United States Office of
Environmental Protection Emergency and
Agency Remedial Response
EPA/ROD/R01 -91/058
September 1991
&EPA Superfund
Record of Decision:
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. .
50272-101
REPORT DOCUMENTATION 11. REPORTNO. 1 ~ I. RecIpIent. ~an No.
PAGE EPA/ROD/ROl-91/058
4. 1ItI8 8IId SWfte 5. A8part D8t8
SUPERFUND RECORD OF DECISION 09/30/91
Groveland Wells, MA &.
Second Remedial Action - Final
7. Aulhor(.) 8. P8rfoImIng OrganlDtlon Rept. No'
8. P8tf0nnlng Org8lnlZ8tl0n N8m8 8IId Addr888 10. ProjectITuklWCIItI Unit No.
11. Contr8cI(C) or Gr8nt(G) No.
Ic)
IG)
1~ SpoMorIng Org8l1lzallan N8m8 8IId Addr888 11. TypII of RtIpOI't. PerIod Coftred
U.S. Environmental Protection Agency 800/000
401 M Street-, S.W.
washington, D.C. 20460 14.
15. SUpplernenWy No..
.-
18. Ab81r8ct (UmIt: 2DO _nI8)
The 8S0-acre Groveland Wells site is a municipal well field in Groveland,
Massachusetts. Land use in the area is residential, industrial, and cormnercial. The
site is bounded to the north by the Merrimack River; to the west by the Haverhill
Municipal Landfill, which is another Superfund site; and to the south and east by
mixed land use areas. The site is underlain by a surfical unconsolidated aquifer,
which is a source of ground water for the well field, and a deeper bedrock aquifer.
Both a current and a former municipal water supply well are located within the site
boundaries. Johnson Creek, including its associated wetlands, flows across the site,
and portions of the site lie within the 100-year floodplain of the Merrimack River.
In 1979, elevated levels of TCE were discovered in the onsite water supply wells,
resulting in the closure of the wells, development of alternate water supplies, and
investigations by EPA. An initial remedial measure (IRM) by EPA in 1985 provided an
alternate water supply by installing a carbon adsorption unit on one of the onsite
water supply wells. EPA investigations identified three likely sources of
contamination: the A.W. Chesterton Company, currently being remediated under RCRA
corrective action and closure activities; the Haverhill Municipal Landfill, which has
(See Attached Page)
17. Doc:un81t An8Jy8I8 L DncripIoI'8.
Record of Decision - Groveland Wells, MA
Second Remedial Action - Final
Contaminated Medium: gw
Key Contaminants: VOCs (benzene, PCE, TCE, toluene), metals (arsenic, chromium,
b. IdentI1I8n/OpIIEncI8cI Term8 lead)
c. COSA11 FI8IdIGroup
18. AYIIIIIlblIty StIIIemenI 19. SecurIty CI... (lb18 Report) 21. No. of P.ges
None 242
20. SecurIty CI888 (lb18 Page) n Price
Non~
272 (4-77
(See ANSl-Z38.18)
See/MlnJClj- on 114-
(Fonnetty N11$.3S)
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J
o
EPA/ROD/ROl-91/058
Groveland Wells, MA
Second Remedial Action - Final
Abstract (Continued)
been addressed as a separate CERCLA action; and the Valley Manufactured Products
Company (Valley), a screw machine products manufacturer and finisher. From 1963 to
1974, Valley operations involved the release of up to 3,000 gallons of waste oil and
solvents, including TCE, to the soil either from an underground disposal storage tank
leak, or from spills or leaks from underground disposal systems. A 1988 Record of
Decision (ROD) provided for removal of source contamination from the Valley property
using vacuum extraction, and installation of a ground water recovery, treatment, and
reinjection system to treat VOC-contaminated ground water beneath the property. The
State also required valley to install a ground water pump and treatment system using
air stripping to intercept the plume at Mill Pond, an onsite man-made water body. This
ROD addresses .management of migration of contamination in the surfical and bedrock
aquifers extending from the valley site, as a final remedy. The primary contaminants
of concern affecting the ground water are VOCs including benzene, PCE, TCE, and
toluene; and metals including arsenic, chromium, and lead.
The selected remedial action for this site includes pumping and treatment of ground
water using an inorganics removal system consisting of equalization/aeration,
flocculation, coagulation, sedimentation, and filtration; disposing of the resulting
sludge offsite; further treating ground water using ultraviolet light and oxidation to
remove VOCs; discharging the treated water onsite to Johnson Creek; monitoring ground
water, surface water, and sediment; and implementing institutional controls including
deed and ground water use restrictions. The estimated present worth cost for this
remedial action is $8,900,000, which includes an annual O&M cost of $333,000 for 30
years.
PERFORMANCE STANDARDS OR GOALS: Interim ground water clean-up levels are based on the
more stringent of Federal MCLs or non-zero MCLGs, or State MCLs. Chemical-specific
ground water goals include benzene 5 ug/l (MCL), PCE 5 ug/l (MCL), TCE 5 ug/l (MCL),
toluene 1 mg/l (MCL), arsenic 50 ug/l (MCL), and chromium 50 ug/l (MCL). The clean-up
level for lead, 15 ug/l, is based on EPA Superfund Policy. When all interim levels are
met, a risk assessment will be performed on residual ground water contamination to
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DECLARATION fOH THE RECORD OF DECISION
Groveland Wells Nos.
Groveland,
1 & 2, Operable Unit I
Massachusetts
statement of PurDose
This Decision Document presents the selected remedial action for
this site developed in accordance with the Comprehensive
Environmental Response, Compensation, and Liability Act of 1980
(CERCLA), as amended by the Superfund Amendments and
Reauthorization Act of 1986 (SARA), and to the extent
practicable, the National contingency Plan (NCP), 40 CFR
Part 300, 55 Federal Register 8666 (M~rch 8, 1990)~
The Commonwealth of .Massachusetts has concurred with the selected
remedy.
statement of Basis
This decision is based on the Administrative Record which was
developed in accordance with Section 113(k) of CERCLA and which
is available for public review at the information repositories
located at the Langley-Adams Public Library in Groveland,
Massachusetts, and at the EPA offices at 90 Canal Street in
Boston, Massachusetts. The attached index identifies the items
which comprise the Administrative Record upon which the selection
of a remedial action have been based.
DescriDtion of the Selected Remedv
~
~
Groundwater within the contaminated plume and throughout the Site
would be restored to designated standards through the
implementation of a series of actions. A groundwater extraction
network of approximately six wells, located throughout the plume,
would be sited to intercept contaminated groundwater along its
entire width and depth including contamination in the shallow
bedrock. The total estimated. flow rate needed to intercept the
plume is about 400 gallons per minute (gpm). The contaminated
groundwater would be subject to an inorganics treatment process
involving equalization/aeration, sedimentation and filtration.
The resulting sludge would be disposed of off-site. .
The filtered water would then be subjected to a process involving
ultraviolet (UV) light and oxidation to destroy trichloroethene
(TCE) and other volatile organics. The treated groundwater would
be discharged to Johnson Creek near Groveland Well No.2. The
discharge structure will include measures to minimize potential
erosion of the. river bed and will be designed to ensure that it
will not cause physical disruption of wetlands (if any) near the
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Institutional controls consisting of deed restrictions
prohibiting installation and use of private wells in the plume
until completion of ground~~ter re~ediation would be implemented.
It is assume::1 that the gra:-:_':'ar ::-:.~.-~:.)o::. adsorption s1-steT:! at
S~a~~=~ ~o. : uou:~ ccnt~:-:ue to ~~erate, but that system is not
part of the seiec~ed remedy.
During remedial design, the existing Mill Pond extraction system
will be considered for use to supplement or replace one of the
six new extraction wells proposed for this area. Treatability
testing would be required during remedial design to confirm
feasibility of the UVjOxidation process and to derive design
parameters. A background groundwater sampling program for
inorganics is also planned during the remedial design phase of
the remedy. site inorganic concentrations will then be re-
evaluated in comparison to these results. If it is determined
through background groundwater sampling that certain inorganic
levels represent background, then those inorganics will no longer
be identified as site related contaminants, and ARARs for those
contaminants would not need to be met.
Sampling of monitoring wells around Groveland Well No.1 would be
conducted regularly to ensure that contaminated groundwater is
not migrating toward the municipal supply well. Groundwater
monitoring wells adjacent to the Chesterton property and
Haverhill Municipal Landfill will be sampled on a regular basis
to ensure that the remedial extraction system do~s not adversely
spread the contamination originating from these properties.
Additionally, sampling of the surface water and sediments in
Johnson creek and other nearby streams would be conducted on a
semi-annual basis to identify any potential discharge of
contaminated groundwater to surface water bodies.
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 action
and is cost-effective. The selected remedy utilizes permanent
solutions and alternative treatment technologies to the maximum
extent pr.acticable. The statutory preference for remedies that
utilize treatment as a principal element to reduce the mobility,
toxicity, or volume of hazardous substances is met by the
selected remedy.
7(3t.(y1
Date
) t
~ ~ ~/..~
Julie~elaga ;~
Regional Administrator, EPA Region I
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()
,t')
Groveland Wells 1 & 2
(Operable Unit I -
Management of Migration)
NPL Site Administrative Record
Index
Compiled: May 29, 1991
Updated: August 14, 1991
ROD Signed: September 30, 1991
Prepared for
Region I
Waste Management Division
U.S. Environmental Protection Agency
With Assistance from
AMERICA~ MANAGEMENT SYSTEMS, INC.
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Introduction
Tr.is document is the :nG~x to the Ad.rrunistT1tive Record for t.1e September 30.1991 Record
ofDec:sion (ROD\ fo:- :he (>.~,\eland Well:. ~--;llrr:bers 1 &.: :'
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'~
~
sec\\01\ \
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"
y,
(',
AD~I~ISTRA TIVE RECORD I~DEX
for the
(j,' , eland \"ells ~umbers ! & 2 ~PL Site
(Operable Lnit I . Management of Migration)
(ROD Signed: September 30, 1991)
3.0
Remedial Investigation (RI)
Correspondence
3.1
1.
Letter from Robert J. Leger, EPA Region I to James R. Forrelli, NUS
Corporation (February 17, 1989). Concerning transmittal of historical
documents on the site. .
Letter from Robert J. Leger. EPA Region I to David Roberts, Town of
Groveland (June 13, 1989). Concerning an update on site progress and the
request for a meeting with the Groveland Water and Sewer Commission.
Letter from Robert J. Leger, EPA.Region I to Leo Downing, Town of
Groveland (July 13, 1989). ,Concerning notification that the Remedial
lnvestigation/Feasibility StUdy will begin in the summer and that a meeting has
been scheduled with the Grove1and Water and Sewer Commission.
Letter from Robert J. Leger, EPA Region I to Dick Sciacca, Town of Grove1and
(July 13. 1989). Concerning notification that the Remedial Investigation/
Feasibility Study will begin in the summer and that a meeting has been scheduled
with the Groveland Water and Sewer Commission.
Letter from Roben J. Leger. EPA Region I to Kurt Anderson, Town of
Groveland (July 13. 1989). Concerning notification that the Remedial
InvestigationlFeasibility Srudy will begin in the summer and that a meeting has
been scheduled with the Grbveland Water and Sewer Commission.
Letter from Robert J. Leger. EPA Region I to Ja.net Angelis, Town of Groveland
(July 13. 1989). Concerning notification that the Remedial Investigation/
Feasibility Study will begin in the summer and that a meeting has been scheduled
with the Gro\'eland Water and Sewer Commission.
Letter from Robert J. Leger, EPA Region I to Carol Davies, Town of Groveland
(July 13. 1989). Concerning notification that the Remedial Investigation/
Feasibility Study will begin in the summer and that a meeting has been scheduled
with the Groveland Water and Sewer Commission.
Letter from Raben J. Leger, EPA Region I to F. John Osborne, Town of
Groveland (July 13. 1989). Concerning notificatiori that the Remedial
InvestigationlFeasibility Study will begin in the summer and that a meeting has
been scheduled with the Groveland Water and Sewer Commission. .
Letter from Robert J. Leger. EPA Region I to Joan Searl, Town of Groveland
(July 13, 1989). Concerning notification that the Remedial Investigation!
Feasibility Study will begin in the summer and that a meeting has been scheduled
with the Groveland Water and Sewer Commission. .
Memorandum'from Roben J. Leger, EPA Region 1 to Addressees
(September 6. 1989). Concerning transminal of the August 1989 "Final Work
Plan." ;\L:S Corporation.
Letter from Robert J. Leger, EPA Region I to Rosanna Sattler, Posternak.
Blankstein & Lund (Attorney for Town of Groveland) (September 12. 1989).
Concerning transmittal of the August 1989 "Final Work Plan - Supplemental
\1anagemem of \1igration." !',LJS Corporation.
..,
3.
4.
5.
6.
7.
8.
9.
10.
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"
3.1
..
..
Page 2
Correspondence (cont'd.)
12. Letter from Robert J. Leger, EPA Region I to Kun Anderson. Town of
Groveland l September 26, 1989). Concerning the results of surfac'e water
sa.~Dlin~ from the area south of Salem Street.
13. Le~ie; fr.om James R. Forrelli. ~"'lS C0rpor:nion to John Carlton. Grcveland
Fire Department (December 18, 1989). Concerning notulcarion Lf1at sampling
will be done at the site.
14. Letter from James R. Forrelli, NUS Corporation to William E. Sargent,
Groveland Police Department (December 18, 1989). Concerning notification
that sampling will be done at the site.
15. Telephone Notes Between Jay Naparstek, Commonwealth of Massachusetts
Department of Environmental Protection and James R. Ferrelli, NUS
Corporation (February 2, 1990). Concerning sampling to begin at the site.
16. Telephone Notes Between Jay Falcone, M. Anthony Lally Associates, Inc. and
James R. Forrelli, J\'US Corporation (February 6, 1990). ,Concerning the
schedule of sampling at the site and the Mill Pond system data.
17. Letter from Patricia Rogers, Town of Grove1and to Merrill S. Hohman, EP A
Region 1 (February 7, 1990). Concerning transmittal of the attached:
A. Letter from David Roberts. Town of Groveland to Merrill S. Hohman.
EPA Region I (January 22, 1990). Concerning restriction of development
within the site.
B. Letter from David Roberts, Town of Groveland to Leo Downing, Town of
Grove1and (Sovember 28, 1989). Concerning the recommendation that
the Town of Groveland not sell part of the Stanfield Pit to William Angelini
, and Wood\' Cammett.
1 R: Telephone Sores Between Jay Falcone, M. Anthony Lally Associates, Inc and
James R. Forrelli. ~t:S Corporation (February 9, 1990). Concerning the
schedule of sampling at the site.
19. Telephone ~ores Between Dave Blanchard. M. Anthony Lally Associates, Inc.
and James R. Forrelli. ~lJS Corporation (February 12, 1990). Concerning the
schedule of sampling at the site.
:!O. Letter from Robert J. Leger, EPA Region I to Dan 1. D'Orazio, Groveland
Machine Co., Inc. (February 13, 1990). Concerning transmittal of samples
collected at well locations J\uS-1 and I\TUS-2. '
21. Telephone ~otes Between David P. Argyros, A.W. Chesterton Co. and James
R. Forrelli. ;...1.]S Corporation (February 16, 1990). Concerning the sampling
of monitorinl:! wells at the site.
22. Telephone ~(>tes Between William Sargent, Town of Groveland Police
Department and James R. Forrelli, NUS Corporation (March 8, 1990).
Concerning notification that the seven day pump test will stan soon.
23. Telephone ~otes Between Jay Naparstek, Commonwealth of Massachusetts
Department of Environmental Protection and Becky Cleaver, NUS Corporation
(May 25, 1990). Concerning well logs for intercept wells 1 G and 2G.
24. Telephone Notes BeN/een Dick Ferrick, Town of Groveland and Becky
Cleaver, J\lJS Corporation (June 11, 1990). Concerning notification that the
Mill Pond Extraction System has been shut down for at least twO weeks.
25. Telephone ~ores Between Richard Willey, EPA Region 1 and James R. Forrelli.
~'US Corporation (June 21, 1990). Concerning the second round of sampling.
26. Letter from Jim Forrelli, ~S Corporation to Robert 1. Leger, EPA Region I
(August 20. 1990). Concerning the transminal of the attached information to be
discussed on the risk assessment. .
27. Letter from Celina Harshman, Commonwealth of Massachusetts Division of
Fisheries & Wildlife to Stephen S. Parker, NCS Corporation
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3.1
Correspondence (cont'd.)
28. Telephone Notes Between Jeff Orient, ~LJS Corporation, James R. Forrelli and
Steve Parker, !'iTS Corporation (August 23, 1990). Concerning division of the
site for risk assessment purposes.
19. TeleDhone :\"otes Bt:;..:eer: Elaine ykCov. Town of Grovelar,d and Steve Parker.
~1.iS Corporation (September -+, 1990). . Concerning records or priva!e water
wells in the town.
30. Lener from George D. Gardner, NUS Corporation to Diane Kelley, EPA
Region I (September 27, 1990). Concerning transmittal of the September 1990
"Draft Risk Assessment Technical Memorandum," NUS Corporation.
31. Memorandum from Roben 1. Leger, EPA Region.I to attached list of Addressees
(February 28, 1991). Concerning ttansmittal of the February 1991
"Supplemental Management of Migration Remedial Investigation Repon," NUS
Corporation.
3.2
Sampling and Analysis Data
1. "Well Data Base for the Groveland Wells Site," EPA Region I (March 7, 1989).
2. Memorandum from James R. Forrelli, NUS Corporation to Roben J. Leger,
EPA Region I (July 5, 1989). Concerning transmittal of the attached preliminary
tables reflecting changes to the work plan for the site.
3. Memorandum from James R. Forrelli, NUS Corporation to Robert J. Leger,
EP A Region I (December 18, 1989). Concerning transmittal of the attached
"Task Modification Re{Juest" which addresses the sampling during drilling at the
site.
4. "Final Sampling and Analysis Plan," ~'US Corporation (December 1989).
5. Memorandum from James R. Forrelli, ~'US Corporation to Roben J. Leger,
EPA Region I (January 29. 1990). Concerning transmittal of the attached results
of field screening at the site.
6. Letter from John L. Falcone Jr., M. Anthonv Lallv Associates, Inc. to James R.
Forrelli, !\US Corporation (February 7, 1990). Concerning transmittal of the
attached Mi11 Pond Quarterly Discharge Monitoring Reports for April 1988 to
December 1989.
7. Letter from Lucy Guzman, ~'US Corporation to Karen Wedlock-Hunt, EPA
Region I (February 23. 1990). Concerning data validation for water quality
parameters.
8. Letter from James R. Forrelli, ~LJS Corporation to Robert 1. Leger, EPA
Region I (March 7, 1990). Concerning transmittal of the attached "Groveland
Wells Site Groundwater Field Screening." .
9. Telephone Notes Between Jay Naparstek, Commonwealth of Massachusetts
Depanment of Environmental Protection and Becky Cleaver, NUS Corporation
(May 10, 1990). Concerning sampling results from the site.
10. Letter from James R. Forrelli, NUS Corporation to Robert J. Leger, EPA
Region I (May 16, 1990). Concerning the recommendation that a second round
of groundwater samples be collected and the attached sampling tables.
The record cited as entry nwnber II contains confidential business information and is
withheld as COl\FIDE.\TIAL.
11.
"Work Plan Amendment Memorandum - Second Round Sampling," ~1:S
Corporation (June 1990).
Comments Dated July 9, 1990 from Robert 1. Leger, EPA Region I on the
June 1990 "Work Plan Amendment Memorandum - Second Round Sampling,"
~LS Corporarion.
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Page 4
3.2
Sampling and Analysis Data (cont'd.)
13. Cross-Reference: "Draft Pumping Test Technical Memorandum." !'oI1JS
Corporation (August 1990) [Filed and cited as entry number 1 in 3.4 Interim
Deli verables].
I-t. Lener from James R. Forrelli. ~LS Corporation !o Robert J. Leger. EPA
Region I (September 7, 1990). Concerning tr.illsminal of the arr.ached
Memorandum from James R. Forrelli, NUS Corporation to Roben J. Leger,
EPA Region I (August 30, 1990) regarding proposed groundwater modeling at
the site.
15. Letter from Madeline Snow, Commonwealth of Massachusens Department of
Environmental Protection to Thomas Quinlan, Valley Manufactured Products
Company, Inc. (October 17, 1990). Concerning the proposed revision of the
monitoring and reporting program being implemented for the Mill Pond intercept
system.
16. Memorandum from James R. Forrelli, NUS Corporation to'Roben J. Leger.
EPA Region I (November 26, 1990). Concerning transmittal of the attached
"Draft Groundwater Model Objectives Supplemental MOM RIIFS."
17. ' Memorandum from Roben J. Leger, EPA Region I to James R. Forrelli, 1\ljS
Corporation (December 13. 1990). Concerning the calibration/validation '
process for the "Groundwater Model Objectives Supplemental MOM RIIFS."
18. "Draft Work Plan Amendment No. 3 - Supplemental MOM RIffS Groundwater
Modeling," 1\LJS Corporation (December 1990).
19. Comments Dated December 10, 1990 from Roben 1. Leger, EPA Region I on
the December 1990 "Draft Work Plan Amendment No.3 - Supplemental MOM
RIfFS Groundwater Modeling," NUS Corporation.'
10. Letter from Rosanna Sattler, Pasternak, Blankstein & Lund (Anorney for Town
of Groveland) to Jay Naparstek. Commonwealth of Massachusens Department
of Environmental Protection (January 8, 1991). Concerning transmittal of the
attached pumping data for Wells 1 and 2 for the Town of Groveland from 1974
throu5!h 1980.
21. Letter from James R. Forrelli. 1\'US Corporation to Roben J. Leger, EPA
Region 1 (January 14. 1991). Concerning the requested information on the
"Groundwater Model Objectives Supplemental MOM RIfFS" and the following
attachments:
A. "~leeting Summary - Computer Modeling Supplemental MOM Rl/FS."
~us Corporation (December 20, 1990).
B. Memorandum from Richard Willey, EPA Region I to Robert J. Leger.
EP A Region 1 (December 24, 1990).
-.,., Letter from David P. Argyros, A.W. Chestenon Co. ,to Roben 1. Leger, EPA
Region I (January 24, 1991). Concerning the transmittal of the attached 1989
and 1990 environmental sampling results for the Chestenon-Pandel site.
23. Letter from James R. Forrelli, N1JS Corporation to Roben J. Leger, EPA
Region I (May 15, 1991). Concerning the attached RAS samples case number
list, SAS chain of custody records, and field chain of custody records.
24. Memorandum from Pei-Fung Hurst, EPA Office of Research and Development
to Robert 1. Leger. EPA Region I (August 19, 1991). Concerning the
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3.2
3,4
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Page 5
Sampling and Analysis Data (cont'd.)
25. Mernorarldum from James R. Forrelli.1\.TUS Corporation to Roben J. Leger,
E?A Re~ion I (AuE:ust 28. 1991). CO:1cerm,,:: ::ransrrJ::::: of the attached result~
or silrfac-e water sampies Laken from the site in June 19<;; and the accompanying:
''[;:1:::' Valici:ion Sheets."
26. Letter from James R. Forrelli, NUS Corporation to RODert J. Leger. EPA
Region I (September 23.1991). Concerning the analytical results for the
residential well and surface water discharge samples and the attached "Table A:
Comparison of Chemical Concentrations to Available Federal SDW A MCLs and
Ambient Water Quality Criteria (ugIL)."
27. Chain,of Custody Records. EPA Region I.
28. "Groveland Groundwater Modeling Results ofFlowpath ModeL"
29. "Draft - Averaged TCE Concentration (u~l)."
30. "Draft - Summary of Stream Aquifer Interactions in the Model Calibration and
Validation Runs."
"Draft - Distribution of Residual Error in Drawdown."
"Draft - RO\lr-path Logbook for Data Set GL."
"Draft. Flowpath Logbook for Data Set GL Pl."
"Draft - Calculation of Residual Error."
"Draft - Distribution of Residual Error in Water Elevation, No Pumping."
"Draft - Distribution of Residual Error in Water Elevation" Pumping."
"Draft - Summary of the Simulated Pumping and Infiltration Conditions."
"Draft - Map A: Bottom of Aquifer," J'o4lJS Corporation.
"Draft - Map B: Hydraulic Conductivity Distribution," NUS Corporation.
"Draft - Map C: Constant Head Conditions," NUS Corporation.
"Draft. Map D: Surface Water Conclitions," l'oo~S Corporation.
"Draft - Map E: Stream-Aquifer Interactions," NUS Corporation,
"Draft - Map F: Surface Recharge Areas," ~L'S Corporation.
"Average TCE Concentration (ug/l)."
"Simulation Domain and Boundary Conditions," NUS Corporation.
Site Sampling Maps. :-""l:S Corporation.
31.
32.
33.
34.
35.
36.
37.
38.
39.
40.
41.
42.
43.
44.
45.
46.
Additi(Jnfl/ Samp/inR and Analysis Datafor th£ Remedial Investigation (R/) may be
ren'e\\'ed, hy appointment nn/y. at EPA Re!!.inn I, Boston, Massachusetts, '
Interim Deli\'erables
Report
1.
"Draft Pumping TesrTechnical Memorandum," l'ooTUS Corporation
(August 1990).
"Draft Risk Assessment Technical Memorandum," NUS Corporation
(September 1990).
"Draft Technical Memorandum #BIO-90-10," EPA Region I
(October 18, 1990). Concerning RPB II analysis of Merrimack River
Tributaries,
2.
3.
Comments
The rec(lrd cited as entry number 4 is CONF/DEl'vTIAL and availahle onlyfor
judicial re\'ieH',
4.
Comments Dated August 27, 1990 from Virginia de Lima, United States
Department of the lnterior on the August 1990 "Draft Pumping Test Technical
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3.4
Interim Deliverables (conI'd.)
Comments Dated August 31. 1990 from EPA Region Ion the August 1990
"Dr:t:t f>lJrnping Test Technical ?\kmorandu.."Tl," ~LS Corporation.
CornInems Datee OctOber 15.1990 from RoDen J. Le£er, EPA Relcion I on the
September 1990 'Draft Risk Assessmem Technical ~1emorandum,':; 1\1.:S
Corporation.
Responses to Comments
5.
6.
3.6
Response Dated September 6, 1990 from Jeff Orient. NUS Corporation to the
Comments Dated August 31,1990 from EPA Region I.
Remeilial Investigation (RI) Reports
7.
Report
1.
"Remeilial Investigation for the Groveland Wells Site - Groveland,
Massachusetts - Volume I," NUS Corporation (June 1985).
"Remedial Investigation for the Groveland Wells Site - Groveland,
Massachusens - Volume II - Appendices," ~'US Corporation (June 1985).
"Draft Supplemental Management .of Migration Remeilial Investigation Report,"
1\1.]S Corporation (~ovember 1990). '
"Draft Supplemental Management of Migration Remedial Investigation Report -
Appendices," 1\'1]S Corporation (November 1990).
"Supplemental Management of Migration Remedial Investigation Report," 1\1)S
Corporation (February 1991). '
"Supplemental Management of Migration Remedial Investigation Report -
Appendices," ~l.;S Corporation (February 1991).
2.
...
~.
4.
5.
6.
Comment~
7. Comments Dated December 6, 1990 from Kenneth Finkelstein, United States
Deparnnem of the Interior I\ational Oceanic and Aanospheric Administration on
the !"ovember 1990 "Draft Supplemental Management of Migration Remedial
Investigation Repon," !'w1.]S Corporation.
8. Comments Dated December 13, 1990 from Cvndi PerrY, United States
Depanmem of the Interior Fish and Wildlife Service 00 the November 1990
"Draft Supplemental \1anagement of Migration Remeilial Investigation Report,"
J\TUS Corporation.
9. Comments Dated December 14, 1990 from Jay Naparstek, Commonwealth of
Massachusens Depanment of Environmental Protection on the November 1990
"Draft Supplemental Management of Migration ReniedialInvestigation Report,"
1\1)S Corporation.
10. Comments Dated December 17, 1990 from Robert J. Leger, EP A Region I on
the November 1990 "Draft Supplemental Management of Migration Remedial
Investigation Repon," }\rus Corporation.
11. Comments Dated March 29,1991 from Cyndi Perry, United States Department
of the Interior Fish and Wildlife Service on the February 1991 "Supplemental
Management of Migration Remedial Investigation Report." l\'US Corporation.
12. Letter from ~1artin C. Pentz. Nuner, McClennen & Fish (Attorney for Valley
Manufactured Products Company, Inc. and Groveland Resources Corporation)
to Mark Lowe, EP A Region I (June 3, 1991). Concerning the anached
"Preliminary Commems on EPA Supplemental MOM RI: Source of Station I'o.
-------
3.7
4.0
c;
Page 7
Work Plans and Progress ReportS
Report
"Final Work Plan." !\l.;S Corporation (August 1989).
C:oss Referen;:e: "Work Pla..oo: Amendmem ~1emorandum - Second Round
Sampling," 1'il.;S Corporation (June 1990) [Filed and cited as entry number 11
in 3.2 Sampling and Analysis Data].
Cross-Reference: "Draft Work Plan Amendment No.3 - Supplemental MOM
RIIFS Groundwater Modeling," NUS Corporation (December 1990) [Filed and
cited as entry number 18 in 3.2 Sampling and Analysis Data].
Comments
1.
2.
3.
4.
Cross Reference: Comments Dated July 9, 1990 from Roben 1. Leger, EPA
Region Ion the June 1990 "Work Plan Amendment Memorandum - Second
Round Sampling:' NUS Corporation [Filed and cited as entry number 12 in 3.2
Sampling and Analysis Data]. .
Feasibility Study (FS)
4.1
Correspondence
4.5
Memorandum from Robert 1. Leger, EPA Region I to attached list of Addressees
(July 15. 1991). Concerning the transmittal of the July 1991 "Supplemental
Management of Migration Feasibility Srudy Repon," NUS Corporation and the
. July 1991 Proposed Plan.
Applicable or Relevant and Appropriate Requirements (ARARs)
1.
.1.
Cross-Reference: Comments Dated April 18, 1991 from Charles Tunle,
Commonwealth of Massachusens Office of Environmental Affairs on Applicable
or Relevant and Appropriate Requirements (ARARs) and the February 1991
"Draft Supplemental Management of Migration Feasibility Srudy Repon," NUS
Corporation [Filed and cited as entry number 7 in 4.6 Feasibility Study (FS)
Reports]. . .
Cross-Reference: Response Dated May 20, 1991 from Robert 1. Leger, EPA
Region Ion the April 18. 1991 Comments from Charles Tuttle, Commonwealth
of Massachusetts Office of Environmental Affairs [Filed and cited as entfv
number 9 in 4.6 Feasibility Study (FS) Reports]. ..
2.
4.6
Feasibility StUdy (FS) Repons
Repon
1.
2.
"Feasibilitv Study for the Groveland Wells Site - Groveland, Massachusens -
Volume I."'SCS Corporation (August 1986).
"Feasibilitv Study for the Groveland Wells Site - Groveland, Massachusetts -
Volume If-Appendices, ~LJS Corporation (August 1986).
"Supplemental Management of Migration Feasibility Srudy Repon," ~rus
Corporation (July 1991).
"Supplemental Management of Migration Feasibility Study Report-
Appendices." !\l..:S Corporation (July 1991).
3.
-------
'.
"
4.6
4.9
Page 8
Feasibility Study (fS) Reports (conI'd.)
Comments
C:munems Dated \1arch 20. i 991 from Kenneth Finkelstein. C.S. DeDmmem
of CO:.lITIe,:e ~ational Ocea.:~ and AL!11Ospheric Acministration on the .
Februa.-y 1991 "Draft Supplement.'il ~1anagemem of Migration Feasibiiity Study
Report," ~US Corporation.
Comments Dated April 2, 1991 from Cyndi Perry, U.S. Department of Labor
Fish and Wildlife Service on the February 1991 "Draft Supplemental
Management of Migration Feasibility Study Report," NUS Corporation.
Comments Dated April 18, 1991 from Charles Tunle, Commonwealth of
Massachusens Office of Environmental Affairs on Applicable or Relevant and
Appropriate Requirements (ARARs) and the February 1991 "Draft Supplemental
Management of Migration Feasibility Study Report," NUS Corporation.
Comments Dated May 30,1991 from Cyndi Perry, U.S. Department of the
Interior Fish and Wildlife Service on the Draft Proposed Plan for the site.
Responses to Comments
5,
6.
7.
8.
9. Response Dated May 20,1991 from Robert J. Leger, EPA Region Ion the
April 18. 1991 Comments from Charles Tuttle, Commonwealth of
Massachusetts Office of Environmental Affairs.
10. Response Dated September 17, 1991 from Richard Cavagnero, EP A Region I
on the March 20. 1991 Comments from Kenneth Finkelstein, U.S. Department
of Commerce ~ationa1 Ocean and Attnospheric Administration [This lener is
addressed to John Lindsay as a representative of the U.S. Department of
Commerce National Ocean and Atmospheric Administration].
11. Response Dated September 17. 1991 from Richard Cav.agnero, EP A Region I
on the April:2. 1
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"
Page 9
5.1
Correspondence (con1'd.)
5.2
Telephone ~otes Between Robert 1. Leger. EPA Region I and Steve Roble.
COrrUnonweaJrr. . . \'13.s~achuse::s Division of Fish and Wi:d1ife
(Se'Pt~!T.ber ~7.. :,):!. .~o~~eming the Cor;unonwealth of Massa~huset:s.
L". :Sion of :-:s:: 2.::': \\ ;ldl1re ~ 'JCS;:ion on now the remedv descDDed In the
Proposed Plan will affect rare and endangered species. -
Cross-Reference: Memorandum from M. Gretchen Muench, EPA Region I to
Robert 1. Leger, EPA Region I (September 20, 1991). Concerning Applicable
or Relevant and Appropriate Requirements (ARARs) for inclusion into the
Record of Decision and notification that the Commonwealth of Massachusetts
will concur with the selected remedy [Filed and cited as entry number 2 in 5.2
Applicable or Relevant and Appropriate Requirements (ARARs)].
Telephone ~otes BetWeen Robert 1. Leger, EPA Region I and Michael Amaral,
U.S. Department of Labor Fish and Wildlife Service (September 27,1991).
Concerning the tWo federally listed endangered species and the effect the remedy
described in the Proposed Plan will have on them. .
Applicable or Relevant and Appropriate Requirements (ARARs)
4.
5.
6.
1.
Letter from Helen Waldorf, Commonwealth of Massachusetts Department of
Environmental Protection to Robert 1. Leger, EPA Region I .
(September 9. 1991) and the attached April 18, 1991 Letter from Charles Tuttle,
Commonwealth of Massachusetts Office of Environmental Affairs to Robert 1.
Leger. EPA Region I. Concerning the identification of Applicable or Relevant
and Appropriate Requirements (ARARs) for inclusion into the Record of
Decision.
Memorandum from \1. Gretchen Muench, EPA Region I to Robert 1. Leger.
EPA Region I (September 20, 1991). Concerning Applic.able or Relevant and
Appropriate Requirements (ARARs) for inclusion into the Record of Decision
and notification that the Commonwealth of Massachusetts will concur with the
selected remedy. .
.,
5.3
Responsiveness SL:mmary
1.
Cross-Reference: Responsiveness Summary is an attachment to the
September 30. 1991 "Record of Decision," EP A Region I [Filed and cited as
entry number 1 in 5.4 Record of Decision (ROD)].
'The following citation.s indicate documents recei\'ed by EPA Region I during the
formal public comment period. .
2.
Comments Dated July 13, 1991 from Gverin E. Carlson on the July 1991
Proposed Plan.
Comments Dated J ulv 31, 1991 from Linda M. Loreth, A. W. Chesterton Co.
on the July 1991 ProPosed Plan.
Comments from Kurt Goodwin on the July 1991 Proposed Plan
(Received September 6, 1991).
Comments Dated September 6, 1991 from Rosanna Sattler, Posternak,
Blankstein & Lund (AttorneyJorTown of Groveland) on the July 1991
Proposed Plan and the attached handwritten notes.
Comments Dated September 9, 1991 from Suzanne K. Condon and William C.
Strohsnitter. Commonwealth of Massachusetts Office of Health and Human
Services on the July 1991 Proposed Plan.
3.
4.
5.
-------
~ )
" ~
5.3
5.4
Page 10
Responsiveness Summary (con1'd.)
Letter from Martin C. Pentz. Nuner, McClennen & Fish (Attorney for Valley
~1anufacnJ.red Products Company. Inc. and Grove1and Resources Corporation)
[0 Robert J. Leger. EPA Region I (September 10. 1991). Concerning the
fol1owin£ anached COIT'mems 00 the jul... 1991 PrODOSed Plan:
A. "CoIT'.rnems on EPA ~1ana2emem 'of Mi2:"ation ProooseC Plan for the
Grove1and Wells Nos. 1 and 2 Site," Valley Manufactured Products
Company, Inc. and Grove1and Resources Corporation
(September 10, 1991).
B. "Comments on EPA Management of Migration Proposed Plan for the
Grove1and Wells Nos. 1 and 2 Site - Appendices: Volume 1 of 2," Valley
ManufactUred Products Company, Inc. and Grove1and Resources
Corporation (September 10, 1991).
C. "Comments on EPA Management of Migration Proposed Plan for the
Groveland Wells Nos. 1 and 2 Site - Appendices: Volume 2 of 2," Valley
Manufactured Products C()mpany, Inc. and Groveland Resources
Corporation (September 10. 1991).
Record of Decision (ROD)
7.
9.1
State Coordination
1.
"Record of Decision." EPA Region I (September 30, 1991).
9.0
Correspondence
1.
Cross-Reference: Comments Dated September 9, 1991 from Suzanne K.
Condon and William C. Srrohsnitter, Commonwealth of Massachusetts Office of
Health and Human Services on the July 1991 Proposed Plan [Filed and cited as
entry number 6 in 5.3 Responsiveness Summary]. .
Cross-Reference: Telephone ~otes Between Roben 1. Leger, EPA Region I and
Steve Roble. Commonwealth of Massachusetts Division of Fish and Wildlife
(September 17. 1991). Concerning the Commonwealth of Massachusetts
Division of Fish and Wildlife's position on how the remedy described in the
Proposed Plan will affect rare and endangered species [Filed and cited as entry
number ~ in 5.1 Correspondence].
.,
13.0 Community Relations
13.1 Correspondence
The list of addressees cited as an attachment to th£ record below is withheld as
- CONFlDE.\TJ.4L and is available onlyfor judicial review.
1.
Letter from Merrill S. Hohman, EPA Region I to the attached list of Addressees
(March 19. 1991), Concerning notification that their propeny overlies the
contaminant plume and that they are encouraged to participate in the selection of
-------
c
Page 11
13.3 News Clippings/Press Releases
~ews Clippings
,
1.
"EPA Srudy Done. Cleanup Can Begin." Daily ?\ews - ~ewburypor!. M-\
(.A.Drii4,1991}.
. "E:£>A: Well Cleanup Could Take Decade," The Haverhiii Gazette - Haverhill.
MA (Apri14, 1991).
"The United States Environmental ProteCtion Agency Invites Public Comment
on the Feasibility Study and Proposed Plan for the Grove1and Wells Nos. 1 and
2 Superfund Site in Grove1and, Massachusetts and Announces the Availability
of the Site Administrative R~ord;' The Haverhill Gazene - Haverhill, MA
(July 1, 1991).
"The U.S. Environmental Protection Agency Announces an Extension to the
Comment Period for the Proposed Cleanup Plan at Groveland Wells Nos. 1 and
2 Superfund Site," The Haverhill Gazette:- Haverhill, MA (August 15, 1991).
2.
3.
4.
Press Releases
5.
6.
"Environmental ~~ws - EPA To Begin Investigation At The Groveland Wells
Superfund Site," EPA Region I (November 22, 1989).
"Environmental ~ews - EPA To Discuss Results of Groundwater Investigation
for the Groveland Wells Nos. 1 & 2 Superfund Site at Upcoming Public
Meeting." EPA Region I (March 22, 1991). .
"Environmental ~ews - EPA Proposes Groundwater $8.6 Million Cleanup Plan
for the Groveland Wells 1'0s. 1 & 2 Superfund Site," EPA Region I
(J uly 2, 1991).
"Environmental ~ews - Additional Sampling Added to EPA Proposed Cleanup
at Groveland Wells ~os. 1 & 2 Superfund Site," EPA Region I (July 16. 1991).
7.
8.
13.4 Public Meetings
1.
"Management of Migration Remedial Investigation Public Meeting Summary -
Groveland Wells ~os. 1 and 2 - April 3. 1991."
Public Meeting Agenda. EP A Region I Public Meeting for the Groveland Wells
Nos. 1 and 2 Site (April 3. 1991). Concerning the Supplemental Management
of Migration Remedial Investigation.
EPA Region I Attendance List~ Supplemental Management of Migration
Remedial Investigation Public Meeting (April 3. 1991).
"Supplemental Management of Migration Feasibility Study/Proposed Plan Public
Meeting Summary - Groveland Wells Nos. 1 and 2 - July 9, 1991."
PUblic Meeting Agenda. EPA Region I Public Meeting for the Groveland Wells
Nos. 1 and 2 Site (July 9.1991). Concerning the Supplemental Management of
Migration Feasibility Study and Proposed Plan.
EP A Region I Attendance List, Supplemental Management of Migration
Feasibility Study and Proposed Plan Public Meeting (July 9, 1991).
Transcript, Public Hearing on the July 1991 Proposed Plan (July 31, 1991).
Public Meeting Agenda, Commonwealth of Massachusetts Office of Health and
Human Services Public Meeting for the Groveland Wells Nos. 1 and 2 Site
(September 16. 1991). Concerning the health assessment process and health
concerns associated with the site. The follov.ing are attachments:
A. "A Fact Sheet on the A TSDR Health Assessment Process,"
Commonwealth of MassachusettS Office of Health and Hunian Services.
B. "'The Health Assessment Process," Commonwealth of Massachusetts
Office of Health and Human Services.
2.
3.
4.
5.
6.
7.
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.)
Page 12
13.5 Fact Sheets
1.
"EPA Announces the ResultS of Remedial Investi2ation and Risk Assessment
StUdies:' EPA Region 1 (\-1 arc h 1991). -
16.0 ~.:.:;,.~:.:.: Reso,-"::::e Tn.lstee
16.1 Correspondence
1.
Cross-Reference: Comments Dated March 20, 1991 from Kenneth Finkelstein,
C.S. Department of Commerce !'iationa1 Ocean and Atmospheric Administration
on the February 1991 "Draft Supplemental Management of Migration Feasibility
Study Report," 1'o'1JS Corporation [Filed and cited as entry number 5 in 4.6
Feasibility Study (FS)].
Cross-Reference: Comments Dated April2, 1991 from Cyndi Perry, U.S.
Department of Labor Fish and Wildlife Service on the February 1991 "Draft
Supplemental Management of Migration Feasibility Study' Report." !\rus
Corporation [Filed and cited as entry number 6 in 4.6 Feasibility Study (FS)].
Cross-Reference: Response Dated September 17, 1991 from Richard
Cavagnero, EPA Region I on the March 20,1991 Comments from Kenneth
Finkelstein, U.S. Department of Commerce !\ational Ocean and Atmospheric
Administration [This letter is addressed to John Lindsay as a representative of
the C .S. Department of Commerce National Ocean and Atmospheric
Administration] [Filed and cited as entry number 10 in 4.6 Feasibility Study
(FS)].
Cross-Reference: Response Dated September 17, 1991 from Ricl1ard
. Cavagnero, EP A Region I on the April 2, 1991 and May 30, 1991 Comments
from Cyndi Perry. C.S. Department of Labor Fish and. Wildlife Service [Filed
and cited as entry number 11 in 4.6 Feasibility Study (FS)].
Cross-Reference: Telephone ~otes Between Robert J. Leger, EPA Region I and
Michael Amaral. C.S. Department of Labor Fish and Wildlife Service
(September 27, 1991). Concerning the two federally listed endangered species
and the effect the remed~: described in the Proposed Plan will have on them
[Filed and cited as entry number 6 in 5.1 Correspondence].
2.
3.
4.
5.
17.0 Site \lanagemem Records
17.2 Access Records
1.
Letter from James R. Forr.elli, ]\lJS Corporation to Robert 1. Leger, EPA
Region I (September 15, 1989). Concerning the attached "Properties Requiring
Access for Fieldwork."
The maps associat:!d '...:ith the record cited as entry number 2 are oversized and may b,'
rc\'icwed. by appoinrment only. at EPA Region I in Boston, Massachusetts.
.,
....
Memorandum from James R. Forrelli, I\'"US Corporation to Robert 1. Leger,
EPA Region I (September 21. 1989). Concerning transmittal of the attached
property maps.
Memorandum from James R. Forrelli, !\'US Corporation to Robert 1. Leger,
EPA Region I (September 27,1989). Concerning transmittal of the attached
draft list of property owners.
Letter from James R. Forrelli. ~LS Corporation to Robert 1. Leger, EPA
Region I (October 18. 1989). Concerning the attached memorandum identifying
specific properties where the monitoring wens will be drilled.
List of property owners and their addresses (October 18, 1989).
3.
~.
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(J
Page 13
17.2 Access Records (cont'd.)
6.
Letter from Merrill S. Hohman, EPA Region I to Bennv Budrewicz
(OctOber 18, 1989). Cor.cerning a request for properr~": access and the attached
Teiephone ~otes 3etween Benny Bu:::,ewicz and James R. Forrelli, }\l.:S
C0:-)(;~2:jOr: ~Dec~~~CT 14. 1";S9L
Lener from ~ferrill S. Hohman, EPA R.;;gion I to Franlc and Charlotte Parker
(October 18, 1989). Concerning a request for property access.
Letter from Robert 1. Leger, EP A Region I to James R. Forrelli, 1'.rus
Corporation (December 6, 1989). Concerning attached list of people who have
returned the "Consent for Access to Property."
Letter from Merrill S. Hohman, EPA Region I to Melita Hutchings
(December 19, 1989). Concerning a request for property access.
Letter from Merrill S. Hohman, EPA Region I to Richard Madison. Concerning
a request for property access and the attached "Consent for Access to Property"
signed December 20, 1989.
The record cited as entry number 11 is CONFIDE}.,TIAL and available onlyfor
judicial review.
,. .
8.
9.
10.
11.
Memorandum from Gregory M. Kennan, EPA Region I to File
(January 19, 1990). Concerning use of unilateral Administrative Orders for
access to residential property.
Telephone I'otes Between Mrs. WiJIiam Dennis and Becky Cleaver, 1'.1.]S
Corporation (Ju]y 2. 1990). Concerning sampling that was done on her -
property.
32 Registered Mail receipts.
12.
17.7 Reference Documents
13.
The record cited as entry number 1 may be reviewed. by appointment only. at EPA
Region I. BostOn. Massachusetts.
1.
"Technology Evaluation Report: SITE Program Demonstration of the 1;1trox
International Cltraviolet Radiation/Oxidation Technology," EPA Headquarters
(January 1990).
"Grovel and By-Laws Article 13, Section 1700, Aquifer Protection," Received
- from J'.,L;S Corporation September 5, 1990.
Letter from James R. Forrelli. N1;S Corporation to Robert 1. Leger. EPA
Region I (July 31, 1991). Concerning the attached groundwater extraction and
treatment system example.
2.
-------
,:
"
Section II
Guidance Documents
"",
-------
()
GlJIDA!,;CE DOC1:MENTS
EPA guidance documems may be reviewed at EPA Region 1, Boston. Massachusetts.
G{>neraJ F'P ~ Guidance Documents
2.
3.
4.
1.
"Protection of Wetlands (Executive Order 11990), Appendix D:' Federal Register
(VoL 42),1977.
U.S. Environmental Protection Agency. Guidance Manual for Minimizin~ Pollution from
Waste Disposal Sites (EPN600/2-78/142), August 1978.
"National Oil and Hazardous Substances Pollution Contingency Plan," Code of Federal
. Re~ulations (Title 40, Pan 3(0), 1985.
"National Oil and Hazardous Substances Pollution Contingency Plan," Federal Register
(Vol. 55, No. 46). \1arch 8. 1990.
5.
U.S. Environmental Protection Agency. Office of Emergency and Remedial Response.
Communitv Relations in Superfund: A Handbook (Interim Version) (EPA/HW-6).
September 1983. .
6.
U.S. Environmental Protection Agency. Office of Ground-Water Protection.
Ground-Water Prorection Strategv (EPN440/6-84/002), August 1984.
U.S. Environmental Protection Agency. Office of Solid Waste and Emergency Response.
Guidance on Remedial Investigations under CERCLA (Comprehensive Environmental
Response. Compensation. and Liability Act) (EPA/540/G-85/002), June 1985.
7.
8.
U.S. Environmental Protection Agency. Office of Solid Waste and Emergency Response.
Guidance on Feasibilitv Studies under CERCLA (Comprehensive Environmental Response.
Compensation. and Liability Act) (EPA/540/G-85/003), June 1985.
9.
U.S. Environmental Protection Agency. Office of Waste Programs Enforcement.
Endangem1ent Assessment Handbook. August 1985.
10.
Memorandum from J. Winston Poner. C.S. Environmental Protection Agency Office of
Solid Waste and Emergency Response to Addressees ("Regional Administrators, Regions
I-X; Directors, Environmental Services Division, Regions I-X; Regional Counsels, Regions
I-X, Director, Waste Management Division, Regions I, IV, V, VII, and VIII; Director,
Emergency and Remedial RespOnse Division, Region ll; Director, Hazardous Waste
Management Division, Region III; Director, Air and Waste Management Division.. Regions
n and VI; Director, Toxics and Waste Management Division, Region IX; Director.
Hazardous and Waste Division. Region X") (OSWER Directive 9850.0-1),
November 22. 1985 (discussing endangerment assessment guidance).
11.
U.S. Environmental Protection Agency and Michigan Department of Natural Resources.
Field Screening for Organic Contaminants in Samples from Hazardous Waste Sites.
April 2, 1986. .' .
12.
U.S. Environmental Protection Agency. Comprehensive Environmental Response.
Compensation. and Liabilit\. Act of 1980. as amended October 17. 1986.
U.S. Environmental Protection Agency. Office of Emergency and Remedial Response.
Superfund Public Health Evaluation Manual (EPN540/1-86/060. OS\VER Directive
9285.4-1 ). October 1986.
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o
"
v
1.3.
24.
.,-
-,).
26.
Page 15
14.
U.S. Environmental Protection Agency. Office of Emergency and Remedial Response.
Draft Guidance on Remedial Actions for Contaminated Groundwater at Superfund Sires
(OSWER Directive 9283.1-2), October 1986.
'':;
.1....-,
L".S. Environmental Protection A£enc\'. Office of Water ReE:ularions and Sta"dards.
~,~1it.. C...;'e";'. :('\.,. \\:",,,r '91
-------
'..
Page 16
27.
U.S. Environmental Protection Agency. Office of Emergency and Remedial Response.
Risk Assessment Guidance for Superfund - Volume I: Human Health Evaluation Manual
(Part A - Interim Final) (EPN540/l-89/002), December 1989.
28.
"~ational Oil and Hazardous Substa.nces Pollution Conrin5!enc'; Pian." Feder:l1 Re~i,te:-
V01 55. :\0. 46!. \.hrch 8. 1990. r 8666. - .
29.
U.S. Environmental Protection Agency. Office of Solid Waste and Emergency Response.
The Feasibili~ Study: Detailed Analysis of Remedial Action Alternatives (OSWER
Directive 9355.3-01FS4), March 1990.
30.
"A Field Evaluation of the UV/Oxidation Technology to Treat Contaminated Groundwater,"
HM!:, March/April 1990.
"Control Technology: A Field Demonstration of the UV/Oxidation Technology to Treat
- Groundwater Contaminated with VOCs," Journal of the Air & Waste Manaiement
Association (Vol. 40, No.4), April 1990, PI'. 540-47. "
-------
.'
RBGION
I
. ~GEKEHT OF XIGRATION RBCORD OF DBCISION SUMXARY
GROVELAND WELLS HOS. 1 , 2 SITE
-------
contents
II.
III.
IV.
VI.
VII.
VIII.
IX.
XI.
T
... .
V.
X.
GROVELAND WELLS NOS. 1 , 2 SITE
TABLE OF CONTENTS
.3I'l'E
NAME, ~CCAT:C~ 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
........
A.
B.
Groundwater. . . . . . . . . . . . . . . . . . .
Surface Water and Sediments. . . . . . . . . . .
SUMMARY OF SITE RISKS. . . . . .
. . . .
. . . . . .
A.
B.
Public Health Risk Assessment. . . . . . . . . . .
Ecological Risk Assessment. . . . . . . . . . . .
DEVELOPMENT AND SCREENING OF ALTERNATIVES
. . .
A.
B.
Statutory Requirements/Response Objectives
Technology and Alternative Development
and screeninq . . . . . . . . . . . . . .
. . . .
. . .
DESCRIPTION OF ALTERNATIVES. . . . .
........
SUMMARY OF THE COMPARATIVE ANALYSIS OF ALTERNATIVES.
THE SELECTED REMEDY. . . . . .
. . . . .
. . . . . .
A.
B.
Int9rim Groundwater Cleanup Levels. . . . . . .
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 Uses 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.
('
paae N'll!ilber
1
...
2
2
6
6
7
9
9
18
20
21
27
31
31
32
32
37
42
42
48
52
S2
53
S5
56
-------
\.,
XII.
XIII.
A
B
~
DOCUMENTATION OF SIGNIFICANT CHANGES
S9
. . . . .
STATE ROLE
S9
. . . . . .
..........
1.PPE~"'DICES
FIGURES AND TABLES
-------
MANAGEMENT OP MIGRATION RECORD OP DECISION SUMMARY
In this Management of Migration Record of Decision
("~anagemen.t-:= Migrati.oD ROD";, the United states
E:cviromnenta - :=:rotec-:ior: .;ger:::y ("EPA") presents a selected
=e~edial a=~:._:.~ for ~~a manage~~~t of ccnta~~na~~ mig=a~ion
at the Groveland Wells Nos. 1 & 2 Site (the "Groveland
Wells Site" or the "Site") located in Groveland,
Massachusetts. This remedial action was chosen in
accordance with the Comprehensive Environmental Response,
Compensation and Liability Act of 1980 ("CERCLA"), as
amended by the Superfund Amendments and Reauthorization Act
of 1986 ("SARA"), 42 V.S.C. SS 9601 et seq. This decision
is based on the administrative record for this Site.
I.
. SITE NAME, LOCATION AND DESCRIPTION.
The Groveland Wells Site is located mostly within the Town
of Groveland, Essex County, Massachusetts and encompasses
approximately 850 acres (Figure 1). The Site is bounded to
the, west by Washington Street and the former Haverhill
Municipal Landfill; to the south by Salem Street; to the
east by School Street; and to the north by the Merrimack
River. The Site is divided by Center Street and contains a
variety of private residences, industries, small businesses
and religious and community institutions. A large, active
sand and gravel operation is located in the central area of
the Site.
Johnson Creek flows north through the Site and discharges to
the Merrimack River at its northern edge (Figure 2). A
portion of Johnson Creek is dammed at the lower end of Mill
Pond. Argilla Brook flows northwest through the Site and
discharges to Johnson Creek. Brindle Brook is a small
tributary to Johnson Creek that flows northwestward through
the southeast corner of the site area, eventually joining
with Johnson Creek near Center Street. There are certain
limited wetland areas at the Site, located mostly next to
Mill Pond, Argilla Brook, Johnson Creek, Brindle Brook and
isolated areas east of Johnson Creek. A portion of the Site
lies within the lOO-year floodplain delineated by the
Federal Emergency Management Agency. Areas outside the
100-year floodplain but within the approximate limits of the
contaminant plume are shown in Figure 3.
One of the Town of Groveland's current municipal water
supply wells, Station No.1, and a former municipal supply
well, Station No.2, are located within the Site boundaries.
The Site encompasses the approximate limits of the
stratified drift aquifer that serves as the source of water
for the current and former municipal supply wells.
Groundwater generally flows to the north through the. Site
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'-
toward the Merrimack River. The overall groundwater flow
pattern is from higher elevations located to the south,
east, and west, toward the valley that forms much of the
site, then north following ~he trend of t~e valley toward
its outlet (Figures 4, 5 a~d 6).
Trichloroethene ("TCE"), a volatile organic compound
("VOC"), was first discovered in the Town of Groveland's
municipal supply wells in 1979 at a level of approximately
120 micrograms per liter ("ug/L"). (The current Safe
Drinking Water Act maximum contaminant level for TCE is
5 ug/L). The discovery of TCE in the groundwater supply
resulted in the closure of the wells, temporary water
rationing, and development of alternate water supplies.
.A new supply well, Station No.3, was installed near the
Merrimack River in the northern part of the Town to serve as
the main municipal supply well (Figure 1).
The Groveland Wells site was placed on the National
Priorities List ("NPL") in December 1982. The Haverhill
Municipal Landfill originally was part of the Groveland
Wells site. However, since that time it separately has been
listed on the NPL and is no longer part of the Groveland
Wells site. .
A more complete description of the site can be found in the
Supplemental Management of Migration Remedial Investigation
("Supplemental MOM RI") at pages 1-2 through i-8.
II.
SITE HISTORY AND ENFORCEMENT ACTIVITIES
This section of the Management of Migration ROD discusses
the site history and enforcement activities undertaken to
date. A more detailed description of the Site history can
be found in the supplemental MOM RI at pages 1-2 through
1-8.' .
A.
Land Use and Response History
1.
. Sources of contamination
The NFL listing resulted in the initiation of studies that
investigated the nature and extent of soil, surface water,
sediment and groundwater contamination, potential sources of
the contamination, and the pathways by which the aquifer
serving the municipal wells were contaminated. These
investigations resulted in identify~ng three likely sources
of contamination in the general ~rea of the site: the A.W.
Chesterton Company property, the Haverhill Municipal
Landfill and the Valley Manufactured Products Company
property.
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Because three different sources of contamination were
discovered, EPA made the decision to address each source
inc:viduallj based upon the type of contamination
discovered, whether the co~~~mina~ion could be dealt with
mere ef:ecti velyunder-~ ;. <~.::::'e==.:" enviromr.e!1tal statute ether
than CERCLA, and wh~ther ~~e nature of ~cn~ar::~atien at a
source warranted its listing as a separate CERCLA site. A
description of these three source areas and how they are
being addressed by EPA follows:
A. W. CHESTERTON COMPANY PROPERTY
The A. W. Chesterton Company is a manufacturer of mechanical
seals and industrial maintenance products, located in the
'south-central section of the site along Salem street (Figure
2). The 70-acre Chesterton property is located along
Brindle Brook, a tributary of Johnson Creek. An
investigation was performed on the Chesterton property in
1984 and 1985 in accordance with an Administrative order
issued pursuant to the Resource Conservation and Recovery
Act ("RCRA"), 42 U.S.C. ~~ 6901 et seq. The investigation
determined that the Chesterton property was contaminated,
that the source of the contamination was a subsurface
disposal system on the Chesterton property, and that soil
and groundwater contamination was confined to the property
boundary. EPA has decided that remediation of contamination
on the Chesterton property best can be dealt with using
corrective action and closure activities under RCRA.
Although RCRA will be used to address contamination at the
Chesterton property and remediation of contamination at that
property is not addressed in this Management of Migration
ROD, that property remains part of the Groveland Wells Site.
Before delisting the Groveland Wells site from the NPL, EPA
will ensure that contamination at the Chesterton property
has been properly addressed.
HAVERHILL MUNICIPAL LANDFILL
The Haverhill Municipal Landfill was originally named a
potential source of the contamination that led to the
closure of station Nos. 1 & 2. The Supplemental MOM RI
revealed that low level groundwater contamination in the
northwestern section of the Site immediately east of the
landfill,' driven by groundwater mounding beneath the
landfill, was migrating toward Johnson Creek. The
contamination did not form a definable plume, however,
because chemical detections were sporadic and at low levels.
Some portion of the contaminants in the groundwater at the
site may have originated from the Haverhill Municipal
Landfill. However, the limited nature and extent of
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~
contamination detected east of the landfill, in the
direction of the contaminant plume, suggests that the
land:ill is a minor source of the contaminants found in the
pl~~e.
Be~ause of the distinct nature of the conta~ination :ound
there, much of which appears to be unrelated to the VOC
contamination of the municipal supply wells, the Haverhill
Municipal Landfill was placed on the NPL in October 1984 as
a separate site from the Groveland Wells Site. As a result,
cleanup of the Haverhill Municipal Landfill is being
addressed as a separate CERCLA action~ The Haverhill
Municipal Landfill is no longer part of the Groveland Wells
Site, and remediation of contamination at the Haverhill
Municipal Landfill is not addressed in this Management of
. Migration ROD.
VALLEY MANUFACTURED PRODUCTS COMPANY PROPERTY
Valley Manufactured Products Company, Inc. ("Valley") is a
screw machine products manufacturer and finisher~ The
company is located near the southwest corner of the Site,
west of Johnson Creek and upstream of Mill Pond. Since
operations began at the property in May 1963, three
subsurface waste disposal systems have been installed and
used on the property for dispersal of liquid effluent into
the environment by filtration through sand and gravel
leachfields.
According to Valley employee accounts, as much as 3000
gallons of waste oil and solvent (including TCE) were
released on the Valley property during the period 1963 to
1974. Of this amount, five to seven hundred gallons of TCE
escaped from an underground storage tank. The balance of
the releases carne from spills or leaks into the subsurface
disposal systems and use of waste oil containing TCE as a
defoliant. Studies at the site have shown that TCE released
at the Valley property has migrated into the aquifer below
the ~roperty and has extended beyond the boundary of the
property to other areas of the Site.
To remediate contamination within the boundary of the Valley
property, EPA issued a first Record of Decision (the "Source
Control ROD") for the site in September, 1988. The Source
Control ROD required cleanup of the organic chemical
contamination source at the Valley property. That action
constitutes the Source Control Operable Unit at the
Groveland Wells site. The Source Control ROD approved an
innovative technology consisting of soil vapor vacuum
extraction to treat VOC-contaminated soil on the Valley
property. The ROD also approved the installation of a
groundwater recovery, treatment and reinjection system to
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~
I J
treat VOC-contaminated groundwater located directly under
the Val~ey property. Pursuant to an Amended Administrative
Order issued on February 1, 1991 under CERCLA S 106(a),
Valley/Grcvs:and Resources Corporation ("GR=") is presently
designing a full scale soil vapor vacuum ex~~action
tr~at~ent syste~ and a grou~dwater recovery, ~reatment ar.~
reinjection system for use on its property.
After issuing the Source Control ROD, EPA commissioned the
preparation of a Supplemental Management of Migration
Remedial Investigation and Feasibility Study ("Supplemental
MOM RIfFS")~ This study, together with earlier studies, was
aimed at determining the nature and extent of the sources of
.contamination off the Valley property. Based upon the
findings of the Supplemental MOM RIfFS, as well as earlier
- studies, EPA is issuing this Management of Migration ROD.
Remedial action required by the Management of Migration ROD
supplements, not replaces or supplants, the remedial action
required by the Source Control ROD. The Management of
Migration ROD outlines actions necessary to remediate
contaminated groundwater that extends from the Valley
property throughout the rest of the site. .
2.
other Actions at the site
In addition to the remedial action initiated at the Valley
property pursuant to the Source Control ROD, the following
additional actions have been undertaken at the site:
MILL POND GROUNDWATER EXTRACTION AND TREATMENT SYSTEM
Beyond the work required as part of the Source Control
Operable Unit at the Site, the Commonwealth of Massachusetts
has required ValleyfGRC to construct and operate a
groundwater extraction and air stripping treatment system to
intercept and treat the VOC plume at Mill Pond. The system
is currently in place and operating at the north end of Mill
Pond. It consists of two extraction wells, G-1 and G-2, .
pumping at an aggregate rate of about 80 gpm currently, and
an air stripping unit used for removal of VOCs from the
pumped water. Pumped water is discharged under an existing
National Pollutant Discharge Elimination System ("NPDES")
permit ~fter treatment to Johnson Creek, immediately
downstream of Mill Pond. Discharge monitoring reports for
the period April 1988 through November 1989 shows that the
average monthly flow treated and discharged by the system
has varied from 31 gpm to 75 gpm. This system has been
operating since April 1988.
The Mill Pond groundwater extraction wells may be included
within the broader remedy selected in this Management of
Migration ROD. The air stripping treatment system, however,
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will be discontinued once the treatment system selected in
this Management of Migration ROD becomes operational.
STATION NO. ~ WELLHEAD TREATMENT
By Action Memorandum dated July 25, 1985, E?A approved an
Initial Remedial Measure ("IRM") to provide an alternate
water supply by rehabilitating station No.1 with granular
activated carbon treatment to remove VOCs from the
groundwater at station No.1. The need for the IRM was
based on an EPA evaluation of water supply/demand and an
aquifer-wide study. In 1987, EPA completed the installation
of the treatment system. The well operates at a pumping
rate of 400 gpm and is used as a supplemental supply to
- station No.3. Station No.1 continues to ensure a safe and
adequate supply of potable water for. the Town .of Groveland.
The station currently supplies about half the Town's
drinking water while the new well, Station No.3, provides
the remainder. .
EPAhas taken into account that the wellhead treatment
system at station No.1 is in place. That treatment system,
however, is not incorporated into or made part of the remedy
selected in this Management of Migration ROD.
B.
Enforcement History
certain enforcement activities undertaken at the site are
described above. In addition, on May 21, 1991, EPA notified
five (5) parties who owned or operated, or now own or
operate, portions of the Site of their potential liability
with respect to the cleanup of contamination at the Site.
EPA may commence negotiations with the potentially
responsible parties ("PRPs") after issuance of this
Management of Migration ROD.
...
..
The PRPs have been active in the remedy selection process
for this site. Comments presented by PRPs during the public
comment period, and EPA's response thereto, are included in
the Administrative Record,
III. COMMUNITY PARTICIPATION
Throughout the site's history, community concern and
involvement has been high. EPA has kept the community and
other interested parties informed of the Site activities
through informational meetings, fact sheets, press releases
and public meetings. .
During September, 1983, EPA released a community relations
plan that outlined a program to address community concerns
and keep citizens informed about and involved in activities
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at the site. This original plan has been updated as
necessary for all subsequent response activities. On July
2~, 1989, EPA held an info~mational meeting in the Town of
G~=,~~a,d.to de~cri~e the p~ans.~~r.the su~plernental .
re~ea:~- lnves~:gatlc~ a~d zeaslc:llty stuay. Cn Aprll 3,
1991, EPA held an informational meeting in the Town of
Groveland to discuss the results of the supplemental MOM RI.
On July 1, 1991, EPA published in the Haverhill Gazette a
notice and brief analysis of the Proposed Plan for
remediating groundwater contamination through the remedy
selected in this Management of Migration ROD, and made the
plan available to the public at the Langley-Adams Library.
On July 9, 1991, EPA held an informational meeting to
discuss the results of the supplemental MOM RI, to outline
the cleanup alternatives detailed in the Supplemental MOM
FS, and to present the Agency's proposed Plan. Also during
this meeting, the Agency answered questions from the public.
On July 10, 1991, EPA made the site administrative record
available for public review at EPA's Record Center at
90 Canal street in Boston, Massachusetts.and at the Langley-
Adams Library in Groveland, Massachusetts. .
From July 10 to August 8, 1991, the Agency held a 30-day
public comment period to accept public comment on the
alternatives presented in the Supplemental MOM FS . and the
Proposed Plan and on any other documents previously released
to the public. During the comment period, EPA received two
(2) requests to extend the public comment period an
additional thirty (30) days. Therefore, EPA extended the
public comment period to September 9, 1991. On July 31,
1991, the Agency held informal public hearing to accept any
oral comments on the Proposed Plan.
A transcript of the public hearing, a summary of other
comments received by EPA, and the Agency's response to the
oral and written comments received concerning the Proposed
Plan are included in the attached responsiveness summary.
IV.
SCOPE AND ROLE OF OPERABLE UNIT OR RESPONSE ACTION
This Management of Migration ROD establishes a Management of
Migration Operable Unit, which, along with the Source
control operable Unit established in the Source Control ROD,
addresses all Site-related contamination, except that found
at the Chesterton property, which is being addressed under
RCRA.
Through the various investigations completed at the Site,
EPA has sought to determine the nature and extent of surface
-------
water, sediment, soil, and groundwater contamination at the
Site, and to identify alternatives for remediating the
contamination that was discovered.
Most importantly, those investigations revealed that a large
groundwater contaminan~ plume of trichloroethene TCE and
1,2- dichloroethene ("1,2-DCE") extends from the Valley
property (Figure 7). The approximate detectable area of the
plume extends approximately 3,900 feet from the Valley
property northward, along the path of Johnson Creek through
the Mill Pond area, downgradient past Station No.2. The
plume width ranges from approximately 350 feet across in the
Valley/Mill Pond area to roughly 1,000 feet wide where it
encompasses Station No.2.
Sediment and surface water contamination at the Site is low
level and sporadic. No remediation of VOCcontamination in
surface water is planned because contaminant levels are
below available Ambient Water Quality criteria ("AWQC").
Similarly, no remediation of VOC contamination in sediment
is planned because EPA believes they present minimal risk to
human health and the environment. Metals concentrations
detected in surface water occasionally exceed AWQC, but no
remediation of those metals is planned because EPA does not
believe they are site-related. Inorganic contamination
detected in sediment also are not being remediated because
the contaminants do not present a risk to human health or
the environment.
The response action outlined in this Management of Migration
ROD is the Management of Migration Operable Unit. That
operable unit includes all areas within the Site, except the
Valley and Chesterton properties, where chemical specific
applicable or relevant and appropriate requirements
("ARARs") are exceeded or cleanup levels are not being met
in the groundwater. Because no remediation of sediment and
surface water contamination is planned, the purpose of the
Management of Migration Operable Unit is to restore the
groundwater within the Site to ensure that both ARARs and
cleanup levels established in this ROD are met.
The remedial action comprising the Management of Migration
Operable Unit outlined in this Management of Migration ROD
supplements, not replaces or supplants, the remedial action
comprising the Valley property Source Control Operable Unit
outlined in the Source Control ROD. In addition, remedial
action to address contamination at the Chesterton property
is not part of the Management of Migration Operable Unit
because that contamination is being addressed using
corrective action and closure activities under RCRA
authority.
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This remedial action will address the principal future
th~e=t to human health posed by the groundwater, namely, the
possible ingestion, inha:ation and dermal absorption by
~~~a~s :rc~ mult~ple use~.of t~e contaminated,grou~dwa~er.
~he respcn3e ac~~cn prov~Qes for ~~e res~cra~~c~ 0:
groundwater to meet both ARARs and cleanup standards
identified in this ROD.
v.
SUMMARY OF SITE CHARACTERISTICS
A.
Groundwater
The principal contaminants detected in groundwater at the
.Site are the VOCs and metals. Chlorinated hydrocarbons such
as TCE and 1,2-DCE are the VOCs most frequently detected in
the groundwater samples collected. Metals frequently
detected in groundwater samples collected include arsenic,
barium, chromium, lead and nickel.
A large VOC plume extends from the Valley property
throughout the Site. This plume has been further defined
with regard to its present position about station Nos. 1 and
2 and, in terms of contamination distribution in the
overburden and bedrock formations of the Site, through the
sampling conducted in the Supplemental MOM RI.
The Site can be divided into four areas based on the
distribution of contaminants in groundwater (Figure 9).
Although no longer regarded as part of the Site, for
purposes of this discussion the Haverhill Municipal Landfill
is addressed because it is part of one of the four areas
discussed in the Supplemental MOM RI. The four areas
impacted by the contamination consist of the three source
areas (the Chesterton property, the Haverhill Municipal
Landfill, and the Valley property) with adjoining
downgradient districts, and a fourth area encompassing the
capture zone of Station No.1, the drinking water supply
well-that is the major receptor at the Site. The boundaries
of these areas are based on the general patterns of
contamination at the Site. It should be noted that the
boundaries are approximate and may even overlap
occasionally. The four areas are as follows:
Area A, The Chesterton Area, includes the Chesterton
property and immediate downgradient area, which is
located to the southeast and upgradient of the Valley
property.
Area B, The Valley/Mill Pond Area, which is located
downgradient of the Valley property, north of Area A,
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'"
and south of the "unnamed brook" flowing easterly and
entering Johnson Creek north of Mill Pond.
Area C, The Area North of Mill Pond, which is located
north of the "unnamed brook. II Area C abuts Area B to
the south and Johnson Creek to the west. For purposes
of this discussion, Area C also is referred to as the
. Station No.1 area.
Area D, The Haverhill Municipal Landfill Area, which
includes the area between the landfill and Johnson
Creek.
Contaminant concentrations differ significantly in each of
these areas. The following sections describe contaminant
occurrence and distribution in each area.
Area A-A. W. Chesterton Company
Table 1 summarizes the groundwater monitoring results for.
Area A, the Chesterton Area. The area encompasses the plant
buildings and property and the immediate area next to the
downgradient property boundaries to the north and northwest.
Only first-round monitoring results are presented, because
no second-round groundwater samples were collected in
Area A. Three shallow overburden monitoring wells (84-3,
83-3, and 83-4) and two shallow bedrock wells (84-8 and 84-
10) are located in Area A. Well 84-3 is located in the
upgradient area of the Chesterton property (Figure 9).
VOCs were not detected in the shallow overburden wells,
including the upgradient well. However, five VOCs were
detected in the shallow bedrock well, 84-8. Although TCE
and 1,2-DCE were frequently detected at significantly higher
concentrations (i.e., greater than 1,000 ugjL) in other Site
monitoring wells, the tetrachloroethene ("PCE"), 1,1,1-
trichloroethane ("l,l,l-TCA"), and l,l-dichloroethane
(ll,l-DCA") concentrations reported in well 84-8 were higher
than those reported in any other first-round monitoring
well. However, the PCE concentration detected in the
second-round groundwater sample from well ERT-lO (Area D)
was 77 ugjL. PCE has been detected at its highest.
concentratiQn (C~x=1,600 ugjL) in wells associated with the
Chesterton property. Based on monitoring at the Site, a
plume of l,l,l-TCA-, l,l-DCA-, l,l-DCE-, PCE-, and TCE-
contaminated groundwater has been identified at the
Chesterton property. The Chesterton property is upstream
of the Valley property. Groundwater quality beneath each
property is .not influenced by activities taking place at the
other property.
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,;
The concentrations of arsenic, chromium, lead, and nickel
detected in groundwater samples collected from well 84-8, a
downgradient well on the Chesterton property, exceed current
or -;:::-oposed Federal Safe Drinking Water Act ("SDWA") prirnary
(hea: th-based) Maxi::1'..l;;'l conta:::inant. Levels ("MCLs").
concentrations of chromium, lead, aluminu::: and iron in
background monitoring well ERT-12A and upgradient well 84-3
also exceed or approach MCLs for these contaminants.
The source
Chesterton
Chesterton
limited to
of the groundwater contamination at the
Area is a subsurface disposal system on the
property. That contamination, however, is
the Chesterton property boundary.
- Area B - The Valley /Mill Pond Area
Tables 2, 3 and 4 summarize the groundwater monitoring
results for Area B, the Valley/Mill Pond Area. The area
includes Mill Pond and extends from approximately the Valley
property south of the pond to the unnamed brook that enters
Johnson Creek north of Mill Pond.
The Area B western and eastern boundaries extend roughly to
include the area just west of washington Street and the
western section of the sand and gravel surface mine.
Numerous monitoring wells were installed in this area to
define the groundwater contamination plume extending from
the Valley property. Based on the strata in which the well
screens were installed, and the contaminant concentrations
detected in the groundwater samples, the following subareas
were identified:
B-1 - Shallow overburden downgradient of the Valley
property (VOC concentrations >1,000 ug/L)
B-2 - Shallow overburden in the Mill Pond Area beyond
Subarea B-1 (VOC concentrations <100 ug/L)
B-3 - Deep overburden/shallow bedrock adjacent to Johnson
Creek (VOC concentrations >100 ug/L)
B-4 - Deep overburden/shaliow bedrock not adjacent to
-Johnson Creek (VOC concentrations <10 ug/L)
B-5 - Deep bedrock (VOC concentration = 1 ug/L)
As shown on Figure 8, the contaminant plume exhibits a
sinking pattern through the overburden and into shallow
bedrock. Deep overburden/shallow bedrock wells in the
center of the plume are grouped together as these are highly
contaminated intervals, although the well elevations
monitored differ significantly.
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~
According to first-round results, VOC concentrations
detected in the two shallow overburden wells located
downgradient of the Valley property (Subarea B-1) exceed
5.000 ug/L. However, only two VOCs, 1,2-DCE and TCE, were
reported in wells GZ-2 and DEQE-8. TCE was detected at a
maxirn~~ concentration of 11,000 ug/L in well GZ-2. VOCs
were not detected at concentrations in excess of 100 ug/L in
other shallow, downgradient"overburden wells, including
those located in the Mill Pond/Johnson Creek Area, but
beyond the immediate Valley property (i.e., Subarea B-2).
As discussed in the following paragraphs, the center of the
VOC contaminant plume migrates steeply downward to the deep
overburden/sh~llow bedrock strata in the Valley/Mill Pond
Area.
Maximum VOC concentrations at the Groveland site were
detected in groundwater samples from monitoring wells
screened/installed in the deep overburden/shallow bedrock
strata of Area B near the Valley property and the Mill
Pond/Johnson Creek Area (Subarea B-3). Total VOC
concentrations ranged between 100 ug/L and 50,000 ug/L
(monitoring well TW-25). Seven VOCs were detected in the
groundwater including: 1,1-dichloroethene, 1,1-
dichloroethane, trichloroethene, benzene~ tetrach,loroethene,
toluene and xylene.
Second-round monitoring data (Table 4) corr~spondwith the
first-round data. However, total VOC concentrations
reported for deep overburden/shallow bedrock monitoring
wells located in Area B, but beyond the immediate Mill
Pond/Johnson Creek surface water bodies (Subarea B-4), are
generally less than 10 ug/L. Only the TCE concentration
detected in monitoring well ERT-16 (first-round result,
C=6 ug/L) exceeds a current primary MCL.
~
Except for the detection of 1 ug/L xylene (first-round
result), VOCs were not detected in deep bedrock well 107,
which is located along Johnson Creek downgradient of the
Mill Pond (Subarea B-5). However, no other deep bedrock
wells are located in Area'B. '
The Supplemental MOM RI results confirm previous monitoring
results for the Groveland Wells Site. All results suggest
that a VOC groundwater contaminant plume 'extends from the
Valley property. The TCE groundwater contaminant plume is
displayed on Figures 7 and 8. As depicted on these figures,
the center of the contaminant plume migrates steeply
downward from the shallow overburden to the deep
overburden/shallow bedrock strata. The plume is narrow and
most of the contamination is found in wells located near'
Johnson Creek and Mill Pond. Generally, contaminant
concentrations decrease with increasing distance from the
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c>
Valley property (i.e., toward the Merrimack River). The
pattern of contamination noted in Area B is consistent with
c~r c~~~ent knowledge of the hydrogeologic conditions at the
;~ove~~~d We:ls Site (discussed in Section I).
:~:a fo~lowing incrganics were detected in =ne or more Area B
monitoring wells at concentrations exceeding current or
proposed primary MCLs:
Arsenic - C~~ = 281
Beryllium - C~~ = 7.5
Chromium - C~~ = 124
Lead - C~~= 113
Nickel - C~~= 240
ug/L
ug/L
ug/L
ug/L
ug/L
As discussed previously, chromium and lead concentrations
detected in background monitoring well ERT-12A also approach
or exceed MCLs. In contrast to the VOC contamination noted,
inorganics concentrations in excess of current primary MCLs
were not detected in monitoring wells located in the deep
overburden/shallow bedrock strata near the Mill Pond/Johnson
Creek Area.
Area C - The station No.1 Area
Tables 5, 6 and 7 summarize the groundwater monitoring
results for Area C. The Station No.1 Area is north of Mill
Pond and roughly encompasses the current 'capture area of
Station No.1. It extends to Area D in the west, to Area B
in the south, and just beyond the Massachusetts Electric
Company right-of-way, (former railroad right-of-way) to the
north and east. The area is bounded to the south by an
unnamed brook flowing easterly and entering Johnson Creek
north of Mill Pond and to the north by the Merrimack River.
The area includes monitoring wells along Argilla Brook but
not those associated with the Haverhill Municipal Landfill.
with one exception, VOC concentrations in Area C monitoring
wells do not exceed 100 ug/L. The total VOC concentration
reported for the second-round groundwater sample collected
from monitoring well 106 was 178 ug/L. Six VOCs were
detected in the monitoring wells located in the shallow/deep
overburden near Johnson Creek including:' 1,2-dichloroethene,
trichloroethene, toluene, ethylbenzene, tetrachloroethene,
and xylene. However, only TCE, PCE, and 1,2-DCE were
detected at concentrations in excess of current/proposed
primary MCLs.
The maximum concentrations of TCE and 1,2-DCE were found in
monitoring wells 106 and 117, respectively. In contrast to
first-round results, VOCs were detected in all second-round
samples from the monitoring well cluster located below the
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~
confluence of the unnamed brook and Johnson Creek
(103/104/105/117).
Total VOC conce~trations in Area C monitoring wells beyond
the immediate vicinity of Johnson Creek generally do not
exceed 10 ug/L. Four VOCs were detected in first-round
groundwater samples collected (1,1,1-TCA; 1,2-0CA; 1,2-0CE;
and TCE). VOCs, TCE and 1,2-0CE, were also detected in two
of three second-round monitoring wells sampled (wells 114,
112). However, TCE was the only VOC detected in a
monitoring well at a concentration higher than the current
primary MCL. TCE (first-round result .C~x=9 ug/L) was
detected in monitoring well 114, which 1S located
approximately midway between Johnson Creek and Argilla
Brook. Monitoring well 114 was installed to determine the
location of a groundwater divide between the drainage areas
of Argilla Brook and Johnson Creek. Except for well 112,
the monitoring wells installed in the deep overburden near
Station No.1 (wells 111, 110, 112) do ~ot show VOC
contamination. The maximum TCE concentration detected in
well 112 was 2 ug/L. VOC contamination was not detected in
the deep overburden well 113 or shallow bedrock well 109.
These wells are located beyond the vicinity of Station
No.1. TCE was detected in monitoring well 115 at 2 ug/L.
These wells were installed to define hydrological conditions
during the pump test, check for additionai sources of VOC
contamination near Station No.1, and characterize the VOC
contamination (if present) in the deep overburden and/or
shallow bedrock near Station No.1 and the area between
Johnson Creek and Station No.1.
The results of the Supplemental MOM RI suggest that the VOC
plume in Area C extends to the east of well 114 and to the
north of ERT-21. Hydrogeologic conditions at the Site
suggest these wells are within the plume associated with the
Valley /Mill Pond Area.
The following metals were detected in groundwater samples
collected from one or more Area C monitoring wells at
concentrations exceeding current or proposed primary MCLs:
Arsenic - C~x =
Barium - C~x =
Beryllium - C~x =
Cadmium - C~X =
Chromium - C~X =
Lead - C~X=
Nickel - C~X =
79.6 ug/L (MW-111)
1,100 ug/L (MW-111)
12 ug/L (MW-105)
57.3 ug/L (ERT-21)
1,230 ug/L (MW-111)
364 ug/L (MW-105)
876 ug/L (MW-105)
The pattern of the inorganic contamination in Area C wells
was similar to that of Area B. Inorganics concentrations in
excess of current primary MCLs were not detected in
-------
monitoring wells located in the deep overburden/shallow
bedrock wells.
Area D - The ~~ver~ill Landfill
The r9s~l~s of the sa~~:~~; and a~2:ysis of ~=c~njwater
samples collected from wells associated witn ~he Haverhill
Landfill are presented in Tables 8 and 9. The Haverhill
Municipal Landfill Area includes the area between the
eastern fringe of the landfill to Johnson Creek on the east.
The southern part of Area D abuts Area B at the unnamed
brook that e~pties into Johnson Creek, while the northern
boundary is the Massachusetts Electric Company right-of-way
(former railroad right-of-way). The following wells are
located in the deep overburden downgradient of the Landfill:
-B-1, ERT-4, ERT-20, ERT-19, and 116.
VOCs were detected above sample quantitation limits in two
of the five Area D wells. B-1 was the ~ost heavily
contaminated monitoring well. In contrast to other
monitoring wells sampled at the Groveland Wells Site, the
aromatic hydrocarbons were the principal contaminants
detected in B-1:
Benzene - C~X =
Toluene - C~X =
Chlorobenzene - C~X =
Ethylbenzene - C~X =
Total Xylenes - C~X =
l7.ug/L
5 ug/L
20 ug/L
18 ug/L
86 ug/L
It should be noted that the aromatic hydrocarbons were not
detected in the three landfill monitoring wells sampled
during the second round (ERT-4, ERT-19, 116).
Benzene, a Class A carcinogen, was the only aromatic
hydrocarbon detected at a concentration in excess of a
current MCL. Several inorganics were detected in one or
more groundwater samples at concentrations exceeding
current/proposed standards.
TCE was detected in one second-round monitoring well at a
coricentration exceeding the current standard. The iron.
concentration (C=20,700 ug/L) was also elevated in the
monitoring well sample containing the maximum arsenic
concentration.
Mill Pond Extraction System
Monthly samp;ing data of the Mill Pond extractiori and
treatment system (performed by Valley) from April 1988 to
September 1990 reflect the contaminant movement and
distribution over time as well as the impact of the
-------
J
extraction system. These results are summarized in the
following discussion.
The Mill Pond system monitoring records for this 2-1/2 year
period report TCE and 1,Z-DCE concentrations in the air
stripper influent (extraction wells G-1 and G-2) and the
effluent, as well as five lateral monitoring wells near the
extraction system (DEQE 1-3, DEQE 1-4, DEQE 5, DEQE 6, and
DEQE 9).
Of the two extraction wells, yearly average TCE
concentrations in G-1 have dropped significantly since the
system startup in 1988 (from 1160 ug/L to 210 ug/L).
Average, 1,2-DCE concentrations have decreased somewhat from
- the 2890 ug/L observed in the first year of operation but
remained consistently high at 1750 ug/L during the last 9
months of operation. However, in G-2, TCE and 1,Z-DCE
concentrations have remained at fairly constant levels
throughout the 30 months, at approximately 1300 ug/L and
600 ug/L, respectively.
TCE levels in the treatment system effluent have remained
for the most part under the 100 ug/L discharge limi~ation,
while DCE levels have remained somewhat above 100 ug/L.
There is no discharge limitation for DCE.
TCE levels have decreased substantially in deep overburden
wells DEQE 1-3, DEQE 5, and DEQE 6. Both DEQE 1-3 and DEQE
6 are downgradient wells, while DEQE 5 is positioned just
east of the extraction wells. Levels in well DEQE 1-4, a
shallow bedrock well, remain consistently high. DEQE 9 is a
shallow overburden well that yields low levels of TCE
throughout the sampling period.
Over the 2-1/2 year period, levels of 1,2-DCE have decreased
in DEQE 1-4, DEQE 5, and DEQE 6, while remaining consistent
in wells DEQE 1-3, and DEQE 9.
It should be noted that the averages of reported TCE and
1,2-DCE concentrations in, these wells for the first 9 months
of 1990 range from 300 to 9800 ug/L, and from 89 to 1830
ug/L, respectively, excluding DEQE 9, which has exhibited
~ow concentrations consistently.
Results of the Mill Pond extraction system monitoring
reflect the general contamination distribution pattern
revealed in Supplemental MOM RI results for the Valley/Mill
Pond Area. That is, the highest contaminant levels are
found in the deep overburden/shallow bedrock, with lower but
significant contaminant levels observed in deeper bedrock.
Generally, low levels of contamination have been found in
the shallow overburden. During the 30 months of operation,
-------
,-
a downward trend is observed in the TCE levels in the
overburden wells monitored. The bedrock well TCE levels are
not affected significantly by the extraction system
c~erat~on. A:though the ext~~=tion wells are situated in
deep overburden di~ectly in ~he plume a~ea, the most
concen~~ated par~ of the pl~~e appears tc be traveli~g in
shallow bedrock under the extraction system's capture zone.
It should be noted that a downward trend in TCE
concentrations is reported for NUS-5, a shallow bedrock well
located 150 feet east of G-1 and clearly beyond the capture
zone of the Mill Pond extraction system. The downward trend
in TCE concentrations in monitoring well NUS-5 may be
attributable to contaminant source depletion and renovation
of the aquifer (dilution, contaminant biodegradation). TCE
.levels have steadily decreased in this well since July 1987
from an average of 1950 ug/L to 450 ug/L in July 1990.
Summary of Groundwater Ouality
Based on two rounds of groundwater monitoring, the principal
contaminants in the groundwater are the volatile organic
compounds. Chlorinated hydrocarbons, such as TCE and
1,2-DCE, were the VOCs most frequently identified in the
groundwater. The observed contamination. is not uniform
across the Site. A VOC contaminant plume extends from the
Valley property. The plume is oriented north-south, with
the long axis parallel to Johnson Creek. The center of the
VOC contaminant plume migrates steeply downward to the deep
overburden/shallow bedrock strata in the Valley/Mill Pond
Area. TCE and 1,2-DCE contamination as high as 50,000 ug/L
and .2,000 ug/L, respectively, were detected near the Valley
property. Generally, VOC concentrations in the groundwater
beyond the immediate vicinity of the Valley property and
Mill Pond are lower than 100 ug/L. .
Low-level «100 ug/L) VOC concentrations were detected in
one monitoring well located downgradient of the Chesterton
facility. TCE (6 ug/L) and PCE (21 ug/L) concentrations
reported for the first-round monitoring samples exceeded,
current MCLs. The groundwater contamination associated with
the Chesterton property appears to be separate and distinct
from that observed downgradient of the Valley property.
Several aromatic hydrocarbons (e.g., benzene), 1,2-DCE, and
TCE were detected in at least one monitoring well located
downgradient of the Haverhill Municipal Landfill. However,
benzene and TCE were the only orga~ics detected at
concentrations exceeding a current MCL. In contrast to
contaminant concentrations reported for the Valley/Mill Pond
Area, the VOC contamination observed in wells downgradient
of the Haverhill Landfill may be described as low-level
(generally <100 ug/L) and sporadic.
-------
<;)
',)
Several inorganics were detected in the groundwater at
concentrations exceeding current primary MCLs.
Concentration of chromium, lead, aluminum, and iron in
background and upgradien~ moni~oring wells also exceed or
approach MCLs. In co~trast to the VOC contamina~ion noted
in the deep overburden/shallow bedrock ~ells, inorganics
concentrations in excess of current primary MCLs were not
detected in monitoring wells located in those wells.
The landfill cannot be discounted as a source of inorganic
and VOC contamination in Areas C and D. Several inorganics
were detected in groundwater samples at concentrations
exceeding current/proposed standards. However, the
available data indicates that the landfill is a minor VOC
contaminant source. As noted above, the landfill has been
listed as a separate CERCLA site, and remediation of
contamination at the landfill will be accomplished through a
separate CERCLA response action. '
Organic and inorganic contaminants detected at
concentrations greater than MCLs are shown in Figures 10 and
11, respectively.
B.
Surface Water and Sed~ments
This section summarizes the results of the sampling and
analysis of surface water and sediments collected from
lS locations along Johnson Creek, Brindle'Brook, and Argilla
Brook. These streams, Mill Pond and the gravel operation
(impoundment near Trimount) are the surface water bodies
potentially affected by contaminants migrating from the
three potential contaminant source areas at the Groveland
Wells Site. Selected results of the sampling and analysis
of surface waters/sediments are displayed ,on Figures 12, 13
and 14.
..
,Fifteen (15) surface water (SW) and 14 sediment (SD) samples
were collected during the first-round. Eight surface water
and eight sediment samples were collected during the second
round of sampling. The results of the surface water and
sediment monitoring conducted at the Groveland site are
summarized in Tables 10 and 11.
VOCs were detected in surface water samples collected at
eight sampling locations along Johnson Creek. VOCs were not
detected in background surface water samples (9, 11) or at
sampling locations along Brindle Brook or Argilla Brook.
The highest total VOC concentrations were detected at the
Mill Pond outlet (total VOCs = 54.6 ug/L) and at the
treatment system discharge below Mill Pond (total
VOCs=150 ug/L). Total VOC concentrations detected at other
-------
sampling locations were generally less than 10 ug/L.
was the most frequently detected VOC.
TCE
The fo:lowing table cOllipares maximum VOC concentrations in
the s~=face water sa~ples to ava::able ~~~bient Wa~er Quality
C::-iter].a (".<:..WQCiI):
No of
Positive(1) AWOC (Freshwater)
Detect./
No. of Range(1) Chronic Acute
Chemical SamDles (ua/L) (ua/L) ( ua I L)
Methylene chloride 1/15 44 NA 11,000(2)
1,2-dichloroethene 3/15 0.5-96 NA NA
Chloroform 1/15 3 1,240. 28,900
1,2-dichloroethane 1/15 0.6 20,000 118,000
1,1,1-trichloroethane 2/15 0.7-1 9,400(3) 18,000
Trichloroethene 9/15 0.7-56 21,900 45,000
Benzene 1/15 0.6 NA 5,300
Toluene 1/15 10 NA 17,500
(1 )
(2)
(3)
NA
First-round monitoring data presented.
Halomethanes in general. .
Chronic value for 1, 1, l-trichloroethane.
Not available.
A review of available AWQC for the protection of aquatic
life indicates that organics concentrations detected in the
surface water samples are below available AWQC.
Metals concentrations detected in the surface waters of the
lower Johnson Creek watershed occasionally exceed AWQC or
AWQC lowest-observed-effect levels ("LOEL") for the
protection of aquatic life in surface water. Table 22
compares the metals concentrations detected to background
concentrations and available standards/criteria.
Volatile organic compounds (MC, acetone, PCE) were detected
in first-round sediment samples from one location on Brindle
Brook (downstream of the Chesterton Facility), three
locations along Johnson Creek (downstream of Valley), and
two locations along Argilla Brook.. In contrast to surface
water results, TCE and 1,2-DCE were not detected in first-
round sediment samples. PCE, a contaminant associated with
the Chesterton Facility, was detected in one first-round
sample downstream of Chesterton at 5 ug/kg. Acetone was
detected (C=19-140 ug/kg) at. three locations on Johnson
Creek downstream of the Valley property and at two locations
on Argilla Brook.
-------
,.
.~
1,2-DCE was detected in one second-round sediment sample
(SD-05) located downstream of Mill Pond. MC, acetone, and
PCE were not detected in second-round samples. Total VOC
c=ncerotrations were highest in sediments collected at the
M:ll Porod inlet (C=l~O ugjkg) and the Argilla Brook
(C~~=94 ug/kg) sa~pling locations. In general, the VOC
contamination in the sedimen~s may be described as low-level
(total VOCs less than 150 ugjkg) and sporadic.
Polynuclear aromatic hydrocarbons ("PAH") and phthalate
esters were the principal semivolatile organics detected in
sediments from the lower Johnson Creek watershed. . Except
for sample location SD-4, PAH and phthalate ester
.concentrations are higher in the background samples than
actual site location samples. Because SD-4 is just below
- the location where Main Street crosses Johnson Creek, run-
off from the road may be affecting sample location SD-4.
PAHs are produced by the combustion process and,
consequently, are frequently found along roadways traversed
by motor vehicles.
A review of the data presented in Table 11 indicates that
the inorganic concentrations detected in Site sediment
samples generally reflect background conditions for the
Groveland Wells Site.
Summary of Surface Water and Sediment Qualitv
Sediment and surface water contamination at the Site is low
level and sporadic. voc contamination in surface water and
sediment are below available AWQC and therefore represent
minimal risk. Metals concentrations detected in surface
water occasionally exceed AWQC, but EPA does not believe
they are Site-related and represent minimal risk to the
majority of the aquatic community. Inorganic concentrations
detected in sediment appear to reflect background for the
site.
Other than as discussed above, and except for soil
contamination on the Valley property (and possibly on the
Chesterton property and at the Haverhill Municipal .
Landfill), no other media are affected by the contamination
on the Groveland Wells Site.
A complete discussion of Site characteristics can be found
in the Supplemental MOM RI at Pages 4-1 through 4-85.
VI.
SUMMARY OF SITE RISKS
The Supplemental MOM RI includes a Public Health Risk
Assessment and an Ecological Risk Assessment. The objective
of these assessments was to define potential risks to human
-------
health and the environment arising from the contaminants at
the Site. These assessments are summarized below.
A.
PUblic Health Risk A9se9s~ent
A ?ublic Health Risk Assess~e~~ was perfor~ed to esti~ate
the probability and magnitude of potential adverse human
health and environmental effects from exposure to
contaminants associated with the Site. The public health
risk assessment followed a four step process:
(1) contaminant identification, which identified those
hazardous substances which, given the specifics of the site,
were of significant concern; (2) exposure assessment, which
identified actual or potential exposur~ 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 site,
including carcinogenic and non-carcinogenic risks. The
results and conclusions of the public health risk assessment
for the Groveland Site are discussed below.
,
~
Twenty-six (26) contaminants of concern, listed in Table 12
of this Record of Decision, were selected for evaluation in
the risk assessment. These contaminants constitute a
representative subset of the more than thirty-eight (38)
contaminants identified at the Site during the Supplemental
MOM RI. The twenty-six (26) contaminants of concern were
selected to represent potential Site-related hazards based
on toxicity, concentration, frequency of detection, and
mobility and persistence in the environment. A summary of
the health effects of each contaminant of concern can be
found in Section 6.2.2 of the risk assessment.
Potential human health effects associated with exposure to
the contaminants of concern were estimated quantitatively
through the development ot several hypothetical exposure
pathways. 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
Site. The following is a brief summary of the exposure
pathways evaluated. A more thorough description can be
found in Section 6.4 of the Supplemental MOM RI.
For each exposure pathway, the frequency and duration of
exposure was evaluated. Exposures to adults for each medium
were evaluated quantitatively while those for a child were
evaluated qualitatively. For contaminated groundwater, an
adult and ~hild (3-6 years) were assumed to consume 2 and 1
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\)
liter of groundwater per day throughout the year for 70 and
4 years, respectively. Accidental ingestion and dermal
co~tact with surface water and dermal contact with sediments
wa5 eval~atec :0= an ad~lt and child (9-:5 years) assuming
eaoj would swi~ in the pond 2 ho~rs pe= day, 24 days per
year ~=r 70 yea~s (fer ~~e a~~:t) a~j seven years (for the
child). Ingestion of finfish taken from the lOwer Johnson
Creek Watershed was evaluated for an adult and child
assuming that 20 percent of all fish consumed by these
populations were derived from the Johnson Creek Watershed
and that 6.5 g of fish were ingested per day per year for 70
years.
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 assesiing exposure to
a mixture of hazardous substances.
The bazard 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 dose ("RfD") or other
suitable benchmark for non-carcinogenic health effects.
Reference doses have been developed by EPA to protect
sensitive indi vidual.s 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. Rfps 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 i~dex 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) .
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, '
1. Groundwater
a. Area A - Chesterton
property
Ta~le 13 depicts the c~~ulative carcinogenic risk and hazard
i~jices, respec~ively, pcs~d by i~gestio~ of groundwater in
areas A, B, C and D. The Reasonable Maximum Exposure
("RME") total cancer risk predicted for the shallow bedrock
is 3 x 10-3. A RME scenario was not presented for the
shallow overburden because only one well was sampled for
this depth. The average risk estimates for the shallow
overburden and shallow bedrock areas are 1.9 x 10-3 and
1.5 x 10-3, respectively. The compound that contributes
most significantly to these carcinogenic risk estimates is
- arsenic in every case. The average case and RME scenarios
for each subarea in Area A exceeds the Superfund target risk
range of 10-10 to 10-6. .
A summation of all average case and RME hazard indices
("HI") for every subarea at the Chesterton Facility area
results in a value greater than unity. When segregated by
toxic endpoint, however, only the target organs for skin and
liver exceed unity with HIs of 1.6 and 1.4, respectively.
The greatest contributor to the HI for skin is arsenic and
for the liver is chromium.
Maximum Contaminant Levels ("MCLs") or Proposed Maximum
Contaminant Levels ("PMCLs") were exceeded for the
following compounds identified in either the. shallow
overburden or shallow bedrock from Area A: trichloroethene,
tetrachloroethene, arsenic, chromium and nickel.
b. Area B - The Valley/Mill Pond Area
The RME total cancer risk predicted for the shallow bedrock,
downgradient of Valley (Subarea B-1), shallow overburden in
. the Valley/Mill Pond Area (Subarea B-2), deep .
overburden/shallow bedrock in the immediate vicinity of
Valley and Johnson Creek (Subarea B-3), and the Deep
overburden/shallow bedrock beyond Johnson Creek (subarea
B-4) is 3.5 x 10.3, 3.4 X 10-10, 1.7 X 10'2 and 1.5 x 10'2,
respectively. The avera~e risk estimates for subareas B-1
through B-4 are 2.8 x 10- , 2.0 X 10-3, 2.6 X 10-3 and
1.5 x 10'2, respectively. The compound which contributes
most significantly to carcinogenic risk estimates in Subarea
B-1 is trichloroethene, in Subarea B-2 is arsenic and
beryllium, in Subarea B-3 is trich1oroethene and arsenic and
in Subarea B-4 is arsenic and beryllium. The average case
and RME scenarios for every subarea in Area B exceed the
Superfund target risk range of 10-10 to 10-6.
-------
G
"
/
A summation of all average case and RME hazard indices for
every subarea in Area B results in a value greater than
unity. When segregated by toxic endpoint, subarea B-1
ex=eeds a hazard index of unity for the target end?cint of
blood in bo~h the aver?ge case (7.0) and the .RME s=enario
(12.6). 7he sc:e contri=ut~r to this hazard index is
1,2-dichloroethene. For subarea B-2 a hazard index of lis
exceeded for toxic endpoints of blood (RME-4.5 and average
case-3.4), and skin (RME only-1.4). The major contributor
to the HI for the toxic endpoint of blood is antimony and
for skin is arsenic. For subarea B-3 a hazard index of 1 is
exceeded for the toxic endpoint of blood for both the RME
(6.6) and average case (1.7). The major contributor to
these HIs is 1,2-dichloroethene. For subarea B-4 a hazard
index of 1 is exceeded for the toxic endpoints of skin for
both the RME (8.0) and average case scenario (8.0). The
major contributor to these HIs is arsenic.
MCLs or PMCLs were exceeded for the following
all of the four subareas: 1,2-dichloroethene,
trichloroethene, 1,1-dichloroethene, antimony,
tetrachloroethene, arsenic, and nickel.
compounds in
beryllium,
c. Area C - The Area North of Mill Pond
The RME total cancer risk predicted for the shallow/deep
overburden near Johnson Creek (C-l) and for the shallow/deep
overburden beyond Johnson Creek (C-2) was 3 x 10-3 and
5.2 x 10"3, respectively. The average risk estimates for
subareas C-1 and C-2 were both 1.1 x 10-3. Compounds which
contribute most significantly to these risk estimates are
arsenic and beryllium for every scenario. The average case
and RME scenarios for each subarea in Area C exceed the
Superfund target risk range of 10'" to 10-6.
A summation of all average case and RME hazard indices for
every subarea in Area C produces a value greater than unity.
When segregated by toxic endpoint, however, results from
round one sampling indicate that a target hazard index of .
one is exceeded in Subarea C-1 for the RME scenario for the
target endpoints of skin and kidneys due solely to arsenic
and cadmium, respectively. For the same depth in Subarea
C-2, a hazard index of one is exceeded for the target
endpoints of blood in both the average case and RME scenario
due mainly to antimony and barium. For the RME scenario a
hazard index of one is exceeded for liver and skin due
solely to chromium and arsenic. Second round monitoring
data produces similar results.
MCLs or PMCLs were exceeded for the following chemicals:
trichloroethene, antimony, arsenic, barium, beryllium,
cadmium, chromium, iron, nickel, selenium and aluminum.
-------
d. Area D - The Haverhill Municipal Landfill Area
The P~E total cancer ~isk predicted for ~he deep overburden
.: :-st and second ro~nd data) was 5 x 10''> and 2 x :'0'2,
r ::::tively. - The av:ra:;e cancer ri:k,:esti.~ates =?;
S::i-:::;...;".lng :"C:.lna C~2 2:nc. -:'"",,:0 we:-.=: 3 x ~~ ., =.:-:=. 9 )( 10 . ,
respectively. The major contributor to this risk was
arsenic in both scenarios. The average case and RME
scenarios for both sampling rounds of data in the deep
overburden in Area D exceed the Superfund target risk range
of 10" to 10'6.
A summation of all average case and RME hazard indices for
both sampling rounds of data in area D exceeds unity. Only
- two target endpoints exceeded a hazard index of one when
segregated by similar endpoint. The first is the liver for
second round data in the RME scenario, with chromium being
the major contributor. The second is the HI for skin which
exceeds unity in every scenario for both first and second
round data, due solely to arsenic.
MCLs or PMCLs are exceeded for the following compounds in
Area Dj trichloroethene, arsenic, beryllium, cadmium,
chromium, nickel, iron and aluminum.
2. Surface Water
Tables 14 and 15 depict the carcinogenic and non-
car~inog~nic risk, respectively, posed by the current
potential accidental ingestion of contaminants in surface
water, for the RME scenario. Exposure parameters for both
present and future scenarios are assumed to be the same,
thus there is one calculation for surface water. Exposure
to this medium can occur through dermal contact and
ingestion. Tables 16 and 17 depict the carcinogenic and
non-carcinogenic risk, respectively, posed by dermal
exposure to contaminants in surface water for the RME
scenario. Exposure parameters for both present and future
scenarios are assumed to be the same, thus there is one
calculation. Cancer and non-cancer effects associated with
all surface water exposures are within Superfund's target
risk range. .
3. Sediment
Table 18 and 19 depict the carcinogenic and non-carcinogenic
risks, respectively, posed by current and future exposures
to sediment in the lower Johnson Creek watershed through the
dermal route for the RME. Exposure parameters for both
present and future scenarios are assumed to be the same,
thus there is one calculation. Both cancer and non-cancer
-------
J
effec~s associated wit~ exposu~e ~o
EPA's Superfund targe~ risk range.
sedi~ents are ~it~~n t~e
4. Pish
Tables 20 and 21 depict the carcinogenic and non-
carcinogenic risk, respectively, posed by the current and
future potential consumption of fish taken from the lower
Johnson Creek for the RME. Exposure parameters for both
present and future scenarios are assumed to be the same,
thus there is one calculation. Both cancer and non-cancer
effects associated with fish ingestion'are within EPA's
target risk range.
s.
uncertainty in Risk Assessment
Carcinogenic and non-carcinogenic health risks are estimated
using various assumptions; therefore, the values presented
in this section contain an inherent amount of uncertainty.
The extent to which health risks can be characterized is
primarily dependent upon the accuracy with which a
chemical's toxicity can be estimated and the accuracy
exposure estimates. The toxicological data that form
basis for all risk assessments contain uncertainty in
following areas: '
of the
the
the
The extrapolation of non-threshold (carcinogenic)
effects from the high doses administered to laboratory
animals to the low doses received under more common
exposure scenarios.
The extrapolation of the results of laboratory animal
studies to human or environmental receptors.
The interspecies variation in toxicological endpoints
used in characterizing potential health effects
resulting from exposure to a chemical. -
.The variations in sensitivity among individuals of any
species.
6.
summary of site Risks to Public 'Health
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 public health, welfare, or the
environment. The media ~hich is the focus for remedial
actions for this Record of Decision is the contaminated
groundwater.
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The surficial
is classified
Massachusetts
designated as
aquifer in the general c~~~a=:.~ant pl~~E area
as a Class I aquifer by the Commonwealth of
(314 CMR S 6.03), which is groundwater
a source of potable water supply.
Under the EPA Groundwater Classification System [EPA
Groundwater protection strategy ("GWPS"), Office of
Groundwater Protection, August 1984], this aquifer is
classified as a Class II. The policy under the GWPS
establishes protection goals based on the "highest
beneficial uses to which groundwater having significant
water resourbes value can presently or potentially' be put."
The aquifer in the general contaminant plume area is
considered a current drinking water source since groundwater
-is used for drinking within a two-mile radius of the Site
(the classification review ar~a). .
The threat to public health posed by the contaminated
groundwater plume represents a possible future threat since
groundwater in the general plume area is not known to be
consumed owing to the availability of the public water
supply. However, the threat to public health posed by the
contaminated groundwater plume could also represent a future
threat if the water withdrawn at Station No.1 were to
increase beyond its present rate, thereby drawing the
contaminated plume to itself, or if additional drinking
water wells were placed into the aquifer. However, as
previously mentioned, station No.1 is presently equipped
with granular activated carbon treatment to remove VOCs from
the groundwater, so the resultant risk would be minimal.
This remedial action will address the principal future
threat to human health posed by the contaminant plume,
namely the possible ingestion, inhalation and dermal
adsorption from multiple household uses of potable
groundwater.
~
..
B.
Ecological Risk Assessment
The ecological risk assessment is based on data collected
during the supplemental MOM R1 and information in the
existing literature. No population studies, bioassays,or
biomonitoring were performed in conjunction with this'
project.
1.
Source Characterization
contaminants in the surface water and sediment are important
for the characterization of Site ecological risks.
Groundwater contaminants are less important and have not
been considered. Discharge of contaminated groundwater to
surface water bodies could result in ecological effects.
However, direct surface water and sediment sample analysis
-------
have provided
irnpac"Cs.
s~fficient
data
to characte~ize such pcten~ial
VOC contamination in surface waters and sediments may be
described as low-level and sporadic. TCE and 1,2-DCE were
detected in surface water samples at maximum concentrations
of 54 ug/L and 96 ug/L, respectively. TCE and 1,2-DCE were
detected in surface water sample collected below the
discharge of the Mill Pond groundwater extraction system.
These and other VOCs have been detected in surface water and
sediments throughout the watershed. Chemicals detected in
surface water and sediments from the lower Johnson Creek
watershed during the remedial investigation are listed in
Table 7-1 of the Supplemental MOM RI.
A review of available Ambient Water Quality criteria
("AWQC") for the protection of aquatic life indicates that
organics concentrations detected in 'the surface water
samples are below available AWQC. Concentrations of
aluminum, silver, iron and lead detected in the surface
waters of the lower Johnson Creek watershed exceed AWQC for
the protection of aquatic life -in surface water. The in-
text table found in Section V of the ROD and Table 22 .
compares the detected organic and inorganic concentrations,
respectively, to available standards/criteria.
2.
Habitat And Potential Receptors
This section briefly describes the habitat types present
within the Site and identifies potential animal and plant
receptors. This information has been compiled from field
observations and data collected during sampling conducted
during the Supplemental MOM RI and other recent activities
at the Site.
Two types of wetland habitat, ponds and streams, are known
to exist within the site. Streams include Argilla and
Brindle Brook, Johnson Creek, and the Merrimack River.
Ponds include Mill Pond and the Trimount impoundment.
The 1985 Groveland Wells Site Remedial Investigation Report
(ERT, 1985) identified three wetland types present in the
study area: Ponds, Bordering Vegetative Wetlands (IIBVWII),
and Kettle Depressions. The 1987 Massachusetts Wetland.
Protection Regulations (310 CMR 10.0) further define wetland
types. The wetland resource areas present at the Site, as
defined by these regulations, include BVW (including marshes
and swamps), Land Under Waterbodies and Waterways (creeks,
streams and ponds) ~ Banks, and Land Subject to Flooding.
Each aquatic habitat (ponds and streams) selected to
represent the Site for this assessment includes all of the
-------
lc=:2. '.;e~la:1d :es.:'...:::-ce a::-e~s as :;:ir:ed :'::,,' 31.0 CMR 10.0.
There is a significant marsh area (BVw) associated with Mill
Pond; this habitat .is evaluated in concert with the pond.
a.
Ponds and Marshes
There are two manmade surface water impoundments within the
watershed: Mill Pond and the Trimount impoundment, which is
located immediately north of Main Street adjacent to
Trimount Bituminous Products. Mill Pond is surrounded on
three sides by a marshy area dominated by purple
loosestrife, cattails and numerous sedges. Although this
marsh is relatively dry in the summer months, spring
flooding is extensive. Johnson Creek meanders through the
center of this marsh, serving as the primary influent to
~ill Pond. .
The Trimount impoundment has no associated marsh, but is
surrounded by a woodland to the east and a field and "edge"
to the west. Farther to the west is the active gravel and
asphalt operation known as Trimount Bituminous Products.
This operation is active during the summer and early fall.
Therefore, the pond is not anticipated to provide extensive
breeding habitat for birds or other species requiring
privacy from human activities and noise. This pond-is,
however, an optimal area for amphibians, reptiles and
invertebrates.
Both impoundments are relatively stagnan~; they are prone to
aquatic vegetation growth although significant vegetative
growth was not observed in the Trimount impoundment during
field activities. This pond may have been under
considerable stress in the past as a result of pumping and
graveling operations. Therefore, the pond bottoms may not
sustain vegetative growth.
b.
streams
Four small streams exist within the study area: Brindle
Brook, Johnson Creek, an unnamed brook which is a tributary
to Johnson Creek south of the Haverhill Landfill, and
Argilla Brook. These streams range in width from 6 to
12 feet and in depth from 4 feet during spring runoff to
less than 6 inches during mid-summer drought conditions.
It is expected that small fish travel in these streams
between the impoundments and the Merrimack River.
Rec~eational fishing for trout and .other warm water species
is reported in both Johnson Creek and the Merrimack River.
The catadromous american eel has been found to use Johnson
Creek and Argilla Brook for adult habitat (NOAA, 1988).
-------
n
c.
!'!errimack River
The Merrimack River has been noted to be an important
breeding and migratory habitat for numerous commercial
species of fish, including striped bass, alewife, blueback
herring, and atlantic salmon (NOAA, 1988). The River basin
also has been reported to serve as wintering grounds for
bald eagles and is important as a summer breeding and
feeding habitat for other soaring predatory birds.
d.
Trustee Resources and Rare and Endanqered species
The Massachusetts Natural Heritage Program was contacted in
July 1990 with respect to rare and endangered species
visiting or residing in the site area. In August 1990,
- representatives of the Natural Heritage Program responded
that two state-listed species w~re known t~ be present near
the Groveland Wells Site. .
The wood turtle' (Clemmvs insculpta) is classified as a
species of special concern and the Blandings turtle
(Emvdoidea blandinqii) is classified as a threatened
species. Both species are known to exist to the southeast
of the Site. The Massachusetts Natural Heritage Program.
also stated that the "Argilla Brook and surrounding forested
area provide the habitat necessary for these turtles'
survival. II
The Massachusetts Division of Fisheries and wild~ife
regulations (321 CMR 8.01) identify a threatened species as
any species which is likely to become an endangered species
within the foreseeable future throughout all or a
significant portion of its range. These regulations
identify species of special concern as any native species
which has been documented to be suffering a decline such.
that the species in the Commonwealth could be threatened, or
which occurs in such small numbers or within such a
restricted distribution that it could become threatened in
the Commonwealth.
3.
Conclusions
Sediment and surface water contamination at the Site is low
level and sporadic and do not appear to present a risk to
the environment. VOC contamination in surface water and
sediment are below available AWQC and therefore represent
minimal risk. Metals concentrations for aluminum, sliver,
iron and lead detected in surface water occasionally exceed
AWQC, but EPA does not believe they present a risk to the
majority of the aquatic community. Inorganic concentrations
detected in sediment appear to reflect background for the
Site.
-------
VII.
r
Di;;~; ELOPMENT A.--" SCREENIl-,C; ::.? ALTERNATIVES
A. statutory Requirements/Response O~jectives
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 is cost effective and that
"uses permanent solutions and alternative treatment
technologies or resource recovery technologies to the
maximum extent practicable; and a preference for remedies in
which treatment 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
contaminants, 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
future potential threats to public health and the
environment.
These response objectives were:
To prevent ingestion of groundwater contamination in
excess of relevant and appropriate drinking water
standards [MCLsjMCLGsjMassachusetts Drinking Water
Standards(MMCLs)] or, in their absence, an excess
cancer risk level of 10"6, for each carcinogenic
"compound. Also, to prevent ingestion of groundwater
contaminated in excess of a total excess cancer risk
level for all carcinogenic compounds of 10"4 to 10"6.
To prevent ingestion of groundwater contaminated in
excess of relevant and appropriate drinking water
standards for each non-carcinogenic compound and a
total Hazard Index greater than unity (1) for non-
carcinogenic compounds having the same target endpoint
of toxicity.
To restore the groundwater aquifer to relevant and
appropriate drinking water standards (MCLsjMCLGsjMMCLs)
or, in their absence, the more stringent of an excess
-------
o
cancer risk of ~O-6, :or eac~ carcineqe~:c co~~ou~d er
a hazard quotient of unity fer each non-carcinogen~c
compound. Also, restore the aquifer to the more
stringent of (1) a total excess cancer risk of 10-' to
10-6 or (2) a hazard index not to exceed an acceptable
range for non-carcinogenic compounds having the same
target endpoint of toxicity.
B. Technology and Alternative Development and screening
CERCLA and theNCP 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 groundwater response action, the
Supplemental MOM RI/FS developed a limited number of
remedial alternatives that attain site specific remediation
levels within different timeframes using different
technologies, a no action alternative, and an institutional
controls alternative.
The Supplemental MOM FS identified, assessed and screened
technologies based on implementability, effectiveness, and
cost. ChapterS of the Supplemental MOM FS presented the
remedial alternatives developed by combining the
technologies identified in the previous screening process.
The purpose of the initial screening was to narrow the
number of potential remedial actions for further detailed
analysis while preserving a range of options. Each
alternative was then evaluated and screened in Chapter 5 of
the Supplemental MOM FS .
In summary, of the thirty-seven (37) management of migration
remedial alternative technology/process options screened in
Chapter 4, seventeen (17) were retained and combined into
six (6) general alternatives for detailed analysis. Table
4-1 of the Supplemental MOM FS identifies the seventeen (17)
technology/process options that were retained in the
preliminary screening as well as those that were eliminated
from further consideration. Table 4-6 of the Supplemental
MOM FS identifies the six (6) general alternatives that.were
finally retained through the screening process.
VIII.
DESCRIPTION OF ALTERNATIVES
This Section provides a
alternative evaluated.
each alternative can be
Supplemental MOM FS.
narrative summary of each
A detailed tabular assessment of
found in Table 5-14 of the
-------
. ,
:iana;emen.. ~~;; Mi;.:::. .~on ("MOM") Alte=:u.a..i"v"a:s A:nalyzaa
The Supplemental MOM FS outlined management of migration
alternatives at the Groveland Site to address contaminants
in the plume extending from the Valley property and
throughout the site. The management of migration
alternatives evaluated for the site include: (1) a no-action
alternative; (2) institutional controls; (3) partial
inorganics removal and treatment, and discharge to the
Haverhill Sewage Treatment System; and inorganics removal
and treatment and subsequent organics treatment using (4)
air stripping, (5) carbon adsorption, and (6) ultraviolet
("UV") / oxidation.
. Alternative No.1 - No Action
This alternative was evaluated to serve as a baseline for
comparison with the other remedial alternatives under
consideration. Under no action, no removal of contaminants
from the aquifer would occur, other than those currently
being removed and treated by the air stripper at the Mill
Pond Groundwater Extraction and Treatment System as well as
the granular carbon adsorption ("GAC") system at Station
No.1. The only cost requirement is the provision for
monitoring every 5 years.
Estimated
Estimated
Estimated
Estimated
Estimated
Time for Design and Construction: Not applicable
Time of Operation: Not applicable
Capital Cost: Not applicable
Annual operation and Maintenance Costs: $5,000
Total Cost (net present worth): $70,000
Alternative No.2 - Institutional Controls
-.
..
Alternative No.2 involves the imposition of institutional
controls. These institutional controls would be designed
to prohibit the use of groundwater in the contaminated area
until cleanup levels have been achieved. Such controls
could include, for example, deed restrictions prohibiting
installation of private wells in the contaminated plume.
The institutional controls would be implemented to minimize
future risks associated with the potential' direct use of
contaminated groundwater and to provide notice of the
migration of contaminants to Station No.1. The cost
requirements include quarterly sampling of monitoring wells.
Estimated Time for Design and Construction: Not applicable
Estimated Time of Operation: Not applicable .
Estimated Capital .Cost: Not applicable
Estimated Annual operation and Maintenance Costs: $39,000
Estimated ,Total Cost (net present worth): $600,000
-------
Al~e~~ative No,. : -
EX~~3=~:C~ ~el:s. P2~~:a:
In~~c=!;:.~s
Removal. and Discharqe to the Haverhill
POTW
This alternative includes the institutional controls and
sampling in Alternative 2. Also included is the construction
of a network of approximately six groundwater extraction
wells to intercept the entire width and depth of the
contaminated groundwater plume originating from the Valley
property (See Figures 7 and 8). The total estimated flow
rate needed to intercept the plume is about 400 gallons per
minute ("gpm"). During remedial design, the existing Mill
Pond extraction system will be considered for use to
supplement or replace one of the six new extraction wells
- proposed for this area. Additionally, sampling of the
surface water and sediments iri Johnson Creek and other
nearby streams would be conducted on a semi-annual basis to
identify any potential discharge of contaminated groundwater
to surface water bodies.
This alternative includes a system for the removal of metals
(primarily iron) in the extracted groundwater to an
acceptable level for discharge to the Haverhill POTW.
contaminated groundwater is pumped to a mixed equal~zation
tank to lessen effects of flow and concentration variations.
Air is diffused into the tank to convert soluble ferrous
iron into insoluble ferric iron. The overflow from the
equalization/aeration system would be transferred to a
sedimentation unit (also referred to as clarifier). In the
sedimentation unit, most of the suspended solids would
sett"le to the bottom of the unit because of the quiescent
condition. Flocculation and coagulation would be performed
prior to sedimentation to promote rapid and effective
removal of the suspended solids. The settled solids would
be transferred to the residual treatment system.
To minimize sludge disposal requirements, a filter press was
selected as the representative process option for separating
free water from the SuspeDded solids in the residual.
treatment process. For disposal, the dewatered filter cake
(dewatered sludge) would be transferred offsite for
disposal. Classification of this waste would have to be
aetermined during remedial design/action. If this filter
cake is found to be a hazardous waste it will be disposed of
in accordance with applicable requirements.
The partially treated groundwater would be discharged to
existing sanitary sewers located throughout the plume area.
The sewers discharge to the Groveland lift station (located
north of Argilla Brook near Washington Street). The current
flow rate into this lift station is about 60 to 140 gpm.
Since the estimated extraction rate is significantly higher
-------
(,
tnan the current ra~e, it is ass~~ed ~~at ~===a=~no =~ t~e
lift station would be required. A parallel" lift station
intercepting the sewers and connected to the existing (and
sufficiently sized) discharge header would be considered..
At the Haverhill POTW, the contaminated groundwater would be
blended with about 11.5 MGD or 8,000 gpm of sanitary
wastewater. An estimated 95 percent of the insoluble metals
would be removed from the water at the POTW because of the
primary and secondary sedimentation treatment units.
Approximately 83 percent of the volatile 9rganics would be
volatilized in the aeration basin; an indeterminate quantity
would be adsorbed onto the sludge for subsequent removal in
the secondary sedimentation unit. The Haverhill POTW
. effluent is discharged to the Merrimack River.
Estimated
Estimated
Estimated
Estimated
Time for Design and Construction: 4 months and 6
months, respectively
Time of operation: 30 years
Capital Cost: $1,800,000
Annual Operation and Maintenance Costs: $643,000
Total Cost (net present worth): $11,700,000
Estimated
Alternative No.4 - Extraction Wells. Inorqanics Removal. .
Air Strippinq. and Discharqe to
Johnson Creek
This alternative includes the institutional controls and
sampling in Alternative 2. It also includes other portions
of Alternative 3 (installation of a groundwater extraction
network and equalization/aeration and sedimentation to
remove inorganics, as well as sampling of surface water and
sediments). A new component of the metal removal scheme
would be filtration, which provides additional removal of
suspended solids which would be necessary to achieve the
metal discharge standards and to allow for the efficient
operation of the treatment equipment.
TCE and other volatile organics would be removed from the
filtered groundwater by a 25 foot air stripping tower.
Emissions from the tower would be captured by a granular
activated carbon unit. Spent carbon would be transported
off-site for regeneration and destruction of the organics.
The treated groundwater would be discharged into Johnson
Creek. The estimated discharge flow rate of about 400 gpm
is within the normal flow rate that the existing stream
channel can accommodate. The discharge structure would
include measures to minimize potential erosion of the river
bed and would be designed to ensure that it will not cause
physical disruption of wetlands (if any) near the discharge
point.
-------
,j
Es't.imated
Time fo= Design and Cor.st=~ctic~: 5 months and
9 months, respectively.
Time of operation: 30 years
capital Cost: $3,400,000 "
Annual "Operation and Maintenance Costs: $341,000
Total Cost (net present worth): $8,700,000
Estimated
Estimated
Estimated
Estimated
Alternative 5: Extraction Wells. Inorqanics Removal. Carbon
Adsorption. and Discharqe to Johnson Creek
This alternative includes the institutipnal controls and
sampling in Alternative 2. It also includes other portions
of Alternative 4 (installation of a groundwater extraction
network and equalization/aeration, sedimentation and
- filtration to remove inorganics, as well as sampling of
surface water and sediments). Under Alternative 5, the
filtered groundwater would then be transferred to granular
carbon adsorption ~nits to remove TCE and other organic
volatiles. Spent carbon would be transported off-site for
regeneration and destruction of the organics. The treated
groundwater would be discharged to Johnson Creek." The
estimated discharge flow rate of about 400 gpm is within the
normal flow rate that the existing stream channel can
accommodate. The discharge structure would include measures
to minimize potential erosion of the river "bed and would be
designed to ensure that it will not cause physical
disruption of wetlands (if any) near the discharge point.
Estimated
Estimated
Estimated
Estimated
Time for Design and Construction: 6 months and 9
months, respectively.
Time of Operation: 30 years
capital Cost: $3,500,000
Annual Operation and Maintenance Costs: $610,000
Total Cost (net present worth): $12,900,000
Estimated
..
Alternative 6: Extraction Wells. Metals Removal.
UV/Oxidation and Discharqe to Johnson Creek
This -alternative includes the institutional controls and
sampling in Alternative 2. It also includes other portions
of Alternative 4 (installation of a groundwater extraction
network and equalization/aeration, sedimentation and
filtration to remove inorganics, as well as sampling of
surface water and sediments). Under Alternative 6, the
filtered water would then be subjected to a process
involving ultraviolet ("UV") light and oxidation to destroy
TCE and other volatile organics. (A more complete
description of this alternat1ve is provided below). The
treated groundwater would be "discharged to Johnson Creek.
The estimated discharge flow rate of about 400 gpm is within
the normal flow rate that the existing stream channel can
accommodate. The discharge structure will include measures
-------
t= ~inimi:a pc~en~ial ercSlC~ c~ the ri~er bed and wil: be
designed to ensure that it will not cause physical
disruption of wetlands (if any) near the discharge point.
Estimated
Time for Design and Construction: 9 months for
each
Time of Operation: 30 years
Capital Cost: $3,800,000
Annual Operation and Maintenance Costs: $333,000
Total Cost (net present worth): $8,900,000
Estimated
Estimated
Estimated
Estimated
IX.
SUKMARY 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:
Threshold Criteria
The two threshold criteria described below must be met in
order for the alternatives to be eligible for selection in
accordance with the NCP.
1.
Overall protection of human health and the environment
addresses whether a remedy provides adequate protection
and describes how risks posed through each pathway are
eliminated, reduced ' or controlled through treatment,
engineering controls, or institutional controls.
2.
Compliance with applicable or relevant and appropriate
requirements ("ARARS") addresses whether a remedy w.i 11
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 used to compare and evaluate
the elements of different alternatives that meet the
threshold criteria.
-------
-------
criteria, except the State ~nd ~omm~ni~y ac~ept2~ce
criteria, was cond~cted. This comparative analysis can be
found in Table 5-14 of the Supplemental MOM.
The section below discusses each of the nine criteria,
including the State and community acceptance criteria, in
connection with each alternative, and outlines their
strengths and weaknesses.
L
OVERALL PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENT
Alternatives 3, 4, and 5 would provide equal overall
protection to human health and the environment by
identifying contaminant migration, treating groundwater
contaminants, controlling new contact with groundwater
contamination and controlling its migration. .
Alternative 1 (the no-action alternative) would not
provide overall protection of human health and the
environment. Humans could be exposed to excessive
levels of certain organic contaminants if new private
wells were to be located in the contaminated plume.
Alternative 2 (institutional controls) is of moderate
effectiveness in terms of protecting human health and
the environment over long periods of time.
Only Alternative 6, however, provides for on-site
destruction of organic contaminants in. groundwater and
utilizes a treatment process for organic contaminants
that produces virtually no waste residuals. Of all the
alternatives, the organic treatment process used in
. Alternative 6 provides the greatest overall protection
of human health and the environment because it destroys
. virtually all organic contaminants in the extracted
groundwater.
...
2.
COMPLIANCE WITH APPLICABLE OR RELEVANT AND APPROPRIATE
REOUIREMENTS ("ARARS")
Except for the no-action (Alternative 1) and
institutional control (Alternative 2) alternatives, all
of the other alternatives that received detailed
analysis in the FS would meet all ARARs.
3.
LONG-TERM EFFECTIVENESS AND PERMANENCE
Alternatives 3, 4, 5 and 6 provide similar degrees of
long-term effectiveness and permanence in reducing
risks presented by the contaminated groundwater at the
site. In each of those alternatives, no significant
residual risks should remain in the groundwater. Under
Alternative 1 (no-action), long-term risks remain and
may increase with time. Under Alternative 2, the use
-------
<.}
. 4.
of instit~t:ona: co~~rcls is of ~nknow~ effectiveness
in terms of protec~ing human health over long periods
of time.
Only Alternative 6 provides for on-site destruction of
organic contaminants in groundwater and utilizes a
treatment process for organic contaminants that
produces virtually no waste residuals. Of all the
alternatives, the organic treatment process used in
Alternative 6 provides the greatest long-term
effectiveness and permanence because.it destroys
virtually all organic contaminants in the extracted
groundwater.
REDUCTION OF TOXICITY. MOBILITY. OR VOLUME THROUGH
TREATMENT
Neither Alternatives 1 or 2 would provide additional
treatment resulting in a reduction of toxicity,
mobility or volume. Alternatives 3, 4, 5 and 6 would
remove or destroy approximately 99 percent of the site
organics by treating approximately 6.3 billion gallons
of contaminated groundwater and removing or destroying
approximately 6,600 pounds of organics. Each of theSe
latter four treatment schemes is irreversible.
Only Alternative 6 provides for on-~ite destruction of
organic contaminants in groundwater and. utilizes a
treatment process for organic contaminants that
produces virtually no waste residuals. Use of this
technology permanently destroys (not merely reduces)
virtually all organic contaminants in the extracted
groundwater.
5.
SHORT-TERM EFFECTIVENESS
Of the alternatives, Alternatives 1 and 2 would have
the least effects on the community and workers since
minimal or no actions would occur. However,
Alternatives 1 and 2 would provide the le~st protection
of the environment, since the contaminants would
continue to migrate.
Alternatives 3, 4, 5 and 6 are all similar in terms of
their short-term effectiveness. There would be a
minimal increase in risk because of the construction
and operation of an extraction, treatment, and/or
discharge system. Worker health and safety practices
would have to be employed during the construction of
extraction wells, particularly in the more contaminated
areas. Alternatives, 3, 4, 5 and 6 would require an
-------
est:TI:2.,,:ed 30 j" ; ",:,,"3 }:'.-'.. '.:.::-e ~::hieving
remedial action cbjec~ives.
cC.:-::lia::1ce '.iw~:th
Only Alternative 6 provides for on-site destruction of
organic contaminants in groundwater and utilizes a
treatment process for organic contaminants that
produces virtually no waste residuals. Use of this
technology most effectively eliminates possible adverse
impacts of organic contaminant transport or transfer
off-site, as occurs with Alternatives 3, 4 and 5.
6.
IMPLEMENTABILITY
The technologies required to implement Alternatives 2
through 6 are readily available, reliable and easy to
undertake. In each case, migration and exposure
pathways should be effectively remediated. Alternative
6 utilizes an innovative technology, the UV/oxidation
organics treatment process, and treatability testing
would be required to confirm the feasibility of the use
of that technology in remediating organic groundwater
contamination at the Site, but EPA believes that the
reliability of that technology has been established.
Alternative 1 is simple to undertake since it requires
no treatment or additional monitoring.
7 .
COST
The capital, operation and maintenance, and total cost
for each alternative is provided as part of the
description of alternatives in Section VIII of the ROD.
Alternatives 1 and 2 are the least costly alternatives,
with total costs of $70,000 and $600,000, respectively.
Alternatives 3, 4, 5, and 6 have total costs of
$11,700,000, $8,700,000, $12,900,000, and $8,900,000,
respectively. Thus, of the four latter alternatives,
Alternatives 4 and 6 would involve the least total
cost.
8.
STATE ACCEPTANCE
Based on its review of the remedial investigations and
feasibility studies for the Site, and the Proposed
Plan, the Commonwealth of Massachusetts concurs in the
selection of EPA's alternative.
9.
COMML~ITY ACCEPTANCE
Community reaction to Alternative 6, the preferred
alternative, has been mixed. Two commenters
specifically supported EPA's preference for Alternative
6. Other commenters stated that Alternative 2
-------
~
(instit~tio~al controls) or Alternative 4 (air
s~~ippi~g) shoulj be selected. rl Du~=er of c~~~enters
stated that remedial action should be focused only in
the most contaminated portion of the plume.
x.
THE SELECTED REMEDY
Based on the comparative analysis as summarized above, EPA
has 'selected Alternative 6 as the remedy for this Site.
A.
Interim Groundwater Cleanup Levels
Interim groundwater cleanup levels have been established
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 ARARs. [e.g., Drinking Water Maximum
Contaminant Level Goals ("MCLGs" and MCLs»), if available,
or other suitable criteria described below. Periodic
assessments of the protection afforded by the selected
remedial action will be made as the remedy is being
implemented and at the completion of the remedial action.
At the time all groundwater ARARs identified in the ROD, and
newly promulgated ARARs and modified ARARswhich call into
question the protectiveness of the remedy, have been
achieved, a risk assessment shall be performed on all
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 the consumption of
Site groundwater. If the risks are not within EPA's risk
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.
These final protective cleanup levels shall be performance
standards for this ROD.
The goal of this remedial action is to restore groundwater
to its beneficial use, which is, at this Site, to restore' a
potential drinking water source to acceptable levels. Based
on information obtained during the remedial investigation
and on a careful analysis of all remedial alternatives, .EPA
believes that the selected remedy will achieve this goal.
It may become apparent, during implementation and operation
of the groundwater extraction system and its modifications,
that contaminant levels have ceased to decline and are
remaining constant at levels higher than the remediation
goal over some portion of the contaminated plume. In such a
case, the system performance standards and/or the remedy may
be re-evaluated.
-------
The selec~ed ~emedy ~ill include grou~_.{3ter ex~rac~ion fer
an estimated period of 30 years, during which the system's
performance will be carefully monitored on a regular basis
and adjusted as warranted by the performance data collected
during operation. Modifications may include the following:
(1)
pumping may be discontinued at individual wells
where cleanup levels have been attained;
(2)
pumping may be attenuated at wells to eliminate
stagnation points;
(3)
pumping may be pulsed to allow aquifer
equilibration and to allow ~dsorbed contaminants
to partition into groundwater;
additional extraction wells may be installed to
facilitate or accelerate cleanup of the
contaminant plume; and
(4)
additional monitoring wells maybe installed to
evaluate remedial progress
To ensure that cleanup levels continue to be maintained, the
aquifer will be monitored at those wells where pumping has
ceased, and at the same frequency as that of other
monitoring wells. The frequency of monitoring for all wells
will be determined during remedial design.
(5 )
Groundwater monitoring wells adjacent to the Chesterton
property and Haverhill Municipal Landfill will be sampled on
a regular basis to ensure that the remedial extraction
system does not adversely spread the contamination
originating from these properties. If it is determined that
the remedial extraction wells are causing the contamination
from these properties to adversely spread, the extraction
system will be modified, e.g., by reducing the pumping rate
or relocating extraction wells.
The proposed extraction well locations (See Figure 15) are
sufficiently distant from the Valley property so as not to
cause any interference with the remedial activities
occurring there. The anticipated zone of influence of the
most southerly well will not extend to the Valley property.
The area of attainment for the management of migration
operable unit is the contaminated plume that extends from
the Valley property as well as any other areas within the
Site where cleanup levels or ARARs are exceeded in
groundwater. The Chesterton property, the Haverhill
Municipal Landfill, and the Valley property are not part of
the area of attainment for the Management of Migration
-------
<,
Op~~able unit. As discussed previously, remediation for
those areas are beir.g handled separa~e~y as f~l:o~s: (1)
remediation of contamination at the Chesterton property
will be conducted under RCRA ; (2) remediation of
contamination at the Haverhill Municipal Landfill, which has
been listed on the NPL, will be conducted separately under
CERCLA; and (3) remediation of contamination at the Valley
property is being implemented under an Amended
Administrative Order dated February 1, 1991, in accordance
with the Source Control ROD.
The approximate area of attainment for the plume, as
presented in Figure 7, is believed to encompass
approximately 75 acres (as delineated using the maximum
concentration of TCE detected during the Supplemental MOM
. RI). A calculated 360 million gallons of groundwater is
believed to be currently affected by virtue of being
contaminated with approximately 6,700 pounds of TCE and 1,2-
DCE, plus lesser quantities of other contaminants. No free
product or dense non.,..aqueous phase liquids ("DNAPLs") have
been detected in the aquifer downgradient of the Valley
property. However, the possibility that free-product may
exist cannot be ruled out. If free-product is discovered
during remediation, the remedy may be reevaluateq in a
supplemental decision document.
'Organic groundwater contaminants in the area of attainment
will be treated to the interim cleanup levels presented
below. TCE and DCE were selected as the two major organic
contaminants of concern in this area of attainment, based on
mobility, toxicity, observed concentrations, and remedial
levels. Remediation of groundwater to the interim cleanup
levels for these two organic contaminants should result in
achieving the respective levels for each of the other
organic contaminants.
Inorganic groundwater contaminants which exceed MCLs
(aluminum, antimony, arsenic, barium, beryllium, cadmium,
chromium, nickel and selenium) within the area of attainment
will be treated to interim cleanup levels presented below.
During the design stage of the remedy, a comprehensive
background groundwater sampling program will be conducted.
If study results indicate that certain Site inorganic
chemicals are present at background concentrations, then
those inorganics will no longer be identified as Site-
related contaminants and standards (ARARsjcleanup levels)
for those inorganics would not need to be met. If necessary,
however, these contaminants may be"cleaned up to background.
If study results indicate that certain inorganic
concentrations are not representative of background, then
the remedy will be designed to attain inorganic interim
cleanup levels for those chemicals.
-------
E."'3.USE. :i'le::,:~'..:::.fer, .:.::c1u::1:':-.. ':~-:e ::ire.=.:: ~t-:'cir::::e:1-':, ~s a
C~3SS II aquifer, which is a po~ential source of drinking
water, 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 & B) have been set at the appropriate MCL
as the MCLGs for these groups of compounds are zero.
Interim cleanup levels for the Class C (possible
carcinogens) have been set at the non-zero MCLG. In the
absence of a non-zero MCLG, an MCL, or a proposed drinking
water standard or other suitable criteria to be considered
(i.e. health advisory, State standard), a cleanup level was
derived for carcinogenic effects based on a 10-6 excess
- cancer risk level considering the ingestion of groundwater.
Interim cleanup levels for compounds in groundwater
exhibiting non-carcinogenic effects have been set at the
non-zero MCLG. In the absence of a non-zero MCLG, interim
cleanup levels for non-carcinogenic effects have been set at
a level thought to be without appreciable risk of an adverse
effect when exposure occurs over a lifetime (hazard
quotient = 1). .
Table 23 below summarizes the interim cleanup levels for
carcinogenic and non-carcinogenic contaminants of concern
identified in groundwater at the Site.
,
All groundwater ARARs identified in the ROD,' and newly
promulgated ARARs and modified ARARs which call into
question the protectiveness of the remedy and the interim
c2eanup levels prescribed by the above described risk
assessment, must be achieved at the completion of the
remedial action within the area of attainment. EPA has
estimated that these levels will be obtained within thirty
(30) years.
While these interim cleanup levels are consistent with ARARs
(and suitable criteria to be considered) for groundwater, a
cumulative risk that could be posed by these compounds may
exceed EPA's goals for remedial action. Consequently, these
levels are considered interim cleanup levels for
groundwater. When all groundwater ARARsidentified in the
ROD, and newly promulgated ARARs and modified ARARs which
call into.question the protectiveness of the remedy, have
been attained, a risk assessment will be performed on
residual groundwater contamination to determine whether the
remedial action is protective. Remedial actions shall
continue until protectiveness concentrations of residual
contamination have been achieved or until the remedy is
otherwise deemed protective. These protective residual
levels shall constitute the final cleanup levels for this
-------
Noncarcinogenic :Cont.
of Concern
Reference
Dose(oral)
, (mg/kg-day)
TABLE 2:5
INTERIM GROUNDWATER CLEANUP lEVELS
Clean-up
level
(mg/L)
Basis
Target Endpoint
of
Toxicity
,..,
Hazard
Indel!
... -..... ------.. -- --....-------.... -.. - -.... --.. -.. - - --.....-.. - - --.. --.... - --...................-.. -........ -..-.. w-.......... -- ---._----
Acetone 1. 1E -01 0.7 MMCl liver, kidney 1. 9E -01
Antimony Io.OE-Oio 0.00:5 MCL blood 2.3E-01
Arsenic 1.0E.0:5 0.05 MCL skin 1. 5E+00
Barilml 5.0E-02 1 MCL blood, fetotol!. 6.0E'01
Beryl I ilml 5.0E-03 0.001 MCL none 6.0E .03
Cadnilml 5.0E-Olo 0.005 MCL kidney :5.0E'01
Chlorobenzene 2 .OE -02 0.1 MCL I iver, kidney 1.5E.01
Chromilml(VI) 5. OE - 03 0.05 MCL kidney 3.0E-01
1,1-Dichloroethane 1. Of -01 0.005 MMCl kidney 1. 5E ,03
1,1-0ichloroethene 9.0E-03 0.007 MCl liver 2.3E-02
1,2'Dichloroethene(c) 1.0E -02 0.07 Met blood 2.1E'01
'Mercury 3.0E .01, 0.002 MCL neurotol!., kidney 2.0E-01
:-- Methylene chloride 6.0E-02 0.005 MCL liver 2.5E-03
0-
Nickel 2.0E-02 O. ! MCL body weight 1.5E-01
Selenilml 0.01 MCL CNA
Si Iver 3.0E-0:5 0.05 MMCl skin 5.0E'01
Tetrachloroethene 1.0E -02 0.005 MCL liver 1. 5E .02
Toluene 2.0E -01 1 MCL CNS, kidney, liver 1.5E.01
I, I, 1.Trichloroethane 9.0E-02 0.2 MCL liver 6.7E'02
Vanadilml 7.0E-03 0.21, HB none 1.0E+00
.. .. . - - - .. . .. .. .. . .. . .. .. .. .. .. .. .. .. .... .. - .. . - .. .. . .. .. .. .. . - . .. .. - .. - ... .. . .. . .. .. .... . ... -. - - .. .. - .. .'.. .. - - .. .. .. .. .. - -..... .. .... .. -... .. .. ... .. .... .. .. ... .. - - -
Liver Endpoint
Kidney Endpoint
CNS
Blood
Skin
SUM
6.0E.01
1.3E+00
:5.5E-01
1. 1E+00
-------
TABLE 23
INTERIM GROUND~ATER CLEANUP LEVELS(CONT'D)
Carcinogenic Contaminants
of Concern
Care. Pot!'ncy
Factor (oral)
(mg/kg-day)
C I C;ln- up
Levcl
(mg/U
Basis
Cancer Risk
Level
.- -...-....---....--... ..-..-.- - - -. ~
. . . - - - - - - - - - . . - . - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - --
Arsenic 1.8E+00 0.05 MCL 8.8E-04
Benzene 2.9E-02 0.005 Met 1 . 5f - 06
Beryll iun 4 - 3E +00 0.001 Met 4 .3f -05
1,l-Dichloroethene 6.0E-01 0.007 Met 4.2E-05
lead 0.015 Pol i cy( 1)
Methylene chlorid~ 7_5E-03 0.005 Met 3.8E-07
Tetrachloroethene 2_9E-02 0.005 MCl 1 .Sf -06
Trichloroethene 1.1E-02 0.005 MCL 5.5E-07
Vinyl chloride 1.9E+00 0.002 MCL 3.8E-05
.r--
--J
--- -- - - - - -- - - ------ - - - - -- --- - - - - -- - - -- - - -- -- -- --- - --- - -- ---- --- --- --- ----- -- ------ --- - - .----------
SUM
1.0E-03.
NOT E S :
(1) - Superfund Policy- Memo from Henry longest, Director, Office of Emergency
Response to Patrick Tobin, Director, Waste Management Division, Region IV,
Cleanup level for lead in Groundwater, June, 1990."
and Remedial
MCl - Maximum Contaminant level
SMCl . Secondary Maximum Contaminant level
HB - Hazard Based (noncarcinogens)'
CNA . Criteria Not Available
"MCl . Massachusetts Maximun Contaminant level
-------
o
,;
~:~agement of ~~gration ROD ar.~ 5~all be considered
performance standards for remedial action. If final cleanup
levels differ significantly from interim cleanup levels, EPA
will reevaluate the selected remedy and take appropriate
action to ensure that the cleanup levels are attained.
B.
Description of Remedial components
EPA's preferred alternative includes:
Installing a groundwater extraction system;
constructing inorganics and ultraviolet
("UV")jOxidation organics treatment units;
Extracting and treating contaminated groundwater; and
Discharging treated groundwater to Johnson Creek.
Each of these components are described separately below.
This alternative includes institutional controls that would
prohibit the use of groundwater in the contaminated .area
until cleanup levels have been achieved. Such controls
could include, for example, deed restrictions prohibiting
the installation of private wells in the contaminated plume.
This alternative also includes quarterly sampling of
monitoring wells around station No.1. These actions would
be implemented to minimize current and future risks
associated with the potential direct use of contaminated
groundwater, and would monitor any potential migration of
contaminants to station No.1.
..
Also included is the construction of an estimated six
groundwater extraction wells to intercept the entire width
and depth of the contaminated groundwater plume originating
from the Valley property (See Figures 7 and 8). The
locations of the extraction wells and treatment system are
shown in Figure 15, but the Iinal decision concerning the
location and number of those wells and the extraction system
will be made during remedial design. The total estimated
flow rate needed to interce~t the plume is about 400 gallons
per minute (gpm). During remedial design, the existing Mill
Pond extraction system will be evaluated for use to .
supplement or replace one of the six new extraction wells
proposed for this area.
As previously stated, groundwater monitoring wells adjacent
to the Chesterton property and Haverhill Municipal Landfill
will be sampled on a regular basis to ensure that the
remedial extraction system does not adversely spread the
contamination originating from these properties. Also, a
-------
=ackgrour:d ;roUndwat2~ £3~pling ~=o;=am for ~~~rga~ics i~
planned during the. remediation phases of the remedy. site
inorganic concentrations will then be re-evaluated in
comparison to these results. If it is determined through
background groundwater sampling that certain inorganic
levels represent background, then those inorganics will no
longer be identified as Site-related contaminants, and
standards for those inorganics would not need to be met.
Additionally, sampling of the surface water and sediments in
Johnson Creek and other nearby streams would be conducted on
a semi-annual basis to identify any potential discharge of
contaminated groundwater to surface water bodies. Exact
sample locations would be determined during the remedial
design.
This alternative includes a system for the removal of metals
in the extracted groundwater to an acceptable level for
efficient operation of the treatment process and to meet the
effluent limitations for discharge into Johnson Creek.
Under the representative process option, contaminated
groundwater would be pumped to a mixed equalization tank to
lessen effects of flow and concentration variations (Figure
16). Air would be diffused into the tank to convert soluble
ferrous iron into insoluble ferric iron.. The overflow from
the equalization/aeration system would be transferred to a
sedimentation unit (also referred to as clarifier). In the
sedimehtation unit, most of the suspended solids would
settle to the bottom of the unit because of the quiescent
condition. Flocculation and coagulation would be performed
prior to sedimentation to promote rapid and effective
removal of the suspended solids. The settled solids would be
transferred to the residual treatment system. Finally,
filtration would provide additional removal of suspended
solids to achieve the metal discharge standards and to allow
for the efficient operation of the treatment equipment.
To minimize sludge disposal requirements, a filter press was
selected as the representative process option for separating
free water from the suspended solids in the residual
treatment process. For disposal, the dewatered filter cake
(dewatered sludge) would be transferred offsite.
Classification of this material would have to be determined
during remedial design/action. If this filter cake is found
to be a either a listed or characteristic hazardous waste,
then it must be treated and disposed of in accordance with
applicable requirements.
The filtered water would then be subjected to a process
involving ultraviolet (UV) light and oxidation to destroy
TCE and other volatile organics (see Figure 17).
Pretreatment is especially important in the UV/Oxidation
process because turbid waters do not transmit UV light
-------
"
/
i
effec~ively. Additionally, ~e~als present in the
gr~~~dwa~cr in red~c== f=~~ (e.g., f===c~s ion a~d c~prcus
ion) could exert a demand upon the free hydroxyl radicals
(discussed below). Metals can also cause problems if there
is a pH shift during treatment which causes them to .
precipitate in the UV/Oxidation reactor. Precipitate
formation would increase the turbidity of the water and may
also coat the UV lamp jackets and be difficult to remove.
The oxidants are typically ozone and/or hydrogen peroxide.
The UV/Oxidation treatment process is actually a two-step
process. First, UV radiation photolyzes (breaks down) ozone
or hydrogen peroxide. This results in the formation of
highly reactive hydroxyl ("OH") free radicals. These
radicals are important because they are stronger oxidizing
. agents than either ozone or hydrogen peroxide .alone. These
hydroxyl radicals then oxidize (take away hydrogen by
combining with oxygen) the organic contaminants in the
extracted groundwater. Once the organics are completely
oxidized, the reaction products would consist of carbon
dioxide and water.
The treated groundwater would be discharged to Johnson
Creek. The estimated discharge flow rate of about 400 gpm
is within the normal flow iate that the existing stream
channel can accommodate. The discharge structure will
include measures to minimize potential erosion of the river
bed and will be designed to ensure that it will not cause
physical disruption of wetlands (if any) near the discharge
point.
The extraction and metals removal treatment component for
this alternative are very well established and of proven
performance. The L~/Oxidation process has been known for at
least 10 years and has been evaluated under the EPA
Superfund Innovative Technology Evaluation ("SITE") program.
The process is still considered an innovative technology, .
mostly because of the small size and number of the existing
full-scale treatment units.
The SITE project evaluation of the UV/Oxidation (ozone)
process revealed that at "preferred" operating conditions,
the process achieved removal efficiencies. as high as
90 percent for the total VOCs present in the groundwater.
The major $ite contaminant, TCE, had removal efficiencies
greater than 99 percent. Treatability testing would be
required to confirm feasibility of the UV/Oxidation process
and derive design parameters. Subject to this verification,
the process reliability of this technology is expected to be
good, based on experience with normal ozonation.
-------
After the cleanup levels r.~ve t;eD ~e~ and :~e remedv is
determined to be protective, the ground water treatment
system will be shut down. The ground water monitoring
system will be used to collect information quarterly for
three years to ensure that the cleanup levels have been met.
and the remedy is protective.
EPA will review the Site at least once every five years
after the initiation of remedial action at the site if any
hazardous substances, pollutants or contaminants remain at
the Site to assure that the remedial action continues to
protect human health and the environment. EPA will 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). .
FLOODPLAIN/WETLANDS ISSUES
When a site is located within a floodplain/wetland, or when
a proposed remedial action would affect a .
floodplain/wetland, EPA as lead agency must conduct an
assessment, which is integrated into the remediation
process. A remedial alternative that affects a floodplain
or wetland may not be chosen unless a determination is made
that no practical alternative exists outside the floodplain
or wetland. If no practical alternative exists, then EPA,
as lead agency, shall act to minimize potential harm or
avoid adverse effects to the floodplain or wetland.
-.
Appendix F of the Supple~ental MOM FS indicates that there
are certain limited wetland areas at the site and that a
portion of the Site lies in a floodplain. It is currently
anticipated that potential impacts to the floodplain or
wetlands which might occur are from: (1) the placement of
extraction wells for pumping and treating groundwater; (2)
construction of the treatment plant; and (3) the discharge
of treated groundwater to Johnson Creek.
A stgnificant portion of the contaminant plume is located
within the lOO-year floodplain. EPA has determined that no
practical alternative exists other than to locate extraction
wells within this area. However, the extraction wells will
be designed and constructed to withstand the lOO-year flood
and will be designed to ensure that the wells will not cause
physical disruption of wetlands (if any).
EPA has also determined that no practical alternative exists
other than to discharge the treated groundwater directly to
Johnson Creek. The only other alternative,would have been
the installation of wells to reinject groundwater in the
vicinity of the contaminant plume. However, reinjection of
treated water poses a risk that may exacerbate the current
-------
Q
I
XI.
sit~:tio~ ~y ca~si~g a~ ~~wanted redistribution of
cor.~amination. It may also conflic~ with, or increase costs
of the proposed extraction system. Reinjection would
involve additional construction of wells in the
floodplain/wetlands area. Lastly, this alternative was
rejected because of the added cost to install and maintain
the reinjection wells.
EPA has made a preliminary determination that the treatment
plant can be located outside the lOO-year floodplain. If
during remedial design it becomes necessary to locate the
treatment plant within the lOO-year floodplain, then EPA
will publish its determination for public review and
comment.
ENDANGERED SPECIES
The Massachusetts Natural Heritage Program was contacted in
September 1991 with respect to proposed remedy (as discussed
in the Supplemental MOM FS and the Proposed Plan) and its
possible implications for the rare and endangered species
visiting or residing in the Site area. Representatives of
the Natural Heritage Program responded that the proposed
remedy should not interfere with the two state-listed
species that are known to be present near the Groveland
Wells Site.
STATUTORY DETERMINATIONS
The remedial action selected for implementation at the
Groveland Site is consistent with CERCLA and, to the extent
practicable, the NCP. The selected remedy is protective of
human health and the environment, attains ARARs and is cost
effective. 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 uses alternate treatment technologies or
resource recovery technologies to the maximum extent
practicable.
A.
The Selected Remedy is 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. ~ore specifically, over the short-
term, the institutional control components of this
alternative would limit potential new contact with the
contaminated groundwater. This would be accomplished
-------
~h=ough inst~~~tional co~~=o~s t~at pror.:~it .~e use of
groundwater in the contaminated area until cleanup levels
have been achieved. Such controls could include, for
example, prohibiting the installation of private wells. The
continued use of activated carbon at Station No.1 provides
additional protection for public water users. In addition,
the extraction system would provide a hydraulic barrier to
minimize the potential for contaminated groundwater to
migrate toward Station No.1.
Over the long-term, the organic and inorganic contaminants
should be removed from the aquifer that extends from the
Valley property. Groundwater contamination directly under
the Valley property and the Chesterton. property, and
. associated with the Haverhill Landfill, are being addressed
under separate actions and should not be affected by the
extraction system selected in this Management of Migration
ROD. The result should be restoration of the aquifer and
unrestricted future use thereof. Most of the organics
should be destroyed at the onsite treatment system or
adsorbed into the sludge and disposed in an appropriate
manner.
Moreover, the selected remedy will result in human exposure
levels that are wi thin the 10." to 10-6 incremental cancer
risk range and that are at or below the hazard index of one
for non-carcinogens. More specifically, the remediation
goals for groundwater for both the organic and inorganic
contaminants of concern will be met. Finally,
implementation of the selected remedy will not pose
unacceptable short-term risks or cross-media impacts. The
remedy provides for on-site destruction of organic
contaminants in groundwater and is a treatment process for
organic contaminants that produces virtually no waste
residuals. Use of this technology eliminates possible
adverse impacts of organic contaminant transport off-site or
cross-media contamination.
B.
The Selected Remedy Attains ARARs
. .
This remedy will attain all applicable or relevant and
appropriate federal and state requirements .that apply to the
Site. Environmental laws from which ARARs for the selected
remedial action are derived, and the specific ARARs include:
Clean Water Act (CWA)
Safe Drinking Water Act (SDWA)
Clean Air Act (CAA)
Massachusetts Hazardous Waste Regulations
Massachusetts Drinking Water Standards
Massachusetts Groundwater Quality Standards
Massachusetts Wetlands Protection Regulations
-------
~
Massachusetts
Massachuset~s
Massachusetts
Program
Massachusetts Operation and Maintenance and
Pretreatment Standards for Wastewater, Treatment
Works and Indirect Discharge
Massachusetts Surface Water Quality Standards
Massachusetts Supplemental Requirements for
Hazardous Waste Management Facilities
Wetlands Executive Order
Floodplains Executive Order
Town Of Groveland Wetlands By-laws
Ambient Air Levels
~~bient Ai~ Quality Sta~dards
Air Pcll~~lcn Con~~~l Reg~la~ions
Surface Water Discharge Permit
-A discussion of the ARARs and TBCs, and the actions that
will be taken to meet these requirements may be found in
Table 24 of the ROD. A discussion of the major ARARs for the
Site follows:
1.
Chemical - Specific Reauirements
The groundwater aquifer is classified as Class II, a
potential drinking water source. The Massachusetts
Department of Environmental Protection has classified this
aquifer under the Massachusetts classification system as
Class I. groundwater, a source of potable wat~r supply. SDWA
MCLs, MCLGs, and the Massachusetts Drinking Water Standards
(MMCLs) are standards that apply to public water systems.
Because these State and Federal requirements apply at the
tap, .not directly to groundwater, MCLs, MCLGs, and MMCLs are
relevant and appropriate rather than applicable. In
addition, this ROD requires testing to identify background
levels for inorganics. If background exceeds these
standards, these standards will no longer be considered
appropriate requirements and would no longer be considered
ARARs.
2 .
Location - Specific Reauirements
40 eFR 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, loss or
degradation of wetlands. Section X.B. of this ROD discusses
how these requirements were taken into account.
-------
3 .
Actic~ - S~ecific Pecruirerne~~s
The remedy selected for this Site requires construction and
operation of a groundwater treatment system. After
treatment, this water will be discharged to surface waters
in accordance with the substantive requirements of Section
402 of the Clean Water Act. Because this is a direct
discharge of pollutants to surface waters, Section 402 of
the Clean Water Act, as well as the Massachusetts Water
Discharge Requirements, are applicable. Treatment will be
required to ensure the State water quality standards are
met. .
In addition, the groundwater treatment process will
generate sludge. This sludge (filter cake) will be evaluated
- during remedial design/remedial action to determine
appropriate off-site disposal. The sludge (filter cake)
will be classified (listed/characteristic) to determine
whether it is a hazardous waste. If it is found to be
hazardous, it will be disposed of in accordance with all
applicable regulations.
c.
The Selected Remedial Action is cost-Effective
In the Agency's judqrnent,the selected remedy is cost
effective, i.e., the remedy affords overall effectiveness
proportional to its costs. In selecting this remedy, EPA
first identified alternatives that would .be protective of
human health and the environment and that attain, or, as
appropriate, waive ARARs. EPA then evaluated the overall
effectiveness of each alternative by assessirig, in
combination, the relevant three criteria: (1) long term
effectiveness and permanence; (2) reduction in toxicity,
mobility, and volume through treatment; and (3) short term
effectiveness, in combination. The relationship of the
overall effectiveness of the selected remedial alternative
.has been determined to be proportional to its costs. The
projected costs of the remedial alternatives are:
Capital Annual Net Present-Worth
Cost O&M Cost
Alternative ~ ($/vr) ~
1 0 5,000 70,000
2 0 39,000 600,000
3 1,800,000 643,000 11,700,000
4 3,400,000 341,000 8,700,000
5 3,500,000 610,000 12,900,000
6 3,800,000 333,000 8,900,000
Alternatives 1 & 2 do not comply with criteria of the NCP
and were not given any further consideration in terms of
-------
~
cost effectiveness. Alternatives 3 through 6
with the crlteria of the NC? Alternatives 3
expensive than the remaining alternatives and
eliminated from consideration.
would comply
a~d 5 are ~c~e
were therefore
Alternatives 4 and 6 are similar in terms of costs, and
offer many of the same benefits. Alternative 6, however,
is the only alternative that provides for on-site
destruction of organic contaminants in groundwater and
utilizes a treatment process for organic contaminants that
produces virtually no waste residuals. That treatment
process provides the longest term effectiveness and
permanence by destroying most organic contaminants, achieves
the greatest reduction in toxicity, mobility, and volume of
those contaminants, and most effectively eliminates possible
- adverse impacts of organic contaminant transport or transfer
off-site while being equal in cost to Alternative 4.
For the foregoing reasons, EPA believes that Alternative 6
is the most cost-effective alternative.
D.
The Selected Remedy Uses Permanent Solutions and
Alternative Treatment or Resource Recovery Technoloqies
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 uses permanent solutions and alternative
treatment technologies or resource recovery technologies to
the maximum extent practicable. This determination was made
by deciding which one of the identified alternatives
provides the best balance of trade-offs among alternatives
in terms of: (1) long-term effectiveness and permanence; (2)
reduction of toxicity, mobility or volume through treatment;
(3) short-term effectiveness; (4) implementability; and (5)
cost. In evaluating these trade-offs, EPA emphasized long-
term effectiveness and permanence, and the reduction of
toxi~ity, mobility and volume through treatment. It also
considered the preference for treatment as a principal
element and the bias against off-site land disposal of
untreated waste. Finally, community and state acceptance
also were considered.
Lonq-term effectiveness and permanence. All of the
alternatives (except Alternatives 1 & 2) provide similar
degrees of long-term effectiveness and permanence in
reducing risks presented by the contaminated groundwater at
the site. In each of those alternatives, no significant
residual risks should remain' in the groundwater.
Alternatives 3 through 6 each would remove or destroy
approximately 99 percent of the site organics by treating
-------
ap;~cxi~a~~ly 5.3 bil:ion gallo~s of cc~~a~ina~e~
groundwater and destroying or removing 6,600 pounds of
organics. Each of these latter four treatment schemes is
irreversible. Only Alternative 6, however, provides for on-
site destruction of organic contaminants in groundwater and
utilizes a treatment process for organic contaminants that
produces virtually no waste residuals. Of all the
alternatives, the organic treatment process used in
Alternative 6 provides the long-term effectiveness and
permanence because it destroys virtually all organic
groundwater contaminants. Consequently, Alternative 6
provides the greatest long-term effectiveness and'
permanence.
Reduction of toxicity. mobility or volume throuqh treatment.
Neither Alternatives 1 or 2 would provide additional
treatment resulting in a reduction of toxicity, mobility or
volume. Alternatives 3 through 6 would remove or destroy
approximately 99 percent of the Site organics by treating
approximately 6.3 billion gallons of contaminated
groundwater and removing or destroying approximately 6,600
pounds of organics. Each of these latter four treatment
schemes is irreversible. Only Alternative 6, however, uses
a technology that permanently destroys (not merely reduces)
virtually all organic groundwater contaminants. For that
reason, Alternative 6 results in the greatest reduction of
toxicity, mobility or volume of the contaminants of greatest
concern.
~
Short-term effectiveness. Alternatives 1 and 2 are
preferable for their short-term effectiveness, but under
those alternatives cleanup objectives may never be attained.
Alternatives 3 through 6 would all be similar in some
respects for their short-term effectiveness. Alternatives
3 through 6 all would involve a minimal increase in risk'
because of the construction and operation of" an extraction,
treatment, and/or discharge system and would require an
estimated 30 years before achieving compliance with remedial
action objectives. Alternative 6, however, utilizes an
organic treatment system that most effectively eliminates
possible adverse impacts of organic contaminant transport or
transfer off-site, which occurs with Alternatives 3, 4 and
5. As a result, in relation to Alternatives 3 through 5,
Alternative 6 is most effective in the short term.
Implementability. Alternative 1 is simple to implement and
undertake since it requires no treatment or additional
monitoring. The technologies required to implement
Alternatives 2 through 6 are readily available, reliable
and easy to undertake. In each case, migration and exposure
pathways should be effectively rernediated. Alternative 6
utilizes an innovative treatment process for organics, and
-------
u
v
treatability testing would be required to c=nfi~~ the
feasibility of the use of that technology in remediating
organic groundwater contamination at the Site. Alternatives
3 through 5 utilize more established and predictably
reliable technologies for the treatment of organic
contaminants, but EPA believes that the reliability of the
treatment technology for remediating those contaminants in
Alternative 6 has been adequately established.
Alternatives 1 and 2 are the least costly alternatives, with
total costs of $70,000 and $600,000, respectively.
Alternatives 3, 4, 5, and 6 have total costs of $11,700,000,
$8,700,000, $12,900,000, and $8,900,000, respectively.
Thus, of the four latter alternatives,. Alternatives 4 and 6,
- the selected remedy, would involve the least total cost.
Other Factors. Alternatives 3 through 6 all provide for
treatment as a principal element. Alternatives 1 and 2 do
not conform to this preference.
Community and State Acceptance. Based on its the review of
the remedial investigations and feasibility studies for the
Site, and the Proposed Plan, the Commonwealth of . .
Mas~achusetts concurs in the selection of EPA's preferred
alternative. community reaction to Alternative 6, the
preferred alternative, has been mixed. Two commenters
specifically supported EPA's preference for Alternative 6.
Other commenters stated that Alternative 2 (institutional
controls) or Alternative 4 (air stripping) should be
selected. A number of commenters stated that remedial
action should be focused only in the most contaminated
portion of the plume.
Balancinq of Trade-offs. Based upon the foregoing factors,
EPA believes that the selected remedy provides the best
balance of trade-offs among the alternatives. Alternative 6
was selected because it provides for on-site destruction of
organic contaminants in groundwater and utilizes a treatment
process for organic contaminants that produces virtually no
waste residuals. That treatment process provides the
longest term effectiveness arid permanence by destroying most
organic contaminants, achieves the greatest reduction in
toxicity, mobility, and volume of those contaminants, and
most effectively eliminates possible adverse impacts of .
organic contaminant transport or transfer off-site.
-------
'.
T~ 3alec~~d Reme~y Sati5fies tje Prefe=~nce fo=
Treatment which permanently and siqnificantly Reduces
the Toxicity, Mobility or Volume of the Hazardous
Substances as a Principal Element
The principal element of the selected remedy is the
management of contaminant migration. This element addresses
the primary threat at the Site, contamination of groundwater
by volatile organic compounds. The selected remedy
satisfies the statutory preference for treatment as a
principal element by extracting and treating inorganic and
organic contaminants. The selected remedy provides for on-
site organic contaminant destruction.
E.
XII.- DOCUMENTATION OF NO SIGNIFICANT CHANGES
EPA presented a proposed plan (preferred alternative) for
remediation of the site at a public meeting on July 9, 1991.
The preferred alternative included:
1.
Installing a groundwater extraction system;
2.
Constructing inorganic treatment and ultraviolet
("UV")jOxidation organics treatment uni.ts;
3.
Extracting and treating contaminated groundwater;
and
4 .
Discharging treated groundwater to Johnson Creek.
No significant changes have been made to the preferred
alternative as a result of state and community comments
XIII. STATE ROLE
The Commonwealth has reviewed the Supplemental MOM RIjFS,
the Proposed Plan, and the Risk Assessment to ensure that
the selected remedy is in compliance with applicable or
relevant and appropriate environmental laws and regulations
of 'the Commonwealth. The' Commonwealth concurs with 'the
selected remedy for the Groveland Site. A copy of the
declaration of concurrence is attached as Appendix B.
-------
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APPENDIX A
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MONITOR' He NP.LLS
SUMMARY or r I NST ReMIND
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T,lchloro.then. 'U 'U 0/1 - -- ... 'U 1/1 ... 10' 1.1 1'1 ' PNCL IF,
-.--------- -----.--- .. ----- ---. ..--- -.. ... ---.-.---- - .-- ----'---'- -------- -- --------.-.--.
Tet'8chlo.o.'hene 'U 'U 0/1 -'- ..- 'U 1/1 )0.11 ID' II.' pO. 'I ' PNCL IP'
--'---'-- -- ----- --.-.-- --- --- ----- -- -. --.-
AI...ln". J4, '00 -.. III n, )00 )1, )00 --. )/1 111.1\,100 10,'" '0.)00 188CL IP'
-_. ----- --'--' - ---- ----- ----- --- --- - -~._.-
A..."le II. J - -- III n.' II.' .'- )/1 '.I-SS.I n. J '0 .IP-
---- - --- - - --. ---- '- ------- ---- - ---- --- -----------
'0.1". IlJ ..- III IU lel ... III )1. ).)\1 IU 1,000 ...-
-.- - ----- .._- ---- .--- ..-. -- -----------
C.lctu. .. ,100 - -- III 14,000 14.000 ... III U, 000. )41,000 II., tOO .""011
- --- - --_..- ---.-..- - -------- ---- h - ----- --. -.. --- ---.--..-. .---- - -.-- ---------- ------ ------- -_._-
Ch.o.tu- ".1 ... III 110 I, I '0 ... 1/1 10.'.IU lOJ. J '0 .IP-
.------- --------- --.-- - __ 'h .-.------ --. - --- _n_----- -.- - ..-.- ----.---.- ----- --.-----.---
Cobolt n.' --. III J4.1 )4. I - --Ie, 1/1 10." II.' 10' 20 .""011
--.-- -- --------. --. ---.- -.-.---- --.-- - ---- ---. ---- --- ----- ---
(.Opp.' '6.IU ,.. IU Oil ... I . .U. If . IU 1/1 .0.) u 1,100 PNCL IP'
- -- ----'----- ---- --- ---.- ---- ----- ------. - -.-.---
I,on II, 100 --. III '.,100 '.,100 JOIU 1/1 JJ, .00. ",000 ID' 11,11' 100 8NCL I.'
. - -. .-- .----- -'- -------. -'-- -------- -- -----------
I...d n.' - -- III .... .... I.IU 1/1 n."".' ID' )J.' '0 .IP-, , 10'
.ourc.. PtIC L tp.
.... - -----
118,nool... 1',600 -- - III 1),100 I ), 100 - - - UI 12,'00-10,000 n,no .",,011
.n -- --
"an,.n... 960 " - III I, liD I, JlO '.tU III )...." ID' n. ,o 888CL IF,
-
"Ie'" n.) --. III lOt 10\ --. J/1 10.'-1'0 n.1 100 PllCL IY.
---- -~--- .- -. --
POI...au. 1,"0 - -- III ',"0 ',"0 . -- III 1,110-',"0 J,nO .""011
.-- ... _u...'--- -~-- ---- --- ---- --- - ..-
S.a.nlu. U.r U.r Olt ... ... u.rlc:' III .. I n.., 10 PNCI. I.'
- - --- - ._- --' ----- - .-. --'-- -----'--' ---- -- --.-- . -. .--.-.-.
50dlu. " UO --. 'II 11,100 !I.IOO .. 1/1 I, UO.I,OIO 1,'If 10,000 -8L
-------' ---.-- -- .--.-.'. ----- ---_.-- ----- -. -- .-. ---- -.. -- ----- -- ---- -. - -------~----_.-
V.nadl... \t. I - -- III "., ". ~ ... III 10.1' n.1 IDI It.t """oIl
- ---- - .--- -- _. --
line ... . -- III III III 1l.IU III IOS.)6I 10, 144. J ',000 INCL cr.
lu,/L'
I",/L'
lu,/LI
l"q/L,
(",/L'
I",/L'
lut/LI
t.../LI
POOR QUALITY
-------
Tilh Il' I
ftONITORINC WP.LI.S IN ARM A - TAR CRP.STEATON rllClI,lTY ARM
SUtUU\RY OP PIRST ROUND (PP.BRUARY 1990) GROONOWIITP.R MONITORING
GROVP.I.IINO WP.I,I,S S I TP.
SIIPPLP.MP.NTAL MOM R I/PS
GMOV£LANO, MASSACIIUSETTS
PIIGP. TWO
REStJI.TS
I Sh.llow Ov..bu.cI...
Ih.II.. '.cI.oc.
-'
..,__,., ..c.,.ouncl ...".., IPr.qu8"cr .....,. o' lI.n,. o. ..8Qu8ncr ".n,. e' 'I.......cJ/C.IIel I.
....,18 o' Po.H"'. ."....,. I..pl. o' Po. HI... ......,.
Qu.nt it.I I." Ou...t Itet 10..
LI8Iul'» 08tecllon 081.ctlo". LI8...1I1 08t.ctlo.. 08t..,llo...
.I.,.,bo...t. u -- - III U U I.OU '/1 " I'.' .....11
- -- -"- - ----- --- ----- --- --
Chlo.llI. Il - - - III U )J --. III n'lI - '1.1 no .IICL Irl
------- ---- .....-- ------- ------- ---- --- ---
IIlt..t..llltr It. .., ..- III 0.11 O.lI - -- l!l 0.1l-0.'
I.. III o,n .0 PllCL 1.1
~ --- ~--- .----- ----- .- ---- ----
5ull.'. 100U IOU 011 .-. -. - . -- III '.,-u II .00 PllCL ITI
.---- -- --- ------- .--- ----- ------- -..- - --. ---.---.- .---.-
Tol.1 DI..ol...1I Il' --. III 101 IOJ --- III III - lJO It,.' '00 IIICL
501111. If'l
. - -' - --- ~---- -- -----
Tolel lu.penll.1I 1,"0 ... III .11 .11 -- - III IU'IU HI.' ......11
501111.
1../Lt
.../L J
I../LI
1../1.1
18.,/11
I.../LI
I../LI
.../LI
III Sa"'pl~ quant Itat Ion I ""It. ISOL) pr~!J~ntf'd for p.r..~t~r. rt~port~d 8. 'nol df't, f'ctt''' I.n on~ or !!lOre
Inor9anlcs. thl!' only SOLs pr~sent~d arl!' thost' which dlff~r from Contract Reqllirt'd Ot'tt'ctlon Limit.
In App~ndi. A.
IC) Results lor one or morl!' lIampl~s In thl!' dala 9rouP w~r~ reported ae non-delecl~d "I the CRDI..
.."'pl~. In . data 9rouP. POI
eCRDLs). CRDLe .re pr~&~"tl!'d
IP) Plopos~d.
IF') Pi na I .
IT) Tentative.
I 0) R~lIu It. e 01
duplicate &l~..
1/
IIJ
p.r.meter wa& not dl!'tect~d. V.lue pr..~ntl!'d i. the .."'ple qu.ntltatlon limit.
Th~ param~ter wae analYI~d for. but not dl!'tl!'ctl!'d. In on~ or mor~ e.mpl~s. The sampi~ quantltlatAon lImit (the CROL) I. ~.tl~.t~d.
Nllvall
OWEL
PHCL
SHCL
NIPOWR
Not Availabl~.
Drlnkln9 Wat~r £qUlv.l~nt Ll!'vel.
p~dl!'ral Saf~ Drinking Water Act ISDWA) prl.ary "a.imu.
p~deral SOW~ Secondary Ma.A",um Contaminant L~v~l.
National Int.rim Primary Drinking Watl!'r Rl!'9ulatAon.
Contaminant Level.
POOR QUAUTY
-------
~
'-'
'1'.11>1('
!.
I 5h.""'v U".,hu.ctwn. ~h.lln. O".,"'u,d.n,
.......dlll,.I, 00"'''9' ect. ent 01 Yol'., 11111 Pond Ih..
I Par.."'''' ellc'cp Gunet ...n9. 01 , t "'1,..,.r, "on.,. 01 ...n.,- 01 r'.'1u.nc, "on,. or Slondo,d/C"'O"O
50.p'. or '0.111.0 Av.,'," 5..(110 or '0.111.. aY8'8'-
o"onlllo,'on O...nIIUllon
1.1.1 uC II IIII.ellon 1181.",lono LI.II.C II lIIucllon 0.18""On8
SItAI.LON OVF.f\RIJROf:N f'ONITORING WF.I.I.S IN ARFA B - TRII VAI.LF.Y SITE/MI.!.L POND
SUMMARY OP F'RST ROt/NO (t'EBRIJARY 1990) GROUNOIfATI':R f'ONITORING RESULTS
. GROVP.I."ND Mr.I.I.S SITE
SUPPI.P.IUNTAL MOM R I /PS
GROVP.t.AND, MASSACRIJSI!T1'S
AAP.A
i,.I'DI"hlo,n. \11 ...00 111 .'0-...00 I.en \U )/1 I.. I." '0/100 ch/'''''o ft4C1.
.then. II. 'I I"
IT"rhlo.o.t...n. "I J/I .,800 - ., ,000 8.100 'U \/1 ..,. I). I \ ...c L I"
i In. 8'
\ Me' t1r 1_,.. \U 1/8 0.' 1.11 "Avel'
1011 \0011 I)OU 011 . - 14U
Chlo,'d. 10."
'''l..'''inu... )4 , \00 '''' _.- .. . 111 nl. .0,100 10,1 J6 \0. no IMe I. '"
-
, Ant 1880"r . _.Iel '"" .- - .., ...C'" 10 n.. 13.' '0/' PJlCL I"
I
I ",..nl" "., "" ." .., ... .--Ie' '/1 41.' 31.. '0 .IP-
,,,.. lu. If, "A " '" ." ... 10 '.J'U' fl. J 1,00' ""IMII
I...r r .,,",, -., Ce' "" ." ." ... .., C", '/1 ,., ' I '...rL C,.,
-
rOld... ",100 "" .. ... ... lit If ,100.11,000 u,no "".0'1
f.'hr 0.1 u.. 19.1 ".. ... ... " .1'" '0 .0) ,. '0 .IP-
..
I Cob. It n.' "A ... ." .. . .. .1" 1 10 III 10.' "".01.
IcoPV.' '..'U "" ." ... ... ,..u '/1 It) .48 1,10' PMCL C.,
lion J9, )00 "" .. . ... .., ... III ....11.,"0 11.,"1 )00 'MeL C',
-
'0 II) ,..1 '0 .,,-. , 18\ 80U'C..
1.~04 n.' "" ... ,.. .. JU ...rL C.,
"o,n..'''. ", .00 "" ... ... .. . . -. III ).110.18,108 II, ..0 .".011
...n.'."... ..0 "" ... ." .. . ... ./1 In ..'.1 10 8tK'L crl
-
M..cur, ...Ie' ... ." .., ... .UJ 011 ... ... I ...rL C.,
(ug/I.)
Cug/L)
(ug/L)
(ug/I.)
(ug/L)
Cug/L)
Cut/I.)
Cu,/L)
)
POOR QUAL\TY
-------
,
";1 hi.,
/
SIII\I.I.O'" OVp.RDUlmt:N MON I TOR I.JG NP.I.LS IN
SI/MMARY OF FIRST ROI/NIt IFP.HRI/ARY 19901
GIIOVP.I,I\NU NF.I,I.S S I TP.
SI/I'I'I.F.MP.NTI\I, ..oM, R 1/f'S
(;IIOVP.I.ANU. MJ\SSI\('IIIISt:TTS
1'1\1:£ TIIRF-P.
ARI'.A H - Till': VAI.LF.Y SITE/"II.I, PONU ARf'.A
GROIINIIWI\TP.R MONITORING RP.SIJI.TS
-.
!l;h.t'flV n......htl.den. ~h.lln" Ch,.rhn,ct.n.
,.....dl.,.a, t.UVII'" ."Ient 01 Vol", "III Pund a,..
r.,.",,,,., ".,'kql nund 118n91 0' "'."II.n,-, "8n"8 01 A8nq. 01 "on91 0' 51.nd.,d/C,III.lo
So",,,11 5...,,10 '..."u.n(",
nl po.a"ve """....q. nl '0.11 hI a..r8'8
Ou.nl ..., Ion 0..8nl 1,.,10"
LI.'t.fll 0.......1 Ion o.,.ctlon. LI..II.III o...ctlnn Detect 1o",
]
...
COD "A "" '-' III J1 J1 ""..11
80llS "A "" ., ... III U, IU ""..11
Hardn..., TolIl "" "" -.- -, III ".1 ",1 MA".II
TOI.I III~.llnll, "A "" . -- . " 1/1 n n ""..11
-- ."
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18tq/L)
(819/1.)
(_1)/1.)
1819/1.)
(819/1.)
C8MJ/L)
C8CJ/L)
~
t I,
s"mplt' 'Iuanilialion Ilmils I SOL') pIP5pnl...) fOI parampfpI8 rrrn,l..d aB "no I df'l..clprl" In on. or mor. Saalpl.8 In a dala I)roup. for
Inorqanics. Iltp only SO!.!I ,Ht'spnl..d "I" llIOAf' "hlch dlf(p, f.om Coni .<1("1 Rf"IUIIf'd Of'l.cl Ion LImits ICROLs). CROLs .r.. pr.8pntf'd
In Apppnrli. A,
("I
RrsultR (or onf' or morf' Rllmplf's In th.. ""'" qrolJp "f'rf' rf'porlf'rI as non-df'teclpd al lhe CROL.
II
11.1
I'lullmf'Ipr "all not d..tf'ct..d. Valli" rr......ntf'd I. Ihp s."'ple '1lIlInlltatlon 11",11.
Tht' par"mete~ "
-------
u
"1';1" Il' :'
SIII\I.LOW OVP.RBURDP.N MONITORING NEI.I.S IN
SIIMMARY OP PIRST ROliN" (pt:nRUARY 1990'
GROVP.I.ANO NEI.LS S I Tt:
SIII'PI.F.Mt:NTAL MOM R liPS
GROVP.I.ANO. KASSACIlIISP.TTS
"AGE 'nf()
ARFA n - TH£ VALLBY SITE/MILL POND "RP~
I:ROIINI,"ATF.R MONI TOR I NG nt:SIII.TS
Shellnv nv.,bu.d.n, !;ho'io. Overhuu'.n,
1.._dlo'.I, bovnq. ad'.n' 0' V.II.., Mill Pond A,..
rar....'.. ..r.qrol.nd Ran,. of , '.'I".n("r "."9- of ".n9w 0' f',p'1u.nc, lI.n,. 0' S..nd.,d/C,I.e.l.
5..1'1. ,,' po.ttlve "v...q. 50...1. 0' '00 It he A....,.
Ouon. 1I.llon Ou.nlll .llon
LI.IUIiI D....c' Ion Delee, lone LI.lulil Delecllon Del.cllon.
J
IIlc'.' '6. J MA ..' ..' leI 1/2 nl II' 100 PtK'L 1"1
..
Pot...lu. 6."0 Mil ..' ... 21l I.UO.',))O I. '" .A...II
Id .
S.'.n'"," 1111 ... UJ Oil . -- .-. 10 PM(' L 1"
_n-
Sihu .4 c I IIA . -- .. I.'U'IO.IU 0/2 . -- u. 'O ""-
t Sndlu.. '.'00 1111 ... ... ' - . l/2 1,'10-'. no I.'" 20.000 _L
'vaned lu. ~6,J IIA u' . -- lei III ".1 St.. ."...11
Illne ..
10' IIA ., ... I,.,u 'll 1,'00 1."'.' '.'00 IIICLC r I
(119/1.»
(u'J/L»
(u'J/L»
(u9/1.,
(u(J/L»
(u'J/Lt
(uv/L»
(uv/L»
le'ca'bon... 12 Mil ,.. ,.. ... 21l JI." tr.' ."...11
--
ICh1o'ide 12 "" .. ... -- . '.OU 1/2 J' Ia. 1 n. IIICLI'I
1.1".'.'~lt'.I. ..
... MA ... ... -- - l/2 '.11-0.' CI.' 10 PtK'LC"
..
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1"01.1 DI..oh.d Il' IIA . .. l/I ".111 ,a., 'DO IIICL .'1
'olld. ... ...
"0101 5...p.nd..d 1,880 IIA 1/2 ,U.I,'IO Ill.' IIA...II
Solid. ... ...
"01.1 O"enlc "" IIA . .. ... .,. ... 1/1 .... '.1 IIA...II
c.. bon
..
(-giLt
(_giLt
(-.,/L»
(-q/l"
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(18CJ/Lt
(8CJ/Lt
(8CJ/L)
POOR QUALiTY
-------
Tdhl cl
OVF.RRIIROF.tf/~H'\I.I.ow IIP:IIROCII MONITORING WP:LI.G IN ARP'.J\ B - nip. VALLP.Y I'UTE/MILL
~IIMI\RY UP' 1'1 RST ROUNO I rr.nIlUAIlY 1990 I GROIINOWATr.R MONITOR I NG RP.SUI.TG
GROVIlI.AND WP.I.I.S SlTft
surPI.p'.Mp.NTAI. MOM R I / P'S
GROVr.I.ANIJ, MASGACHIISP.'I'TS
IIY-FoP
POND AA P'..A
0..1' 0....bu.d.n/Sh81Inv lod.o~. In tho 1-."'.'. 0..1' Ov..h","on/Sh.llo.. '.d.o~. I.,on" 'h.
VI~ Inlt, 01 Vall., end the ~ohn.on Cr..' ,....,10'. Vlrinli, 01 30hn80n C....
Deop
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58.101. a' P08ltho a"..aq. S881p18 o. P08ltlvo A.....,. "''' '0'
OU8nl1l8t Ion Ou.nl I 1.lIon
LI.I..II. Del.cl Ion 081.~,Ion8 LI.I...., De'.~llon DeI.~.lon8
I,I-Olchlo.o-
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-------
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.------
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-
--------
---...
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POOR QUAUTY
ORIGINAL
111
luq/LI IU9/LJ ("'J/LJ
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u_-.- -- .- - -- .-- - - -.-----
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SIIMMARr Of" 1"1 RST ROIINII II"I';RRUARY 1990 I GROIINIIWIITr.R MON' TOR I NG IU:S"'.TS
(amVF.'.IINU "1';'.',5 S' TP. '
S\JI"'..t~F:NTIII, MOM R lip'S
(amVt:..ANIJ, MASSArnIlSF:TTS
I'A(:F. TWO
S' TF./M'I,L I'(INII ARP.A
n..p OV.,bd,d8n/5h.I'ow ..droc' In the I..~dl.t. n..p Ov...burden/!\h81Iov ..dlocll "'0"" 'h.
Vlclnll, 0' V.I", .nd 'he .Johnlon (',... ,......dl.'.8 VI'"lnll, o' .'ohn80n r.. ..,
De.p
P.,,""'.' ',~.,,'ound ".n,1 0' ".' ,."nrr ".n'8 0' ".nq. 0' ".' U.O,., lI.n". 01 ..eI. oc. 1'.nd.leI/CI't.,I.
S..pl. o. .081,1.,1 "v...aq" 5..,,1. 0' Po. II h. "".'891 ...., 101
Qu.n' ., .I'on Ol'8nl I tat Ion
LI-IlI'" DI'lctlon D.'ectl"n. 1.1_11.'11 DeUcllon Det.cllonl
',on J., JOO -' J/I I, nO-n,600 10. "" -- 1/1 .,. ,000 I,. ,000 1,410 JOO IIOCL .r,
-.-. -- --- --- -- ---- - -- -- - ---------- - .-
t ...d 1\.. '.~U 2/1 ..0. 20.' 1 I .' III 61. 2 ".2 2. IU ~8 ".-: . CIt
.ourc.. .-ca. CPI
- -- --. --- -- -- - - . _u. -- - .-- --- -" ----- --- ---- --- ------ --.--.
...,n..lu", ",600 J/1 ',190 II, 100 .,011 III n, 100 n.loo IJ,.OO 1111...11
..-- ---' ,,- -- - ._..~U__. .- ---- --- --- -.. _U'---' - . -.-.- - - .. ---. .---.-. ------ --- ---.--.- ----..---- -----.
".n98n... 960 -- 1/1 HI-J,O" .\2 1/1 5, JlO '.140 Jt " 11Iea. I"
-. ------ .. -.-.- ---. --- - -- --.---- - ..-- - --- -------. - -. ---- -- -" --- .- --. .- --- ---...- --' -----.-. ------
III~'" 96. ) .- J/1 n. '.n. ) 11.9 1/1 JlO 140 .1.. 100 .-cL CT,
- _ 'n -- -- -- .-.- -- - .-...- ----- ------- ._-- - -- -- -- - " - -... .-.. ---. ---- ----- '- _._-- --- -..-.. ---
Po,...'u", 6,.'0 -- )/1 2,"0",950 J, IIJ 1/1 ',110 '.110 ',9" 11....11
- '" - -- . --- --.- -- .. ._-- -- --.--.. .----- .-----.--. .-_. -- ... - - --- -..- -.
S.a.nl".. 1<'1 1<'1 III ). ) , , ..., 011 -. II,) " Pw.L CP'
- -- - -- ... --
SI I.., 1<'1 Cd Of) '.'U 011 -- -- .... I'.'U " 111.-
---- _uu ". --- .-- - -------.-- ..-... -- ._- -- .. ------ --_.-.- --......-- -- -_u_.--.--.---
Sod'u.. 'I, 110 Jf) J), '00- II 100 III IJ, JOO IJ, JOO )4,"0 10,000 D118L
",.00
--.. -. - -- ..' --- -- .- - -- -- ._-- .---- - --.-. . __h -- --.. --. --
venedlu'" ,.. 1 .1'" III .. . ".2 1\. J III '0.' '0.' --I" I 1111...11
--- 00 -- -- .._u .-.-.-. -- .---- -- -- --- --. U'. --- -- -- .------..-- ----.- ----.- --_.-- --------
IIn~ ... JI. JU - 5IU Of) ... -- III U) UI JlU ..0.0 IIOCL Ir,
--
,ug/L)
lug/L)
IlIq/")
IlIq/l.)
III'J/L)
,uCJ/L)
,u'J/L)
,utl/L)
--
8h:.rbon.'. 6l. --. Jf) n.1I ~O. ) 1/1 ..-It ...~ .,O 1111...11
- _..- -.---. n' -. ._----- ._---- ._. --- 00' --. -- ---. ..--.- -_u- .... -.---.-.'---'- ----- 0_._..---'-.- --- --- --- - n
Chlo. lei. IJ Jf) U-6I ".2 5.0U IfJ '.0 '.J I.' no IIOCL cr,
---.------ -- --- - --- -- -.----- _..- -. --- _0--'------.-- .-.- ---. ---- ---
...,..,.."It..,. I .. _..- Jf) J.'-'-J 5.6 .-.- JIl 0.01-0." 0.0. 0.' 18 PlICa. 1.1
--' -- .-- --- --- -- .--. - -- . ----- ------- -- -.--- ---- ._- ------....--
S"lIlt. 100U -_.- Jf) JO.14 U.. .... 1fJ non u.~ n 600 .-cL CT,
. -_..- --.----- ---- -.---- -' -' - -- --.---- ----.-- - -- .---.---. - -- --- --- ._-- ---- ---
Toul Dlno....d 119 .-.- J/I In-Jn 2n ..-. JIl It-In n.' 101 "0 llOCL Ir,
Sol lei.
18q/l, )
'18CJ/1. )
'18q/1.)
'IIICJ/L)
18q/L)
18CJ/L)
'18CJ/L)
18CJ/L)
POOR QUALITY
-------
l;ij, Il'
OF-P.P OVr:RRIIRVEN/SII'I.I.I.oM DEOROCII MONITORING NP.I.I.6 IN ARM B - mE VlU,LP.Y
SIII'IMARY OF FIRST ROllNII (Fr:nRIIARY 19901 GROIINIIWI\T!':R MONITORING Rr:StII.T9
GROV!':IJ\.ND "RI.LS S I TP. .
SIII'PLF.MP.NT'U. MOM R I/F6
GROVP.I.AND. MASfoACIIIIS!':TTS
PAGP. THII!':P;
SITP./MILL PONO ARF'"
-
P~.p O".,bu,d8n/Sh."nw ..tt.Dd In Ih. I...d,a'p "...' 0"., hurd.o/Shel'ow ..dror. ..,Dnd Ih.
VlclnH, Dr V.IIe, .n" the ~ohn.Dn C,..k I...dt.t. Vlrlnll, Dr .JDhn.Dn C,..,
De.p
P.,...'.r ..~II,'ounci ".n,. or. "8"".n.., ".n,. Dr ..098 or F..quenr, ".n,. Dr ..d.ocll 't.nd.,d/C.lt.,'.
'..pl. Dr '0.111.. a..,.q. 5..",. or '01" Iv. A.....,. "'II 10J
Quont 111110" QUln,lullDn
Lloll.ll, O.hc,IDn De,.ct IDnl LI.II...I D8teetlon Del.cllonl
TDIII Su.pentt.d I 440 II' 6 .0' 164 I I ' J/J lJ I .lIO ." .. III IIA..oll
Sol Id. '
----- - -- -- -.. -. .. - -.. ...- U ,... .. uU -.-.------ -.. --- ------------ -,
Tot.a 0lq8nl£" IIA IIA '/.1 1. . J. I "II ....1 I
c., bon
..- .--- .. .. " - .-. -' " .. .. -".-. ---- ----- ._------ --- ,-_ ...
COD 1111 1111 II' n n IIA "",,11 I
___.0, - --' - ... ---- .. --.-.- - ---- _.-. _. . '---'. ------ .--- ------ - . --- ..---.------ -...
.OD~ IIA 1111 III 8 . "" 11"...11
.. .. ---- " -- -. .- " __40 ...- . -.- - .. .. .. .. -- ._---- --'- --,. .... -..--------
Totel ..'.1 I nil, 1111 1111 II' " " If" IIA...I I
- - --- ... ... - .. - -.. -- .-. "- - .---- - ---. ----- ._-- ._----- .- " ..-. -..------- -
Sui ' Id.. 1111 IIA . . ou 0/1 - ' If A IIA..II
..-
(8q/L)
(I8CJ/LI
.-q/I. t
(I8CJ/LI
(IIMJ/LI
(8CJ/L)
(8CJ/L)
(8CJ/L)
C I)
Samplp. quantltatlon limits ISOLt prt'spnlPd for paramp.tp.rs IpportP.d It" 'not dp.tp.etP.d' In a 8amplp.. For Inorqanle.. thp. only SOL!!
prp.sp.ntp.d arP. thosp. which dlff.. from Conlract R"qulred O..lpcliun Limite (CRDI.e). CRDLs ar. prp.8p.nted In AppP.ndl. A.
Onp ur mort' sam"ll'!! In Ihp. ",.ta CJIOUI' "1',0' IPportl'd as non.,lpll'r:tP.d at thl' CROI..
Ie)
(0)
IPt
If')
IT)
Rt'su 1 t s of
Plopo!!p.d.
Pln..l.
T,."t ,,' Ivl'.
duplicatp. samplps.
II
"
IIJ
Poram.tP.r "a9 not d..t..ct..d, V.lu. 1'......."11''' la thl' lampl.. '1"...'1 Ita lion limit.
Data I..jp.ctp.d durlnq validation. .
Thl' paramp.tP.r was analyz..d for. but not "plpelp.d. In onP. or morP. samples.
Thl" Ramplp. quantitatlon limit Ith. CROI.I 19 "stI1ll81..1I.
UAva 11
I1Wf:L
PMCL
SMCL.
NIPOWR
. Not AvallablP..
Orlnklnq Watl'r Equlval~nt L..vP.l.
Federal Saf. Drinking Hat.r Act (SOHAl prllllary Ma.l~um
Fedpr~l SDMA SP.condary Ha.l~um Contaminant LpvP.I.
National Interim Primary Orlnklng Water Regulation.
Contaminant Levp.I.
POOR QUAUTY
-------
;::;
u
:.=.":>le .:,
MONITORING
WELLS IN AREA B - THE VALLEY SITE/MILL POND AREA
SUMMARY or SECOND ROUND (JULY 1990)
GROUNDWATER MONITORING RESULTS (ug/L)
GROVELAND WELLS SITE
SUPPLEMENTAL MOM RI/PS
GROVELAND, MASSACH1JSETTS
Parameter
Range of
Sample
Quantitation
Limits
Frequency
of
Detection
SUBAREA/STRATA/
LOCATION
Range of
Positive
Detections
Average
B-2/SBALLOW OVERBURDEN/
ADJACENT MILL POND
Trichloroethene (TCE)
1,2-Dichloroethene
(1,2-DCE)
su
2/2
0/2
2-6
4
Wells Sampled:
ERT-ll, 102
B-3/DEEP OVERBURDEN/SHALLOW BEDROCK/
ADJACENT JOHNSON CREEK
Trichloroethene (TCE)
1,2-Dichloroethene
( 1 , 2-DCE) .
3/3
3/3
220-1,100
31-150
537
87
Wells Sampled:
ERT-13, ERT-9, 101
B-4/DEEP OVERBURDEN/SHALLOW BEDROCK/
NOT ADJ ACEN'l' JOHNSON CREEK.
Trichloroethene (TCE)
1,2-Dichloroethene
(1,2-DCE)
su
1/1
0/1
4
4
Well Sampled:
108
B-5/DEEP BEDROCK
Trichloroethene (TCE)
1,2-DiChloroethene
(1,2-DCE)
su
SU
0/1
0/1
Wells Sampled:
107
Not detected
Parameter was not detected.
quantitation limit.
No wells in Subarea B-1 were
Value presented is the sample
u
Note:
-------
T.I"I('
'J
SIUILt.oM/DF.EP OVmRIIROF.N MONITORING "F.1.1.5 IN ARF.A C - niE AREA NORTH OF MII.L
:;m"ARY OP PIRST ROtlND CPERRI/ARY 1990) GROtlNIJWATF:R MONITORING RESULTS
GRUVF.I.I'INO WF.I,LS S I TF.
SUI'PI.t:Mt:NTAI. MOM R I/FS
GROVF.I.AND. MASSACHUSETTS
POND
I
5h811.0.,/0..p Ov.rhu.d.n Sh81IovtO..p OV8,b..,den ..rond John.on C...-
'" . h. Vlrlnlt, 01 .Iolln.on C. ... TOV8.d ,.. 'I III. .,00-
,........ 111'\11."1."1 0' Ito"do.d/C.lt..I.
...11 ..an.. ,. .'1"8n(', ".n98 0' "."'1. 0' ...quencr "."9. or
S..pl. 0' PO. II Iv. AV.'8'- S..pl. 0' Po.tt I... A.....,.
Ou...t Itot 10" Ou."IIt.1 10"
LI.". o.lecllo" o.locllo". Llott. Ool.ello" Oot.ello".
1,1,1-", '('hlo.o-
elhan.
-
_,l-nlchloro
et hane
.n .. - --
I.J-Dlchlo.o.
.. h8 ne
--
-. ---.
T.lchlo.o.then.
--
Toluene
I ~;;;-;ib~~~~~; --
I~: ~~ :j;; :;;; ....
I ::f:;~:; - ---
a...nle
I:~;~;i:~ -----
li~d~-I~~ . ..---
:c;;~,~~ _n - -.
I t'h.'~~,~~' --. ---
I ~~::~: ---~~--=.
CU9/L)
SU
--
SU
- --
\U
- - --_..
SU
--
SU
.._- ._-
SU
.- -.---.-
\U
n. -
"A
."..----..-
",'00
- - ----
-- - -Ie'
--
". ,
II'
--.--
- - -Ie'
-------
-- - -Ie'
------.
41.100
----- --
.'.J
---_._-----
n.'
-_._--."---
S6.IU
--
C"9/1.1 IU9/LI IU9/L)
IU-SU 1/10 I
- - _u_--- .-----
IU-SU 1/10 )
CU9/LI
IU-SU Oil
--- - -
IU- SU Oil
._-- --
JU- SII 111
IU9/LI
\ 40
.-. '''-11
-----..
---- -
---
..". --
\U-UU
411
II'
.-n
JI-J 1))-11
1_4 10. SI
- ---.. - .-.
1-, 10.6'
.- ---.--.
1-6 II-II
..- --.
--
H-
IU- 'U
I
.---...-.---
-- ..u
----- -' _n
-----
IU-\U
Ilf
0.6
---.-----.
-. ..- -
--.---_., u
---- --
IU-'U
J/'
O-S.J
..---
----
- . .. ..-
---
.---_.. --
u -.-
IOU
III
,
,
.---..------
.._-~ -
--
- ..-.
- - - -
S/\
IOI-H. JOO
11.9"
----
-- ---
- ... ------- .----
--- --.-
---..
OIS
'IS
J_4-S0-'
It. J
H-
-
._---------
- - -
-- ---.
.-. --.-..
- - --Ie'
on
---_._--+-
-- - -- .. ... .-..
---..- .-.--
- --
- - --
\1'
--. ---
lIS
-U.J-JU
".8
---
------
--------..
.- --Ie'
J.8
J_6
----
--.- '.- ..
------
-
-- - -Ie'
lIS
". J
IJ- S
----
--- --.-
---
--- --- ----
- - --
\1'
11.800- JO.OOO
n,'\O
-- ._---- .-
--
- -- -Ie'
'I'
-6.6-1]1
U.6
-----
.-. -.-.--
---
--
...ulel
n.'
n.'
lIS
.-------
-- .-----
------- -
8.0U-15.IU
II'
lOt
It.l
POOR QUALITY
ORIGINAL
.-.n-----_---
IU-'U
--
-----..- ---
IU-SU
_n- -. - - ----
IU-\U
-------
IU-SU
-----
IU-SU
-- --- ----
IOU
--- u
-----_.-
116U
----
..--Ie'
-_.------
-. ..Ie'
--~-_.
1 . 'U - , . )U
----
- -- -lei
--
00001<"
- -...-
----Ie'
----Ie,
.. 8U-IO.'U
.---_._--
1/10
--.- --
J/IO
--.-.- -.- -
0110
-----
0110
----.-
0110
------ --
0/4
-
6/8
lI'
-- --
S/.
------
S/8
lI8
------
0/8
-
8/8
4/8
lI8
lI8
J
--
1-'
- -....
- -......
- - - -
- - --
._--
JOI-ltO.OIO
".2-21.1
-----
J.I- It.8
--
'.'-1,101
..S-'.O
- - - ~
".600-nl,OOI
8.J-I.nl
--
U. ,-nl
151-141
lug/LJ
lug/L)
I.' CI.OI
JOO 'MeL C.,
----
--------
..6 III "A... I I
--
..6 Il' 10/100 ChI",.". tile!.
.',
--
J.) ISI \ PMCL 1'1
--
..... -.. J.OOO 'MeL I"
--
.........- '00 PMCL I"
........... 10.000 I'I4CL I"
-
- - - - "A... I I
".112 SO-JOO lMet. C.,
- --
n.' IOIS PlCCL IP'
--- -
IJ.) '0 .'P-
an.. 1,10. ...-
-
J.' I PIleI. IT'
......... .. \ PMCL I"
n,)n ......11
16.. J '0 ..P-
".J "A... 11
-------
'1".11>1 I" '.
snAI.I.ow/IIEF.P OVEARUROr.N MONITORING MRI.I.S IN A"P'" C - TIlE UP",
SUMMARY OF FIRST ROt/Nil 1f'F.RRUARY 1990) GROUNIIWIITr:R MONITORING
GHOVF.I.ANII WF.I.I.S sIn:
SIII'I'I.f:l'lY.MTIII. "0" R 1/1"6
GUOVP.I.IINII. MASS/lCIlIISt:TTS
1'/lCoV. 'Mf()
[
NORTH or MII.L PONO
RF.SIII.TS
...
~h."C1"/O..,. Ow..tnude" ~h.llo"I"".p o",..b.udan ..,ond John.on C,...
In ,,,.. VI.".n", ..I ..ohn80n C. ... 70"..d ""III. ..00111
Par....'.' "1'9,.dl.nl 01 01 1'.n,.,"C.lt..I.
...11 "an,. ,. equ8n." r "8n.8 0' ".n9- rrequ.ncr ".n,. 0'
S..pl. 01 '0.111.. Av...,. ''''ph 01 'o.lt"'. a".r.,.
Ouant t,.,lon Quantl..'lon
1.1.11. (k'erl Inn net.c' Inn. LI.IU Detert ion De..c.lon.
.Icarbon.t. 6J - . . - ~/~ .0-11 U., ..-- 7/' )1."0 ... ."...11
h. --.--.- -.. -- ---.----' ---....- ..._- --.-.. '-'-------- - --_."'--- -----.- ___A --- --- --------
Chlo,ld. IJ 'u J/~ II-II . ~U "6 . ....1) n.1 no SItCL I"
..--------- -- ~--- --- -.. - ---- - ---- ---..----- --.-- .- ._- ----- -
.II,.t...'t.lI. ... O.OtU J/6 0.01-0.21 o.n O.OtU 6/' 0.01-0.' 0.1 to fMCL cp.
- ------...-...-- --- ------.- -.. ---- .-- .--- ----- ----- --
Sulht. 100U ---- ,,~ JI.,. J4.1 aoou II' II-II n.' .01 fMCL IP,
--...-..--- _...- -.---- n---'- -- - .- ----- - ._- -.
Tot.) Ole.olv.ca tn -. -. ~/~ 10'- JIt I" .--- '" 70-IU nO.4 ~Ol SItCL I"
Sollcal
I,on
1119/1.) (u9/L) ( uq/I.) 1 "9/1.)
1'1. 100 ~/' 10" III .000 11.11'
.n' ..
n.' J.I" II )U 11' 11.1 n.' 11 ,
-. ---. - ..- -- - ---- ._-- .-
II. .00 ~,~ ~.160.1"'00 10.'"
... .. .. .- ._.- --.-.-. .-
960 H~ a6'- a. '.0 660
._. --.--.-- -- -
Id UJIC' II" O.J O. I
..- --.--. - --. -- .. .-.-----.-- -
9'.J .Ic I \/~ 1.'-141 61. I
.... -- -- --. --- -- - .- ..
6..,0 .. ~/' 1.160".410 ., "I
---.------ u .---.-- - ..
UJ UJlc, U\ '.J.II.' \.0
-- -- ... .._-- .-.
Ic' ~ . 'U - 11 . ~U O/~ --
..-u. ,"---' .. -----.. ___A .. ------- ---- -- --
....0 - ~/~ 1.100-111.000 ) I, J r'
-.-' -""- - . - ---- __A .. --.--- '-
\'.J IC' U\ 10.1-110 .. I
.- .u- .._- -- -- .._---- - - -- .--- ....
... n.ltI.uu "~ U.J-IOI ".7
, ...d
...- ....
-.
MICfn..llJ'"
..-----
-- - ... .-.
"1"9In...
..." ,.-
N"'''''II,
...
111...1
I - - -
, ~~~~~~-~~~
S.tenlu-
I ;;~;::_-
vanettlu.
I i i~c
--
..
-.
-..
...
(IIMJ/L)
(189/1.)
189/1.)
.8q/I.)
cJOOR QUALITY
ORIGINAL
(U9/L)
IU9/L) IU9/L)
III .,.. '11.000 'o,"~
..- _... .--. -.--..-. ------ -
)/1 14.I.au H
1.9" '.011
- ..
.- .-
--... .--
..
"I
I. JlO- 10), 000
Jt, In
_..
... .-..-.
-.. .... .--
-.--.----
----..-
--
III
1."6.760
"0
.. .
.---.--.--
.---. -. --
-... - ------..
-----
UJlc I
0"
-..-
.--.
..-..- --.---.
-..--
.-.----
---
I. JUlet
1."1.,
a,laO"',IOO
tn
'"
-.
.._-
-....----
Ie'
III
',IJt
..
.- -- - -
.~_.. -.-'
-----
-----
IIJI<"'
J. 1-).)
La
111
.. .
----
-
--
-
-- .-----
-------
,. I U I. 'U I c ,
OIl
.. -
....-
-. ._- - _u
-. ...-
..
"I
J, no.. J, '00
at,IU.I
-----..------
..- --.
-...-.--
-----
.. Ic'
1.1-'11
"..
tli
-- --.---.
.-- --
.--..-
-----..
It. IU- )lU
"1
",I.a...o
IJJ
. 1189/1.)
1189/1.)
1189/1.)
(ut/L)
)00 SItCL I"
_.-
---- _._--
~o .I.~, \ at .ource
PltCL I"
..- --.-.---.----.-
."...u
--..-----.------
'0 IMCL I"
-.------- ....----..
I fMCL CP'
--- -
tOO PItCL IT'
--
-.---.. --------.
.....It
- -..--'.'-----"
ao fMCL IP,
-- ---..-.,-----.
\0 ...-
_. -- ---.--- -.----.
10.000 _L
-- . -------"---.
."..u
- - - - . -..-------
~.OO' IItCL I"
..
-------
'Llhl (' "
SIIAI.I,OW/0F.F.P OVF.nnUltOEN MONITOR I HG WP.I.I.S IN ARI'''' C
SUMMARY Of' PI RST ROil NO C pFonnl/ARY 1990 I r.ROIINIlMATF.R
(;nOVF.I.ANU MF.I.LS S I TP.
SIII'I'I.t:MP.NTAI. NO" R I II'S
GnOVF.I.ANI). MASSAClllfSF.TT5
PAGF. TIIRP.f:
- TilE AAI'''' NORTII 01' MII.I. PONU
'IONITORING Rt':SIII.TS
_.
~",,'Iov/P.pr O".rbu.ct.n !;h.I'n"/P~~J1 OVf'.hu,d.n ..,ond John.on c....
'" . h. Vit Ini.. 0' .'ohn.on CI..~II Tow.rd ".,111. I'OD~
'.r...... "",,'.'''."1 II.n,,8 of D' '..nd..d/C.lt..I.
W.II "p'I".nr, II.",. O. ".n". r..qu.n(", II.",. 0'
5..pl. 0' .0.I.t.. a"...q. 5."'1'1. 0' Po. I t h. ay...,.
Qu.". 1...10" Quant 't., Ion
LI.". 0......- '0" D...~t'on. LI..It. 081.r.' Ion 0.' 8C t 'Oft.
Total ~u."''''1ft.d I .440 \/\ .,0 1.190 I" ..011 \/1 6.0 ..0'0
501 ide H' """811
.- .... -_... _._. -.--. . -- q --- --- ...
Tot.' O.q."lr "" O. tll 1/1 O. I 0 I O. III 0/1
Carbon ""..11
_hh ' -- -- ... . -- . - -."- .... --.. .-. -..- ..n -. -.
COO "" 1/1 ' 66 '01 n.\ 1/1 6' " ""..11
. -- -.- .. -- _... ... --_. .- , " ...-.- - _._- - ----.. -- --- -..-- ----
IIOO~ "" 1/1 J.) 101 1 , III 0/1 -- ""..11
-. - .. . -q -.-..----. -- -..- .. _.- -- .-' -- ..- .u .---.- - -- _. .. .--.---
H..dn.... "" . 1/1 U.5.101 91 . 1/1 61. I n. I ""..11
, -- -. --. --.. -- -- -"---- .- .--. -- --_. ..-- ".-. -- -- --- --.--.. ..---.---.-- - --- ..-.- -.- --'--'
Tot.' "".. Inl., "" " 1/1 tJ." It.' 1/1 ..0 ..0 ""..11
( II
1 21
1(')
II
IIJ
(0)
(P)
(FI
ITI
NAva 11
01011'1.,
PHCL
SHCL
NIPOWR
("'
-------
l,
r
Sh.llow/o..p o..._u.4." Ih.II../o..p o...bu.4... ..,.n' J.hn..n c....
I.. ,he Vld"lI, .. ~.h"..~ Cr..' Tow..4 ..,111. .....
.......... ..",. of '..qu8ne" "ft.. 01 ....,. of r..qu.ft~, ..n,..' 'I.~.,"C.II..I.
1....1. 0' .....S.. av.. ... .....1. ., ..."... a..,...
ou.... .... .." Qu."..'.'I."
LI.". 08'8'" I." "..etl.". LI.". oet.a,t... "'..1'.".
'1.11, It' h
.
SRALf'OW/0811P OVIIA9UADI!N ..oNITO.IING "PoLl.!) IN AJlIIA C - TRII AJlIIA NORTH or "ILL
81WtAAY 0,. SF.COND ROIJIID (JULY 1990) CROUNDtlATr.a 8IONlTORINC RESULTS
CROV81.AND "IILLS S 1'1"11
5UPPI,P.MP.wrAL ..,.. IlIlrs
CAOVIU.AND, 8lA8BACRuBET1'8
POND
I.J.OI~hlofO..h.". ,u ./. '.4' ,.-. 'v 1/1 I I.' ""11 ('I./T.....
1'0,.1' ftlCL IP'
..
T.lchlolo8thene '" '"~ I-no n.' .v If) '-J I." ftIC L Irl
'.tl.~hlolo.'h.". 'V 1/. I'-HIDI . '"~ 0/1 _..- . . ~ - . ftIC L 1.1
1I,,1I1t...4 JOoV 'I' II.' - ill, .0. ", fl. .... ... a III '4,'01 18,'"
A'".inu. -. -.--.- - ---_._--- .. ..-- ... . - -. - .. - 110 IJIC L CFI
I PI It.... IUU"I'U 1/. .tt.' .01 ........ .,. .. . .... . .....
I At ....Ie u..'I1,.... - V.I I~I 1/1 '.1- 11.1 II.' ....... III ,I. I n.1
------- ----- ---- -. _._--- - .. ...-
i rll ....4 I.JU-I.'U 0/' _.-- . _..- ..--.. 011 ......... ..........
\...IU. U,,'II,.... JI.'U '"~ ".'-1,0)0 II'.' III I" ...
.._--- --- ----.-- .-.._~- ','0' ..F-
rll,.... IJ.IU-Jl.4 ," 11.0-1\.' .. ........... III II II
I..,rlll- U"fllI...' ~ .. .. .. 4/. 1.)-11.1 1.1 ........... 0/. ...... -.. .. -....
- .---... ____4- .- -- -- -- -- -- --.--.-- - -- . PllCL ITI
PI 11...4 ..... . .. 0/. -....... .. ... ..... . .......... 011 _..-- .........
Ic."..- U..'llt...' ---- )/1 '.'-U.' ... ......... 011 ---- ..........
---'.--- -. -..-... - ---..... ._--- - , ftIC L CFI
I rlll...4 -_..- 0/1 . ..... .. ...... ..... ... ....... 011 ......... ...---
\('.lcI- U", II. ...4 ......... ,/I 11,100-",400 ",'1' .......... 1/1 ","1 10,'"
-----. - -- ------- --- - ---------. .----- --.- ....1.
rll ....eI ..-..- .,. 11,'10-44,108 JI,I'I ....... III 1t,"1 ",'"
I ('hlO.1 U. U"fll..... - - --1.,1 '" 11.'.10' HI ..-..- III .ar II'
-----.---.... -------- _.- .- ----. -- .. ...-
rill..." ---- 0/1 .. ..... .. .. ....... .......... 0/1 ...--... ..........
Unlllt.... ...-C~I '" II. ,. ". J9.) .. --- III ,a. I ".)
Cohat ....11
rllt...' --...- OIl ......... .......... ---- 011 ........... ......--
..
Unlilt ...4 . - - - C~' '" U. ,-n. ..... --...... 1/1 .n .n
('oppe. - ',1" ftlCL CF'
rill...' '.IU-'.'U Ce' 2/' '.J-I.' '.1 '1. I' .....- '/1 -...- ---...
C-9/L)
IU9/L)
( u9/L)
('"IlL)
('"IlL)
C../L)
('"IlL )
POOR QUALITY
-------
.LIIII t' h
SIIAI,I.ow/IIEt;P OVf:RRUJlUEN MONITORING WELLS IN IIRI'-" C - THE AREA NORTH
SUMMARY 01' SF-CONO ROUND (.IlIl,Y 1990 t CROIINI)\ofATP.R MONITOR I He RF.SUI.TS
r;UOVp.I.IINII "P.I,I.S SITE
!;III'I'I.t:Mt:NTIII, ..0.. R I II'S
GnOVp.I.ANIi. MASSACHU5F.TTG
PIIGI': Ttf()
0.. "11.1. PONO
-. --
S~.llov/O..p Ov.,bu,d.n 5".llov/0.." O"albUlClan .a,ond Johnaon Claa'
In Iha vlclnll, o. John.on CI... To..,d al,llla "00'
".,...,., ".n,. 0' r..quenC', "8"98 nf "."98 0' P'.quenr, .an,a o' '.andal./CIII.,la
S..pte 0' po.tt've ",.,..89. S..ple 0' .08111". ....,.,.
au.ntlt.tlon 008nll'.tlon
LI.I.. Delacllon De,.ctlon. LI.IU De.acllon De.ae.lona
--
Un'lI t...d -- -. ./1 16.100.141,000 1",'19 ... 1/1 n. .0. - - - -
t Ion .--- ---- -.-- ---.- - ---- --- - - -. ..- - . -.---. --.-. .- ---..--- ------.---. 101 IIICL Irl
rllial.d )J ..u Icl ./1 li-I.IID I. ZlD U.JU 0/1 ..... -.... -
IInfllla..d 1/1 1.4 ,,,. ." 4 ... 1/1 60.0 ".0 .0 ..._, . ,.,
1...41 . . - .- -. - ..-. -. --.... - -. -.
'II ta.ad . - -- Cc I '/I I., 1.4 II.' I ---- 0/1 --.. -..-. ..ure.. PllCL ,.,
.....--.
Unllltalad ....- 1/1 1.6~0.1\.IOO '0, "" ---" 1/1 JO.JOI JO, JOO
"ltCJn..iu. - - ..no ..- .- ... . ---- - - .-.--- ---_...--- -- ----- "a.all
'"t.,ad _.-. 1/1 J, nO.'.lJo \.1'6 - - -. 1/1 .,"1 .. JlO
Unfllt.r.d ---- 1/1 ".I".~\O I. '.0 ---. 1/1 11. I"
".n98n... --- -- - ------ ... .. - _u.-----.- .. -. --- ---- - - ---- -------. --- to IIICL 1'1
rllI.,ed -. - - "I 19.'.1" nJ -. - - III IU 141
....1..1 -
I"IC"I Un" Ital.d 1/1 11.1" I".. -... 1/1 IU IU
u-'- - - _..- -- ._ .- --- - ---.- ---- .. --- ... -.- - ---- 101 PNCL IYI
'"Ialad _.-- 0/1 ..-- -..- - - -.. 0/1 .... -... ----
Un" lIal.d I.OOOU." "OU '/1 ....0,)6. \00 11,IJO.' ..-. 1/1 ','01 '. "0
pot...lu- ----.-- ---- ---- ----- _. .. ---- ------- - --- -.- ._- ------ --- --.------ .a.all
'11t.,ad J, )tOU.~, \OOU 0/1 . - .... ---- l,tlOU 0/1 - - -.. .... -.
--.. I.. I -
Un" Italad 1/. J.J J J.~ JJ. JI - -... - 0/1 -..... - .. - - -
S.lanlu- .------ - _. - _-h--'--- ---.--.-. ._----- ---- ---- 10 PIIC L 1'1
'I Italad -- - -C..I 0/. .. - - - ..-.. ... - - - 0/1 ...--- --... -
...~
Un.ll.aled -..... 1/1 .,"O-I',~OO I2,On.1 - - - - 1/1 ',n. '.110
Sodlu- .. ---- -- ----.- .---. ------.-. --------- ------ --'.-' --- --'-- JO.OIO _IL
'IIt.,ad ... -... 1/" , 190- I' .001 '.111. I ..... -.. 1/1 .,111 .,890
Un.llieled I..U.J.IU 1..1 0/1 -_.- ---- ...U 0/1 -. -... -_.-
Thalllu- - - -- ------ -----. .-. .-"--- .-----.- ,.-------- ---..--- -_. .-- .a.all
rllt.,ad ---- 0/8 -.. - - ..... - LIU 0/1 ... - -... . -. -
Un' II t.,ad --. -lei ./1 ".J'!U I)}. , ........... 1/1 n.1 n.'
Vanadlu- ---------- ------ - ------ ------- ---- .-- --.-- -- "a..11
,1I1.r.d II.IU 0/1 -.... - .. -...... 0/1 .... -- ...... -
.-
Un" Italad -. - - 1/. '12.,n IH. J -. -- .1/1 III In
Unc - ----- - - ',101 SIICL IF)
'Ilter.d U.'U-JO.IU Icl J/. U-H.' 1).2 -. - - 0/1 - - - - ... --
(ug/Lt
(ug/Lt
(ug/Lt
(ug/I.t
(u9/Lt
(ug/Lt
(u9/L)
POOR QUALITY
-------
v
L,III.' h
SItAI.LOtf/OEF.P OVF.RRIIROF.N
SUMMARY 01' SECON!) ROIINO
GROVI':I."NII WI':I.I.5 fi I TF.
fi\JI'I'I.F.MF.NT"L MOM Rill'S
GIIOVP.I."NO. MIISSACHIISF.TI'S
PAGP. THREP.
[
MONITORING IfBLLS IN ARKA C - THI! AREA NORTH 01' "11.1. POND
IJIJI.Y 1990) GROIINIIWI\TF.R MONITORING RF.SIII.TS
Sh81Io-../Deep 0".' h'Jlct.n Sh.llou/D~.p O..,bUld.n ..,and John.on c....
In th.. v'~I"lt, 01 John.on CI... To..,d a"llla 1'00'
Par..e'.. "an9. 01 " .qu.n~, "an,. o' Ran". 0' r..q,..nc, "an9. 01 l'andard/Crl'., I.
5..1'1. 01 P08't Iv. Av.._,. Sa.ph 01 '00 It h. a..,...
Quanlll.llon Quanlltat Ion
LI.It. Oe.act 10" Det 8C t Inn. LI.lto 08'.
-------
,
Shallow Bedrock
.
Parameter Upg rad i en., RanC)e of Sample Frequency RanC)e of Standard/Criteria
Well
Quant. it.at. ion of Poc it i ve Avera
-------
~
u
T:I h Il' I
SHALI~W BEDROCK MONITORING WELLS IN AREA C ~ THE AREA NORTH OF MILL POND
SUMMARY OF FI RST ROUND (FEBRUARY .1990) GROUNDWATER MONI'.I'OR I NG RESUl,TS
GROVELAND WELLS SITE
SUPPI~«:MENTAL MOM R I IFS
GROVEI~AND, MASSACHUSETTS
PAGE TWO
.
Deep Overburden
Parameter Upgud ient Range of Sample Frequency Range of Standard/Criteria
Well Quant Hat ion of positive Avera",e
Limits Detect ion Delection5
Bicarbonate 62 - - - .- 2/2 1S H NAvail
Chloride 12 - - - - 2/2 5.0-26 15.5 250 SNCL (F)
Nitrate-Ni tri te 1.9 0.0111 1/2 0.01 0.01 10 PMCL (P)
Sulfate 100U - - - - 2/2 16-29 22.5 400 PMCL (P)
Tolal Dissolved 129 2/2 65-185 125 500 SMCL (F)
- - - -
Solid5
Total Suspended 1,440 2/2 4.0-7.0 . 5.5 NAva i 1
- - - -
solids
(mg/L)
(mg/L)
(mg/L)
(mg/L)
(mg/[, )
( D)
(P)
. (F)
( T)
Results of
Proposed.
Final.
Tentative.
duplicate samples.
U
UJ
Parameter was not detected. Value presented is the sample quantitation limit.
The parameter was analyzed for, but not detected in, one or more samples. The sample
quantitation limit (the CRDL) is estimated.
NAvail
DWEL
PMCL
SMCL
NIPDWR
Not Available.
Drinking Water Equivalent Level.
Federal Safe Drinking Water Act (SDWA) Primary Maximum
Federal SDWA Secondary Maximum Contaminant Level.
National Interium Primary Drinking Water Regulation.
-------
T;lh Il' 1
SHALLOW BF.DROCK MONITORI NG Wr-;I,J.5
SUMMARY OF FIRST ROUND (FEBRUARY
GROVELAND WELl,S SITE.
SUPPLEMENTAL MOM RIIPS
GROVELAND, MASSACHUSETTS
PAGE THREE
IN ARF..A C - '1'1IE AREA NORTII OF MI LL POND
1990) GROUNDWATER MONITORING RESULTS
(c)
Results for one or more samples in the data group were reported as non-detected at
the CRDL.
( 2 )
Wells .103 and 109 were sampled during
TCE (6 ug/L) were detected in well 103.
well 103 are as follows:
the second round.
Inorganic. results
1,2-DCE (1 ug/L)
(total/dissolved)
and
for
Aluminum
Barium
Calcium
Chromium
Copper
Iron
Lead
Magnesium
Manganese
Nickel
Potassium
Sodium
Zinc
4,900/137U
84/20.8U
37,100/34,200
20.7/ND
33.7/ND
9,860/ND
13.6/ND
9,870/6,790
420/280
17.1/ND
3,250U/2,470U
6,600/6,500
490/ND
NO
U
Not detected
The compound was analyzed for, but not detected.
numerical value is the sample quantitation limit.
The
-------
1 (' H
Deep Overburden
Parameter 8ackcjround .RanCje of Sample Frequency RanCje of Standard/Criteria
Quantitation of p08itive ~ver.Cje
Limit.(l) Detection ' Detect ions
MONITORING WELLS IN AREA 0 - THE RAVERBILL MUNICIPAL LANDFILL AREA
SUMMARY OF FIRST ROUND (FEBRUARY 1990) GROUNDWATF.R MONITORING RESULTS
GROVELAND WEI.LS SITE
SUPPLEMENTAl, MOM R I IFS
GROVELAND, MASSACHUSETTS
Chloroethane IOU lU-10U 1/5 3 3.9 11.5) N~va il
Trlchloroethene 5U lU-5U 1/5 4 2.4 141 5 PNCL (")
.
Benzene 5U 1 U - 5U . 1/5 17 5 1111 5 PMCL (")
Toluene 5U lU-5U 1/5 5 2.6 15) 2,000 PMCL (P)
Chlorobenzene 5U lU-5U 1/5 19 - 20 (D) 5.5 119.5) 100 PMCL (P)
Ethylbenzene 5U lU-5U 1/5 18 5.2 118) 100 PMCL (P)
Total xylene. 5U lU-5U 1/5 86 18.8.186) 10,000 PMCL (P)
Aluminum 34,500 - - - - 2/2 519-2,270 1,425 50-200 SMCL (P)
Ar.enic 19.1 ----(c) 1/2 97.7 51.4 50 NIPDWR
Barium 171 - - - - 2/2 49.2-50.5 50 1,000 NIPDWR
-....
Calcium 41,100 - - - - 2/2 31,600-"53,100 42,650 "~va 11
Chromium 89.2 - - - - 2/2 10.1-10.9 10.8 50 NIPDWR
Cobalt 32.9 8 . OU - 10 . lU 0/2 - -- - -....- - N~v.il
Copper 56.1U 10.8U-l1.5U 0/2 ---- 1,300 PMCL (P)
(ug/L)
(ug/L)
(ug/L)
(ug/L)
-------
'1':11>1(' H
MONITORING WELLS IN AREA D - THE
SUMMARY OF FIRST ROUND (FEBRUARY
, GROVELAND WELLS SITE
SUP'PLEMENTAL MOM RI/FS
GROVELAND, MASSACHUSETTS
PAGE TWO
HAVERHILL MUNICIPAL LANDFILL AREA
1990) GROUNDWATER MONITORING RESULTS
.
Deep Overburden
Parameter Background JtanC)e of Sample Frequency Range of Stendard/Criteria
Quanti tat ion of po.itive Average
LimiU(l) Det.ection Detection.
Iron 39,300 - - - - 2/2 5,010-9,150 1,110 300 SMCL (P')
Lead 25.9 5.0U 1/2 )4 18.3 50 NIPDWRi 5 a.t. .ouree I
PHCL (P) /
Magneaium 11 , 600 - - - - 2/2 6,280-11,900 9,090 NAvail
Manganese 960 - - - - 2/2 12-544 308 50 5HCL (F)
Mercury NO UJ(c) 0/2 - - - - - - -- 2 PMCL (P)
Nickel 963 - - - - 2/2 16.8-21.6 19.2 100 PHCL (T)
pot.a..ium 6,970 - - - - 2/2 4,550-24,700 14,625 NAvail
Selenium UJ UJ(c) 0/2 - - - - - --- 10 PMCL (P)
Silver NO 8 . 6U - 14 . 3U 0/2 ---- ---- 50 NIPDWR
-"
Sodium 9,140 - - - - 2/2 10,100-44,100 21,100 20,000 OWEL
Vanadium 56.3 ----(c) 1/2 6.3 6.3 NAvail
....
Zinc 449 35.1U-40U 0/2 - - -- ---- 5,000 SHCL (F)
(ug/L)
(ug/I, )
(ug/L)
(ug/L)
-------
D
()
"1";11>1 l' H
MONITORING WELLS IN AREA D - THE
SUMMARY OF FIRST ROUND (FEBRUARY
GROVEI.AND WELLS SITE
SUPPI,F..MENTAL MOM R I/FS
GROVEI,AND, .MASSACHUSETTS
PAGE THREE
HAVERHILL MUNICIPAL LANDFILL AREA
1990) GROUNDWATER MONITORING RESULTS
De~p Overburden
Background . of Sample of
Parameter Range Frequency Range Standard/Criteria
Ouantitation of Pos i t tve AveraC)e
Limiu(l) Detection Detections
Bicarbonate 62 - - - - 2/2 42-200 121 NAvail
Chloride 12 - - - - 2/2 17-28 23 2!)0 SMCL (F)
Nitrate-Nitrite 1.9 - - - - 2/"1 0.3-1.8 1.1 10 PMCL (P)
Sulfate 100U - - - - 2/2 ~2-~8 !)!) 400 PMCL (PI
Total Dissolved 129 2/2 192-]88 290 500 SMCL
- - - - 1 f)
Solids
Total Suspended 1,440 2/2 25-1,340 683 NAvail
- - - -
SOlid.
(mg/L)
(mg/L)
(mg/L)
(mg/L)
(mg/L)
11 )
Sample quanlitation limit. (SOL) presented for parameters reported a. -not detected- in a sample. for
inorC)anic., the only SOLs presented are tho.e which differ from Contract Required Detection Limit. (CRDLa).
CRDLs are presented in Appendix A.
Results for one or more sample. in the data group were reported as non-detected at the CRDL.
Parameter va. not detected. value presented is the sample quantitation limit.
The parameter was analyzed for~ but not detected i!'l, one or more samples. The sample quantitation limit It lie
CRDL) is estimated.
(c)
U
UJ
( D)
( P)
(F)
(T)
Re5ul U of
Proposed.
F i na1-
Tentative.
duplicate samples.
HAvail
DWEL
PMCL
SMCL
NIPDWR
Hot Available.
Drinking Water Equivalent Level.
Federal Safe DrinkinC) Water Act (SDWA) Primary Maximum
Federal SDWA Secondary Maximum Contaminant Level.
National Interim Primary Drinking Water Regulation.
-------
,
Tahl,' ')
o...p Ov.,bu,d.n
P.,._t., ".n... o' FI.qu.ner ...n... 0' Stende,d/Crlt.,I.
S..pl.
Qu.ntltetlon o' '081t Iv.. "V.,.,.
1.1.". Det.etion O.t.ellon.
MONITORING WELI.S IN AAI!A D - TilE HIWERHILI. "UNICIPAI. LANOI'ILL AAI'.A
SU:routARY OP SP.CONO ROUND (JULY 1990) GROUNOWATP.R MONITORING RESUI.TS
GROVELANO "''':I.LS S I TF.
SUPPI.!MENTAI. MOM R I /I'S
GROVEI~D, ""SSACHUS~TTS
a.J-Dlchlolo.th.n. (totea. ~U If) J J.) III JO/IOO Ch/T,.n. PNCL (PI
~rlchlolo.th.n. ~U 1/) 9 4. J ~ PMCL IF.
Unfllt.,.d ... - )/J ).160-96.400 )J. IU
IIau.lnu. .------ .._- ---- --- . ------- \0- JOO SMCL (PI
FIIt.I.d - - -- (e I Of) - - -- --..
Unfl H.r.d UJ (cl J/J '1.'-40' I III . \
III..nlc - ---...- -._----- --- ---- ---- -. "-""" --_.- --..-.-- \0 .IPDWIt
FII tel.d UJ leI If) J)) 81
Unfllt.,.d - - - - II) ~4.)-)II II)
..,Iu. .-------- ----. ,_h ----- ------- ------ -- _.. ---.. .- -- - .-----.---- - 1,000 .IPDWIt
Fllt.,.d - --- II) U-.0-~4.9 J9-
Unf 11 t...d .. --Ie I If) J. I 1.4 !l.1I
..r,lalu. ---------- ---- ------- - - - - -- .--- - - ----- ..- I PMeL ITI
FIIt.I.d -- - .leI Of) -_.- .. - -
Unfllt.l.d -- --Ie I a/J 10. a \.0
Ced.lu. --.----- ~ ,MeL 1'1
PI It. I .d -- ..Ie I Of) - - .... --'"
Un' 11 t ...d -- II) )J.)OO'\','OO ".'"
Caaclu. --' -- ...------.- -- ----- --- --_.--_. ---. ."v.11
,Iltel.d --'" )/J n,100-\4,100 )9. I"
Unfl It.r.d - - .. - If) aO.I-u, UJ
Chlo.lu. - --- - \0 ."DWIt
ria t.l.d - -'- -I c I Of) - .. .. - -- --
unfl It.,.d -- --Ie: I J/) JI. J-1\.' tJ. J
Cobelt .IIvell
'IIt.l.d - -- -Ie I 0/) - - - - - - - -
Unfllt...d 10. JU J/J n. . 191 UO
Copp.' ----- --.- .,----- -- ---- ~._--~ - -- .----. ..---- --- -- I,JOO PMCL II'I
FIU.,ed - .. -Ie I on ...- - - ~ -
Unfl it el.d . - --Ie: I )f) ~,O'O- 116.000 J',nO
lIon -- ---~ ------- _.._~---- JOO SMeL IFI
F II t . , ad II.OU lei II) JO. JOO '.'JO
ug/I.
ug/L
uq/l.
ug/l.
POOR QUAL!
-------
Q
'1 .. I> Il' t I
MONITORING WKLLS IN ARM 0 - TilE HAV~RIIII.L MUNICIPAl. LANOPJI,I. ARP.A
SUMMARY SECOND OP ROtJNU CJUI.Y 1990) GHUIINIIWATV-R MONITOHING RP.SUI.T5
GROVPoLANO NPoLI.S 81 TR
SIJI'PI.F.MRNTAL MOM A I IPS
GAOVELANU. MASSACHUSETTS
PAGK TWO
o..p 0.... burd.n
'ara-t.r ".nq. 01 'r .qu.ncJ ".n'l. of
S..pl. Standard/Crlt..la
Q..ant It.t Ion of Po. it Iv. 11.....'1.
I.I.1t a o.t.ctlon Datactlon.
Unfiltered .--- )/J lO.).J9.. 41.J ~O ..1.01111; ~ Cat aou.ce,
Lead .. ------------ --- - --..-
.IHered UJ Ie, 1/J I.~.).O I.J PMCL IPI
Un"ltered .-.- )1) ~.600.1J..00 '0,090
Maqne.lu. --- ---- --------.-- - -. -----.-.--' "lI..ali
"'tered .--- )1) 6. ) '0 - I) . 600 '.~.)
Un" Itered .-.- )1) . ~ . I - ) ,600 1,061
Man'Jane.e .--.-- " ._- .~----_..._-- .-. ....--- '0 5NCL C.,
.Iltered ....Cel )/) III '61 181
unfllter.d .-'- )1) (4.)16 '14
IIlckel ... .--... ".-- ---.- - ._0... 100 ,NCL ITI
rllte..d ....Ccl J/) ".1 )0.0 II..
Unf" 1 ered ..UOU J/) I J. .00-) '. )00 1),0)/
pota..lu. -----..- ---- ----- ----- .--- .--'. -.--.----' ""vall
ri Itered ). nou'.,.60U '/J I 1,600 ~,Hl
Unf IIUred - - - - )f) 10. )00 - )9, ~OO 14 , 16 J
Sod I... --- .-------- --.--. d'_'-------- 10,000 OWIL
'Iltared - - - - - Jf) 10. .00. )1,000 11,)))
Unfllte.ed I..U-I..U Of) - - - - - - - -
Thalli... --'-' ""..all
.1 nared I.~U, UJlcl 01) - - - - - - - -
Un" I Urad - - --Ie I )/J 1'.6-1\1 6J
Vanadlu8 -- ---- -- ...--- 1I"...i I
.it te..d .. - - Ccl Of) ---' -. - -
Unf I I Urad ---- )/J ".9-.41 160
:&Ine -------. ------..--- -_.-.. .-----.- ~,OOO 5NCL IF)
'11t...d -.. Ccl If) )).1
uq!l.
uq!l.
uq/I.
uq/l.
POOR QUAUl ~
-------
Tah II' IJ
MONITORING WELLS IN MEA D - THB IUWEAHII.I. MUNICIPAL (.ANOFII.L ARI'.A
SUMMARY SECOND or ROUNO (JUI,V 1990) GAOI/NUWATF.A MONITORING RESIJI.TS
GROVELANO WELLS SITE
SUPPLEMENTAL MOM Rill'S
GROVBLAND. MASSACHUSETTS
PACH THREE
o..p O...rburd.n
..ra..t.r lI.n.,. 01 r..qu.nc, ".n,. or Standard/Crit..I.
S..pl.
Qu.ntlt.,lon 01 .o.lti... ".....,.
LI.It. o.l.cllon Det.ctlon.
Bicarbonal. - --- I/) )t . 4 . 116 II.' ""...11
Chlorld. --.. )f) ".'-)\.2 n.2 nOSMCL crt
"ltr.t.-nltr It. -. - II) 0.IU-2.n I. J4 10 PMCI. CPt
SuUat. - - - - Ce. 2f) !)O!)) .00 PtlCL (p.
Total DIe.oiv.d Sol ide .--- )/) 11'-40) 21) !)OO 5MCL cr.
Toul Pho.phat. - - - - I/) 0.041.0. II 0.09!) ""...CI
Ortho-Pho.phat. .--- )/) O.O~!)-O. lU 0.1 J) ""nil
"11I.Unit, - ..- )1) )1..-186 11.9 "....11
.q/L
.l)/t
IIIq/l.
111)11.
Ica ResultS for Qne or more samples in the data qroup were reported as nonilt.tN:ted at or below the Contract
Required Detection Limit (CRDL).
IP) Proposed.
I 1') F i na I .
IT) Tentative.
U
Parameter was not detected.
Value presented Is the sample qllantltatlon limit.
NAva 11
PMCL
SMCL
NIPOWR
Not available.
pederal Safe Drink lng Water Act «SOWA) primary Mallhllum
federal SOWA Secondary MCL.
National Interim Primary Drinking Water Regulation.
Contaminant Level (MCL,.
jJQOR QUAL\TY
-------
o
v
'I.d" "
III
SUMMARY
0' SUR'''C8 M"TER f'IONITORING
CROVKLAHO WELLS SITE
&UPPLEI4F:NTAI. "ON Rill'S
GROVP:LAHD, "A6SACHIISt:TTS
R£SUI,TSI" (J 1
John.on ',In.U. 8'01'11 Johnlon C.eek/YIII., 51../M11I Pond AI.. ..10. .ond
Cr..' .John.on Cr..'
..,...,.. UPI II ... Uplll.'. 0' Oown.,....o' Up" ",. 0' Mill Pond Mill Pon" Tr..'..nt Oo.n.',...
0' Yd a., Ch..'.rton ("h..'., Ion Pon" Inl.t Out 1.. Allth_. Ie: .,.... 0' Mill a,IU_.I,
SM-' SW-II IiN 10 SW'I SM- 1 5W'6 .....,.1 a I Oloch",. Pon" a..r.,.II,
P-U S"-~
...~h,a.n. e:haorad. au au IU/IU ~U IU .. u.~ SU au ...... -.
-..
a,~-Dlchlolo..h.n. au au aU/lu IU IU ) I.) '6 O. S J ...)
170..a I 1'1
--
Chaoro'ol. au au aU/lu IU au IU ..-... au au - ... -..
a.2-Dae:hlorO'lh.n. au au au/IU au IU 0.6 J O.~ IU IU .........
l,a,I-Trlchaolo.'h.n. IU IU au/IU '0. JJ IU a 0.1 IU IU ... .. .. -
IU IU/IU a IU 6 l.~ U 0.'" JJ. ~
Tllchaolo.th.n. IU U "I.
t -.n..". '"'-."
IU IU IU/IU IU IU 0.'" O.S IU IU .. -.....
'--
I Tolu.n. IU IU Itl/IU IU IU 10 )., 2U IU ----
-
Alu.lnu. ".4U )8.6U 118/111 SI.6U I'.'V 41.4V -.. -... IIU H.IU
'''.IUI ----
_..
a,l.naC U.IUI ...-- 20 II.'
.'
",au. '.1 ao.'/I.' '.1 I.~ ~.~ '.J n.4 ..,
la'.'1 1&:I.'ul 111.l/al.ol/l 110.01 lao.lul II
c.acl- aO,401 ',"~I ',890/4,"0 aO,200 aO.200 10,100 ao, I" 20, tOO ao,~oo I S, no
IU,IOOI II , , 600 I 114, ~OO/I4, 6001 II' ,1001 "4, lOll
Chro.lu. 9.~ t.' -.........
110 a.o 16I/Ht 110 IU 110 a H. I ',1'0 Ha
lion In'l 1)"1 I H./Jl61 11611 IU21 J,'JO.S
..-
L"" I.) 1.1/1.' I.IJ LOJ 1.1 1.1 ............
-.
".,n..lu,,; 1,120 1,110 a,O~O/I,O'O 1,"0 ~,))O ~,JlO I, nl.' 4,'40 I, HO I"n
IJ, nOI 1),4101 1I,IlO/),IIOI !J,Jnl II, 10o.JI
I...n..n... n.' ~'.J/~'.I 20.' 19.' II.' I' 1,200 2'.' .ao.~
20.4 "4. II 140.'1 111.0/11.'1 110,'1 II' .'1
(ug/LI
(u9/LI
(u9/LI
(ug/LI
C ug/L I
(u9/1, )
(U9/LI
(ug/L)
( u9/I, I
(uCJ/L)
POOR QUALITY
-------
T,lIlll' 1 ()
SUKMAAY or SURFACE WATBR
CROV8LANO WELLS SITE
SUPPLEMENTAl. MOM R I IPS
CROV!I.AND, MASSACHUSETTS
PACE TWO
MONITORING AF.SULTSIIII II
John.on ..Indlo .'oo~ John.on C.oo~/V.II.J SII./MIII
c.... Pond ",.. John.on C.... ..10. .ond
.
"a,...'., Up."... Up.t....ol Down8,.....t Up.troo. 01 ..III .oncl ..111 .ond Yr..'..nt 00"n8t'...
01 Voll., Ch..t..lon Ch..t..ton .ond Inlo, Ou,lo' A. It h_tI " .,Uo. 01 MIll Ad I II_II
SM-' SW- II S".IO 1"-1 SN-' S"., Av..o,.,I, Dlo""o.,. .onel .....,.111
1"- IS IN.'
.-
J
1110:'01 6.1 IS.' - -..
.ot...IU8 1.100 )" UI/)" 1.660 1.'00 1.610 1.6'0 ).9'0 I. "0 J,II.
II. "OU' '1.~60U' 'I. 4JOUII. HOUI ...noul
lol.nluo ...-
~_...-.
Siho. '.1 )0.1 n.1 19 ~ J n.) n.I
I~. IJ' I~.O' ".1
-
Soclluo '. )90 ','10 10. '00/10. '00 '.0)0 9.010 I. J90 1.'6'.' U,'OO 9."0 II,II~
"I, tOOl "'.~OO' ..), 1001lt,OOO, "', .,01 11).)001
! Von.dluo 1. I -. - - ....... -
Chlo.ld. CCLI lo,/L, II IJ 10/11 8.J II II ".1 U II
1)).'1 P8.81 IH.'I'I.'1 Pr.11 UI.11 JO
IIlu.,o.lIh...o 0.' 0.01 0.09/0.0' 0.1 0.' 0.1 0.' 0.'
'"01 . IIOJI ,.,/L' 10.)4' 11.111 10.lt/0.1" 10.'" .., 10. JII 1.0
---
O.tho ."o.phUo IO~.' O.OIU. O..IU D.OIU/O.DIU O.OIU D.DIU D.OIU -...... ...IU 0.01
I../L' 10.011' 10.0111 10.0J/0.OU' 10."1 ID.OUI '.008
lullo'o I../LI II J.' 6.'/6.' II II U II.) U u
16.UI '6.'1' 16. Jl/6. 64' '6." '1.11' II
. ~ .~_....
1'0'01 D"ool.od 8011.' .1 91 61/" It " .1 II. I n
11'01' lo,/L, II'" IU8' pOO/lIII IJlII III ,uOI III
--
Tot.1 IUlponelod lolldo IU IV IV/IU II. .v .v I 'U
CTlII C../LI 11101 11.1" I I. 9/MD' ........ 1101 '
11'0'.1 .holph.'o ID
11101 10.0111 10.Oltl
(U4)/L)
I uCJ/L»
IUej/L)
lug/L)
I U4)/I.)
I u4)/I.)
(ug/LI
(u4)/L)
IU4)/L)
(ug/LI
POOR QUALITY
-------
a
o
1".11" c' I II
SIII'IMAMY OF SURFACE WATER
CROVBLAND NEI.LS SITE
SUPPLEMENTAl. MOM AliI'S
CROVEI~NO, MASSACHUSETTS
P"CI!; TBRRE
MONITORING RESULTSIIIIJI
John.on Cr..' '.10" Unn...d Trlbuler,
.'9" \8 8'00'
~ohn.Dn c~~.. ..10. ..",.. .,00.
''',1
'" J
....th..' Ic
..".re..111
5'" I J
..lIh_t Ie
.nre'lieUI
.". I
.rlt_lle
"".re..111
..,...,.,
M.th,l.n. chloride IU IU IU/IU .-_. IU IU - ....... IU IU ........
O. JJ I IU/I 0.' IU IU 1 o. rJ 0.'
Trlchloro.th.n. 18J1 PJI I tJl II. JI .-.. PJI
.."..n. IU IU IU/IU - .. - - IU IU ---- IU IU ....... -
Tolu.n. IU IU IU/IU ---- IU IU ---- IU IU ..........
n.lu H.~U "U/69. JU ItO UI JI~. ~ .,..U JU U2.~
.lu8Inu. IUIUI I )lIUI IJJIUI .-.' IUJUI
_.
A...n'c ........ .. ... . -... J.J I.'
..
I.' 1.1 '.'/'.~ I.' J.' r.' r.' I.' '.1 J.~
...Iu. IU.IUI IU.IUI 118. ~ul \)0. 'UI
Celc IU8 ','10 10,'00 10. roo/IO.IOO 10, JrO It . 100 1\,000 .. ,'00 10,100 II,JOO 10,'00
IU,lDOI IU,JOOI 116,1001 118,0"1 III, .001
IChrO.IU. -. " -..... -.. .....
IU IU IU/IU -.-- IU IU
I,J-Dlchloro.th.n. ITo1e11 IUI IJJI 12. JI IU tu -_.- IUI .... - -
I JJI
Chlorofor. IU IU JJ/IUJ I IU IU ........ IU IU ..........
I,,-Dlchloro.then. IU IU IU/IU .... ... .. IU IU ........ IU IU ........
---
1,I,I-T,lchloro.th.nO IU IU IU/IU ---- IU IU ....... .. IU IU ....... ..
III 2fJ uo/ue '".' UI ... IOJ IIJ "I UI
lion IU'I I'UI lUll lUll 1It'I
L.ed 1.8J I.' 1.1 J.' 1.1 I. rJ "I 1.1 .., ,. J
--
(U9/L)
(u9/L)
(u9/LI
(u9/LI
(u9/L)
(u9/L)
(u9/L)
CU9/L)
(u9/L)
(U9ILI
POOR QUALITY
-------
,
Table III
SUMMARY 0,. SURFACE WATER
CAOVElaANO "PoLI,8 81TE
8111'PI.".I'IP.NTJlU, MOM A 1/..8
CAOVP.I.ANO. MAS9ACHUSP.TTS
PACE rO""
MONITORING RESULTSI.,1l1
~ohn.on c.... 'olov Unno..d T.lbut..,
a"lIlo 1.00'
John.on C.oo. lolov a.,lllo '.0..
SII. e
5W.2
a.lth..tlt
a.o.o,olll
SW' II
a.lth..tlc
a.....,olll
....1
a.lt'-tlc
a....o,.111
P..o..to,
lIo,n..lu. 2,210 I.'" 2.'00/2,JIO 2,nl 1,110 ),1'0 J,nO I,J.O 2,no 1,'0'
IJ. U031 1',4"JI II. .oUI IJ, .011 II,'''JI
10.' 2S.' U . JIll n.2 ..., .... U.I Ie n.'
Nan,.n... IU.II 11).11 '''.'1 In.11 111.)1 '0.'
"Idol at.' .' Ie.' - ~ -... II.' II.'
'ot...lu. 1,110 ., OlD I. "0/1, "0 I, 'JJ 1,1'0 I,no I,U' 1,"0 I, no 1,'00
II,"OUI II, noul ,I."OUI II, tJOUI
..a.nlu. .--- --.- ..... J.'
1119.. '.1 42 11.2 11.1 )1.. 111.11 - ........
. Sodlu. 1,"0 10. '-00 10,000/10,200 ',").) n,lOO n.loo n,IO' ',no 11,100 .',1"
I". '001 IH,IOOI 111, )00 I Ill,.'" 111,1001
.Vonadlu. .. - -.. -. .... ).1 11.1
n )1 11/11 n.' 50 u U II JI II
Chlo.ldo ICLI I...,/LI I". II I"." '40." 1"1 I". 'I
IIH..t.-IIlt. Ho 0.' 0.' 0.'10.' 0.' 0.1 0.4 0.1 0.' 0.' ..,
1110) . 110) I I...,/LI 10.))1 10.)1 10.1' 10.411 1'.'1
Oltho Phoophoto ,OPOel O.OIU O.OIU O.OIU/O.OIU .. -..... O.OIU 0.01 '.OIU O.OIU
O. II ... - ...-
I../LI 10.OUI 10,'211 '0.041 10.011 lo..el
10 U UIU II.) IS II n.' n tJ 12.'
lul roto I../LI 110. II 110.0' 110.'1 110.'1 111.21
..
Total DI"o"'od Solid. JI 74 "/10 12.) 55 I)) U II 11
ITDlI I../LI 12111 POll UUI lUll lUll "
Total Su.ponclod Solid. 4U IU 4U/IU IU ' ,., IU I
............ ,
ITSSI 1.9/LI p. 'I IUI IU.21 11.'1
I Total Pho.phot. liD 110 10.OtJl .IO.OUI
IU9ft)
CU9/L)
IU9ft)
IU9fL)
IU9fL)
IU9fL)
IU9fL)
IU9fL)
IU9fL)
I'"J/L)
POOR QUALITY
-------
o
(j
T.II.\\' 10
SUMMARY or S8DIMlrN'l' SURPACIr
CROV.LAND MELLS SITS
SUPPLEMBNTAL MOM RI/PS
GROVlrLAHD, MASSACHUS8TT8
PACK PIVIr
MATO MONITORING AlrSULTS...UI
11) Arithmetic averag- calculated uslnq one-half the salllple.quantitation limit ISOL) for nondetect values. Averag..
are calculated for data group. that have at least one positive detection for a parameter. A blank .pace indic.te.
that the parameter was not det.ectt'd and that the SOL for the sample 19 the Contract Required Detection Lllllit
(CRDL). .
12) Surface vater .a"'pl.. were collf'cted frOIll location. I throuqh 8 dur!nq the ..cond .alllplln9 round. Only.the
po.ltlve detection. are pre.ented In Table 4-18 In brackets I ). The sample quantltatlon 1I1II1t for the nondetect
VOCe ranged frolll ~ to 8 uq/L.
I]) Thallium and copper were d~tected In second-round samples SW-4 and SW-j at I uq/L and 6.4J ug/L, respectively.
u
Parameter vas not detected.
Value presented 1. the sample quantltatlon limit.
J
The analytical re.ult presented vas qualified a. an estimated concentration ba.ed on validation of the analytical
data.
----Arlthmetl'c average va. not calculated becau.e positive detections were nut reported for the data group.
POOR QUALITY
-------
';IIMM"A Y
T.lhll' II
0,. SP.OIMP.NT MONITORING RP.SIJI,TS( It III
GIIOVP.I.I\NO "F:I,I.S S I TP.
SUPPI.D4t:NT"I. MOM A I IFS
GROVEI.AN", MASSACHUSETTS
John.on ..In''l. III"o~ .Johnlon c...h/V.II.y 511./MIII Pond A...
C.pd John.on C...k 8.108 Pond
P.t."'.'.' 11,"1 . .... IIp.1 n." Oo"n~'f"fI'" 0' ".lth..t Ic tI,., , '..IR "III Pond "III Pond ,....I_ot Downetr...
o' o' ".lth_tlc I,.t.. o' ""I ".lth_llc
o' V.lley ("h"I'."on ""e....111 Inl.t O"II.t
50.. Ch.....ton SO.IO Pond 5D' J so. ""...,.(11 Ole"h..,. Pond "....,ull)
10.11 50.1 80-1S 10-'
._~
Meth,lene chlo.lete J U II U J U/6 II .. .. IU 10 U II U - - .. - 11$ IS U . -.. -
---. --. --.. ._-~. -.-- - ---. .-.------ - .- _n- -- .- --' ...--- -. ..---- --.. ..- ------
Ac.ton. .. II 21 11.1 .. 11.'/1 J II.' .. .. 14 11.1 140 .I II 11.1 St.' III n .I n
--' ---------- .- ...- ----- -- - - .. - _...0 - . -- - ---- ...-- - -.- -.---- ... .- -. ----- ----- -. __0___- --------.
Tett.chlo.o.I',.n. I II II 11.1 I 11/. .1 e.' '" 10 UJ 6 U -..- "I , II
-_... --' ._- -- n' ..- " 'n '. -. -- ---_._- --- -- -.--. .-...
To'u.n. I U II 11.1 I 11/6 II .... "' 10 UJ 6 U - - - - 11$ J U ..
. - - --------- - - -- . -------- --- - ..- - n_h- ------ '- '- ____n- ---_.-..-- ------ ---- --- --~-- -- -.--- .-.
l,l.Dlchloro.'h.n. .e .II
-. --------- ---- --' ---- --_..--- - ---. -- -- ---- u_--- -.. - - ----. --. -.------..-.- --~._._--- -----. ..-.----- -----.--_.-
Chlo,o..th.n. 14 .11
- - -..- - _.---- . -- ._. ..----. ----. ---- -- -. -.- ---...- - ---- ._--- -- --.--. ---- -. -_.- f--_.. ..-
J N.th,lph.nol 1,900 UJ J,'OO U.J J,OOO 11.1/1, '00 UJ .--- 1,100 11.1 J,IOO 11.1 1,100 UJ .. -... - liS '.001 W ......... -
...- - _u_---. --.--..-- ------.-. --. - ---.- .- -. --. -.-- ---- --------.- --- --- ------ ---- ------
".nlo'(' .cld ',100 UJ 190 .I " JOO U.I/I, .100 11.1 nn 11t01 1.'00 U.J 14 ,000 U.J 1,000 UJ . -.. - 115 9,100 W .- .
------.-.---. - - .- ------.- - -------- -. - --. - -.. - ----.- -.----- .. -- ----- ------ ... ---.- --- ---- -- -.__.. -
Ph.n8nth,.neo 190 .I 1,900 U.J J,OOO UJ/I, 100 11.1 .-.- ..0 J 110 J I, JOO UJ 41) 11$ no
(UOI J no
---...---- .--- - --- -- .--
"nthr.cen. 1,900 UJ J,'OO U.J 1,000 UJ/I,JOO UJ .--- 1,800 UJ J,IOO UJ I,JOO UJ - - -.. liS ',008 W ...... - -
--.----- ---- .--- ---- ----. ----.---- ---.----- -.--- ---- -.- ---- -- - ... -- --.
rluo,.nthen. 410 .I 1,900 UJ ',000 11.1/1, JOO UJ - - - - 110 .1 1'0 .I 110 .I 140 liS 180 J )III
- -.. --- .....__._-- - -- .------- ---- ---- -- . -- -_.-- --- -.. . - +--- -- -_._-- - .-.-- ------ ---- --.- --- - .._--
",r.ne .eO .I J,900 UJ J,OOO 11.1/1,100 11.1 . - - - 110 .I ..0 .I 180 .I III liS 410 J 480
-- . - --_. . - -- d .. _u_.-- -_._-- ---.- .--- ---- - -_._- -.---- --...-' --- --._- .----- '_.n -.
.eo.,1 but,1 1,'00 UJ 1,'00 J 1,000 11.1/1, JOO UJ n 119001 1,800 UJ J,IOO UJ 1,100 UJ - - -.. liS ',001 W .-..
phth81."
.--- -.--- - -.-. -- --- ._- -.-- - .-.-- ------- --...-...--- ----- --'---- -.-- .. .--- .- -.-.
.eonloC.).nth,.c.ne no .1 1,'00 U.J 1.000 U."I, '00 UJ 1..00 11.1 no .I 1,100 U.J 'U 185 IJO .I ))0
---- ,UI,
. - -. --- - u_-- .-- ---_.. - .... . --- --. -------- ---- ------- -- --.--.--
Ch.,..n. no .I 1,900 U.J 1,000 u.I/I, JOO UJ ......... 1,100 UJ J,IOO UJ I,JOO IiJ .... - - 115 no .J "0
--. ---------- _0.- -'---' ---- - _. - . - - -- - .-... .---.- '" .-- --." ---- --_...-- -- --- -------. -_.- -.. .-..
.i.IJ-.th,lh..,11 1,'00 UJ )10 U 2,000 UJ/I,JOO UJ .. - -... 1,100 UJ J,IOO UJ no U .. - - - 115 100 U - - ...
phth81.tp
------- ---- ---- ---_. ----_..
.enlolbl'luo..nthen. ~IO .1 1,900 U.J J,OOO UJ/I,JOO UJ -.... - 1,800 UJ 2,100 UJ 1,100 UJ .. -..... 11$ ',000 W ..... . -
--- -_._--~ --- ---- ------ ---- --- --- -- ----.--
..nlolklfluo..nthpne no .1 J,'OO U.J J,OOO UJ/I,100 UJ ---- 1,100 UJ 2,100 UJ 1,100 UJ ........ III ',000 W .... - -
- _. ----
.enlol.lp,r.n. 800 .1 J,'OO U.J 2,000 UJ/I,JOO UJ - -- - I ,100 UJ ',100 UJ 1,100 UJ ......-.. .1 JIO .I JIO
-------..---- -' --- -- --------- . -------< -- -- _.-.
J net.nol I , 1. I. I'd I 1,900 UJ 1,900 U.J 1,000 IIJ/I,JOO UJ .. -...- 1.100 UJ ',100 UJ I,JOO UJ - -.... 115 1,000 U.J - -.. -
p,ren. ---------- ---- -
------- ---- ----- ----- '"
lIenlol"h,llpe.,I.n. 1,'00 UJ J,'OO U.J J,OOO UJ/I,IOO U.J . -..... 1,100 UJ 1,100 UJ I,JOO 11.1 .... - - 11$ ',001 U.J .---
(u9/"CJJ
(uCj/"9 )
(uq/"Cj)
(UCj/"9)
IUCj/"9)
(uCj/"CJ)
(u9/"9)
(U9/19J
(U9/ICJJ
(u9/1CJJ
(u9/119)
POOR QUAL\TY
-------
T;IIII.,
II .
SUMMARY OF SEOIMF:NT MONITORING
GROVEI.I\NII Wt:I.I.S S 1 TP.
SUI'PLDlF:NTAI, MOM R I/rs
GROVf:I.ANO, MASSACIIUSE'M'S
I'AGE '""0
R P.SUI. TS' I " 1I
,
o
C>
Johnlon .,;n'''~ 8. no' Jflhnson rle~k/V.II., 5 It e/Mll1 PDnd Ar.. ,John.on C.... ..ID" .ond
c..~k
Pal."'.'.' 111"" ~.. II,.., ...'" Onwnl' I"'.. fl r Up."..'" Mill PDnd Mill Pond Tr.....n. Downetr...
DI ".I.h... Ie .., ".Ith_tlc S,..~. 01 Mill ". i'h..' Ic
01 y.II~, r.h..,p.lon "... 'gelll t nlet Oulle' "...,.,.111 DI.ch.". ."",,0111
Ch..t.rCon Pond Pond
SO . 50.10 50. I 50..
5D-1I 5D-' ID-U ID-'
IIIKJ/lIg)
"1...lnu..
6,5)0
-- ---..---
-----
"..on Ie:
IJ.I
-. .- .-'-
-.
..---..
...Iu..
n.9
.. ---. -" --
. - -
-. - ---
O. )J
...,lllum
....---
. - . - . - --... .--. .d . .
C.ldu.
4,600 J
. - --
.. -
--- -.
Chln.lu",
15.4
-.-. --- -.
------'-
r"holl
'..1
--_..- ."
.-
..----.
COPP"
9)J
- - ---.- .-.-. --
.-----
lion
10.400
--------. _...- ..
.-----.
I...d
I.OJO
...." ----- -
------
N8qn..lum
8 , 4'0 J
-- ---------
---.- u
"8n980...
~10 J
-- -------- .._on'
---
0.14 J
".fCUlr
----
-- ---. --.----. ..--
11,('..1
14.) U
- .--"'--'
--
.--'
Pot...'um
1,010
-- -----~-- --
I.IJ
Sol.nlu..
.- .--.-----.. ---
-----
Silw.,
-UJ
-- - ~ -"-'
. ..'-- .-_...
--
5Ddl...
191 U
- --...-.-----'
---
Venedlu.
)0
- - _.- ---
- U'-' .--.
IInc'
166 U
Img/lIg)
\,860
-----.----.
'.1
--..-.- --.-
H.9
-----"---
...-----
1.1'0 J
..-. . --' ._.-.
11. ,
- ...-'
1.)
-
18U
------
6.180
-.------
14. J
--- - -----
1.440 J
-..- - - - __-A
In J
--_.- -.---
0.16 .I
-----
r. I U
-.---.---
15\
1.1 J
----
4.1 U
---
91.1 U
--
II
------
19.9 U
----.-
POOR QUALITY
ORIGINAL
(189/119)
6,510/4,6100
-------. ..
11.1/11.6
._-----
U/14 \
-_u. -
-.--- _...
-. _.
1."0.1/1,100.1
-.
14.'111.8
.-. -.-.--.
8.511. ]
------ .-
n.6 U/I1.8 II
-- - ---- - - - . - -
10.\00/IJ,100
-"- -.-----.. .
19.6/11.) .I
----'-- --.
I. no J/J."~O .I
.-----.
"8 JI1Jl .I
------ -
-UJ/-UJ
---.----
JI. J 11/12.1 U
----
194/481
-UJ/-UJ
------.- ...
-UJ/-UJ
------. --- .
1\1 U/64.9 U
----- ----.
IJ.J J/I4.6
- - ---
U.2 U/42.4 U
Img/lIg)
512\
-..- ----
II.'
..-----.
21.6
--..
_.---
-.----.---..-
lJlI
.. . --..-.--
11 .9
.--.
1.1
---. -_u.-
- - - -
-----
1540
..--------
14. )
.----------
"I.
.----
))6
. --.,-----.
O.IS
.- ----
.---
.- ..
----..----
HI
-~ --
...-.
1.9
-.---
. - --
-----
- - -.
.---
1).6
-----
. -...-
.---
(18CJ/lIg)
,..lU
14.680 JI
--- hi: .---
11.) UI
_h' H". i -
.. "I:~!.-
10. III
-",040 'r
18nl
-- 1.: ~ - -
116.1JI
--- i : i-
I).DJ
- U.'1 ii 'iI.4 j-
18.9.11 IIJ.' .II
--',140'- '-'r;66Ir-
14..,UJI 11,640 JI
- H':; - "0. \ .. ...
11.'.11 1)).1 JI
..6J1I J ','1111 i-
11.1101 11.1101
-'1. i'J -HI j--
-1JO:~J! -- -_.!!~~-~!-
-UJ -UJ
--7: n.-- - -, J Tif--
--1~:~L- 110.11
2JO '--'41-'-
1)80UI 1~4rU/'44U
.._-- -_!-
'UJ -UJ
---.---- ---~
-UJ -UJ
-..:ro- -n-TU-
1I04UI 1111 UI
---'.0"- -B,l
12.IUI 119.1 UI
--j,.~,..u- -n:nr-
121.11 iu.~1
189/119)
);~40
p, ]90.11
-'- 2T
12.0UI
-- i I.)
--' JJ : II
10 291
-nil J
: 4J IJ
-- I I. .
._11: UI
1.1
(IMJ/lIgl
118CJ/Kg)
1.IJO 1.7.J
!.!!..~.~q!!!!2L .J!C!!J-
'2.1 uil., UI J.t
-- _u- j: j--- -n:-r--
--. !? Y ~ !. ~L- - --'-!!.:.! L-
10.161 10.)1
--'---HI j--- -l;nr-
-_!~~.!'!IJ- -- P2~
6.' U ~.
'4.6 J/'.O JI 'lo.~1
--.------- --r.T--
I.~ '4:)1
----lI:ru-' -"'~T-
11.4 J/)I.2 JI 114.JI
'--';060--- -r.TII:-r-
i~.!!~_~ J/.'.~~!.-~ --'~I-
16 .~.I
._!,~'I.t{~..!-.tL -\~~
-t!I!;Cl,6JI0)-- -4;'-P-
-1~!:.! J(!!~~L --1!~L.
'UJ u_-
----". i-ij-
--_.I! :~'-- .--!.~~-
n~
11" U/HJ ul
no.'
--- ~
-UJ
. - --
--..---- -.
-11.1
----n:.'u
191.2 U/I~
4.4
~6 U/'.6 ul
. . ,.:-1 ...---
116.1/16.01
- - --
- - --
9.2
li;:il
(IMJ/IIIJ)
liS
---
--.-..-
-'-"---
--'----
--- .---.
-----.---.
--
--
--.--
-----
----
--
---
"'
CIMJ/Kq)
..-
J4:li:-f:~ ~:~~--
nt';j!J- ~~: I ---
_!l!~~I_- __l~_- ---
CIMJ/K9)
115
115
.-
115
'-;11"11-'- -.: I~~--
-W't- -..---"
11).2 JI 18.1
."--~~:~J= =-~- 0 -~._.
.Jif.;riL --~ '... ..
(I~~ ~i~_-!L_~~: ~o~ -..
-\~~.JJ- __._I~_- ---
_J~,}jf- _1~9~~ -.-
-'!~~1- _.~~~ ----
-UJ ----
-Il-:ru- --.----.
- -'
Inl ----'--'-
412
'682 ul
115
115
liS
liS
III
liS
liS
"'
III
liS
492
---.--.-..
liS
liS
-UJ
--- -_._--.--
-UJ
- ---.r....-u-
1104 UI
~1:~i'JI II~;---
JI:TU- ---.- ..--.
in.'. _u-
----
-
. .
--------
liS
- ..-
"'
-------
-1;1 II I,' I I
SUMMARY 0,. 6F.11I MENT MOM I TOR 1 MG
CIIOVF.LI\NIJ WF.I,I.S S 1 TF.
r;I/I"".n'lt:NTI\', MO" R 1/,.6
GHOVF.LANIJ, MASSI\CHUSF.1'TS
PAGE TRHF-F.
".'8",p.I..
~elhl!!,,! ch!o!..!de___-
acetone
. .. -_.- ---- -- ----- .---
!!I!!,,~!~~oethene ---
Tolu.n.
." ---- --
1 Me'h,lph.nol
-
- -- - -...
8~n.o'C acid
-- .-.
---- - - -
ph..nanthre".
..- - - -- -.
Anthr.e.""
. - .-
. ---. --.
...un..nlh.n.
---
--- --
--
P".ne
~. ------ -- .-
.-. ------
Bano,l but" phth.lat.
- -
.- . -- . --- --_.- - ---
"enooC.,.nlh..c.ne
-_. -- _.---
-.---
Ch.,.en.
----------.
.... 1 1 - . t h, 11...,1 I
t.~'~~I!~~~~ . - .----
...n2o(b,fluor.nlhene
-- -------
ft.n.D'k.fl"~r.nth.n.
-.-----.--.----"
8.n.o(.'p,r.ne
------
Indenotl,l,l-cd'p,rene
---"",,--- -----
8en2ol9,h,I'per,lene
RF.SUI.TSIIII II
5D 4
John.on Cr..' ...1..\11 Uun....." T. tbutar,
A.. th......t 1("
A.....,.I II
(U9/119t
16 U
111 UJ
6 U
.---.--.--...-
6 "
--
1.600 UJ
--
_.- .. -.."
50 )
(u4)/IC4) .
. U
----. - -_.-~_.
U UJ
--- - . -----
. U
- ..,-_.~----
. U
-
1,000 UJ
--- --
',600 .,J
--
-
'.000 U.I
--...
--..
1.000 UJ
--_.------
1,000 11.1
--- -
1.000 UJ
.-.----.
1,000 UJ
- -.. -- -----
1,000 U.I
------ --
1,000 UJ
-.------
1,000 UJ
--- ----
1,000 ""
---.
.-. .-_. - - -- .-
610 J
--
- -. .----
1,000 UJ
----
1,000 UJ
.-----.---
1,000 UJ
1,000 UJ
1.000 UJ
POOR QUALITY
- ORIGINAL
110 .I
p"
-..-- --
1.100 J
.. --
_____n'__--
1,800 J
--------
I.~OO UJ
--- ------
1)0 J
----
no J
-- ___d.-'--.
140 II
-- -.--
.-.- --
610 J
----
"OJ
-_...-
--------- -
640 J
----
160.1
UO .I
50 1
IU9/119)
(U9/K9t
u- II ~n..!'___------
..- 61 .:!{8!.~______1~- I
1!,(~.~_-- -----
I U/6 U
-----
1,100 11.1/1,100 U.J
u.
- - 0-
.---- -
8,400 UJ/8.'00 U.J
-- . -. -.
1,100 UJ/I, 100 UJ
- -
--
.----..-
8.100 UJ/I, 100 U.I
-." - --
I.JOO UJ/I,100 IIJ
.------.--.-
1,100 UJ/8,100 U.J
.- --..--..
110 J/8,I00 UJ
.-- -----------
1,100 UJ/I,100 UJ
--- -------
8,100 UJ/8,IOO UJ
---
--- --
1111 11/1, 100 U.J
--. --
1,100 qJ/8,100 UJ
- - -- - ----- ---
1,100 UJ/I.IOO U.J
.-------'
1,100 UJ/8,IOO UJ
- -.--.
8,100 UJ/I,100 UJ
- -_._.
-----
8,100 UJ/8,700 UJ
---..
-
--
---
----.. -
840
_____1 ~!O '---
6"
- - !' 10 I
1,011
~!.,100l
1,08)
u.!! ! ~OO,
16 )
11)0'
849
( IJO'
-- -----
860
(1)0 I
- - ---
50 I)
(UCj/"9)
--
,)
II J
-~-- ---
8 U
8 U
810 J,OOO UJ
~_!O'------
..0
_~~IO'u-
810
..~~'--
10) 1,000 UJ
--1!'-~I- ----
190
(UO,
--
1.000 UJ
---.
9,"00 UJ
--
1,000 UJ
.- -- ---
1,000 UJ
_0-_----
1,000 IIJ
---------
1,000 UJ
------------
1,000 IIJ
-------.-- --_.
1,000 UJ
J,OOO UJ
__0___-- --
,'0 II
1,000 IIJ
---- -.--
J,OOO UJ
1,000 UJ
".,111. 1I."o~
(U9/IICj)
II U
t8J
8 II
---- ,---
8 U
-- - ----
100 J
--- ----- ---
',000 IIJ
. -
-----_u
8,900 UJ
-----
1,900 IIJ
....- ----_..
8 ,900 11.1
----
8.900 UJ
--- ---
8,900 UJ
--- --
8. '00 UJ
.------
1,90n UJ
------
. . '00 ...1
--
---
8,'00 UJ
-------
8,900 UJ
-._- --- .--
1,'00 UJ
-
1,'00 UJ
1,'00 UJ
Ar Ith..et8~
"vere,eCl'
(U9/119.
19. )
--- -------.--
66
--- -----..---
- - - -
--"'---"-
. - - -
--
-
-----
.._.
'00
!10~L-
-- --
--
-.------
--
--------
----
._-.
-_. -
-.--..
--
- - --
--.-
----
--
......... -
... -"''''
-------
-. -----
... - -...
----
... - . ...
----
...--'"
......", ...
-...... -
.John.on c....
50-I
- (ut/-t)
. U
--_. --
IJ UJ
------
7 II
----
I U
---------
8.100 UJ
---.--
8,100 UJ
0.10. Ar,811. I'oo~--a-
50'. "~II"-t"-
......,.111
lug/lit)
9 U
--------
U UJ
----,-,,-
---...- --
1 U
---
..- -- ---*
1,900 U.J
--..-
..---'
890 J
------ ----.--.
----
1,100 UJ 1.0 J
--- ---
I, '00 OJ 1.'00 UJ
--- -.-- -.-.---
1,100 UJ )00 J
---
1,100 OJ )00 .J
-----
1,100 UJ ..0 .J
------
I, rOI UJ 8,'00 UJ
1,701 OJ
',100 U.J
-- -----. -- ..
1,701 OJ
---"
1,100 UJ
--.--
1,701 OJ
1.101 UJ
1,701 OJ
110.J
---.-
.On .J
d-
)to J
---
1,900 U.J
--------
8.900 UJ
8,tOO UJ
--
1.'00 UJ
IUI/"I.
-- -
-
~ - - -
---
- ~ - ~
---
---.......- --
-------
1. ..,
- !!~~~--
.n
~!~~!
- - -
-_.-
~"
-----1~!~ 1__-
,,~
-1.!!!L
In
~!'L-
~ . . .
----
-- --
~n
~~~~I_-
11"
"!Ol
.n
_!.!~!
---
--....
... -... .
. -... -
...---
-------
o
v
T;thll' II
SUMMAIIY Of' SF.IIIMF.NT MONITORING
(;IIOVF:I.I\NIJ WI':I.I.S SITE
SIIPI'Lr.M,.:HTAI. MOM R I/rs
GIIOVF.I.ANO, MA~~ACIJIJSF:TTS
I'AGF: fOlIR
RF.SIII,TSII'll'
Johnlon c,..~ ..Ioy Unn8..d T.lbut..,
"'9\11. Iroo.
John.on c...~ 1.loy ""III. I,oo~
50 4
~D 1
".11 h..II..
""""0111
SO I)
", IIh_tie
"....,.111
50-1
a, Hh_t i<
a..,o,.II'
Pal 18"'.''''
---
Alu...lnu... 1.910 6..10. 4,~~0/~."'0 4,9'0 1,910 ), .10 ),410 J,IIO 1,"0 1.1J'
11.660 .II _!~,IIO JL 11,990.11 I.~. ~~Ol IJ, "01
.. .- "h--':~ -- .,.~ . - '/'.1 -. .- .- . - .- - - - ----.--- -_...:! .--- --..-- ----
AI..n'~ II.' ul 1 ~. I UI 14. I UI 6.6 J.l J.I ,. I 14. 1 UI 10.1 '.1
.- . - ".- .... .-:-.- -.n:T--. .- iid/lo. \. - --.nT - -"--.----- - ". ----- ,"_no- --.. ._--- - --.1"i:"1 -- ------ --- ---
...In.. __"!~~!.- In.l' 110.11 119.11 10.0 11..1 10.' -_!IJ.:.~L 14.' 41.'
- - ..-.- - -.. ..- - - 0-:'-. -- Iii. \ --- ..- - 0.. - .. --- ...---. ------ .---.---. - ."--. ------.
lu , III um lo.nl 10.'" 10.41 - . ~ ~ O.U 0."
--.. -.- - ...- .-- .---sn J ' ..- .-1;1111 .J- - nil UI,2111 roo -- -1 ; 0111 -.. .. -.--.-- -------- - -,: 1In-:r- .-----". --_. ..---.
C.lrlu. 1801' 11,110"- Ilnl 11,141' 1,160 .I 711 .I 961 __I~'p;L- 2,160 .I 1,110
-- ..- .. -- n- ..;, .-- )11".1 iLI/li.6 - .. ..-. H.2 .-- .- -... .... - -. -. --- ..h_' -- -_._---
Ch,n.lu'" '10.1 .I! 1)0.6 .IL 11.6 .II 116.61 1.6 U II.' 1.1 11.\ .II 16.7 ...1
... .. . -- '.1 -- _.- .:r 1. ;/\.0 -. .. -- ..... - - ._--- --'-.- ---..-- -- I:r---- .----..-- -.-- -----'--
("0",'1 (,. " 1'.21 1.5 1.4 1.45 6.0 4.1
- - - -. TJ:i if - -,~:I j- -.11.' jilt... U- -.-H~I .- -.- -- .-.-- .---_ .. -- -. -.----'- - - -"'-:'-11- -.------.. .- ---.-
CO"".. 11.1 .I' 110-1 .I, '4.' .I, 110_'1 ..1 U I.' U ---- -4:ML- ti J 5)
-- ---- --_.- - - -_.. -- ---- -.S;ii50-- --io;Uii- _. i I 610/'; 810.- --.-;fH .. --------_... ----.---- .--- ---
I.on (1,1}01 116,600 .I, ~ ,no .I I ---- 110,0161 J,I40 6,J60 ',100 -~~~ 1),\00 10,1'0
- - - - --. H_-- -- -- --.- --n.- -. --jj:. --- (.. i/I:, ---0:; .-- .. _. _.- .---.--- -----_. --- ---- --
L..d 110. I .II 114.' .11 I- . 4 .II 11).11 1.9 1.6 I.J ".5 .II 116 110. J
-. .-....- -1;ill1--j - -. \;HD r ',It/') U2.~2IrJ -,; 111 - - _. ...-. h__- --- ------- -. ;n.--r- ---_.- ---
".qn..lu", 11,6901 14 ,9~01 1',1101 _.J 2,6401 ',060 .I I, liD .I .;)15 ~ J, HO .I 1,11'
.. --.---.- . - -on: Li - -BilT- - 61: 1 jJIiTJ- 19."1.- _. -.---.- --.-.- . .I --- --
"8..q8n.... .-!,S.4.J.L _.I?IJ~_~'- '6)~!. .I} -_!!O~:!L- JI. I J ,J. I .I 45.1 -1!~UL- In .I In. I
------- -.-.'.- -..--- _..-- - -. -.-.------' ----- ---- --_.
"..("u., -UJ -UJ .11.11 11.1 .--- -UJ -U.I ~ - - ... -UJ 0.1 .I 0.'
-- - -.--...---.. .-_. .-- -I-:-rtr- '-"..'.U-- IC1 1i7lJ:'-U- --.--- --. --..-- ---- ... I~
"le..1 - - - - 1.1 U ..,. U - - - - 21.1 U - - ...-
---4~l- -„.WJ- 16,'1 -I1I.Jl ----I...
-- ------- - --. iH7hi -.- - -nT - ._--- - 1"-
Po....lu18 150 In 100 1.))0 "'
.. .-----.-.------- _.-!.!~L -~!?~O_L. .. I \14 .~! .-. --I!!~L - -. ------ -_. J~~!.-~ ----
S.'enlu.. -UJ -U.I . "J/-U.I ~ . - - -II -U.I - ~ -... -UJ -UJ -.. -..
. ------.----. -- - - --- - ---- ..----..--- - ---- -- _.
51"'., -UJ -U.I . "J/-U.I - - - - -UJ 1.' U - - .. - -U.I -UJ - - --
. -~ -. -_._-.. ---.---- 96.6 U n) T- ---11.6 ii7n~nr . -..... .-------' ---- -- 1~4 . , ~I
50dlu. (101 UI 1l0al 196.0 UI -I;.HL- 1'.1 U 11.4 U -.. - - 110 U lit U .... -..
-- ---. -..---- -r.r- -.1"'-- _. .lii.'111.r- ----- -"---.' .~.~- ~J-
V.nodlu. (J. I UI III.' .II 16.7 Ul '1. JJ ... J.J 6.. 11.1 n.'
- -- -. - -- .. .... -- -,-r.-r-- -. -n:lu'-. -- ".iiln'. ij- - -
line iz;.Jf Iji~jl '1.1 U n.. U ---- II.' JJJ U - ......
j'l.11 1I,.i'-
18CJ/ICcJ t
118CJ/IICJt
fmCJ/IICJt
(1IICJ/1I9t
(189/119 t
118CJ/IICJt
f8lCJ/1I9t
f8l9/119)
fl8CJ/1I9t
(819/119'
POOR QUAUTY
-------
"1';1 hi ('
II
911""AHY 0.. ..IR8T ROIJND IIP.OIMI':NT MONITORING RW8U1.T8
(:HOVP:I.ANJ) NF.I.I.S S' Tr:
SIII'I'I,".HY.NTM. MOM R I IPS
GROVF.I.IINO, MASSACIIIJSF.'I'TS
I'AGF. .', VP.
I II
Arithmetic averag~ calrulal~d uRlng one-half Ihp sample quantltallon
I\veraqes are calculatpd for data qroups that hav.. at Ipast one positive
6pac~ Imticatp9 that thp I'iullm..tpr was not drlp!:I..,1 an.1 that the SOL for
IJplprllon I.imlt ICRIII.I.
limit CSOL) for nondetect value..
detect Ion for a para18eter. A blank
thp sample 18 thp Contract Required
In
Srotlmpnt Bllmpl..e wpre c:oll....lpd 'or IOl'allons I throuqh 8.
T"hl" 4-)9 In hrllcJcplR I I. Thp Rampl.. qUlIlII 11,,1 ion IImll
1\11 <;reo",l-rc'IIIHI mptals "'<;1111<; dIe prpsPlltf>d in t.'d..kpts.
Only the pOilU Ive detect Ion. are pre.ented 'In
for Ihe nl.ndptpct VOCe ranqpd f,om (, 1o 18 uq/kq.
Rf>..BURP Ihp nample quantllal Ion limltll for polynuelpa, IIromatlc hydrocarbons 1I'IIIIsi are frequently higher than
actulII positivI' detections, the averaqe of thf> positive detection Cfor thePAHs only) arl' presented In
pllrpnthesf>R.
II
I'a,ampter was not dl'tectpd.
value presented Is thp sample quantltatlon limit.
J
The analytical rPAult
""i'lI.yt Ie,,) dllta.
IHPIIPllt ~d waB
qllBllflrd
as
an
P!ltlmated
concentration
based on
valldat Ion
of
the
11.1
1'h~ value presented Is the f>stlmatl'd sample quant II at Ion limit.
NS
Not sampll'd.
Arithmetic averaqe was not calculated because positive det~ctlons vere not reported for the data group.
POOR QUALITY
-------
"
,:>
v
Tal> II'
I:'
NO. OF RI\NGE OF
I'OSITIVF. POSITIVE I\VEIII\(;F.( I) REI.ATIVE RISK RELATIVE RISK
ut:n:CTIOIIS/ RACKC;ROIlIID
I'll RIIMt:1'1:1I 111'1/1.1 FACTORS - FAC10RS - RI\TIONALE
()F.TECTIOIl5 I:OIIO:IITRAT I 011
NO. OF '"'1/1.) IIOIlCARCINOGEIlS CARCIIIOGEIIS
SAMI'LES
TrichlolHPlhelie ~(,/I 18 I .~O,OOO 144. J (1'':\8.41 . - TIII\ 0.415 p. incipal site contaminant.
1,2-IJIC"tllorc,ptI1prtP 44/118 0.)-4400 IOb.1 1210.41 . - O. 11>9 TNA p. incipal site contaminant.
.. ..
Te1 rachluJucthl!n.- 1/118 0.)' n 11.8 (20. II ." 0.006 0.00) B-2 carcino'Jen.
Tolupne 4/118 1-5 12.8 12.251 0.00001 111A Low concentrations and inf.equently detected;
however, a contaminant of concern for the
Valley Sile Source control Operable Unit.
Methylenp Chlo, .de 2/118 0.4.0.9 I J. 4 (0.65) - - - 0.00001 0.000005 B-2 carcino'Jen.
-,..
I, I ,Diehl",o"t hane 2/118 0.8 - 15 IJ.O 17.90) 0.". 0.0001 ,-- C ca.cinogen.
1,1,1- 2/118 1-16 IJ.O (8.01 ." 0.0001 1MI\ Historical data indicates compound Is a
Tr ic:hloloPlhane principal site contaminant.
Renzene 2/118 0.2- i 7 1].0 (8.6) --' TN 1\ 0.0004 1\ carclno'Jen.
Acel one 1/118 5 12.1 (5.0) --.. 0.00004 1111\ Low concentrations in Cjfoundw8ler: hovevel
detected in surface waters at 140 ug/L.
I, I UlchJoroetht!ne 1/118 2 12.9 (2.0) --' 0.0002 0.0009 C carcinoljen.
.-
Ch 1 (" ohenzene 1/118 20 1].1 (19.5) , -" 0.0008 1NI\ RRY approaches 0.001.
Vinyl Chlor ide 0/118 1111 1111 .. - - TN 1\ MI\(2) Mot detected, howeve., a contaminant of
concern for the Valley Site Source ConU.ol
operable Uni t.
"ntimony ]/42 19.2-35.4 29.1 (25.4) .. -" 0.0618 TMI\ RRY > 0.001: Conc > PHCL.
ArseniC JO/42 2. I 401> )4.5 (46.]) 19.7 0.)1] 0.55 RRY > 0.001: Conc > HCL.
cm:MICAI.s Ot' CONCt:RN (COC) - GROUNDWATER
. GROVt:I,ANI> HEI,t,S SITE
SUPPLt:MRNTI\I. MOM R I /FS
GROVf.I.I\NO, MI\SSI\CIIUSt:TTS
POOR QUALITY
-------
--
NO. OF RANroE OF
POSITIVE IIACKGROIINO REI.IITIVE RISK REI,AT I VE RISK
m:nTT I ONS/ POS IT I V E AVt Rilla: CONc:t:IITRAT ION rACTORS FACTORS
l'IIRIIMt:TER DETFC1' IONS (II'J/I.I RATIOIIALE
NO. OF (II'J/LI ("'1/1.1 NONCARC I 'IOC;F.NS CARCINOGENS
SIIH!'I,':S
Ba, itlm 18/41 1,1- 1100 148.2 I 1t.1.1) I II 0.01'1 TNA RRF > 0.001
lie. ylll II,n 10/42 I. f,- '1.0 J.O 14.8) 0.0011 0.02'1 RRF > 0.001; Conc > PMCL.
.-. j
cadmi uln (,/42 2.1 ~1,J ~.2 (21.") 0.082& TNA RRF > 0.001; Conc > MCL.
.-
t'hlomiulIl 12/42 4.1- I HO I OJ. 4 (1.14.4) 8'1.2 0.171 TNA RRF > 0.001; Conc > HCL.
I.pad }1/42 I - 4 - J&4 41.4 161. &) 2'>.'1 TNA TNA Conc. > MCL.
..
Maqnallesp. 4n/42 8.'1 7.,.,n 11124.6 (I024.f>l ' bO 0.021 TNA RRF > 0.001.
...
Hplcury 1/42 11.2. 0.1 (0.2) -. - 0.00'> TNA RRF < 0.001; however, a contaminant of cancel I.
for the Valley Site Source Control operable
Unit.
.
Nickel 'lb/42 ".]-816 I 2J. '> (141.41 'If>. ] 0.0]) 6 TNA RRF > 0.001.; Cone > PHCL.
Selenillm 10/42 LI-2]'~ 2.9 (f,. J) -- 0.00'>6 TNA RRF > 0.001; however, Cone < PMCL.
-.
S i I ver - - - - - - - - - - -- --' TNA Detected in surface water at Conc. > HCL; not
detected in groundwater.
-'
Vanadium 22/42 2.2.'>6'> 66.8 (104.2) '>6.] 0.0'>82 TNA RRF > 0.001.
1. i nc 2.,/42 14.9- ]'100 280.'> (48'1.8) 44'1 0.014 TNA RRF >. 0.001.
'1;81".'
I!
CII~:MICI\I.S 0..' CONCt:JtN (COC)
GHOV..:I.I\NJ> WF.I.I.S S l'rE
SIIPPI...:MI':N'I'I\I, MOM R I II'S
(;HOVI-:I.I\NJ>, MI\SSI\('IIlJSE'r'rS
PI\GE ' 'WO
- GROUNDWA'rER
(I)
(2 )
1NII
RRF
1T
HC!.
I'HC!.
of the sample quantllat'on for nondetect values (ArithmetIc average of positIve detections).
detected in the Supplemental MOM RI.
chemical.
Arithmetic average calclliated USing one-half
lIot calculated because this chemicat was not
Toxicity Criteria are not availahle for this
Rplat ive Risk Factor
Toxicity Criteria
F"derlll Safe Drinking Water Act Haximllm Conta,nlnant Level
Fpderal Sale Or inkinq Water Act Proposed Maximum Contaminant Level
POOR QUALITY
-------
">
~
TABLE 13
CUMULATIVE CARCINOGENIC RISK ESTIMATES AND HAZARD INDICES
INGESTION OF GROUNDWATER (1)
Well Groupings
------------------------------------------------------------------------
Cancer Risk Estimates
Ave RME (2)
Hazard Indices
Ave RME
------------------------------------------------------------------------
"AREA A
Shallow overburden
Shallow bedrock
AREA B
Shallow overburden,
(downgradient Valley)
Shallow overburden, "
(Mill Pond Area)
Deep over/shallow bed
(vicinity Valley, Johnson)
Deep over/shallow bed
(beyond Johnson Cr.)
AREA C
Shallow/deep overburden
(vicinity Johnson Cr.)
Shallow/deep overburden
(beyond Johnson Cr.)
AREA D
..
Deep overburden
(1st round)
Deep overburden
" (2nd. round)
NOTES:
1.9E-03
(3 )
2.9
(3)
1. SE-03
3.0E-03
1.9
3.7
2.8E-03 3.SE-03 7 12.6
2.0E-03 3.4E-03 4.3 6.1
2.6E-03 1.7E-02 2.5 7.9
1. 5E-02 1. SE-02 10.5 10.5
1.lE-03
3.0E-03
1.9
6.9
1.lE-03
5.2E-03
3.8
15.9
3.0E-03
S.OE-03
1.9
3
9.0E-03
2.1E-02
6.5
15".7
(1) The risks presented in this table may be underestimated by one-half
because the contribution of volatile organic compounds through the
inhalation pathway is not included in the risk assessment.
(2) RME - Reasonable Maximum Exposure
(3) The reasonable maximum exposure scenario is not presented for the
-------
'1';1 II Il' II,
SUMMARY OF' EXCESS LIFETIME CANCER RISK POSED BY
THE CURRENT POTENTIfU. ACCIDENTAL INGESTION OF ORGANIC CHEMICALS
GROVELAND WELLS SITE
SUPPLEMENTAL MOM RI/PS
GROVELAND, MASSACHUSETTS
IN SURFACE WATER
Exposure Oose Cancer Risk
Carcinogenic Cancer Cancer Slope Maximum
Contaminants of Wei9ht of Factor Concentration Reasonable Reasonable
Concern Evidence (mg/kg/day)-l (ug/L) Worst Case
(mC)/kC)/day) Worst Case
...
Methylene chloride 82 7.5 x 10-) 44 4.1 x 10-6 3.1 x 10-8
....-
Trichloroethene B2 1.1 x 10-2 54 5.1 x 10-6 S.S x 10-8
Benzene A 2.9 x 10-3 0.6 S.6 x 10-8 1.6 x 10-9
Total Cancer Risk: 8.8 x 10-8
..._~
'1';111 Il' I',
SUMMARY OP NONCARCINOGENIC RISKS POSED BY
THB CURRENT POTENTIAL ACCIDENTAL INGBSTION OP ORGANIC CHEMICALS
GROVELAND WELLS SITE
SUPPLEMENTAL MOM RI/PS
GROVELAND, MASSACBUSETl'S
IN SURPACE WATER
Maximum Exposure 008e Hazard Quotient
NoncarcinoC)enic Reference Do8e Endpoint Concentrat ---
Rea80nable
Contaminants of Concern (mg/kg/day) of Concern 10n Wor8t Case Reasonable
(uCJ/L) (ing/kg/day) Worst Ca8e
Methylene chloride 6 x 10-3 Liver 44 4.1 x 10-6 6.9 x 10-s
1,2-Dlchloroethene 1 x 10-3 (ch) Blood 96 9.0 x 10-6 9.0 x 10..
(2 X 10-3 (tran8)) (4.5 x 10-4 )
.-
1,1,I-Trichloroethane 9 x 10-3 Liver 1 9.4 x 10-8 1.04 x 10-6
Total (Hazard Index): 9.7 x 10-4 (1)
(1)
-------
c
t-
T.. h I (! I II
SUMMARY
TOR CURRENT POTENT I AI.
0,. "DCBSS LIP'BTIME CANCER AISK POSED 8Y
DERMAL CONTACT WITH OAGANIC CHP'.MICALS IN
GAOVELAND WELLS SITE
SUPPLP.MENTAL MOM AI/FS
GAOVELAND MASSACHUSETTS
SURFACE WATER
"
Exposure Dose Cancer Risk
Carcinogenic Cancer Cancer Slope Maximum .
Contaminants of WeiCJht of Factor Concentration Aeasonable Reasonable
Concern Evidence (mg/kCJ/day) -I (uCJ/L) Wor.t Case
(mg/kg/day) Wor.t Case
Methylene chloride 82 7. S . 10-J 44 1.4 . 10-6 1.1 . 10-1
Trichloroethene 82 1.1 . 10-2 S4 1.7. 10-6 1.9 x 10-1
Benzene A 2.9 . 10-2 0.6 1.8 x 10.1 S.2 x "10-10
Total Cancer Rieke 3.1 x 10-1
(II
The excess lifetime cancer risk calculated for benzene using a permeability Constant of 1.11 x }0.1
is 7.0 x 10-1
"I";lhll' 17
TBB CURRBNT
SUMMARY OF NONCARCINOGKNIC AISKS POSED BY
POTBNTIAL DBRMAL CONTACT WITH ORGANIC CHEMICALS
GROYBLAND WBLLS SITE
SUPPLBNENTAL MOM RI/FS
GROVBLAND MASSACBOSET'I'S
IN SURPACB WATER
"
Exposure Do.e Haaard Ouotient
Noncarcinogenic Reference Dose Endpoint of Maximum ... ~
Contaminants of Concentration Reasonable
Concern (mg/kCJ/day) Concern (ug/L) Wor.t Ca.e Reasonable
(mg/kg/day) Worst Case
Methylene chloride 6 x 10-2 Liver .. 1.4 x 10-. 2.3 x 10-'
1,2-Dichloroethene 1 . 10-2 (cte) Blood 96 3.0 x 10-6 3.0 X 10-4
(2 . 10-2 (tran.)) (1.5 x 10-4 J
1.1.1- 9 x 10-2 Liver 1 3.1 x 10-1 3.4 x 10-1
Trichloroethane
Total (Hazard Index). 3.2 . 10-4 01
III Hazard Index based on C18-l,2-dichloroethene.
-------
,
T;lhl,' I H
Exposure Dose Cancer ROi sk
Carcinogenic Cancer Cancer Slope Maximum
Contaminant8 of Weight of Pactor Concentration Rea80nabt"e ReaBonable
Concern Evidence. (mg/kg/day)-1 (ug/L) Worst Case
(mg/kg/day) Worst CaBe
Methylene chloride 82 7.5 x 10-) 53 1.3 x 10-1 9.8 X 10-11
Tetrachloroethene 82 5.1 )( 10-J 5 1.2 )( 10-' 6.0 . 10-11
Total Cancer Risk. 1.6 x 10-10
SUMMARY OP EXCESS LIFETIME CANCD RISK P09RD BY TOR CURRF.NT PO'I'EWI'IAL DERMAL CONTACT
WITH ORGANIC CHEMICALS IN SIIDIMENT9 AT Tn8 LOWY.R JOnNSON CRP.HK WATERSBP.D
GAOVELAND W8LLS SITE
SUPPLEMENTAL ~ RI/PS
GROVRLAND. MASSACHUSETTS
°1;1111 l' I (J
, Exposure Dose Hazard Ouotlent
I Noncarcinogenic Ma.imum
\ Contaminants of Reference Dose Endpoint of Concentration Reasonable
Concern (mg/kg/day) Concern (ug/L) Wor8t Case Reasonable
(mg/kg/day) Wor8t Case
jMethylene chloride 6 )( 10-1 Liver S3 1. 2S )( 10-1 2.1 x 10-1
I Tetrachloroethene 1 x 10-:1 Liver S 1.18 x 10-' 1.2 X 10-1
1~2-Dlchloroethen. 1 )( 10-2 (ch) Blood 4 9.4 )( 10-10 9.4 x 10-1
(2 X 10-:1 (trans)) (4.7 x 10-1)
Acetone 1 x 10-1 Liver, kidney 140 3.3 x 10-1 3.3 . 10-1
Total (Hazard Index). 1.5 x 10-1 (1)
SUMMARY 0.. NONCAACINOCENIC RISKS POS8D BY THE CUARKNT POTENTIAL DBRMAL CONTACT
WITH ORGANIC CHEMICALS IN S8DIKilNTS 0.. T08 LOWER JOHNSON CREEK WATEASBP.D
GROVBLAND WaLLS SITE
SUPPLEMENTAL MOM RI/PS
GROV8LAND. MASSACBUSBTTS
(1)
Hazard Index based on cls-l,2-d1chloroethene.
-------
Q
t>
E.po8ure Oo.e eencer AI8k
Carcln09Bnlc eanc.r Cane.. Slop.. Ma. Illu. BloconcBnlr.tlon R.aaon.bl.
eonlalllinanla of ....19hl of reclo. Conc-.nl,etlon raclor Woral C...I R...on.bl.
Concern Evldpnce IIIQ/k~/d8Y)-1 IUQ/L) I L/k9) Avpre9. C.a. Mo,.l e.ael
Cm9/k9/iJay) Av.re9. Ca..
Helhylene chloride HZ 7.5 . 10-1 "0.6 ~ ..2-. 10-11 ].1 . 10 II
J.. . 10-' Z.6 . 10.9
Trlchloroethene B2 1.1 10-1 5./..6 17 1.7 . 10-'/ 1.9 . 10"1
. 1.~ . 10-1 -1.6 . 10-1
" 2.. . 10' J 0..10.' U 2.7 . 10-'1 ,.. . 10.9/
ean..". 2-) . 10" ... . 10..
Totel eencer AI.k, Z.] . 10.'1
:Z.5 . 10.1
Tahll' let
5UMMAJ1Y or IICUS LI'P.TIMK CANeD .15K ~ID 8Y TIll CU1UIDIT PO'I'F.trI'IAL
CONSmtPTION 0' '158 TIUIEII PROM SUR'ACE MATDS IN THK LOWER JOHNSON CRP-HI! NATERSHED
CROVBI.AHD NBLL5 SITB
SUPPLP.MBNT~ MOM III/rs
CROVBUUfD M88AC1f1J&E1TS
I.poeur. He.erd
NoncerclnOCJenlc ....Iau. 810conc.ntr.tlon Do.. Quotient
eont..ln.nt. of A.f.renc. Do.. Endpoint of Conc.nl ,et Ion '.ctor
Concern l1119/k9/4a,,) Conc.,n CU9!LI CL/k9) 1I..aonebl. ...e.on.bl.
Norat C...
189/k9/d.yl Nor.t C...
Methyl.ne chloride 6 . 10-2 Liver .. 5 ..U. 10" 7.7. 10..
I.Z-Dlch10roethen. 1 . 10-2 Ich) 81004 96 :z:z ... . 10-. - ... . 10.1
I Z . 10-2 Itren.I' 12.2 . 10-2'
1.1.1- 9 . 10-2 Liver 1 5.6 1.1 . 10-1 1. 2 . 10-1
Trlchloroeth.ne
ToUI IBalard Inde.). ..5 . 10-2 lat
Llh II' :! I
SOMARY or MONCAACIIIOCDUC RI81l8 P088D BY ftI8 CURRDIT POTIDI'I'I~
CONSUMPTION 0' PIS8 TIUIIPI PROM Sua'AC8 NaTIDS III TB. LOMID JOBNSOIt CRlnl. "AT_8BBD
C~ WIII.LS 81T.
SUPPLBM8NrAL MOM 111/'8
GROVIrLAIIO M8SAC110611rM'&
10
-------
"
Table 22
SuRFACE
WATER METALS RANGES AND STANDARDS
GROVELAND WELLS SITE
SUPPLEMENTAL MOM RI/FS
GROVELAND, MASSACHUSETTS
AWQC(2) NO. OF
PARAMETER BACKGROUND RANGE(l) FRESH-WATER POSITIVE
ug/L ug/L CHRONIC DETECTIONS/NO.
ug/L 'OF SAMPLES
Aluminum ND 183.0-332 150 3/15
. 48(4)
Arsenic ND 2.2-20 2/15
Barium 6.8 5.5-17.4 NA 14/15
Calcium 7,770-10,400 6,890-20,500 NA 15/15
Chromium ND 9.2 11 1/15
Iron 130-160 130-6,690 1,000 15/15
Lead 1.3 1.0-6.2 3.2 12/15
Magnesium 1,130-2,420 1,050-4,640 NA 15/15
Manganese 20.4-53.8 16.4-1,200 NA 15/15
Hickel ND 6.2-14.9 160 4/15
Potassium 384-1,800 384-3,970 NA 15/15
Selenium HD ND 5 ND
Silver 6.7-30.8 6.7-67.1 0.12(3) 8/15
Sodium 5,910-9,390 5,910-26,900 NA 15/15
Vanadium ND 2.1-2.7 NA 2/15
0)
(2 )
First-round data presented.
AWQC f~r several metals are dependent on the oxidation state of the me~al and
hardness level of the surface water body of concern.
AWQC 10west-observed-effect level (LOEL). An actual criterion has not been
established for this compound.
-------
C1
\::
,
1 able 24
ONSITE
ACTION-SPECIFIC ARARs AND TBCs FOR ALTERNATIVE
METALS REMOVAL, UV/OXIDATION AND DISCHARGE TO
SUPPLEMENTAL MOM FS
GROVELAND WELLS SITE
GROVELAND, MASSACHUSETTS
6 - EXTRACTION WELLS,
JOHNSON CREEK
Requirement
Actions Taken to Heet Requirements
FEDERAL
CWA Section 402 (Applicable) Substantive requirements are applicable to the treatment
-
system discharge. The treatment system will be designed
and operated to achieve Clean Water Act requirements.
Substantive requirements wi 11 be relevant and appropriate
CAA - National Ai r Quality Standards during the construction activities. Dust suppressants
(40 CFR Part 50) (Relevant and Appropriate) wi 11 be used as requir-ed during construction to minimize
fugitive dust emissions.
Sllb~tantive requirements wi 11 be met during the
General Industry Standards construction activities. Construction workers and
OSHA - wi 11 be trained, and appropriate health and
operators
(29 CFR Part 1910) (Not ARAR) safety practices will be employed as required for each
spec if ic task. Note this requirement is not an ARAR, but
must be' campI ied with.
OSHA - Safety and health standards for Federal Substantive requirements will be applicable during the
service contracts (29 CFR Part 1926) (Not construction activities. Note this requirement is not an
ARAR) ARAR, but must be complied with
OSHA - Record keeping, reporting, and related Substantive requirements wi 11 be applicable during the
regulations (Not ARAR) construction activities. Note this requirement is not an
-------
labtp. 2/,
ONSITE ACTION-SPECIFIC ARARs
METAI~S REMOVAL, UV/OXIDATION
SUPPl~EMENTAL MOM FS
GROVELAND WELLS SITE
GROVELAND, MASSACHUSETTS
PAGE TWO
AND TBCs FOR ALTERNATIVE 6 - EXTRACTION WELLS,
AND DISCHARGE TO JOHNSON CREEK
Requi rement
Actions Taken to Meet Requirements
COMMONWEALTH OF MASSACHUSETTS
Ambient Ai r Quality Standards (310 CMR 6.00) Suhstantive requirements will be relevant and appropriate
(Relevant and Appropriate) during the construction activities. Dust suppressants
wi 11 be used as required during construction to minimize
fugitive dust emissions.
Air Pollution Control (JIO CHR 1.00) Substantive requiremen~s wi 11 be applicable air
(Applicable) to the
discharge [rom the treatment system.
Surface Water Discharge Permit 'Program Substantive requirements are applicable to the treatment
(314 CMR 3.00) (Applicable) system discharge. The treatment system wi 11 be designed
and operated to meet these dischage requirements.
Operation and Maintenance and Pretreatment Substantive requirements related to pretreatment of the
Standards for Wastewater, Treatment Works and sludge will be me t .
I nd i r ec t Di scha'rge (31 4 CMR 12.00)
Substantive requirements will be applicable to the
Surface Water Ouality Standards treatment system discharge. Treatment system will be
( 31 0 CMR 4.00) (Appl icable) constructed to 'ensure that water quality standards are
met.
Requirements These r'egulat ions apply to wastewater treatment fad 1 i ties
Supplemental for Hazardous Waste exempted from M.G.L. c.21C, which treat, store, dispose
or
Management Facilities (314 CMR 8.00) of hazardous ",astes. The treatment plant will meet the
(Applicable) substantive ~equirements of 314 CMR B. OS .
-------
T"bl~
24
ONSITE ACTION-SPECIFIC ARARs
METALS REMOVAL, UV/OXIDATION
SUPPI,EMENTAL MOM FS
GROVELAND WELLS SITE
GROVEl,AND, MASSACHUSETTS
PAGE THREE
AND TBCs FOR AI,TERNATIVE 6 - EXTRACTION WELLS,
AND D1SCHARGE TO JOHNSON CREEK
Requirement
Actions Taken to Meet Requirements
COMMONWEALTH OF MASSACHUSETTS (CONTINUED)
These regulations wi 11 be looked to to determine the
appropr iate disposal method for the sludge. Sludge wi 11
be evaluated as to whether it is a listed (characteristic)
Hazardous Waste Regulations (310 CMR 30.00) waste to determi ne appropriate disposal methods. If
(Applicable) hazardous, it wi 11 be stored in accordance with these
.reguli\lt ions. If DNAPL were discovered and determined to
be hazardous. it wi 11 be stored in accordance with these
regulat ions.
Monitoring wi 11 be conducted to ensure that standards are
Ambient Ai r Levels (To Be Considered) not exceeded at the wplls and the treatment plant. If
standards are exceeded, action will be taken to ensure
that the standards wi 11 be met.
c
-------
T,1bl (> ".!./~
I,OCATION-SPECIFIC MARs AND TBCs FOR ALTERNATIVE 6 - EXTRACTION WELLS,
METALS REMOVAL, UV/OXIDATION AND DISCHARGE TO JOHNSON CREEK
SUPPI,F.MENTAL MOM FS
GROVF.LAND WELLS SITE
GROVF.I.I\ND, MASSACHUSF.TTS
. I
Requ 1 reme." t
Actions Taken to Heet Requirements
FEDERAL
Potentially applicable to cons t r uc ti on of discharge piping
Section 404 (Appl icable) and outfall near the creek. The routi ng of the treatment
CWA -
system effluent piping to the creek wi 11 avoid wetlands if
possible. If passage through a wetland is necessary,the
I equ i rement in H CFR HO.5(a)(12) and HO.6 shall be met.
fedelal agencies ale rpquiled to minimize destruction,
loss or degradation of wetlands and preserve and enhance
Wetlands executive order (EO 11990) natural and beneficial value of wetlands. Ac t i v i tie s
40 CfR, Part 6, Appendix A (Applicable) impacting wet lands are prohibited unless there is no
practical alternative. The discharge pipe wi 11 not be
located In wet lands if a practical alternative exists.
Impacts wi 11 be minimized.
Federal agencies are required to reduce risk of flood
loss, to minimize impact of floods and to restore and
Floodplains executive order (EO 11988) preserve the natural and beneficial value of floodplains.
40 CFR, Part 6, Appendix A (Appl icable) No practical alternative exists for placement of wells and
discharge outfall in floodplain. Impacts will be
minimized. Wi 11 have minimal displacement and wi 11 be
built to withstand 100 year flood event.
COMMONWEALTH OF MASSACHUSETTS
Wetlands Protection (310 CMR 10.00)
(Applicable)
Any regulated area disturbed by the remedial action will
be restored to original conditions. All practical means
-------
c.
I.-
TiJI.Jlp 24
LOCATION-SPECIFIC ARARs AND TBCs
METALS REMOVAL, UV/OXIDATION AND
SUPPLEMENTAL MOM FS
GROVEI.AND WELLS SITE
GROVELAND, MASSACHUSETTS
PAGE TWO
FOR ALTERNATIVE 6 - EXTRACTION WELLS,
DISCHARGE TO JOHNSON CREEK
Requirement.
Actions Taken to Meet. Requirements
LOCAL
Town of Groveland, Wetlands By-laws (Section
8 -19» (To Be Cons idered)
Applicable to constru~tion of discharge piping near the
creek. The routing of the treatment system effluent to
the creek will avoid potential wetlands if possible. If.
passage through a wetlands is necessary, appropriate
-------
Tabl~ 2/.
CHEMICAL-SPECIFIC REQUIREMENTS FOR AI.TERNATIVE 6 - EXTRACTION WELLS,
METALS REMOVAl.., UV/OXIDATION AND DISCHARGE TO JOHNSON CREEK
. SUPPLF.MENTAL MOM FS
GROVF.LAND WELLS SITE
GROVF.LAND, MASSACHUSETTS
Requirement
Actions Taken to Meet Requirements
FEDERAL
SDWA - Maximum Contaminant Levels (MCLs) and
non-zero maximum contaminant level goals These requirements wi 11 be attained by the selected
( MC LG s) 40 CFR 141.11 - 141.16 and 141,':>0 - alternative in the groundwater beneath the Sit e.
141.':>2. (Relevant and appropr iate)
EPA Risk Reference Doses (RfDs) (To Be EPA RfDs were used to characterize risks due to exposure
Considered) to contaminants in groundwater, as well other media.
EPA Carcinogen Assessment Group Potency These factors were used to assess health risks from
Factors (To Be Considered) carcinogens present at the Site.
EPA Health Advisories and Acceptable Intake To be used, if adequate data exist, in assessing health
Health Assessment Documents (To Be Considered) ri sks from ingesting groundwater at the Site.
EPA Groundwater Protection Strategy (To Be This strategy is considered in conjunction with the
Considered) Federal SDWA and Massachusetts Water Ouality Standards.
COMMONWEALTH OF MASSACHUSETTS
Groundwater quali ty standards exist for a number of
Oual ity Standards 314 CMR 6.00 contaminants in the groundwater. When state levels are
Groundwater stringent than the federal levels, the state levels
(Applicable) more
wi 11 be used. This remedial act ion wi 11 meet these
standards in the groundwater beneath the Site.
Drinking Water Maximum These state drinking water standards wi 11 be compared to
Massachusetts the federal standards. If stringent, the state
more
Contaminant Levels - 310 CMR 22.00 (Relevant standards wi 11 be used. This remedial action will
meet
-------
<0
APPENDIX B
DECLARATION OF CONCURRENCE
COMMONWEALTH OF MASSACHUSETTS
-------
Commonwealth of Massachusetts
Executive Office of Environmental Affairs
Department 0'
Environmental Protection
-
"'=""
D E P
Deniel S. Gr_nbaum
CommiSSioner
September 27, 1991
Ms. Julie Belaga
Regional Administrator
u.S. EPA Region I
JFK Federal Building
Boston, MA 02103
RE:
Groveland Wells Federal
Superfund Site - OU2
Management of Migration
ROD Concurrence
Dear Ms. Belaga:
The" Department of Environmental Protection (the Department)
has reviewed the preferred remedial action alternative"
recommended by EPA for the Management of Migration, Operable Unit
2, at the Groveland Wells Federal Superfund site. The Department
concurs with EPA's selected alternative.
The Department has evaluated EPA's preferred alternative for
consistency with M.G.L Chapter 21E and the Massachusetts
contingency Plan 310 CMR 40.00 (MCP) and has determined that the
alternative of UV/Oxidation with metals removal is consistent
with the overall permanency requirements of the MCP. However, a
permanent solution determination cannot be made until it has been
demonstrated that the remedial measure or combination of measures
will meet the Total site Risk Limits as defined in 310 CMR 40.00
for the entire site.
The Department encourages EPA to use alternative treatment
technologies that eliminate media transfer of contaminants as a
remedy, and supports EPA's decision to conduct treatability
studies for UV/oxidation as an alternative groundwater treatment
technology to air stripping at this site. .
The Department generally identifies the MCP as an applicable
requirement for sites in Massachusetts while reserving the right
to argue that Chapter 21E constitutes an independent enforcement
authority that is not subject to the waiver provisions of CERCLA
section 121 (d) (4). The Department identifies the MCP and
Chapter 21E as applicable requirements, within the meaning of
CERCLA, for operable unit 2, of the Groveland Wells Nos. 1 and 2,
One Winter Street ".
Boston, Massachusetts 02108
.
FAX(617)5~1049
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;}
\)
Groveland ROD
Belaga
September 27,
Page -2-
Concurrence.
1991
Superfund site.
The Proposed Remedy appears to meet all Massachusetts state
ARARs. This will continue to be evaluated as remedial design
progresses and during implementation and operation.
The Department looks forward to working with you in
implementing the preferred alternative. If you have any questions
or require additional information, please contact Charles Tuttle
at 292-5903.
~rY truly yours
---- . .' /' .,,/ . .
Da l~. reenbaum, Comm~ss~oner
Massach setts Department. of
Environmental Protection
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RESPONSIVENESS SUHKARY
MANAGEMENT OF MIGRATION OPERABLE UNIT
GROVELAND WELLS NOS. 1 AND 2 SUPERFUND SITE
GROVELAND, MASSACHUSETTS
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,;
"
SECTION
TABLE OF CONTENTS
RESPONSIVENESS SUMMARY
GROVELAND WELLS NOS 1 AND 2 SUPERFUND SITE
PAGE
. . . . .
. . . e. . . . .
. . . . .
1
1.
PREFACE. . . . . . .
2
A.
OVERVIEW
REMEDIAL ALTERNATIVES
2
B.
. . . .
. . . .
.......
. . . . . .
. . . .
. . . . .
General Reaction to the Preferred Alternative
4
BACXGROUND ON COMMUNITY INVOLVEMENT AND CONCERNS
. . . .
4
II.
III. COMMENTS RECEIVED DURING THE PUBLIC COMMENT
PERIOD AND EPA RESPONSES . . . . . . . . . .
A.
B.
IV.
5
Inorganics (metals)
6
. . . . .
........
Extent and Sour~es of contamination
........
8
c.
Mill Pond Extraction/Treatment system
. . 15
. . . . .
D.
Groundwater Modeling/Pump Test
. . 20
. . . . . .
Eo
A.W. Chesterton
. . 30
. . . . .
........
F.
Selected Remedy
. . . 32
.......
. . . . .
G.
Analysis of Alternatives.
. . 35
. . . .
.......
H.
Institutional Controls
. . . 38
. . . .
........
1.
Risk Assessment
. . 39
. . . . .
........
J.
Miscellaneous
. . . . 42
. . . . . .
REMAINING CONCERNS - COMMENTS RAISED OUTSIDE THE
61-DAY PUBLIC COMMENT PERIOD. . . . . . . . . . .
. . . 42
A.
Status of Cleanup at Other contamination Sources. . 42
B.
Concerns About the Preferred Alternative.
. . 43
C.
Drinking Water Supply - The Public Supply
. . 44
D.
Drinking Water Supply - Private Wells
. . . 45
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.H.
"r.
TABLE OF CONTENTS
RESPONSIVENESS SUMMARY
GROVELAND WELLS NOS 1 AND 2 SUPERFUND SITE
E.
Long-term Public Health Impacts
. . . . . .
F.
Surface Water Contamination
. . . .
. . . .
G.
Liabilj.ty
. . . .
. . . . .
. . . .
.......
Timing of the Cleanup
The Plume
.......
. . . .
. . .
. . . .
. . . . . .
. . . .
ATTACHMENTS
A
COMMUNITY RELATIONS ACTIVITIES CONDUCTED AT THE
GROVELAND WELLS NOS~ 1 AND 2 SUPERFUND SITE IN
GROVELAND, MASSACHUSETTS
B
TRANSCRIPT OF THE JULY 31, 1991 INFORMAL PUBLIC
HEARING
45
45
46
46
47
A-1
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()
PREFACE
The u. S. Environmental Protection Agency ("EPA") held a 61-day
public comment period, from July 10, 1991 to September 9, 1991, to
provide an opportunity for interested parties to comment on the
Supplemental Management of Migration Feasibility Study
("Supplemental MOM FS") and the Proposed Plan prepared for the
Groveland Wells Nos. 1 and 2 Superfund Site in Groveland,
Massachusetts (the "Groveland site" or the "Site"). The
Supplemental MOM FS examined and evaluated various options, called
remedial alternatives, for addressing groundwater contamination.
EPA identified its preliminary recommendc;t.tion of a preferred
alternative for the site cleanup in the Proposed Plan, issued in
early July 1991, and then requested comments during a public
comment period. On July 31, 1991, EPA held an informal public
hearing at which two commenters spoke. A total of eight commenters
responded during the public comment period, one of which responded
both in writing and through testimony at the public hearing.
The purpose of this Responsiveness Summary is to document EPA
responses to the comments and questions raised during the public
co~ment period. EPA has considered all of the comments summarized
in this document before selecting a final remedial alternative for
the groundwater contamination at the Groveland Site.
The Responsiveness Summary is divided into the following sections:
Section I. overview. This section discusses the Site history,
outlines the objectives of the Supplemental Management of Migration
Remedial Investigation and Feasibility Study ("Supplement 'MOM
RIfFS"), identifies the remedial alternatives evaluated in the
supplemental MOM FS, and identifies and summarizes general reaction
to EPA's Preferred Alternative.
Section II. Backaround on Community Involvement and Concerns.
This section contains a summary of the history of community
interest and concerns regarding the Groveland Site.
section III. ,Summary of Maier Comments Received Durinq the Pubic
Comment Period and EPA's Response to those Comments. Written and
oral comments from the public, interested parties and potentially
responsible parties ("PRPs") on the extent of contamination, ,the
supplemental MOM FS, and Proposed Plan, along with EPA's responses,
are presented according to topic.
Section IV. Comments Received Prior to the Comment Period. This
section presents community concerns raised prior to the public
comment period and EPA responses to those expressed concerns.
ATTACHMENT A - This attachment provides a list of the community
relations activities that EPA has conducted for the Groveland Site.
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ATTACHMENT B - This attachment is the transcript of the July 31,
1991, . informal public hearing held in Groveland, Massachusetts.
I.
OVERVIEW
The Groveland Site is a nearly 850 acre parcel, located mostly in
southwestern Groveland, Massachusetts, that contains two municipal.
water supply wells, Station Nos. 1 and 2. In 1979, these wells were
closed when high levels of trichloroethene ("TCE"), a volatile
organic compound ("VOC"), were discovered. The Town of Groveland
established a new supply well, station No.3, outside the site
aquifer, and reopened Station No.1 in 1987 after a granular
activated carbon treatment system was installed. Station No.2
remains closed. The site was placed on the National Priorities
List ("NPL") in 1982, making it eligible for federal action under
Superfund.
EPA's supplemental Management of Migration Remedial Investigation
("supplemental MOM RI"), a study that investigates the nature and
extent of Site contamination, determined that a large, elongated
contaminant plume extends from the Valley Manufactured Products
Company ("Valley") property to just south of the Merrimack River.
This finding, together with the Risk Assessment, which assesses
potential risks to human health and the environment associated with
site contamination, resulted in the development of remedial
objectives. for the Site cleanup approach. These objectives,
generally stated, are to prevent people from drinking groundwater
in the contaminated plume area until carcinogenic and
noncarcinogenic contaminant levels meet Federal and State drinking
water standards, as well as other applicable or relevant and
appropriate requirements ("ARARs") and cleanup levels, and to
restore the groundwater quality to meet Federal and State drinking
water standards or goals, as well as other ARARs and cleanup
levels.
..
From these
alternatives
alternatives
contamination
alternatives.
objectives, EPA developed and evaluated cleanup
in the Supplemental MOM FS. This report describes the
considered for addressing the groundwater
and the criteria EPA used to identify six. remedial
These alternatives are described briefly below.
A.
Remedial Alternatives
Alternative 1:
No Action
This alternative was evaluated to serve as a baseline for
comparison with the other remedial alternatives under
consideration. The only cost is the provision for monitoring every
5 years.
Alternative 2:
Institutional Controls
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u
'0
This alternative involves the use of institutional controls, such
as deed restrictions prohibiting installation of private wells in
the plume. The cost includes quarterly sampling of moni to~ing
wells.
Alternative 3: Extraction Wells, Partial Inorganics Removal, and
Discharge to the Haverhill Sewage Treatment System
This alternative includes the components of Alternative 2
(institutional controls), and also includes: the construction of a
network of approximately six groundwater extraction wells to
intercept the entire width and depth of the plume; a treatment
system composed of equalization/aeration, sedimentation, and sludge
dewatering and disposal for removing inorganics from the extracted
grotmdwater; and discharge of the treated groundwater to the
Haverhill publicly owned sewage treatment system. During remedial
design, the existing Mill Pond extraction system would be
considered for use to supplement or replace one of the six new
extraction wells proposed for this area. An additional component
o,f this alternative is semi-annual surface water and sediment
sampling of Johnson Creek and other nearby streams.
Alternative 4:
Extraction Wells, Inorganics Removal, Air
Stripping, and Discharge to Johnson Creek
..
This alternative includes the components of Alternative 2 plus
portions of Alternative 3 (installation of a groundwater extraction
network and equalization/aeration and sedimentation to remove
inorganics) . A new component of the metal removal scheme is
filtration, which provides additional removal of suspended solids,
which would be necessary to achieve the metals discharge standards
and to allow for the efficient operation of the treatment
equipment. TCE and other volatile organics would then be removed
from the filtered groundwater by a 25 foot air stripping tower.
Emissions from the tower would be captured by a granular activated
carbon unit. Spent carbon would be transported off-site for
regeneration' and destruction of the organics. The treated
groundwater would finally be discharged into Johnson Creek near
station No.2. This al ternati ve also includes the semi-annua 1
surface water and sediment sampling.
Alternative 5:
Extraction Wells, Inorganics Removal, Carbon
Adsorption, and Discharge to Johnson Creek
This alternative includes the components of Alternative 2 plus
portions of Alternative 4 (installation of a groundwater extraction
network and equalization/aeration, sedimentation and filtration to
remove inorganics). The filtered groundwater would then be
transferred to granular carbon adsorption units to remove TCE and
other organic volatiles. Spent carbon would be transported off-
site for regeneration and destruction of the organics. The treated
9roundwater would be discharged to Johnson Creek. Thi,s alternative
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also includes the semi-annual surface water and sediment sampling.
Extraction Wells, Metals Removal, UV/Oxidation and
Discharge to Johnson Creek
This alternative includes the components of Alternative 2
(institutional controls). A groundwater extraction network of
approximately six wells, located throughout the plume, would be
cited to intercept contaminated groundwater along its entire width
and depth, including contamination in the shallow bedrock. The
total estimated flow rate needed to intercept the plume is about
400 gallons per minute ("gpm"). The contaminated groundwater would
be subject to an inorganics treatment process involving
equ~lization/aeration, sedimentation and filtration.. The resulting
sludge would be disposed of off-site. The filtered water would
then be subjected to a process involving ultraviolet ("UV") light
and oxidation to destroy TCE and other volatile organics. The
treated groundwater would be discharged to Johnson Creek near
Station No.2. The estimated discharge flow rate of about 400 gpm
is within the normal flow rate that the existing stream channel can
accommodate. The discharge structure would include measures to
minimize potential erosion of the river bed and be designed to
ensure that it will not cause physical disruption of wetlands (if
any) near the discharge point. This alternative includes the semi-
annual surface water and sediment sampling.
Alternative 6:
During remedial design, the existing Mill Pond extraction system
would be considered for use to supplement or replace one of the six
new extraction wells proposed for this area.
The July 1991 Proposed Plan presented EPA's preferred alternative,
Alternative 6, discussed above.
B.
General Reaction to the Preferred Alternative
There was a mixed reaction to the Preferred Al ternati ve. Two
commenters (Carlson and Goodwin) specifically supported
Alternative 6. Of those commenters that offered an opinion on the
Preferred Alternative, however, most suggested (including Carlson)
that a more sensible and cost-effective solution would scale back
the scop~ to focus on locating extraction wells only in the most
contaminated portion of the plume. The Groveland Well Pollution
Commi ttee contends that an air stripping technology should be
selected while citizen Argyros and Valley Manufactured Products
Company contend that institutional controls alone should be
applied.
II.
BAC~GROUND ON COMMUNITY INVOLVEMENT AND CONC&RNS
Community interest in the Groveland Wells Nos. 1 and 2 Superfund
Site arose as soon as TCE was discovered in 1979. The loss of
these sources of potable water resulted in ~he imposition by the
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.~
Q
Town of Grove~and of an area-wide water ban until Station No.1 was
restored in 1987. Throughout this period, interest by local
officials and Groveland residents in efforts to remediate the site
has been high. It has continued to be high during the subsequent
Remedial Investigation, Feasibility Study and the development of
the remedial alternatives. .
During September, 1983, EPA released a community relations plan
that outlined a program to address community concerns and keep
citizens informed about, and involved in, response activities.
This original plan has been updated as necessary. On July.24,
1989, EPA held an informational meeting in the Town of Groveland to
describe the plans for the Remedial Investigation and Feasibility
Study. On April 3, 1991, EPA held an informational meeting in the
Town of Groveland to discuss the results of the Supplemental MOM
RI. .
On July 10, 1991, EPA made the administrative record available for
public review at EPA's offices in Boston and the Langley-Adams
Library in Groveland, Massachusetts. EPA published a notice and
brief analysis of the Proposed Plan in the Haverhill Gazette on
July I, 1991 and made the plan available to the public at the
Langley-Adams Library.
On July 9, 1991, EPA held an informational meeting to discuss the
results of the Supplemental MOM Remedial Investigation and clean-up
alternatives 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 July 10 to August 8,
1991, the Agency held a 3D-day public comment period to accept
public comments on the alternatives presented in the Supplemental
MOM FS, the Proposed Plan, and on any other documents previously
released to the public. During the comment period, EPA received
two requests to extend the public comment period an additional 30
days. EPA extended the public comment period to S~ptember 9, 1991.
On July 31, 1991, the Agency held a public hearing to accept any
oral comments on the Proposed Plan. A transcript of this meeting
and the comments and the Agency's response to comments are included
in this responsiveness summary.
III.
COMMENTS RECEIVED DURING THE PUBLIC COMMENT PERIOD AND
EPA RESPONSES
Comments raised during the Groveland Wells Nos. 1 and 2 Superfund
site public comment period (from July 10 through September 9, 1991)
are summarized and addressed below. Section III identifies and
responds to comments offered either in writing during the public
comment period or orally at the public hearing on July 31, 1991.
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"
A.
Inorqanics (metals)
COMMENT: One commenter stated that there is no engineering basis
to believe that the Preferred Alternative or any other treatment
scheme will reduce inorganic contamination in the aquifer to
drinking water standards.
EPA RESPONSE: During the design stage of the remedy, a
comprehensive background groundwater sampling program will be
conducted. If study results indicate that certain Site inorganic
chemicals are present at background concentrations, then those
inorganics will no longer be identified as Site-related
contaminants and standards for those inorganics would not need to
be met. If study results indicate that certain inorganic
concentrations are not representati ve of background, then the
remedy will be designed to attain inorganic interim cleanup levels
for those chemicals.
COMMENT: One commenter questions the need for metals treatment and
the costs associated with this treatment. The commenter also
identifies the potential requirements for treatment of sludge.
EPA RESPONSE: The treatment for metals may be requireq for the
groundwater prior to discharge, at least initially. It is
possible, after a period of time, that the metals concentration
will decrease to below potential Clean Water Act requirements. The
estimated quantities of sludge generated are expected to be
approximate maximum quantities rather than "no less than"
quantities, because they are, in part, based on current turbidity
in monitoring wells. Also, if remediation is completed much sooner
than estimated in the Supplemental MOM FS as indicated by some
commenters, this quantity would be significantly reduced.
The sludge will be evaluated during RD/RD to determine whether it
is a hazardous waste. If it is determined to be hazardous, it will
be disposed of in accordance with applicable requirements
COMMENT: Several commenters believe that "arsenic is naturally
associated with the Site at background levels" and that the
presence of arsenic. in the .groundwater "should not drive the
remedy." Adequate sedimentation and filtration, together with the
addition of a sulfide mixture. greater than that discussed in
Appendix E to precipitate the arsenic, will achieve the FS-
identified arsenic tolerance level of 50 ug/l.
EPA RESPONSE: EPA partially agrees with this comment. Some level
of arsenic and other metals appear to be natural for the area.
However, background levels for those contaminants need to be
determined. This determination can proceed concurrent with the
design of the selected alternative, so as to not delay the
remediation any longer. This is discussed in more detail in a
previous comment.
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.J
"t>
The system proposed by the commenter mirrors that proposed by the
Supplemental MOM FS. During the design, the suggestions provided
by the commenter will certainly be considered. Exact requirements
for sulfide (if any, because of co-precipitation) will be
determined during a treatability study. .
COMMENT: Several commenters suggest that a method of inorganics
reduction not studied in the Supplemental MOM FS could result in
considerable cost savings which could then be applied to supporting
the purchase of a technology like thermal oxidation. This method
of constructing the extraction well reduces the suspended solids in
the groundwater thereby allowing iron and manganese to oxidize in
the air stripper column. Such an approach could eliminate the need
for. a precipitation and sedimentation treatment phase.
EPA RESPONSE: The design of extraction wells would consider
techniques to minimize the production of suspended solids.
Inorganics of concern are those that migrate through the aquifer in
a soluble or colloidal form.
COMMENT: One commenter conducted an economic analysis of the
feasibility of removing inorganics in the groundwater to the level
specified in the Supplemental MOM FS. It concluded that treating
the naturally occurring inorganic contaminants of concern in this
Class III area is not economically feasible.
EPA RESPONSE: The treatment for metals, whether natural or man-
made, is economically feasible. Also, it is likely that the costs
associated with treatment of metals will decrease significantly in
a period of six months to two years. This is based on the
consideration that much of the metal contaminants identified during
the Supplemental MOM RI are likely to be insoluble. The metals in
the extraction wells would rapidly washout, whereas those
inorganics away from the extraction wells would remain in place.
It should be noted that this is not a Class III aquifer. area.
COMMENT: One commenter states that EPA guidelines for groundwater
characterization classify this area as Class III, unfit for
drinking water use, unless the.inorganics can be reasonably removed
by public water supply systems (reasonable treatment). The
comrnenter's position is that the inorganics cannot be removed by
reasonable treatment. .
EPA RESPONSE: The statement that EPA's classification for the
aquifer should be Class III at the Site is incorrect. EPA believes
that in the absence of manmade contamination, the groundwater could
be used. as a drinking water source, without treatment. Even if
treatment were necessary, the types of contaminants in the aquifer
are types that could be reasonably treated.
COMMENT: One comrnenter contends that there is no basis to conclude
that the secondary maximum contamination levels identified in the
-------
FS for manganese and zinc constitute "relevant and appropriate"
cleanup standards for the situation.
EPA RESPONSE: EPA has determined that the use of secondary maximum
contamination limits ("SMCLs") is unnecessary to remediate
contamination at the site to health based levels. No reference is
made in this Management of Migration ROD to SMCLs as a basis for
setting cleanup levels, and manganese and zinc, to which cleanup
levels based upon SMCLs were assigned in the FS, are no longer
identified as contaminants of concern.
COMMENT: One commenter states that the objective of cleaning up
the contaminated groundwater (aquifer restoration) e~tending from
the Valley property is. beyond EPA'S authority, probably is
impossible because the inorganic contamination detected is
naturally occurring and its sources are unknown, and is too costly.
EPA RESPONSE: EPA has not determined whether unacceptably high
concentrations of inorganics detected in some monitoring wells are
naturally occurring. During the design stage of the remedy, a
comprehensive background groundwater sampling program will be
conducted. If study results indicate that certain site inorganic
chemicals are present at background concentrations, then those
inorganics will no longer. be identified as site-related
contaminants and standards for those inorganics would not need to
be met. If study results indicate that certain inorganic
concentrations are not representative of bi;lckground, then the
remedy will be designed to attain inorganic interim cleanup levels
for those chemicals.
If remediation of inorganics is necessary, the cost associated with
operating the inorganic treatment system will be dependent on the
severity of inorganic contamination encountered. If minimal
inorganic contamination is encountered, or the contaminant
concentration decreases significantly during operation, then the
costs would decrease correspondingly.
The aquifer has been and continues to be used as a major source of
municipal water by the Town of Groveland and should be viewed as a
valuable resource. This aquifer is classified as Class II (a
potential source of drinking water) by EPA and a Class I aquife'r
(potable water source) by the Commonwealth of Massachusetts.
Restoration of this aquifer is consistent with these
classifications. See 55 Fed. Rea. 8732. Remediating site-related
inorganic contamination falls squarely within EPA'S statutory
authority under the Comprehensive Environmental Response,
compensation and Liability Act of 1980 ("CERCLA").
B.
Extent and sources of contamination
COMMENT: One commenter cites the fact that all previous
investigations that found TCE in surface water samples from Johnson
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~
~
Creek below Mill Pond were taken prior to the installation of the
Mill Pond interceptor discharge. The cornmenter cites this as
evidence that groundwater discharges to Johnson Creek in this area.
EPA RESPONSE: EPA does not dispute the first sentence of the
comment. EPA does not agree that this is "evidence" that "all"
contaminated groundwater discharges to the stream in this area.
Field data indicate the TCE plume is present downstream of this
area and water level data indicate a northerly groundwater flow.
The investigations cited found TCE in surface water from Mill Pond
to the Station No.2 area. Surface water samples collected north
of Lawrence Road in 1982 and in 1983 had levels of TCE as high as
55 micrograms per liter ("ug/L") and levels in samples north of
Mill Pond and south of Lawrence Road as high as 82 ug/L. The first
MOM-RI detected TCE levels as high as 30 ug/L in Johnson Creek
north of Lawrence Road and as high as 48 ug/L south of Lawrence
Road.
Surface water samples collected during the Supplemental MOM RI from
Johnson Creek north of Lawrence Road yield only loW level « 5
ug/L) detection of TCE while samples collected from Johnson Creek
north of Mill Pond were also at low level « 5 ug/L) except for the
sample collected immediately downstream of the Mill Pond
extraction/treatment system discharge. The l~vel of TCE in this
February 8, 1990 sample was 54 ug/L. It is noted that TCE levels
from samples of the Mill Pond system effluent collected for
discharge monitoring purposes were reported at 200 ug/L for January
24, 1990 and 38 ug/L for February 15, 1990.
..
COMMENT: One commenter contends that the contaminated groundwater
will not have a significant impact on Johnson Creek and the
Merrimack River in the future. The commenter further states that
t~e contaminated plume is discharged to Johnson Creek where its
concentration is dissipated by volatilization and other mechanisms.
Also, the commenter assumes the concentrations in the Creek will
decrease with time.
EPA RESPONSE: EPA assumes that "other mechanisms" include
dilution: The Supplemental MOM FS addresses concerns with possible
future contamination of Johnson Creek and the Merrimack River based
on low flow conditions where periodically, not on the average,
higher concentrations of contaminated groundwater may be found in
the streams. Under seasonal low flow conditions and lower ambient
temperatures, the benefits from dilution and volatilization would
be significantly reduced.
COMMENT: One commenter states th~t there has not been sufficient
time for contamination to reach Station No.2 from Station No.1.
EPA RESPONSE: This comment disregards the path of overall
contaminant migration. Data from all investigations performed at
the Site to date show that the main body of the contaminant plume
-------
migrates northward, parallel to Johnson Creek. Pre-1979 pumping of
the Station No.1 well may have redirected an outlying portion of
the plume towards that well, but the main body of the plume likely
continued to migrate towards Station No.2. Pumping of the Station
No.2 well would accelerate the migration of this main portion of
the plume towards this well, thus contaminant travel times from
Station No.1 to Station No.2 are beside the point. The
contamin~tion of Station No.2 likely came from the main body of
the plume and not from the portion that may have been pulled
northeastward by Station No.1.
COMMENT: One commenter states that sediment sampling data for
Station SD-13, showing a detection of methylene chloride ("M/C") of
53 ug/kg, is indicative of possible sources of contamination other
than Valley, Chesterton, or the Haverhill Landfill.
EPA RESPONSE: The emphasis in EPA's studies of the Site was to
identify the nature and extent of contamination the affected
aquifer. EPA believes they have identified all major sources of
contamination to the aquifer within the Site boundaries. EPA does
not believe that the data cited by the commenter demonstrates that
a major source of contamination has been overlooked. Sediment
sample locations downstream of SD-13 (SD-12 on Argilla Brook and
SD-1 on Johnso~ Creek) did not yield any detections of methylene
chloride. The only surface water. sample with a detection of M/C
was collected at SW-6 located at the north (outlet) end of Mill
Pond. It is noted that (M/C) was a contaminant detected in soils
at the Valley property. Sporadic detection of M/C and other
organics at low levels is to be expected in a suburban stream
basin. However, the data do not indicate that a new round of
investigations for new "sources" is warranted.
COMMENT: One comrnenter questions the potential for vinyl chloride
to be present in the groundwater near Station No.1. The commenter
further states that it has never been detected at the Site.
EPA RESPONSE: The Supplemental MOM FS presented the potential
formation of vinyl chloride as a concern because of its highly
toxic nature and the implications to human health if it is present
or does form in the future. Also, it should be noted that the
contract-required detection 'limit for vinyl chloride is 10 ug/l and
the maximum contaminant level (tlMCL") for vinyl chloride is 2 ugjl.
Therefore, vinyl chloride may be present at concentrations above
the MCL and yet not be detected. Also, data obtained during the
first MOM RI (1984) indicate vinyl chloride was detected at the
Site and the concentrations ranged from 4.5 to 5.0 ug/l.
COMMENT: One comrnenter states the Supplemental MOM RI does not
contribute any ,additional information regarding the aquifer
behavior or the source of contamination.
EPA RESPONSE:
Geologic, hydrologic, and water quality data were
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L-
v
needed by EPA to support its Record of Decision and proceed with
groundwater remediation. The pumping test performed during the
Supplemental MOM RI provided a great deal of information regarding
aquifer behavior and its relation to contaminant migration. It
provides an evaluation of the aquifer stresses from pumping station
No.1 and some understanding of the hydrologic impacts of physical
changes that occurred in the study area since the 1980 test. Based
on data gathered during the first MOM RI and the supplemental MOM
RI, EPA maintains its support of the position that the Valley plume
remains the most likely source of contamination of station No.1.
COMMENT: One commenter suggests that contamination of Stations 1
and 2 was the result of a spill from a machine shop located
adj~cent to the Eastern boundary of the site along School Street.
. .
EPA RESPONSE: The machine shop referenced by the commenter was
investigated as a potential source area by EPA, but no evidence of
groundwater contamination was uncovered. That investigation was
not an intensive sampling effort, but initial results showed that
further sampling was not warranted. If elevated levels of TCE had
been detected in the downgradient w~lls at the machine shop, then
EPA would have investigated further. It should also be noted that
the NUS-3/3A well cluster, located between the machine shop and
station No.1, is not and historically has not been contaminated.
COMMENT: One commenter asked if contamination was currently
reaching Station No.1, and, if not, why the granular activated
carbon ("GAC") treatment system still is in operation?
EPA RESPONSE: The Valley plume does not reach Station No.1 at the
present time. contamination is not presently being detected at the
station No.1 pumping well, and groundwater within the immediate
area surrounding and upgradient of that pumping well has non-
detectable to trace concentrations of contamination. continued use
of the granular activated carbon (GAC) system at station No. lis
prudent because it ensures a safe drinking water supply from this
well. .
COMMENT: One commenter stated that the original source of
contamination of Station No.1 has not been found. The commenter
further stated that available evidence gathered to date proves that
it is inconceivable for contamination in the Mill Pond area to have
reached Station No.1, even in a drought period. Finally, the
conunenter stated that the available data strongly suggest that
Argilla Brook is the source of the contamination found at Station
No. 1.
EPA RESPONSE: The emphasis in EPA's studies of the Site were to
identify the nature arid extent of contamination throughout the
affected aquifer. EPA believes it has identified all major sources
of contamination to. the aquifer within the site boundaries. The
contaminant plume that extends from the Valley property
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(hereinafter referred to. as the "Valley plume") does not reach
Station No.1 at the present time. contamination is not presently
being detected at the Station No.1 pumping well, and groundwater
wi thin the immediate area surrounding and upgradient of that
pumping well has non-detectable to trace ~oncentrations of
contamination.
EPA strongly disagrees with the statement that it is inconceivable
for contamination in the Mill Pond area to have reached Station No.
1. EPA believes that it is probable that the daily pumping of
Station No.1 may have resulted in the interception of the Valley
plume in the past. Given the lack of evidence that other areas
within the Site are sources, and the Agency's determination that
the pumping of station No.1 extends a cone of influence toward the
Valley plume and Mill Pond, the Valley plume is the most likely
source of past contamination at Station No.1.
For contaminants to be captured by the Station No.1 well, they do
not have to travel all the way to the well during the drought (low
recharge) period; they only need to migrate to within the well's
normal. capture zone limit. Once within this capture zone,
contaminants will travel to the well within the well's groundwater
migration pattern, even under conditions of .normal precipitation
and groundwater recharge. As a result, movement of the plume some
fraction of the total distance to the pumping well may be all that
is needed for contamination to eventually reach the well. EPA
believes that contaminants from the Valley plume could have
migrated to station No.1 in this manner in the past.
Modeling.of drought conditions (low recharge) was performed as part
of the no action evaluation, to estimate conditions during which
station No.1 well may be impacted. Once established, the limiting
conditiori was evaluated for its potential to occur. This is an
appropriate method of evaluating a no action alternative. . Contrary
to the commenter's assertions, the limiting flow line to station
No.1 in the referenced figures does intersect the Valley plume,
albeit under apparently extreme (and infrequent) conditions, as the
Supplemental MOM FS points out.
EPA does not believe that Argilla Brook is the source of the
contamination found at station No.1. It is highly unlikely that
contaminants would persist at levels exceeding 100 ug/l to the well
intake considering the dilution of surface water recharge to the
pumping well, the volatilization of contaminants within the stream
prior to reaching Argilla Brook, and dilution/dispersion during
subsurface migration from the source area to the stream.
Contaminant levels exceeding 100 ugjl are extremely unlikely in a
swiftly moving stream that flows over a shallow, gravelly stream
bed, unless the contaminant source was in the immediate vicinity of
the sampling point. That is not the case here.
COMMENT:
One commenter states that the Supplemental MOM RI assumes
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,j
"
that the Valley plume extends continuously from the Valley property
to the Merrimack River.
EPA RESPONSE: As discussed in the supplemental MOM RI report,
direct evidence of contaminant migration from the Valley property
to station No.2 and beyond is provided by the comparison of TCE
concentrations in wells downgradient of the Valley property.
However, no assertion is made that the plume extends to the
Merrimack River as there are no wells located close to it. The
closest well to the Merrimack River sampled during the Supplemental
MOM RI was ERT-21. This well is about 800 feet from the River; TCE
levels recorded in the first MOM RI and the supplemental MOM RI
were 10 ug/L and 20 ug/L, respectively.
The furthest extent of the plume can only be assumed to be between
ERT-21 and the River. Regardless of whether the pl~me does, in
fact, currently reach the River, all areas wi thin the site not
meeting ARARs or cleanup levels must be addressed by the remedial
action and additional wells may be required to determine the extent
of the. groundwater that must be extracted.
COMMENT: One commenter contends that if the TCE in station No.2
is from the GZ-5 area, a high ratio of DCE to TCE should also be
found there. It is not. . .
EPA RESPONSE: As discussed above, the differing mobility of DCE
versus TCE could explain the relatively higher. ratio of DCE/TCE in
the GZ-5 area. Also, much of the data at this location is near the
detection limit, significa~tly affecting the reliability of these
ratios.
COMMENT: One commenter states that the fingerprint of the
contamination, as determined by the DCE to TCE ratio at the Valley
property and Station No.2, demonstrates that the contamination at
station No.2 is not derived from the Valley property.
EPA RESPONSE: "Fingerprinting" is often used to identify fuels and
other materials in which the relative ratio of compounds do not
change significantly with time. However, the use of the DCE/TCE
ratio as a "fingerprint" to demonstrate that the plume near Station
No.2 is "different" than that at the Valley property i~
misleading. Various factors can account for. this "difference",
including the use of skewed data and differences in DCE and TCE
mobility.
Review of the data used to compare the DCE/TCE ratio indicate that
some data being used to draw these conclusions may not be
representative of the area referenced. Relatively high
concentrations in well No.4 in the Valley area skew the data.
Other wells in this area, such as NUS-5, have DCE/TCE ratios closer
to 0.1 or less.
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Higher DCE/TCE ratios near the Mill Pond extraction sy.stem may be
explained by differing transport properties. DCE is about twice as
)bile in the environment as TCE, as measured by the Organic Carbon
„artition Coefficient. The higher mobility of DCE indicates that
DCE would move through the aquifer more rapidly than TCE. DCE.
generated in the .upgradient areas wi th much higher TCE
concentrations would be expected to migrate to the extraction wells
faster than would the TCE in this area. This would result in a
higher DCE/TCE ratio at the extraction point.
COMMENT: One commenter states that the contaminant plume extending
from its property is not spreading.
EPA RESPONSE: Contaminants are continuing to migrate (or spread)
with ~he groundwater from the Valley property toward $tation No.2
and the Merrimack River. EPA has not yet determined whether the
leading edge of the plume is currently advancing or stationary.
COMMENT: One commenter states that the source of contamination of
Station No.2 has not been found, that the Valley plume is not
continuous, and that an alternative source of contamination in the
gravel pit area east of the Valley plume is responsible for the
contamination at station No.2. The commenter further state that
the Valley plume discharges totally to. Johnson Creek and Main
Street.
EPA RESPONSE: EPA believes that the Valley plume is the primary
source for the groundwater contamination in the station No.2 area.
The Valley plume is continuous and traceable all the way from the
Valley property to station No.2. In addition, similar contaminant
types are detected throughout the area extending from the Valley
property to station No.2, and overall contaminant concentrations
decrease downgradient of the Valley property as expected.
..
The commenter further contends that the increase in TCE
concentrations at Station No.2 violates the second law of
thermodynamics - the plume cannot become more concentrated. This
would demonstrate that the plume is not continuous.
-
However, minor variations in contaminant concentration trends in
the region between the valley property and the station No.2 area
are not uncommon within contaminant plumes and do not indicate the
existence of a plume in the Station No.2 area that is distinct
from the Valley plume. Such minor variations can be readily
explained through a variety of factors, including: normal sample
analysis variations; heterogeneities in the subsurface that produce
zones of preferential migration of groundwater/contaminants within
the aquifer; induced infiltration of contaminated surface water due
to the pumping of the station No.2 well; and/or separate "pulses"
of contamination released from the source creating two areas of
elevated contaminant concentrations.
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w
"
EPA has found no evidence of a contaminant plume originating in the
gravel pit area east of the Valley plume. This is based upon
review of EPA sampling data. Groundwater flow patterns in the
Johnson Creek area are similar for the stream segments from Mill
Pond to Main street and from Main street to station No.2.
The commenter's contention that the Valley plume discharges totally
to . JohnsOn Creek near Main street is not supported by the data
since plume migration parallel to the stream as aquifer underflow
has been documented. Data obtained during the Supplemental MOM
RI/FS further indicate that contaminants have migrated parallel to
the stream a significant distance downgradient of the Valley
property. In addition, highest concentrations of contaminants
found. within the Valley plume are generally at the base of the
ove~burden aquifer.
Surface water levels in Mill Pond and portions of Johnson Creek
near the pond were observed to be above adjacent groundwater
levels, indicating that surface waters recharge groundwater in some
of the areas located above the plume. This surface water
infiltration probably acts locally to inhibit contaminant migration
towards the stream. Overall contaminant migration is controlled
primarily by the general northerly groundwater flow direction
within the valley. . Local groundwater discharge to surface water
bodies has not eliminated the continued movement of the contaminant
plume at depth.
c.
Mill Pond Extraction/Treatment system
COMMENT: One commenter states the downward vertical gradient
exceeds the horizontal gradient by an order of magnitude in the
Mill Pond area, suggesting a high degree of horizontal to vertical
anisotropy in this area, a feature no analysis in the Supplemental
MOM RI was capable of simulating. .
..
EPA RESPONSE: The large downward gradient in the Mill Pond area is
an expression of the infiltration of pond waters into groundwater
in this.area (which is described in the Supplemental MOM RI report
and substantiated by field data), and of the localized effects of
the pumping of partially penetrating wells, a category in which the
current. extraction wells belong. This partial penetration effect
can be expected to dissipate rapidly away from the pumping wells,
as occurred in the Station No.1 pumping test, with the flow field
reverting to a laminar form. The capture zone extent is unlikely
to be affected by anisotropy/partial penetration effects unless the
capture zone is so small as to be limited to the immediate vicinity
of the extraction wells. .
COMMENT: One commenter states that contaminant concentrations
downstream of the Mill Pond interceptor system are more likely a
result of movement of further portions of the plume back toward the
interceptor system or possibly represent stagnation of
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contamination as a result of pumping at extraction wells G-1 and
G-2.
EPA RESPONSE: The commenter's statement that contaminants located
downgradient of the extraction system are likely a reflection of
contaminants being drawn back to the Mill Pond extraction system
does not agree with evidence that suggests the contamination is not
being captured, but rather is continuing to migrate further
downgradient away from the extraction system. Groundwater level
contour maps developed from actual field data clearly show a flow
gradient away from the extraction system almost immediately
downgradient of the extraction system, indicating that flow
reversals are not occurring at any substantial distance
downgradient of the extraction wells. A downgradient capture zone
limit calculation performed using field-measured data regarding
flow gradients, aquifer thickness, a 'pumping rate of 40 gpm
(ignoring stream recharge which is likely occurring), and the
hydraulic conductivity of 22 feet per day as claimed in the
comment, results in a downgradient capture zone limit of less than
60 feet. This is much less than the downgradient extent of the
most concentrated portion of the plume, let alone the portions of
the plume containing lower contaminant levels and located ~urther
downgradient. It should be noted that the assumptions made
regarding pumping rate and hydraulic conductivity are conservative
in that they will tend to overestimate the capture zone extent.
COMMENT: One commenter states that the Mill Pond System should not
be abandoned and that the Supplemental MOM RI analysis did not
consider the design data.
EPA RESPONSE: The Supplemental MOM FS clearly states that the
remedial design provides for incorporating elements of the Mill
Pond system based on further review. It should be noted that
Discharge Monitoring Reports ("DMR") for the Mill Pond extraction
and treatment system indicate that the system has at least on two
occasions, exceeded its TCE effluent limitation due to "an
accumulation of mineral solids. which have precipitated in the
groundwater treatment air stripper tower (see DMR transmittal
letter dated April 26, 1989, from John L. Falcon to u.S. EPA).
This iron sludge buildup has caused the shut down of the unit for
clean out and maintenance on two occasions, in November 1988 and in
April 1989. In addition, the problem has resulted in the reduction
of loading (flow) to the unit. At startup in 1988, the extracted
groundwater flow to the unit was approximately 75 gpm; currently
flow to the unit is approximately 40 gpm.
Clearly, this system is not capable of operating at 75 gpm or even
on a continuous basis at a lower flow without some form of pre-
treatment to prevent solids buildup. The analysis of the design
data would be of interest but is not a reflection of the actual
operation of the system in 1990 when the Supplemental MOM RI was
carried out. .
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u
'0
COMMENT: One commenter feels that the supplemental MOM FS
indirectly attacked the lack of a vapor treatment system on the
Mill Pond System.
EPA RESPONSE: The supplemental MOM FS did not indicate that the
vapor emissions from the Mill Pond System presented "unacceptable
risks." Calculations presented in the supplemental MOM FS Appendix
indicate the full scale system would not present unacceptable risks'
due to untreated emissions, and therefore the much smaller system
at Mill Pond would be expected to cause even less risks. The need
for air pollution controls under Alternative 4 is based on an ARAR
for new sources of vapor emissions.
CO~ENT: One commenter disagrees with the statements in the
supplemental MOM FS that the "concentration of target compounds in
the discharge to Johnson Creek from the air stripper effluent
exceeds the preliminary discharge standards." The commenter also
contends that average dilution factors from Johnson Creek should be
considered when determining allowable discharge concentrations.
EPA RESPONSE: EPA disagrees with these comments. Acceptable
concentrations of metals for surface water differ from (and are
less than) those for groundwater. That some of these metals may be
of natural origin is not relevant. The comments focus' on arsenic.
. In addition to arsenic, there are nine other metals which may
exceed preliminary discharge standards if not treated. The final
standards for a pump and treat system discharge will be developed
taking into account all ARARs associated with this portion of the
remedy.
COMMENT: One commenter states that the supplemental MOM FS fails
to justify the proposed removal and replacement of the Mill Pond
Interceptor
EPA RESPONSE: EPA agrees that the Mill Pond system. has been
effective in reducing the migration of contaminated groundwater
near Mill Pond and has removed significant quantities of
contaminants. However, this system was established as an interim
measure. and was not designed to effect a complete remediation of
the contaminant volume. Specific components of this system will be
retained' if feasible for inclusion in a site-wide remediation
system. However, a system designed for 40 to 75 gpm may not be
easily upgraded to handle a flow rate of about 365 gpm.
Groundwater to be treated may also contain other analytes above
potential receiving waters criteria. The existing system is not
designed to ameliorate these concerns. It also employs an air
stripper without vapor phase controls 'and, thus simply transfers
contaminants from the groundwater to the air.
COMMENT: One commenter contends that the quantity of TCE in the
aquifer, as calculated by NUS, is significantly overstated. To
support this contention, the commenter compares the quantity of TCE
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removed by the existing Mill Po,':': extraction system with the
estimated quantity of TCE remaini::;g, the use of maximum versus
average, concentrations of contaminants at each location, the use of
bedrock groundwater data, and the' basis for estimating the
partitioning coefficient.
EPA RESPONSE: The 6700 pound quantity of TCE is an estimate. The
actual quantity of TCE present beneath the Valley property and
within the Valley plume cannot be accurately estimated because the
dense non-aqueous phase liquid ("DNAPL") mass (if it exists) is
unknown. The direct comparison of NUS' est,imated quantity of
contaminants versus that removed by the system is not necessarily
valid. The use of maximum concentrations at each point is valid.
The use of average concentrations would incorrectly indicate that
several areas are not contaminated. A remediation objective is to
achieve compliance with the remediation goals at all areas, not
just on the average. Also, the use of groundwater' data in the
bedrock is relevant since it is connected with the overburden.
Additionally, as presented in Appendix A of the Supplemental MOM
FS, the average concentration for a given zone is used. The
average used is the geometric average for each area. The geometric
average is less than the arithmetic average.
The partition coefficient used is appropriate for this aquifer.
References in Appendix L of the commenter' s statements do not
provide sufficient basis to eliminate the values used. EPA agrees
that the presence of iron would bias the total organic carbon
("TOC") results on the high side. However, the partition
coefficients used are not unreasonably high.' Also, if the
partition coefficients are lower, remediation would be completed
earlier than the estimated 30 years. This would result in
similarly lower costs than those estimated.
COMMENT: One commenter questions the Supplemental MOM RI critique
of the Mill Pond extraction system by claiming that the system is
effective in remediating the contaminant plume and that no
additional efforts are needed to adequately remediate the aquifer.
EPA RESPONSE: The two issues addressed by the commenter are. the
existing system's recovery of contaminants from the aquifer and the
capture zone extent of the system. EPA agrees that the existing
system is removing some contamination from the aquifer. However,
EPA believes the existing system cannot meet the remediation goals
of complete aquifer cleanup within an acceptable time frame and
cannot control plume migration. Wells pumping at various rates
will remove contamination from the aquifer, but lower-than-needed
pumping rates or incorrect well placements will compromise the
system's performance and effectiveness , despite the removal of
contaminants.
The supplemental MOM RI analysis of the capture zone of the Mill
Pond extraction system was approximate in nature due to a lack of
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<1
"V
conclusive data. As a result, the results must be considered as
rough approximations of the Mill Pond extraction system capture
zone. The commenter cites a pumping test performed as part of the
original design studies for the Mill Pond system as a source of the
data used to support its analysis. A review of these data reveals'
that the pumping test analysis used evaluation methods that were
inappropriate. The method used has a minimum time requirement that
must be met before the analysis can be applied. The method
requires a much longer testing time than the 270 minute pumping
test that was performed. As such, the transmissivity and hydraulic
conductivity values used in both the original design and reviewers
analyses are based on improper analyses. '
Additionally, the gradient calculated by the commenter as
representative of the natural flow gradient is in error. The data
points used by the commenter were within the projected zone of
influence of the extraction system. As a result, water levels
measured wer~ not representative of background, unstressed water
levels. The background flow gradient is required for the type of
analysis performed, not the gradient used by the commenter., It is
also not clear that the two wells used are directly downgradient of
one another, and the use of only two wells to determine flow
gradients is not a generally acceptable approach to gradient
determinations. These factors resulted in a much lower calculated
gradient than is appropriate for the analysis performed by the
commenter and overestimated the extraction system's capture zone by
a considerable amount.
Additio~al work, including additional well installations and
aquifer testing, would be required to accurately determine the
capture zone of the Mill Pond extraction system. However, several
points can be made regarding the extraction system performance
ba,sed on the data available. The overall groundwater flow pattern
identified for the area of the plume clearly shows that
downgradient portions of the plume, both south and north of Main
street, are outside of the capture zone of the Mill Pond extraction
system. If additional extraction wells are not installed in this
area, the contamination will persist in the groundwater
indefinitely until natural flushing/degradation eventually cleans
this portion of the aquifer. Given the current 'use of this water
as a drinking water source, EPA finds this unacceptable. It is
also apparent from the observed mounding of groundwater at Mill
Pond and the locally observed discharge of surface water to
groundwater, that a portion of the water pumped by the current
extraction system is derived directly from Mill Pond and Johnson
Creek. The effectiveness of contaminant removal is reduced by
surface water infiltration, and the system's capture zone is also
reduced.
COMMENT: One commenter questions the placement of the Mill Pond
System under the No Action and Institutional Control Alternatives.
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EPA RESPONSE:
These are no longer part of the alternatives.
COMMENT: One commenter states that EPA should select the existing
Mill Pond Extraction and Treatment system as its remedial
technology.
EPA RESPONSE: The existing Mill Pond extraction system does not
capture all of the contaminated groundwater in the Valley plume,
will not achieve the remedial objectives set forth in the
supplemental MOM FS, and is not sufficiently protective of human
health and the environment. As such, it will not cleanup the Site
within a reasonable time frame considering the beneficial uses of
groundwater at the Site. .
COMM~NT: One commenter states that the discharge of contaminated
groundwater to Mill Pond and Johnson Creek was miscalculated in the
Supplemental MOM RI.
EPA RESPONSE: The commenter overestimates the discharge of
contaminated groundwater to Mill Pond and Johnson Creek. Data
obtained during the Supplemental MOM RIfFS indicate contaminants
have migrated parallel to the stream a significant distance
downgradient from the Valley source area. Surface water levels in
Mill Pond and portions of Johnson Creek near the pond were observed
to be above adjacent groundwater levels, indicating that surface
waters recharge groundwater over some of the area located above the
plume. This surface water infiltration probably acts locally to
inhibit contaminant migration towards the stream. Overall
contaminant migr~tion is controlled primarily by the general
northerly groundwater flow direction within the valley. Local
groundwater discharge to surface water bodies has not eliminated
the continued movement of the contaminant plume at depth.
COMMENT: One commenter states that the contaminant transport model
does not include the Mill Pond interceptor system and no check with
hydrogeology was presented for the model. .
EPA RESPONSE: The Mill Pond interceptor was not included because
the model was used to develop an extraction well array that would
capture the entire TCE plume. The model was calibrated to the
observed contaminant distribution in the plume. During remedial
design, locations of extraction wells, including those in the Mill
Pond area, and pumping rates, will be determined.
D.
Groundwater Kodelinq/Pump Test
COMMENT: One commenter states that the two-dimensional computer
flow model used. in the Supplemental MOM FS has not conclusively
demonstrated that contamination from the Valley property could have
reached Station No.1 under pre-1979 pumping conditions.
EPA RESPONSE:
This particular modeling exercise does not show
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<.)
Q
Valley to be the source under the conditions simulated. However, it
cannot be concluded that the model shows that Valley is not the
source of contamination of station No.1 before 1979, because the
model may not represent past conditions. Past conditions cannot be
replicated or verified because of changes in the physical setting.
Although EPA believes it has demonstrated that contaminants in the
plume did reach station No.1 in the past, it is not necessary for
EPA to demonstrate that contaminants from a particular source were
present at station No.1 for EPA to take response action.
COMMENT: One commenter contends that the zone of influence is not
a proper measure of a well's capture zone.
EPA RESPONSE: The commenter is correct that the zone of influence
is not a proper measure of a well's capture zone. .The discussion
of the zones of influence was intended to illustrate the extent of
impacts on the aquifer due to pumping. Since Station No.1 is not
being pumped at 600gpm as was the case in the past, and surface
mining acti vi ties have al.tered recharge conditions upgradient of
station No.1 (possibly increasing the recharge rate and decreasing
the width of the capture zone),. past conditions cannot be
duplicated in the field.
COMMENT: One commenter states that the terms "capture zone" and
"zone of influence" were confused in the supplemental MOM RIfFS.
~
EPA RESPONSE: EPA recognizes that the terms refer to different
concepts, and that they may not be used interchangeably. The
Supplemental MOM RIfFS did not confuse" zone of influence" with
"capture zone." The zone of influence, and not the capture zone,
was emphasized in the supplemental MOM FS because it is readily
definable by the data, whereas the capture zone is more open to
interpretation. The zone of influence (drawdown) can be projected
with reasonable certainty for different lengths of pumping time,
rates, and distance from the pumping well, whereas capture zone
cannot be projected with equal certainty.
COMMENT: One commenter suggested that future water demand in the
Town of Groveland could be accommodated by increasing the Station
No. l' pumping rate to 600 gallons per minute (gpm) during the
cleanup process. On-site crews could sample groundwater to assure
that the plume's path is not diverted to the well.
EPA RESPONSE: Based on simulations performed under conditions at
station No.1 of non-pumping, pumping at 400 gpm, and pumping at
600 gpm, the preferred extraction system should prevent further
migration of the plume toward Station No.1.
Comment: One commenter contends that the pumping test conducted in
the supplemental MOM RI, which showed the influence of pumping to
extend to station No.2 and to the Valley plume, was run at too
high a rate to simulate the 1969-1979 conditions. .
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EPA RESPONSE: The commenter dismisses the importance of the fact
that drawdowns from Station No.1 can intersect the Valley plume in
the glacial aquifer for two reasons: 1) the pumping test rate (400
gpm) exceeded the average rate for the 1969-1979 period; and, 2)
the Supplemental MOM.RI confused the zone of influence with the
capture zone. .
However, the pumping test rate of about 400 gpm closely
approximates the average rate for the period between 1969 and 1979,
which was estimated to be about 380 gpm. The 20 gpm difference is
physically and analytically insignificant at the scale of this
site. Also, the actual pumping rate for Station No.1 during the
summers no doubt exceed the average annual rate (pre-1979) for
extended periods of time.
The commenter also ignores the fact that drawdownsdueto pumping
in the bedrock, parallel to the reported strike of the bedrock, and
in direct line with the Mill Pond area where the Valley plume
occurs at some of the highest concentrations in bedrock. One of
the wells effected by the pump test lies between Mill Pond and
Station No.1 and is presently contaminated.
COMMENT: One commenter states the surface water infiltration
contribution to Station No.1 is not accounted for in. the pumping
test analysis. -
EPA RESPONSE: The Supplemental MOM RI acknow.ledged that some
stream infiltration occurs in the vicinity of station No.1-
However, the increase in surface water discharge in the downstream
direction may be small due to the short distance between measuring
points, and whether or not there was a thaw. The commenter' s
estimate of 200 gpm from surface water infiltration is probably
high. A more reasonable estimate would be 10-20% of the total flow
or 40-80 gpm. However, factoring in gains from surface water
infiltration will not decrease the capture zone of the well, as the
pumping rate used in the pumping test analysis would have to be
adjusted downward an amount corresponding to the surface water
infiltration rate. This will ultimately reduce the test-derived
value for hydraulic conductivity and result in an increa~e of the
required capture zone beyond what would be calculated using the
higher value of hydraulic conductivity, obtained without factoring
in stream. recharge. In essence, the increase in recharge from the
stream would offset the resulting decrease in the aquifer's pumping
test-calculated hydraulic conductivity as they relate to the well's
capture zone. A final consideration is that the observed drawdown
pattern within the aquifer includes the effects of stream
infiltration, whatever rate it may hav~ been for the test.
COMMENT: One commenter
contamination that EPA
separated from Station
divide.
has concluded that the area of aquifer
used to establish cleanup limits is
No.1 by a permanent groundwater flow
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"'-\
EPA RESPONSE: There appears to be no evidence of a fixed and
permanent groundwater flow divide between Station No.1 and Johnson
Creek. Under non-pumping conditions, groundwater flows generally
northwird, some discharging locally to Johnson Creek and Argilla
Brook; the remainder discharges to the Merrimack River. Depending
on the climatic conditions and the magnitude of groundwater
pumping, the effect of that pumping can be expected to extend
further away from the extraction well (s), capturing water that
would have moved to the Creek, Brook or River. Therefore, the
likelihood of contaminants reaching station No.1 depends on how
much water is pumped and how dry the season or year. Currently it
appears unlikely that contaminants from the Valley plume will
migrate to Station No.1. The contaminated portion of the aquifer
has, however, been used as a potable water supply source (Station
NO..2) and could potentially be used again.
COMMENT: One commenter states that the model simulates the
Pond interceptor system as one well pumping at 40
Representing the two wells individually at 20 gpm would
resulted in a larger calculated capture zone.
Mill
gpm.
have
EPA RESPONSE: Given the size of the model and the intended
purpose, the approach to use one well was technically valid. The
capture zone is dictated by the pumping rate rather than the number
of wells. The location and pumping rate of extraction welles) will
be determined in remedial design.
COMMENT: One commenter states that the pumping rate proposed for
the proposed extraction system is 365 gpm.
EPA RESPONSE: The results of the modeling were used to simulate
capture zones to assure that the extraction system would capture
the entire plume. To provide for uncertainties in this analysis,
the treatment system capacity was increased to.400 gpm.
The pumping rate for the extraction system will be determined
during remedial design.
COMMENT: One commenter states the contaminant transport model does
not permit discharge to Johnson Creek.
EPA RESPONSE: Contaminant discharge to Johnson Creek cannot be
simulated by the analytical transport model used in the
Supplemental MOM FS, however, this is by no means a fatal flaw in
the model. The simulated concentrations match well with the
average observed concentrations as shown in the commenter's Figure
2. In fact, both the model result and actual field data show
similar trends. without hard data to back up the commenter's
average observed concentrations data, it is not even clear that the
apparent minor difference is valid.
COMMENT: One commenter states there has not been enough time to
travel from Valley to Station No.2 using velocities cited in the
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Supplemental MOM RI and retardation factors impled by the model.
EPA RESPONSE: using the reasonable retardation factor of 2.0
proposed by the comrnenter, the initial estimate of travel time in
the model is reduced to less than eight years. Whether a trave~
time of 25, 18, or 8.years is used, it is clear that the scenario
of contaminant migration from Valley to station No.2 is very
viable and likely under the range of scenarios mentioned by the
commenter and in the supplemental MOM FS. The travel times
calculated that result in migration of the contaminant plume in
Station No.2 are well within the range of error in any modeling
effort of this type.
COMMENT: One comrnenter reconstructed the contaminant modeling in
the ~upplemental MOM FS to incorporate their own modifications.
EPA RESPONSE: EPA has reviewed the contaminant ttansport model
reconstructed by the commenter and in general does not agree with
the modifications because the model appears to provide results that
no longer replicate the observed trends, as shown in the
commenter's own Figure 8.
COMMENT: One commenter states that there is a much more rapid
reduction in contaminant concentrations than predicted by the
contaminant transport model.
EPA RESPONSE: The data presented in the comment do indicate that
in several areas TCE concentration, are decreasing more rapidly
than predicted by the model. However, these data also indicate
that in several areas the contaminant concentrations are remaining
the same or are increasing. The model was not intended to predict
the concentration at discreet locations. The model estimates the
time required to clean up all locations in a given area and, as a
result, it is generally on the conservative side. During the
remediation, it is likely that groundwater at some locations will
reach the remediation goals sooner than other areas. Based on the
data presented in Table 2 of the commenter's statements, the length
of time required to clean up specific locations can be estimated.
These es~imates are based on the consideration that the percent
reduction in concentration as a function of time is typically a
constant. Note that this approach is not always accurate because
of factors such as non-ideal flow conditions, upgradient sources,
and non-equilibrium conditions. However, this approach often
provides insights into cleanup times and several examples are
provided below. .
For well 71-21, there is a 90% reduction in 6 years. six years
later, another 90% reduction would be expected to occur. At that
time, the estimated concentration at this location would be about
6 ugjl, or very close to the remediation goal. For Well 71-24,
about an 80% reduction would occur every 6 years, indicating that
about 8 to 10 years would be required for the groundwater
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v
concentration to equal the remediation goal. Using the average
reduction of 82% every six years, and the most contaminated well
location (TW-25), about 32 years would be required to achieve the
remediation goals at this location. For well ERT-5, if a 32%
reduction occurs every 6 years the data indicate that this location
would remain contaminated for an additional 42 years. As can be
seen, various points can be expected to be cleaned up at various
rates. The conclusion that "80%" of the contamination has been
removed and "20%" remains is very misleading.
COMMENT: One commenter comments that the contaminant .transport
model cannot be used to evaluate the effectiveness of different
pumping scenarios.
EPA RESPONSE: The contaminant transport model. estimates the
number of aquifer pore volumes that must be removed to achieve
cleanup goals. The estimate can be used along with information
regarding pumping rates, well location, and contaminated volume of
the aquifer to estimate cleanup times of effectiveness of different
pumping scenarios. .
COMMENT: One commenter questions the hydraulic conductivity values
used in the modeling effort, stating that those used in the Johnson
Creek area were too high.
. \
EPA RESPONSE: The values were based on an initial input of pumping
test-derived values of hydraulic conductivities, and is an
appropriate us~ of these field data. These values were adjusted
during the modeling process to create a satisfactory match bet\7een
the modeled groundwater levels (lead) and corresponding field data
results, as is standard modeling procedure. The use of limited
slug test data by the commenters to the exclusion of long-term
pumping test data is contrary to generally accepted practices.
Pumping test data reflects hydraulic conditions within a volume of
aquifer orders-of-magnitude greater than the extremely localized
slug tests effects and are thus more appropriate for establishing
general aquifer characteristics. In addition, slug test results
are much more susceptible to the smearing effects of drilling
activities (skin effects) o~ the well boring walls which generally
causes. an underestimation (lower-than-actual) of hydraulic
conductivity. pumping test data are relatively insensitive to
localized effects. The trend discussed by the commenter appears to
be more a function of variances between testing methods.
Boring log descriptions support this alternate view, as the overall
makeup of the aquifer materials was relatively consistent
throughout the station No. l/Johnson Creek areas. If the hydraulic
conductivity trends were accurately portrayed by the commenter,
this would be one factor facilitating the movement of contaminated
groundwater from areas of lower hydraulic conductivity (Johnson
Creek) to areas of higher hydraulic conductivity (station No.1
vicinity) and increased dispersion.
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COMMENT: One commenter states that "for some inexplicable reason"
modeling was included in the Supplemental MOM FS.
EPA RESPONSE: Modeling was used in the Supplemental MOM FS as a
tool to evaluate potential future scenarios regarding the continued
use of the Station No.1 well as it relates to the existing
groundwater contaminant plume.
This was done to determine the potential long-term effects of the
Valley plume on Station No.1 and is consistent with good
engineering practices. The model was also used to develop a
conceptual design for a groundwater extraction system for the
Valley plume. Again, this is a valid reason for modeling and the
model used was designed explicitly for this purpose.
COMMENT: One commenter requests that, EPA develop
dimensional, anisotropic model that more accurately
conditions at the Groveland Wells Nos. 1 and 2 Site.
a three-
reflects
EPA RESPONSE: A three-dimensional model will provide a more exact
simulation of groundwater flow conditions than a two-dimensional
model, if the additional field. data needed to adequately
characterize the modeled area are obtained. The need for
additional modeling to assist in remedial design and track progress
during the remedial action will be evaluated. However, it is
uncertain that the additional modeling could be used to establish
an incontrovertible tie between the Valley plume and Station No.1.
COMMENT: One commenter states the groundwater model developed
during the first remedial investigation at the Site could have been
used to test hypotheses regarding suspected contamination events.
..
EPA RESPONSE: The intent of the Supplemental MOM RI was to
define the current extent of contamination and to determine the
impacts of pumping on the groundwater conditions in the study area.
Therefore use of the groundwater model developed during the first
MOM RI to test hypotheses regarding suspected contamination events
was not warranted. .
Since Station No.1 is no longer contaminated, and has not been
since the well was returned to service, the Valley plume is no
longer within the well's capture 'zone, or the hydrologic conditions
in the study area have changed such that the Station No.1 well is
no longer affected by ongoing (and/or persisting residuals from)
releases from a known source. If another unidentified source of
the contamination to Station No.1 existed, it was not found in
previous studies and apparently is no longer present.
COMMENT: One comment,er expressed various concerns about the
groundwater modeling performed as part of the Supplemental MOM FS
as follows:
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"q
u
o
Criteria identified for acceptance of a calibration are
inconsistent with established criteria as presented in
"stochastic Subsurface Hydrology From Theory to
Applications" by Lynn W. Gelhar, published in Water
Research Vol. 22 No.9 (August 1986).
The calibration of the supplemental MOM RI two-
dimensional model is significantly poorer than that
achieved by the model used in the first remedial
investigation completed at the site.
o
o
The two-dimension
aquifer behavior.
model
does
not
accurately
reflect
EPA "'RESPONSE: Among the three "estaplished criteria" identified by
the commenter, two of them (the average difference and systematic
bias) were not mentioned, developed, or defined in the cited
publication. The only acceptance criteria, head variance,
described in the cited publication, addressed the influence of
unmodeled heterogeneity on the quality of predictions from such
models in which only averaged parameters were used to describe the
simulated aquifers. According to the author, "this head variance
can be viewed as a measure of the error in the model as the result
of unmodeled aquifer heterogeneity," and "this head standard
deviation is an appropriate calibration target provided that other
sources of error are also considered."
..
The calculation of a specific head variance value involves
estimating the aquifer mater ial-based parameters, si te-specif ic
dimensional consideration based-parameters, and site-specific mean
hydraulic gradient. Gelhar did not attempt or suggest generalizing
the calculated head variance for a specif ic case study as a
criteria that should be applied anywhere other than the studied
site. Also, in the field application discussed in the publication,
the head variance was used as a "target" and not an upper limit of
the sample variance. The final sample standard deviation (0.16 m)
judged to be acceptable in the example was higher than the
estimated head standard deviation (0.14 m). It is clearly pointed
out that this criteria should be used an order of magnitude type of
criteria.
As mentioned earlier, Gelhar also pointed out that, in addition to
the aquifer heterogeneity, there will be other sources of modeling
error and acceptable values of all these possible errors which will
need to be independently estimated. The final model criteria
should be the summation of all these errors. These possible errors
may inc~ude measurement errors, discretization errors associated
with the numerical scheme, and, in most simplified long-term steady
flow approaches, the unavoidable seasonal water level fluctuations
in the measurement.
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The commenter's specific values of 0.1 ft and 0.6 ft for "average
difference" and "standard deviation" apparently were taken from
Table 2, in the cited publication. The values (from a number of
studies) summarized in this table were actually standard deviations
and correlation scales for log hydraulic conducti vi ty or log
transmissivity, not head variance as the commenter states, that can
be utilized as references for two of the parameters required in the
calculation for the head variance.
In this Table, for silty clay loam soil (alluvial) and outwash
sand, values of 0.6 and 0.1, respectively, are. labeled in meters,
rather than feet as the commenter states. By quoting these two
values using wrong units the commenter gave them totally "new"
meanings. Clearly, they cannot replace the criteria identified in
the Supplemental MOM FS.
with respect to the commenter's concern about the systematic bias
in the simulated flow direction, it is interesting to note that in
Fig. 10 of the field application example in the cited publication,
in ma.ny locations the differences between the observed and
simulated flow directions are more than 30 degrees.
The ERT three-dimensional model used in the first remedial
investigation achieved a 1.525 foot standard deviation between'25
field measurements and simulated results in a smaller model area as
shown in Figure M5-1 of the remedial investigation report. The NUS
two-dimensional model used in the Supplement~l MOM FS, with the
simplified aquifer structure covering a larger ar~a, achieved 2.06
and 1.88 overall standard deviations using 72 and 49 field
measurements, respectively. As described in the Supplemental MOM
FS, these two standard deviations are well wi thin the seasonal
fluctuations of the local water table. Considering the greater
number of comparison points, the larger area covered by the model
and model simplification, the NUS model is calibrated and validated
as well as, if not better than, the ERT model, and is a
representative model of overall aquifer behavior within the area of
concern. '
COMMENT: One commenter states the Supplemental MOM FS modeling
shows that contaminant discharge to Johnson Creek is occurring and
implies that contaminant migration does not reach station No.2.
EPA RESPONSE: The flow model classified reaches of Johnson Creek
between Mill Pond and Station No.2 as either a gaining or a losing
stream, as shown in Figure B-1a. The model shows Mill Pond between
Staff Gauge No.5 and. a smaller pond by Station No.2 are
recharging groundwater while the rest of the reach of Johnson Creek
between Staff Gauge No.5 and the downstream pond is gaining
groundwater. The surface water elevation of Staff Gauge No.5 (19
mean sea level [msl]) was used directly in the model at the
location of the gauge. A msl of 23 was used for the reach of Creek
between Mill Pond and Staff Gauge No.5 and is an interpolated
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'"
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the covering of the sand and gravel excavation areas south of
station No.1 would have little impact on the station No.1 capture
area.
EPA RESPONSE: EPA does not agree with this interpretation of the
statements made in the Supplemental MOM FS.
E.
A. w.
Chesterton
COMMENT: One commenter states that the results of the computer
flow model used in the Supplemental MOM FS show that, the A. W.
Chesterton property is a potential source of the original
contamination of station No.1, while demonstrating that the Valley
prope.rty is not.
EPA RESPONSE: The flow model shows that the A.W. Chesterton
property is a potential source area for the contamination of
Station No.1. It is unlikely that this is the case as evidence of
a significant source at Chesterton does not exist. Although the
flow model results indicate that the Valley property is nota
potential source area for the contamination of station No.1 under
present conditions, it cannot be concluded that Valley was not the
historical source of contamination at station No.1. Again, the
purpose of EPA's investigations, was to identify contaminant
releases within the aquifer beneath the site in order to fashion a
protective remedy. EPA's investigations were sufficient for that
purpose.
COMMENT: One commenter contends that EPA failed to name earlier
owners/operators of the A.W. Chesterton facility as PRPs.
EPA RESPONSE: This comment concerns enforcement actions against
PRPs that may be undertaken in connection with remediation
activities at the site, and does not relate to the Proposed Plan or
the remedy selection process.
COMMENT: One commenter, represent ing A. W . Chesterton Company,
expressed dismay that EPA had characterized the company as a
"likely" source, and as "one of several" sources, of the
contamination of station Nos. 1 and 2 Superfund Site. The
commenter further states that, since the contaminants on' the
Chesterton property are different from those found at station Nos.
1 and 2, the supplemental MOM RI indicates that the contamination
on the Chesterton property is confined to its own boundaries, and
EPA is addressing remediation at the Chesterton property under a
separate law, these characterizations are creating unwarranted,
adverse publicity for an innocent company.
EPA RESPONSE: The Chesterton property is one of three potential
sources of groundwater contamination within the Site boundary
identified in both remedial investigations completed at the site.
Groundwater sampling at Chesterton first was undertaken in a
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'-'
remedial investigation completed earlier in 1985. As part of the
Supplemental MOM RI, additional groundwater sampling was undertaken
at . the Chesterton property to update the characterization of
contamination. Groundwater sampling data indicate that Chesterton
is not a likely source of groundwater contamination for the Valley
plume. However, groundwater contamination exists wi thin the
Chesterton property boundaries. Included among the contaminants in
that groundwater are low levels of TCE as well as other
contaminants. Al though EPA is addressing this problem under
separate legal authority, this property is still considered part of
the Site and will be further evaluated to ensure that all CERCLA
requirements are met at this property.
COMMENT: Several commenters state that instead of proceeding with
the-proposed contaminant plume-wide pump and treat operation, EPA
should focus its efforts on the most highly contaminated portion of
the Valley plume, with the result that fewer extraction wells would
be needed, the flow of contaminated water needing treatment would
be decreased, and the cost of remediating the groundwater would be
reduced. .
EPA RESPONSE: EPA believes that the extraction system included in
the selected remedy focuses on the highly contaminated portions of
the Valley plume. EPA's preferred extraction well locations, which
may be revised during remedial design, will essentially capture the
Valley plume where TCE levels exceed 5 ugfL. Estimated extraction
well locations and pumping rates are based on capturing the Valley
plume based on model simulations as discussed in Appendix B of the
Supplemental MOM FS report.
Two extraction wells with pumping rates of 100 gpm and 125 gpm are
situated between Mill Pond and Main Street to intercept the
concentrated portion of the plume as close as possible to the
source area. One well with a pumping rate of 100 gpm is positioned
near Station No.2. The other three wells extract less
contaminated groundwater at lower rates (10 to 20 gpm) in the
downgradient portion of the plume.
COMMENT: Several commenters feel that by concentrating the
extraction system in .the area. between Mill Pond and Main Street,
the flow rate could be reduced to probably less than 200 gpm. The
commenters suggests that this targeting could reduce the size of
the treatment plant to one-tenth. The commenters believe that this
approach would result in a significant capital and operations and
maintenance cost savings.
EPA RESPONSE: EPA agrees that limiting the extraction system to
those areas would likely decrease capital and operating costs,
although treating 200 qpm (or less) would not be expected to reduce
costs by a factor of 10 from the preliminary extraction rate of 365
gpm. However,. a significant portion of the contaminated plume
would not be addressed under this scenario and, thus, the remedy
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would not be protective of human health and the environment, nor
would. it meet ARARs, necessary components for selection of remedies
under CERCLA.
F.
Selected Remedy
COMMENT: One commenter states that the cost estimate for the
UVjOxidation system in the Supplemental MOM FS is too low as it was
based on information provided by a single vendor.
EPA RESPONSE: FS Guidance for cost evaluations recommends that
estimates be in a -30% to +50% range to avoid significant
underestimates of remedial costs. A conservative posture was
adopted in the Supplemental MOM FS for costing purposes. The
vendor providing the cost information has supplied the process to
approximately 30 commercial facilities over the last five years.
The vendor's cost information is considered to be within the
appropriate range.
COMMENT: One commenter states that EPA has failed to perform a
treatapility study which it concedes will be necessary to determine
whether the UVjOxidation process will be effective. EPA guidance
makes it clear that EPA cannot select a process where it lacks
treatability studies to demonstrate effectiveness. In.addition,
circumstance under which testing can be postponed until remedial
design do npt exist here.
..
EPA RESPONSE: The Superfund Remedial Design and Remedial Action
Guidance Manual (OSWER) Directive No. 9355. 0-4A) indicates in
Section 2.3.2 that remedial actions involving on-site treatment or
disposal of contaminated wastes may require additional studies to
supplement the technical data available from the RIjFS so that the
optimum treatment or disposal methods may be determined.
Additional studies could include bench- and pilot-scale studies.
Since treatability studies were not conducted during the
Supplemental MOM RIjFS,these additional studies on UV/Oxidation
will be conducted as part of the remedial design/remedial action.
The Guidance for Conducting Remedial Investigations and Feasibility
studies. under CERCLA (OSWER Directive No. 9355.3-01) indicates in
Chapter 5 that the decision to conduct treatability must be made by
weighing the cost and time required to complete the investigation
against the potential value of the information in resolving
uncertainties associated with selection of a remedial action. In
some situations, treatability investigations may be postponed until
the remedial design phase. The decision process for treatability
investigations includes 1) determining data needs, and 2) reviewing
existing data on the site and available literature on technologies
to determine if existing data are sufficient to evaluate
alternatives. The Guidance further states that pilot-scale studies
should be limited to situations in which bench-scale testing or
field sampling of physical or chemical parameters provide
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COMMENT: One commenter questions the reliability and sturdiness of
UV/oxidation, particularly given the estimated 30-year operational
requirement. It cites the case of a plant in Nashua, New
Hampshire, where the UV reactor vessel, less than five years old,
has become perforated, the electrical system has required annual
overhauls and the "technical response to difficulties has been
problematic."
EPA RESPONSE: The plant referenced in this comment treats phenol-
contaminated groundwater at a rate of 50 gpm for discharge to a
local publicly owned treatment works using a UV system with ozone
as the oxidant. EPA contacted both the owner and the vendor who
supplied the treatment unit to discuss this comment. According to
the owner's representative, the plant has treated about 92 million
gallons since start up and has met the treatment requirements with
no extended shut downs. This installation was among the first of
the commercial units employing this technology and has been in
operation for 5 years. The owner's representative reports that
pitting of the reactor vessel floor and walls has occurred to the
point that the serviceable life of the unit is in question.
According to the vendor~ the reactor vessel design was changed
about 3-1/2 years ago to specify a more resistant stainless steel.
No pitting in units fabricated with the new design have been
reported. Concerning the electrical system overhaul, this problem
could not be verified except that some site-specific wiring
problems have been experienced. The owner reports that the ozone
generators are rebuilt on a 12 to 18 month schedule by the
generator supplier. The comment about technical response is vague
and could not be verified.
COMMENT: One commenter expressed concern about the cost of the
quarterly monitoring, which he estimates at $32,000. He suggested
that if EPA contracted the monitoring effort out to a private
co~pany, these costs could be reduced by one-fourth to one-half.
EPA RESPONSE: EPA's estimates of the cost of performing quarterly
monitoring are based on substantial experience. The cost of the
sampling program was determined by taking into consideration the
number of analytes, the required sensitivity of the analysis, the
regulatory requirements, and the data quality objectives.
When remedial design is completed, and implementation of the remedy
is about to begin, a determination will be made concerning who will
perform the monitoring.
COMMENT: One commenter questions the number, location, and pumping
rate of the extraction wells.
EPA RESPONSE: The extraction well system presented in the
Supplemental MOM FS was based on the capture of the entire
contaminant plume. This includes groundwater north of Main Street.
The exact locations and number of wells will be determined during
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Q
\}
remedial design. A preliminary extraction system was developed to
allow costing of alternatives. The pumping rate used was estimated
to capture all of the contaminated groundwater, not just the most
contaminated. The extraction system design will be revised during
remedial design to optimize the capture of contaminants.
COMMENT: 'One commenter states that nearly all of the new wells
installed in preparing the Supplemental MOM RI were at the location
of existing wells.
EPA RESPONSE: Approximately one-third of the wells installed were
in areas where no wells existed, and another third were installed
at key' locations where previously installed wells were destroyed or
unusable. The remaining wells were installed adjacent to existing
wells to provide a three-dimensional profile o.f contaminant
distribution and groundwater flow.'
G.
Analysis Of Alternatives
COMMENT: Several commenters cite the different sensitivities to
metals between the two treatment systems. It states that an air
stripping unit could tolerate a higher level of metals in the
groundwater than co~ld a UV/Oxidation unit. The UV system lamp
surfaces are sensi ti ve to metals coating and can be readily
rendered ineffective due to scaling.
EPA RESPONSE: The commenters' statements are correct. However,
the system designed for metals removal is intended to effectively
reduce the problems associated with metals ccating the UV lamps.
COMMENT: Several commenters recommend that an air stripping system
(Alternative 4 in the supplemental MOM FS) be selected as the
appropriate remedy because that system would be safer and more
implementable, reliable, efficient, and cost-effective than EPA's
preferred UV/Oxidation system (Alternative 6 in the Supplemental
MOM FS).
EPA RESPONSE: EPA agrees that air stripping is a reliable,
eff icient, cost effective, .and readily implementable technology.
The UV/Oxidation process, has been known for at least 10 years and
has been evaluated under the EPA Superfund Innovative Technology
Evaluation (SITE) program. The process is still considered an
innovative technology, mostly because of the small size and number
of the existing full-scale treatment units.
The SITE project evaluation of the uv/oxidation process revealed
that at "preferred" operating conditions, the process achieved
removal efficiencies as high as 90 percent for th~ total VOCs
present in the groundwater. The major contaminant at that Site,
TCE, had removal efficiencies greater than 99 percent.
Treatability testing would be required to confirm feasibility of
the UV/Oxidation process and to derive design parameters at the
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,~
Groveland Wells Site. Subject to this verification, the process
reliability of this technology is expected to be good, based on
experience with normal ozonation. There are several vendors who
are capable of providing UV/Oxidation treatment systems.
EPA selected UV/Oxidation over air stripping because UV/oxidation
provides for on-site destruction of organic contaminants in
groundwater and the use of that treatment technology for organic
contaminants produces virtually no waste residuals.
COMMENT: One commenter suggests that
explore alternatives between the no
technical, costly alternatives discussed
and the Proposed Plan.
EPA RESPONSE: EPA's primary responsibility at the Site is to
undertake remedial action that is protective of human health and
the environment. I~ addition, under Section 121 of CERCLA, 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, be cost-
effective and utilize permanent solutions and alternative treatment
technologies or resource recovery technologies to the maximum
extent practicable, and prefer remedies in which treatment
permanently and significantly reduces the volume, toxicity, or
mobility of the hazardous substances.
EPA adequately did not
action and the highly
in the Supplemental MOM FS
The Supplemental MOM FS considers the universe of potentially
applicable technologies given the nature and extent of
contamination at the site and focuses specifically on a limited
number of alternatives which address groundwater contamination at
the Site. (See Section 4 of the Supplemental MOM FS for a
discussion of the alternatives that were screened). Those which
were not technically implementable were eliminated from further
consideration; the remaining technologies include alternatives that
potentially are capable of achieving the statutory requirements
outlined above. The Proposed. Plan includes this group of
alternatives, which is a subset of the feasibility studies' many
considerations.
Given the scope of the statutory requirements, and the nature and
extent of contamination at the site, EPA believes that it
considered an appropriate range of alternatives in the Supplemental
MOM FS and the Proposed Plan. See later response re: range of
alternatives.
COMMENT: One commenter recommends that EPA reinject the treated
water into the downgradient portion of the Valley plume or dilute
the less contaminated areas of the plume by injecting water from
the Merrimack River into the plume through the Station No.2 well,
in order to accelerate the cleanup process.
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(.j
v
EPA RESPONSE: Reinjection of treated water into the aquifer was
considered in the supplemental MOM FS. Its use was rejected
because it appeared to be less cost effective than the proposed
discharge to Johnson Creek. In addition, there was concern that it
would exacerbate the current contamination distribution, and may
conflict with proposed remediation. Injection of Merrimack Rfver
water into the aquifer was rejected also because it dilutes rather
than remediates the problem.
COMMENT: One commenter states that the supplemental MOM FS failed
to conform to the National Contingency Plan (NCP) by not evaluating
different cleanup times.
EPA RESPONSE: The Supplemental MOM FS did evaluate alternative
pumping rates (and therefore different cleanup times). During the
evaluation of technologies, the supplemental MOM' FS . evaluated
injection as a means of accelerating remediation through higher
pumping rates. However, these technologies were not found to be
technically implementable~ As a result, only one pumping rate was
developed, namely that required to capture the entire contaminated
plume. . Pumping at a lower rate would result in contaminants
bypassing the extraction system. Pumping at a higher rate would
result in excessive drawdown in the area.
COMMENT: One comrnenter states that since there presently is no
contaminatipn 'at station No. l, and no likelihood that the plume
will be drawn to station No.1, efforts to clean-up the Valley
plume to protect people from drinking contaminated groundwater are
unjustified.
EPA RESPONSE: EPA disagrees with the commenter because taking no
action to remediate the Valley plume would not provide overall
protection of human health and the environment. For example,
humans could be exposed to excessive levels of organic contaminants
if new private wells were located in the aquifer.
The aquifer at the site is a valuable resource both under EPA's
Guidelines for Groundwater Classification and under the State
classification for groundwater. The goal of EPA .and the
commonwealth of Massachusetts is to restore usable groundwater on
the site .to its beneficial uses. This aquifer is classified as
Class I by the Commonwealth of Massachusetts and Class II by EPA.
Restoration of this aquifer is consistent with these
classifications. See 55 Fed. Rea. 8732.
COMMENT: Several commenters feel that the relative total costs
between Al ternati ves 4 and 6 are uncertain . capital costs are
usually' more expensive, while energy consumption is substantially
higher for UV systems than those for air strippers. The commenters
question whether the supplemental MOM FS evaluated other air
emission control systems such as thermal oxidation and if air
controls were included in the cost for Alternative 6. .
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EPA RESPONSE: The relative accuracy of costs in an Supplemental
MOM FS are typically -30%/+50%. EPA believes that the cost
estimates provided are within this range of accuracy.
The use of other air pollution control devices was considered in
the Supplemental MOM FS. However, for the relatively low level of
contaminants expected to be in the groundwater treated, the
operation of an incinerator-type (thermal oxidation) air treatment
system is typically higher in both capital and operating costs.
Also, as contaminant concentrations decrease with time, the
operating costs for activated carbon also decrease; for thermal
oxidation, they remain the same.
B.
Institutional controls
COMMENT: One commenter states that No Action and Institutional
Controls will meet groundwater quality ARARs.
EPA RESPONSE: The EPA disagrees with this comment. The point of
time referenced for compliance with ARARs is at the completion of
the remedial activities. At this time, contaminated groundwater
would remain in the aquifer and therefore groundwater quality ARARs
would not be met. .
..
COMMENT: One commenter states that the existing Institutional
Controls are sufficient to prevent ingestion of contaminated
groundwater.
EPA RESPONSE: Institutional Controls, on a praciical basis, have
a spotty record of effectiveness in preventing the use of
contaminated groundwater! In addition, Section 121 of CERCLA
states Congress' preference for treatment and permanent remedies as
opposed to simple prevention of exposure thru legal controls.
Although institutional controls are used by .EPA in appropriate
circumstances, they should not substitute for more active response
measures that actually reduce, minimize, or eliminate contamination
unless such measures are not practicable. .
COMMENT: One comrnenter states that Institutional Controls will be
needed indefinitely because of natural contamination of the
groundwater.
EPA RESPONSE: At the present time, EPA does not believe that
natural inorganics concentrations exceed MCLs. During remedial
design, however, background levels of inorganics will be
determined. If cleanup levels set forth in the Management of
Migration ROD are achieved, institutional controls should not be
necessary. EPA does not dispute the need for institutional
controls while remediation of the Valley plume is ongoing.
COMMENT: One comrnenter states that the imposition of institutional
controls is an effective strategy and can achieve the objective of
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()
'l;
preventing people from drinking contaminated groundwater from the
aquifer.
EPA RESPONSE: Institutional controls have a spotty record of.
effectiveness in preventing the use of contaminated groundwater.
However, effective institutional controls, although difficult to
implement and enforce, may prevent people from drinking
contaminated groundwater from the aquifer. However, such controls
would need to be maintained for a much longer period of time than
the approximately 30 years that would be required for complete
implementation of the selected remedy. In addition, additional
remedial actions will be required regardless of what institutional
controls are employed. See earlier response re: preference in
CERC.LA .
The NCP, at S 300.430 (a) (iii) (D) states that "the use of
institutional controls shall not substitute for active response
measures (e.g., restoration of ground waters to their beneficial
uses) as the sole remedy unless such active measures are determined
not to be practicable, based on the balancing of tradeoffs among
alternatives."
I.
Risk Assessment
COMMENT: One commenter asked whether the groundwater contamination
was related to the high rate of cancer in the vicinity of Harvard
and Yale Streets.
EPA RESPONSE: EPA lacks sufficient data t.o respond to this'
comment. However, the commenters concerns will be referred to the
Agency for Toxic Substances and Disease Registry.
..
COMMENT: One commenter states that the risk assessment "grossly"
exaggerates the real risk due to volatile organics because an EPA
guidance document entitled "Risk Assessment Guidance for Superfund,
Volume I: Human Health Evaluation Manual, Supplemental Guidance,
, standard Default Exposure Factors,'" OSWER Directive 9285.6-03
(Interim.Final March 1991) was not correctly followed.
EPA RESPONSE: The risk assessment performed for the Supplemental
MOM RI, completed in February 1991, followed the guidance in effect
for Region I at that time. Consistent with this guidance, it is
acknowledged that the resulting risk estimates are designed to
overstate the actual (real) risk estimates. This approach is
adopted by EPA to account for uncertainty inherent in the risk
assessment process and the fact that the actual (real) risk can
never be known. While it is true. that the risk estimates would be
modified slightly were the OSWER Directive 9285.6-03 followed, the
Directive was not issued (March 25,1991) until after the Risk
Assessment had been finalized (February, 1991). EPA determined
that a new risk assessment was not warranted after consideration of
these two documents.
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COMMENT: One commenter states that the Supplemental MOM RI risk
assessment does not consider that natural attenuation,
biodegradation or dilution is occurring. Use of this approach
would decrease the risk by a factor of 13 to 21, over an order of
magnitude. Similar. results would be obtained for all aspects of
the risk analysis in Section 6 of the Supplemental MOM RI. The
commenter further states that the Supplemental Risk Assessment
Guidance. notes that the exposure duration should be 30 years for
carcinogens, while in the Supplemental MOM RI, a duration of 70
years is used, and that the Guidance cites an exposure frequency of
350 days as opposed to the frequency of 365 days used in the
Supplemental MOM RI. The commenter states that the combined
reduction in risk, after conforming the analysis to guidance, will
be by a factor of 31 to 51 times, the higher values being based on
observed behavior.
EPA RESPONSE: It is not EPA' s intention to ignore natural
attenuation, biodegradation, or dilution in groundwater. However,
given that the baseline risk assessment is to characterize both
present and future potential exposure and resulting risk, and that
the groundwater under the Groveland Site has been classified by the
Commonwealth of Massachusetts.as Class I (suitable lor drinking),
it is consistent to assume that someone could consume groundwater
from the contaminated area. Thus natural attenuation,
biodegradation, or dilution does not preclude someone from
consuming groundwater from within the contaminated plume at some
point in the future.
With respect to the potential concentrations of contaminants that
could be expected to arise in the groundwater in the future, it is
EPA's bel ief that given the high degree of uncertainty in any
predictions (due to an unknown mass of contamination and complex
chemical and physical properties of the chemicals and the
environment), it is reasonable to assume for the purpose of risk
evaluation, that those concentrations remain constant over time.
Consequently, natural attenuation were not factored into the risk
assessment, but were recognized in the discussion of uncertainty.
EPA believes the appropriate place to evaluate natural attenuation,
biodegradation, or dilution at the Groveland Site is not in the
risk assessment, but rather in the evaluation of remedial
alternatives in the Feasibility Study. From EPA's view of the no
action alternative, it was concluded that it would take
approximately 50 years to reach the interim groundwater cleanup
goals listed in this ROD which EPA deemed to be unacceptable.
With respect to the comment regarding exposure assumptions
contained in the "Human Health Evaluation Manual, Supplemental Risk
Assessment Guidance: Standard Default Exposure Factors" of March
25, 1991, and the relevance of that guidance to the Supplemental
MOM RI finalized before this date (February, 1991), please refer to
the comments and responses above.
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L)
C>
COMMENT: One commenter states that regarding the baseline risk
assessment, data from 1984 to 1990 indicate that natural
attenuation is occurring at an even faster rate and that based on
observed data, the decay rate is 0.30/year for a cleanup time of 21
years.
EPA RESPONSE: These comments imply that the potential decay of TCE
over time should have been factored into the baseline risk
assessment. However, it is standard procedure in most baseline
risk assessments to calculate risks based on current contaminant
levels assuming no significant remediation at a Site. It should be
noted that the potential change in contaminant concentrations over
time and the affect of such a change on the risk assessment was
briefly discussed in the uncertainty section of the baseline risk
assessment. More importantly, the TCE contamination in the
groundwater of certain areas downgradient" of the Groveland site is
grossly in excess of the current Safe Drinking Water Act ("SDWA")
MCL for TCE. The TCE concentration in the groundwater will remain
at concentrations in excess of the MCL or the 1 x 10*6 cancer risk
level for many years, even using the optimistic decay rates
suggested in the commenter's statements. The consideration of the
natural decay of TCE over time "does not alter the p~imary
conclusion of the Supplemental MOM RI.
COMMENT: One conunenter states that the failure of the supplemental
MOM FS to use time-averaged contaminant concentrations in intake
calculations has resulted in gross overstatement of excess cancer
risks associated with volatile organic contamination in the
management of migration study area.
EPA RESPONSE: One commenter implies that the guidance requires the
use of a time-averaged contaminant concentration in risk
calculations for the baseline risk assessment. This is incorrect.
In fact, page 1 of the Supplemental Guidance states that:
Separate guidance on calculating contaminant concentrations is
currently being developed in response to a number of inquiries
from both inside and outside the Agency. The best method for
calculating the reasonable maximum exposure (RME)
concentration for different.. media has been subject to a
variety of interpretations and is considered an important area
where further guidance is needed. .
Page 29 of the EPA Region I guidance document states that "Average
and maximum chemical concentrations (exposure point concentrations)
should be developed for each exposure pathway based on Site
sampling data or on modeling results. II The baseline risk
assessment presents risks based on average and maximum chemical
concentrations, as required by the Region I guidance document.
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J.
Miscell.neous
COMMENT: One commenter suggested that the cleanup acti vi ty be
undertaken using EPA's removal authority because this approach
would allow an immediate response to the spreading plume, as
opposed to waiting forEPA to identify and negotiate with PRPs or
obtain authority to use money from the Superfund Trust Fund.
EPA RESPONSE: EPA's removal authority is used when a determination
is made that it is necessary to minimize or mitigate a release in
the short term. In this case, EPA has determined that it is more
appropriate to address the contaminated groundwater plume extending
from the Valley property on a permanent, long-term basis,
consistent with the definition of a remedial action.
COMMENT: One commenter states that well cluster DEQE-1 should have
been sampled instead of only DEQE 1-1.
EPA RESPONSE: Sampling of this cluster requires a special sampling
apparatus which was not r~adily available. EPA feels that there
were enough other wells available for sampling in the area for the
purpose of the investigation, and sampling this well was not
warranted.
COMMENTS RECEIVEP PRIOR TO THE COMMENT PERIOD.
Other issues concerning the Groveland Wells Nos. 1 and 2 Superfund
site that were raised prior to the public comment period are
summarized as follows:
A.
Status of CleanuD at Other Contamination Sources
COMMENT 1: A citizen wanted to know what is happening to make A.
W. Chesterton and the Haverhill Landfill address the contamination
within their property boundaries. .
EPA RESPONSE: Contamination at Chesterton appears to be confined
to its own property. It will be required to cleanup under another
law, the Resource Conservation. and Recovery Act ("RCRA"), through
a corrective action permit. At the Haverhill Landfill, EPA will
address this site as a separate Superfund action.
COMMENT 2: A citizen wanted to know what Valley Manufactured
Products Company is doing to cleanup its site and how long will it
take.
EPA RESPONSE: Valley was issued an Administrative Order in
December 1990, effective February 4, 1991, to remediate the
unsaturated soil using a vapor extraction system. In the saturated
zone, Valley will extract groundwater, remove solvents with an air
stripper, then recirculate the treated water into the ground to
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u
~,
assist in flushing remaining contaminants. They will also install
a.granular activated carbon system downgradient of their property.
The Order requires that most of the contamination be removed within
5 years and the groundwater must meet drinking water standards in
10 years.
Valley agreed to comply with this Order, so it is expected that on-
site remediation should begin in the near future.
COMMENT 3: A resident wanted to know if the use of granular
activated carbon will simply transfer pollution from one medium to
another.
EPA RESPONSE: The carbon unit will adsorb the contaminants. After
the carbon is fully exhausted, it typically will be disposed of off
site at a special facility. .
COMMENT 4:
of the. plume?
EPA RESPONSE: Only 3 or 4 wells were sampled in the area of the
Haverhill Landfill. Some metals and semi-volatiles were found but
information gathered to date does not appear to indicate that the
Landfill is a major TCE contaminant source.
Is the Haverhill Landfill impacting the northern end
COMMENT 5: If the Haverhill Landfill isn't cleaned up, is it
likely that the area around station No.2 will be cleaned up?
EPA RESPONSE: Most of the contamination around station No.2 is
different from the type of contamination found at the Landfill.
B.
Concerns about the Preferred Alternative
COMMENT 1: will the extraction wells create anew hydrogeological
influence such that they will draw contaminated groundwater from
the .Haverhill Landfill toward the existing plume?
EPA RESPONSE: That is an interesting question. You may want to
make it part of the official record through either oral or written
comment during the public comment period.
COMMENT 2:
determined?
How will the locations of the .extraction wells be
will EPA take anyone's land by eminent domain?
EPA RESPONSE: The groundwater flow model used in the Supplemental
MOM FS determined preliminarily that six wells would be needed
based on capture zone definitions. It also defined conceptual
locations for the wells. Permission to drill these wells will be
obtained from land owners through access agreements similar to the
procedure used to drill wells during the Remedial Investigation.
. COMMENT 3:
Did
EPA
evaluate
focusing
its
extraction
well
-------
efforts in the plume where the contamination is highest, down near
Mill Pond?
EPA RESPONSE: The groundwater flow model suggested that one of the
extraction wells would be located near the Mill Pond area and that
it would have the highest pumping rate of the extraction wells.
Since the plume is moving, EPA also has to address its outlying
sections.
COMMENT 4: About how large an area would the proposed treatment
plant take up? How will EPA deal with aesthetics, noise, security,
property values and ownership issues?
EPA RESPONSE: EPA anticipates that the physical plant may require
about an acre. Underground piping would bring the extracted water
to the plant. EPA doesn't have specifics yet but a likely location
for the plant is just east of station No.2, land that is owned by
the Town. A similar plant at a site in Maine was about the size of
a barn, is surrounded by a cyclone fence and no odor or noise
issues have been raised~ The Commonwealth of Massachusetts has
found that cleaning up groundwater has increased-property values.
COMMENT 5: will EPA build a backup treatment system
something goes wrong?
in case
EPA RESPONSE: No. operation and maintenance costs are built into
the cost estimates. If something serious should go wrong, however,
the system would be shut down for repair.
C.
Drinkina Water Oualitv - the Public SupplY
COMMENT 1: Several residents expressed concern about the safety of
the Town's drinking water supply and asked what is a 'safe' level
for TCE.
EPA RESPONSE: Groveland's water supply is safe. The water is
tested quarterly. Station No.3 is in another aquifer and station
No.1, which has a backup water treatment system, is not showing
any contamination. The Safe Drinking Water Act maximum contaminant
level for TCE is 5 parts per billion ("ppb").
COMMENT 2: One commenter stated that instead of spending all this
money, why not just dig another water supply well.
EPA RESPONSE: The commenter has stated that other potential well
locations had been studied throughout the Town but none have proven
suitable. There is, however, cur~ently a safe, adequate supply of
potable water.
COMMENT 3: If EPA chooses Alternative 6, is it their intention
to let station No.2 come back in service at the end of 30 years?
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EPA RESPONSE: The purpose of the remediation is not to restore
Station No.2 to service. Its goal is to cleanup the contaminated
groundwater. The Town itself, however, may chose to bring Station
No.2 back into service in the future.
COMMENT 4: Shouldn't Groveland have as its highest priority
protecting Station No.1?
EPA RESPONSE: The Well Committee decided to decrease the pumping
rate at Station No.1 to assure the plume would not be drawn to it.
D.
Drinkina Water Oualitv - Private Wells.
COMMENT 1: Several residents who have property located over
the.plume asked what EPA would do to help them. .
EPA RESPONSE: Questionnaires were sent to 19 property owners whose
land overlies the contaminated plume to determine present and past
private well usage. If wells exist beyond those 19 properties, EPA
wants to know about them. Only one respondent indicated the
existence of a private well and that the water from the well was
not being consumed. EPA subsequently sampled the well and
determined that the TCE level was below drinking water standards.
E.
Lona-Term Public Health Implications
COMMENT 1: A resident expressed concern about the long-term
effects of having consumed public water prior to 1979, when the two
wells were closed becaus~ of contamination. He stated that
children born in 1979 (including one of his own) had an unusually
high incidence of learning disabilities.
EPA RESPONSE: There is no known relationship between ingestion of
TCE-contaminated water and learning disabilities.
COMMENT 2: This same resident related several cases of cancer and
cancer-related deaths for people living at both ends of Center
Street. He implied a cause/effect relationship between drinking
contaminated water over the years and their deaths.
EPA RESPONSE: Monitoring wells near Chesterton were sampled; no
excessive levels were found. Based on existing field .data, the
plume's source is downgradient of Center Street.
F.
Surface Water Contamination
COMMENT 1: One citizen wanted to know whether it was safe to
wade in the brooks and Creek.
EPA RESPONSE:
activity.
There should be no adverse impact expected from this
-------
COMMENT 2: A resident asked if EPA could determine how long it
would take for the TCE plume to dissipate by measuring how quickly
it volatilizes through contact with surface water at Johnson Creek.
EPA RESPONSE: The only surface water location found to have high
volatile organic compound levels was at the Mill Pond treatment
system discharge point. In addition, a large portion of the plume
is well below the level of Johnson Creek. The natural dissipation
rate of the plume (or the time needed for contaminant
concentrations to fall below MCLs throughout the plume) is not just
a function of the rate that contaminants volatilize upon entering
Johnson Creek. Insufficient data exist to succeed in that type of
a study.
G.
- Liabilitv
COMMENT 1: Several citizens wanted to know who is going to pay
for the cleanup.
EPA RESPONSE: EPA has completed its search for responsible
parties. They may be sent a 'special notice' inviting them to
undertake the cleanup activities and reimburse the government for
past cleanup costs. .
COMMENT 2: The $8.3 million cost EPA is proposing is high,
particularly when the Town of Groveland has a potable water supply.
Why not let the groundwater clean itself up? .Who is going to pay
for this remedy? The Town of Groveland and its residents cannot
afford to foot the bill. Has EPA looked at a more economical and
practical alternative that features a low-maintenance option with
institutional controls?
EPA RESPONSE: Once the ROD is signed, EPA will begin negotiations
with those responsible for the contamination. . If that fails, EPA
has two choices: it can institute a suit against those responsible
or it can use money from the trust fund to pay for the cleanup.
EPAmust also include in its selection process protection of the
environment (not just the public) which is why natural attenuation
is not a viable option. Natural attenuation would take over 50
years. .
COMMENT 3: The problems at this site have been known for over 10
years. Can't Groveland be placed at the front of the line for Fund
money?
EPA RESPONSE: EPA will look to negotiations and enforcement before
seeking money from the Trust Fund since Region I must compete with
sites across the country to make a site a 'Fund-lead' site.
H.
Timinq of the CleanUD Schedule
. COMMENT 1:
Once the ROD is signed, when does actual work begin?
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EPA RESPONSE: EPA expects to complete negotiations with the PRPs
and begin design work in fiscal year 1992. So the earliest design
could start is 1 1/2 years from today and actual work could start
1 1/2 years after that.
1.
The Plume
COMMENT 1~ Where will the plume be by the time the actual cleanup
work begins?
EPA RESPONSE:
Natural groundwater flow is about one foot per day.
COMMENT 2: Is the Mill Pond system not currently capturing the
entire plume?
EPA RESPONSE:
No, it is not.
COMMENT 3: Won't the concentrated area of the plume spread out as
it travels closer to the Merrimack River?
EPA RESPONSE: The concentrated area is expected
downgradient and lengthen and spread out as it moves.
to
move
COMMENT 4: Could water from the Merrimack River be used to
dilute the plume such that its concentrations fall below 5 ppm?
EPA RESPONSE:
Station No.1.
Reinjection could force the plume to move toward
COMMENT 5:
What happened to the pollution at station No.1?
EPA RESPONSE: The pump test showed that the most likely source of
contamination was the plume coming from the Mill Pond area. Since
1979, among other things, hydraulic conditions have changed,
thereby altering the plume's configuration.
COMMENT 6:
Is 75 acres the area of the plume itself?
EPA RESPONSE:
site.
Yes, and 850 acres is the area of the entire NPL
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ATTACHMENT A
COMMUNITY RELATIONS ACTIVITIES CONDUCTED AT THE GROVELAND
WELLS NOS. 1 AND 2 SUPERFUND SITE IN GROVELAND, MASSACHUSETTS
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ATTACHMENT A
COMMUNITY RELATIONS ACTIVITIES AT THE
GROVELAND WELLS NOS. 1 AND 2 SUPERFUND SITE
1982
Groveland Wells Nos. 1 and 2 site listed on
the National Priorities List.
1983
EPA issued a community Relations Plan.
EPA held a public meeting to discuss EPA 's
plans under superfund.
January 1983
July-10, 1985
EPA issued a press release announcing an
initial remedial. measure (IIIRM") that would
relieve the water emergency. .
september 30, 1988
EPA announced that the source control Record
of Decision was available to the public.
November 22, 1989
EPA issued a press release that the
supplemental (RIfFS) would commence.. Its focus
was on groundwater contamination on the Mill
Pond Area.
March 1991
EPA issued a Fact Sheet on the RI results and
the Risk Assessment.
March 22, 1991
EPA issued a press
relea~e on April 3
the supplemental
Assessment.
release announcing a press
to discuss the results of
MOM RI and the Risk
July. 1991
EPA conducted a town meeting at the Groveland
Town Hall to discuss the results of the RI.
EPA issued the Proposed Plan.
April 3, 1991
July 1, 1991
EPA published a notice announcing the public
meeting and public hearing on the FS and the
Proposed Plan and the availability of the
Administrative Record.
July 9, 1991
EPA issued a press release
release of the Proposed Plan.
EPA held a Public Meeting At the Groveland
Town Hall to explain the FS and the Proposed
Plan and to answer questions.
announcing
the
July 2, 1991
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ATTACBXENT B
TRANSCRIPT. OF THE JULY 31, 1991
INFORMAL PUBLIC HEARING
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<"
\.;
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ENVIRONMENTAL
PROTECTION AGENCY
SUPERFUND
PROGRAM
* * * * * * * * * * * * * * * * * * * * * * * * * * * * * * *
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IN
RE:
GROVELAND WELLS NOS. 1 AND
GROVELAND, MASSACHUSETTS
2
* * * * . * * * * * . * * * * * * * * * * * * * * * * * * * *
BEFORE:
JAY NAPARSTEK, Chairman,
Mass Department of Environmental
Protection, Branch Chief for Bureau
of Waste .Site Management;
CHARLES TUTTLE, Geologist
Mass Department of Environmental
Protection;
ROBERT J. LEGER, Remedial Project
Manager. U.S. Environmental
Protection Agency
"
.,
.1
Groveland Town Hall
183 Main Street
Groveland, Massachusett.~
Wednesday, July 31, 1991
7 : 3 3 p. m .
Marybeth
Coldwell
RPR
M.A.
TOROSIAN
ASSOCIATES,
I N C .
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3
4
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8
9
1 0
1 1
1 2
1 3
1 4
1 5
1 6.
1 7
1 8
1 9
20
2 1
22
2 3
2 4
P
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C
E
E D
I
N
G
S
MR.
NAPARSTEK:
Okay.
I
think
we
will
get
started
now
i f
that
i s
okay.
Thank
you
all
for
coming
tonight.
My name
i s
Jay Naparstek.
I'm a
Branch
Chief
with. the
Bureau
of
Waste
Site
Cleanup
for
the
Mass.
Department
of
Environmental
Protection
and
I ' I I
be
serving as
a
hearing
officer
for
tonight's
hearing
on
the
proposed
plan
for
groundwater
contamination
at
the
Gr,:,veland
i'! ell s
Si t e .
Let
me
introduce
the
other
members
c f
the
panel
here
tonight
and
explain
the
agenda
and
the
format
for
tonight's
hearing.
On
my
right
here
i s
Robert
Leger
and
he
i s
the
Remedial
Project
Manager
with
E . P . A .
On
my
1 eft
is
Charles
Tuttle
and
he
i s
the
Project
Manager
f :: r
the
r'l ass.
Department
c f
Environmental
Protection.
Also
here
tonight
are
Diane
Ready,
Public
Relations
Coordinator,
and
Lisa
West
M.A.
TOROSIAN
&
ASSOCIATES,
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1 1
1 2
1 3
1 4
1 5
1 6
1 7
1 8
1 9
20
"
"
2 1
2 2
2 3
2 4
also working with Diane in the Public
Relations Of f ice.
Now, for those of you who are
not familiar with the Groveland Wells
Site 0 r with E.P.A.'s approach to the
cleanup, you should know that we have
divided the remediation into two phases
which
are
also
known
as
Operable
Units
1
and
~
.. .
The
first
phase
addresses
the
contaminated
soils
and
g r.o u n d w ate r
that
are
on. 0 r
adjacent
to
the
Valley
Manufactured
Products
. .
on washington
Street.
The
remedy
for
this
phase
i s
presently being
designed
by
the
consultant
for
Valley under
the
terms
of
an Administrative
Order
with
the
E. P. A.
The
second
phase
of
the
project
addresses
the
contaminated
groundwatel
in
the
aquifer
north
of
the
Valley
Property which
i s
the
subject
of
tonight's
hearing.
:.; 0 w ,
back
on
,"!'Jly
9th
the
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1 6
1 7
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19
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20
21
22
2 3
2 4
E.P.A.
held
a
public
meeting
here
to
present
the
results
of
the
Feasibility
Study which
examined
alternative
ways
for
the
cleaning up
of
the
groundwater
and
then we
presented
E.P.A.'S
preferred approach, followed by a
question and answer period.
Now, after I conclude these
introductory
remarks,
Bob
Leger
from
the
E . P . A .
will
just
briefly
recap
the
proposed
plan
and
then
we
will
begin'
the
actual
hearing.
The
purpose
of
tonight's
hearing
i s
to
allow
the
puolic
to
comment
on
the
E . P . A. ' S
proposed
plan
for
cleaning
up
the
groundwater
under
the
second
operable
unit.
We
will
be
transcribing
the
meeting
and
later
provide
a
printed
transcript
which will
become
part
the
administrative
record
which
i s
used
by
E. P . A.
to
make
a
fin (1 1
remedy
decision.
In
order
to
ensure
accuracy
in
the
record,
I
ask
that
anyone
..,.,h 0 '
!1 . A .
TOROSIAN
&
ASSCCIATES,
-------
'--'
-'
\j
j:
"
"
1 !'
"
2 \\
3
II
4
5 "
;i
6 n
!I
i'
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8
9
1 0
1 1
1 2
1 3
1 4
1 5
1 6
1 7
18
1 9
20
21
22
2 3
2 4
wishes
to
make
a
statement,
first
fill
out
one
of
the
index
cards
that
are
provided
at
the
entrance
with
your
name,
your
address
and
your
affiliation,
i f
you
have
any.
I'll
then
call
on
you
in
the. order
in
which
the
cards
are
submitted.
I
must
reserve
the
right
to
limit
the
time
available
to
any
one
speaker
to
ten
minutes
to
ensure
that
everybody
who
wishes
to
make
a
statement
gets
a
chance.
You
should
understand
that
E . P . A.
will
not
be
responding
to
any
questions
tonight.
HOv.:ever,
you
may
ask
questions
as
part
of
your
statement
and
a
response
will
be
included
in
the
Responsiveness
Summary
that
E . P . A .
"'. ill
prepare
after
the
public
comment
period
closes.
The
Responsiveness
Summary
will
then
.N i 11
be
included
in
the
Record
of
Decision
...; h i c h . the
E . P . A .
plans
to
issue
later
this
f all .
In
addition
t :)
;.! . .~ .
TaROS 1.:":-;
"
ASS:'.:IATES,
-------
~
1 :i
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2 Ii
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ii
3
4
5 'I
::
II
6 ! ~
II
7
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8
9
1,0
1 1
12
1 3
1 4
1 5
1 6
.. 1 7
1 8
1 9
20
21
22
2 3
.., .
.. ...
tonight's
hearing,
you may
also
sucmlt
written
comments
for
E.P.A.'s
consideration.
E. P. A.
recently
received
two
requests
to
extend
the
public
comment
period
and we
will,
therefore,
be
extending
the
comment
period
to
September
9 ,
1991 .
The
written
comments
should
be
written
to
the
E . P . A .
contact
in
the
proposed
plan
which
you
could
pick
up
at
the
front
desk
and must
be
postmarked
no
later
than
September
9 ,
1991 .
.C 0 pie, s
of
the
proposed
plan
are
available
at
the
reg i s t r a t,i 0 n
desk
jus t
as
you
carne
in.
And
finally,
let
me
rem,ind
you
that
copies
of
the
administrative
record
are
located
at
the
Langley-
Adams
Library here
in
Groveland
as
well
as
the
E . P . A .
offices
at
90
Canal
Street
in
Boston
and
you
may
review
any
documents
contained
i n
the
administrative
record
at
these
locations
during
the
normal
business
t-i . i-. .
IOROSIA;--;
&
ASSOCIATES,
-------
f
~
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5 :i
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1 1
12
1 3
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1 4
1 5
1 6
1 7
1 8
19
20
21
22
2 3
2 4
hours.
Before
I
begin
the
actual
hearing,
are
there
any
questions
either
on
the
hearing
format
or
on
the
public
participation
process
that you would
like
clarified?
Yes ,
Karl.
MR.
LeMUTH:
'Ju s t
one
question.
I
assume
that
you've
gotten
the
well
pollution" committee
request
for
an
extension.
MR.
NAPARSTEK:
I
believe
that
we
have.
MR.
LeMUTH:
Could
I
ask
who
the
other
person ",,'as
that
asked
for
the
extension?
MR.
NAPARSTEK:
I
think
that
i s
part
of
the
publi::
record.
That
..., as
Martin
Pentz 'from Nutter,
McClennan
&
F ish .
Okay.
Anybody
else?
Okay.
Bob
Leger
then
i s
jus t
going
to
give
a
brief
recap
of
the
proposed
plan
for
the
remediaticn
of
.. .
1'1.. n.
-- ,....., - r. - - "'. ...
.. ...... r~ v ;:, ~ ...-... 1'.
u
';SS:::.;IE:S,
-------
8
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3
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4 ;i
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7 II
II
8 .
9
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12
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1 4
1 5
1 6
1 7
18
19
:j
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20
21
22
2 3
:; .;
groundwater un::er Oper.-:le Unit 2.
MR. LEGER: Thanks, Jay. My
name i s Bob Leger, the Remedial Project
Manager.
I'm with
the
Environmental
Protection Agency
in Boston
and
I ' I I
be
going
over
very
briefly
tonight
some
of
the
material
that
we went
over
in
the
beginning
of
July
when we
presented
the
proposed
plan
to
you
for
your
consideration.
My
comments
will
be
very
brief
to
give
you
people
an
opportunity
to
present
your
opinion
and
your
thoughts
.a nd
your
:onsiderations
on
our
propos,=d
plan
to
clean
up
the
pollution
i n
the
groundwater
in
Groveland.
Very
quickly,
Grovel-and
Wells
No.
I
and
"')
""
Superfund
Site
consists
of
approximately
850
acres
located mostly
in
the
town
of
Groveland,
bounded
by
School
Street,
Salem
Street,
Washington
Street,
i1 a i n
Street
and
the
H a v e r h ill
1 a.n d f ill.
Get
your
bearings.
Station
No.
,
...
(indicating) ,
St~.tion
No.
"1
""
.. .
,c.. n.
:- 0 R () S I ;.. :~
0.
ASSOC~ATES,
-------
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1 ;1
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1 1
12
1 3
1 4
1 5
1 6
1 7
1 8
1 9
20
"
21 "
22
2 3
2 4
9
(indicating) ,
valley Manufacturing'
Company
and A.W.
Chesterton
Company
(indicating) .
Based
investigations
that
on
were
conducted
several
here
over
years
at
the
Site,
we've
identifled
three
sources
of
pollution.
Let me
back
Back'in
1979,
up.
the
town's
wells
became
were
discovered
be
polluted with
a
to
solvent
called
Trichloroethene.
At
the
time
Station
1
and
Station
"1
...
provided
entire
drinking
water
supply
of
the
town.
And
when
the
contc;.mination
in
the
wells
discovered,
both
towr!
were
wells
shut
down
and
the
went
town
were
into
emergency water
rationing
and
subse~ue!1t.ly drilled another 'we 11 right
up here (indicating) Station No. 3
which provided drinking w'a t e r for the
town.
subsequently,
Station
1
was
rehabilitated
result
of
E.P.A.
as
a
funding
the
has
a
sa f e
so
now
town
drinking
supply
from
the
water
',,' ate r
... .
..... n.
~OROSIn~
.;SSc:~..;"!'ES ,
T .... ,...
.. .Iot \.... ..
-------
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1 3
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1 5
1 6
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20
21
22
., 3
..
2 4
being
supplied
from Station
3
and
Station'l.
Station
2
has
remained
closed
since
1979 .
The
E.P.A.
through
funding
came
and
started
investigating
into
the
contamination
of
the
property
and
subsequently
identified
three
major
sources
of
pollution
on
this
'S i t e ;
the
Chesterton
Company,
the
Valley
Manufactured
Products
Company
and
the
Haverhill
Landfill.
The
contamination
of
the
Chesterton
property we
discovered
i s
primarily
confined
to
the
property
boundary.
The
contamination
of
the
Chesterton
property
does
not
appear
to
be
related
in
ar1y way
to
the
contamination
that
'N as
discovered
in
the
Stations
1
and
2 .
Haverhill
landfill
contamination
Let
me
back
up
a
bit.
The
Chestertc:"l
contumination
i s
being
dealt
with
under
the
Resource
Conservation
:.1 . ;.. .
:8?CS:i:;"~
&.
;, 5 5 'J C :: J... T E S ,
-------
\)
1
2
3
4
5
6
7
8
9
1 0
1 1
1 2
1 3
1 4
1 5
1 6
1 7
1 8
1 9
20
2 1
22
2 3
2 4
~ ,
"
II
"
!!
ij
and Recovery Act
(RCRA) .
That
contamination
in
the
Chesterton
property
i s
being
handled
under
another
q
law.
.,
of
the
Haverhill
Contamination
.1
I'
t!
handled under
Landfill
being
i s
a
il
j!
I'
- 11
I'
;j
II
,.
basically what
law
superfund
we
are
so
tonight,
we
are
not
about
talking
talking
about
the
contamination
of
the
Chesterton
the
Haverhill.
are
We
o r
talking
about
the
contamination
emanating
from
the
Valley
Manufactured
Products.
Contamination
from
the
Valley
Manufactured
Products
primarily
Company
consists
of
Trichloroethene
conti\mination,
what
call
Volatile
we
a
Organic
Compound,
solvent
that
was .used
by valley
Manufactured
Products
Company.
As
result
of
spills
and
a
"
contamination
leaks,
into
the
i t
Slot
groundwater
and
resulted
groundwater
in
contamination.
Basically
the
9roundwater
f 1 0...' s
M.A.
':'ORCS:;"N
;'.SSQCIATES,
IN C .
-------
l. L
,
1 11
:1
2 II
II
i!
3
"
4 :1
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5 11
II
i!
6 !'
7 II
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8
9
1 0
i!
11
,
12
1 3
14
15
16'
1 7
1 8
1 9
20 :j
:!
21
22
2 3
2 4
from
south
to
the
north.
And
again
here
(indicating)
i s
the
Center
Street
and
Merrimack
i s
up
here
(indicating) .
We
discovered
a
groundwater
contamination,
what
we
call
contaminant
plume.
What
you
see
he"re
i s
concentrations
of
Trichloroethene
of
above
drinking-water
standards,
above
five
parts
per
billion
and
this
i s
what
the
groundwater
within
this
a r e'a
here
(indicating)
outlined
in
the
black
i s
contaminated
with
Trichloroethene
above
safe-drinking water
standards
for
that
contamination.
Basically
i t
i s
about,
the
contamination
i s
primarily
7 5
acres
surface
area,
about
six
billions
gallons
of
water,
about
6 , 000
pounds
of
trichloroethene
that
needs
to
be
cleaned
up
to
drinking water
standards.
When
we
were
here
in
the
beginning of J u l.y, we basically put
forth to you '.-1h a t aur objectives w"=!re.
Basically to clean up the groundwater
II . ..-:0. .
10ROS:;"0:
'"
ASSOCIATES.
-------
: 3
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-,
Ii
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.;
2 ii
.!
3
4 !'
..
5
6 ;j
,.
II
7 II
. II
8 it
9
1 0
1 1
1 2
1 3
1 4
1 5
1 6
1 7
18
19
2 0
21
22
2 3
2 4
so
that
it
can
be
i t
could
be
used
for
drinking
in
the
future
time.
As
I
said
right
now
there
i s
no
present
threat
to
groundwater
because
the
ground
the
groundwater
you
are
getting
right
now
i s
from Stations
1
and
2
and
that
i s
perfectly
safe.
The
E . P . A. ' S
task
i s
to
clean
up the contamination to the groundwater
so that possible future use i f someone
wanted to d r ill a well i n that area
that
they
could
1 n
the
future.
So,
basically
our
objective
i s
to
clean
up
the
grcund\o,'at'er
so
that
i t
~an
be
safely
drank.
MR.
FALCONE:
Stations
are
Sources
1
and
3 .
MR.
LEGER:
I'm
sorry.
l'i R .
FALCONE:
You
said
Stations
1
and
'"
... .
They are stations 1 and 3
;'i R. :': A P A F: S T E K : That' s 1 and ~
;,
are
the
statiC!r.s,
',,' a.t e r
drinking
stations.
MR.
:EGE?,:
Yes,
:hat's
., .
J,'J,. r..
-:;:- C R 0 SIn :.:
0.
.:"550ClATE:S,
-------
1 4
.,
rl
.1
1 iI
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2 !I
I,
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3
ii
4 II
II
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6 i'
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8
9
1 0
1 1
12
1 3
1 4
1 5
1 6
1 7
1 8
19
20
:i
21
22
2 3
2 4
correct.
We
looked
at
several
alternatives to clean up the
contaminant plume that I showed you
earlier and I' 1 1 put that picture back
up again so that you could take a look
at
it.
We
looked
at
several
alternatives
on
how to .clean
that
up.
When we
look 'at
the
alternative,
we
have
to
the
law
says
that we have to evaluate each
alternative according to the n i n e.
criteria. And we look at all
any
alternative
that
we
look
at,
we
balance
against
these
nine
criteria.
The
No.
1
and
..,
...
obviously
the
overall
protection
of
human. health
and
the
environment
in
compliance
with
ARARs.
The
compliance
with
the
environmentai
laws
and
regulations
and
that's
what ARARs
are.
So,
i f
any
alternative
passes
muster
for
the
fir s t
two,
then we
look
at
how
i t
passes
muster 'for
the
last
remaining
seven
c r i t e ria .
t.. ~
,ti . .--. .
:OROSIAN
,:;.
ASSOCIATES,
-------
G
\!
1
2
3
4
5
6
7
8
9
1 0
1 1
1 2
1 3
1 4
1 5
1 6
1 7
1 8
19
20
2 1
22
2 3
24'
;1
1:
!:
II
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II
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ii
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11
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i!
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"
:. s
We
discussed
this
criteria
early
in
July
I'm not
going
to
go
so
over
them
again.
looked
at
We
basically
looked
lot
of
at
a
-- we
different
things
clean up
the
to
groundwater,
lot
of
technology,
lot
a
a
of
differential
techniques
to
best
clean up
the
water
here
at
Groveland.
I t
down
basically
six
carne
to
major
alternatives we
considere'd
to
cleaning
groundwater.
The
first
i s
up
an
alternative
which we
mandated
by
are
law
consider
and
that
i s
not
do
to
to
anything.
No
action.
All
the
other
criteria
based
against
that.
are
So,
the
first
criteria
i s
not
to
do
anything.
what would
happen?
Well, obviously the groundwater would
never get cleaned up. Wouldn't be
sa fey to drink for a long long time.
But,
that
i s
there
action
1 S
no
alternative
i s '0 n e
that
required
we
are
to
look
by
law.
...~ e
requi red
.. f"\
C. .
are
at
balance
each
alternative
and
i t
compare
r.l . .r.. .
TOROS:;:.;:\
ASSCC:A:ES,
INC.
-------
:. 6
.
:!
1:
1 Ii
,i
'I
I.
II
2 H
"
II
I:
!;
3
"
4 !I
II
5 I
6 I
d
"
7
8
9
1 0
1 1
12
13
14
1 5
1 6
1 7
1 8
19
2 0
2 1
22
2 3
24
against
no
action.
The
second
alternative
is
basically what
we
call
institutional
controls.
Prevent
people
through
deed
restrictions
to
prevent
them
from
putting
a
well
in
the
contaminated
groundwater
area.
Now,
that
wouldn't
clean up the groundwater but it would
provide some protection to the public.
They wouldn't be able to drill a well
there.
And
the
remaining
four
alternatives
basically
consider
taking
the
groundwater
out
and
treating
i t
by
some
way .a n d
putting
the
water
back
in.
Taking
the ....:ater
out
and
treating
i t
t Q
drinking
water
standards.
Once
you
take
it
out,
you
put
i t
through
some
sort
of
treatment
so
that
when
you
put
it
back
in
i t
i s
now
sa f e. to
drink.
We
looked
at
four
different
alternatives
to
pump
the
water
out.
No.
1
was
to
pump
i t
out
and
to
send
i t
to
the
Haverhill
publicly
owne:i
., .
..'. . ..""\ .
:- eRe S : :; :\
&
;'SS:::ATES,
-------
\:
1
i
ii
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II
:i
removal
treatment
2
we
have
3
4
Ii
"
standard
5
i:
.,
;j
Ii
:!
ii
II
11
- Ii
alternative
gave
it
6
Haverhill
7
8
"
:!
;\
!:
9
alternative
1 0
treat
1 1
i t
using
1 2
familiar
1 3
Mill
Pond,
1 4
through
1 5
from
the
16
1 7
take
the
1 8
through
H
19
Activated
'i
20
used
now
::
,
21
have
you
.'
22
filtered
L
Granular
23
2 4
out
a'l 1
r.1 . .; .
plant.
to
do
some
because
for
metals
to
the
treatment
was
The
fourth,
was
i t
onsite.
, -
- I
When we
take
it
out,
sort
of
metals
we
have
the
to meet
in water
before
we
Haverhill
the
to
plant.
The
fourth
to
take. it
out.
fifth
and
sixth
to
take
i t
and
out
Take
i t
and
treat
out
I f
air
stripping.
with
the
basically
the
.....ater
water
The
fifth
groundwater
a
f i 1 t e r
Carbon
at
Station
you
a r.e
air
stripper
up
at
air
forced
i s
and
contaminants
go
to
the
air.
alternative
was
to
out
and
i t
put
called
Granular
the
similar
to what
i s
1 .
The
that
water
been
drinking
now
has
been
through
.:.ctivated
what
i s
called
a
Carbon.
filters
I t
the
contaminants.
TOR 0 5 I .; :\
(..
.;SSOCIATES,
-------
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9
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11
12
1 3
1 4
1 5
1 6
1 7
1 8
19
20
21
22
2 3
2 4
And
the
sixth
alternative
that
we
looked
at
was
to
take
the
water
out
and to take car e of the inorganics and
then destroy the contaminants by a
process known as Ultraviolet Light/
Oxidation.
I'm not
going
to
go
into
the
actual
details
of
ultraviolet
light
and
oxidation.
It
i s
an
inn ov a t i v e
process
but
i t
involves
actual
destruction
of
the
contaminants
onsite.
Any volatile
organic
compound
that
comes
out
of
the
groundwater
would
be
destroyed
onsite
as
opposed
to
taking
't he
water
out
and
the
water
the
cont.aminant
would
be
transferred
to
another
media,
i f
you
1 i k e ,
the
air
stripping.
The, con tam i n ant 'w 0 u 1 d
be
transfered
from
the
water
to
the
air
and
then
you
have
to
treat
the
air
or
the
carbon.
You
would
have
to
treat
the
carbon.
That
treatmeant
would
occur
off
sit e .
But,
the
ultraviolet
1 i 'g h t / ( U V ~
oxidation
process
contaminants
are
being
actually
:.: . ;.. .
TO?\()S:;"~
&
;"SSC::ATES,
-------
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11
12
1 3
1 4
1 5
1 6
1 7
l8
19
20
2 1
22
2 3
24
1
ji
il
II
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idea
destroyed
2
So,
3
because
the
that we
look
4
5
and
so we
6
with
the
7
!I
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consideration.
Superfund
8
9
one
of
were
"
We
"
Air
stripping
were
the
two
..
"
say
cheap
million
onsite.
we
opted
for
that
new
Superfund
law
at
thought
and
laws.
the
the
The
The
that
the
permanent
would, be
intent
cost was
par tic u 1 a'r
cheaper
ones.
looked
and
at
air
l~
primarily
requires
treatment
in
line
of
the
new
cheaper.
because
dollars.
they were' two
alternatives
The
i s
proposing
d'
II
:i
'I
:1
nine
million
groundwater.
i
:,
"
installing
extraction
groundwater
of
that
also
a
,c 0 s t s
stripping.
I'm not
were
i s n ' t
cheap
they
I t
we
cheaper
1 0 0 k e'd
alternative
will
ultraviolet/oxidation
the
dollars
I t
cost
that
going
to
over
a
t:>
to
treatment
f a c i 1 i 1 tie s
but
at.
the
E. P . A .
approximately
to
clean
basically
a
network
wells
out,
r1 . ;... .
T C R 0 S l ;... :,
of
up
the
consists
of
groundwat\!:r
take
the
~onstruct
for
the
special
&
;"'SSCCI;"'TES,
-------
~ ~
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1 :i
!/
2 ii.
il
3 !!
4
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7 .1,
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9
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1 1
12
:1
1 3
1 4
1 5
1 6
1 7
1 8
19
20
2 1
22
2 3
2 4
inorganic
and
for
organics,
to
extract
the
water
from
the
installation
of
the
wells,
extract
the
water
and
finally
to
discharge
the
treated
water
back
to
Johnson
Creek.
The
schematic
basically
looks
like
t his .
The
extraction wells
will
take
the
water
out
and
flow
is
approximately
400
gallons
per
minute.
There
i s
some
inorganics
like
metals
tha~
needs
to
be
removed
to
protect
the
equipment,
to
help
the
process,
the
treatment
process
operate
more
effectively
and
need
to
take
the
metals
out.
So,
the
metals
are
taken
out.
They
are
eventually put
into what
we
call
a
dry,
a
dry
sludge.
They are
transported
out
off
sit e
to
a
landfill.
The
filtered water
that
now has
most
of
the
inorganics
removed
from
i t
i s
subject
to
;.:ha~
we
call
the
ozone,
ultraviolet
light,
hydrogen
peroxide
treatment
and
then
basically
the
groundwater
once
i t
i s
treated,
i t
.. .
.'.. . .~ .
:- eRe S : A :~
..
";S.3J::;'.TES,
- ... -
-------
,
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it
2 :1
11
"
3 ii
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II
4 "
"
I
5 I
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9
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,.
1 3
1 4
1 5
1 6
1 7
1 8
19
"
"
20 1-
"
I
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22
23
2 4
is
discharged
back
to
Johnson
creek.
The
approximate
location
of
the
wells
so
to
give
you
an
idea
of
where
the wells
would
be
located
( i n d i c a. tin g )
This
i s
very
pre1iminary,
very
preliminary.
These
little
circles
over
here
represent
(indicating)
the'extraction wells.
Six
of
them.
Most
of
the
contamination
from
the
valley
i s
around
this
area
right
here
(indicating)
so we
want
to
put
a well
over
here.
The
wells
have
been designed
to
extract
all
of
the
contamination,
all
of
the
contamination.
Basically we
figure
around
six
'.-Ie 11 s
'''; 0 u 1 d
be
neede'd
to
be
installed.
Exact
location
of
the
wells
or
the
exact
location
of
the
treatment
facilities,
we
are
leaving
that
for
a, '
later
decision
in
what
we
call
during
remedial
design.
We
'.-I i 11
be
looking
at
where
i s
:!1e
best
place
to
loc3t'?
th"s"
wells,
where
i s
the
best. place
to
locate
the
treatment
f a c i 1 i t Y .
Right
TL.:" .
-......--,.._...~..
- - ;:\ - :; .. ...-.......
.;.
.;;SSCC::.;'TES,
-:- '.... ,...
-------
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4
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8
9
1 0
1 1
12
1 3
1 4
15
16'
... 1 7
1 8
19
20
2 1
22
2 3
2 4
'\
now we
are
very proximal
to
the
location
of
the
treatment
station.
Now,
Station
..,
"-
that
doesn't
say
where
it
i s
going
to
be
put.
For
now
that
1 S
a
possible
location.
The
wells,
as
I
s aid ,
is
not
absolute.
The
location
isn't
set
in
concrete.
These
are
preliminary
locations
of
the
wells.
The
wells
are
to
be
installed
and
to
capture
the
entire
contaminant..
Basically
our
best
statement
right
now
for
a
time
of
clean
up
i s
approximately
3 0
years
it will
take
to
clean up
the
groundwater
to
drinking
water
standards.
Right
now
that's
our
best
estimate.
That's
all
I
really
have
to
say
about
E.P.A.'s
proposed
alternatives.
We
welcome
questions.
I
won't
be
responding
to
your
questions.
The
format
i s
to
ask
questions
and
your
questions
will
be
responded
to
in
what
we
call
a
Responsiveness
Summary
which
wi 11
be
issued
by
the
E . P . A .
at
a
1 ate r
M.A.
TOROSIA~
&
ASSOCIATES,
-------
,
u
'"
1
~ ;
:1
II
!I
I!
"
d
I:
MR.
time.
2
With
all
I
have.
3
4
Ii
II
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1,
II
II
I'
- ,I
tonight
5
Okay.
6
more
time
one
hearing
7
8
although,
I'm
9
questions
some
1 0
ask,
we
are
that,
Mr.
NAPARSTEK:
2 3
Chairman,
that's
I
just want
the
purpose
i s
as
sure
that
that
you
not
here
1 1
questions
tonight.
We
..
12
your
comments
1 3
then
consider
1 4
decision
for
1 5
your
comments
1 6
and will
be
1 7
responsiveness
1 8
I
think
i,
,
'I
begin
the
19
to
"
20
,
':
speakers
that
il
I:
21
I'm
that
sure
"
!!
couple
that
22
::
1:
2 3
to
i n
order
go
2 4
would
ask
that
M.A.
TOROSIAN
and
your
those
the
remedial
will
go
responded
summary.
with
hearing.
have
filled
there
would want
that
you
come
in
Bob
to
a r. e
Thanks,
Bob.
the
I
to
emphasize
of
the
said
it
is,
you
all
have
would
like
to
answer
your
here
to
take
questions
and
into
to
that,
are
!
hav~
final
action.
All
the
record
as
part
of
the
I
w 0 u 1 d. 1 i k e
only
have
two
out
cards.
probably
a
to
but
I'm
goin?
them.
I
up
and
us
give
&
ASSOCIATES,
-------
2 4
!1
"
1 ii
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2 ,I
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1 3
1 4
15
16
1 7
18
19
20
21
22
23
2 4
your
name
and
any affiliation
that you
have.
The
first
speaker
that
I
have
i s
Linda
Loreth.
MS.
LORETH:
Hi.
MR.
NAPARSTEK:
Hi.
MS.
LORETH:
Did you
want me
over
there?
MR.
NAPARSTEK:
Anywhere
that
you would
like.
MS.
LORETH:
Okay.
I'm
the
Environmental
Health
a n'd
Sa f e t y M a,n age r
with A.W.
Chesterton
Company and my
name
i s
Linda
Loreth.
I'd
1 i k e
to
read
a written
comment
that we
have.
"This
i s
in
regards
to your
Feasibility
Study
regarding
the
E . P. A.
region
Superfund
for
Groveland wells,
No.
1
and
2 ,
in Groveland,
Massachusetts
of July
of
, 91.
This
i s
submitted within
your
30-day
comment
period"
which
has
been
extended.
MR.
NAPARSTEK:
Which
has
been
extended.
MS.
LORE'!H:
"You
are
aware
M.A.
TOROSIAN
& .h.SSOCIATES,
-------
: 3
\..
1 II
II
I.
2 II
!!
3 Ii
Ii
4 ~ I
II
'I
'I
5 II
!I
6 II
"
I
7 !
I
- I
8 i:
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9
1 0
11
12
1 3
1 4
1 5
1 6
1 7
1 8 ..
;'
19 "
,!
"
"
20 :i
"
2 1
ii
:1
22 "
"
"
:1
2 3
2 ~
that Chesterton went to great lengths
and expense prior to the involvement of
the E. P. A. to assure the town and
itself
that
Chesterton was
not
the
source
of
the
contamination
of
the
Groveland
wells
Nos.
1
and
2 .
Despite
that
effort
Chesterton
con tin u.e s
to
receive
adverse
and
inaccurate
publicity.
Your
proposed
plan
dated
July
199 1
describes
Chesterton'Site
as
( 1 )
" 1 i k e 1 y "
rather
than
"possible"
source
of
the
contamination,
( 2 )
as
one
of
"several
sources
of
contamination"
of
the
Groveland wells,
and
( 3 )
not
"currently"
contaminating
the
wells.
There
i s
no
evidence
that
we
have
ever
contaminated
the
wells.
In
fact,
the
contaminants
on
Chesterton
property
are
distinctly different
from the
contaminants
associated with
the
Groveland wells
No.
1
and
2 .
"Please' comment
on "'hy
the
E. P. A.
as
recently
as
July
2nd,
, 9 1
i n
the
:: . P . A .
Environmental
News
Press
M.h.
TOROSIAN
&.
ASSOCIATES,
-------
25
1 H
il
2 Ii
II
,
3 "
"
il
4 I'
"
:1
5 ii
"
II
6 ii
II
II
7 .11
8 11
'!
9
1 0
11
12
1 3
1 4
15
1 6
1 7
18
1 9
20
2 1 "
:!
22
23
2 4
Release
refers
to
the A.W.
Chesterton
Company as
a
"likely source
of
contamination"
in
relation
to
the
closing
of
the Groveland wells No.
1
and 2;
when
( 1 )
Chesterton has
never
used or
stored
the
well
contaminant;
( 2 )
the
E.P.A.
remedial
investigation
determined
that
the
contamination was
confined
to Chesterton property
boundary;
( 3 )
the
E.P.A.
considered
Chesterton property as
a
separate
remedial
u nit ;
and
( 4 )
the
E.P.A.'s
remediation
i s
to
treat
Chesterton
separately under
RCRA.
" I f
you need
clarification
to
this
request,
please
contatt me
at
( 617 )
438-7000
extension
2 309 . "
I
thank
you
for
the
opportunity
to
speak
and
I
would
1 i k e
to
offer
you written
copies.
MR.
NAPARSTEK:
Thank
you,
Linda.
The
second
speaker
that
I
h a 0" E'
submitted
on
a
card
i s
David Argyros.
MR.
ARGYROS:
My name
i 5
Dave
M.A.
TOROSIAN
&
ASSOCIATES,
-------
: i
1 Ii
I
I
2 I
II
Ii
3 ,I
II
Ii
4 I'
:\
5 Ii
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1 2
1 3
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1 7
1 8
19
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i!
21 "
"
11
22 :1
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2 4
..
Argyros.
I'm an
environmental
engineer
by background.
I ' ve
also
been
a
Chesterton 'employee
for
the
past
11
years
and
familiar with
the
Groveland
well
problem,
a member
of
the
town
and
member
of
the
aquifer
protection
committee
for
several
years.
My
comments
are
in
regards
to
the
proposal
from the
point
of view of
a
u . S .
citizen
and
taxpayer
and
someone
who
has
been
a
taxpayer
and may
have
to
ultimately
foot
the
bill
for
the
project.
My
comments
are
in
regards
to
two
areas.
The
first
are
the
treating
plant.
Given
that
the
town
Well,
No.
1 ,
the
primary
town well
i s
currently
supplying
safe
drinking
water
and
that
the
area
surrounding
well
No.
1
i s
no
longer
contaminated
due
to
the
natural
flushing
and
the
controlled
pumping
and
also
that
the, natural
flow
of
the
contaminant
plume
i s
not
directly
towards
well
;~ 0 .
1 ,
i t
should
be
M.A.
TOROSIAN
&
ASSOCIATES,
-------
2 S
~
11
I
r
1 II
2 II
II
3
ij
4 :'
5 !i
'I
Ii
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6 :1
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8
:1
9 :1
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1 1
12
1 3
1 4
1 5
16
17
18
i
"
\:
19
2 0
21
22
23
24
concluded
that
groundwater
monitoring,
control
pumping
and
limited well-head
treatment
such
as
the
current
carbon
polishing
and
institutional
controls
would
be
effective
in
assuring
continued
safe
drinking water
sup' ply
for
the
town.
Also,
the
fact
that
the
contaminant
source
has
been
discharging
. in t 0
the
valley
area
for
approximately
1 5
years
and
that
i t
currently
continues
to
discharge
into
that
area
and
that
the
natural
migration
of
tt!at
plume
i s
along
the
brook
and
towards
the
river
and
also
given
that
there
i s
a high rate of transitivity in the
sandy soils, I would also like to point
out that the majority of the
contaminants
within
that
entire
contaminated
75
acre
plume,
more
than
80
percent
of
that
entire
contamination,
i s
confined
to
i'I
relatively
small
area
near
the
valley
sit e ,
that
area
i s
roughly
1/20th
or
M.A.
TOROSIAN
&
ASSOCIATES,
-------
"
v
1
i
I,
II
II
II
"
Ii
contains
five
percent
2
plume
3
29
of
the
total
volume
of
the
80
of
the
percent
contamination where
those
4
!i
I
I
I
i
II
I
. II
:,
:i
one
concentrations
5
near
the Valley
are
site
approximately one
higher
6
than
the
majority of
plume.
7
thousand
times
the
Considering now
facts;
8
that
the
9
the
treatment
10
the
volume
of
1 1
capture
and
to
12
,
.1
'1
,;
,;
ii
II
to
disruption
1 3
town
itself
from extraction wells,
1 4
piping
"
systms,
1 5
i s
also
proportional
of
I 6
that
water
you
I 7
and
t rea tin g .
18
reduction
and
If
H
.,
"
19
of
contaminants
.,
d
11
il
i!
ii
"
ii
II
;1
you
20
the
volume
of water
as
21
i t
i s
proportional
to
the
as
22
concentrations
23
that
water
2 4
i f
i 5
you
pump
M.A.
TOROSIAN
several
.
cost
of
cost
of.
treatment,
plant
proportional
are
to
water
that
are
going
you
t rea t ;
also
the
that
the
people
town's
and
the
pumps,
tanks,
e t c . ,
that
to
the
volume
are
going
pumping
be
to
However,
the
contaminant
removal
and
destruction
i s
not
proportional
to
as
nearly
much
of
the
contaminated
are
pumping out
t hat
and
out
small
quantity
at
a
&
ASSOCIATES,
-------
1 4
15
1 6
..
1 7
1 8
19
2 0
21
22
2 3
2 4
1
II
Ii
II'
parts
of
groundwater
contaminated
2
thousand
3
"
;'
more
treatment
much
get
"
4
1'1
I;
"
If
il
II
il
II
.II
!I
"
cost
effectiveness,
quantity
of
water
5
billion.
6
For
7
should
be
concluded
8
efficiency,
q
9
minimum disruption
1 0
treatment
efforts
1 1
focused
per
billion,
at
these
to
than
five
at
30
a
you will
parts
that
reasons,
for
the
themselves
at
eliminating
12
where
80
percent
ii
1 3
is
concentrated
percent
of
area
the
I f
you
were
were
to
focus
your
entire
s i z e
of
the
five
percent
area
"
,
ii
:,
concentrated,
you
your
treatment
plant
l/lOth
the
proposed
reduce
your
costs
dollars
down
to
reasonable
level.
M.A.
TOROSIAN
of
the
and
that
and
to
the
town
source
a
greater
per
i t
maximum
and
a
should
be
area
contamination
i s
volume.
do
efforts
plume
where
could
size
f r o'm
a
much
You
but
it
f'i ve
this,
not
i s
roughly
in
the
i f
you
and
eight
smaller
'Ii'on't
on
the
on
that
reduce
vicinity
&
ASSOCIATES,
of
also
million
and
be
-------
\,
" \
1
:1
II
!I
ii
.1
ii
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,:
higher
con tam i n a,t e d
treating
2
the
contaminated
3
treating
4
million
5
water.
6
7
size
of
8
9
..
it may be
1 0
different
1 1
air
stripping
alone
12
capture.
.,
"
1 3
use
the
1 4
No.
1
1 5
there.
1 6
1 7
comments
18
that
in
19
evaluated
"
entire
water.
roughly
1 8
gallons
Also,
the
air
when
In
to
your
alternatives
20
22
!;
,:
alternative
21
1
H
"
i n vol \. e d
2 3
There
of
because
360
j ~
million
gallons
You would
but
more
practical
be
million
highly
type
treatment
no
that
\\' as
gallons,
1 2
contaminated
of
the
smaller
system needed
I t
might
stripper
the
levels
summary,
E . P . A. ' S
proposed
several
from do
with
be
that
to
to
that
treat
smaller
volume,
to use
a
method
such
as
the 'carbon
even
possible
to
was
at
once
were
higher
summarize
my
proposal,
widely
i t
i s
cleanup
plan,
you
different
nothing
plume
evaluation
M.A.
TOROSIAN
&
ASSOCIATES,
INC.
to
alternatives which
complete
was
2 4
alternative
extract,ion.
of
an
in
between
-------
32
I
1 I
I
2 Ii
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,I
3 ,
"
-,
I,
4 II
,-
-,
"
5 II
I
6
7
- ,I
,
8 "
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9
10
Ii
1 1
12
..
1 3
1 4
1 5
1 5
1 7
1 8
19
20
21
22
2 3
2 4
would
seem to be
the most
practical.
And that
alternative
which
should be
evaluated
.,
in detail
involves
basically
the
capture
and
the
treatment
of
the
highly contaminated
head
portion
of
the
plume which
is
continuing
to migrate
off
the Valley
sit e .
That
treatment of
the
smaller
highly contaminated
area
at
a much
lower
cost
combined with
the
institutional
and monitoring
c 0 'n t r 0 1 s
at
the well
head and
throughout
the
rest
of
the plume
should be
able
to
treat
the
contamination,
stop
the
source.
And during
that
time
that
the
head
of
the
plume
or
the
highly
contaminated portion
i s
being
treated,
the
remaining
95
percent
of
the
plume
with
the
20
percent
of
the
contamination will
naturally dissipate
on
its
own.
The
high
transivity of
the
soils
there,
I
think
the water
flow
i 5
that
of
about
a 'f 0 0 t per
day
combined
with
the
fact
that
i t
i 5
basically
discharging
towards
the
Merrimack
and
M . A .
TOROSIAN & ASSOCIATES,
-------
-- ,
, ,
, I
\
1 0
1 1
.,
1
Valley would
!I
I.
'I
!I
;!
2
concenttated
dissipate
but
larger
plume
probably well
within
3
4
Ii
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!,
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I
I
i
majority,
that
it would
take
you
the
1 e s s
size
the
to
treat
5
highly
co~centrated portion.
6
7
percent
that
that
large
is
less
size
plume,
of
.., ..,
- ~
that
time
the
In
that
contaminated,
the
95
8
there
may only be
120
gallons of' the
I
II
~ I
~ ;
solvent
c r
9
of
material
"
"
in
the
order
that
'....ou 1 d
captured
and would be
12
decrease.
1 3
That
.,
1 4
relation
to
..
1 5
the
proposed
1 6
evaluate
to
1 7
somewher'e
1 8
clean up
the
"
:!
plume.
1 9
:1
My
20
i;
21
taxpayer,
'.
!I
i!
!.
I.
"
,.
:1
"
22
the
bill
summarizes
the
town's
treatment
a
practical
in
between
enti re
second
360
of
800
actually
left
to
my .c .0 m men t
system
itself.
pounds
not
be
naturally
in
itself
or
I t
i s
alternative
do
nothing
million
comment,
again,
who
may
some
for
this
pt;oject
briefly
looking
through
2 3
day
foot
a'n d
gallon
as
a
part cd
involves
the
costs
2 4
the
sample
program outlined
in
M.A.
TOROSIAN
&
ASSOCIATES,
just
of
the
-------
1 0
11
12
13
.1 4
15
16
..
1 7
18
19
20
21
22
23
2 .:;
':1 ~
-' ..
1
::
I
!I
!i
i t
report and the numbers were
sort
of
2
shocking,
surprising
to me.
For
3
example,
in
alternative No.
2 ,
4
II
"
j!
j!
H
"
II
times
indicates eight
groundwater
samples
for
5
the
sampling. For
the
of
sampling
cost
6
itself,
the
eight
samples
four
a
II
. II
,
,
travel,
7
the
$8,000
based upon
cost was
year,
24
8
man hours per
sampling,
plus
9
living and
the
shipping
expenses.
The
analysis
of
those,
there would
be
40
samples
a year would be
$20,000
and
the
reporting,
20
man hours
~ :
to produce
a
report,
plus
costs was
other
direct
approximately
4 , 000
a year
roughly
looking
$ 32, 000
to pull
at
eight
a
year
groundwater
samples
four
times
a
day
and
produce
It may be
report.
a
more
cost
effective
E.P.A.
rather
than
sending
somebody out
and
putting
them
:,
"
hotel
in
the
take
the
to
samples
to
contract with
private
agency,
privat~
a
testing
lab with
a
the
E. P. A. ,
"
certified
lab
and
simply
E. P . A.
puttin?
them en
sch~duling
P tl11
rotating
to
a
M.A.
TOROSIAN & ASSOC!ATES,
-------
: I
16.
1 7
18
19
20
21
22
2 3
2 4
;,
... ~
-' ::;
1
,
,
Ii
Ii
'II
I.
:/
II
11
q
II
II
!
cost associated
samples
and produce
a
report.
The
cost
2
should be
approximately half or
to a
3
the
quarter
costs
contained
in
the
4
report.
5
So
that
summarizes
my second
6
comment.
Again,
one.
7
Simply look
the
at
cost
of private
8
- II
!I
:!
'I
,/
Thank
contracting
pulling the
samples.
9
Should be
significantly
1 e s s .
1 0
you very much.
1 1
MR.
NAPARSTEK:
Thank
you,
12
Mr.
Argyros.
Okay.
1 3
.i
I'
,!
,:
ij
are
Those
the
only two people
14
that
have
submitted
cards.
Are
there
"
1 5
any other
speakers
that would
like
to
'.
submit
time?
a
comment
this
at
Okay.
Well,
i f
there
are
no
others
that would
like
to make
a
,.
,
"
statement,
I ' 1 1
close
the
hearing.
Let
"
:'
me
just
the
remind you
again
that
!
.,
'!
:;
deadline
submit
to
written comments
i s
I:
,I
I,
:!
'I
S e p t e m b' e r
9 t h .
All
c' 0 m men t s
must
be
postmarked
hand-delivered
OI
to
the
E . P . A.
that
at
time.
thank
I
you
for
..
M.A.
TOROSIAN
& .;SSOCIATES,
-------
1
2
3
4
5
6
7 .
8
9
1 0
11
12
13
14
1 5
1 6
... 1 7
1 8
19
20
21
22
23
.24
coming
tonight.
~ I
I
II
II
1!
"
:\ .
:!
ji
;!
il
Ii
"
II
II
II
,\
;.
l ~
"
;i
I
.,
!i
Ii
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I:
II
I,
'I
;1
"
!!
~ 1
M.A.
36
and f~r your participation
Thank you.
(Whereupon,
the hearing
con c 1 u d e d' a t 8: 0 5 p. In. )
TOROSIAN & ASSOCIATES,
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