ones are
not met.
It's two to one,
instead of
I
three to one.
I don't know how we
c
address that.
It should have been
11
addressed before.
It wasn't.
It is a
1
problem.
We cannot solve'it, we cannot
1
live with it, unless we have a complete
1
cap.
l'
And as I said before, we cannot
11
maintain the venting system unless it
is
1E
repaired.
I don't know what's wrong
1.
with it.
That's not my department.
But
IE
it isn't working.
I cannot believe
1 c
either that we're talking about leaving
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Upper Mill Pond, Richardson Pond, with a
2
breakout of leachate,
I believe the most
2~
serious breakout of leachate,
and not
2 ~
addressing that problem.
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1365 Main Street
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(617) 723-06AO
Pinsfield, MA (~13) 443-7263
Hartford, CT (203) 525-3097
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We've been told in elaborate terms
"
that it is not possible for things like
fragmented base rock and things like
that, when we know that there are
culverts under there.
Those must be
straightened out.
They must be sealed.
If that poses a problem about drainage,
then there must be some other solution
worked out, but when you have a culvert
and a dump on one side in a swamp, dump
below the surface of the water, and you
have a pond on the other side of the
track,
and they're equal
height, you
in
know where the contaminants are going to
go.
50 we do need to fix that up.
And finally,
I'm very concerned
about the groundwater.
We found there
were four families drinking water out of
wells in this aquifer.
They have since
been hitched up to the town drinking
water supply.
One family, however,
drank water for fifteen years out of
that, and incidentally, there are two
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1365 Main Sireel
Springfield, MA 01103-1615
(413) 732-8100
66 long Wharf
8oslon, MA 02110-3610
(617) 723-0640
Pittsfield. MA (413) "3-7263
Hartford, CT (203) 525-3097
Northomplon. MA (413) 586-3586 even
TElECOPIER (413) 739-4226
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cancer cases in that family.
I'm
another cancer case,
incidentally.
Twice I've had it.
But we've not done a
health study,
and possibly these are not
connected.
I don't know.
But I cannot
see this stuff going into the
neighborhood, under the houses,
and into
the aquifer of Content Brook and
Shawsheen River and do nothing about it.
It must be addressed somehow.
MS. LESHEN:
Next I'd like to call
Julie Bonacci.
MS.
BONACCI:
My name is Julie
Bonacci.
My husband spoke here last
meeting,
and I'm here to represent our
family tonight.
We live near the
landfill.
We live on Gray Street.
We've been there for ten years.
When we
bought the house, we didn't realize
there was a landfill behind us.
It
wasn't until we were at the dump,
and we
could see the top of the roof of our
house,
that we realized the kind of a
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CATUOGNO COURT REPORTING SERVICES. INC.
1365 Main Street
Springfield, MA 01103-1615
(413) 732-8100
66 long Wharf
Boston, MA 02110-3610
(617) 723-0640
Pittsfield, MA (413) 443-7263
Hartford, CT (203) 525-3097
Northampton, MA (413) 586-3586 evr.in~
TElECOPIER (413) 739.4226
-------
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,
situation we were in.
We were excited about the house at
first.
It had a well and it was good
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tasting, which we thought
it was.
And
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we went ahead and kept drinking the
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water.
I went through two pregnancies
drinking the water.
And fortunately my
children are healthy at this point.
But
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we have had illnesses in the family.
My
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husband has kidney failure, and so there
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are different situations that we have
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had to confront thinking about the
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landfill and thinking about the
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long-term effects that it has had on us.
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Several times the children wanted
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to take walks and we keep telling them
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you can't go walking through there.
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It's not safe,
it's dangerous.
And with
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the fence,
it would be very good to tell
them, and to realize the danger of going
2
back there, and keeping them out as they
22
grow older,
and being teenagers, and
2.;
realizing that they can't go back there.
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(617) 723-a6AO
Pi"$field, MA (AI3) AA3-7263
Hartford, CT (203) 525-3097
Northampton, MA (AI3) 586-3S86evenir
TELECOPIER (AI3) 739-A226
-------
-------
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drainage and the leach,
I a180 back that
up a hundred percent.
And that's all
I'd like to say at the moment.
Thank
you for your attention.
MS. LESHEN:
The next person I'd
like to call is Barbara Morrissey.
MS. MORRISSEY:
As I left my house
~
tonight I was also assaulted by the
c
noxious
odors coming from our landfill,
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and it made me even more determined to
1
come
and speak tonight.
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From the beginning, the Shaffer
1
Landfill has received inadequate
u
monitoring.
In 1966/67, Gray Pond
1 ~
Realty received a permit from the
IE
Department of Natural Resources for the
1.
operation of the landfill.
The permit
1E
required a liner.
This was not done,
15
yet the permit was not revoked.
Now we
2C
are here to fix this problem.
Haggie
2 J
Leshen stated at our last meeting of
2~
February 5 of 1991 that liners are the
2~
norm in landfills, and caps are the
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1365 Main Street
Springfield. MA 01103-1615
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66 Long Wharf
8oston. MA 02110-3610
(617) 723-0640
Pittsfield, MA (413) 443-7263
Hartford. CT (203) 525-3097
Northampton. MA (413)S86-3S86evenin
TElECOPIER (413) 739-4226
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fixes.
We are trying to fix a major
problem and should do so doing the most
appropriate means available to us today.
The missing liner has resulted in the
migration of the landfill contaminants,
via the leachate, to groundwater and
surface water.
This migration is the
primary threat to human health in the
environment.
It seems reasonable that the
reduction and control of this leachate
;\ '
production should be the number one
priority.
Leachate production is
directly proportional to the amount of
water that is able to penetrate the
landfill cap and filter through the
waste.
The reduction or elimination of
this infusion through the cap must be
stopped.
The existing cap does not even meet
the requirements of the 1984 consent
agreement.
I quote,
from the Superfund
sheet of August 1989:
"The depth of the
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CATUOGNO COURT REPORTING SERVICES. INC.
1365 Main SIreet
Springfield. MA 01103-1615
(.13) 732-6100
66 long Wharf
Bo.,on. MA 02110.3610
(617) 723~
Pittsfield. MA (.13) 443-7263
Hartford. CT (203) 525-3097
Northamplon. MA (.13) S86-3S86evening
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cap of the clay layer may not meet the
agreement's requirement, and the
approved specifications on the top and
side slopes of the landfill.
In
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addition, the permeability of the clay
has not been verified to meet the EP
requirements.
It is questionable
whether the topsoil layer is thick
enough to support adequate vegetation."
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How can this cap reduce the human
1
and environmental hazards caused by the
1
Ie/hate production if the current cap's
1
design is faulty and the cap is
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inadequate.
The EPA must properly
cover
11
the entire landfill and not just the top
11
sixteen acres if the inadequacies of the
1
past are to be corrected.
If we are
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given the quick fix being proposed by
the EPA, the basic problem will not be
2(
corrected, and the result will be the
2
continued leachate production and
24
migration.
To stop this continual
2
pollution, the EPA recommended cover
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1365 Main Slreel
Springfield, MA 01103-1615
(413) 732-8100
66 long Whorf
Boslon, MA 02110-3610
(617) 723-06AO
Pilt1field, MA (413) "3-7263
Hartford, CT (203) 525-3097
Northampton, MA (413) 586-3586 evenings
TELfCOPIER (413) 739-4226
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design,
in Figure 5-5 of the Final Draft
Phase Feasibility Study for Hazardous
Waste Landfills, must be applied to the
total area of the Shaffer Landfill.
The problems we have today are the
result of lax monitoring by the
responsible agencies and a lack of
proper 0 & M contracts on the cap and
gas venting systems.
Ongoing 0 & M
l(
contracts are necessary to ensure the
1
future integrity of the landfill cover
1
and ventj
system.
Gray Pond Realty
1
has demonstrated its inability to
1
provide such contracts.
To guarantee
1
the money is available for the future
If
maintenance requirements of the
l'
landfill, a trust fund or bond must be
11
created.
With a proper cap, the 0 , M
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contract,
and the financial guarantee,
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leachate production should be controlled
2
and leachate migration will be reduced.
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The leachate that is still being
22
produced must be collected, contained,
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(617) 723-06AO
Pi"sfield, MA (413) 443-7263
Hartford. CT (203) 525-3097
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and treated off-site as proposed in the
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Feasibility Study.
There must be a plan
developed in case there is a leachate
spill.
If possible, the leachate
removal should be done by railroad and
not over town roads.
Truck routes
through the neighborhood would have a
negative impact and create many
potential problems.
It has also been
discovered that four culverts connect
the landfill to Richardson Pond.
The
remediation must
.elude permanent
closure of these culverts to stop their
further surface and groundwater
contamination.
The impact on
groundwater will be decreased if the
contaminants can be kept on site.
Total
cap reconstruction would be the most
effective means to accomplish this.
Before final closure begins, we
need a round of current test samples.
This would provide us with initial
baseline values of all hazards,
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CATUOGNO COURT REPORTING SERVICES, INC.
1365 Main Street
Springfield. MA 01103-1615
(413) 732-8100
66 Long Wharf
Basion. MA 02110-3610
(617) 723-~O
Pittsfield. MA (413) 443-7263
Hartford. CT (203) 525-3097
Northampton, MA (413) S86-3S86eveninc
TELECOPIER (413) 739.4226 .
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hazardous chemicals, at the landfill.
By routine, scheduled retests the
.
migration of chemicals will be
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monitored.
Threshold values must be
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set, and public notification should be a
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requirement,
that these values are met
.
or exceeded.
Predetermined actions must
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be designed so appropriate action can be
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implemented immediately.
If an escrow
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account was in place,
the money would be
1
immediately available to start the
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appropriate corrective me
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Without the money, the Shaffer's record
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of slow and inappropriate action will
11
again be the norm.
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To restate, because the landfill
1
has no liner, we want the best remedy
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15
available.
That includes a total cap
reconstruction, leachate collection and
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off-site treatment, and groundwater
monitoring at frequent,
regular
2~
intervals.
If the primary goal of the
2.
action is to reduce the hazard to human
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1365 Main Street
Springfield, MA 01103-1615
(~13) 732.8100
66 long Wharf
Baston, MA 02110-3610
(617) 723.0640
Pittsfield, MA ("13) ~3-7263
Hartford, CT (203) 525-3097
Northampton, MA (~13) S86-3586 evenings
TElECOPIER ("13) 739-"226
International
-------
26
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health in the environment, nothing less
will be appropriate or acceptable.
MS. LESHEN:
Thank you.
The next
person I'd like to call is Robert
Williams.
MR. WILLIAMS:
Good evening.
My
name
is Bob Williams,
and I own Williams
Energy Systems.
I'm in the process of
doing an environmental and energy
project with the Shaffer Landfill.
I ' 11
be using the gas that is currently being
flared on site with all the contr
°ersy
and problems associated with the
landfill, that have been ongoing in the
years.
I'm going to be stepping into
the middle of this problem to bring an
energy project online that is good for
the environment.
In fact,
this is one
of the few times when something good can
come from a Superfund site.
This might
strike all of you as a bit ludicrous.
It's like talking about the Lebanese
government.
It's an oxymoron.
It
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CATUOGNO COURT REPORTING SERVICES, INC.
1365 Main Street
Springfield, MA 01103-1615
(413) 732.8100
66 long Wharf
Boston. MA 02110.3610
(617) 723-06AO
Pittsfield, MA (413) U3.7263
Hortford, CT (203) 525-3097
Northompton. MA (413) 586-3586 e"enir
TELECOPIER (413) 739-4226
-------
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27
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really doesn't make much sense.
But
this is a good project because it can
improve the problems that are already
existing.
What will be improved is not
only the environment,
but will be the
energy resources that come out of the
gas that's being flared.
In case any of you are wondering
what landfill gas is,
it is methane,
the
1
same
as natural gas.
When the landfill
1
is capped,
oxygen-free,
anaerobic
1
bacteria begin eating away at cellulose
1 I
product's,
anything made from wood~
and
1
their waste produce becomes methane.
1
When you have anaerobic bacteria eating
1
away at a million tons of rubbish,
it
1
produces a tremendous amount of that
11
gas.
In fact, energy equivalent of
1
what's packed away in that landfill is
2(
equal to two supertankers.
And of
2
course I need not remind you of the
2
situation we're in and how an energy
2
resource like this would do really good
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Springfield. MA 01103-1615
(AI3) 732-8100
66 long Whorl
BasIon. MA 02110.3610
(617) 723-0640
Pittsfield. MA (AI3) 40&3-7263
Hartford. CT (203) 525.3097
Northomplon. MA (AI3) 586-3586 eve'"
TElECOPIER (AI3) 739.4226
-------
28
things for both the country as a whole
as well as the environment.
There are two problems associated
with landfill gas.
Gas migration
through the soil is the most dangerous.
The gas can seep into houses and
basements and cause explosions if
ignited.
In Lowell they have this
problem at their capped landfill.
There
1
three businesses on Westford Street have
1
been closed and vacated because of the
1
gas migration problem there.
1
The other problem is environmental.
1
Methane is an ozone destroyer,
and in
1
regards to the greenhouse effect,
it
1
holds twenty times the heat, molecule
1
for molecule,
as carbon dioxide.
11
Flaring the gas is a good way of
1C
reducing this problem.
In fact, an EPA
21
study on reserve at the Billerica
2
library lists the results of the
2=
Alliance Technology Report and
2
Recommendations.
The results of the
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1365 Main Street
Springfield, MA 01103-1615
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66 long Whorf
Boston, MA 02110-3610
(617) 723-0640
Pinsfield, MA (413) ~-7263
Hartford. CT (203) 525-3097
Northampton, MA (413) 586-3586 evenIng
TBKOPIER (413) 739-4226
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analysis and testing after the gas is
flared is that it meets DEP and EPA
requirements and recommendations, and it
is recommending that the flaring
continue.
I will be taking that one
step further.
I will put a slight
vacuum on
the well system to suck the
gases out of the ground to prevent the
gas from migrating and odor problem
1
seeping into the air, causing additional
1
atmospheric destruction.
I will also be
1
dehydrating the gas so when it burns
1
it'll burn hotter and cleaner.
This gas
1
is now going to be used on site.
It
1
will be pumped by pipeline for
1
industrial cogeneration use at Iron
1
Horse Park.
The pipeline will
cross
1
only the industrial property of the
1 c
energy users.
It doesn't matter to my
21
project what the final solution to the
2
capping or leachate problems are.
I can
2
draw on the existing resources without
2
interfering to the future solution, and
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1365 Main Street
Springfield, MA 01103-1615
("'3) 732-8100
66 long Wharf
Boston, MA 02110-3610
(617) 723.06.c0
Pittsfield, MA ("13) UJ.7263
Hartford, CT (203) 525-3097
Northampton, MA ("13) 586-3586e......ing,
TElECOPIER (413) 739-4226
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I will be meeting all DEP and EPA
requirements.
I cannot fix the
Superfund puzzle, but I can take one
piece of that puzzle and I can make it
much better.
If you folks have any questions
regarding my project,
I live in
Wilmington,
and I'm listed in the yellow
pages under Williams Energy Systems.
Feel free to give me a call,
because I'm
going to be going ahead with this
project in the next three to six months
as I receive licensing and permitting.
I should be able relieve a good part of
the problems in regard to odor and
migration of the landfill gas that is
there right now.
And I hope to have
your support.
Thank you.
MS. LESHEN:
The next person I'd
like to call is JoAnne Giovino.
MS. GIOVINO:
1981.
1981
was a
very significant year for me.
It was
the year that I gave birth to my first
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CATUOGNO COURT REPORTING SERVICES. INC.
1365 Main Street
Springfield, MA 01103-1615
(413) 732-8100
66 long Wharf
80Slon, MA 02110-3610
(617 ) 723-()6.4()
Pittsfield, MA (413) 443-7263
Hartford, CT (203) 525-3097
Northampton, MA (413) 586-3586 eVC!"'lln~
TELECOPIER (413) 739-4226
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child, a daughter.
And it also was the
first year I was introduced to Iron
Horse Park.
I realized that being a
parent was going to be a lifelong
responsibility.
I did not realize that
being a watchdog for Iron Horse Park was
going to become that too.
Little did I
think I'd be standing here ten years
later, trying to convince the EPA to do
the right thing.
What is the right
thing?
Closing the dump the best way
the first time around.
This
let's-try-this-first-and-see-what-
happens policy just isn't acceptable.
It seems to me that your preferred plan
is a Bandaid solution to a serious
problem.
We hear a lot about maintenance and
monitoring and I agree these are two
essential elements of the closure.
However, Alternative 4 in my opinion
depends too heavily on maintenance and
monitoring.
Time and time again history
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CATUOGNO COURT REPORTING SERVICES, INC.
1365 Main Street
Springfield, MA 01103.1615
(.13) 732-8100
66 long Wharf
Boston, MA 02110.3610
(617)723-06AO
Pittsfield, MA (.13) ..3.7263
Hartford, CT (203) 525-3097
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TELECOPIER (.13) 739.A226
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has shown us,
and our experience has
taught us, that maintenance and
monitoring are the very areas where Gray
Pond Realty has consistently failed.
It
is my opinion that the solution chosen
should be the one with the least amount
of maintenance and monitoring because at
best this is what we will get from Gray
Pond Realty.
What is needed to achieve a
community-acceptable solution?
One,. a
total cap reconstruction.
Strewn
throughout the many investigative
reports issued by the EPA, the integrity
of the cap has been considered
questionable, to say the least.
The
current cap has never been certified by
the DEP, that it fulfills the closure
compliance.
Quite to the contrary,
there have been many shortcomings
pointed out, and I do not see the EPA
addressing these flaws.
EPA has told us
that there are obstacles involved.
And
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66 Long Whorl
80stan, MA 02110-3610
(617) 723-06AO
Pinsfield, MA (AI3) 443-7263
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I suggest that you throw out that cookie
cutter solution, use ingenuity,
creativity,
and approach this with fresh
new ideas.
Number two,
I agree with Helen,
you
can't
fix something when it doesn't
work.
A complete redesign of the gas
collection and flare system has to be
done.
Maintenance is just not enough.
The design and implementation is
obviously flawed.
The design must be
fully reviewed and revamped.
DEP has
never
accepted this design.
It has only
been tentatively accepted,
and a grant
has not been permitted -- I mean,
a
permit has not been granted.
Excuse me.
I do agree with the EPA on the
leachate collection and off-site
treatment.
I think that's an excellent
idea.
And I agree with the EPA on a
site perimeter fence.
I think it's
necessary for site security.
And I
would also like to see a deed
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CATUOGNO COURT REPORTING SERVICES, INC.
1365 Main Street
Springfield. MA 01103-1615
(413) 732.8100
66 long Wharf
Boston, MA 02110-3610
(617) 723-0640
Pi"sfield. MA (413) 443.7263
Hartford, CT (203) 525-3097
Northampton. MA (413) 586-3586 e.ening,
TElECOPIER (413) 739.4226
-------
34
restriction.
Like my fellow SAC members,
I am
going to talk about bonding and escrow
accounts.
Past experience has taught us
never assume anything.
We have to know
that there is money put aside to
complete work and follow through on the
maintenance.
Thirty years is a long
time,
and I believe the key players will
1
change.
We may still be here, but I
1
doubt that Gray Pond Realty and you will
1
b
.lere.
Billerica does not want to
1
inherit this white elephant.
1
And finally, at this time I am
1
requesting the EPA to initiate a natural
11
resource damage assessment that's
1
provided by CERCLA,
in Section 107,
11
Paragraph D, entitled Natural Resource
1 c
Liability.
2 (
MS. LESHEN:
And now I'd like to
2
call on Richard Farren.
2:
MR. FARREN:
My name is Richard
2
Farren.
I live on Newport Drive, and
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I've been a resident of Billerica for
fifteen years.
Some friends and
neighbors in my neighborhood have
brought the issue of the landfill and
the EPA work to my attention,
and it's
been a concern to myself over the last
several years.
I'm a family -- a father of two.
I
have two children approaching teen-age
years,
and Content Brook runs directly
behind my property.
Over the years
we've bee~ plagued with,
in our
neighborhood,
the odor emanating from
the landfill site.
Content Brook has
not been what I would call one of the
most stable bodies of water.
There are
several different color variations
coming from the brook,
odors coming from
the brook, and this has all been of
concern to me.
I've only recently had an
opportunity to review some of the
material, but what I have reviewed
is
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(617) 723-0640
Pinsfield, MA (413) 443-7263
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fairly disturbing-
Number one,
a prior speaker talked
about a Bandaid approach,
and certainly
this reeks of a Bandaid approach.
There
are opportunities here to solve a
problem,
not just temporarily fix
something that may go away in fifteen to
thirty years.
And there is a long
history,
as some of the previous
speakers have spoken about.
It's not a
question where we can monitor or
maintain.
It's a~ opportunity where we
should eliminate and correct,
right from
day one.
There's a concern about the cap,
where it's a small percentage of the
entire landfill.
Not being an
environmental engineer, but just common
sense would tell you that the basic
problems aren't necessarily at the top
of the cap but certainly at the sides
where the groundwater and Content Brook
and Richardson Pond are.
The sides are
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where the biggest problems would be to a
layman.
There are some good points in terms
of the fence being constructed.
The
collection and transportation of the
leachate is important.
But beyond that,
I'm concerned that there may not be
enough testing used during the process
or even at the start of the process.
It
11
does not sound like there are adequate
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testing results.
Number one,
they
were
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last conducted in 1988,
a nd I'm
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14
Content Brook runs -- I'm at least a
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What about further down on the stream?
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here, and it's a crucial opportunity
that we must take advantage of.
As the
previous speakers have stated,
there
have been dozens of years that have gone
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I'm fearful that dozens of more years
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are going to be going by on the calendar
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solution.
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IC
MS. LESHEN:
The next person is
2(
John Morris.
2
MR. MORRIS:
My name is John
22
Morris, director of public health.
I've
2
been a resident of Billerica my entire
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life, thirty-one years.
At our last
gathering,
I mentioned to the EPA about
the escavation of this property and the
direct deposit of refuse into the water
)
table.
Well, since then the board of
health has reviewed your documents, and
we have developed our own preferred
alternative.
This alternative must
include, but may not be limited to the
1
following issues:
The EPA must require
1
(1) a total cap reconstruction;
( 2 )
1
repair and,
if need be,
replace or
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expand upon the current methane
1
collection system;
(3) containment,
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collection, and treatment of
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groundwater;
( 4 )
leachate collection and
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treatment;
(5) proper operation and
1
maintenance in place and properly
1
funded;
(6) a significant contingency
2
fund to cover the cost of any surprises;
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(7) cleanup of Richardson Pond;
( 8) we
2
need a significant escrow account for
2
future repairs or work that may need to
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be performed.
There i8 one lesson that we should
all learn here tonight, and that is that
we should learn from our mistakes.
During the last ten years, the Superfund
Action Committee and several other
residents of this town have been trying
to properly cap that landfill.
Whenever
we wanted to spend .ore money, we kept
hearing about this infamous escrow
account which had $700,000, which was to
be used for leachate collection.
There
was no more money.
We constantly heard
that until we finally applied some
pressure to politicians to get the fence
up,
and that is finally being done.
We should make darn sure that we
either appropriate or secure the
necessary funds from tbe responsible
parties up front.
It seems that the
bottom line to th'is cleanup is the
dollar amount.
Well, there can be no
dollar amount attached to anyone's
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health.
I am very concerned about the
residents of this town and our neighbor,
the Town of Tewksbury, and their well
water supply.
That's why I think that
we need one hundred and ten percent, not
one hundred percent, not fifty percent.
And be sure that we have selected the
best alternative to the cleanup of this
landfill.
Thank you.
MS LESHEN:
The next person is
Arnold Ventresca.
MR. VENTRESCA:
I'm Arnold
Ventresca, chairman of the Billerica
Board of Health.
I'd like to begin by
saying that I think that the EPA should
be the people who would recommend the
most effective possible solution, at
least initially.
At least as to going
in
position, that's where you should be.
It seems to me, though, that you are
more concerned with cost than
effectiveness.
As laypeople, we look to
agencies such as the EPA,
the experts,
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Pinsfield, MA (413) 443-7263
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to seek the one solution that will be
most effective in protecting the health
~
of the public and the environment.
I
thought that was what the "P" in EPA
meant.
We are not ready to accept your
proposed solution.
We want a complete
reconstruction of the cap; containment
and collection of the groundwater;
1
extraction and treatment of the
1
leachate; an effective methane control
1
system; complete perimeter fencing and
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posting at the site and continuous
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monitoring; an operation and maintenance
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that will provide the necessary
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protection; also continuous community
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involvement in the monitoring process.
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Although at the last meeting you said
1
that was not possible,
I don't believe
2
it.
2
Richardson Pond must also be part
2
of the final cleanup of -- I expect the
2
EPA to concern itself with the health of
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1365 Main Street
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(413) 732-8100
66 Lang Wharf
Boston. MA 02110-3610
(617) 723-0640
Pittsfield. MA (413) 443-7263
Hartford. CT (203) 525-3097
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the public and the environment, not the
wallet of the polluters.
Please
remember that your real responsibilities
are to protect the people and the
environment.
We will be the ones left
to live with the situation once a
solution is approved,
not the EPA, and
not the polluters.
MS. LESHEN:
The next person I'd
like to call is Brian Cangiamila.
MR. CANGIAMILA:
Thank you.
As
we've all heard tonight from many
speakers,
the many people that have been
involved with the problem up at Iron
Horse Park, the Shaffer Landfill, and
Richardson's Pond for many years, these
people have been fighting for more than
ten years to try to clean this problem
up.
Already one stop-gap solution has
been proposed.
A cap is in place, a
venting system has been put into place,
and none of these measures has dealt
with the problem effectively.
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(617)7~
Pittsfield. MA ('13) 443-7263
Hartford. CT (203) 52S-3097
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I think that we all could agree
that the process to introduce change in
the future is a lengthy process.
Already these people have been working
for, as
I said, ten years,
to try to
correct the problem, since the landfill
has been shut down, and again we are
going back to the process again, to
propose just a patch to a solution that
never works.
As the board of health spoke, and
the director of public health has
spoken,
the town has set down
some
reasonable goals for a solution to the
problem.
As the many residents have
expressed, many health hazards have
been, have surfaced throughout the
years, and the EPA and the Government's
just proposing to repair something
that's not worked.
As Helen Knight
mentioned earlier, we're looking at
trying to maintain a venting system that
doesn't work.
We're looking at
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(617) 723-06AO
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repairing a cap that never served the
purpose.
And we're completely
overlooking one of the most significant
points that needs to be addressed.
In your earlier comment back two
meetings ago, you mentioned that there
were unhealthy levels of arsenic in the
groundwaters.
In your preferred plan,
we're not even addressing the fact that
the groundwaters that are migrating
underneath the existing cap are not
going to be extracted and dealt with
properly.
We're going to, under the
proposed plan, allow those waters to
continue to migrate and fester with
whatever matter is stored under the
landfill.
I don't think anyone in this room
here can testify or certify what truly
is buried underneath that landfill.
Fortunately,
I live on the opposite side
of town, but as a state representative,
I'm concerned for all of the people of
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(617) 723-06AO
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TtLfCOPIER (A13) 739-A226
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the town.
Driving through that area at
any point in the year there are horriblE
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stenches that these people must live
with.
The venting system that's been
~
proposed does not meet -- does not solve
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the problem, does not purify or
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eliminate that odor that permeates the
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air.
I would like to propose to the EPA
1
to rethink the proposal,
to go with one
1
of the other alternatives,
preferably
1
a~~ernative S or SA, where the
1
groundwater is addressed,
totally
a new
1
cap is placed over the area, and that
1
the groundwater is
taken care of
in a
1
proper manner.
1
Trucking the water off-site by
1
means of a truck further poses health
1
hazards to all the residents of
2
Billerica and any other community which
2
those trucks pass through.
We've
seen
2
in the last year significant,
2
significant accidents that have,
that
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have had significant impact on
communities.
Some of the other speakers
have spoken about removing the
groundwaters by rail.
I would like the
EPA to consider constructing a
groundwater facility on site for
treating the water there, versus
trucking it or removing it from the site
at all.
Just to give you a little bit of an
analogy,
it would seem to be taking the
proposed ~andaid approach.
It's also
like having a leaky roof and going up on
the roof,
and you patch the leak.
Sooner or later, you're back up there
patching another leak.
The real problem
is that the cap does not work,
it's not
adequate,
it needs to be replaced.
I would like to ask the EPA to
rethink.
The monies are available.
The
real people that are responsible for
this problem should be held liable;
they're there now.
Ten years from now
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Baston, MA 02110.3610
(617) 723-0640
Pinsfield, MA (413) 443.7263
Hartford, CT (203) 525-3097
Northampton, MA (413) 586-3586 eve"'nc
TELECOPIER (413) 739-4226 -
-------
48
when this problem resurfaces, there's no
one in this room can tell who's going to
be there to pay for it.
There's no one
to say whether or not there'll be
Superfund monies to address the problem.
The problem's resurfaced.
We have a
serious health hazard.
And I would like
to ask the EPA to reconsider and address
the problem adequately and address it
1
once and for all. Thank you.
MS. LESHEN: And now I'd like to
call David DeLore-" Jr.
MR. DELOREY: My name is David F.
1
1
1
14
Delorey, Jr.
I live at 1 Edgar Road,
11
and I'm a selectman of the town.
11
I'd like to start off by
1
identifying what the problem is, and
11
then working toward the solution.
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problem is two.
The problem is that
21
there is no documentation,
and there
is
2
no oversight on the site.
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two problems.
All these other
issues
2
that we're talking about
are a
function
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of those two things.
I think that all
of the previous speakers, the EPA and
everyone else, have been very polite in
calling the Shaffer Landfill that,
because it is not that.
The difference between a landfill
and a dump is that a dump doesn't have
any documentation.
A dump does not have
any oversight.
This is a dump
we're
talking about, not a landfill.
50 with
regard to that,
I think that it
is
important to outline tha'
Nhat we really
have here is a problem.
What we have is
a landfill that doesn't have a liner.
Nobody would recommend a landfill
without a liner, so it is a dump.
In
addition to the absence of a liner,
excavations have been alleged fifteen
feet below the current grade, which
further exacerbates the problem of not
having a liner.
In addition,
the current landfill
has been presumably capped, but it has
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(617) 723-0640
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all kinds of problems:
flat spots,
depressions,
fractures, outbreaks,
and
so on.
And as a function of that,
the
current cap does not seem to be quite
adequate to deal with the problem.
The
landfill slopes are not recommended
slopes.
There are -- the prescribed
slopes are three
these are,
to one;
these slopes are much more, much
steeper.
A couple of things ought to be
considered when dealing with the~-
slopes,
some corrective measures.
One
of them would be that denting would be
put on the surface,
that they would be
terraced, or they would put retaining
walls,
or they would put traprock or
they would encroach on the wetlands,
or
the solution would have to be to shave
the slopes,
the material
from
or remove
the slope back to the top;
or they would
do all of these things.
But something
must be done toward the three to one
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CATUOGNO COURT REPORTING SERVICES. INC.
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1413} 732-8100
66 Long Wharf
Baston. MA 02110-3610
(617) 723-0640
Pittsfield. MA (413) 443-7263
Hartford. CT (203) 525-3097
Northampton, MA (413) 586-3586eweninl
TELECOPIER (413) 739-4226
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slopes.
Because the landfill doesn't have
any manifest records,
as I indicated at
our last meeting, this leads to
testimony that this is in fact a dump
and not a landfill.
And another idea
that has surfaced, or another constraint
has surfaced.
In the last meeting when
discussing the idea of other remedies,
one was that the bedrock was fractured
below the surface; and as a result of
that,
that even further exacerbates the
problems, because any leachate will now
get into the bedrock, will get into the
aquifer.
So that puts the town at
further risk.
In addition, it's been alleged that
the rail bed has subsurface piping that
has not been plugged.
Currently the
site security is at a minimum, and there
is a potential for the addition of
unauthorized materials and all sorts of
other problems.
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8oston, MA 02110-3610
(617) 723-()64()
Pittsfield, MA (413) ~7263
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So as a result of all of these
.
constraints,
I think that we have a
special need to deal with the cap,
,
because the cap,
if not properly put
in
1
place, generates even more and more
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leachate and puts all of those
issues
.
that I just mentioned at risk.
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What we have now,
for a collection
system,
is -- Content Brook apparently
11
serves as a role of disposing of some of
1
the leachate.
That has to be checked.
1
There has to be something put in the way
1
of between the dump and the brook.
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Benchmark testings must be done
in
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a tighter time frame and they must be
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preservedd, not thrown away.
If -- what
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we need is the benchmark tests put in
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little bottles and we can watch them.
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Again, we don*t know what's in that
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landfill,
and our sophistication with
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checking chemicals is not geared to
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checking the things that we don't know
23
all the problems right now.
So we
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should put those bottles away and look
at them as the thirty-year maintenance
cycle goes through.
We should put test wells, but not
just one set of test wells.
They should
be -- I would call them shells, or onion
skins, that round the, around the site.
Perhaps -- and a minimum of two -- and
to watch the leachate lateral migration,
because the leachate lateral migration
is going to be a problem in the future.
We don't know what's going to happen to
this dump because we don't know what
is
in this dump, and we don't know if the
EPA's solution,
if it doesn't involve a
total, one hundred percent solution for
a cap, what that will do five years, ten
years,
fifteen years, twenty years, and
so on down the cycle.
We need to have some control plans
and those control plans should be fully
funded up front, not later.
There
should be
some assurances.
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66 long Wharf
Bos'on, MA 02110-3610
(617) 723-0640
Pi"sfield, MA (413) 443.7263
Hartford, CT (203) 525-3097
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The notion of a bond or an escrow
account or some such thing like that
must be put in place so that it can be
paid for, because the third problem,
beyond the documentation and the
oversight, was the finances.
It's
already been brought out by a number of
previous people.
The finances are not
there when we need them to react to the
II
problem.
As a result, the people in
1
that area, the town of Billerica, the
1
town of Tewksbury, are all put at risk
1
for that third problem, which is
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finances.
1
The stack monitoring.
There's a
1
gentleman previously who spoke of it,
1
Mr. Williams.
The stack monitoring
11
should be done before and after the -- I
11
spoke with Mr. Williams and we had a
2 (
very interesting discussion about this,
2
and I would hope that the EPA would
24
require before and after stack
2.
monitoring.
We are not going -- we
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should not incinerate chemicals like
PCB's and PVB's at temperatures of four
to six hundred degrees.
You need
eighteen hundred degrees for those
particular chemicals.
Others need
different temperatures.
We should find
out what we're burning before we put it
into the
air.
The groundwater treatment must be
offsite.
It's far too costly to build a
groundwater treatment plant onsite and
defend it.
And what I mean is that it
would be subject to vandalism.
All it
will take is one vandalism attack to
render our whole operation useless for
long periods of time.
There is no way we are going to
reclaim the spillages from an act of
vandalism or a mechanical breakdown on
site.
We must have disaster recovery
procedures and event management, and in
no case should the documentation of this
site ever not be a public record.
The
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(617) 723-06AO
Pittsfield. MA (AI3) U3.7263
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problem with this landfill -- again,
I
said the two major problems were
.
documentation and oversight.
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oversee
that which you, that which is a
secret.
50 all of the documentation
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should be a matter of public record sent
to the board of selectmen, the board of
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health, and to the Billerica Public
Library for those folks that are
interested in finding out the progress
of the maintenance the EPA will put
forward.
I'm not going to get into an awful
lot of other details about a couple of
other issues, but I just wanted to leave
the EPA with the notion that we should
have adequate documentation.
We should
look to the future so that we can
manage, successfully manage and react in
a timely fashion, to events that we have
no idea will happen at this time because
we have no idea what is in that
landfill.
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Pittsfield, MA (413) 44:)-7263
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And the last remark I'd like to
make is that, because the town, this is
the last time the townspeople and the
town will have an opportunity to comment
on the details of the EPA's plans and
remedies, that I plan on filing, and I
would assume that the board of selectmen
ultimately will plan on filing,
in
addition to some of the remarks I made,
other remarks plus some questions for
the EPA to answer that there
are no
answers
for at this time, as we learned
at the last comment period.
I would like to thank the EPA for
providing us this opportunity to provide
comments.
I'd also like to thank them
for extending the comment period to
allow the townspeople to react to your
recommendations.
In summary,
I believe
we should have a total cap, and we
should have an adequate groundwater and
leachate collection system.
And I'm not
an engineer so I don't know what that
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66 long Wharf
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(617 )723-0640
Pinsfield. MA (413) 443-7263
Hartford. CT (203) 525-3097
Northamplon, MA (413)586-3586 evening:
TELECOPIER (413) 739-4226
-------
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r
is.
Other folks can speak to that.
Thank you.
MS. LESHEN:
I'd like to call
Arthur Doyle.
MR. DOYLE:
Most of it's been said.
I don't like to reiterate, but as a town
selectman and a committee member,
I want
to stress the fear that the money will
not be there to complete this job.
We
l(
hoped that you would have the money up
1
front so that when you're fifty percent
L:
or 'seventy-five percent, along with the
L
job, you won't. walk away from the job.
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If the money is in an escrow account, we
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know it's guaranteed.
We know the money
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is there,
and the job will be completed.
1
This is a fear of most of us in the
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town.
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Also, too, an ongoing project
2(
2]
report should be sent to the board of
selectmen,
the board of health,
and even
22
a coopy to the library,
so that we
2
could, anybody could get their hands on
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Springfield, MA 01103-1615
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(617) 723-0640
Pittsfield, MA (413) 443-7263
Hartford, CT (203) 525-3097
Northampton. MA (413) 586-3586 evenings
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it, and read it, so there won't be any
surprises, and the work being done on
this project, and we'll know what's
going on on an ongoing -- and there
won't be anything confidential in this,
because there shouldn't be anything
confidential.
I want to see everything
kept above board, so that we all know
what's going on during the cleanup.
I want to thank the EPA for giving
us this opportunity to stress our
fee 1 i n g s '":!n t his.
Thank you.
MS. LESHEN:
If anyone would like
to make additional comments, you can
just put up your hand, and we have
additional cards, but we also have two
people that would like to make a
comment.
I'll call Christine Chisholm.
Christine Chisholm.
MS. CHISHOLM:
I've been living in
Billerica all my life, and I'm an
environmental scientist.
I was asked to
look over some of the documents.
I
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CATUOGNO COURT REPORTING SERVICES, INC.
1365 Main Street
Springfield. MA 01103-1615
(AI3) 732-8100
66 long Wharf
Bo,ton, MA 02110-3610
(617) 723-06AO
Pilllfield, MA (AI3) AA3.7263
Hartford, CT (203) 525-3097
Northampton. MA (AI3) 586-3586 evenin!
TELECOPIER (AI3) 739.A226
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haven't been with the Superfund Action
Committee as long as some other people
have, but I was able to make some
technical advisory comments to the
Superfund Action Committee.
A comment was made at the last
meeting, 2/5/91, that the caps are
atypical, liners are the norm, and caps
are a fix.
While in the mid-'60s, the
Department of Natural Resources gave a
permit to the Shaffer's on the condition
that a liner be
p"...L': in,
a liner was
never installed into the landfill, and
the landfill was actually excavated
fifteen feet below the groundwater
table.
Therefore we want the best fix
for this landfill, a total
reconstruction of the cap,
as other
people have mentioned.
The EPA's remedy assumes that
over
time, contamination levels
in the
groundwater will decrease.
Given the
current contamination levels adjacent to
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66 long Wharf
BasIon. MA 02110.3610
(617) 723.a640
Pinsfi.ld, MA (413) .0.7263
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the landfill and the absence of
groundwater treatment,
I feel that
detailed and rigorous groundwater
monitoring program is necessary to
ensure
that the cap is achieving its
design criteria.
It is imperative that
this monitoring program include
contingencies for groundwater treatment
should contamination levels increase
above the maximum contamination levels,
or the MCL's.
I s u g g est t hat the .,. nit 0 r i n g
program include a series of monitoring
wells adjacent to the landfill and a
series adjacent to the property lines.
Prior to this, a round of current
groundwater and surface water samples
should be taken in order to adequately
assess
current contamination levels.
The last round of samples was taken in
1988, two years ago.
With groundwater
movement occurring, according to the
EPA, at 50 to 500 feet per year, a
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BaSIon. MA 0211G-3610
(617) 723-06AO
Pittsfield, MA (AI3) AA3-7263
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Northampton, MA (A13) 586-3586evenin\
TELECOPIER (AI3) 739."226
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two-year monitoring gap or sampling gap
seems to be a rather inadequate
assessment of current levels, and
, .
therefore an inadequate basis for
current or design criteria.
I agree with EPA regarding the
on-site collection of leachate and the
off-site treatment of this leachate.
I
also agree with the perimeter fence and
l(
!'m rather surprised that we are now
1
just getting this fence.
! also want to
1~
reiterate the point that JoAnne
ide, to
1
initiate a natural resource damage
1 '
assessment as provided by CERCLA.
Thank
l'
you.
1E
MS. LESHEN:
!'d like to call
1
Robert Donati.
IE
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MR. DONAT!:
Hi.
I live on 302
Andover Road.
I'm also an environmental
2C
engineer who has worked on the Superfund
2
sites for several years,
so !'m familiar
2~
with the activities that take place.
2
The entire effectiveness of the
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Pi",field, MA (AI3) 4&3-7263
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Northampton, MA (AI3) 586-3S86evenir
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remedial design that EPA chose is
contingent upon the integrity of the
cap; That is, that the cap would
completely isolate the waste, reducing
the migration of leachate into the
groundwater and resulting in an overall
reduction of groundwater contamination
levels.
The remedy also assumes that
the existing cap was properly installed
to begin with.
That is, proper
c~mpaction and moisture content
requirements were attained.
And given
the past history of the landfill
activities,
I think this is a very
generous, if not unfounded,
assumption.
In the documents I read there's no
information to indicate that the
landfill cap was installed properly to
begin with.
Throughout the remedial
investigation report, there were
concerns raised regarding the integrity
of the existing cap.
These concerns
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801l0n. MA 0211G-3610
(617) 723-0640
Pi",field. MA (413) ~-7263
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Northomplon. MA (413) 586-3586 evenln~
TELfCOPIER (413) 739-4226
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included inadequate and inconsistent
thicknesses of the impermeable clay
layer, topsoil layer in many areas not
thick enough to support vegetation to
prevent erosion, lack of a sufficient
drainage layer, or any drainage layer
for that matter, and I think most
importantly, concerns that the cover may
not adequately protect against frost
1
damage to the clay layer.
There's test
1
pits and perm~ability testing
1
information r~sults tha~ have been
1
conducted that support that conclusion.
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I think while the EPA option
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addresses some of these problems,
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don't think it addresses the two most
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important ones, that is, whether the
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existing cap was properly installed and
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in the absence of any drainage layer,
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with the option that's selected,
that
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this 'would 'prevent frost damage to the
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clay layer.
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Given all the concerns raised and
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Pittsfield. MA (413) 40&3-7263
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the RI and other reports, it would
appear obvious to me and apparently to
everybody else that's been up here
tonight that without groundwater
treat~ent,
the only remedy of choice
would be a total reconstruction of the
cap, a cap that includes a liner, a
drainage layer, a filter layer, and a
vegetative cover.
This also meets EPA's
recommendations for the design.
A cover
design that just satisfies the '84
consent decree does not appear to be
adequate.
In addition, along with the
reconstruction,
I think it's necessary
that we institute strong institutional
controls to prevent human exposure to
the soils and groundwater, to prevent
any groundwater on that site from being
used for drinking in the future.
Thank
you.
MS. LESHEN:
At this point I would
like to ask, is there anyone else that
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80lton, MA 0211G-3610
(617) 723-0640
Pittsfield, MA (413) 443-7263
Hamo,d, CT (203) 52S-3097
Northampton, MA (413) 586-3586 evening:
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would like to make a comment into the
record?
You can go again.
Is there
anyone else?
Is .there anyone else that
would like to make a comment into the
record?
MR. DELOREY:
David Delorey.
There's one thing that is very striking
in the EPA's matrix,
the recommended
matrix,
and that is that one of them is
to do nothing, which is one absurd
solution to the problem.
But the other
absurd solution to the problem that is
not priced out,
so that we can find out
what the real limits are,
is to do right
by what all the regulations
are in
place
right now; that is to put a liner under
the landfill.
No one priced that part
out.
Now, I admit it's an exercise, but
so isn't doing nothing.
But it does
frame the problem.
And, you know, to
really solve the problem,
I think,
is to
dispose of all the materials in the
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(617) 72~
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proper fashion and convert the dump into
a landfill.
So I would appreciate the
EPA just taking a look at that,
just to
frame the price,
to make sure that when
this goes,
it will end up in court in
terms of assessing the costs, that the
courts are apprised of how reasonable
the solution put forth tonight is,
in
terms of the current -- of the
recommendation's
implementation, which
I, which I would say would be in the
tens of millions,
if not in the hundreds
of millions of dollars to do that
solution.
And I think that that serves
the responsible parties well.
Thank
you.
MS. LESHEN:
Is there anyone else
that would like to read a comment into
the record this evening?
Hearing no further requests, I will
close the hearing this evening.
People
are welcome to submit written comments
to our office by March 16.
They should
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State
National
Inte,natianal
CATUOGNO COURT REPORTING SERVICES, INC.
1365 Main Street
Springfield. MA 01103.1615
(413) 732.8100
Pittsfield, MA (413) 443.7263
Hartford. CT (203) 525-3097
Northampton, MA (413)586-3586 evening
TELECOPIER (413) 739.4226
66 Long Wharf
Balton, MA 02110-3610
(617) 723-0640
-------
68
I
I
I
I
I
I
1
I
11
l~
2
2
2
2
be addressed to Don McElroy,
and his
address is on the back of the proposed
plan.
The comments received this
evening,
February 5, as well as any
comments received in writing prior to
March 16 will be responded to in writing
in a document called a Responsiveness
Summary, which will be attached to a
decision document called a Record of
Decision.
The proposed plans,
if anyone needs
one,
are at the desk coming
in, as
well
as there is additional information in
terms of the remedial investigation and
feasibility study, which are available
in the Billerica Public Library,
as well
as our offices in Boston.
Hearing no further comments,
I will
close the hearing this evening.
(Hearing closed)
-_"'';'''':'''''9~
- ~ - .
,; 1£. ~
': -
~~}
. .,~~..g-
State
National
International
CATUOGNO COURT REPORTING SERVICES, INC.
1365 Main Slree'
Springfield, MA 01103-1615
(413) 732-8100
66 long Wharf
Boston, MA 02110.3610
(617) 72:J.06.«>
Pi"sfield. MA (.13) 40&3-7263
Hartford. CT (203) 525-3097
Narthamp'on. MA (413) 586-3586 evenings
TfLECOPIER (413) 739-4226
-------
(j
I;
,
69
ENVIRONMENTAL PROTECTION AGENCY
I ,
BROOKS, Registered
ELIZABETH M.
Professional Reporter, do hereby certify that the
1
foregoing testimony is true and accurate,
to the best
1
of my knowledge and ability.
1
Februar" ,
1
1
1
1
1
EMB/ed
1
1 c
2 (
2
2
2
WITNESS MY HAND,
1991.
this 22nd day of
~~I:2_- [ -------
EliZa~rOOkS
'--'~'~'.:"\
,. .
; !
~~..i
...,,~~......-
State
National
International
CATUOGNO COURT REPORTING SERVICES. INC.
1365 Main Street
Springfield. MA 01103.1615
(413) 732.8100
66 Long Wharf
Bolton. MA 02110-3610
(617) 723-0640
Pinlfield. MA (413) U3.7263
Hartford. CT (203) 525-3097
Northampton. MA (413) 586-3586 evenings
TELECOPIER (413) 739.4226
-------
-------
o
Iron Horse Park
(Operable Unit II - Shaffer Landfill)
NPL Site Administrative Record
Index
Compiled: January 15, 1991
ROD Signed: June 27, 1991
Prepared for
Region I
Waste Management Division
U.S. Environmental Protection Agency
With Assistance from
AMERICAN MANAGEMENT SYSTEMS, INC.
One Bowdoin Square, 7th Floor. Boston, Massachusetts 02114 . (617) 557-2000
-------
This docU11'U!nt was prepared under EP A's TES 6 prime contract (#68-W9-0003) for EP A
Region I. American Management Systems, Inc. prepared the doCU11'U!nt under a subcontract
(#1-635-999-AMS) with Alliance Techn%gies Corporation.
-------
{)
This Document Printed on Recycled Paper
"
-------
Volume I
Iron Horse Park
. .
(Operable Unit II . Shaffer Landfill)
NPL Site Administrative Record
(ROD Signed: June 27, 1991)
Table of Contents
1.0 Pre-Remedial
1.18 FIT Technical Direction Documents (!DDs) and Associated Records
3.0 Remedial Investigation (RI)
Volume n
3.1
3.2
3.4
3.5
3.6
Correspondence
Sampling and Analysis Data
Interim Deliverables
Applicable or Relevant and Appropriate Requirements (ARARs)
Remedial Investigation (RI) Reports
3.6
3.7
Remedial Investigation (RI) Reports (cont'd.)
Work Plans and Progress Reports
4.0 Feasibility Study (FS)
Volume ill
4.1
4.5
4.6
4.9
Correspondence
Applicable or Relevant and Appropriate Requirements (ARARs)
Feasibility Study (FS) Reports
Proposed Plan for Selected Remedial Action
5.0 Record of Decision (ROD)
5.1
5.3
5.4
Correspondence
Responsiveness Summaries
Record of Decision (ROD)
10.0 Enforcement
10.3 State and Local Enforcement Records
11.0 Potentially Responsible Party (PRP)
11.9 PRP-Specific Correspondence
11.12 PRP-Related Documents
-------
()
Iron Horse Park
(Operable Unit II . Shaffer Landfill)
NPL Site Administrative Record
(ROD Signed: June 27, 1991)
V olume IV
13.0 Community Relations
13.1 Correspondence
13.3 News Clippings/Press Releases
13.4 Public Meetings
Volume V
13.5 Fact Sheets
13.7 Technical Assistance Grants
14.0 Congressional Relations
14.1 Correspondence
17.0 Site Management Records
17.1 Correspondence
17.4 Site Photographs/Maps
17.5 Site Descriptions/Chronologies
17.8 State and Local Technical Records
V olume VI
17.8 State and Local Technical Records (cont'd.)
Volume VD
17.8 State and Local Technical Records (cont'd.)
Volume VDI
17.8 State and Local Technical Records (cont'd.)
Volume IX
17.8 State and Local Technical Records (cont'd.)
-------
This Document Printed on Recycled Paper
.
-------
o
Introduction
This document is the Index to the Administrative Record for the June 27, 1991 Record of
Decision (ROD) for the Iron Horse Park National Priorities List (NfL) site (Operable Unit n -
Shaffer Landfill). Section I of the Index cites site-specific documents, and Section n cites guidance.
documents used by EP A 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,
Massachusetts, and at the Billerica Public Library, 2S Concord Road, Billerica, Massachusetts,
01821. This Administrative Record includes, by reference only, all documents included in the
September 14,1988 Administrative Record/or this NPL site. Questions concerning the
Administrative Record should be addressed to the EP A 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 (SARA).
-------
Section I
Site-Specific Documents
'"
-------
£)
Page 1
ADMINISTRATIVE RECORD INDEX
for the
Iron Horse Park NPL Site
(Operable Unit n . Shaffer Landfill)
ROD Signed: June 27,1991
1.0
Pre-Remedial
1.18 FIT Technical Direction Documents (TDDs) and Associated Records
3.0
Memorandum from Rebecca Deaver, NUS Corporation to Richard Leighton,
EPA Region I (March 6,1984). Concerning drinking water samples tested for
metals.
Memorandum from Rebecca Deaver, NUS Corporation to Richard Leighton,
EPA Region I (April 24, 1984). Concerning the transmittal of analytical results
for all samples collected during the NUSIFlT Site Inspection.
Remedial Investigation (RI)
1.
2.
3.1
Correspondence
3.2
Memorandum from Bruce Marshall, EP A Region I to Addressees
(April 17 , 1987). Concerning transmittal of the WetlandlFloodplain and Biota
Assessment sections of the Remedial InvestigationIFeasibility Study work plan
and the request for written comments by May 6, 1987.
Memorandum from Bruce Marshall, EP A Region I to Addressees
(May 13, 1987). Concerning transmittal of the Remedial Investigation Phase IA
Report and the request for written comments by June 1, 1987.
l..A:tter from Ralph P. Penney, GHR Engineering Associates, Inc. to John
Gallagher, EP A Region I (March 15, 1989). Concerning transmittal of the
attached infonnation pertaining to capping activities at the landfill.
Letter from John Gallagher, EP A Region I to Richard Bento, Town of Billerica
Department of Public Works (December 6, 1989). Concerning transmittal of the
November 1989 "Phase IC Remedial Investigation Report - Volume I," Camp
Dresser & McKee Inc. for comments.
Letter from John Gallagher, EP A Region I to Dale Young, Commonwealth of
Massachusetts Department of Environmental Protection (December 6, 1989).
Concerning transmittal of the November 1989 "Phase IC Remedial Investigation
Report - Volume I," Camp Dresser & McKee Inc. for comments.
Letter from John Gallagher, EPA Region I to Raymond G. Dougan,
Commonwealth of Massachusetts Department of the Attorney General
(January 3,1990). Concerning transmittal of the November 1989 "Phase IC
Remedial Investigation Report - Volume I," Camp Dresser & McKee Inc. and
the Shaffer Landfill Draft Feasibility Study for comments.
Sampling and Analysis Data
1.
.'I~'.
,
. "2.
3.
4.
5.
6.
Additional Sampling and Analysis and Contract lAboratory Program (CIP) Data as
well as the Chain of Custody Recortbfor the Remedial Investigation (Rl)for both
Operable Units may be reviewed, by appointment only, at EPA Region I, Boston,
MassachusettS .
-------
Page 2
3.2
Sampling and Analysis Data (cont'~.)
3.4
Letter from Stephen V. Capone, Alliance Technologies Corporation to Edward
Braczyk, Commonwealth of Massachusetts Department of Environmental
Quality Engineering (November 7,1988). Concerning ttansmittal of the
attached "Summary Report - Gas Flare Testing - Passive Mode."
Memorandum from Scott Clifford and Mary Jane Cuzzupe, EPA Region I to
John Carlson, EP A Region I (September 11, 1989). Concerning drinking water'
purgeable organic analysis.
"Residential Property Sampling Survey," Roy F. Weston, Inc.
(September 19, 1989).
Memorandum from Michael Whitehead, Camp Dresser & McKee Inc. to Dick
Christian, Camp Dresser & McKee Inc. (November 1, 1989). Concerning the
results of the permeability and density tests performed to evaluate the caps at the
site.
Memorandum from Thomas McGrath, Commonwealth of Massachusetts
Department of Environmental Protection to Helen Waldorf, Commonwealth of
Massachusetts Department of Environmental Protection (June 4, 1990).
Concerning the results of air monitoring conducted during the May 23, 1990 site
walkover.
Memorandum from Thomas McGrath, Commonwealth of Massachusetts
Department of Environmental Protection to Dale Young, Commonwealth of
Massachusetts Department of Environmental Protection (July 31, 1990).
Concerning the results of the detailed landfill gas emission survey conducted on
July 2, 1990 and July 16, 1990.
Interim Deliverables
1.
2.
3.
4.
5.
6.
3.5
"Wet"- -js Characterization and Biological Investigations," CDM Federal
Pro~_...ns Corporation (January 1989).
Applicable or Relevant and Appropriate Requirements (ARARs)
1.
3.6
Letter from Rich Cavagnero, EP A Region I to Madeline Snow, Commonwealth
of Massachusetts Department of Environmental Quality Engineering
(March 12, 1987). Concerning the request to identify the Applicable or Relevant
and Appropriate Requirements (ARARs) for the B & M Lagoon and the Shaffer
Landfill.
Letter from John Gallagher, EP A Region I to Robert Bois, Commonwealth of
Massachusetts Department of Environmental Quality Engineering
(July 14, 1989). Concerning the request to identify the Applicable or Relevant
and Appropriate Requirements (ARARs) for the Shaffer Landfill.
Remedial Investigation (RI) Reports
1.
2.
3.7
"Phase IC Remedial Investigation Report - Volume I," Camp Dresser & McKee
Inc. (November 1989).
''Phase IC Remedial Investigation Report - Volume n - Appendices," Camp
Dresser & McKee Inc. (November 1989).
Work Plans and Progress Reports
1.
2.
1.
Letter from Sharon A. Checrallah, JoAnne Giovino, Dorothy P. Walker, and
Helen R. Knight, Superfund Action Committee to Richard Leighton, EP A
Region I (March 23, 1985). Concerning comments on the December 21, 1984
"Draft Work Plan for Remedial InvestigationIFeasibility Study - Volume I:
Technical Scope of Work," Camp Dresser & McKee Inc.
"Work Plan Excerpts for Shaffer Landfill (RI only)."
2.
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o
Page 3
4.1
Feasibility Study (FS)
Correspondence
4.0
1.
Letter from John Gallagher, EPA Region I to John W. Duggan, Commonwealth
of Massachusetts Department of Environmental Protection (December 15, 1989).
Concerning transmittal of the first draft of the Feasibility Study.
Letter from John Gallagher, EPA Region I to Ken Carr, U.S. Fish & Wildlife
Service (December 15, 1989). Concerning transmittal of the first draft of the
Feasibility Study.
Letter from John Gallagher, EP A Region I to Dale Young, Commonwealth of
Massachusetts Department of Environmental Protection (December 15, 1989).
Concerning transmittal of the first draft of the Feasibility Study.
Letter from Don McElroy, EP A Region I to Allen Johnson, Massachusetts
Historical Commission (March 6,1991). Concerning the remedial alternatives
being contemplated by EP A and their effect on the Middlesex Canal.
Letter from Elsa Fitzgerald for Judith B. McDonough, Massachusetts Historical
Commission to Don McElroy, EPA Region I (March 22,1991) with two
attached letters. Concerning the remedial work scheduled for the site and how it
relates to the Middlesex Canal
2.
3.
4.
5.
4.5
Applicable or Relevant and Appropriate Requirements (ARARs)
1.
Letter from M. Gretchen Muench, EPA Region I to Donald Nagle,
Commonwealth of Massachusetts Department of Environmental Protection
(Apri112, 1991). Concerning notification thatEP~ Region I does not believe
that the Massachusetts Contingency Plan and Chapter 21E are Applicable or
Relevant and API'" ''ite ReqAirements (ARARs) and the attached:
A. Letter from ',. .Jiam Walsh-Rogalski, EPA Region I to Peter R. Bronson,
Commonwealth of Massachusetts Department of Environmental Protection
(January 3, 1991).
B. Letter from William Walsh-Rogalski, EPA Region I to Peter R. Bronson,
Commonwealth of Massachusetts Department of Environmental Protection
(January 9, 1991).
Letter from Peter R. Bronson, Commonwealth of Massachusetts Department of
Environmental Protection to William Walsh-Rogalski, EPA Region I
(April 22, 1991). Concerning the Commonwealth of Massachusetts Department
of Environmental Protection's position on whether the Massachusetts
Contingency Plan is an Applicable or Relevant and Appropriate Requirement
(ARAR).
Memorandum from M. Gretchen Muench, EP A Region I to File
(June 27, 1991). Concerning notification that EPA Region I does not consider
310 CMR 19.150, 151,021 to be Applicable or Relevant and Appropriate
Requirements (ARARs) and that the state will concur with the selected remedy.
2.
3.
4.6
Feasibility Study (FS) Reports
Report
1.
"Final Draft Phase IC Feasibility Study Report," Camp Dresser & McKee Inc.
(January 1991).
-------
5.0
Page 4
4.6
Feasibility Study (FS) RepOrts (cont'd.)
Comments
4.9
Cross-Reference: Comments Dated February 22,1991 from Thomas G.
Carbone, Town of Tewksbury on the January 1991 "Final Draft Phase IC
Feasibility Study," Camp Dresser & McKee Inc. and the January 1991 Proposed
Plan [Filed and cited as entry number 2 in 5.3 Responsiveness Summaries].
Cross-Reference: Comments Dated March 6,1991 from Arnold Ventresca,
Wallace Mallett, Paul Ransom, Marie O'Rourke, Robert Soloman, John W.
Morris on the January 1991 Proposed Plan [Filed and cited as entry number 16
in 5.3 Responsiveness Summaries].
Cross-Reference: Comments Dated March 14, 1991 from David F. Delorey Jr.,
Town of Billerica on the January 1991 "Final Draft Phase IC Feasibility Study,"
Camp Dresser & McKee Inc. and the January 1991 Proposed Plan [Filed and
cited as entry number 28 in 5.3 Responsiveness Summaries].
Cross-Reference: Comments Dated March 15, 1991 from Town of Billerica
Conservation Commission on the January 1991 "Final Draft Phase IC Feasibility
Study," Camp Dresser & McKee Inc. and the January 1991 Proposed Plan
[Filed and cited as entry number 35 in 5.3 Responsiveness Summaries].
Proposed Plan for Selected Remedial Action
2.
3.
4.
5.
1.
2.
"EP A Proposes Cleanup Plan for the Shaffer Landfill Portion of the Iron Horse
Park Superfund Site," EPA Region I (January 1991).
"EP A Issues Supplement to Proposed Plan for Cleanup of the Shaffer Landfill
Landfill, Iron Horse Park Superfund Site," EPA Region I (May 1991).
Record of Decision (ROD)
. .~\ ;\
5.1
Correspondence
1.
Memorandum from Don McElroy, EP A Region I to File (June 26, 1991).
Concerning notification that EP A Region I coordinated with the Commonwealth
of Massachusetts Department of Environmental Protection and solicited and
received comments on the January 1991 "Final Draft Phase IC Feasibility
Study," Camp Dresser & McKee Inc., the January 1991 Proposed Plan, the
May 1991 Supplemental Proposed Plan, and the Record of Decision (ROD).
Cross-Reference: Memorandum from M. Gretchen Muench, EPA Region I to
File (June 27, 1991). Concerning notification that EP A Region I does not
consider31OCMR 19.150, 151,021 to be Applicable or Relevant and .
Appropriate Requirements (ARARs) and that the state will concur with the
selected remedy [Filed and cited as entry number 3 in 4.5 Applicable or Relevant
and Appropriate Requirements (ARARs)].
"Total Estimated Costs for Shaffer Remedy," EPA Region I.
2.
3.
5.3
Responsiveness Summaries
1.
Cross-Reference: Responsiveness Summary is an attachment to the
June 27,1991 "Record of Decision," EPA Region I [Filed and cited as entry
number 1 in 5.4 Record of Decision (ROD)].
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G\
Page 5
5.3
Responsiveness Sununar.ies (cont'd.)
The following citations indicate documentS received by EP A Region 1 during the first
formtJl public comment period.
2. Comments Dated February 22, 1991 from Thomas G. Carbone, Town of
Tewksbury on the January 1991 "Final Draft Phase IC Feasibility Study," Camp
Dresser & McKee Inc. and the January 1991 Proposed Plan.
3. Comments Dated February 25, 1991 from Jerry L. Tuzzolo and Stephanie M.
Tuzzolo on the January 1991 Proposed Plan.
4. 1 Comment Letter Dated February 27, 1991 from Member of the Public on the
January 1991 Proposed Plan.
5. 4 Comment Letters Dated February 28, 1991 from Members of the Public on the
January 1991 Proposed Plan.
6. 21 Comment Letters Dated March 1, 1991 from Members of the Public on the
January 1991 Proposed Plan.
7. Comments Dated March 1, 1991 from Patricia McGovern, Commonwealth of
Massachusetts Committee on Ways and Means on the January 1991 Proposed
Plan.
8. Comments Dated March 1, 1991 from Brion M. Cangiamila, Member of the
Commonwealth of Massachusetts House of Representatives on the Proposed
Plan.
9. 3 Comment Letters Dated March 2,1991 from Members of the Public on the
January 1991 Proposed Plan.
10. 2 Comment Letters Dated March 3, 1991 from Members of the Public on the
January 1991 Proposed Plan.
11. 9 Comment Letters Dated March 4,1991 from Members of the Public on.the
January 1991 Proposed Plan.
12. 12 Comment Letters Dated March 5, 1991 w.1embers of the Public on the
January 1991 Proposed Plan.
13. Comments Dated March 5, 1991 from Levon Chorbajian on the January 1991
Proposed Plan.
14. 18 Comment Letters Dated March 6, 1991 from Members of the Public on the
January 1991 Proposed Plan.
15. Comments Dated March 6, 1991 from John 1. Moynihan on the January 1991
Proposed Plan.
16. Comments Dated March 6, 1991 from Arnold Ventresca, Wallace Mallett, Paul
Ransom, Marie O'Rourke, Robert Soloman, John W. Morris, Town of Billerica
on the January 1991 "Final Draft Phase IC Feasibility Study," Camp Dresser &
McKee Inc. and the January 1991 Proposed Plan.
17. 10 Comment Letters Dated March 7, 1991 from Members of the Public on the
January 1991 Proposed Plan.
18. Comments Dated March 7, 1991 from William H. Hulbrunner on the
January 1991 Proposed Plan.
19. 9 Comment Letters Dated March 8, 1991 from Members of the Public on the
January 1991 Proposed Plan.
20. Comments Dated March 9,1991 from Madeline T. Sargent, Town of Billerica
on the January 1991 Proposed Plan.
21. 1 Comment Letter Dated March 9, 1991 from Member of the Public on the
January 1991 Proposed Plan.
22. 5 Comment Letters Dated March 10, 1991 from Members of the Public on the
January 1991 Proposed Plan.
23. 6 Comment Letters Dated March 11, 1991 from Members of the Public on the
January 1991 Proposed Plan.
24. Comments Dated March 12, 1991 from Helen R. Knighton the January 1991
Proposed Plan.
25. Comments Dated March 12, 1991 from Carl T. Moore on the January 1991
Proposed Plan.
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Page 6
5.3
Responsiveness Summaries (cont'd:-)
26. 1 Comment Letter Dated March 13, 1991 from Member of the Public on the
January 1991 Proposed Plan.
27. 3 Comment Letters Dated March 14, 1991 from Members of the Public on the
January 1991 Proposed Plan.
28. Comments Dated March 14, 1991 from David F. Delorey Jr., Town of Billerica
on the January 1991 "Final Draft Phase IC Feasibility Study," Camp Dresser & .
McKee Inc. and the January 1991 Proposed Plan. and the following
attachments:
A. Letter from Robert S. Knorr, and Jonathan Spack, Massachusetts Health
Research Institute, Inc. to Henry S. Cassell ill, Center for Disease Control
(April 17, 1990).
B. Letter from Henry S. Cassell ill, Agency for Toxic Substances and
Disease Registry to Jonathan Spack, Massachusetts Health Research
Institute, Inc. (June 22, 1990).
29. Comments Dated March 14, 1991 from Ann dePierro, Massachusetts Bay
Transportation Authority on the January 1991 Proposed Plan.
30. Comments Dated March 14, 1991 from Charlotte Cooper on the January 1991
Proposed Plan.
31. 1 Comment Letter Dated March 15, 1991 from Member of the Public on the
January 1991 Proposed Plan.
32. Comments Dated March 15, 1991 from Edward J. Markey, Member of the
United States Congress on the January 1991 Proposed Plan.
33. Comments Dated March 15, 1991 from Steven C. Sneider and Leonard C.
Sarapas, Balsam Environmental Consultants, Inc. for Graypond Realty
Corporation on the January 1991 Proposed Plan.
34. Comments Dated March 15, 1991 from Thomas A. Mackie, Wright & Moehrke
(Attorney for Graypond Realty Corporation) on the January:-l Proposed
Plan.
35. Comments Dated March 15, 1991 from Town of Billerica Conservation
Commission on the January 1991 "Final Draft Phase IC Feasibility Study,"
Camp Dresser & McKee Inc. and the January 1991 Proposed Plan.
36. Comments Dated March 15, 1991 from Suzanne K. Condon and William C.
Strohsnitter, Commonwealth of Massachusetts Department of Public Health on
the January 1991 Proposed Plan.
37. Comments Dated March 15, 1991 from Dale C. Young and Helen Waldorf,
Commonwealth of Massachusetts Department of Environmental Protection on
the January 1991 Proposed Plan.
38. Comments Dated March 16, 1991 from Rick Shaffer on the January 1991
Proposed Plan.
39. Comments Dated March 16, 1991 from Alfred E. Wilson, Gone Birding! on the
January 1991 Proposed Plan.
The following citations indicate documents received by EP A Region I after the first
formal public comment period.
40. 2 Comment Letters Dated March 18, 1991 from Members of the Public on the
January 1991 Proposed Plan.
41. 1 Comment Letter Dated March 19, 1991 from Member of the Public on the
January 1991 Proposed Plan.
42. 1 Comment Letter Dated March 21,1991 from Member of the Public on the
January 1991 Proposed Plan.
43. 2 Comment Letters Dated March 22, 1991 from Members of the Public on the
January 1991 Proposed Plan.
44. 1 Comment Letter Dated March 24, 1991 from Member of the Public on the
January 1991 Proposed Plan.
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o
Page 7
Responsiveness Summaries (cont'd.)
45. 1 Comment Letter Dated March 26, 1991 from Member of the Public on the
January 1991 Proposed Plan.
46. 1 Comment Letter Dated March 28, 1991 from Member of the Public on the
January 1991 Proposed Plan.
47. Comments from David L. Johnson on the January 1991 Proposed Plan.
48. 1 Comment Letter from Member of the Public on the January 1991 Proposed
Plan.
5.3
5.4
10.0 Enforcement
The following citations indicate documents received by EP A Region I during the
second public comment period.
49. Comments Dated June 12, 1991 from Helen R. Knight on the May 1991
Supplement to the Proposed Plan.
50. Comments Dated June 14, 1991 from Ann dePierro, Massachusetts Bay
Transportation Authority on the May 1991 Supplement to the Proposed Plan
with the attached Comments Dated March 14,1991 from Ann dePierro,
Massachusetts Bay Transportation Authority on the January 1991 Proposed
Plan.
Record of Decision (ROD)
1.
"Record of Decision," EPA Region I (June 27, 1991).
10.3 State and Local Enforcement Records
1.
Memorandum from Mr. Karaian to Mr. McLoughlin (February 21, 196'- /.
Concerning transmittal of the attached February 19, 1968 "Proposal to the Town
of Billerica from Graypond Realty Trust" and February 19, 1968 Letter from
The Dump Study Committee to the Town of Billerica Board of Health.
Letter from the Deputy Commissioner to the Town of Billerica Board of Health
(July 11,1968). Concerning the October 11, 1967 hearing regarding the
operation of the commercial dump owned by the Graypond Realty Corp.
Memorandum from Kenneth A. Tarbell to File (July 23, 1968). Concerning a
complaint that had been moo regarding the burning of waste at the commercial
dump owned by the Graypond Realty Corp.
Letter from John C. Collins, Division of Sanitary Engineering to the Town of
Billerica Board of Health (July 23,1968). Concerning the continued burning of
refuse at the site despite ordinances banning the process.
Memorandum from Richard R. Albanese to File (September 23, 1968).
Concerning an investigation of the site in response to a complaint of burning
refuse.
Letter from Russell A. Young (Attorney for Graypond Realty Trust) to David L.
Standley, Commonwealth of Massachusetts Department of Environmental
Engineering (December 2, 1975). Concerning confirmation that the volume of
solid waste at the site does not exceed one hundred seventy-five tons per day.
"Solid Waste Disposal Inspection Sheet" (August 10, 1977).
"Solid Waste Disposal Inspection Sheet" (January 11, 1978).
Letter from Kenneth A. Tarbell, Commonwealth of Massachusetts Department
of Environmental Quality Engineering to Burton Shaffer, Graypond Realty Trust
(February 23, 1978). Concerning the January 12, 1978 inspection and the
discovery that violations of the "Regulations for the Disposal of Solid Wastes by
Sanitary Landflll" still exist
2.
3.
4.
5.
6.
7.
8.
9.
-------
Page 8
10.3 State and Local Enforcement Records (cont'd.)
10. Letter from Thomas McLoughlin to Burton Shaffer, Graypond Realty Trust
(April 7, 1978). Concerning the order to cease operations at the landfill until
various violations have been corrected.
11. "Solid Waste Disposal Inspection Sheet" (July 7,1978).
12. Letter from Russell A. Young, Russell A. Young (Attorney for Graypond Realty
Trust) to Kenneth A. Tarbell, Commonwealth of Massachusetts Department of
Environmental Quality Engineering (January 5,1979). Concerning the progress
of the corrections of violations at the site.
13. "Solid Waste Disposal Inspection Sheet" (August 22, 1980).
14. "Solid Waste Disposal Inspection Sheet" (October 23,1980).
15. Letter from William J. St. Hilaire, Commonwealth of Massachusetts Department
of Environmental Quality Engineering to Graypond Realty Trust
(December 18, 1980). Concerning the results of the "Open Dump Inventory"
completed in the Spring of 1980.
16. Letter from Burton Shaffer, Middlesex Disposal Service, Inc. to William St
Hilaire, Commonwealth of Massachusetts Department of Environmental Quality
Engineering (January 22, 1981). Concerning the composition of the material
dredged up from the bottom of Nuttings Lake.
17. "Solid Waste Disposal Inspection Sheet" (May 28,1981).
18. Letter from William 1. St. Hilaire, Commonwealth of Massachusetts Department
of Environmental Quality Engineering to Burton Shaffer, Graypond Realty Trust
(J une 22, 1981). Concerning the May 28, 1981 inspection of the facility and the
overall evaluation of the operation and condition of the facility as poor.
19. Letter from William 1. St. Hilaire, Commonwealth of Massachusetts Department
of Envirorimental Quality Engineering to Burton Shaffer, Graypond Realty Trust
(July 21, 1982). Concerning a second notice to correct violations at the site and
specific remedial actions that are required.
20. Letter from William J. St. Hilaire, Commonwealth of Massachusetts Department
of Environmental Quality Engineering to Burton Shaffer, Graypond Realty Trust
(December 10, 1982). Concerning the status of the site and further measures
that must be taken to correct deficiencies.
21. "DEQE Oil and Hazardous Material SpilllRelease Incident Initial Inspection
Report," Commonwealth of Massachusetts Department of Environmental Quality
Engineering (February 1, 1984).
22. Letter from John C. Gherson, Town of Billerica Department of Health to Burton
Shaffer, Middlesex Disposal Service, Inc. (February 3, 1984). Concerning
confirmation that Middlesex Disposal Service, Inc. will take immediate action to
correct violations at the site.
23. Trip Report on a Visit to the Iron Horse Park Site, John Maddox,
Commonwealth of Massachusetts Department of Environmental Quality
Engineering (February 7, 1984). Concerning the September 21, 1983
inspection of the site.
24. Letter from William J. 51. Hilaire, Commonwealth of Massachusetts Department
of Environmental Quality Engineering to Burton Shaffer, Middlesex Disposal
Service, Inc. (May 18, 1984). Concerning notice that the Commonwealth of
Massachusetts Department of the Attorney General has extended the operation of
the landfill to June 6, 1984 in order to allow for the execution of the Consent
Judgment.
25. Memorandum from John Fitzgerald, Commonwealth of Massachusetts
Department of Environmental Quality Engineering to William Cass,
Commonwealth of Massachusetts Department of Environmental Quality
Engineering (June 13, 1985). Concerning notification that disposal operations at
the Shaffer Landfill will cease or be substantially reduced by September or
October of 1985.
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o
Page 9
10.3 State and Local Enforce~ent Records (cont'd)
26. "Certificate of the Secretary of Environmental Affairs on the Supplemental Final
Environmental Impact Report," Commonwealth of Massachusetts Executive
Office of Environmental Affairs (September 16, 1985).
27. Letter from William F.M. Hicks, Cuddy, Lynch, Manzi & Cunningham
(Attorney for Citizens Group of Billerica) to John Fitzgerald, Commonwealth of
Massachusetts Department of Environmental Quality Engineering
(Apri118, 1986). Concerning transmittal of the attached
A. Agreement for Judgment, The Department of Environmental Quality
Engineering, The Anorney General of the Commonwealth of
Massachusens and Anthony P. Bonacci, Julie A. Bonacci, Beverly
Chorbajian, Leon Chorbajian, Joseph J. Grant, Helen R, Knight, Martin
L. Mills, CarlL. Moore, Eleanor K. Moore, Diane Robinson and Michael
Tomberlin v. Irving Shaffer, Individually and as Trustee of the Graypond
Realty Trust, Philip W. Shaffer, Individually and as the Former Trustee of
the Graypond Realty Trust, Middlesex Disposal Service, Inc., Suffolk
Services, Inc., Shaffer Enterprises, Inc., Shaffer Realty Corp., Burton
Shaffer, Milton Shaffer, Frederick S. Shaffer, Ruth Shaffer, and Thomas
S. Bagley, as Trustee of the Frederick Shaffer Realty Trust,
Commonwealth of Massachusetts Superior Court, Civil Action No.
83-6986 (February 19, 1986).
B. Final Judgment, The Department of Environmental Quality Engineering, et
al. v.Irving Shaffer, et a!., Commonwealth of Massachusetts Superior
Court, Civil Action No. 83-6986 (June 12, 1984).
28. 'DEQE Oil and Hazardous Material SpilllRelease Incident Inspection Report"
Form, Commonwealth of Massachusetts Department of Environmental Quality
Engineering (July 2, 1986).
29. Letter from Richard 1. Chalpin, Commonwealth of Massachusetts Department of
Environmental Quality Engineering to Burton Shaffer, Suffolk services, Inc.
(January 20, 1987). Concerning odor generation at the site.
30. Letter from Edward A. Kunce for Richard J. Chalpin, Commonwealth of
Massachusetts Department of Environmental Quality Engineering to Burton
Shaffer, Graypond Realty Trust (June 12, 1987). Concerning the Gas
Extraction and Gas Treatment and Discharge phases of the odor abatement
project for the landfill.
31. Letter from Edward A. Kunce, Commonwealth of Massachusetts Department of
Environmental Quality Engineering to Richard R DeBenedictis, GHR
Engineering, Burton Shaffer, Middlesex Disposal Services, Inc., Anton T.
Moehrke, Wright & Moehrke (Attorney for Graypond Realty Trust), Town of
Billerica Conservation Commission (July 13, 1987). Concerning transmittal of
the attached" Amended Superseding Order of Conditions Massachusetts
Wetlands Protection Act," Commonwealth of Massachusetts Department of
Environmental Quality Engineering (July 13, 1987).
32. Letter from Edward A. Kunce, Commonwealth of Massachusetts Department of
Environmental Quality Engineering to Valerie A. Talmadge, Commonwealth of
Massachusetts Historical Commission (July 13, 1987). Concerning transmittal
of the attached "Notice of Effect to Historic Properties."
33. Letter from Richard 1. Chalpin, Commonwealth of Massachusetts Department of
Environmental Quality Engineering to Burton Shaffer, Middlesex Disposal
Services, Inc. (August 26, 1987). Concerning the presence of several leachate
seeps at both the residential and commercial areas of the landfill.
34. Letter from Anton T. Moehrke, Wright & Moehrke (Attorney for Graypond
Realty Trust) to Raymond G. Dougan, Commonwealth of Massachusetts
Department of the Attorney General (September 1, 1987). Concerning the gas
venting schedule for the landfill.
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Page 10
10.3 State and Local Enforcement Records (cont'd.)
35. Letter from Rebecca A. Backman, Wright & Moehrke (Attorney for Graypond
Realty Trust) to Jane Nolan, Town of Billerica Board of Appeals
(September 2, 1987). Concerning the request for a meeting with the Board of
Appeals and the attached "Statement of Clarification for Special Permit Granted
to Graypond Realty Corp. on August 17, 1987."
36. Letter from Rebecca A. Backman, Wright & Moehrke (Attorney for Graypond
Realty Trust) to John W. Duggan, Commonwealth of Massachusetts Department
of Environmental Quality Engineering (September 28, 1987). Concerning
notification that pipes for the gas venting system was completed
September 28, 1987 and that initial sampling for the gas venting system should
be completed by October 1, 1987.
37. Letter from Rebecca A. Backman, Wright & Moehrke (Attorney for Graypond
Realty Trust) to John W. Duggan, Commonwealth of Massachusetts Department
of Environmental Quality Engineering (March 1, 1988). Concerning the list of
people to be contacted regarding activities at the Shaffer Landfill.
38. Letter from Rebecca A. Backman, Wright & Moehrke (Attorney for Graypond
Realty Trust) to John W. Duggan, Commonwealth of Massachusetts Department
of Environmental Quality Engineering (June 15, 1988). Concerning a visit to
the site of June 8, 1988 and clarification of closure activities.
39. "Notice of Intent to Assess A Civil Administrative Penalty," Commonwealth of
Massachusetts Department of Environmental Quality Engineering
(August 5, 1988).
40. Letter from Richard J. Chalpin, Commonwealth of Massachusetts Department of
Environmental Quality Engineering to Irving Shaffer, Graypond Realty Trust
(December 3, 1988). Concerning issues raised in the October 25, 1988
"Inclusive Monthly Activities Report from July 1988 for the Pond Street
Landfill," GHR Engineering Associates, Inc.
41. Letter from Rebecca A. Backman, Wright & Moehrke (Attorney for Graypond
Realty Trust) to Richard 1. Chalpin, Commonwealth of Massachusetts
Department of Environmental Quality Engineering (December 28, 1988).
Concerning the response to the December 3, 1988 letter regarding closure
activities.
42. Letter from Richard J. Chalpin, Commonwealth of Massachusetts Department of
Environmental Quality Engineering to Paul Talbot, Town of Billerica
(January 5, 1989). Concerning the request that the Town of Billerica consider
use of the expanded treatment facility in a leachate management plan for the
landfIll.
43. Letter from Peter J. Gray, Town of Billerica Board of Health to Richard J.
Chalpin, Commonwealth of Massachusetts Department of Environmental Quality
Engineering (January 20,1989). Concerning recommendations on the proposed
sewer tie-in at Pond Street.
44. Letter from Rebecca A. Backman, Wright & Moehrke (Attorney for Graypond
Realty Trost) to John W. Duggan, Commonwealth of Massachusetts Department
of Environmental Quality Engineering (May 26, 1989). Concerning revisions to
the Post Cosure Operation and Maintenance Plan.
45. Letter from John W. Duggan and Richard J. Chalpin, Commonwealth of
Massachusetts Department of Environmental Quality Engineering to Irving
Shaffer, Graypond Realty Trust (August 15, 1989). Concerning the status of
groundwater and leachate containment, collection and treatment, odor abatement,
and operation and maintenance of the landfill cap.
46. Letter from James C. Coleman, Commonwealth of Massachusetts Executive
Office of Environmental Affairs to Thomas A. Mackie, Wright & Moehrke
(Attorney for Middlesex Disposal Services) (June 8, 1990). Concerning
notification that Middlesex Disposal Services is potentially responsible for the
construction of a fence around the Shaffer Landfill.
(',
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Page 11
10.3 State and Local Enforcement Records (cont'd)
47. Letter from James C. Coleman, Commonwealth of Massachusetts Executive
Office of Environmental Affairs to Irving Shaffer, Richard Shaffer, Milton
Shaffer, Mark Shaffer, and Burton Shaffer, Graypond Realty Corporation
(July 16, 1990). Concerning conditional acceptance of the July 3, 1990
proposal to fence the Shaffer Landfill portion of the site.
48. Letter from Dale Young, Commonwealth of Massachusetts Department of
Environmental Protection to Graypond Realty Corporation (March 19, 1991).
Concerning the fence to be built around three sides of the site.
11.0 Potentially Responsible Party (PRP)
11.9 PRP-Specific Correspondence
Town of Arlington
Letter from Donald R. Marquis, Town of Arlington Office of the Town Manager
to Town of Billerica Board of Selectmen (May 26, 1970). Concerning
notification that an agreement is pending between the Town of Arlington and
Philip Shaffer for refuse disposal.
Boston & Maine Corporation
1.
2.
Letter from Jim Diorio, Boston & Maine Corporation to Gino L. Palmacci,
Massachusetts Bay Transportation Authority (January 31, 1986). Concerning
encroachment of the landfill onto property owned by Boston & Maine
Corporation.
Graypond Realty Trust
3. Letter from Richard DeBenedictis, GHR Engineering Corporation to Anton T.
Moehrke, Wright & Moehrke (Attorney for Graypond Realty Trust)
(December 7, 1984). Concerning a response to the October 31, 1984
"Certificate of the Secretary of Environmental Affairs on Pond Street Sanitary
Landfill. "
4. Letter from Robert S. Cummings, GHR Engineering Associates, Inc. to
Raymond G. Dougan, Commonwealth of Massachusetts Department of the
Attorney General (March 8, 1989). Concerning notification that Graypond
Realty Trust has contracted with GHR Engineering Associates, Inc. to comply
with the requirements of the December 3, 1988 Letter from Commonwealth of
Massachusetts Department of Environmental Quality Engineering.
11.12 PRP-Re1ated Documents
1.
"Report and Operating Procedure," Graypond Realty Trust (October 1975).
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Page 12
13.0 Community Relations
13.1 Correspondence
1. Letter from Brian 1. Sullivan (Attorney for Carl Moore) to the Commonwealth of
Massachusetts Executive Office of Environmental Affairs (April 6, 1982).
Concerning the desire that the Shaffer Landfill be closed immediately.
2. Letter from William 1. St. Hilaire, Commonwealth of Massachusetts Department.
of Environmental Quality Engineering to Ferren Residence
(September 21, 1982). Concerning the results of water sampling and the
attached "Gas Chromatography-Mass Spectromentry Analysis of Purgeable
Organics," Commonwealth of Massachusetts Department of Environmental
Quality Engineering.
3. Letter from Helen R. Knight, Committee to Enforce Dump Controls to Richard
Chalpin, Commonwealth of Massachusetts Department of Environmental Quality
Engineering (December 11, 1982). Concerning the existing situation at the
landfill and the attached "Map Showing Points At Which Leachate Is Visibly
Entering The Wetland."
4. Letter from Ralph M. Krau, Town of Billerica Finance Committee to John
Fitzgerald, Commonwealth of Massachusetts Department of Environmental
Quality Engineering (October 10,1985). Concerning the fmancial repercussions
of closing the Shaffer Landfill.
5. Letter from David L. Johnson to John Fitzgerald, Commonwealth of
Massachusetts Department of Environmental Quality Engineering
(October 21,1985). Concerning the request for copies of all final plans
regarding the Shaffer Landfill.
6. Letter from David L. Johnson to Richard J. Chalpin, Commonwealth of
Massachusetts Department of Environmental Quality Engineering
(December 18, 1985). Concerning the demand for action to be taken by the
Commonwealth of Massachusetts Department of Environmental Quality
Engineering in cleaning up the Shaffer Landfill.
7. Letter from David L. Johnson to Barry Fogel, Commonwealth of Massachusetts
Department of Environmental Quality Engineering (February 28, 1986).
Concerning the granting of a variance to the wetlands regulations to allow for
fmal closure of the landfill.
8. Letter from Helen R. Knight, Committee to Enforce Dump Controls to John
Fitzgerald, Commonwealth of Massachusetts Department of Environmental
Quality Engineering (February 23, 1987). Concerning the odor problem at the
site.
9. Memorandum from Helen R. Knight, Committee to Enforce Dump Controls to
John W. Duggan and John Fitzgerald, Commonwealth of Massachusetts
Department of Environmental Quality Engineering (June 21,1987). Concerning
notification that no visible progress has been made to construct a leachate
collection facility or a venting system.
10. Memorandum from Helen R. Knight, Committee to Enforce Dump Controls to
John W. Duggan, Commonwealth of Massachusetts Department of
Environmental Quality Engineering (December 31,1988). Concerning the odor
problem at the site.
11. Memorandum from the Town of Billerica Board of Health to John W. Duggan
and John Fitzgerald, Commonwealth of Massachusetts Department of
Environmental Quality Engineering, GHR Engineering Associates, Inc.,
Graypond Realty Trust, Richard Bento, Superfund Action Committee
Selectman, Raymond G. Dougan, Commonwealth of Massachusetts Department
of the Attorney General (January 31, 1989). Concerning notification of a
February 8, 1989 meeting.
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13.1 Correspondence (cont'd.)
12. Letter from John Gallagher, EPA Region I to Helen R. Knight, Committee to
Enforce Dump Controls (December 1, 1989). Concerning the transmittal of the
November 1989 "Phase IC Remedial Investigation Report - Volume I," Camp
Dresser & McKee Inc.
13. Letter from John Gallagher, EPA Region I to JoAnne Giovino
(December 7, 1989). Concerning the transmittal of the November 1989 "Phase
IC Remedial Jnvestigation Report - Volume I," Camp Dresser & McKee Inc.
14. Memorandum from John Gallagher, EPA Region I to Site File
(December 28,1989). Concerning the attached notes and data received from
Helen R. Knight, Committee to Enforce Dump Controls.
15. Letter from John W. Morris, Town of Billerica Board of Health to Merrill S.
Hohman, EP A Region I (January 2, 1990). Concerning the lack of progress at
the site and the continuous odor problem.
16. "SAC Goals for Shaffer Dump," Superfund Action Committee
(January 18, 1990).
17. Cross Reference: Letter from Conal C. Foley, EP A Region I to JoAnne
Giovino, Superfund Action Committee (March 26, 1990). Concerning the
confIrmation that the Superfund Action Committee no longer wishes to me an
application for the single available Technical Assistance Grant [Filed and cited as
entry number 1 in 13.7 Technical Assistance Grants].
18. Cross Reference: Letter from Mary H. Grealish, EPA Region I to Tim
Coppinger (July 13, 1990). Concerning information on the available Technical
Assistance Grant [Filed and cited as entry number 2 in 13.7 Technical Assistance
Grants].
19. Cross Reference: Letter from Don McElroy, EPA Region I to Helen R. Knight,
Committee to Enforce Dump Controls (August 16, 1990). Concerning the
transmittal of the attached "Listing of Citizen Group Recipients of a Superfund
Technical Assistance Grant," EPA Region I (July 12, 1990) [Filed and cited as
entry number 3 in 13.7 Technical Assistance Grants].
20. Letter from Ralph M. Krau, Town of Billerica to Don McElroy, EP A Region I
(January 24, 1991). Concerning a request that the Public Meeting be scheduled
on February 5, 1991 and that the Public Comment Period begin on
February 6, 1991.
21. Letter from Don McElroy, EP A Region I to Ralph M. Krau, Town of Billerica
(January 25, 1991). Concerning approval of the extension of the Public
Comment Period to March 16, 1991.
22. Letter from John W. Morris, Town of Billerica to Don McElroy, EP A Region I
(January 25, 1991). Concerning a request that the Public Comment Period be
extended.
23. Letter from JoAnne Giovino, Superfund Action Committee to Don McElroy,
EPA Region I (January 28,1991). Concerning a request that the Public Meeting
be scheduled on February 5,1991 and that the Public Comment Period begin on
February 6, 1991.
24. Letter from Don McElroy, EP A Region I to John W. Morris, Town of Billerica
(January 29, 1991). Concerning notification of the extension of the Public
Comment Period to March 16, 1991.
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Page 13
,1"QT1'
.',- .
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Page 14
13.3 News ClippingslPrcss Releases
News Clippings
"Environmental News - EPA to Hold Public Meeting to Discuss Results of
Study on the Shaffer Landfill at the Iron Horse Park Superfund Site," EP A
Region I (August 7, 1989).
"Environmental News - EPA Releases Results of Study on the Shaffer Landfill
at the Iron Horse Park Superfund Site," EPA Region I (December 8, 1989).
Cross Reference: "The United States Environmental Protection Agency
Announces Technical Assistance Grants Program," EP A Region I [Filed and
cited as entry number 4 in 13.7 Technical Assistance Grants].
"Environmental News - EPA Issues Supplement to Proposed Cleanup Plan for
Shaffer Landfill, Iron Horse Park Superfund Site," EPA Region I
(May 15, 1991).
13.4 Public Meetings
1.
2.
"Report Details Iron Horse Park Pollutants," The Sun - Lowell, MA
(August 5, 1987).
"Hazardous Waste Dumping Causes Irreversible Damage," Merrimack Valley
Advertiser - Tewksbury, MA (August 23, 1989).
Press Releases
3.
4.
5.
6.
1. Meeting Agenda, Superfund Action Committee (November 9, 1983).
2. Letter from Sharon A. Checrallah and Helen R. Knight, Superfund Action
Committee to John Fitzgerald, Commonwealth of Massachusetts Department of
Env; ..11ental Quality Engineering (November 12, 1983). Concerning
app....~;1ation for attending the November 9, 1983 meeting and the attached
meeting notes. .
3. Meeting Agenda, Superfund Action Committee (January 9,1984).
4. Minutes of the February 22, 1984 Town of Billerica Superfund Action Coalition
meeting.
5. Minutes of the June 19, 1984 Town of Billerica Superfund Action Coalition.
6. Letter from Sharon A. Checrallah, Superfund Action Committee to John
Fitzgerald, Commonwealth of Massachusetts Department of Environmental
Quality Engineering (July 3, 1984). Concerning notification of the
August 1, 1984 meeting to discuss progress of the capping operation.
7. Minutes of the August 1, 1984 Town of Billerica Superfund Action Coalition
meeting.
8. Minutes of the October 10,1984 Town of Billerica Superfund Action Coalition
meeting.
9. Meeting Agenda, Superfund Action Committee Coalition (November 14, 1984).
10. Memorandum from Dotty Walker, Superfund Action Committee Coalition to
Superfund Action Committee Coalition Members (March 10, 1985).
Concerning notification of the March 27, 1985 meeting to discuss the Remedial
Investigation work plan and transmittal of the attached meeting agenda.
11. Minutes of the March 27, 1985 Town of Billerica Superfund Action Coalition
meeting.
12. Minutes of the August 14, 1985 Town of Billerica Superfund Action Coalition
meeting.
13. Letter from Superfund Action Committee to John Fitzgerald, Commonwealth of
Massachusetts Department of Environmental Quality Engineering
(September 23, 1985). Concerning confmnation of what issues the
Commonwealth of Massachusetts Department of Environmental Quality
Engineering agreed to assume responsibility for.
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Page 15
13.4 Public Meetings (cont'd.)
14. Minutes of the January 21, 1986 Town of Billerica Superfund Action Coalition
meeting.
15. Minutes of the May 27, 1986 Town of Billerica Superfund Action Coalition
meeting.
16. Meeting Agenda, Town of Billerica Superfund Action Committee and EPA
Region I (November 18, 1986) with the attached "Suggested Topics for the
Proposed Meeting on the Shaffer Landfill."
17. Meeting Agenda, Town of Billerica Superfund Action Committee
(March 24, 1987) with attached annotated copy.
18. Meeting Agenda, Town of Billerica Superfund Action Committee
(November 17, 1987) with the attached "Progress Report - B & M Lagoons."
19. Meeting Agenda, Town of Billerica Superfund Action Committee
(March 30, 1988) with the attached March 3, 1988 Letter from Dorothy Walker,
Superfund Action Committee to John Fitzgerald and John W. Duggan,
Massachusetts Department of Environmental Quality Engineering and the
"Proposed Outline for Presentation Regarding Leachate Containment"
20. Meeting Agenda (August 9, 1988). Concerning the agenda for the
August 9, 1988 health study meeting.
21. Transcript, Proposed Plan Public Hearing (February 5, 1991).
22. Transcript, Proposed Plan Public Hearing (February 19, 1991).
23. "Iron Horse Park Site History," "Recommendations," "Groundwater
Contamination at Iron Horse Park," "Organics Results Summary."
\:\
The record cited as entry number 24 may be reviewed, by appointment only, at EPA
Region I Boston," Massachusetts. "
24. Overhead Transpa. ~:bes, EPA Region I.
,-i)o
13.5 Fact Sheets
"Superfund Program Fact Sheet," EPA Region I (August 1989). Concerning
EPA investigation results for the Shaffer Landfill.
13.7 Technical Assistance Grants
1.
1.
Letter from Conal C. Foley, EP A Region I to Jo Anne Giovino, Superfund
Action Committee (March 26, 1990). Concerning the confmnation that the
Superfund Action Committee no longer wishes to fIle an application for the
single available Technical Assistance Grant.
Letter from Mary H. Grealish, EPA Region I to Tim Coppinger (July 13, 1990).
Concerning information on the available Technical Assistance Grant
Letter from Don McElroy, EP A Region I to Helen R. Knight, Committee to
Enforce Dump Controls (August 16, 1990). Concerning the transmittal of the
attached "Listing of Citizen Group Recipients of a Superfund Technical
Assistance Grant," EPA Region I (July 12, 1990).
"The United States Environmental Protection Agency Announces Technical
Assistance Grants Program," EP A Region Y.
2.
3.
4.
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Page 16
14.0 Congressional Relations
14.1 Correspondence
1. Letter from Helen R. Knight, Committee to Enforce Dump Controls to Michael
J. Rea, Member of the Commonwealth of Massachusetts House of
Representatives (November 9, 1982). Concerning an update of site activities.
2. Letter from Dorothy P. Walker, Superfund Action Committee to Patricia
McGovern, Member of the Commonwealth of Massachusetts Senate
(June 2, 1989). Concerning the attached summary sheet and the request that
immediate action be taken to cleanup the site leachate problem.
3. Letter from John Gallagher, EP A Region I to Edward Markey, Member of the
U.S. House of Representatives (December 6, 1989). Concerning transmittal of
the Remedial Investigation report
4. Letter from John Gallagher, EP A Region I to Patricia McGovern, Member of the
Commonwealth of Massachusetts Senate (December 6, 1989). Concerning
transmittal of the Remedial Investigation report
5. Letter from Patricia McGovern, Member of the Commonwealth of
Massachusetts Senate to Julie Belaga, EPA Region I (January 23,1990).
Concerning the need for federal assistance in cleaning up the site.
6. Letter from Julie Belaga, EP A Region I to Patricia McGovern, Member of the
Commonwealth of Massachusetts Senate (February 21,1990). Concerning an
update of site activities.
7. Letter from Edward M. Kennedy and John F. Kerry, Members of the United
States Senate to Julie Belaga, EPA Region I (February 1, 1991). Concerning
the request that the February 5, 1991 hearing be changed to an informal question
and answer period.
8. Letter from Edward J. Markey, Member of the United States House of
Representatives to Julie Belaga. . A Region I (February 27, 1991).
Concerning a request that a replw~entative from the Town of Billerica be allowed
to monitor the negotiations with the parties potentially responsible for the site
cleanup.
9. Cross-Reference: Comments Dated March 15, 1991 from Edward J. Markey,
Member of the United States Congress on the January 1991 Proposed Plan
[Filed and cited as entry number 32 in 5.3 Responsiveness Summaries].
10. Letter from Julie Belaga, EPA Region I to Edward J. Markey, Member of the
United States House of Representatives (March 20, 1991). Concerning the
response to the February 27, 1991 letter requesting that a representative from the
Town of Billerica be allowed to monitor the negotiations with the parties
potentially responsible for the site cleanup.
11. Letter from Julie Belaga, EPA Region I to Edward J. Markey, Member of the
United States House of Representatives (March 29,1991). Concerning
notification that EPA Region I received his comments on the January 1991
Proposed Plan.
17.0 Site Management Records
17.1 Correspondence
Letter from S.H. Morawski, Tennessee Gas Pipeline to Bruce Marshall, EP A
Region I (September 30, 1987). Concerning transmittal of the attached sampling
results taken from along the proposed trench line.
17.4 Site Photographs/Maps
1.
1.
Memorandum from Thomas R. Osberg, EPA Region I to Bruce Marshall, EPA
Region I (Apri13, 1987). Concerning transmittal of the attached "Site Analysis
and Wetlands Assessment - Volume 1," EPA Region I (March 1987).
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Page 17
17.5 Site Descriptions/Chronologies
Due to copyright restrictions, the record cited as entry number 1 may be reviewed, by
appointment only, at EPA Region J Boston, MassachusettS.
1.
2.
"The Supply Mill on Content Brook in Massachusetts," Journal of Field
Archaeology (Volume 3 Number 1 1976).
"Town of Billerica Information."
17.8 State and Local Technical Records
Correspondence
1. Letter Report from D.L. Higgins Jr. (March 8, 1965). Concerning the
examination of the Pond Street Landfill.
2. Letter from John C. Collins, Town of Billerica Department of Health to P.
Curtis (April 3, 1968). Concerning a proposed dump site in North Billerica. and
the attached "Billerica Citizens Petition State for Dump Controls."
3. Letter from Emile J. Hamwey, Fay, Spofford & Thorndike, Inc. (Attorney for
the Town of Billerica) to Richard Power, Commonwealth of Massachusetts
Department of Public Health (February 15, 1973). Concerning additions and
improvements to the Town of Billerica Sewage Treatment Plant. .
4. Letter from Francis C. Emmons Jr., Emmons, Fleming & Bienveu, Inc.
(Attorney for Graypond Realty Trust) to Kenneth A. Tarbell, Commonwealth of
Massachusetts Department of Public Health (February 27, 1975). Concerning
the division of the site into household waste and commercial waste sections and
the proposal to accomplish compliance to the landfill regulations.
5. Letter from Kenneth A. Tarbell, Commonwe8~ :.)f Massachusetts Department
of Public Health to Francis C. Emmons Jr., LhtlnOnS, Fleming & Bienveu, Inc.
(Attorney for Graypond Realty Trust) (March 14, 1975). Concerning receipt of
the February 27, 1975 letter and the notion that Graypond Realty Trust is
responsible for covering refuse at both the commercial and residential sections of
the landfill.
6. Letter from Donald C. Bassett, Town of Billerica Health Department to Paul
Anderson, Commonwealth of Massachusetts Department of Environmental
Quality Engineering (September 16, 1975). Concerning notification that Roy
Brothers, Inc. has been given permission to dispose of waste at the landfill on
September 16, 1975 and September 17, 1975.
7. Letter from William 1. St. Hilaire, Commonwealth of Massachusetts Department
of Environmental Quality Engineering to Kenneth A. Tarbell, Middlesex
Disposal Services, Inc. (February 27,1981). Concerning review of the
September 8,1980 "Sieve Analysis," Arnold Greene Testing Laboratories, Inc.
and notification that the dredge material from Nutting's Lake is too high in
organic material and the particle size is too large.
8. Letter from Kenneth A. Tarbell, Middlesex Disposal Services, Inc. to William 1.
St. Hilaire, Commonwealth of Massachusetts Department of Environmental
Quality Engineering (February 10, 1984). Concerning the origins of the odor
problems near the site.
9. Memorandum from Margo Thornton, Commonwealth of Massachusetts
Department of Environmental Quality Engineering to File (March 23, 1984).
Concerning visual observations and attached notes regarding the culverts within
the watershed area of Gray Street.
10. Memorandum from Bill Sirull, Commonwealth of Massachusetts Department of
Environmental Quality Engineering to File (June 22,1984). Concerning a tour
of the site with Helen R. Knight, Superfund Action Committee and a water
sample taken from the site.
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Page 18
17.8 State and Local Technical Records (~nt'd.)
11. Letter from Richard R. DeBenedictis, GHR Engineering Corporation to William
J. St Hilaire, Commonwealth of Massachusetts Department of Environmental
Quality Engineering (July 16, 1984). Concerning transmittal of the plans for
closure of the site.
12. Letter from Robert S. Cummings, GHR Engineering Corporation to William J.
St Hilaire, Commonwealth of Massachusetts Department of Environmental
Quality Engineering (August 31, 1984). Concerning a request for an extension
of time in order to complete the "Final Environmental Impact Report"
13. Letter from Robert A. Lacourse, GHR Engineering Incorporated to John
Fitzgerald, Commonwealth of Massachusetts Department of Environmental
Quality Engineering (April 1 , 1985). Concerning average tonnage of waste
disposed of at the site between February 13, 1985 and March 28, 1985.
14. Letter from Robert A. Lacourse, GHR Engineering Associates, Inc. to John
Fitzgerald, Commonwealth of Massachusetts Department of Environmental
Quality Engineering (May 23, 1985). Concerning average tonnage of waste
disposed of at the site between March 29,1985 and May 18, 1985.
15. Letter from Richard J. Chalpin, Commonwealth of Massachusetts Department of
Environmental Quality Engineering to Paul F. Talbot, Town of Billerica
(November 15, 1985) with the attached October 30, 1985 Letter from Kenneth
A. Tarbell, Middlesex Disposal Service, Inc. to Richard J. Chalpin,
Commonwealth of Massachusetts Department of Environmental Quality
Engineering. Concerning notification that landfill expansion is not approved.
16. Letter from Robert S. Cummings, GHR Engineering Associates, Inc. to John
FItzgerald, Commonwealth of Massachusetts Department of Environmental
Quality Engineering (December 30, 1985).
17. Letter from Richard J. Chalpin, Commonwealth of Massachusetts Department of
Environmental Quality Engineering to Burton Shaffer, Midc". .~x Disposal
Services, Inc. (January 21, 1986). Concerning operation~. Aosure, and
remedial activities at the site.
18. Letter from S.H. Morawski, Tennessee Gas Pipeline to John FItzgerald,
Commonwealth of Massachusetts Department of Environmental Quality
Engineering (March 25, 1986). Concerning the relocation of the 16" Concord
Lateral through or near the site.
19. Memorandum from Burton Shaffer, Graypond Realty Trust to John W. Duggan,
Commonwealth of Massachusetts Department of Environmental Quality
Engineering (June 11, 1986). Concerning transmittal of the attached "Proposed
Schedule for the Development of the Landfill Gas-to-Electricity Project as of
May 30, 1986."
20. Letter from Joseph P. Salvetti, GHR Engineering Associates, Inc. to John W.
Duggan, Commonwealth of Massachusetts Department of Environmental Quality
Engineering (January 23,1987). Concerning the proposed pumping tests to be
performed at the site.
21. Letter from Richard J. Chalpin, Commonwealth of Massachusetts Department of
Environmental Quality Engineering to Robert Cummings, GHR Engineering
Associates, Inc. (January 26, 1987). Concerning the schedule for pump tests to
be performed at the site.
22. Letter from Christine R. LeBlanc, GHR Engineering Associates, Inc. to Pat
Lewis, Commonwealth of Massachusetts Department of EnvironmentaI Quality
Engineering (January 29,1987). Concerning transmittal of the attached revised
January 9, 1987 letter and notification that the 3:1 slope on the west side of the
commercial1andfill does encroach on the Boarded Vegetated Wetlands by
13,300 square feet
23. Letter from Christine R. LeBlanc, GHR Engineering Associates, Inc. to George
Chretien, Greater Lawrence Sanitary District (January 30, 1987). Concerning
transmittal of the attached "Request to Discharge Commercial and Industrial
Holding Tank at the Greater Lawrence Sanitary District"
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17.8 State and Local Technic~ Records (cont'd.)
24. Letter from Christine R. LeBlanc, GHR Engineering Associates, Inc. to John
W. Duggan, Commonwealth of Massachusetts Department of Environmental
Quality Engineering (February 2, 1987). Concerning information on the
hydraulics of the pump test, water quality and leachate/groundwater disposal.
25. Letter from Christine R. LeBlanc, GHR Engineering Associates, Inc. to John
W. Duggan, Commonwealth of Massachusetts Department of Environmental
Quality Engineering (February 10, 1987). Concerning information on fInal
slope stabilization at the site.
26. Letter from C.F. Mistretta, Commonwealth of Massachusetts Department of
Public Works to Bruce Marshall, EPA Region I (July 10, 1987). Concerning
notes of the July 8, 1987 meeting and the proposal of how to dispose of the
material stored at the site.
27. Letter from Robert S. Cummings, GHR Engineering Associates, Inc. to John
W. Duggan, Commonwealth of Massachusetts Department of Environmental
Quality Engineering (October 14, 1987). Concerning certifIcation of closure of
the commercial and residential areas of the landfill and the following attachments:
A. Letter from Richard R. DeBenedictis, GHR Engineering Associates, Inc.
to William St Hilake, Commonwealth of Massachusetts Department of
Environmental Quality Engineering (November 16, 1984).
B. Letter from Richard R. DeBenedictis, GHR Engineering Associates, Inc.
to William St Hilaire, Commonwealth of Massachusetts Department of
Environmental Quality Engineering (December 6, 1984).
C. Letter from Robert S. Cummings, GHR Engineering Associates, Inc. to
William St Hilaire, Commonwealth of Massachusetts Department of
Environmental Quality Engineering (December 30, 1985).
D. Letter from Robert S. Cummings, GHR Engineering Associates, Inc. to
Richard 1. Chalpin, Commonwealth of Massachusetts Department (
Environmental Quality Engineering (December 8, 1986).
28. Letter from Richard 1.'Chalpin, Commonwealth of Massachusetts Department of
Environmental Quality Engineering to Burton Shaffer, Graypond Realty Trust
(November 25, 1987). Concerning the review of the plans, specifIcations, and
the Standard Operating and Maintenance Procedures relative to the proposed
installation of landfIll gas control equipment
29. Letter from Robert S. Cummings, GHR Engineering Associates, Inc. to
Raymond G. Dougan, Commonwealth of Massachusetts Department of the
Attorney General (January 22, 1988). Concerning transmittal of the attached
"Hydrogeologic Assessment Chronology."
30. Letter from Ralph P. Penney, GHR Engineering Associates, Inc. to John W.
Duggan, Commonwealth of Massachusetts Department of Environmental Quality
Engineering (April 7, 1988). Concerning the transmittal of site closure
documents.
31. Letter from Thomas A. Mackie, Wright & Moehrke (Attorney for Middlesex
Disposal Services) to John W. Duggan, Commonwealth of Massachusetts
Department of Environmental Quality Engineering (April 8, 1988). Concerning
confmnation that GHR Engineering Associates, Inc. will be submitting monthly
reports regarding closure activities at the landfill.
32. Letter from Mark Jablonski, GHR Engineering Associates, Inc. to John
Duggan, Commonwealth of Massachusetts Department of Environmental Quality
Engineering (May 18, 1989). Concerning the proposed pumping activities at the
site.
33. Memorandum from John W. Duggan, Commonwealth of Massachusetts
Department of Environmental Quality Engineering to John Fitzgerald,
Commonwealth of Massachusetts Department of Environmental Quality
Engineering (May 23, 1988). Concerning observations from the May 23, 1988
inspection of the site.
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17.8 State and Local Technical Records (cont'd.)
34. Memorandum from John W. Duggan, Commonwealth of Massachusetts
Department of Environmental Quality Engineering to John Fitzgerald,
Commonwealth of Massachusetts Department of Environmental Quality
Engineering (June 8, 1988). Concerning observations from the June 8, 1988
inspection of the site.
35. Letter from Richard 1. Chalpin, Commonwealth of Massachusetts Department of .
Environmental Quality Engineering to Paul Talbot, Town of Billerica
(January 5, 1989). Concerning notification that Graypond Realty Trust has been
required to contain, collect, and provide for the treatment of Leachate
contaminated groundwater at the site.
36. Letter from Paul Talbot, Town of Billerica to Richard J. Chalpin,
Commonwealth of Massachusetts Department of Environmental Quality
Engineering (January 26, 1989). Concerning notification that the Town of
Billerica will not allow the contaminated groundwater to be treated at the Town's
waste water treatment plant
37. Letter from Robert S. Cummings, GHR Engineering Associates, Inc. to John
W. Duggan, Commonwealth of Massachusetts Department of Environmental
Quality Engineering (June 14, 1989). Concerning the scope of work regarding
the pumping test to be performed at the site and the attached "Pump Test Fact
Sheet"
Report
38. "Report and Plans for Improvements to Sanitary Landfill," Middlesex Disposal
Service, Inc. (August 1981).
Report
39. "Environmental Impact Report," Middlesex Disposal Service, Inc.
(February 17, 1982).
Report
40. "Preliminary Hydrogeologic Analysis," Goldberg-Zoino & Associates, Inc. for
Middlesex Disposal Service, Inc. (Apri11984).
Report
41. "Final Environmental Impact Report," GHR Engineering Associates, Inc.
(September 1984).
Comments .
42. "Certificate of the Secretary of Environmental Affairs on the Final Environmental
Impact Report," Commonwealth of Massachusetts Executive Office of
Environmental Affairs (September 24, 1984). Concerning the statement that the
September 1984 "Final Environmental Impact Report," GHR Engineering
Associates, Inc. does not adequately and properly comply with Massachusetts
General Laws.
43. Comments Dated September 28, 1984 from Richard J. Chalpin, Commonwealth
of Massachusetts Department of Environmental Quality Engineering on the
September 1984 "Final Environmental Impact Report," GHR Engineering
Associates, Inc.
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17.8 State and Local Technical Records (cont'd.)
44. Comments Dated October 24, 1984 from William F.M. Hicks, Cuddy, Lynch,
Sikora &Cunningham (Attorney for the tWelve named citizen residents who are
plaintiff/intervenors in The Department of Environmental Quality Engineering, et
aJ. v. Irving Shaffer, et al.) on the September 1984 "Final Environmental Impact
Report," GHR Engineering Associates, Inc.
Report
45. "Supplemental Final Environmental Impact Report," GHR Engineering
Associates, Inc. (July 1985).
Comments
46. Comments Dated September 9, 1985 from Joseph P. Hannon, Northern
Middlesex Area Commission on the July 1985 "Supplemental Final
Environmental Impact Report," GHR Engineering Associates, Inc.
47. Comments Dated September 11, 1985 from Helen R. Knight, Superfund Action
Committee on the July 1985 "Supplemental Final Environmental Impact
Report," GHR Engineering Associates, Inc.
48. "Certificate of the Secretary of Environmental Affairs on the Final Environmental
Impact Report," Commonwealth of Massachusetts Executive Office of
Environmental Affairs (August 9, 1985). Concerning the statement that the
July 1985 "Supplemental Final Environmental Impact Report," GHR
Engineering Associates, Inc. adequately and properly complies with
Massachusetts General Laws.
49. Comments Dated September 1985 from David L. Johnson on the July 1985
"Supplemental Final Environmental Impact Report," GHR Engineering
Associates, Inc.
50. Comments Dated September 26, 1985 from Robert T. Legere, New England
Testing Laboratory, Inc. on the July 1985 "Supplemental Final Environmental
Impact Report," GHR Engineering Associates, Inc.
51. Comments Dated October 21,1985 from David L. Johnson on the July 1985
"Supplemental Final Environmental Impact Report," GHR Engineering
Associates, Inc.
Report
52. "Evaluation in Support of Variance Application Pursuant to 310 CMR 10.58
with Regard to Wetlands Requirements and Request to Vary Department of
Environmental Quality Engineering Policy Regarding Final Landfill Slopes,"
GHR Engineering Associates, Inc. for Graypond Realty Trust (April 1986).
Report
53. "Supplemental Hydrogeologic and Water Quality Assessment," GHR
Engineering Associates, Inc. for Graypond Realty Trust (April 1988).
Comments
54. Comments Dated January 5, 1989 from Richard J. Chalpin, Commonwealth of
Massachusetts Department of Environmental Quality Engineering on the April
1988 "Supplemental Hydrogeologic and Water Quality Assessment," GHR
Engineering Associates, Inc. and the July 26,1988 "Additional Information for
the Hydrogeologic and Water Quality Assessment," GHR Engineering
Associates, Inc.
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17.8 State and Local Technical Records (cont'd.)
Report
55. "Post-Closure Operation and Maintenance Plan," GHR Engineering Associates,
Inc. (Apri11989).
Comments
56. Letter from John W. Duggan and Richard J. Chalpin, Commonwealth of
Massachusetts Department of Environmental Quality Engineering to Irving
Shaffer, Graypond Realty Trust (May 12, 1989). Concerning transmittal of the
attached Comments Dated May 12, 1989 from John W. Duggan and Richard J.
Chalpin, Commonwealth of Massachusetts Department of Environmental Quality
Engineering on the April 1989 "Post-Closure Operation and Maintenance Plan,"
GHR Engineering Associates, Inc.
Sampling and Analysis Data (Alliance Technologies Cmporation)
57. Letter from Stephen V. Capone, Alliance Technologies Corporation to Edward
Braczyk, Commonwealth of Massachusetts Department of Environmental
Quality Engineering (November 7, 1988). Concerning transmittal of the
attached "Summary Report - Gas F1are Testing - Passive Mode."
Sampling and Analysis Data (GHR Engineering Associates, Inc.)
58. Letter from Richard R. DeBenedictis, GHR Engineering Associates, Inc. to
William S1. Hilaire, Commonwealth of Massachusetts Department of
Environmental Quality Engineering (April 11, 1984). Concerning inspection of
the site to ascertain existing conditions and the attached "Phase Closure of
Residential Area - Table #1."
59. "Final Report," GHR Analytical Incorporated (March 19, 1986).
60. "Monitoring Well Installation Report," GHR Analytical Incorporated
(April 17, 1986).
61. "Interpretive Report of Results of Billerica Landfill Conducted
November 5 & 6, 1986," GHR Engineering Associates, Inc.
62. "Final Report," GHR Analytical Incorporated. (January 14, 1987).
63. Sampling Maps and BoringlMonitoring Well Logs (January 29, 1987).
64. Letter from Christine R. LeBlanc, GHR Engineering Associates, Inc. to John
W. Duggan, Commonwealth of Massachusetts Department of Environmental
Quality Engineering (September 2, 1987). Concerning transmittal of the
attached August 14, 1987 "Final Report," GHR Analytical Incorporated
65. Letter from Leanne E.S. Cobb, GHR Analytical Incorporated to Graypond
Realty Trust (December 21,1987). Concerning transmittal of the attached
December 8, 1987 "Final Report," GHR Analytical Incorporated.
66. "Final Report," GHR Engineering Associates, Inc. (February 15, 1988).
67. Memorandum from Ralph P. Penney, GHR Engineering Associates, Inc. to
Milton Shaffer, Graypond Realty Trust (June 8, 1988). Concerning transmittal
of the May 25, 1988 "Final Report" of laboratory results taken from the landfill.
68. Letter from Ralph P. Penney, GHR Engineering Associates, Inc. to Dodie
Brownlee and John W. Duggan, Commonwealth of Massachusetts Department
of Environmental Quality Engineering (July 26, 1988). Concerning transmittal
of the attached contour maps associated with the "Hydrogeologic and Water
Quality Assessment"
69. "Final Report," GHR Engineering Associates, Inc. (January 31, 1989).
70. "Groundwater and Surface Water Quality Data for April 1989," GHR
Engineering Associates, Inc. (Apri11989).
71. "Draft Preliminary Report," GHR Engineering Associates, Inc. (June 6, 1989).
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Page 23
"
'I
17.8 State and Local Technical Records (cont'd)
72. Letter from Robert S. Cummings, GHR Engineering Associates, Inc. to John
W. Duggan, Commonwealth of Massachusetts Department of Environmental
Quality Engineering (June 20, 1989). Concerning the historical analysis of
ground and surface water quality data using data from sampling completed in
April 1989.
Sampling and Analysis Data (Goldberg-Zoino & Associates, Inc.)
73. Memorandum from Sara R. Harris, Goldberg-Zoino & Associates, Inc. to
William St Hilaire, Commonwealth of Massachusetts Department of
Environmental Quality Engineering (June 21,1984). Concerning transmittal of
the attached results of Goldberg-Zoino & Associates, Inc.'s soils laboratory
permeability testing of cover material from the landfill.
74. Boring Logs, Goldberg-Zoino & Associates, Inc. (June 27, 1984).
75. Gradation Tests, Goldberg-Zoino & Associates, Inc. (July 1984).
76. Memorandum from Dan Schulze, Goldberg-Zoino & Associates, Inc. to Bob
Cummings, GHR Engineering Associates, Inc. (June 5, 1986). Concerning
transmittal of the attached "Laboratory Testing Data Summary ,"
"Compaction-Gradation Tests," and "Laboratory Test Procedures."
77. "Laboratory Testing Data Summary," Goldberg-Zoino & Associates, Inc.
(August 1986).
Sampling and Analysis Data (Middlesex Disposal)
78. "Draft Ambient Air Monitoring in Billerica, Massachusetts," MDS Advanced
Analytics, Inc. (June 1986).
79. "Final Report - Ambient Air Monitoring in Billerica, Massachusetts," MDS
Advanced Analytics, Inc. (June 1986).
Work Plans and Progress Reports (Alliance Technologies Corporation)
80. Letter from Howard 1. Schiff, Alliance Technologies Corporation to Edward
Braczyk, Commonwealth of Massachusetts Department of Environmental
Quality Engineering (April 8, 1988). Concerning the attached "Graypond Realty
Trust Billerica Landfill Flare Test Program Tentative Schedule."
81. Letter from Stephen V. Capone, Alliance Technologies Corporation to Irving
Shaffer, Graypond Realty Corporation (May 17, 1989). Concerning the
monthly report for March 1989.
82. Letter from Stephen V. Capone, Alliance Technologies Corporation to Irving
Shaffer, Graypond Realty Corporation (May 17, 1989). Concerning the
monthly report for April 1989.
83. Letter from Stephen V. Capone, Alliance Technologies Corporation to Irving
Shaffer, Graypond Realty Corporation (June 12, 1989). Concerning the
monthly report for May 1989.
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17.8 State and Local Technical Records (cont'd.)
Work Plans and Progress Reports (Commonwealth of Massachusetts Department of
Environmental Quality Engineering)
"
'(
84. Memorandum from Thomas F. McLoughlin, Commonwealth of Massachusetts
Department of Public Health to File (February 27, 1968). Concerning an
inspection of the proposed landfill site off Billerica A venue. The following are
attached:
A. Memorandum from Merrill M. Plunkett, Town of Billerica to File
(February 26, 1968). Concerning an inspection of the proposed landfill
site adjacent to the existing town dump.
B. Letter from Richard R. Albanese, Town of Billerica Health Department to
Thomas F. McLoughlin, Commonwealth of Massachusetts Department of
Public Health (February 21, 1968). Concerning a request for inspection of
the dump site for conversion to a sanitary landfill.
C. Letter from Richard R. Albanese, Town of Billerica Health Department to
Thomas F. McLoughlin, Commonwealth of Massachusetts Department of
Public Health (February 21, 1968). Concerning a request for inspection of
the Arakelian property and the Corenco property.
D. Letter from Robert E. Seeley, Dump Study Committee to Marion D.
Gould, Town of Billerica (February 15, 1968). Concerning preparation
for the March 9,1968 Town Meeting.
85. "Report of the Billerica Dump Study Committee - 1967-1968."
86. Letter from William J. St Hilaire, Commonwealth of Massachusetts Department
of Environmental Quality Engineering to Robert Hamilton, Shawsheen River
Watershed Association (August 13, 1981). Concerning transmittal of the
attached "Reports and Plans for Improvements to Sanitary Landflll," Middlesex
Disposal Service, Inc. (August 1981).
87. "Certificate of the Secretary of Environmental Affairs on the Draft Environmental
Impact Report," Commonwealth of Massachusetts Executive Office of
Environmental Affairs (March 8, 1982). Concerning the statement that the March
1982 "Draft Environmental Impact Report," Middlesex Disposal Service, Inc.
does not adequately and properly comply with Massachusetts General Laws.
88. "Status Report - SolidIHazardous Waste Site Assessment" (February 9,1983).
The following are attached:
A. Memorandum from Joe Dorant, Commonwealth of Massachusetts
Department of Environmental Quality Engineering to Sabin M. Lord,
Commonwealth of Massachusetts Department of Environmental Quality
Engineering (October 29, 1980). Concerning the investigation of a report
of salt leaching into a nearby brook.
B. "Monthly Operation Report-Licensed Hazardous Waste Collector."
C. Letter from E.V. Fitzpatrick, Division of Surveillance & Analysis to H.B.
Berkshire, Boston and Maine Corporation (November 29, 1974).
Concerning a request for delivery of the Spill Prevention Control and
Countermeasure (SPeC) Plans before an extension of time to implement
those plans can be granted.
D. Letter from E.V. Fitzpatrick, Division of Surveillance & Analysis to H.B.
Berkshire, Boston and Maine Corporation (July 12,1974). Concerning
notification that some facilities may be exempt from submitting Spill
Prevention Control and Countermeasure (SPCC) Plans.
E. Letter from E.V. Fitzpatrick, Division of Surveillance & Analysis Boston
and Maine Corporation (January 13,1975). Concerning the request for
extensions of time to implement Spill Prevention Control and
Countermeasure (SPCC) Plans.
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17.8 State and Local Technical Records (cont'd)
89. Letter from Richard 1. Chalpin, Commonwealth of Massachusetts Department of
Environmental Quality Engineering to Burton Shaffer, Middlesex Disposal
Services, Inc. (October 9, 1987). Concerning approval of GHR Engineering
Associates, Inc.'s plan to address leachate seeps and erosion channels and the
attached August 26,1987 Letter from Richard J. Chalpin, Commonwealth of
Massachusetts Department of Environmental Quality Engineering to Burton
Shaffer, Middlesex Disposal Services, Inc.
90. Letter from Richard J. Chalpin, Commonwealth of Massachusetts Department of
Environmental Quality Engineering to Irving Shaffer, Graypond Realty Trust
(June 28, 1988). Concerning the request for additional maps associated with the
"Supplemental Hydrogeologic and Water Assessment," GHR Engineering
Associates, Inc.
91. Letter from Edward A. Kunce, Department of Environmental Quality
Engineering to Valerie A. Talmadge, Commonwealth of Massachusetts
Historical Commission (July 10, 1987). Concerning transmittal of the attached
'.'Notice of Effect to Historic Properties."
92. Letter from Richard J. Chalpin, Commonwealth of Massachusetts Department of
Environmental Quality Engineering to Irving Shaffer, Graypond Realty Trust
(December 3, 1988). Concerning issues raised in the October 25, 1988
"Inclusive Monthly Activities Report from July 1988," GHR Engineering
Associates, Inc.
93. Letter from Richard 1. Chalpin, Commonwealth of Massachusetts Department of
Environmental Quality Engineering to Irving Shaffer, Graypond Realty Trust
(January 5, 1989). Concerning review of the April 1988 "Supplemental
Hydrogeologic and Water Quality Assessment," GHR Engineering Associates,
Inc. and the July 26, 1988 Additional infonnation for the Hydrogeologic and
Water Quality Assessment," GHR Engineering Associates, Inc.
94. Letter from John W. Duggan and Richard J. Chalpin, Commonwealth of
Massachusetts Department of Environmental Quality Engineering to Mark
Jablonski, GHR Engineering Associates, Inc. (May 12, 1989). Concerning
review of the April 12, 1989 "Post-Closure Operation and Maintenance Plan,"
GHR Engineering Associates, Inc.
('
, ,\
Work Plans and Progress Reports (GHR Engineering Corporation)
95. Letter from Richard R. DeBenedictis, GHR Engineering Corporation to William
J. St Hilaire, Commonwealth of Massachusetts Department of Environmental
Quality Engineering (June 15, 1984). Concerning certification of work done by
CJ. Mabardy, Inc. in the commercial area of the landfill.
96. Letter from Richard R. DeBenedictis, GHR Engineering Corporation to William
1. St. Hilaire, Commonwealth of Massachusetts Department of Environmental
Quality Engineering (June 21, 1984). Concerning the availability offmal cover
material on-site at the landfill.
97. Letter from Richard R. DeBenedictis, GHR Engineering Corporation to William
J. St Hilaire, Commonwealth of Massachusetts Department of Environmental
Quality Engineering (July 2,1984). Concerning Status Report No. 1.
98. Letter from Richard R. DeBenedictis, GHR Engineering Corporation to William
J. St. Hilaire, Commonwealth of Massachusetts Department of Environmental
Quality Engineering (July 2, 1984). Concerning the July 2, 1984 site
inspection.
99. Letter from Richard R. DeBenedictis, GHR Engineering Corporation to William
J. St Hilaire, Commonwealth of Massachusetts Department of Environmental
Quality Engineering (July 16, 1984). Concerning Status Report No.2.
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17.8 State and Local Technical Records (cont'd.)
100. Letter from Richard R. DeBenedictis, GHR Engineering Corporation to William
J. St. Hilaire, Commonwealth of Massachusetts Department of Environmental
Quality Engineering (July 17,1984). Concerning the July 13, 1984 site
inspection.
101. Letter from Richard R. DeBenedictis, GHR Engineering Corporation to William
J. Sl Hilaire, Commonwealth of Massachusetts Department of Environmental
Quality Engineering (July 31, 1984). Concerning Status Report No.3.
102. Letter from Richard R. DeBenedictis, GHR Engineering Corporation to William
J. St. Hilaire, Commonwealth of Massachusetts Department of Environmental
Quality Engineering (August 6, 1984). Concerning the July 31, 1984 site
inspection.
103. Letter from Richard R. DeBenedictis, GHR Engineering Corporation to William
J. St. Hilaire, Commonwealth of Massachusetts Department of Environmental
Quality Engineering (August 20, 1984). Concerning the delay in installing
public water service to Gray Street residents.
104. Letter from Richard R. DeBenedictis, GHR Engineering Corporation to William
J. St. Hilaire, Commonwealth of Massachusetts Department of Environmental
Quality Engineering (August 20, 1984). Concerning Status Report No.4 and
the attached Letter from Richard R. DeBenedictis, GHR Engineering
Corporation to William J. St. Hilaire, Commonwealth of Massachusetts
Department of Environmental Quality Engineering (August 20, 1984) regarding
the August 15, 1984 site inspection.
105. Letter from Richard R. DeBenedictis, GHR Engineering Corporation to William
J. St. Hilaire, Commonwealth of Massachusetts Department of Environmental
Quality Engineering (August 21,1984). Concerning reasons for an extension
for tl. ,1:placement of intermediate cover in the residential area.
106. Let...,. from Robert S. Cummings, GHR Engineering Corporation to William 1.
Sl Hilaire, Commonwealth of Massachusetts Department of Environmental
Quality Engineering (August 31, 1984). Concerning delay of submission of the
Final Environmental Impact Report
107. Letter from Robert S. Cummings, GHR Engineering Corporation to William J.
Sl Hilaire, Commonwealth of Massachusetts Department of Environmental
Quality Engineering (August 31, 1984). Concerning Status Report No.5.
108. Letter from Robert S. Cummings, GHR Engineering Corporation to William J.
Sl Hilaire, Commonwealth of Massachusetts Department of Environmental
Quality Engineering (September 4,1984). Concerning a bi-weekly inspection of
the construction activities for the closure of the commercial area of the site.
109. Letter from Robert S. Cummings, GHR Engineering Corporation to William J.
Sl Hilaire, Commonwealth of Massachusetts Department of Environmental
Quality Engineering (September 18, 1984). Concerning Status Report No.6.
110. Letter from Richard R. DeBenedictis, GHR Engineering Corporation to William
J. 51. Hilaire, Commonwealth of Massachusetts Department of Environmental
Quality Engineering (September 18, 1984). Concerning a bi-weekly inspection
of the construction activities for the closure of the commercial area of the site.
111. Letter from Richard R. DeBenedictis, GHR Engineering Corporation to William
J. St. Hilaire, Commonwealth of Massachusetts Department of Environmental
Quality Engineering (October 3, 1984). Concerning Status Report No.7.
112. Letter from Richard R. DeBenedictis, GHR Engineering Corporation to William
J. St. Hilaire, Commonwealth of Massachusetts Department of Environmental
Quality Engineering (October 3, 1984). Concerning a bi-weekly inspection of
the construction activities for the closure of the commercial area of the site.
113. Letter from Richard R. DeBenedictis, GHR Engineering Corporation to William
J. St. Hilaire, Commonwealth of Massachusetts Department of Environmental
Quality Engineering (October 26, 1984). Concerning Status Report No.8.
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(\
17.8 State and local Technical Records (cont'd.)
114. Letter from Richard R DeBenedictis, GHR Engineering Corporation to William
J. Sl Hilaire, Commonwealth of Massachusetts Department of Environmental
Quality Engineering (October 26, 1984). Concerning a bi-weekly inspection of
the construction activities for the closure of the commercial area of the site.
115. Letter from Richard R DeBenedictis, GHR Engineering Corporation to William
J. St. Hilaire, Commonwealth of Massachusetts Department of Environmental
Quality Engineering (November 16, 1984). Concerning a bi-weekly inspection
of the construction activities for the closure of the commercial area of the site.
116. Letter from Richard R DeBenedictis, GHR Engineering Corporation to William
J. Sl Hilaire, Commonwealth of Massachusetts Department of Environmental
Quality Engineering (November 19, 1984). Concerning Status Report No. 10.
117. Letter from Richard R DeBenedictis, GHR Engineering Corporation to William
J. St. Hilaire, Commonwealth of Massachusetts Department of Environmental
Quality Engineering (December 6, 1984). Concerning Status Report No. 11.
118. Letter from Richard R DeBenedictis, GHR Engineering Corporation to William
1. Sl Hilaire, Commonwealth of Massachusetts Department of Environmental
Quality Engineering (December 6,1984). Concerning a bi-weekly inspection of
the construction activities for the closure of the commercial area of the site.
119. Letter from Richard R. DeBenedictis, GHR Engineering Corporation to William
J. St. Hilaire, Commonwealth of Massachusetts Department of Environmental
Quality Engineering (December 20, 1984). Concerning Status Report No. 12.
120. Letter from Richard R. DeBenedictis, GHR Engineering Corporation to William
J. St. Hilaire, Commonwealth of Massachusetts Department of Environmental
Quality Engineering (January 10, 1985). Concerning a bi-weekly inspection of
the construction activities for the closure of the commercial area of the site.
121. Letter from Robert A. Lacourse, GHR Engineering Corporation to William 1.
Sl Hilaire, Comr. wealth of Massachusetts Department of Environmental
Quality Engineel1ng (February 4, 1985). Concerning Status Report No. 13.
122. Letter from Robert A. Lacourse, GHR Engineering Corporation to William 1.
SL Hilaire, Commonwealth of Massachusetts Department of Environmental
Quality Engineering (March 6, 1985). Concerning Status Report No. 14.
123. Letter from Robert A. Lacourse, GHR Engineering Corporation to William 1.
Sl Hilaire, Commonwealth of Massachusetts Department of Environmental
Quality Engineering (April 1, 1985). Concerning Status Report No. 15.
124. Letter from Robert A. Lacourse, GHR Engineering Corporation to William J.
Sl Hilaire, Commonwealth of Massachusetts Department of Environmental
Quality Engineering (May 23, 1985). Concerning Status Report No. 16.
125. Letter from Robert S. Cummings, GHR Engineering Corporation to William J.
Sl Hilaire, Commonwealth of Massachusetts Department of Environmental
Quality Engineering (November 27,1985). Concerning the attached September
16,1985 Memorandum from Bill Swanson, Camp Dresser & McKee Inc. to
File and the descriptions of tasks that have to be done to complete the remedial
design.
126. Letter from Robert S. Cummings, GHR Engineering Corporation to Richard
Chalpin, Commonwealth of Massachusetts Department of Environmental Quality
Engineering (December II, 1985). Concerning Status Report No. 17.
127. Letter from Robert S. Cummings, GHR Engineering Corporation to Richard
Chalpin, Commonwealth of Massachusetts Department of Environmental Quality
Engineering (December 12, 1985). Concerning Status Report No. 18.
128. Letter from Robert S. Cummings, GHR Engineering Corporation to John
Fitzgerald, Commonwealth of Massachusetts Department of Environmental
Quality Engineering (March 24, 1986). Concerning notification that Task 1 of
the remedial design work as described in the February 19, 1986 letter has been
completed.
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17.8 State and Local Technical Records (cont'd.)
129. Letter from Robert S. Cummings, GHR Engineering Corporation to Richard
Chalpin, Commonwealth of Massachusetts Department of Environmental Quality
Engineering (March 24, 1986). Concerning Status Report No. 19.
130. Letter from Robert S. Cummings, GHR Engineering Corporation to Richard
Chalpin, Commonwealth of Massachusetts Department of Environmental Quality
Engineering (May 6, 1986). Concerning the results of an inspection of the site.
131. Letter from Robert S. Cummings, GHR Engineering Corporation to Richard
Chalpin, Commonwealth of Massachusetts Department of Environmental Quality
Engineering (July 1, 1986). Concerning the results of an inspection of the site.
132. Letter from Robert S. Cummings, GHR Engineering Corporation to Richard
Chalpin, Commonwealth of Massachusetts Department of Environmental Quality
Engineering (July 30, 1986). Concerning Status Report No. 22. .
133. "Addendum to Scope of Work - Additional Hydrogeologic and Water Quality
Assessment," OHR Engineering Corporation (October 21, 1986).
134. Letter from Robert S. Cummings, GHR Engineering Corporation to Richard
Chalpin, Commonwealth of Massachusetts Department of Environmental Quality
Engineering (December 8, 1986). Concerning Status Report No. 23.
135. Letter from Christine R. LeBlanc and Robert S. Cummings, GHR Engineering
Corporation to Richard Chalpin, Commonwealth of Massachusetts Department
of Environmental Quality Engineering (December 22,1986). Concerning Status
Report No. 24. .
136. Letter from Christine R. LeBlanc, GHR Engineering Corporation to John W.
Duggan, Commonwealth of Massachusetts Department of Environmental Quality
Engineering (December 24, 1986). Concerning progress made in securing
access and obtaining permission for the installation of groundwater monitoring
wells near the landfill.
137. Letter from Christine R. LeBlar.~-" .GHR Engineering Corporation to John W.
Duggan, Commonwealth of M.:.~.;achusetts Department of Environmental Quality
Engineering (January 4, 1987). Concerning closure activities report for the year
ending 1986.
138. Letter from Christine R. LeBlanc, GHR Engineering Corporation to Richard
Chalpin, Commonwealth of Massachusetts Department of Environmental Quality
Engineering (January 30, 1987). Concerning Status Report No. 25.
139. Letter from Christine R. LeBlanc, GHR Engineering Corporation to Richard
Chalpin, Commonwealth of Massachusetts Department of Environmental Quality
Engineering (March 10, 1987). Concerning Status Report No. 26.
140. "Draft Supplemental Evaluation in Support of Variance Application Pursuant to
310 CMR 10.58 With Regard to Wetlands Requirements and Request to Vary
department of Environmental Quality Engineering Policy Regarding Final
Landfill Slopes," GHR Engineering Corporation for Graypond Realty Trust
(April 1987).
141. Letter from Christine R. LeBlanc, OHR Engineering Corporation to John W.
Duggan, Commonwealth of Massachusetts Department of Environmental Quality
Engineering (May 1, 1987). Concerning Status Report No. 27.
142. Letter from Joseph P. Salvetti, GHR Engineering Corporation to John W.
Duggan, Commonwealth of Massachusetts Department of Environmental Quality
Engineering (May 21, 1987). Concerning installation of monitoring wells.
143. Letter from Christine R. LeBlanc, GHR Engineering Corporation to John W.
Duggan, Commonwealth of Massachusetts Department of Environmental Quality
Engineering (June 11, 1987). Concerning Status Report No. 28.
144. Letter from Christine R. LeBlanc, GHR Engineering Corporation to John W.
Duggan, Commonwealth of Massachusetts Department of Environmental Quality
Engineering (September 10, 1987). Concerning an inspection of the site.
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(\
17.8 State and Local Technical Records (cont'd.)
145. Letter from Christine R.LeBlanc, GHR Engineering Corporation to John W.
Duggan, Commonwealth of Massachusetts Department of Environmental Quality
Engineering (September 30, 1987). Concerning information on leachate seeps
present at the site.
146. Letter from Robert S. Cummings, GHR Engineering Corporation to Raymond
G. Dougan, Commonwealth of Massachusetts Department of the Attorney
General (January 22, 1988). Concerning transmittal of the attached
"Hydrogeologic Assessment Chronology."
147. Letter from Ralph P. Penney, GHR Engineering Corporation to John W.
Duggan, Commonwealth of Massachusetts Department of Environmental Quality
Engineering (May 10, 1988). Concerning the Monthly Activities Report for
Apri11988.
148. Letter from Ralph P. Penney, GHR Engineering Corporation to John W.
Duggan, Commonwealth of Massachusetts Department of Environmental Quality
Engineering (June 17, 1988). Concerning the Monthly Activities Report for
May 1988.
149. Letter from Ralph P. Penney, GHR Engineering Corporation to John W.
Duggan, Commonwealth of Massachusetts Department of Environmental Quality
Engineering (August 11, 1988). Concerning the Monthly Activities Report for
June 1988.
150. Letter from Ralph P. Penney, GHR Engineering Corporation to John W.
Duggan, Commonwealth of Massachusetts Department of Environmental Quality
Engineering (October 25, 1988). Concerning the Monthly Activities Report for
July 1988.
151. Letter from Mark Jablonski, GHR Engineerine Corporation to Steven Capone,
Alliance Technology Corporation (Apri112, .~). Concerning submittal of the
"Methane Gas Recovery Assessment"
152. Letter from Mark Jablonski, GHR Engineering Corporation to John W. Duggan,
Commonwealth of Massachusetts Department of Environmental Quality
Engineering (April 24, 1989). Concerning the Post Oosure Monthly Inspection
Report for April 21, 1989.
153. Letter from Mark Jablonski, GHR Engineering Corporation to John W. Duggan,
Commonwealth of Massachusetts Department of Environmental Quality
Engineering (May 31, 1989). Concerning the Post Closure Monthly Inspection
Report for May 26,1989.
154. Letter from Robert S. Cummings, GHR Engineering Corporation to John W.
Duggan, Commonwealth of Massachusetts Department of Environmental Quality
Engineering (June 14, 1989). Concerning the scope of work regarding the
pumping test to be performed at the site and the attached "Pump Test Fact
Sheet"
155. Letter from Mark Jablonski, GHR Engineering Corporation to John W. Duggan,
Commonwealth of Massachusetts Department of Environmental Quality
Engineering (July 6, 1989). Concerning the Post Oosure Monthly Inspection
Report for June 28, 1989.
156. Letter from Robert S. Cummings, GHR Engineering Corporation to Brian
Furman, Commonwealth of Massachusetts Department of Environmental Quality
Engineering (July 12, 1989). Concerning the attached scope of work regarding
the pumping test to be performed at the site and the "Pump Test Fact Sheet"
157. Letter from Mark Jablonski, GHR Engineering Corporation to John W. Duggan,
Commonwealth of Massachusetts Department of Environmental Quality
Engineering (July 13, 1989). Concerning an update to activities for the flI'St half
of 1989 and the attached June 23, 1989 Letter from Mark Jablonski, GHR
Engineering Corporation to Jim Sprague, Commonwealth of Massachusetts
Department of Environmental Quality Engineering.
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17.8 State and Local Technical Records (cont'd.)
158. Letter from Mark Jablonski, GHR Engineering Corporation to Irving Shaffer,
Graypond Realty Trust (July 18, 1989). Concerning the June 28, 1989
inspection of the site.
159. "Scope of Work - Additional Hydrogeologic and Water Quality Assessment,"
GHR Engineering Corporation.
Work Plans and Progress Reports (Graypond Realty Trust)
160. Letter from Burton Shaffer, Graypond Realty Trust to John Fitzgerald,
Commonwealth of Massachusetts Department of Environmental Quality
Engineering (February 26, 1986). Concerning transmittal of the attached
"Proposal to Graypond Realty Trust to Develop a Landfill Gas Recovery Plant,"
Northern Energy Recovery (January 1986).
161. Letter from Rebecca A. Backman, Wright & Moehrke (Attorney for Graypond
Realty Trust) to Raymond Dougan, Commonwealth of Massachusetts
Department of the Attorney General (October 23, 1987). Concerning the
schedule for the work required to complete closure of the landfill.
162. Letter from Anton T. Moehrke, Wright & Moehrke (Attorney for Graypond
Realty Trust) to Raymond Dougan, Commonwealth of Massachusetts
Department of the Attorney General (October 30, 1987). Concerning closure
work at the landfill.
163. Letter from Rebecca A. Backman, Wright & Moehrke (Attorney for Graypond
Realty Trust) to John W. Duggan, Commonwealth of Massachusetts
Department of Environmental Quality Engineering (January 20, 1989).
Concerning the response to the April 1988 "Supplemental Hydrogeologic and
Water Quality Assessment," GHR Engineering Corporation
Work Plans and Progress Reports (Middlesex Disposal Service, Inc.)
164. "Report on Operations from July 26-31,1982 and August 2-7, 1982," K.A.
Tarbell (August 11, 1982).
165. "Report on Operations," Middlesex Disposal Service, Inc. (August 9-14, 1982).
166. "Report on Operations," Middlesex Disposal Service, Inc.
(August 16-21, 1982).
167. "Report on Operations," Middlesex Disposal Service, Inc.
(August 23-28, 1982).
168. "Report on Operations," Middlesex Disposal Service, Inc.
(September 13-18, 1982).
169. "Report on Operations," Middlesex Disposal Service, Inc.
(October 4-9, 1982).
170. "Report on Operations," Middlesex Disposal Service, Inc.
(October 11-16, 1982). ,
171. "Report on Operations," Middlesex Disposal Service, Inc.
(October 18-23, 1982).
172. "Report on Operations," Middlesex Disposal Service, Inc.
(October 25-30, 1982).
173. "Report on Operations," Middlesex Disposal Service, Inc.
(November 1-6, 1982).
174. "Report on Operations," Middlesex Disposal Service, Inc.
(November 8-13, 1982).
175. "Report on Operations," Middlesex Disposal Service, Inc.
(November 15-20, 1982).
176. "Report on Operations," Middlesex Disposal Service, Inc.
(November 22-27, 1982).
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Page 31
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17.8 State and Local Technical Records (cont'd.)
177. "Report on Operations," Middlesex Disposal Service, Inc.
(November 29-December 4, 1982).
178. "Report on Operations," Middlesex Disposal Service, Inc.
(December 6-11, 1982).
179. "Report on Operations," Middlesex Disposal Service, Inc.
(December 13-18, 1982).
180. "Report on Operations," Middlesex Disposal Service, Inc.
(December 1983).
181. "Report on Operations," Middlesex Disposal Service, Inc.
(January 1984).
182. "Report on Operations," Middlesex Disposal Service, Inc.
(February 1984).
183. "Report on Operations," Middlesex Disposal Service, Inc.
(March 1984).
184. "Report on Operations," Middlesex Disposal Service, Inc.
(April 1984).
185. "Report on Operations," Middlesex Disposal Service, Inc.
(May 1984).
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Section II
Guidance Documents
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Page 32
GUIDANCE DOCUMENTS
EP A guidance documents may be reviewed at EP A Region I, Boston, Massachusetts.
General EP A Guidance Documents
1.
U.S. Environmental Protection Agency. Hazardous Waste E~gineering Research
Laboratory. Handbook for Stabilization/Solidification of Hazardous Waste
(EPA/540/2-86/001), June 1986.
2.
U.S. Environmental Protection Agency. Comprehensive Environmental Response.
Co~sation. and Liability Act of 1980. as amended October 17, 1986.
U.S. Environmental Protection Agency. Office of Emergency and Remedial Response.
CERCLA (Comprehensive Environmental Re$pOnse. Compensation. and Liability Ac~)
Compliance with Other Laws Manual (EPA/540/G-89/006, OSWER Directive 9234.1-01),
August 1988.
3.
4.
U.S. Environmental Protection Agency. Office of Emergency and Remedial Response.
Guidance for Conductine Remedial Investi~ations and Feasibility Studies Under CERCLA
(Comprehensive Environmental Response. Conwensation. and Liability Act) (Interim Finan
(EPA/540/G-89/004, OSWER Directive 9355.3-01), October 1988.
U.S. Environmental Protection Agency. Office of Solid Waste and Emergency Response.
A Guide on Remedial Actio.ns for Contaminated Ground Water (OSWER Directive
9283.1-2FS), April 1989.
5.
6.
U.S. Environmental Protection Agency. Office of Research and Development Technical
Guidance Document: Final Covers on Hazardous Waste Landfills and Surface
Impoundments (EPA/530-SW-89-047), July 1989.
U.S. Environmental Protection Agency. Office of Solid Waste and Emergency Response.
CERCLA (Comprehensive Environmental Response. Conwensation. and Liability Act)
Compliance with Other Laws Manual - Part IT: Clean Air Act and Other Environmental
Statutes and State Requirements (EPA/540/G-89/009, OSWER Directive 9234.1-02),
August 1989.
7.
8.
U.S. Environmental Protection Agency. Office of Solid Waste and Emergency Response.
CERCLA Compliance with Other Laws Manual - RCRA ARARs: Focus and Closure
Requirements (OSWER Directive 9234.2-04), October 1989.
U.S. Environmental Protection Agency. Office of Solid Waste and Emergency Response.
CERCLA Compliance with Other Laws Manual - Overview of ARARs - Focus on ARAR
Waivers (Publication 9234.2-03/FS), December 1989.
9.
10.
U.S. Environmental Protection Agency. National Oil and Hazardous Substances Pollution
Control Plan Code of Federal Re~ulations. Title 40. Part 300. March 8, 1990.
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Commonwealth of Massachusetts
Executive Office of Environmental Affairs
Department 0'
Environmental Protection
Daniel S. G,...,baum
Com............,
June 24, 1991
Ms. Julie Belaga
Regional Administrator
us EPA
JFK Federal Building
Boston, MA 02203
RE: Iron Horse Park Federal
Superfund site, Billerica
Shaffer Landfill Operable
unit
ROD
Concurrence
Dear Ms. Belaga:
The Department of Environmental Protection (the "Department") has
reviewed the Selected Remedy recommended by the EPA for measures
at the Shaffer Landfill Operable Unit of the Iron Horse Park
Federal Superfund Site (the "site"). The Department concurs with
EPA's Selected Remedy for this Operable Unit.
The Department has evaluated the EPA's Selected Remedy for
consistency with M.G.L. Chapter 21E and the Massachusetts
Contingency Plan ("MCP"). The Selected Remedy includes source
control and management of migration measures to address closure
of the landfill. This Operable unit's remedial action has the
following components:
1) Reconstruction of the entire landfill cap
2) Construction, operation, and maintenance of leachate
collection facilities
3) Off-site treatment and disposal of leachate
4) Construction of a perimeter fence
5) Monitoring of groundwater and surface water quality
6) Institutional controls
7) Monitoring and improvement, if necessary, of the gas
collection/flare system
The Department has determined that the Selected Remedy for this
operable Unit is a remedial action on a portion of the Site which
would be consistent with a future permanent or temporary solution
for the entire Site. M.G.L. Chapter 21E allows the
implementation of remedies on portions of a disposal site. Once
the remedial actions are developed for the remainder of this
Site, the Department will evaluate the reduction of total site
OM Winter Street
.
Bolton, Malsachuletts 02108
.
FAX (617) 556-1049
. Telephone (617) 292.5500
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risk, in conformance with the MCP.
The Department has reviewed the ARARs identified for the Shaffer
Landfill and has determined that the Selected Remedy appears to
meet these. The ARARs will continue to be evaluated as remedial
design progresses and during implementation and operation of the
remedy. In addition, we will continue to identify ARARs and
evaluate consistency with M.G.L. Chapter 21E during evaluation of
the third operable unit of the Iron Horse Park Site.
You should be aware that the EPA's Project Manager, Don McElroy,
should be commended for a superb job in managing this complex
project. His efforts to include the State in the Superfund
process at this site have been greatly appreciated.
, ,>
The Department looks forward to working with EPA in the design
and implementation of the Selected Remedy. If you have any
questions or require additional information please contact Dale
Young, Project Manager, at 292-5785.
Environmental
cc:
Dale Young, DEP-BWSC-Boston
Don Nagle, DEP-OGC-Boston
Joel Hartley, DEP-DSW-NERO
Deb Gallagher, DEP-DSW-Boston
John Fitzgerald, DEP-BWSC-NERO
Betsy Harper, Office of the Attorney
Tom Higgins, DEP-Boston
Ed Braezyk, DEP-AQC-NERO
Barbara Kwetz, DEP-AQC-NERO
Janet Waldron, DEP-BWSC
General
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