United States
Environmental Protection
Agency
Off ice of
Emergency and
Remedial Response
EPA/ROD/R01 -91/061
September 1991
&EPA
Superfund
Record of Decision
-------
50272-101
REPORT DOCUMENTATION 1'. REPORTNO.
PAGE EPA/ROD/ROl-91/061
I ~
3. Reclpient's ~on No.
4. 11tIe and SImtItIe
SUPERFUND RECORD OF DECISION
Silresim Chemical, MA
First Remedial Action - Final
7. Aulhar(s)
5. R8port Date
09/19/91
6.
8. Performing Organization RepI. No.
8. Performing Orgllnlzation Name and Addreu
10. ProjectfTuklWortI Ur8t No.
11. Contract(C) or Grant(G) No.
(C)
1~ IIpon8orIng Organization N8me and ~
U.S. Environmental Protection
401 M Street, S.W.
Washington, D.C. 20460
(G)
13. Type of Report . PerIod CoftI'8CI
Agency
800/000
14.
15. Supplement8ry No,"
16. Ab81raCt (Urr8t: 200 wonI8)
The 4.5-acre Silresim Chemical site is a former chemical waste reclamation facility in
Lowell, Massachusetts. Land use in the area is predominantly industrial, although
residential areas are located to the south, east, and northeast with the closest
residences approximately 300 to 500 feet from the site. The nearby residences obtain
their drinking water from a municipal water supply. From 1971 to 1977, Silresim
Chemical Corporation (SCC) used the site for a chemical waste reclamation facility.
The facility's primary operations included recycling and reclaiming various chemicals
and consolidating waste for offsite disposal. The facility handled approximately
3 million gallons of waste per year including halogenated solvents, oily wastes,
alcohols, metal sludge, and plating and pesticide wastes. From 1977 to 1978, SCC
abandoned the facility, leaving approximately 1 million gallons of hazardous waste
onsite in bulk tanks and nearly 30,000 decaying drums. State investigations revealed
evidence of numerous spills, leakage of drums, discharges to nearby sewers, and run-off
to adjacent property. A number of EPA and State investigations revealed contamination
of soil and ground water. From 1978 to 1982, the State constructed a fence, removed
liquid waste in onsite drums and tanks, and constructed berms and absorbent-filled
(See Attached Page)
17. Document An8Jy8I8 L Du8crtptora
Record of Decision - Silresim Chemical, MA
First Remedial Action - Final
Contaminated Media: soil, gw
Key Contaminants: VOCs (benzene, TCE, toluene, xylenes), other organics (dioxin,
PAHs, PCBs, phenols), and metals (arsenic, chromium, lead)
b. IdentHleralOpen-Endud T-
Co COSA 11 RekIIGroup
18. AYIIII8bi1ity St8Iement
18. Securtty CIau (ThIs Report)
None
20. Securtty CIau (lb18 Page)
}Jt"ln~
21. No. of Pages
280
~ Price
(See ANSl-Z38.1S
See INItIVcfi- on~-
272 (4-77)
(Formerly NTlS-3S)
-------
EPA/ROD/ROl-91/061
Silresim Chemical, MA
First Remedial Action - Final
Abstract (Continued)
trenches. From 1983 to 1984, EPA removed all onsite structures, extended the fence,
and placed a clay cap over the site. This Record of Decision (ROD) addresses both
onsite and offsite soil and ground water contamination. The primary contaminants of
concern affecting the soil and ground water are VOCs including benzene, TCE, toluene,
and xylenes; other organics including dioxin, PAHs, PCBs, and phenols; and metals
including arsenic, chromium, and lead.
The selected remedial action for this site includes constructing additional perimeter
fencing; placing a low-permeability temporary cover over areas of contaminated offsite
soil; extending and repairing the existing cap as required; conducting in-situ
vacuum/vapor extraction of approximately 137,000 cubic yards of contaminated soil;
excavating and stabilizing any soil with residual contamination after treatment with
vapor extraction, followed by onsite disposal; backfilling excavated areas with clean
fill; installing a RCRA Subtitle C cap over the stabilized soil; pumping and
pretreatment of ground water using a phase separation tank to separate non-aqueous
phase liquids (NAPLs), followed by chemical addition, flocculation, precipitation, and
filtration to remove metals; offsite disposal of NAPLs and residuals from the metals
removal process; treating residual ground water using air stripping of heated influent,
thermal oxidation, and aqueous phase carbon adsorption, followed by offsite discharge
of the treated ground water to the municipal sewer system or onsite discharge to
surface water; conducting long-term soil, surface water, and ground water monitoring;
and implementing institutional controls including deed, ground water, and land use
restrictions The estimated present worth cost for this remedial action is
$22,300,000, which includes a present worth O&M cost of $9,263,000.
PERFORMANCE STANDARDS OR GOALS: Chemical-specific unsaturated soil clean-up goals are
based on leachability modeling and include among others benzene 4 ug/kg,
dioxin 1 ug/kg, PAHs 10,000 ug/kg, PCBs 2,300 ug/kg, phenol 5,300 ug/kg, toluene
2,700 ug/kg, TCE 6 ug/kg, and xylenes 22,000 ug/kg. Chemical-specific surficial soil
clean-up goals are based on risk assessments, background levels, and EPA pOlicy and
. include among others arsenic 21,000 ug/kg (background), benzene 15,000 ug/kg (risk),
dioxin 1 ug/kg (policy), lead 500,000 ug/kg (policy), PARs (total) 29,000 ug/kg
(background), PCBs 1,000 ug/kg (policy), and TCE 40,000 ug/kg (risk).
Chemical-specific interim ground water clean-up goals are based on MCLs, MCLGs,
proposed MCLs (pMCLs), reference doses, and EPA policy and include among others
arsenic 50 ug/l (MCL), benzene 5 ug/l (MCL), chromium 100 ug/l (MCLG),
dioxin 5x10-8 ug/l (pMCL), lead 15 ug/l (policy), PAHs 0.2 ug/l (pMCL), PCBs 0.5 ug/l
(MCL), phenol 21,000 ug/1 (reference dose), TCE 5 ug/l (MCL), toluene 1,000 ug/l
(MCLG), and xylenes 10,000 ug/l (MCLG). EPA will conduct a risk assessment of residual
-------
,
RECORD 0:1' DBC:J:S:J:OB SUlllmRY
SILRESIK SITE
LOWELL, MASSACHUSETTS
SBPTBKBBR 19, 1991
u.s. ENVIRONMENTAL PROTECTION AGENCY
-------
UNITED STATES ENVIRONHEN'l'AL PROTBCTION AGENCY
.. REGION I
J.P. KENNEDY FBDERAL BUILDING, BOSTON, MASSACHUSETTS
02203
DECLARATION FOR TBB RECORD OF DECISION
SILRBSDI BID
LOWELL, MASSACJWSE'1"1'S
STATEKEH'l' OF PURPOSE
This decision document represents the selected remedial action
for the Silresim Site, in Lowell, Massachusetts, developed in
accordance with the Comprehensive Environmental Response,
Compensation and Liability Act of 1980 (CERCLA), as amended by
the Superfund Amendments and Reauthorization Act of 1986, and to
the extent practicable, t~e National oil and Hazardous Substances
Contingency Plari (NCP); 40 CFR Part 300 et seq., as amended. The
Regional Administrator has been delegated the authority to
approve this Record of Decision.
The Commonwealth of Massachusetts has concurred on the. selected
remedy.
STATEMENT OF BASIS
This decision is based on the Administrative Record which has
been deveioped in accordance with Section 113 (k) of CERCLA and
which is available for public review at the Pollard Memorial
Library in Lowell, Massachusetts and at the Region I Waste
Management Division Records Center in Boston, Massachusetts. The
Administrative Record Index (Appendix F to the ROD) identifies
each of the items comprising the Administrative Record upon which
the selection of the remedial action is based.
ASSESSMENT OF THE SITE
Actual or threatened releases of hazardous substances from this
Site, if not addressed by implementing the response action
selected in the ROD, may present an imminent and substantial
endangerment to human health or public welfare or to the
environment.
-------
DESCRIPTION OF THE SELECTED REMEDY
This ROD sets forth the selected remedy for the Silres1m 'Site,
which includes both 'source control and management of migration
components to obtain a comprehensive remedy.
The major components of the selected source control remedy
include:
*
In situ vacuum/vapor extraction of contaminated soil to
remove volatile organic compounds (VOCs):
Excavation of soil with residual contamination and further
treatment using stabilization;
*
*
Disposal of stabilized soil on Site;
~nstallation of a Resource Conservation and Recovery Act
(RCRA) Subtitle C cap over the stabilized soil: and
*
*
Institutional Controls.
The major components of the selected management of migration
remedy include:
*
Extraction of contaminated groundwater from the overburden
and shallow bedrock using extraction wells; .
Pretreatment of contaminated groundwater using a phase
separation tank to separate non-aqueous phase liquids
(NAPLs), and metals precipitation/filtration to remove
metals; .
*
*
Treatment of contaminated groundwater using air stripping of
a heated influent, thermal oxidation and aqueous phase
carbon adsorption; and
*
Institutional controls.
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. This remedy satisfies the statutory
preference for remedies that utilize treatment as a principal
element to reduce the toxicity, mobility, or volume of hazardous
substances. In addition, this remedy utilizes permanent
solutions and alternative treatment technologies to the maximum
extent practicable. .
-------
As this remedy will result in hazardous substances remaining on
site above health-based levels, a review will be conducted within
five years after commencement of remedial action to ensure that
the remedy continues to provide adequate protection of human
health and the environment.
Iff/
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Contents
ii.
iii.
IV.
Vi.
Vii.
Viii.
IX.
X.
Xi.
i.
V.
RECORD OF DECiSiON
SiLRESiM SiTE
TABLE OF CONTENTS
SiTE NAKE, LOCATiOB AIm DBSCRiPTZOB
. . . . . . . . . . . . . . . . .
SiTE HiSTORY & ENFORCEMENT ACTiViTiES ...............
A.
B.
Response History & Land Use .....................
Enforcement History .............................
COMMUNiTY PARTiCiPATiON .............................
SCOPE' ROLE OF OPERABLE 1nf:I~ OR RESPONSE ACTiON.....
SUMMARY OF SiTE CHARACTERiSTiCS .....................
SUMMARY OF SiTE
RISKS. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
A.
B.
Current and Future Potential Exposure Pathways...
Risk Characterization .............:.............
DEVELOPMENT AND SCREENiNG OF ALTERNATiVES...........
A.
B.
statutory RequirementS/Response Objectives ......
Technology and Alternative Development
and S cree~iDq .............................8.......
DESCRiPTiON OF ALTERNATiVES .........................
A.
B.
Source Control (SC) Alternatives Analyzed .......
Management of Migration (MK)
Alternatives Analyzed ...........................
SUMMARY OF THE COMPARATiVE ANALYSiS OF ALTERNATiVES...
A.
B.
Comparison of Source control (SC) Alternatives....
comparison of Managment. of Migration (MK)
Alternatives......................................
THE SELECTED REMEDY..................................
A.
B.
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 ...
B.
C.
Paae Number
1
1
1
3
..
5
6
14
16
21
26
26
26
28
28
43
51
53
60
64
64
75
85
85
86
-------
D.
The Selected Remedy utilizes Permanent Solutions'
and Alternative Treatment or Resource Recovery
Technoloqies to the Maximum Extent Practicable....
The Selected Remedy Satisfies the Preference
for Treatment as a Principal Element .............
E.
XII.
XIII.
STATE ROLE
DOCUMENTATION OF SIGNIFICANT CHANGES .................
APPENDICES
Appendix A
App~ndix B
Appendix C
Appendix D
Appendix E
Appendix F
. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Figures
Tables
ARAR Tables
Massachusetts Letter of Concurrence
Responsiveness Summary
.Administrative Record Index
95
97
97
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RECORD OF DECISION SUKKARY
SILRESIK SUPERFUND SITE
SEPTEMBER 19, 1991
I.
SITE NAKE, LOCATION AND DESCRIPTION
This Record of Decision (ROD) is for the cleanup of the Silresim Superfund
site (the Site) in Lowell, Massachusetts. The SilresimSite is located at
86 Tanner Street in an industrial area of Lowell, Massachusetts, just south
of the Central Business district (Figure 1, Appendix Al. The Site is
defined by the extent of contamination and all suitable areas in very close
proximity to the contamination necessary for implementation of the response
action. The original facility (Silresim Chemical Corporation) consisted of
approximately 4.5 acres: however, the extent of contamination includes
approximately 16 acres (bound by the extent of groundwater contamination).
The 4.5 acre silresim property is bordered by the Lowell Iron and steel
Company to the north, the B & M railroad yard and tracks to the
east/northeast, and an automobile salvage yard to the south, and Tanner
street to the west. Residential" areas are located south, east, and
northeast of the Silresim property, with the closest residences located on
Canada, Main, "and Maple Streets, roughly 300 to 500 feet from the Silresim
property boundary. River Meadow Brook lies approximately 400 feet west of
the silresim property boundary (Figure 2, Appendix A).
No buildings or permanent structures currently exist on the Silresim
property, which is' enclosed by an eight-foot high chainlink fence. Most of
the land surface within the fence is covered with a clay cap, with the
exception of the northeast corner which is covered with crushed stone.
Crushed stone also has been placed on runoff areas along the northern and
southern perimeter of the Silresim property to prevent direct contact with
contaminated soils. .
A more complete description of the Site can be found in the Silresim
Remedial Investigation report at pages 16 through 20 (March 1990).
II.
SITE HISTORY AND ENFORCEMENT ACTIVITIES
A.
Response History and Land Use
i.
Response History
From 1971 through 1977, the Silresim Chemical Corporation operated a
chemical waste reclamation facility on the Site. The facility's primary
operations included recycling and reclaiming various chemicals and
consolidating wastes for off-site disposal. The Massachusetts Division of
Water Pollution Control (DWPC) granted the Silresim Chemical corporation
facility a hazardous waste collection and disposal permit in 1973. Wastes
were accepted at the facility in drums, tank trucks, railroad tanker cars,
and other containers. These substances included halogenated solvents, oily
wastes, alcohols, plating wastes, metal sludges and pesticide wastes.
Although exact figures do not exist, it is estimated that the facility
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RECORD OF DECISION SUMMARY
silresim site
Page 2
Between 1973 and 1975, DWPC cited Silresim for numerous. permit violations
as the volume of waste received exceeded the facility's capacity. In 1976,
DWPC initiated efforts to close the facility because of the increased
number of permit violations and the deteriorating condition of the Site.
DWPC subsequently issued modifications to the company's permit,
modifications that were lifted after DWPC imposed a compliance schedule to
clean up the Site and improve operations.
The Silresim Chemical Corporation filed for bankruptcy in late 1977 and
abandoned the facility in January 1978, leaving approximately one million
gallons of hazardous materials on Site in drums and bulk tanks, including
almost 30,000 decaying drums covering virtually all open areas of the
facility. Subsequent investigations reveal.ed that the facility had been
poorly maintained and revealed evidence of numerous spills, leakage of.
drums, discharges to Lowell sewers, and runoff to adjacent property.
From 1978 to 1982, the Massachusetts Division of Water Pollution Control
(DWPC was the original regulator of hazardo~s waste in Massachusetts prior
to the Department of Environmental Quality Engineering, which is now the
Massachusetts Department of Environmental Protection) secured the Silresim
facility and minimized immediate threats to public health and the'
environment. The DWPC constructed a Site fence, hired a 24-hour guard,
removed liquid wastes in the on-site drums and above-ground tanks,
constructed berms and absorbent-filled trenches to reduce the spread of
waste through surface runoff, and conducted studies of the Site soils and
groundwater. .
In 1982, EPA proposed the site to the National Priorities List (NPL) for
long-term cleanup. The Silresim' site became a final listing on the NFL in
1983. Between the spring of 1983 and December 1984, EPA removed all
structures remaining on the Site, extended the fence, and placed a qlay cap
over the Site. The Massachusetts Department of Environmental Protection
has been and is currently responsible for regular operation and maintenance
of the Site, which includes maintaining the cap, fence and postings. .
A more complete history of the Site can be found in the Remedial
Investigation Report at pages 3 through 12.
ii.
LandU..
The Site and its surrounding areas have been used for industrial activities
since the early 1900'8. From 1916 to 1971, several petroleum companies
used the Silresim property as an oil and fuel storage depot. The Lowell
Iron and Steel Company/Scannell Boiler Works is located just north of the
Silresim property. Lowell Used Auto Parts operates an auto salvage yard
just south of Silresim. The parcel just east/northeast of the Site is used
for railroad activities. Various other industries, as described in the
Remedial Investigation Report, are located along Tanner Street.
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RECORD OF DECISION SUKKARY
Silresim Si~e
Page 3
the Lowell Connector are located to the west of the site. River Meadow.
.Brook runs north to northeast about 400 feet west of the Site. It is
classified by the Massachusetts Division of Water Pollution Control as a
Class B Stream and is therefore designated for the uses of protection and
propagation of fish, other aquatic life and wildlife, and for primary and
secondary contact recreation. However, the water quality from upstream of
the Silresim site to the Concord River does not comply with Class B
standards. The Brook is affected by upstream industrial discharge
unrelated to contaminant plumes from Silresim. The banks are of marginal
value to wildlife and aquatic biota due to anthropogenic changes to the
stream cou~se and banks, the upstream discharges, and general urban, paved
and altered environments adjacent to the stream bank. The potential use of
the Brook for recreational activities appears to be limited due to physical
characteristics, degraded conditions and observed dumping of trash and
debris.
The land southeast of the Site, beyond the railroad property, is being
developed as industrial/commercial condominiums. East Pond, a small
surface water body is located about 300 feet to the east of the Silresim
property. It is filled at its southern end and its banks are completely
denuded of trees. The entire perimeter of this small.water body is .
physically disturbed. The state of Massachusetts has not classified East
Pond, however, it could be used for recreational activities such as
swimming and rafting. The pond is small and shallow during the summer
months and recreational use is expected to be infrequent and of short
duration.
A mUlti-family residence is located about 300 feet southwest of the
southern boundary of the Site, on Main street. The Ayer City residential
district of south central Lowell is situated just south of this residence,
roughly 400 feet and further from the Silresim property boundary. A second
residential area is located approximately 1,000 feet north of the site.
The. City of Lowell obtains its water supply from the Merrimack River. The
intake is located approximately 3.5 miles upstream of the confluence of the
Merrimack and Concord Rivers. The aquifer below the Site is classified by
the Federal Government and the Commonwealth of Massachusetts as a Class IIB
and I aquifer, respectively. However, groundwater is not being used for
drinking water supply purposes in the Silresim area. The closest
identified groundwater use is at the Lowell Car Wash at the corner of
Tanner and Plain Streets. Groundwater was being used for car washing
operations at this location, but employees of the Lowell Car Wash recently
stated that use of this well has been terminated. City-supplied water is
being utilized for drinking.
B.
Enforcemen~ Bis~ory
During July, August and september of 1983, EPA notified approximately 325
parties who had: owned or operated the facility: generated wastes that were
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RECORD OP DECISION SUMMARY
silresim Site
Page 4
facility; or transported wastes to the facility, that they were potentially
liable with respect to the Site. Negotiations commenced with these
potentially responsible parties (PRPs) in 1984 regarding the settlement of
the PRP'sliability at the site.
On July 12, 1985, EPA issued an Administrative Order by Consent to the
Silresim Site Trust, a group of approximately 200 Potentially. Responsible
Parties (PRPs), who agreed to undertake a Remedial Investigation and
Feasibility Study (RI/FS) to investigate site conditions and to evaluate
potential cleanup alternatives which would address contamination at the
Silresim SLte. In addition, in 1990 EPA entered into an administrative
agreement with over 200 PRPs for the past costs incurred at this Site for
EPA removal and enforcement activities.
The PRPs have been active in the remedy selection process for this site. .
During the public comment period the PRPs submitted written comments which
are included in the Administrative Record and which are responded to by EPA
in the Responsiveness Summary (Appendix E). .
III. COMMUNITY PARTICIPATION
Throughout the Site's history, community concern and involvement has been
sporadic. During the early 1980's community concern and involvement was
high when groundwater, soil and air quality data became available.
However, in recent years indicators of local interest have decreased
significantly. EPA and the Massachusetts Department of Environmental
Protection (DEP) have kept the community and other interested parties
informed of Site activities and involved in the decision-making process
through informational meetings, fact sheets, press releases, public
meetings, and a publicly accessible Site file in the Pollard Memorial
Library in Lowell. In 1983 and 1984, EPA and DEP operated an information
hot-line and participated in regular meetings of a group called the
Silresim Task Force which was designed to improve communications between
federal, state, and local officials, and the citizens. .
. In September 1985, EPA released a community relations plan which outlined a
program to address community concerns and keep citizens informed and
involved in the remedial activities. In response to a petition from a
local environmental organization (the Ayer City Homeowners Chapter of the
Greater Lowell Environmental Campaign), DEP designated the Silresim Site as
a Public Involvement Plan site in 1988. DEP developed the plan jointly
with EPA so that federal and state community relations efforts would not be
duplicated. The resulting joint Community Relations Plan/Public
Involvement Plan was finalized in June 1991. .
EPA has held numerous informational meetings since the Site's listing on
the NPL. For example, on April 26, 1990, EPA held an informational meeting
to discuss the results of the-~emedial Investigation. On June 19, 1991,
EPA held a meeting to describe the cleanup alternatives presented in the
Feasibility Study, and to present EPA's Proposed Plan. During both of
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RECORD OF DECISION SUMMARY
silresim si~e
paqe 5
these meetings EPA answered questions from the public. A 30-day public
comment period beginning June 20, 1991 was extended an additional thirty
days to August 19, 1991 to accept public comment on the alternatives
presented in the Feasibility study, the Proposed Plan and on any other
documents previously released to the public. On July 10, 1991, EPA held an
informal public hearing to accept any oral comments. A transcript of this
hearing, and EPA's response to the comments are included in the attached
Responsiveness Summary (Appendix E). A more complete list of community
, relations activities can be found in Attachment A to the Responsiveness
,Summary.
EPA published a notice with a brief analysis of, the Propo~ed Plan in the
Lowell Sun on June 8, 1991 and made ,the plan available to the public at
EPA's offices in Boston and at the Pollard Memorial Library in Lowell on
June 19, 1991. On June 19, 1991, EPA also made the updated Administrative
Record available for public review at EPA's offices at 90 Canal Street in
Boston and at the Pollard Memorial Library in Lowell, Massachusetts.
This decision document presents the selected
chosen in accordance with CERCLA, as amended
practicable, the National contingency Plan.
based on the Administrative Record.
remedial action at this Site,
by SARA and, to the extent
The decision for this Site is
IV.
SCOPE AND ROLE OF OPERABLE UNIT OR RESPONSE ACTION
The selected remedy was developed by cOmbining different source control and
management of migration components to obtain a comprehensive approach for
Site remediation. In summary, the remedy calls for in situ vacuum/vapor
extraction of approximately 137,000 cubic yards of contaminated soil.
Following this treatment, soil with residual contamination will be further
treated using a stabilization process. The stabilized soil will be
disposed of on site under an impermeable cap meeting federal requirements.
The remedy also includes active restoration of the overburden and bedrock
aquifers by pumping the contaminated groundwater and treating it by air
stripping.
This remedial, action will address the following potential risks to human
health and the environment posed by the site and resulting from:
1) Dermal absorption and incidental ingestion of contaminants in surficial
soils;
2)
Ingestion of groundwater;
3) Inhalation of volatile organic compounds (VOCs) from groundwater
seepage inside buildings at Lowell Iron and Steel and nearby residential
basements;
4)
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RECORD OF DECISION SUMMARy
Silresim site
Page .~
5) Direct contact with contaminants in surface water in the East Pond,
River Meadow Brook, and Concord River; and .
6) The continued release of contaminants from unsaturated soils to
groundwater.
~
v.
SUMMARy OF SITE CHARACTERISTICS
Chapter One of the Feasibility study contains an overview of the Remedial
Investigation. In addition to the Remedial Investigation prepared by the
Silresim Site Trust, EPA has prepared an addendum, referred to as the
Supplemental Remedial Investigation Report dated June, 1991. . The
supplement was developed to address data gaps related to the geologic and
hydrogeologic conditions at the site. The significant findings of the
Remedial Investigation and Supplemental Remedial Investigation are
summarized below: .
A.
General
The field investigation of the Remedial Investigation (RI) was. conducted
between 1985 and 1990. The RI assessed the type and extent of contaminants
present at the Site and included a risk assessment, which evaluated the
potential impacts .upon human health and the environment posed by Site
conditions. The RI provided baseline data required to evaluate potential
cleanup actions. Principal RI field activities included the collection an~
analysis of samples of groundwater, soil, sediment, surface water, and air.
These analyses identified approximately 100 individual contaminants in on-
site groundwater and soils. Primary among them were volatile organic
compounds (VOCs). In addition, metals, polychlorinated biphenyls (PCBs),
herbicides, pesticides, and dioxin were identified.
The field investigation of the .Supplemental Remedial Investigation was
conducted during the fall and winter of 1990/1991. The objectives were to
further determine the extent and distribution of dense non-aqueous phase
liquid (DNAPL) in the shallow overburden and bedrock, and the hydraulic
properties of bedrock at the Site. .
.
The following sub-sections summarize the findings of both investigations:
B.
Geology and Hydrogeology
The study area is underlain by fine-grained glacial outwash deposits
ranging from less than 20 to more than 100 feet thick. These soil deposits
consist predominantly of layered silty-sands and silts of lacustrine
deposition. These deposits are, on average, more than 80 feet in thickness
directly below the Silresim property. Underlying the lacustrine silts and
sands are thin discontinuous layers of galacial till (ablation and.
lodgement till) that form a veneer along the bedrock surface. Bedrock
below the property consists of gneiss that is moderately fractured and
faulted. Bedrock topography at the Site is dominated by a buried valley
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RECORD OF DECISION SUMHARY
si1resim Site
Page 7
that trends east-west under the Site.
The lacustrine silts and sands are a common proglacial feature of the
region. These deposits are characterized by layering in the upper 5 to 20
feet of overburden. The layering consists of alternating 1/8 to 1/4 inch
thick clay and one-inch thick sand layers. Hydraulic conductivities for
these lacustrine outwash deposits range betwee 0.1 t9 3.0 feet per day
(Figure 3, Appendix A).
The depth to groundwater at the Site and in the local area is appoximately
6 to 10 feet below the ground surface or the bottom of the clay cap over
the Si1resim property. The regional groundwater flow is north and west
toward River Meadow Brook. River Meadow Brook drains to the Concord River,
, which then joins the Merrimack River. Approximately 40 percent of
groundwater flow from the Site infiltrates into the 84-inch diameter 100-
year-old brick interceptor sewer just north of the Si1resim property.
Smaller quantities of flow discharge to branch sewers on Canada, Tanner,
and Maple Streets, with the balance (about 1 gallon per minute) flowing to
River Meadow Brook. The effects of the sewer lines, coupled with low
hydraulic conductivities of soils beneath the S"i1resim property, have
resulted in the mounding of groundwater beneath the si1resim property and
radial groundwater flow. Total groundwater flow leaving the Site ,is
estimated to be approximately 3 gallons per minute (gpm).
Average horizontal groundwater transport velocities have been estimated to
be approximately 85 feet/year in the upper portion of the overburden.
Transport velocities in the lower portions are believed to be significantly
lower. Observed downward vertical gradients beneath the Site are
apparently occurring due to groundwater mounding. Downward vertical flow
of groundwater is limited by layering of higher and lower permeability
sediments. Therefore, actual vertical flow is substantially less than
horizontal flow.
c.'
Groundwater
Volatile organic compounds (VOCs) were the predominant groundwater
contaminants identified. VOCs were detected in overburden groundwater and
in the bedrock.' The groundwater flow patterns cause the plume to extend
northwest to an interceptor sewer and southeast toward Maple Street.
Movement of this plume to the southwest and northeast is less extensive.
Much of the contaminated groundwater infiltrates into sewers, with the
remainder moving toward River Meadow Brook (Figure 4, Appendix A).
Approximately 70 groundwater wells were installed and monitored to develop
the conceptual groundwater flow patterns for the Site (Figure s, Appendix
A) ..
Approximately 70 different organic compounds were detected by sampling and
analyzing groundwater at the Site, with VOCs representing the highest
concent~ations. In the center of the plume, total VOC concentrations up to
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frequently encountered VOCs include trichloroethene (TCE), methylene
chloride, acetone, benzene, and 1,2-dichloroethane. The highest observed
, concentrations occurred both on and directly north of the Silresim
property, within the upper 40 feet of the aquifer/water table at monitoring
wells MW-309, MW-405, and MW-404. Maximum concentrations of individual'
VOCs detected in late 1988 in well MW-405B, which is located in the center
of the plume, were as follows:
CONTAMINANT
CONCENTRATION' (oom) .
Benzene
1,2-dichloroethane
Methylene chloride
styrene
Tetrachloroethene
1,1,1-trichloroethane
Trichloroethene
450
1,300
1,000
650
300
1,300
1,600
Elevated contaminant concentrations also occurred up to 120 feet below the
ground surface. In recent years, increased VOO levels have been measured
in the groundwater southeast of the Site, where the highest levels (in the
100 ppm range) were found 20 to 30 feet below ground ,surface.
While highest observed VOC levels generally occur within 10 feet of the
water table near the Silresim property, some wells further to the northwes~
(MW-407, 408 & 105) and southeast (MW-502) indicate that the highest VOC
levels occur at intermediate depths, about 15 to 20 feet below the water
table. This is believed to result from a combination of downward hydraulic
gradients and recharge from precipitation. The presence of slightly more
permeable zones in the overburden deposits may also influence migration in
these ar~as.
Although VOCs were detected most frequently and showed the highest relative
concentrations, semi-volatile organic compounds (extractable organics) were
also detected in the groundwater. The concentrations of total extractable
compounds in gr~undwater on and just north of the Silresim property
typically ranged from 0.1 ppm to 40 ppm. In general, data indicate only
limited migration of these constituents. Isophorone and 1,2-
dichlorobenzene were the most frequently detected extractable organics,
followed by benzoic acid and phenol. Dioxins were not detected in the
groundwater.
Elevated metals concentrations were found to be erratically distributed in
groundwater on the Silresim property. Isolated areas were identified
including high chromium (1.3 ppm at MW-4~4, 0.97 ppm at MW-406); nickel
(2.2 ppm at MW-404, 0.29 ppm at MW-405, 0.51 ppm at MW-406); and zinc (37
ppm at MW-404, 2.7 ppm at MW-406, and 1.'9 ppm at MW-309). Slightly
elevated arsenic concentrations (0.039 to 0.06 ppm) were found in
groundwater at MW-408, MW-407, MW-I01, MW-404, and MW-403. Iron was
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Dense non-aqueous phase liquid (DNAPL) has been detected in the shallow
overburden and shallow bedrock at two locations (MW-309, MW-405) near the
north-central border of the Silresim property. The DNAPL analyzed
consisted primarily of trichloroethene, tetrachloroethene, and 1,1,1-
trichloroethane.
Although regional and local hydrogeology primarily governs the migration
and distribution of dissolved contaminants at the Site, local stratigraphy
may have controlled the. downward vertical migration ofDNAPLs~ Data show.
that thin clay and silty-clay layers, which may act as retarding layers for
DNAPL, are found throughout the upper zone of lacustrine silt and sand
deposits in the top five to twenty feet of overburden. The lower zone of
the overburden includes the weathered bedrock-sediment interface and the
shallow bedrock. Although existing analytical data regarding the presence
of DNAPL are limited, its presence below these clay layers suggests that
the clay did not restrict DNAPL from the deeper overburden (Pigure 5,
Appendix A).
D.
soil
In evaluating the nature and extent of soil contamination and its potential
impacts within the study area, two distinct soil zones have been defined.
Surficial soils are those soils exposed at ground surface and extending to
a depth of 1 foot below ground surface. Soils deeper than 1 foot below
ground surface and above the water table are referred to as unsaturated
zone soils. This dis~inction is made in order to discuss differences in the
sources, types, and extent of contamination and differences in potential
exposure scenarios.
i.
surficial Soils
Most of the Silresim property is covered with gravel and clay, therefore,
the surficial soil sampling program addressed those soils outside the
Silresim perimeter fence. Contamination in the surficial soils beyond the
edges of the clay cap has been documented in primarily five areas (Figure
2, Appendix A). certain portions of the eastern perimeter were found to
. contain elevated levels of some metals, along with other contaminants.
Elevated concentrations of PCBs, certain metals, and trichlorobenz~ne were
found in samples collected from the southeast corner, while VOCs were the
predominant contaminants identified on the former Arrow Carrier property
just south of the Silresim property. Limited areas of the Lowell Iron and
Steel property were found to contain elevated levels of PCBs, VOCs, PAHs,
bis(2-ethylhexyl)phthalate and lead. Detectable levels of certain dioxin
and furan isomers were also found on the Lowell Iron and Steel property.
PCBs, VOCs, PAHs, and certain metals were found in the northeast corner.
Specific concent~ations.detected in each of these areas are listed below:
1. Along the eastern perimeter of the Silresim property, on the
Boston and Maine railroad grade, elevated levels of mercury (0.2 to
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RECORD OF DECXSXOH SUKMARY
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detected. VOC analysis in this area indicated that the majority of
samples had non-detectable to trace levels of total VOCs (up to 2.7
ppm TCE). PCBs were detected at levels ranging from 0.02 to 0.14 ppm.
Q
2. In the Southeastern corner of the Silresim property, dioxins,
furans, PCBs, metals and organics were detected. Total toxic
equivalence concentrations (TTEC) for dioxins and furans ranged from
0.00004 to 0.007 ppm. PCB Aroclor 1221 was detected as high as 1,500
ppm. Elevated levels of metals were detected, including mercury (63
ppm) and arsenic (640 ppm). VOCs in this zone were typically less
than 0.7 ppm, and extractable organics such.as 1,2,4-trichlorobenzene
were ?etected as high as 110 ppm.
3. In the area just south of the Silresim property (former Arrow
Carrier lot) VOCs are the most significant surficial soil
contaminants. TotalVOCs were detected as high as 210 ppm based on
the results of a screening. survey. Arsenic, mercury and chromium
concentrations were detected at 17.4 ppm, 5.73ppm and 1870 ppm
respectively. PCBs were detected at. low levels (less than 0.1 ppm).
PARs and phthalates were consistently founa at concentrations ranging
from 0.2 to 3.2 ppm. In addition, 752 ppm of 1,2-dichlorobenzene and
278 ppm of 1,4-dichlorobenzene were reported.
v
4. On the Lowell Iron and Steel property, north of the Silresim
property, elevated levels of PCBs, PARs, phthalates, dioxins, furans
and lead were detected in surficial soils. Total VOC concentrations
were detected as high as 46.7 ppm but were otherwise generally less
than 0.5 ppm. Total lead detected ranged from 526 to 7,850 ppm.
Total PAR and phthalates concentrations were as high as 2,255 ppm and
35 ppm, respectively. PCB Aroclor 1254 was detected as high as 4.6
ppm and total toxic equivalence concentrations for the dioxins and
furans were less than 0.0003 ppm.
5. In the northeast corner, PAR compounds totaling 13.2 ppm were
detected. Total VOC levels were less than 0.1 ppm and PCB Aroclor
1254 was found in two samples at concentrations less than 1 ppm.
Elevated levels of chromium (5,000 ppm) and slightly elevated levels
of arsenic (55 ppm) were observed~ .
ii.
Unsaturated Soils
The contaminants within the unsaturated zone at the Site are primarily
VOCs, although concentrations of extractable organics, metals, and dioxins
also occur sporadically (85 constituents were detected). The highest
concentrations are in the general vicinity of the clay-capped area.
.Elevated VOC levels in this zone extend from the base of the cap fill down
to the saturated zone (6 to 10 feet below surface grade). Within this
zone, VOC levels exceed 1,000 ppm at a number of locations. The highest
observed concentrations were detected in the north .central and central
portions of the cap (as high as 6,400 ppm of tetrachloroethene in the C-g
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RECORD OP DECISION SUHKARY
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test boring).
Total VOC levels in the
from 100 to 1,000 ppm.
northeast and northwest
southeast and northeast
unsaturated soil across the Site generally range
The lowest levels were detected underlying the'
corners of the Silresim property and to the
off the Silresim property.
The most commonly detected extractable compounds included phthalates, PAHs,
and chlorinated benzene. Maximum reported concentrations of these were in
the 10 to 500 ppm range. The only pesticides detected in more than one
sample were aldrin, lindane (Gamma BHC), Beta BHC, and 4,4-DDD, reported at
concentrations of 0.01 to 14 ppm in less ,than 10 percent of the samples
analyzed. Herbicides were detected during an earlier investigation
(Perkins Jordan," 1981) at levels between 0.25 and 7.5 ppm of 2,4-D and
2,4,5-TP. PCBs were detected at concentrations ranging from 0.03 to 65
ppm.
Arsenic, chromium, copper, lead, mercury, and zinc were detected
sporadically in the unsaturated zone soils. In general, the elevated
levels of arsenic (36 to 125 ppm) and mercury (~.5 to 19 ppm) were found
along the eastern perimeter of the Silresim property. Typically, average
concentrations of metals reported in unsaturated soils were within the
ranges for natural soils.
The total toxic equivalent 2,3,7,8-TCDD (dioxins) concentrations exceeded
one part per billion (1.96 to 10.42 ppb) at three locations near the
central and eas~ern portions of the Silresim property.
E.
Surface Water and Sediments
i., River Meadow Brook
Results from the most recent sampling event (Oct. 1989), as well as earlier
sampling, show that there is no consistent pattern of contamination in the
water or sediments of River Meadow Brook attributable to the site. The
highest levels of cadmium, chromium, copper and zinc in sediments were
found upstream 'of the Site. Extractable organic compounds including
dichlorobenzene and phenol, ranging in concentrations from 0.1 to 1.8 ppm,
were detected in the sediments. Levels of copper and zinc were similar in
upstream and downstream samples. VOCs including trichloroethene, toluene
and tetrachloroethene were found in the surface water at low levels
(primarily single parts per billion) during both sa~pling events. PCBs
were not detected in the water, but PCB Aroclor 1254 and 1260 have been
found at low levels (less than 0.5 ppm) in twO" downstream sediment samples.
Addit~onally, cyanide was detected at levels below 1 ppm in both the
surface water and sediment samples, upstream and downstream.
In general, significant concentration variations between upstream and
downstream samples were not noted. Existing groundwater samples collected
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RECORD OF DECISION SUMMARY
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Page 12
plume has not yet reached the Brook: therefore the detected contaminants
are likely to be the result of other sources, such as other area
industries. There are two major discharges to the Brook upstream of
Silresim. Additionally, there are. automobile junkyards and fuel storage
facilities along the Brook.
ii.
East Pond
Although surface water samples collected from East Pond indicated no
contamination, samples of Pond sediments taken closest to the site
contained low levels (1 to 20 ppb) of eight VOCs. Metals concentrations
fell withiR expected background ranges. Concentrations of extractable
organics ranged from 0.1 to.1.8 ppm in a sediment sample: PAHs were the
primary constituents observed. Because the detected substances are.
components of the Silresim plume, it is suspected that they reached East
Pond as a result of groundwater flow from the Site.
F.
Ur
Two air monitoring programs were conducted during the Remedial
Investigation. From 1985 through November 1986, the air vents in the clay
cap covering the Silresim property were sampled to characterize VOCs in the
vent emissions. Additionally, an indoor air sampling program was conducted
at Lowell Iron & Steel's facilities in October and December 1988.
.
The sampling results from the air vents indicate that vent number 4
contained the highest concentrations of target compounds as compared to
other vents. The most abundant compounds in that vent were 1,1,1-
trichloroethane (564 ppm), and trichloroethene (377 ppm). The
concentrations of other target compounds in vent number 4 ranged from below
the detection limit to 83.5 ppm. In the remaining vents, the relative
concentrations of target compounds were similar to those in vent number 4,
but total concentrations were lower. (It should be noted that air flow
rates from the vents were below measurable levels suggesting no significant
potential for off-site migration).
Ten individual VOCs were found in basement air in the Lowell Iron & Steel
operations (warehouse) facility, typically at levels below 2 ppb based on
an 8-hour average concentration. Specific compounds detected included
halogenated VOCs (l,l,l-trichloroethane, carbon tetrachloride,
trichloroethene, tetrachloroethene and trichlorofluoromethane), aromatics
(benzene, toluene, ethylbenzene and xylenes) and acetone. The primary
contaminants, based on relative concentrations, were acetone, 1,1,1-
Trichloroethane, toluene and xylenes.
Fourteen VOCs were reported in the basement air of the Lowell Iron and
Steel's administrative building. Specific constituents detected included
the 10 VOCs listed above as well as 1,1-dichloroethene, methylene chloride,
1,1-dichloroethane and chloroform. Eight-hour average concentrations for
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RECORD OF DECISION SUKKARY
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Page 13
chloride which was reported at a concentration of approximately 71 ppb~
, The sump from which these samples were collected is reportedly connected to
the neighboring 84-inch diameter interceptor sewer. It should be noted
that based on a review of groundwater data adjacent to the administrative
building, it is unlikely that the elevated levels of methylene chloride are
a result of the Silresim plume (the sump is reportedly connected to the 84-
inch diameter interceptor sewer adjacent to Lowell Iron and steel).
G.
Environmental and wildlife Habitat
The primary environmental receptors in the study area are River Meadow
Brook, East Pond and the B & M Railroad area. All three are urbanized,
altered, and geographically limited environments. None of these provide a
high level of valuable wildlife habitat as described under Massachusetts
Wildlife Habitat Policy Guidance. The low vegetative diversity, simple
biological community structure, and frequent presence of opportunistic
species indicate that these are dis~pted environments of minimal value as
wildlife or aquatic habitat.
River Meadow Brook near the site is severely impacted by upstream
industrial discharge. The stretch of Brook in this area meets little of
the descriptive criteria which guides state regulatory policy concerning
wildlife habitat. The Brook and associated banks are of marginal value to
wildlife and aquatic biota due to anthropogenic changes to the stream
course and banks, upstream industrial effects on water quality (does not,
meet Class Bstandards), and the general urban,pave~, and,altered
environment adjacent to the stream bank. Vegetative structural diversity
is low, and the observed high suspended load in the water makes the
presence of freshwater clams or mussels unlikely. The trees are generally
too young and small to provide cavities for shelter of small animals or
bird nests. Most portions of the Brook have steep banks, and little
vegetation overhangs them to provide cover or perches. The bushes and
saplings do not supply fallen logs or debris extending into the Brook.
, .
East pond has no observable surface inlet or outlet and is filled at its
southern end and completely denuded of trees all around its banks. The
entire perimeter of this small pond is physically disturbed and has few
characteristics ascribed to valuable wildlife habitat~ There is no shrub
or canopy cover, no overhanging branches ~nd little structural diversity.
The banks are dominated by nearly monospecific stands of Purple
Loosestrife, an oppOrtunistic species which thrives in disturbed
environments.
The B & M Railroad area is a mixed grassland and woodlot habitat. The
woodlot is dominated by Aspen, a pioneer species, which indicates recent
physical disturbance in the area. Local1y, the trees may support small
bird populations, and the grassland may support rodent populations and
serve as an occasional feeding area for carnivorous birds. The habitat is
not extensive enough, however, to provide breeding habitat for such
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RECORD OF DECISION SUMMARY
Si1resim Si~e
Page 14
development, railroad corridors, and pavement, and is not large or
vegetatively diverse enough to support large wildlife populations.
A complete discussion of Site characteristics can be found in Chapters 4
through 6.of the Remedial Investigation Report at Pages 21 to 90.
VI.
SUKMARY OF SITE RISKS
A Risk Assessment (RA) was performed to estimate the probability and
magnitude of potential adverse human health and environmental effects from
exposure to contaminants associated with the Site. The Risk
Assessment.followed a four step process: contaminant identification (which
identified those hazardous substances which, given the specifics of the
site were of significant concern); exposure assessment (which identified
actual or potential exposure pathways, characterized the potentially
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RECORD OP DECISION SUHMARY Paqe 15
silresim site
TABLE 1
SILRESIM SITE
CONTAMINANTS OP CONCERN
contaminants Groundwaterl Vent Indoor
of Concern Surface Water Soils Emissions Air
Acetone X
Arsenic X X
. Benz ene X X X X
Bis(2-ethy~hexyl)phthalate X X
2-Butanone X
Carbon Tetrachloride X X X
Chlorobenzene X X
Chloroform X X X X
.Chromium X X
Copper X
l,l-Dichloroethane X X
1,2-Dichloroethane X X X
l,l-Dichloroethene X X X X
1,2-Dichloroethene X
Dioxins X
Ethylbenzene X
Lead X
Methylene Chloride X X X X
Mercury X
Nickel X
PAHs X
PCBs X
Phenol X
Selenium X
styrene X
Tetrachloroethene X X
1,1,2,2~Tetrachloroethane X X
Toluene X X X
1,2,4-Trichlorobenzene X X
1,1, I-Trichloroethane X X X X
Trichloroethene X X X X
Trichlorofloromethane X
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RECORD OF DECISION SUMMARY
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Page 16
toxicity assessment (which considered the types and magnitude of adverse
human and environmental effects associated with exposure to hazardous
substances); and 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 and
environmental risks). The results of the public health risk assessment for
the Silresim Site are discussed below.
Table I (above) lists the contaminants of concern for each medium. The
Remedial Investigation Report presents detailed information regarding the
concentrations and frequency of detection for each indicator substance in
each medium.
There were 33 contaminants of concern selected for evaluation in the Risk
Assessment. These contaminants constitute a representative subset of the
more than 102 contaminants identified at the Site during the Remedial
Investigation. The 33 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 of the contaminants ~f concern can be found in
Section 7.22, pages 95 to 102, of the Risk Assessment in the March, 1990
Remedial Investigation (RI) report. -
Potential human health effects associated with exposure to tbe contaminants
of concern were estimated quantitatively through the development of severa'
hypothetical exposure pathways. These pathways were developed to reflect
the potential for exposure to hazardous substances based on present and
potential future land uses. For each pathway evaluated, a more-likely and
a reasonable worst-case exposure scenario was developed. Unless otherwise
specified, the more-likely case scenario corresponds to the risks computed
based on the average concentration of contaminants detected in the
particular medium, and the worst-case risk scenario corresponds to the
maximum concentrations per medium. Evaluations were based on an integrated
model of site contaminant characteristics and the locations and activities
of identified receptor populations. For those exposure scenarios for which
a source of contamination, potential receptors, and a route for. exposure
exists, a quantitative evaluation was completed. Exposure scenarios that
do not meet these criteria are discussed in qualitative terms. The
fOllowing is a brief summary of the exposure pathways evaluated. A more
thorough description can be found in Section 7.33, pages 109 to 118, of the
RI Risk Assessment. .
A.
Current and Pu~ure Poten~ial Exposure Pathways
i.
Soils
EXDosure to Soils. Under the Cap: A majority of the total
contaminant mass associated with the Site is contained in the soils
directly under the clay cap. In January 1978, a chain-link fence was
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RECORD OF DECISION SUMMARY
silresim si~e
paqe 17.
property. In January 1983, the Si1resim property was qraded, a clay cap
averaging 14 inches in thickness was then placed over a layer of qrave1;
and the fence was extended to a height of 8 feet. Ten PVC vents, extending
5 feet above the cap were installed as part of the cap. In addition,
crushed stone was placed over areas of surficial soil adjacent to the
southeast and northeast sections of the Site. The purpose of these
temporary remedial responses was to limit direct access to contaminated
soils and to minimize the release of VOC and particulate matter into the
air.
Although the clay cap supports vegetative growth and is regularly
maintained; portions of its surface are noticeably cracked and eroded. The
presence of the fence minimizes the accessibility of Si1resim property to
children and trespassers, and therefore to minimize the direct exposure to
soil under present conditions. Additionally, the gravel cover in the
fenced northeast and and southeast corners minimizes the potential for
exposure.
A potential impact on air quality from VOCs released from unsaturated soils
may exist under the current conditions. VOCs may be released into the air
through cracks in the clay cap, although quantitative measurements of the
extent of the releases were not conducted. Instead an evaluation of air
quality impacts from emissions from vents located on the site was performed
in the Risk Assessment using an advection-dispersion. model. Although
detectable levels of VOCs were indicated in the vents, no measurable flow
was detected, which would suggest no adverse risk due to VOC emissions from
the vents. However, variable climatic conditions may lead to changes in
flow rates from the vents and contaminant emissions may increase. Under
these conditions, residents located downwind from the Si1resim property may
be impacted by VOCs released from the vents. Potential exposures to
emissions from vents have been evaluated based on the results of the
dispersion model using assumed flow rates and levels of compounds reported
inside the vents. It was assumed that an off-site resident may inhale
contaminated air for 70 years.
Under future conditions, the further disturbance of the clay cap and
failure of the surrounding fence may create a source for direct exposure to
soils. Neighborhood children playing on the Si1resim property are the most
likely receptors. The potential routes for exposure for this group are
direct contact with soils and incidental ingestion of soils. This risk has
been quantified using present case contaminant concentrations detected in
the unsaturated soils under the cap. Dermal contact and incidental
ingestion of soils was evaluated for a school-aged child aged 5-18 years
who may be exposed 20 days per year for 14 years. The amount of soils
ingested was assumed to be 0.1 gm/day and the soil was assumed to cover the
arms and hands.
Exposure to Soils Off the Silresim Propertv: Five areas
located immediately outside the Si1resim fence have been found to contain
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RECORD OP DECISION SUMMARY
Si1resim Si~e
Page 18
perimeter (B & M Railroad property); the southeast corner; the former Arrow ~
Carrier property south of the fence; the Lowell Iron & Steel property north
. Qf the Silresim property; and the northeast corner. As discussed earlier,
portions of areas adjacent to the southeast and northeast sides of the Site
are covered with crushed stone to prevent direct contact. 0
The contaminants in these soils may present a current threat to human
health through direct contact, inhalation of VOCs released from the soil,
and from inhalation of particulates carrying contaminants. Inadvertent
ingestion of small amounts of uncovered contaminated soil by workers from
adjacent businesses, children playing near these areas, joggers and
motorbike riders could potentially occur. Therefore, an evaluation has
been completed of the potential exposures and risks associated with
incidental ingestion of and direct contact with surficial soils (upper one
foot of soil) off the silresim property.
At each area outside the Silresim fence, incidental ingestion of 0.1 gm/day
contaminated soils was assumed for a child aged 5-18 years,. 120 days per
year for 14 years. Dermal absorption of contaminated soil at each location
was also assumed for a child aged 5-18, 120 days per year for 14 years. In
addition, for adult employees at Lowell Iron and Steel, a dermal exposure
scenario was developed corresponding to contact with the arms and hands for
10 days each year for 20 years.
ii.
Groundwater
.
Drinkinq Water Supplv Wells: Groundwater in the area is not
currently being used as a drinking water source because public water is
provided to the area. Therefore, only future use of the groundwater as a
drinking water supply was evaluated as a potential exposure pathway. The
aquifer Qelow the site is classified by the Federal Government and the
Commonwealth of Massachusetts as a Class IIB and I aquifer, respectively.
Groundwaters assigned to these classes are defined as being fresh waters
found in the saturated zone of unconsolidated deposits or consolidated rock
and bedrock, and are designated as a source of potable water supply.
The installation of private drinking water wells in residential areas
underlain by contaminated groundwater, could create a potential exposure
and therefore a risk. The results of the solute transport analysis
indicate that the groundwater plume is not likely to reach the vicinity of
the Robinson Street residential neighborhood located north of the Site;
however, contaminants in groundwater may reach the four residential streets
to the south of the Site in the future.
Under the potential future condition that groundwater may be used as a
drinking water source in the vicinity of the Site, the exposures to
contaminants may potentially occur through ingestion, dermal absorption, or
inhalation of vapors. For the ingestion of contaminated groundwater, it
was presumed that an adult may ingest 2 liters of undiluted water per day
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RECORD OF DECISION SUHMARY
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Page 19
groundwater at the Site were used for the worst-case and more-likely case
ingestion exposure scenarios, respectively.
Basement Seepaqe: Groundwater flow originating at the site may
impact residences and industries through the seepage of water into
basements and indirectly through the volatilization of compounds through
soils which are saturated with contaminated groundwater. The inhalation of
vapors released from the water leaking into basements is expected to be the
primary route of exposure if this condition occurs. In addition, receptors
may be exposed to contamination through direct contact with basement soils,
resulting from infiltration of groundwater.
Lowell Iron and Steel property is presently located within the boundaries
of the contaminated groundwater plume. The basement areas of their
storage/operating building are frequented by employees on a daily basis for
variable durations. Their basement is partially earthen and has been known
to flood. Therefore, inhalation of contaminated air by Lowell Iron and
Steel employees is a current potential exposure. For this exposure
scenario it was presumed that the seepage would be undiluted groundwater
based on the solute transport model (worst-case) and from detected
concentrations in an adjacent well (more-likely case). The worst-case
exposure estimate was calculated based on an adult employee who may be
exposed to contaminated air 3 hours per day, 10 days per year, for 20
years, while the more-likely case assumed 1.5 hours of exposure 5 days per
year for 5 years. For dermal contact with contaminated soils inside Lowell
Iron and Steel's storage facility, it was assumed that the arms and hands
of an employee may be exposed for 3 hours per day to contaminated soils for
similar durations.
Residential basement seepage was not considered a current potential
exposure pathway because existing data indicates that the contaminated
plume does not extend to the residential areas. However, in the future,
the plume may reach residences to the south of the site; For future
basement seepage into the nearest residential dwelling, it was presumed
that a resident may be exposed to contaminated air 1 hour a day for 70
years for the worst-case scenario, and .5 hours per day, 5 days per year
. for 70 years for the more-likely case scenario. These exposure scenarios
also assumed that the seepage would be undiluted groundwater based .on the
solute transport model (worst-case) and from actual concentrations in an
adjacent well (more-likely).
The sewer lines in the vicinity of the site have been found to influence
groundwater flow patterns and to act as interceptors of groundwater
originating from the site. The 84-inch diameter sewer line appears to
receive most of the primary groundwater flow. Based on a solute transport
analysis, maximum total.VOC concentrations discharging to the sewer were
calculated. Although it is expected that VOCs in the sewerage would
experience significant reduction through aeration or removal with solids,
the potential inhalation by residents downwind and in close proximity to
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RECORD OP DECISION SUMHARY
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Page 20
exposure based on modelled concentrations. It was presumed that an
individual may be exposed to 20 cubic meters per day of contaminated air
continuously for 70 years.
iii.
Surface Waters
River Meadow Brook and Concord River: River Meadow Brook has been
assigned a class B status by the Commonwealth of Massachusetts, and is
therefore designated for the uses of protection and propagation of fish,
other aquatic life and wildlife, and for primary and secondary contact
"recreation. In the future, the Silresim groundwater plume may reach the
Brook. Al~hough the potential use of the Brook in the vicinity of the Site
for recreational purposes is unlikely due to the physical characteristics
and degraded conditions, dermal contact with and ingestion of contaminated
water from River Meadow Brook, has been evaluated. For incidental
ingestion of contaminated Brook water, it has been presumed as part of the
worst-case scenario that children aged 5-18 may ingest 0.05 liters of
water, 3 days per year for 14 years. For dermal absorption, it has been
assumed as part of the worst-case scenario that a child may be completely
immersed in the Brook for a total of 2 hours per day, 2 days per year for
14 years.
Additionally, the potential future environmental impacts on the surface
water of River Meadow Brook and Concord River were evaluated.
Specifically, a qualitative comparison of predicted concentrations (using
solute transport model) of indicator substances in the brook to freshwater
aquatic life was evaluated. The comparison was based on predicted
concentrations under low-flow (worst-case) and average flow (more-likely
case) in River Meadow Brook and Concord River. This comparison assumes
that organisms in the Rivers are exposed under similar conditions and
respond similarly to organisms for which Federal Water Quality Criteria
(FWQC) were established.
River Meadow Brook ultimately flows to the Concord River which is also a
Class B river. Although the contaminants entering River Meadow Brook would
be attenuated in concentration before impacting Concord River, future
exposure thr~ugh dermal absorption and incidental ingestion could occur and
was therefore evaluated. The exposure assumptions for incidental ingestion
and dermal absorption of contaminated water in Concord" River are the same
as those listed above for River Meadow Brook.
East Pond: East Pond has not been classified by the Commonwealth of
Massachusetts. However, it could potentially be used for recreational
activities such as swimming and rafting. The Pond is small and shallow
during the summer months and recreational use is expected to be infrequent
and of short duration. .
Although the Silresim.plume appears to have only minimally affected the
sediment and surface waters of East Pond, a solute transport analysis has
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incidental ingestion and dermal absorption of contaminated surface water
from East Pond were quantified based on predicted future concentrations
from the transport model. The worst-case exposure assumptions for the
incidental ingestion of surface water for East Pond are the same as those
listed above for River Meadow Brook and Concord River except the frequency
of exposure was presumed to be 15 days per year. For dermal absorption, it
was assumed that a child may be completely immersed in the Pond 2 hours per
day, 15 days per year for 14 years as part of the worst-case exposure.
The potential future environmental impacts from the surface water in East
Pond were evaluated. Specifically, a qualitative comparison of predicted
concentrations (based on the solute transport model) of indicator
substances"in the Pond to freshwater aquatic life was evaluated. The
comparison was based on the predicted low flow concentrations entering into
East Pond. This comparison assumes that organisms in the Pond are exposed
under similar conditions and respond similarly to organisms for which WQC
were established. .
B.
Risk Characterization
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.
Current EPA practice considers carcinogenic risks to be additive when
assessing exposure to a mixture of hazardous substances.
The hazard quotient was also calculated for each pathway as EPA's measure
of the potential for non-carcinogenic health effects. The hazard quotient
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 individuals over the
course of a lifetime and they reflect a daily exposure level that is likely
to be without an appreciable risk of an adverse health effect., RfDs are
derived from epidemiological or animal studies and incorporate uncertainty
factors to help ensure that adverse health effects will not occur. The
hazard quotient 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 quotient
is only considered additive for compounds that have the same or similar
toxic endpoints (for example: the hazard quotient for a compound known to
produce liver damage should not be added to a second whose toxic endpoint
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Table 5, found in Appendix B of this ROD, summarizes the adverse human
health effects for the exposure pathways identified in the previous
section. Risks have been evaluated in the context of risk management
criteria utilized by EPA. Paraphrasing the National Contingency Plan, an
acceptable excess upper bound lifetime cancer risk is one which falls
within the range of 10-4 and 10-6. For the non-carcinogenic effects, a
hazard index less than one generally indicates an acceptable exposure
level. A qualitative discussion of the risks is provided below:
i.
Summary of CUrrent Potential Risks
Exposures to surficial soils beyond the Silresim property fence were
evaluated for five distinct areas. Risks calculated for all five of these
areas were comparable for noncarcinogenic effects, with cumulative hazard
indices under the worst-case and more-likely scenarios being less than one,
except for the south corner (3 x 10+1) as a result of dioxins and PCBs, and
Lowell Iron & Steel (1.8) due to lead under the worst-case scenario.
Under the worst-case cancer risk scenario the cumulative risk estimates for
the dermal contact and ingestion of soils at the B & M Railroad property,
southeast corner, and Lowell Iron & Steel property exceed the 10-4 to 10-6
acceptable cancer risk range. The cumulative risk estimate for each area
was 2 x 10-4, 3 X 10-3, and 8 x 10-4, respectively. ~one of the cancer or
non-cancer risk projections for the ingestion of and de~al contact with
soils from any of the five areas exceeded EPA's acceptable risk values
under the more-likely case exposure scenarios. The cancer risks for each
of the five areas beyond the Silresim fence is attributable almost entirely
to the presence of arsenic and carcinogenic PAHs, with the exception being
in the southeast corner and at Lowell Iron and Steel where PCBs and dioxins
presented the most signigicant risk. .
For the basement seepage scenario at Lowell Iron and Steel, the cancer. risk
estimate under a worst-case scenario for the inhalation pathway is 1 x
10~1. This. risk was due in large part to an array of VOCs detected in
groundwater, including 1,2-dichloroethane and trichloroethene. Under the
more-likely scenario, the cancer risk estimate was 4 x 10-6. The risk from
inhalation exposures in the basement of Lowell Iron and Steel during a dry
period is considerably lower for this scenario, based on measured
concentrations. Under the worst-case assumptions, the hazard index is
significantly less than 1 (1 x 10-z) and the cancer risk is 2 x 10-5. .
Possible exposures to airborne VOc emissions from the cap vents were
quantitatively evaluated at the nearest residential receptors assuming a
continuous lifetime of exposure. The worst-case cumulative cancer risk
estimate is I X 10-5 while the more-likely case excess cancer risk estimate
fell below the acceptable risk range of 10-4 to 10-6. 1,1-dichloroethene
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ii.
Summary of Future Potential Risks
'presuming no further substantial remedial activities, it was assumed that
both the fence and cap will occasionally be simultaneously impaired which
could lead to exposure to contaminated soil on the Silresim property. The
ingestion of and direct contact with soil on the Silresim property by
children were evaluated assuming worst-case and more-likely case scenarios.
Under both scenarios, hazard indices were less than one for exposure
through ingestion of soil and the cumulative cancer risk estimates did not
exceed the acceptable risk range. The worst-case cumulative hazard index
and cancer risk estimate for dermal contact with soil on the Silresim
property slightly exceeded the benchmarks of 1 and 1 x 10-4, respectively.
Dioxin, cPAHs and arsenic were three of the major contributors to these
risk projections. More-likely case risk projections were within or below
acceptable levels for cancer and non-cancer endpoints.
Risk associated with the future ingestion of Site groundwater has been
evaluated under a worst-case and a more-likely case scenario and both were
found to exceed the acceptable risk levels for carcinogenic and non-
carcinogenic endpoints. Projected cancer risks for both the more-likely
and the worst-case scenarios were in excess of 1 x 10-2. Maximum
concentrations of nearly all indicator substances exceeded their respective
MCLs including, carbon tetrachloride, 1,2-dichloroethane,
tetrachloroethene, trichloroethene and benzene. The hazard quotients under
each scenario were found to exceed one for most indicator substances.
A portion of the Site groundwater plume has been projected to move beneath
the nearest residence south of the Site in the future. The
characterization of non-carcinogenic and carcinogenic risk which may result
from inhalation of volatile contaminants in basements under a worst-case
scenario yielded a cumulative hazard index of app-roximately one and a
cumulative excess cancer risk estimate of 2 x 10-2. Under a more-likely
scenario based on modelled concentrations the calculated cumulative hazard
index was less than one and the cancer risk estimate slightly greater than
10-5.. The main contributors to these risk estimates were VOCs incl~ding
1,2-dichloroetha~e and TCE which were detected in groundwater.
For the evaluation of volatilization of site chemicals from sewage entering
the Duck Island Wastewater Treatment Plant and the resulting impact to the
nearest neighborhood, a simple advection/dispersion model was used to
project ambient VOC concentrations. For both the more-likely and worst-
case scenarios, hazard indices and incremental lifetime cancer risk
estimates were less than one and 10-6, respectively.
For exposures related to contact with surface waters of River Meadow Brook,
East Pond, and the Concord River, only the excess cancer risk attributable
to dermal contact with surface water in East Pond based on projected
concentrations exceeded 10-4, at 1 x 10-3 and 3 x 10-4 for the worst-case
and more-likely case scenarios, respectively. The major contributers to
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dichloroethene. All other cancer risk estimates for surface water bodies
fell within or below the acceptable risk range. Similarly, for the non-
cancer endpoints, dermal contact with East Pond surface water was projected
to present the greatest risk. Carbon tetrachloride was projected to exceed
its reference dose as part of the evaluation of both the worst-case and
more-likely case chronic exposure scenarios.
iii.
" r
Summary o~ Potential BDviroDmenta1 Risks
An Environmental Risk Assessment was conducted as well to determine the
effects th~t site contaminants could pose to the surrounding environment.
Three potential environmental receptors near the site were evaluated,
including River Meadow Brook, East Pond, "and the B & M railroad area. It
was determined that none of these three areas exhibit the characteristics
which describe valuable wildlife habitat in Massachusetts. They are not
structurally diverse, are often dominated by opportunistic species, "
surrounded by urban and industrial land, and are obviously degraded as
wildlife or aquatic habitat by activities unrelated to the Silresim Site.
No endangered species have been identified at the Site.
The potential environmental threat to aquatic life from the future
discharge of contaminated groundwater into East Pond, River Meadow Brook
and the Concord River was evaluated. Surface water quality expected in the
future was qualitatively compared to the predicted concentrations of
indicator substances .in each water body. The predicted concentrations for
ten indicator substances in the three surface waters were less than the
respective Water Quality criteria (wQC) under both the worst-case and more-
likely case scenarios. WQC were not available for two of the indicator
substances (2-butanone, methylene chloride). It should be noted that
detectable levels of VOCs could reach River Meadow Brook within about
nine years given a starting date of 1990.
Based on the findings of this evaluation, it was not necessary to identify
response objectives to mitigate threats to the environment. However; the
response objectives developed for public health exposure to soils and
" groundwater would provide adequate. protection to the environment.
iv.
Conclusion
In summary and as presented in Table 5 in Appendix B of this document,
cumulative incremental lifeti~e cancer risk estimates were calculated to be
greater than 10-4 for the following worst-case exposure pathways:
*
Ingestion and dermal absorption of soils on B & M Railroad property
(arsenic); southeast corner (dioxins, PCBs, and arsenic); and Lowell
Iron & Steel property (carcinogenic PAHs);
Inhalation exposures at Lowell Iron & Steel operational facility from
groundwater seepage into a basement (VOCs);
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*
Future dermal absorption of soil from the unsaturated zone on the
Silresim property (VOCs and semi-VOCs);
Future ingestion of groundwater as a drinking water supply (organic
and inorganic compounds);
*
*
Future inhalation exposure at a residential receptor near North Main
street from groundwater seepage into a basement (VOCs); and
Future, dermal absorption of surface water from East Pond (VOCs).
*
Cumulative hazard indices calculated for the evaluated exposure pathways
were generally less than one. However, several pathways were noted to have
instances in which an observed or projected concentration for a given
compound was predicted to exceed an acceptable value (usually a reference
dose) when worst-case exposure a~sumptions were used. These pathways
include a subset of the pathways listed above found to pose unacceptable
cancer risks.
Maximum concentrations of all groundwater indicator substances exceeded the
applicable regulatory standard set or proposed under the Safe Drinking
Water Act - Maximum contaminant Levels (MCLs) and Maximum contaminant Level
Goals (MCLGs), except for dioxin, which were not detected in the
groundwater, and PAHs detected in low concentrations only.
In terms of the environmental assessment, it was determined that none of
the three environmental receptors (East Pond, River Meadow Brook/Concord
River, B & M) exhibit the characteristics which describe valuable wildlife
habitat in Massachusetts. The predicted concentrations for ten indicator
substances in the three surface water bodies were less than the respective
WQC .under both the worst-case and more-likely case scenarios.
It should be noted that the findings of the Silresim Risk Assessment were
dependent on numerous assumptions and subject to many uncertainties
inherent in the risk assessment process. The findings are not an absolute
characterization of actual risk, but rather serve to highlight potential
sources of risk at the site. Although the range of uncertainties have not
been quantified, the use of conservative assumptions and parameters
throughout the assessment would be expected to err on the side of
protection of human health and the environment.
Consequently, 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 and the environment. Specifically an imminent and substantial
threat to public health could result from the contaminated soils, surface
waters, air, and groundwater in proximity to the site.
For a complete explanation of risks posed by contamination at the Silresim
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silresim RI report, which is available at the information repositories.
VII. DEVELOPMENT AND SCREENING OP ALTERNATIVES
A. Statutory Requirements/Response Objectives
Under its legal authorities, EPA's pri~ary 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 utilizes permanent solutions and alternative
treatment technologies or resource recovery technologies to the
maximum extent practicable; and a preference for remedies in which
treatment which permanently and significantly reduces the volume,
toxicity or mobility of the hazardous substances is a principal
element over remedies not involving such treatment. ' Response alterna-
tives were developed to be consistent with these congressional-
mandates.
Based on preliminary information relating to types of contami-
nants, environmental media of concern, and potential exposure
. pathways, remedial action objectives were developed to aid in the
development and screening of alternatives. These remedial action
objectives were 'developed to mitigate existing and future potential
threats to human health and the environment. These response
objectives were: '
1. Prevent direct contact and incidental ingestion exposure to
contaminated surficial soils at' the Site (located on and off the
Silresim property);
2. Prevent future migration of contaminated groundwater to a
hypothetical water supply well, thereby reducing risks from ingestion
of contaminated 4rinkinq water;
3. Prevent contaminated groundwater discharge to surface waters,
thereby reducing risks from dermal absorption and ingestion exposures
to contaminated surface water and sediments; and
4. Prevent contaminated groundwater flow toward buildings,
thereby reducing risks from inhalation exposures.
B. Technology and Alternative Development and Screening
CERCLA and the NCP set forth the process by which remedial actions are
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range of alternatives was developed for the Site.
with respect to source control, the RI/FS developed a range of
alternatives in which treatment that reduces the toxicity, mobility,
.or volume of the hazardous substances is a principal element. This
range included an alternative that removes or destroys hazardous
substances to the maximum extent feasible, eliminating or minimizing
to the degree possible the need for long term management. This range
also included alternatives that treat the principal threats posed by
the site but vary in the degree of treatment employed and the
quantities.and characteristics of the treatment residuals and
untreated waste that must be managed; and a no action/limit~d action
alternative that involves no treatement but provides limited
. protection through engineering or institutional controls.
with respect.to ground water response action, the RI/FS developed a
limited number of remedial alternatives that seek to attain site
specific remediation levels using different technologies; and a no
action alternative.
As discussed in Chapter 5 of the Feasibility Study, the RI/FS
identified, assessed and screened technologies based on imple-
mentability, effectiveness, and cost. These technologies were
combined into source control (SC) and management of migration (MM)
alternatives. Chapter 6 of the Feasibility Study presented the
remedial alternatives developed by combining the technologies
identified in the previous screeping process with the categories
identified in section 300.430(e) (3) of the NCP. The purpose of the
initial screening was to narrow the number of potential remedial
.actions for further detailed analysis while preserving a range of
options. Each alternative was then evaluated and screened in Chapters
8 and 9 of the Feasibility Study.
In summary, of the 15 source control and 5 management of migration
remedial alternatives screened, 9 of the source control and 4 of the
management of migration alternatives were retained for detailed
analysis. Tables 6 and 7 in Appendix B identify the alternatives that
were retained through the screening process, as well as those that
were eliminated from further consideration.
VIII.
DESCRIPTION OF .ALTERNATIVES
This section provides a narrative summary of each alternative retained
for detailed analysis. A detailed assessment of each alternative can
be found in Tables 11-11 and 12-6 of the Feasibility Study.
A.
Source Control (SC) Alternatives Analyzed
The Source Control alternatives that underwent detailed analysis for
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SC-l:
No-Action/Minimal Action
Cover System On and Off the Silresim Property
SC-2:
SC-3:
Vacuum/Vapor Extraction and Cap on the Silresim
Property
Vacuum/Vapor Extraction, Stabilization and Cap
on the Silresim Property .
SC-4
SC-6
Thermal Desorption, Stabilization and Cap
on the Silresim Property .
Incineration, Stabilization and Cap
on the Silresim property
SC-lO
SC-ll
Vacuum/Vapor Extraction, Incineration,
Stabilization and Cap on the Silresim Property
SC-14
Vacuum/Vapor Extraction, Solvent Extraction,
Stabilization and Cap on the Silresim Property
SC-l5
Vacuum/Vapor Extraction, Solvent Extraction,
Stabilization, Off-Site Disposal and Cap on
the Silresim Property
1.
SC-l NO-Action/Minimal Action
This alternative was evaluated in detail in the FS to serve as a baseline
for comparison with the other remedial alternatives under consideration.
Under this alternative, contaminated soil would remain on-site and no
contaminants would be removed, treated or destroyed. SC-1 would include
measures to prevent exposure and to restrict access to the Site.
Because access to areas of soil contamination outside of the existing
perimeter fence is unrestricted, an extension of the perimeter fence and
paving or placement of crushed stone over contaminated areas would be
conducted. New sections of fence would encircle the contaminated soil
zones near the east side, the northeast corner, and the southeast corner of
the Site. After the additional fencing is installed, the existing cap.
would be extended into the newly-fenced areas. Capping of these soils
would further reduce direct contact exposures to surficial soils.
Additionally, eroded areas of the existing cap would be repaired and
regularly maintained.
A public education program would be initiated to inform the public about
potential hazards at the Site. The program would include public meetings,
presentations, local newspaper articles, and direct mailings to public
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Institutional controls would include access, deed and land use
restrictions. These controls would be pursued through legal channels to
restrict or prevent the potential use of contaminated areas. Access
restrictions could include laws providing for levying of fines against
trespassers. Deed and land use restrictions would limit future uses of the
Site, and would require appropriate permits, supervision, and health and
safety procedures for any intrusive work done on site.
Any monitoring wells within proposed work areas not intended for
long-term monitoring would be decommissioned. Wells in proposed
intended for long-term monitoring would be extended or protected
necessary. -
Long-term monitoring would record and allow evaluation of trends in
contaminant concentration. Monitoring would consist of sampling and
analyses of soil at selected locations at five-year intervals.
use in
work areas
as
The 1986 CERCLA amendments require that conditions be reviewed every five
years at NPL sites where wastes remain on site. As alternative SC-1 would
result in wastes remaining on Site, this five-year review process would be
mandatory. All data obtained in this monitoring program would be evaluated
in the five-year reviews. The reviews would consider all relevant data and
determine if additional remedial actions are necessary.
2.
ESTIMATED TIME FOR DESIGN AND CONSTRUCTION: One Year
ESTIMATED TIME FOR OPERATION: One Year
ESTIMATED CAPITAL COST: $564,000
ESTIMATED 0 & M (Present Worth): $485,000
ESTIMATED TOTAL COST (Present worth): $1,050,000
CaD On and Off the silresim PrODertv
SC-2
Under this alternative, all soils contaminated above the cleanup levels
would be covered with a low-permeability cap conforming to Resource
Conservation and Recovery Act (RCRA) Subtitle C standards (the existing cap
on t~e Silresim property would be upgraded). Contaminated soil would
, remain on Site, and no contaminants would be removed, treated, or
destroyed. The cap would prevent direct contact with contaminants ,in
surficial soils, minimize inhalation exposure, and limit rainwater
infiltration and therefore contaminant migration in the groundwater.
Fence construction, posting of the Site, public education programs,
decommissioning of wells, and institutional controls would be implemented
as described under Alternative SC-1.
Under this alternative, the existing cap (including the crushed stone cap
in the northeast corner of the Site) would be upgraded to conform to RCRA
standards. The upgraded cap would, at a minimum, consist of at least 3
feet of low permeability (~ 10.7 cm/sec) soil liner including: 6 inches of
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Page 3r
filter fabric, 2 feet of final cover, and seed and mulch.
in all areas would be from 3 percent to 33 percent.
Under this alternative, the cap would be extended over a significantly
larger area than under alternative SC-l. The proposed areal extent of the
cap includes any area where soil contaminant concentrations have been
observed in excess of the target cleanup goals. These areas would have to
. be prepared appropriately so that the cap could be constructed. Site
. preparation activities may include Site grading and removal of debris,
fences, scrap vehicles, etc.
Final cap grades
Construction of the fence and the RCRA cap would be accomplished using
common, well-demonstrated construction practices. Numerous RCRA cap
installations are already in place, and standard construction procedures
exist for the installation of all components. Construction of a RCRA cap
outside of the current Silresim 'fence would involve coordination with the
adjacent property owners. Easements and ~ccess to adjacent property areas
would have to be obtained (true for all alternatives considered)..
Implementation of this alternative would not be likely to result in
significant additional environmental impacts, because no contaminants would
be removed, treated or destroyed. Adequate control measures would be
instituted to reduce VOC and dust emissions. Some disturbance to adjacent
properties to be capped would occur, but these are not areas of siqnifican
environmental sensitivity.
It is estimated that all components of Alternative SC-2 would be
implemented within two years after the completion of remedial design.
Because contaminated materials would remain on Site, long-term monitoring
and' five-year reviews would be implemented as described under Alternative
SC-l. All data obtained in the monitoring program would be evaluated in
the five-year reviews to determine if additional remedial actions are
necessary.
3.
ESTIMATED TIME FOR DESIGN AND CONSTRUCTION: One Year
ESTIMATED TIME FOR OPERATION:. Two years
ESTIMATED CAPITAL COST: $4,900,000
ESTIMATED 0 & M (Present Worth): $468,000
ESTIMATED TOTAL COST (Present worth): $5,370,000
In Situ Vacuum/VaDor ExtractioD and Cap
SC-3
This alternative involves in situ vacuum/vapor extraction to remove
primarily VOCs (and potentially semi-VOCs) from the unsaturated soils.
Following the remediation of soil to cleanup levels for VOCs, soil outside
of the current Silresim fence exceeding cleanup levels for non-VOCs would
be excavated and consolidated on the Silresim property under a final RCRA
Subitle C cap. The areas off of the Silresim property would be backfilled
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The RCRA cap would be implemented as described under Alternative SC-2.
However, under this alternative, the extent of the RCRA cap would not be as
large as that proposed under SC-2 because contaminated soil outside of the
Silresim fence would be treated or removed. Approximately 137,000 cubic
yards of contaminated soils would be treated by a vacuum/vapor extraction
system using wells and/or trenches. vacuum/vapor extraction is a process
which removes VOCs from unsaturated soils by using vacuum pumps or blowers
to induce air flow towards a trench or a network of extraction wells. VOCs
from soil and water desorb into this air stream for further treatment prior
to release to the atmosphere.
-
To enhance the effectiveness of vacuum/vapor extraction and to reduce
direct contact exposures, the existing clay cap would be extended and
upgraded as discussed above under alternative SC-1. Areas off of the
Silresim property to be treated using vacuum/vapor extraction would be
covered with a low-permeability cover. This interim cover will induce a
radial air flow through the soil and prevent vertical short circuiting of
air flow in the vicinity of each extraction trench or well during the
period of operation of the vacuum/vapor extraction system.
.
A treatability study was performed to evaluate the effectiveness of
vacuum/vapor extraction on silresim site soils (test results are presented
iri Appendix F of the RI). Results of the test showed that VOC cleanup
levels can be attained for most target compounds. The results of the
treatability testing, along with information on soil characteristics
obtained during the RI, were used as input for a two-dimensional soil gas
flow model to assess the time required to attain cleanup levels with
various well/trench spacings. Preliminary results indicate that close well
spacings would be required to provide acceptable cleanup times. Trenches
would allow somewhat wider spacing (18 trenches of varying length, with a
nominal spacing of 45 feet), and increased effectiveness in ac~ieving goals
in heterogeneous soils. Trenches would be installed to the water table, to
depths up to 14 feet (due to dewatering to lower the water table).
The estimated times to achieve VOC cleanup levels for the soils.at the site
are: .
approximately three years for the gravel fill on the Silresim
property which is part of the existing cap (placed in 1984).
approximately five years for the cinder and miscellaneous fill
material throughout the site. .
approximately 30 years for the natural sandy silts throughout the
Site.
The results of the treatability study indicate that vacuum/vapor extraction
would provide relatively short-term reduction of VOC concentrations in the
fill layers, but would need to be undertaken for a longer term to achieve
cleanup levels in the lower-permeability natural soils.
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Waste streams from vacuum/vapor extraction include a VOC-contaminated vapor
stream and collected condensate. Off-gas treatment by fume incineration
(thermal oxidation) with scrubbing would be employed for the vapor stream.
Collected condensate from the vacuum/vapor extraction system and aqueous
. wastes from the scrubber could be either treated on Site and discharged or
shipped off Site for treatment.
Following vacuum/vapor extraction, approximately 3,000 cubic yards of soil
off of the Silresim property still contaminated with non-VOC's and
inorganic compounds would be excavated and consolidated with appoximately
15,000 cubic yards of soil on the Silresim property. A final RCRA Subtitle
C cap as described above under alternative SC-2 would be installed over the
contaminated soil located primarily on the Silresim property (also onto
limited areas just northeast and southeast of the property).
The aboveground spatial requirements of this alternative are relatively
small, consisting primarily of a building to house the vacuum/vapor
extraction equipment. Use of areas off of the Silresim property may be
required if soils are to be stockpiled before placement under the RCRA cap.
Similar to SC-2, construction of a portion of the RCRA cap into areas off
of the Silresim property would involve coordination with the adjacent
property owners. .
Potential adverse environmental impacts that may result from excavation
activities at the Site include erosion of contaminated soil, generation of
contaminated stormwater runoff, and VOC emissions to the atmosphere.
Drainage and erosion control structures (e.g., stacked hay bales and silt
fences) would be placed prior to excavation to reduce the potential for
environmental threats. Stacked hay bales and silt fences, if properly
emplaced, are established and reliable means of drainage and erosion
control. Disturbed vegetation areas would be revegetated following the
completion of remediation activities. .
VOC emissions would be reduced by the application of vapor suppressing
foams, or the erection of domes or air sealed "tents" over work areas.
Exhaust air from the domes or vents would be treated to remove VOCs prior
to discharge. Releases of particulate matter during excavations would be
controlled by the application of water sprays, dust suppressant chemicals
(e.g., calcium chloride), and/or specialized excavation equipment (e.g.,
caisson augers). These control measures are likely to be reliable in
reducing most emissions from small-scale excavation activities, such as
those proposed for the vacuum/vapor extraction systems under Alternatives
SC-3, SC-4, SC-ll, SC-l4 and SC-l5.
This alternative would reduce potential risks for direct contact and
inhalation exposures by vacuum extraction of VOC-contaminated soils, and
the excavation and placement of soils with concentrations of other
constituents above cleanup levels under the RCRA cap. This alternative
would also reduce potential human and environmental risks associated with
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page 33
RECORD OF DECXSXON sUMMARY
silresim si~e
unsaturated-zone soils, and by the limitation of infiltration and therefore
leachability of contaminants into groundwater.
Because contaminated materials would resain on site (i.e., heavier organicS
and metals), long-term monitoring and five-year reviews would be
implemented as discussed under Alternative SC-l. AdditionallY, fencing and
posting signs at the site, institutional controls, public education
programs and access restrictions would be instituted as described under
alternative SC-l. Data obtained in the monitoring program would be
evaluated in the five-year reviews, and the need for fu~er remedial
actions would be assessed.
ESTIMATED TXME FOR DESIGN AND CONSTRUCTION. 2 to 3 years
ESTIMATED TIME FOR OPERATION: 30 years
ESTIMATED CAPITAL COST: $7,272,000
ESTIMATED 0 & M (present Worth): $1,745,000
ESTIMATED TOTAL COST (present worth): $9,020,000
In Bitu vacuum Va or Extraction Btabilization and ca
4.
Alternative SC-4 involves treating unsaturated-zone soils by in situ
vacuum/vapor extraction for removal of VOCs, followed by excavation and
stabilization/solidification of soils exceeding cleanup levels for non-
VOcs, followed by on-site containment of treated soils under a RCRA
subtitle C cap. Excavation would be performed onlY for those unsaturated-
zone soils exceeding cleanup levelS for non-VOCs. Removal of VOCS prior to
excavation and fu~er treatment reduces the volume of soils to be
excavated, and reduces health risks associated with VOC emissions during
excavation.
As described above, approximatelY 137,000 cubic yardS of contaminated soil
on and off the silresim property would be subject to vacuum/vapor
extraction. Following an estimated 5 years of vacuum/vapor extraction,
approximatelY lB,OOO cubic yards of soil contaminated with non-VOCs and
inorganic compounds (metals) above cleanup levels, would be excavated,
stabilized and permanentlY disposed of on the silresia property.
stabilization is a process by which the waste is either converted into a
more chemically stable form or to a more solid fcrm by mixing it with a
binding material such as cement. This process is intended to reduce the
waste solubility, mobilityand/or toXicity and to limit the potential for
contaminant migration into the groundwater by reducing the exposed surface
area. Because stabilization involves .the addition of reagents to the soils
to be treated, the volume of soil would be expected to increase by 20 to 60
percent. The excavated areas off of the silresim property would be
backfilled with clean fill.
Following stabilization, the RCRA Subtitle C cap would be constructed over
the stabilized material primarilY on the silresim property as described
above under SC-2.
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RECORD OP DECISION SUMMARY
silresim Site
Page 34
It is estimated that all components of Alternative SC-4 would be
implemented within seven years after the completion of remedial design,
although approximately 30 years would be required to achieve cleanup levels
in the natural soils. This assumes that cleanup levels for VOCs in soils
to be excavated and stabilized are reached in approximately five years,
that stabilization would be implemented within one-half year (assuming a
production rate of 180 cubic yards per day), and that the cap would be
constructed in approximately one and one-half years. As with Alternative
SC-3, cleanup levels forVOCs in the natural soils would be attained in .
approximately 30 years.
Most of the Site area is expected to require excavation. . Although some
portions of the Site would be available for siting of equipment,
facilities, and stockpiles, some areas off of the Si1resim property may be.
necessary (property access/easements). It appears likely that available
space would exist on the Si1resim property for longer-term facilities such
as the treatment bui1ding(s), so that areas off of the Si1resim property
could be used mainly for the stockpiling of soils and stabilization
operations. . .
This alternative would reduce potential risks for direct contact and
inhalation exposures by vacuum/vapor extraction of VOC-contaminated soils,
by stabilization of soils with concentrations of other constituents above
cleanup levels, and by placement of stabilized soils under a RCRA Subtitle.
C cap. This alternative would also reduce potential human and
environmental risks associated with the migration of contaminants in
groundwater by removing unsaturated-zone VOCs, by significantly reducing
the leachability of semi-VOCs, PCBs, metals and potentially dioxins through
stabilization, and by reducing infiltration throug~ the placement of a RCRA
cap.
Potential adverse environmental impacts associated with excavation and
. stabilization activities were discussed under alternative SC-3. Proposed
impact controls include established and reliable means of drainage, erosion
and emissions controls. VOC emissions generated during the operation of
the vacuum extraction system would be controlled by a fume incinerator with
a scrubbing system. This system is an established and reliable means of
VOC emission control.
Because contaminated materials would remain on site in a
stabilized form, long-term monitoring and five-year reviews would be
implemented as described under alternative SC-l. Additionally, fencing and
posting signs at the Site, institutional controls, public education
programs and access restrictions would be instituted as described under
alternative SC-l. Data obtained in the monitoring program would be
evaluated in the five-year reviews to determine if further remedial actions
are required.
ESTIMATED TIME FOR DESIGN AND CONSTRUCTION: 2 to 3 years
ESTIMATED TIME FOR OPERATION: 30 years
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RECORD OF DECISION SUMMARY
silresim site
Page 35
ESTIMATED CAPITAL COST: $8,637,000
ESTIMATED 0 & M (Present Worth): $1,986,000
ESTIMATED TOTAL COST (Present worth): $10,620,000
5.
SC-6
Thermal Desorntion, stabilization an~ Cap
Alternative SC-6 includes excavating soil with concentrations of VOCs,
semi-VOCs, dioxins, metals and PCBs above cleanup levels. These soils
would be treated using thermal desorption, and replaced on Site under a
"RCRA Subtitle C cap. The ability of thermal desorption to achieve
cleanup levels at the Silresim Site (particularly"those for PCBs and
dioxins) has not been demonstrated; therefore, laboratory" and/or pilot
testing would be required during the Remedial Design stage. Thermal
desorption does not destroy or stabilize metals. Metals may be present in
a more leachable form after treatment. Treated soils that exceed TCLP
limits or cleanup levels would be stabilized prior to disposal within the
limits of the cap located primarily on the Silresim property.
Under this alternative, approximately 50,000 cubic yards of soils "off of
the Silresim property and approximately 87,000 ~ubicyards on the Silresim
property would be excavated and treated using thermal desorption. Thermal
desorption is a process similar to incineration, except lower temperatures
are used. contaminants are stripped or driven off heated soils, and are
either burned in a secondary combustion chamber and scrubbed to reduce acid
gas and particulate emissions, or are separated from the gas stream by
condensing, quenching, and/or absorbing in a scrubber solution for further
treatment. Scrubber water would be treated either on Site or shipped off
site for treatment.
Prior to treatment with thermal desorption, crushing/shredding of soil
clods and screening of large objects (e.g., scrap metal, rocks, etc.)
would be performed. This can result in a loss of volatile organic
compounds and particulates directly to the atmosphere, and provisions for
containment and control of emissions within the excavation and soils
handling areas would be required. To reduce these emissions, aggressive
measures would be taken. These measures would include the application of
vapor suppressing foams and/or the erection of massive domes or air-sealed
"tents" over work areas. After treatment, soils would be tested to see if
cleanup levels are exceeded. Clean fill would be used to backfill off-site
excavations.
A bench or pilot-scale study with Site soils would be necessary to assess
thermal desorption operating parameters (i.e., temperature, pollution
control and auxiliary fuel requirements) and to assess removal efficiency
for contaminants of concern, especially PAHs, PCBs and dioxins. It should
be noted that soil moisture is typically the major factor in energy
consumption and treatment time for thermal desorption. Moist soils such as
those at Silresim will require a higher energy input and treatment time
than drier soils.
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RECORD OF DECISION SUMMARY
silresim Site
Page 36
Following thermal desorption, soil still contaminated above target cleanup
levels would be stabilized according to the methods described above under
alternative SC-4. The stabilized mass would be disposed of primarily on
the Silresim property and capped with a RCRA cap (constructed as described
above under alternative SC-2).
The major constructability issue involved in this alternative is the
substantial excavation of contaminated soils. The area to be excavated
includes all of the Silresim property and substantial areas outside of the
Silresim fence. To allow room for soil stockpiles, thermal desorption and
stabilization equipment, and other facilities, it is likely that access to
areas outside of the Silresim property will need to be obtained.
It is estimated that all components of SC-6 would be implemented within
eight years after the completion of remedial design. Thermal desorption
production rates typically range from 75 to 100 cubic yards per day for
soils with VOCs and low molecular weight semi-vocs. Longer residence times
would be necessary for heavier organics. Therefore, lower production rates
would be required. At a rate of 60 cubic yards per day, thermal desorption
would take approximately six years to treat 137,000 cubic yards of soil.
stabilization would be implemented within approximately one-half year.
Installation of the cap would take approximately one and one-half years.
This alternative would reduce potential risks for direct contact and
inhalation exposures through the treatment of VOCs and semi-VOCs present ir
soils at levels above cleanup levels. Reductions in PCBs and dioxin
concentrations are uncertain; therefore, the magnitude of residual risks
due to these co~pounds cannot be evaluated until further testing is
completed. This alternative would also reduce potential human and
environmental risks associated with the migration of these contaminants to
groundwater through the treatment of contaminated subsurface soils and the
limitation of infiltration, and therefore leachability, of contaminants
into groundwater. Although metals will not be affected by the thermal
desorption process, risks associated with direct contact of metals in soils
and potential leaching into groundwater would be reduced by stabilization
prior to capping.
Potential adverse environmental impacts that may result from excavation
activities at the site are discussed above under alternative SC-3.
Proposed impact controls include established and reliable means of drainage
and erosion control. The emissions control measures may be less reliable
for completely controlling emissions from the large-scale excavation
efforts proposed under this alternative. VOC emissions generated during
the operation of the thermal desorption system would be controlled by the
secondary combustion chamber and the scrubbing" system. This system is an
established and. reliable means of VOC emission control.
Because contaminated materials would remain on Site, long-term monitoring
and five-year reviews would be implemented as described under alternative
SC-2. Additionally, fencing and posting signs at the Site, institutional
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RECORD OF DECrSrON SUMMARY
Si1resim Si~e
Page 37
controls, public education programs and access restrictions would be
instituted as described under alternative SC-1. All data obtained in this
monitoring program would be evaluated in the five-year reviews to determine
if further remedial actions are required.
ESTIMATED TIME FOR DESIGN AND CONSTRUCTION: 2 to 3 years
ESTIMATED TIME FOR OPERATION: 8 years
ESTIMATED CAPITAL COST: $50,307,000
ESTIMATED 0 & M (Present Worth): $947,000
ESTIMATED TOTAL COST (Present worth): $51,250,000
6~
se-10- On-si~e Incinera~ion. S~abi1iza~ion and CaD
Alternative SC-10 would treat contaminated soils by excavation and on-.site
. incineration. Incinerated soils with residual contamination above target
cleanup goals would be stabilized and disposed of on Site under a RCRA
Subtitle C cap.
Again, approximately 137,000 cubic yards of soil both on and off the
Silresim property would be excavated and incinerated. Inciner~tion is the
controlled destruction of organic matter (VOCs, semi-VOcs, and heavier
organics such as PCBs and dioxin) that results in the reduction in volume
and toxicity of contaminated soils, liquids, and gases. On-site
incinerators can be installed on a permanent basis: however, mobile units
are typically used for shorter-term projects. Incinerators generally use
either a rotary kiln, circulating bed, or infrared system, each of which
are described in more detail in Chapter 5 of the Silresim FS.
All incineration systems produce three types of effluents: combustion
gases, ash, and scrubber water. Air pollution control equipment would be
required to meet emission limits for combustion gases~ which typically
contain hydrochloric acid and particulates. Scrubber water from the air
pollution control devices is neutralized using a solution of sodium
hydroxide, which precipitates as a salt. The scrubber water is generally a
low volume stream and can be treated together with wastewater generated
from other site activities, such as groundwater extraction and dewatering
operations. Incinerator ash contains metals; these metals typically.
oxidize as a result of the high temperatures and presence of excess air in
the combustion chamber and may be hazardous. The ash would be stabilized
prior to disposal. .
This alternative involves excavating contaminated soils and transporting
them to an on-site incinerator. Before incineration, the soils would be
prepared by crushing, grinding, screening, and/or drying. Similar to
alternative SC-6, some form of VOC and particulate emissions control would
be required during these operations. The effectiveness of incineration at
the Silresim Site would require a pilot study (test burns).
Following incineration, soils would be tested to see if cleanup levels have
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RECORD OP DECISION SUMMARY
Silresim Si~e
Page 38
levels would be stabilizep according to the method described above under
alternative SC-4, assuming that only metals-contaminated soils would
'require this treatment. The stabilized mass would be disposed of primarily
on the Silresim property under a RCRA Subtitle C cap. Excavations off of
the Silresim property would be backfilled with clean fill.
It is estimated that all components of Alternative SC-10 would be
implemented within eight years after the completion of remedial design.
This assumes that excavation and incineration activities would be completed
in approximately six years (assuming a treatment rate of 100 tons per day),
that stabilization would be implemented within the next one-half year
(assuming some overlap between incineration and stabilization activities),
and the cap would be installed in the next one and one-half years.
Most of the site area would require excavation. Although some portions of
the Silresim property would be available for siting of equipment,
facilities, and stockpiles, use of areas outside of the Silresim property
would be necessary. Available space would exist on the Silresim property
for longer-term facilities such as the treatment building(s), so that areas
off of the Silresim property would be required for the incineration and
stabilization portions of the project.
This alternative would reduce potential risks for direct contact and
inhalation exposures through the treatment of VOCs, semi-vocs, dioxins, and
PCBs present in soils at levels above cleanup levels. Although metals
would not be removed or destroyed by the incineration process, direct
contact and leaching related risks would be prevented through stabilizatio
and capping. This alternative would also reduce potential human and
environmental risks associated with contaminant migration into groundwater.
Potential adverse environmental impacts that might result from excavation
activities at the Site are discussed under alternative SC-3 and SC-6.
Proposed 'impact controls include established and reliable means of drainage
and erosion control. The emissions control measures may be less reliable
for completely controlling emissions from the large-scale excavation
efforts proposed under this alternative. VOC and particulate emissions
during the operation of the incinerator would be controlled by off-gas
treatment and a scrubbing system. .
Because contaminated materials would remain on-site, long-term. monitoring
and five-year reviews would be implemented as described under alternative
SC-1. Additionally, fencing and posting signs at the Site, institutional
controls, pUblic education programs and access restrictions would be
instituted as described under alternative SC-l. All data obtained in this
monitoring program would be evaluated in the five-year reviews to determine
if further remedial actions are required.
ESTIMATED TIME FOR DESIGN AND CONSTRUCTION:
ESTIMATED TIME FOR OPERATION: 8 years
ESTIMATED CAPITAL COST: $53,879,000
ESTIMATED 0 & M (Present Worth): $956,000
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RECORD OF DECISION SUMMARY
silresim sit:e
Page 39
ESTIMATED TOTAL COST (Present worth):
$54,840,000
SC-ll In sit:u vacuum/vanor Ext:ract:ion. Incinerat:ion. st:abilizat:ion and
Can
Under this alternative, approximately 137,000 cubic yards of contaminated
soil would be remediated on Site by in situ vacuum/vapor extraction as
described under alternative SC-3. Vacuum/vapor extraction would be used to
reduce the volume of soils requiring incineration by remediating VOC-
contaminated soils in situ. After acceptable VOC concentrations in soil
have been achieved through vacuum/vapor extraction, soils having
concentrations of semi-VOCs, PCBs, and dioxins above cleanup levels
(approximately 18,000 cubic yards) would'be excavated and incinerated as
described above under alternative SC-10. Following incineration,
approximately 6,000 cubic yards of incinerated soil with metals and other
contaminants above cleanup levels would be stabilized and disposed of .
primarily on the Silresim property under a RCRA subtitle C cap (constructed
as described under alternative SC-2). .
7.
Treatment residuals include a contaminated air stream and scrubber waters
from both the incineration process and the vacuum/vapor extraction system.
Contaminated air would be subjected to off-gas treatment and scrubbed to
reduce acid gas and particulate emissions. Scrubber water would be treated
either on site, or shipped off site for treatment. Although contaminant
concentrations in the scrubber water are likely to be high, quantities
should be relatively'low.
Like alternative SC-10, most of the Site area is expected to require
excavation, but to a lesser extent. Although some portions of the Silresim
property would be available for siting of equipment, facilities, and
stockpiles, use of areas off of the Silresim property would be necessary.
Available space would exist on the Silresim property for longer-term
facilities such as the treatment building(s), so that areas off of the
silresim property would be required for the incineration and stabilization
portions of the project.
It is estimated that ali components of alternative SC-11 would be ,
implemented within eight years after the completion of remedial design,
although approximately 30 years would be required to achieve cleanup levels
for VOCs in the natural soils. This assumes that VOC cleanup levels for
the materials to be excavated would be reached in approximately five years,
that incineration would be completed in approximately one year (assuming a
production rate of 100 tons per day), that stabilization would be
implemented within the next one-half year (assuming a produ~tion rate of
180 cubic yards per day), and the cap would be installed in the next one
and one-half years.
This alternative would reduce potential risks for direct contact and
inhalation exposures through the vacuum/vapor extraction of VOCs, and the
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RECORD OP DECISION SUMMARY
8ilresim Site
Page 40
PCBs. Although metals will not be affected by vacuum extraction or
incineration, risks associated with direct contact of metals in soils and
potential leaching into and migration in groundwater will be reduced by
stabilization prior to capping. This alternative would also reduce
potential human and environmental risks associated with the migration of
these contaminants in groundwater.
The environmental impacts and controls are similar to those described under
'alternatives SC-4 and SC-6; VOC and particulate emissions during the
operation of the incinerator and vacuum/vapor extraction system would be
controlled by off-gas treatment including a scrubbing system.
, ,
Because contaminated materials would remain on Site, long-term monitoring
and five-year reviews would be implemented as described under alternative
SC-2. Fencing and posting signs at the Site, institutional controls,
public education programs and access restrictions would be instituted as
described under alternative SC-l~ All data obtained in this monitoring
program would be evaluated in the five-year reviews to determine if further
remedial actions are required. '
ESTIMATED TIME FOR DESIGN AND CONSTRUCTION: 2 to 3 years
ESTIMATED TIME FOR OPERATION: 30 years
ESTIMATED CAPITAL COST: $15,182,000
ESTIMATED 0 & M (Present Worth): $2,040,000
ESTIMATED TOTAL COST (Present worth): $17,220,000
8.
8C-14 Vacuum/VaDor Extraction. Solvent Extraction.
stabilization. and Cap
Alternative SC-14 is similar to SC-ll, except that solvent extraction would
be performed instead of incineration. Approximately 137,000 cubic yards of
unsaturated VOC-contaminated soils would be treated in situ for VOCs using
vacuum/vapor extraction. Following vacuum/vapor extraction, 18,000 cubic
yards of soil exceeding the cleanup levels for non-VOCs and inorganics
would be excavated and treated using solvent extraction. Following solvent
extraction, 6,000 cubic yards of soil would be stabilized, assuming that
only metals contaminated soils would require this treatment;.
Solvent extraction is a technology which consists of using a solvent to
extract organic compounds and metals from soils. Sol vent E~xtraction ,
systems using triethylamine (TEA) or liquid propane to remove PCBs and
other organic compounds are available and in service.
Separate phase extracted organics from the solvent extraction process would
either be destroyed on Site in,a small liquid injection incinerator, or
temporarily stored on Site until permitted off-site incineration capacity
becomes available. Process wastewaters would contain some contaminants,
and would be treated at an off-site facility or in the groundwater
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RECORD OF DECISION SUHMARY
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Page 41
Performance data from system manufacturers indicate that residual PCB
concentrations in soils were less than 1 mg/kg (the PCB cleanup level for
the Silresim Site) in 2 of 14 test cases. Residual PCB concentrations
appeared to show little dependence on initial PCB concentrations; rather;
soil characteristics appear to be a major factor in process performance.
Removal efficiencies exceeded 98.5 percent (the efficiency that would be
required at the Silresim Site for the maximum observed. PCB concentration of
65 mg/kg) in 10 of the 14 cases, which suggests that the cleanup level may
be achievable. However, bench-scale study of this technology would be
necessary to verify that the PCB cleanup level can be achieved.
Bench-scale testing would also be used to assess the effect of the reported
high concentrations of styrene on the solvent extraction process. The
latter compound may be of concern because easily-polymerized materials
interfere with solvent extraction by "competing" with the solvent for
organic molecules. The cinder f.ill materials at the Site may also present
similar problems.
Following solvent extraction, 6,000 cubic yards of soil with contaminants
above cleanup levels (metals) would be stabilized arid redeposited on the
Silresim property under a RCRA Subtitle C cap as described above under
alternatives SC-4 and SC-2, respectively.
All components of Alternative SC-14 would be implemented. within eight years
after the completion of remedial design, although approximately 30 years
would be required to achieve cleanup levels in the natural soils. This
assumes that VOC cleanup levels for the materials to be excavated would be
reached in approximately five years, that solvent extraction would be
completed in approximately one year (assuming a production rate of 100 tons
per day), that stabilization would be implemented within the next one-half
year (assuming a production rate of 180 cubic yards per day), and the cap
would be installed in the next .one and one-half years. As with Alternative
SC-3, cleanup levels for VOCs in the natural soils would be attained in
approximately 30 years.
This alternative would reduce potential risks for direct contact and
inhalation exposures through the vacuum/vapor extraction of VOCs, and
solvent extraction of heavier organic target compounds such .as semi-VOCs,
including PAHs. However, residual concentrations of PCBs and dioxins may
be above cleanup levels. Risks associated with direct contact of metals in
soils and potential leaching and migration in groundwater would be reduced
by stabilization prior to capping. This alternative would also reduce
potential human and environmental risks associ~ted with the migration of
these contaminants in groundwater.
The potential adverse environmental impacts and controls are similar to
those described under alternative SC-3; VOC emissions during the operation
of the vacuum/vapor extraction system would be controlled by fume
incineration with scrubbing. Fugitive emissions from the solvent
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RECORD OP DECISION SUKKARY
si1resim Si~e
Page 42
as necessary.
Because contaminated materials would remain on Site, long-term monitoring
and five-year reviews would be implemented as described under alternative
SC-2. Fencing and posting signs at the Site, institutional controls,
public education programs and access restrictions would be instituted as
described under alternative SC-l. All data obtained in this monitoring
program would be evaluated in the five-year reviews to det~ermine if further
remedial actions are required.
ESTIMATED TIME FOR DESIGN AND CONSTRUCTION: 2 to 3 yecirs
ESTIMATED TIME FOR OPERATION: 30 years
ESTIMATED CAPITAL COST: $9,991,000 .
ESTIMATED 0 & M (Present Worth): $854,000
ESTIMATED TOTAL COST (Present worth): $10,850,000
9.
SC-15 Vacuum/VaDor Ex~raction. Solven~ Extraction.
stabilization. Off-site DisDosal
This alternative is similar to alternative SC-14, except that treated soils
would be disposed of off Site. This alternative includes "acuum/vapor
extraction of approximately 137,000 cubic yards of soil to remove VOCs,
followed by excavation and solvent extraction of 18,000 cubic yards of soil
to reduce concentrations of semi-Vocs and PAHs to below cleanup levels.
Removal of VOCs prior to excavation and further treatment reduces the
volume of soils to be excavated, and reduces health risks associated with.
VOC emissions during excavation. Soils exceeding cleanup levels for metals
alone (6,000 cubic yards) would be stabilized as described under
alternative SC-4. Stabilized soils would be disposed of at a location off
Site. Excavations would be backfilled with clean fill, and covered with a
RCRA Subtitle C cap (constructed as described under alternative SC-2).
This alternative involves the removal and transportation of large volumes
of. soil off Site toa RCRA-permitted landfill. Soils would need to be
excavated, staged, and shipped off-site in accordance with U.S. Department
of Transportation (DOT) and RCRA regulations. . Staging of soils would be
simpler if off-site stabilization were chosen because no dedicated area.
would be required for this process, and the volume of soil to be handled
and shipped would drop significantly (by approximately one-third). The
amount of soils to be sent off Site would be large, and locating a RCRA-
permitted landfill which accepts dioxin contaminated waste and could
guarantee capacity may not be feasible. CUrrently, there are no licensed
facilities in the United States that are available to accept dioxin
contaminated soil. The solvent extraction process may not reduce dioxin
concentrations below the proposed cleanup level of 0.001 mg/kq. If no
dioxin disposal facilities can be located, dioxin-contaminated soils would
be reconsolidated on Site, stabilized, and covered with a RCRA cap.
The estimated timeframe to meet the objectives is essentially the same as
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RECORD OF DECISION SUMMARY
silresim site
paqe 43
would be implemented within approximately 30 years after the completion of
,remedial design.
Metals would not be treated under this alternative, but would be converted
to a less-mobile form. This alternative would reduce exposure risks
associated with inhalation exposures and direct contact and ingestion of
unsaturated-zone and surficial soils, and limit rainwater infiltration and
therefore contaminant migration in groundwater.
The potential adverse environmental impacts and controls are similar to
those described under Alternatives SC-3: VOC emissions during the operation
of the vacuum/vapor extraction system would be controlled by fume
incineration with scrubbing. Fugitive emissions from solvent extraction
and stabilization systems would be monitored, and actions taken as
necessary. Off-site disposal operations and facilities would conform to
DOT and RCRA regulations.
Because contaminated materials would remain on Site during the period that
the vacuum/vapor extraction system is in operation, a monitoring program
and five-year reviews would be implemented as described under Alternative
SC-2. Fencing and posting signs at the Site, institutional controls,
public education programs and access restrictions would be instituted as
described under Alternative SC-l. All data obtained in the monitoring
program would be evaluated in the five-year reviews to determine if further
remedial actions are required.
ESTIMATED TIME FOR DESIGN AND CONSTRUCTION: 2 to 3 years
ESTIMATED TIME FOR OPERATION: 30 years
ESTIMATED CAPITAL COST: $17,765,000
ESTIMATED 0 & M (Present Worth): $854,000
ESTIMATED TOTAL COST (Present worth): $18,620,000
B.
Management of Migration (MM) Alternatives Analyzed
Management of migration alternatives address contaminants that have
migrated from the original source of contamination. At the Si1resim Site,
contaminants have migrated from the Si1resim property into groundwater
primarily northwest toward River Meadow Brook and southeast toward Maple
Street (flow is not limited to these directions, however). The Management
of Migration alternatives evaluated for the site include the following
alternatives:
MM-l:
No Action/Minimal Action
MM-2:
Groundwater Extraction, Metals Pretreatment, Air Stripping,
Aqueous Phase Carbon Adsorption, Vapor Phase Carbon
Adsorption or Thermal Oxidation
MM-3:
Groundwater Extraction, Metals Pretreatment, Steam
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Page 44
MM-4:
Carbon Adsorption or Thermal Oxidation
Groundwater Extraction, Metals Pretreatment, UV/Chemical
Oxidation, Vapor Phase Carbon Adsorption or Thermal
Oxidation
i.
Groundwater Extraction and Treatment
The principal objectives of groundwater remedial action are to eliminate or
minimize, to the maximum extent practicable, the threat posed to the public
health, welfare, and the environment by the current extent of contaminated
groundwater, and meet Federal and State drinking water quality standards
(ARARs) to-return the aquifer to its beneficial uses. The estimated time
to achieve interim cleanup levels is contingent on aquifer characteristics,
contaminant characteristics, plume mass and areas of extraction. EPA is
unable to reliably predict when cleanup levels at the points of compliance
can be achieved. However, it is anticipated that cleanup levels at the
point of compliance will be achieved in no less than thirty years.
Alternative's MM-2, MM-3, and MM-4 each include a groundwa'ter extraction
and treatment system, and a system for discharge of treated water. The
groundwater extraction system would collect contaminated groundwater from
the aquifer and move the groundwater to the surface for treatment. The
treatment system would consist of a series of treatment processes to reduce
the concentrations of contaminants requiring removal. The discharge syste~
would consist of a means to deliver the treated water back to the aquifer,
to the City of Lowel1 sewer system or to River Meadow Brook.
For each of the groundwater extraction and treatment alternatives
groundwater extraction wells would be installed in the overburden and
shallow bedrock, strategically located to intercept groundwater
contamination migrating toward vulnerable receptors (basements, East Pond,
River Meadow Brook). The extraction system would be designed to maximize
contaminant recovery rates. The estimated maximum total flow rate from all
the wells for each alternative is approximately 2S gallons per minute
(gpm). Potential short-term impacts to the wetlands of East Pond during
the installation of a potential extraction well would be minimized by
drainage and erosion control measures, including stacked hay bales and silt
fences. These'controls, when properly emplaced, are reliable means' of
drainage and erosion control.
Gravity separation of contaminated water from non-aqueous phase
contaminants such as floating product and DNAPL would be accomplished using
a tank sized to allow qravity separation of aqueous and non-aqueous phase
contaminants at the design flow rate. Floating product wou~d be skimmed
from the surface: dense ,non-aqueous phase contaminants would be removed
from the bottom of the tank. The remaining aqueous stream would flow by
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A pretreatment step would be necessary to remove iron and manganese prior
to primary treatment to reduce clogging of the system and reduce iron and
manganese concentrations to within discharge limits. As indicated in the
RI, iron concentrations up to 268 mg/l and manganese concentrations up to
12.3 mg/l have been observed in silresim groundwater. These concentrations
indicate that iron/manganese removal is required to reduce clogging of
treatment equipment. Some incidental removal of metals other than iron and
manganese is expected to occur during treatment. Potential systems
. considered for iron/manganese removal included chemical
_precipitation/filtration and ion exchange. Chemical precipitation removes
dissolved metals by precipitating them as hydroxides or sulfides. A
subsequent-filtration step would remove additional solids_not removed by
the clarifier. The ion exchange process removes dissolved metal
contaminants by passing contaminated groundwater through a fixed bed packed
with ion exchange resin(s).
The following three methods of disposal for treated groundwater were
discussed and compared in the FS:
On-site groundwater recharge.
Discharge to the City of Lowell's Duck Island Treatment Plant via
sanitary sewer lines.
Discharge to River Meadow Brook through an existing storm drain
or a specially-constructed drain line.
The first of these three options involves construction of a series of
recharge trenches to allow treated water to seep back into the soils at the
Site. While the construction of a recharge system may be possible at the
silresim Site, this would be least practical due primarily to the low
permeability and heterogeneity of on-site soils which make recharge
technically difficult. Additionally, recharge would tend to increase
hydraulic gradients at the site, which may increase the off-site flow of
contaminated groundwater.
Discharge to River Meadow Brook would involve construction of buried piping
from the on-site treatment building to either the Brook, which at its
closest point is approximately 400 feet from the site boundary, or to a
storm drain that flows to the brook. If discharge to River Meadow Brook is
adopted, a NPDES permit would have to be obtained. Discharge limitations
would likely be imposed on many of the contaminants found in site
groundwater, and additional parameters such as pH and total suspended
solids (TSS). Imposed standards for organic compounds may be as stringent
as drinking water standards, while TSS standards are typically 20 to 30
mg/l. Toxicity standards similar to those proposed for the Duck Island
facility may also be imposed.
Discharge to the City of Lowell's sanitary sewer system, which flows to the
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construction of a connec~ing pipe from the groundwater treatment building
to a nearby (existing) sewer line with available capacity to handle the
expected flow. This connection would probably be made to t,he Tanner street
sewer near the present site gate. Discharges would have to conform to the
sewer use ordinances, which include a TTO (Total Toxic Orga,nics) standard
of 2.13 mg/l, and may include toxicity-based standards. All state and
federal requirements for discharge to sewers and to the POTW would be met.
The final decision regarding the discharge location wili be made during the
design phase of the project, based upon results of the pre-design
activities.
1.
HK-l NO-Action/Minimal Ac~ion
This alternative is intended to include the minimal actions that must be
taken at the site to reduce potential risks to the public. This
alternative, as required by CERCLA, is used as a basis of comparison for
evaluating other proposed management of migration alternatives. MM-l
consists of restricting the use of groundwater on Site, and monitoring of
groundwater both on and off Site. Education programs would inform the
public about potential hazards associated with Site groundwater.
Institutional controls would be implemented to restrict or prevent the
potential use of contaminated groundwater. A long-term groundwater
monitoring program'would be instituted for a period of at least 30 years to
evaluate changes in study area conditions over' time. As required under the
1986 CERCLA amendments, five-year reviews would be conducted because waste~
would remain on Site.
Education programs would inform local agencies, utilities, and the public
about potential hazards at the Site. The programs would include public
meetings, presentations, local newspaper articles, and direct mailings to
businesses and residences located near the site.
Institutional controls would include access, deed and land use
restrictions. These controls would be pursued through legal channels to
restrict or prevent the potential use of contaminated groundwater. Land
use/deed restrictions would include the addition of water use restriction
clauses to property deeds in areas of known groundwater contamination.
Long-term monitoring would record and allow evaluation of trends in
contaminant concentration and extent of contaminant migration. Monitoring
would consist of samplinq and analyses of surface water, groundwater, and
downgradient sewers. Surface water samples, and samples from the
downgradient sewer would be collected. Groundwater samples would also be
collected from multiple selected, existing monitoring wells. . Samples would
be analyzed for the Target Compound List (TCL) volatile organic compounds
during each sampling round, and for the other TCL organics and Target
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No treatment of groundwater contaminants would be implemented in this
alternative; therefore, the risks associated with the potential exposures
to groundwater as identified in the RI would not be permanently mitigated.
The institutional controls included in this alternative would be
, implemented within approximately one year.
The 1986 CERCLA amendments require that conditions be'reviewed every five
years at NPL sites where wastes remain on site. As Alternative MM-1 would
result in wastes remaining on site, this five year review process would be
mandatory. All data obtained in the monitoring program would be evaluated
in the five-year reviews. These reviews would consider all relevant data
and determine if additional remedial actions are necessary'.
Implementation of this alternative would not be expected to result in ,any
additional environmental impacts, since no contaminants would be removed,
treated 9r destroyed.
ESTIMATED TIME FOR DESIGN AND CONSTRUCTION: 1 year
ESTIMATED TIME FOR OPERATION: 1 year
ESTIMATED CAPITAL COST: $64,000'
ESTIMATED 0 & M (Present Worth): $416,000
ESTIMATED TOTAL COST (Present worth): $480,000
2.
MM-2 Groundwater Extraction, Metals pretreatment, Air stripping,
Aqueous Phase Carbon Adsorption and Vapor Phase Carbon Adsorption or
Thermal oxidation
This alternative would remove both inorganic and organic groundwater
contaminants by gravity separation, metals pretreatment, air stripping,
vapor phase carbon adsorption or thermal oxidation and liquid phase carbon
adsorption. Groundwater would be pumped to a settling tank where non-
aqueous phase materials (e.g. floating product and DNAPL) would be
separated and shipped off Site for reclamation or incineration. The
aqueous stream would be directed to a metals removal process. After metals
removal, the groundwater would be heated and pumped to the air stripper.
organic compounds would be removed by air stripping and liquid phase carbon
adsorption. Secondary waste management would be required for off Site
disposal of some contaminants. The treated water would be discharged to
one of the three discharge options discussed above which will be determined
during the remedial design phase.
Air stripping would be accomplished using either a counter-current air
stripping tower or a tray aerator. A stripping tower consists of a
vertical tower filled with packing material. Contaminated water flows
downward through the packing material while air is forced upward through
the tower by a blower. The large surface area of the packing material
improves contact of contaminated water with the flowing air. Contaminated
air exits the top of the tower, and is directed to subsequent treatment to
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RECORD OP DECISION SUMMARy
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as a packed tower, but differ substantially in construction. The unit
consists of stacked, perforated trays across which water flows while air is
bubbled through from beneatb the trays.
To increase the air stripper removal efficiency, the groundwater influent
would be heated prior to air stripping. Heating would be accomplished by
using steam or other heating methods. Heating of influent results in more
efficient stripping and thus reduces the organic loading on the liquid-
phase carbon adsorbers. Volatilized organics from the air stripper would.
be removed by either vapor-phase carbon adsorption or thennal oxidation.
The thermal oxidation unit would require an auxiliary fuel source to
incinerate the volatile emissions, and a scrubbing system to remove acid
gasses. Because of the presence of ketones in groundwater" the use of
vapor-phase carbon is a less desirable technology at Silre~;im. The high
heat of adsorption .of ketones can result in unacceptable tE~mperature
increases and/or carbon bed fires.
v
An aqueous-phase carbon adsorption unit would be used to remove organic
contaminants not removed by the air stripper. Compounds nc)t efficiently
removed in the air stripper would tend to be either heavier molecular
weight compounds (e.g., PAHs) or highly soluble compounds (e.g., ketones).
Carbon adsorption removes organics by collecting them .on the surfaces of
granules of activated carbon.
Secondary waste management would be required for off-site disposal of non-
aqueous phases from gravity separation (e.g., DNAPL, floati.ng product), .
residues from the metals removal process (e.g. metals hydroxide sludge from
chemical precipitation), and the off-site regeneration or disposal of spent
carbon. Since hazardous materials would be transported off' Site, DOT and
RCRA regulations for the transportation of such materials would be
applicable and must be met.
The groundwater extraction and treatment system could be
constructed, and started up in a period of approximately
years. As discussed above, the extraction and treatment
expected to func~ion as a long-term remediation system.
Public education programs, institutional restrictions, long-term
monitoring, and five-year reviews would be implemented as described above
under Alternative MM-l.
designed,
two to three
system would be
3.
ESTIMATED TIME FOR DESIGN AND CONSTRUCTION: 2 to 3 years
ESTIMATED TIME FOR OPERATION: Long-term Remediation
ESTIMATED CAPITAL COST: $4,405,000
ESTIMATED 0 & M (Present Worth): $7.,277,000
ESTIMATED TOTAL COST (Present worth): $11,680,000
MM-3 Groundwater Extraction, Hetals Pretreatment, Steam Stripping,
Aqueous Phase Carbon Adsorption, and Vapor Phase Carbon Adsorption or
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This alternative is essentially the same as MM-2 detailed above, with the
substitution of steam stripping for air stripping. As with Alternative MM-
2, groundwater would be pumped to a settling tank where non-aqueous phase
liquids (NAPL) would be separated and shipped off-site for reclamation or
incineration. FOllowing pretreatment to remove metals from the
groundwater, the groundwater would be treated using steam stripping. steam
stripping uses steam, instead of air, to remove contaminants from the
groundwater. The contaminated vapor from the steam stripper is condensed
then collected and separated in a tank. The non-aqueous phase product,
containing high concentrations of contaminants, would be removed and
shipped to an off-site facility for disposal or reclamation. The aqueous
phase may be recycled through the air stripper. The treated water would be
discharged-to one of the three discharge options discussed above, which
will be determined during the remedial design phase.
steam stripping uses a vertical column into which groundwater is fed from
the top while steam, provided from an on-site boiler, is injected from the
bottom. The column contains packing material or a series of perforated
plates to increase the contact between the steam and the groundwater. The
vapor from the steam stripper is condensed in a water-cooled heat
exchanger, and collected in a tank to allow separation into immiscible
product phases and aqueous phases. (Very soluble compounds such as acetone
will not form a separate phase.) The aqUeous phase, containing high
concentrations of stripped compounds, may be either treated, disposed of,
or recycled back into the treatment system. If the condensate has
unacceptable concentrations of ketones (e.g., acetone), recycling into the
treatment system may not be viable.
Aqueous-phase carbon adsorption, as described under Alternative MM-2, would
be used to remove additional organic contaminants not removed by the
stripper.
Secondary waste management would be required for off-sit~ disposal of non-
aqueous phases from gravity separation, residues from the metals removal
process (e.g. metals hydroxide sludge from chemical precipitation),
treatment or disposal of the aqueous phase condensate (if it cannot be
recycled into the treatment process), recycling or disposal of recovered
.product condensate, and the regeneration or disposal of spent carbon.
Volatilized contaminants from the pretreatment systems (phase seperator and
metals pretreatment) would either be removed by vapor-phase carbon
adsorption or a thermal oxidizer. since hazardous materials would be
transported off Site, DOT and RCRA regulations for the transportation of
such materials must be met.
The groundwater extraction and treatment system could be designed,
constructed, and started up in a period of approximately two to three
years. As discussed above, the extraction system would be expected to
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Public education programs, institutional restrictions, long-term
monitoring, and five-year reviews would be implemented as described above
under Alternative MM-l.
Q
4.
ESTIMATED TIME FOR DESIGN AND CONSTRUCTION: 2 to 3 years
ESTIMATED TIME FOR OPERATION: Long-term Remediation
ESTIMATED CAPITAL COST: $4,405,000
ESTIMATED 0 & M (Present Worth): $7,914,000
ESTIMATED TOTAL COST (Present worth): $12,320,000
MH-4 Groundwater Extraction, Metals pretreatment, UV/Chemica1
Oxidation, and Vapor Phase Carbon Adsorpti~n or Thermal Oxidation
Similar to Alternatives MM-2 and MM-3, groundwater would be pumped to a
settling tank where NAPL materials would be separated and .shipped off Site
for treatment. Following pretreatment to remove metals fr,om the
groundwater, the groundwater would be treated using ultraviolet
(UV)/oxidation to remove the VOCs. UV/oxi~ation is a trea'tment which
involves the destruction of dissolved organic compounds using ultraviolet
light in combination with strong chemical oxidizing agents (ozone or
hydrogen peroxide). The treated water would be discharged to one of the
three discharge options discussed above to be determined during the
remedial design phase. .
UV/chemical oxidation would be used to destroy organic contaminants.
Available UV/chemical oxidation systems use either hydrogen peroxide or
ozone, or both. Either hydrogen peroxide or ozone alone will oxidize
organics: however, oxidation rates are significantly increased by using UV
light in conjunction with these oxidants. UV light enhances the oxidation
process by transforming hydrogen peroxide and ozone into hydroxyl radicals,
which are more powerful oxidants than hydrogen peroxide or ozone. UV light
also reportedly excites organic molecules to higher, less-stable energy
levels, making them more susceptible to oxidation. If the oxidation
reaction is carried to completion, the end products from oxidation of non-
chlorinated hydrocarbons are carbon dioxide and water. Chlorinated
hydrocarbons would also produce hydrochloric acid and/or inorganic
chlorides. If the oxidation reaction is not carried to completion, then
organic compounds remain.
UV/chemical oxidation processes preferentially destroy more easily oxidized
compounds such as vinyl chloride and trichloroethene. Compounds that are
harder to destroy require more residence time in the oxidation chamber.
These compounds include trich10roethene, dichloroethane, methylene
chloride, carbon tetrachloride, and ketones (e.g., acetone). In general,
saturated hydrocarbons are more difficult to oxidize than compounds with
double or triple bonds. Also,' several compounds and constituents interfere
with UV/chemical oxidation. Carbonates interfere by consuming oxidants,
resulting in higher chemical and/or ozone production costs. Iron and
manganese precipitates, oil and grease, and suspended solids coat the UV
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require periodic cleaning and replacement of UV lamps.
The use of ozone would require an on-site ozone generator, a relatively
high capital cost item. Hydrogen peroxide offers lower capital costs but
higher annual costs. The benefits of using ozone improve with higher
operating lifetimes. Systems using ozone typically leave residual ozone in
the effluent from the oxidation chamber. Release of ozone is unacceptable
because it is a priority pollutant. Ozone systems thus require a
decomposer, such as a fixed-bed catalytic decomposer, to convert ozone to
oxygen. The decomposer is vented to the atmosphere. Hydrogen peroxide
does not present these problems, but it is a potentially dangerous chemical
that must be handled with care. . .
Secondary waste management would be required for off-site disposal of non-
aqueous phases from gravity separation, residues from the metals removal
process (e.g. metals hydroxide sludge from chemical precipitation).
Volatilized contaminants from the pretreatment systems (phase seperator and
metals pretreatment) would either be removed by vapor-phase carbon
adsorption or a thermal oxidizer. Since hazardous materials would be
transported off-site, DOT and RCRA regulations for the transportation of
such materials would be applicable and must be met.
The groundwater extraction and treatment system could b$ designed,
constructed, and started up in a period of approximately' two to three
years. As discussed above, the extraction system would be expected to
function as a long-term remediation system.
Public education programs, institutional restrictions, long-term
monitoring, and five-year reviews would be implemented as described above
under alternative MM-l.
ESTIMATED TIME FOR DESIGN AND CONSTRUCTION: 2 to 3 years'
ESTIMATED TIME FOR OPERATION: Long-term Remediation
ESTIMATED CAPITAL COST: $4,866,000
ESTIMATED 0 & M (Present Worth): $6,570,000
ESTIMATED.TOTAL COST (Present worth): $11,440,000
IX.
SUMMARY OF THE COMPARATIVE ANALYSIS OF ALTERNATIVES
Section 121(b) (1) of CERCLA presents several factors that at a minimum EPA
is required to consider in its assessment of alternatives. Building upon
these specific statutory mandates, the National Contingency Plan
articulates nine evaluation criteria to be use~ 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. These criteria and
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Threshold Crit:eria
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 t:he environment addresses
whether or not a remedy provides adequate protec,tion 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 appr~priat:e
requirements (ARARS) addresses whether or not a :remedy will meet
all of the ARARs of other Federal and State environmental laws
and/or provide grounds for invoking a waiver. ' ,
Primary Balancina Criteria
The following five criteria are utilized to compare and evaluate the
elements of one alternative to another that meat the threshold criteria.
4.
5.
6.
3.
Lonq-term effectiveness and permanence addresses the criteria
that are utilized to assess alternatives for the long-term
effectiveness and permanence they afford, along ,~ith the degree
of certainty that they will prove successful.
Reduction of toxicit:y, mObilit:y, or volume through t:reat:ment
addresses the degree to which alternatives employ recycling or
treatment that reduces, toxicity, mobility, or volume, including
how treatment is used to address the principal threats posed by
the site.
Short t:erm effectiveness addresses t:he period of time needed to
achieve protection and any adverse impacts on human health and
the environment that may be posed during the construction and
implementation period, until cleanup goals are achieved.
Implementabilit:y addresses the technical and administrative,
feasibility of a remedy, including the availability of materials
and services needed to implement a particular option.
Cost: includes estimated capital and operation and maintenance
(O&M) costs,' as well as present-worth costs.
Modifvina Criteria
7.
The modifying criteria are used on the final evaluation of remedial
alternatives generally after EPA has received public COmmeJlt on the RI/FS
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8.
state acceptance addresses the state's position and key concerns
related to the preferred alternative and other alternatives, and
the state's comments on ARARs or the proposed use of waivers.
community acceptance addresses the public's general response to
the alternatives described in the Proposed Plan and RI/FS report.
FOllowing the detailed analysis of each individual alternative, a
comparative analysis, focusing on the relative performance of each
alternative against the nine criteria, was conducted.
9.
The section below presents the nine criteria and a brief narrative summary
of the alternatives and the strengths and weaknesses according to the
detailed and comparative analysis.
A.
COMPARISON OF SOURCE CONTROL (SC) ALTERNATIVES
1.
Overall Protection of Human Health and the Environment.
Each of the alternatives except for SC-1 and SC-2 use technologies that
will be protective of human health and the environment by treating the soil
to reduce the principal threats (i.e, VOCs) found at the Site, and/or
preventing exposure through containment mechanisms. In most cases the
mobility, toxicity and volume of contaminants will be reduced.
Alternatives SC-10 and SC-11 would provide the most permanent protection of
human health and environment. Under each of these alternatives, .
essentially all contaminants but metals would be eliminated: and the metals
would be stabilized and capped. Although PCB and dioxin cleanup levels may
not be met in alternatives SC-6, SC-14, and SC-15, the overall permanent
protection of these alternatives would be expected to be only slightly less
than with alternatives SC-10 and SC-11. Alternative SC-4 and SC-3 would
offer slightly less permanent protection than those mentioned above,
because they do not permanently eliminate heavier organics and some semi-
VOC.s, although they are similarly protective because they reduce exposures
to those constituents. Under SC-4, the residual contaminants would be
stabilized to provide for added protection against potential inhalation,
ingestion, direct contact and leaching related exposure risks.
Alternatives SC-1 and SC-2, the no action and cap alternatives, would
provide the least amount of overall protection.
2.
Compliance with ARARs
A list of ARARs is found in Section X, as well as in Appendix c.
Chemical-Specific. There are no federal or state regulations that
specify concentration limits for contaminants detected in soil at the
Silresim site. Federal and State requirements for ambient air emissions
(Federal Clean Air Act and Massachusetts Air Pollution Control Regulations)
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RECORD OF DECISION SUMHARY
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through SC-lS would be met utilizing proper control mechanisms.
Location-SDecific. If activities related to the sourc:e control
portion of the remedy were to occur within a lOa-foot buffer zone of the
two wetland are~s at Silresim (East Pond and River Meadow Brook), the
requirements of the Massachusetts Wetlands Protection Act and the
Massachusetts Hazardous Waste Siting Regulations would be Dlet.
Action-SDecific. Each of the activities and technologies
implemented under the source control alternatives SC-l thrc1ugh SC-lS would
be designed and implemented to meet corresponding action-specific ARARs.
3.
Lonq-Term Effectiveness and Permanence
Maqnitude of Residual Risk. Alternative SC-lS would I'esult in the
least residual risk at the site because treated soils would be disposed of
off site (if feasible). Although alternatives employing incineration (SC-
10 and SC-ll) would result in marginally higher residual risk than sc-is,
because some waste (metals) would be ~isposed of on Site, essentially all
organics would be destroyed. Alternatives employing thermal 1 desorption or
solvent extraction with on Site disposal (SC-6 and SC-l4) Dlay result in a
higher residual risk than SC-lO, SC-ll and SC-lS, because dioxins and PCBs
may be present above cleanup levels. Alternatives employing vacuum/vapor
extraction as the only organic removal component (SC-3 and SC-4) result in
slightly higher residual risk than those listed above because dioxins,
PCBs, and some semi-VOCs will remain on Site above cleanup levels, however.
both would provide protection against direct contact and inhalation
exposures to the residual contamination. SC-4 would afford greater long-
term protection than SC-3 because it would additionally include
stabilization to prevent migration of the residual contaminants to the
groundwater. Alternatives involving no treatment (SC-2 and SC-1) result in
the highest residual risks. Of these two alternatives, SC-2 offers lower
direct contact and inhalation risks, and reduced contaminant migration as a
result of the RCRA Subtitle C cap.
All alternatives except SC-lS include the disposal of some waste on site.
Stabilization is a component in all alternatives, except SC-l, SC-2, and
.SC-3,. to reduce the mobility and toxicity of the residual contaminants.
Therefore each. of these 6 alternatives would provide essentially equal
protection against all potential long-term exposure risks.
Adequacv of Controls. Alternatives SC-4 through SC-l5 employ
stabilization, a RCRA Subtitle C cap, a site fence, and ins:titutional
controls to manage residual contamination. These alternatives offer the
most adequate controls. Alternatives SC-3, SC-2, and SC-l do not employ
stabilization. Furthermore, alternative SC-l employs a non-RCRA cap,
offering a less adequate control than SC-2.
Reliabilitv of Controls. Because stabilized soils protected by a RCRA
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Page SS
alternatives SC-4 through SC-14 are the most reliable in this respect.
Alternative SC-1S is unreliable because there are no known facilities that
currently accept dioxin contaminated waste. Alternatives SC-1 through SC-3
offer less reliable controls, with SC-l being the least reliable because a
non-RCRA cap is used.
4.
Reduction in Toxicity. Mobility. and Volume Throuqh Treatment
-Alternatives employing incineration (SC-10 and SC-11) appear to offer the
greatest reductions in toxicity, mObility and volume because of the
demonstrated effectiveness and removal efficiency of incineration with
VOCs, semi-VOCs, PAHs, PCBs and dioxins.
Alternatives employing solvent extraction and thermal desorption (SC-14,
SC-1S, and SC-G) appear to comprise the next level of TMV reduction,
destroying or removing VOCs, semi-VOCs, and PAHs. Some PCB removal would
be expected with these technologies, but cleanup levels may not be
achieved. Bench and/or pilot scale testing would be required for both
technologies to evaluate their effectiveness with dioxins, since neither
are proven technologies for treatment of dioxins. -
Alternative SC-4 offers VOC removal and immobilization of heavier organics
and metals by stabilization treatment. Although little removal of heayier
organics results from this alternative, it should be noted that VOCs
comprise the bulk of contamination at the Site.
Only alternative SC-1S offers a volume reduction of metals as a result of
off-site disposal. SC-3 through SC-14 utilize stabilization which would
substantially reduce the mobility and toxicity of metals.
Alte~native SC-3 offers VOC removal but no treatment for heavier organics
or metals. Alternatives SC-2 and SC-l offer only minimal reductions in
mObility of contaminants, and would not satisfy the statutory preference
for alternatives employing treatment as a principal element.
5.
Short-Term Effectiveness
Protection of Community. Implementation of alternative SC-1 (no-
action) would not result in additional risks to the community because no
contaminants would be removed, treated or destroyed. Implementation of
alternative SC-2 would result in minimal risks to the public, because a
limited amount of soils may be exposed during cap construction operations
and grading.
Alternatives SC-3 through SC-1S involve excavation and treatment activities
that could result in potential exposure to the community through direct
contact and inhalation. In alternatives SC-4, BC-ll, SC-l4 and BC-1S,
excavation activities are performed subsequent to vacuum/vapor extraction,
so that volumes of soil to be excavated and direct contact and inhalation
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Alternatives se-6 and se-10 appear to pose the greatest risk to the
community during implementation in that large volumes of voe contaminated
soils would be excavated and the reliability of emissions controls is low.
Implementation of alternative se-lS could pose additional public health.
exposures due to the off-site transport and disposal of contaminants (if an
off-site facility for the disposal of dioxin waste can be utilized).
Protection of Workers. Implementation of alternative se-l would
result in the lowest short-term risks to workers, since minimal actions
will be taken and no contaminants would be removed, treated or destroyed.
Implementation of alternative SC-2 should result in minimal risks to the
workers, because a limited amount of soils may be exposed .during cap
construction operations and grading.
Alternatives se-3 through se-lS involve excavation and treatment activities
that may result in potential exposure to the workers through direct contact
and inhalation. Alternatives Se-3, Se-4, Se-ll, SC-l4 and se-lS require
trench excavation for the vacuum/vapor extraction system. In the latter
four alternatives, further excavation and treatment activities are also
required; however, direct contact and inhalation exposures and any
resulting risks would be reduced because of the prior reduction in VOC
concentrations. Alternatives SC-6 and SC-lO appear to pose the greatest
risk to workers in.that large excavation efforts in VOC~conta~inated soils
would be required. Alternative SC-lS may pose additional worker exposures
due to the off-site transport and disposal of contaminants.
Environmental ImDacts. The implementation of alternative SC-l should
not result in environmental impacts. Disturbance of vegetated areas should
be the only environmental impacts associated with alternative SC-2.
Potential adverse environmental impacts may result from alternatives SC-3
through SC-lS from excavation activities, including soil erosion,
generation of stormwater runoff, and VOC and dust emissions. However,
measures for drainage, erosion and emissions controls are expected to be
reliable. Emissions controls for large-scale excavation efforts are
expected to be less reliable.
Additional low-level emissions may result from the operation of on Site
extraction and treatment systems. Each of the proposed emissions control
systems are reliable. Alternatives employing large-scale incineration or
thermal desorption (Se-6 and SC-lO) probably pose the largest risk of air
emissions. Differences in the degree of potential environmental impacts
will be dependent on the amount of materials excavated and treated.
Alternative SC-lS may pose additional environm~ntal risk due to the off
Site transport and disposal of contaminants.
Estimated Time to Achieve Obiectives. Alternative SC-l has the
shortest estimated implementation time (one year), followed by SC-2 (two
years). Alternatives SC-IO and SC-6 have estimated implementation times of
approximately eight years. Alternatives SC-3 and SC-4 have estimated
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RECORD OF DECISION SUMMARY
silresim Site
Page 57
they require approximately 30 years to achieve VOC cleanup levels in
natural soils. Alternatives SC-ll, SC-14, and SC-15 require approximately
eight years to implement, but also require approximately 30 years to
achieve cleanup levels in natural soils.
6.
Implementabilitv
Technical Feasibilitv
Construction and Operation. Alternative SC-l offers the fewest
constructability concerns. Alternative SC~2 involves a larger construction
effort than SC-l, but constructability concerns are minor. Alternatives
. 5C-3, 5C-4, 5C-ll, 5C-14 , and SC-15 employ vacuum/vapor extraction.
Extraction trenches could be up to 14 feet deep, presenting potential
construction problems. Alternatives SC-6 and SC-IO involve major
excavations in highly VOC-contaminated soils which could pose major
constructability problems, particularly with the large-scale application of
VOC emissions controls, and the location of treatment equipment and
facilities. Treatment equipment would have to be either located on the
Silresim property and moved at least once during the course of the project,
or located off the property, outside the areas to be excavated. The latter
option would involve obtaining easements or acquirin~ adjacent properties.
Reliabilitv of TechnoloQv. Alternatives 5C-l and 5'C-2 employ the
simplest technologies, and pose few reliability concerns. Vacuum/vapor
extraction (alternatives SC-3, SC-4, SC-ll, SC-14, and SC-15) offers a
reliable technology for VOC removal, but little or no reliability for the
removal of PAHs, PCBs, dioxins, or metals. Stabilization (alternatives 5C-
4 through SC-15) offers a reliable means of reducing mobility of metals and
potentially heavier organics such as PCBs. Thermal desorption (alternative
5C-6) offers high reliability for VOCs and only limited reliability for the
removal of PCBs and. dioxins. Data is also lacking on the effectiveness of
thermal desorption in moist soils. Solvent extraction (alternative SC-14
and SC-15) has been shown to be a reliable technology for the removal of
PCBs (but not for dioxins).
Ease of Undertakina Additional Remedial Action.. Alternative SC-l
provides the least impediment to future remedial action. All other
alternatives employ a RCRA subtitle C cap which would require greater
effort to remove than the existing cap. Alternatives employing
vacuum/vapor extraction (alternatives SC-3, SC-4, SC-l1, SC-14 , and SC-15)
may require repair, replacement, or abandonment of the extraction piping.
Alternatives employing on~site disposal of stabilized soil (5C-4 through
5C-14) could offer potential difficulties because of the hardened soil
masses that would be produced.
Monitorina Considerations. Alternative SC-l presents no impediments
to futu~e monitoring. All other alternatives present minor problems
involved with maintaining integrity of the RCRA cap during and after soil
sampling operations. Alternatives employing or potentially employing
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RECORD OP DECISION SUXHARY
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stabilization (SC-4 through SC-15) may make soil sampling somewhat more.
difficult if hardened soil masses require coring equipment.
Administrative Feasibility
All alternatives would require coordination between EPA, DEP, the City of
Lowell, and adjacent property owners. Rights-of-way may be required for
work in or near railroad property. Alternatives involving or potentially
involving the treatment or disposal of process waste (SC-3 through SC-15)
would be required to comply with applicable EPA, Department of
Transportation, and State DEP regulations. None of these issues are
. anticipated-to present major administrative feasibility pr~b1ems. The only
major feasibility issue is in locating an off Site facility for the
disposal of dioxin contaminated waste associated with SC-15.
Availabilitv of Services and Materials
Alternatives SC-1 (Minimal/No Action), SC-2 (On-site Cover System) and SC-3
(On-site Vacuum/Vapor Extraction) use readily available services and
materials. All other alternatives require advance scheduling of treatment
equipment for stabilization, thermal desorption, incineration, and/or
solvent extraction. Stabilization ( SC-4 through SC-15) is relatively
widely available. On-site incineration (SC-10 and SC-11) is somewhat less
available, and thermal desorption and solvent extraction are the least
available. Alternative SC-15 presents major concerns associated with the
availability of off-site disposal capacity for large volumes of treated
soils, and for soils with residual dioxin concentrations above 0.001 mg/kg.
7.
Cost
The estimated present worth value
. listed below. It should be noted
during the Feasibility Study that
percent to -30 percent.
of each Source Control alternative is
that these costs are estimates made
are expected to provide accuracy of +50
Ca'pi tal Present
Costs 0 & M Worth
SC-1 $564,000 $485,000 $1,050,000
SC-2 $4,997,000 $391,000 $5,390,000
SC-3 $7,409,000 $1,745,000 $9,150,000
SC-4 $8,637,000 $1,986,000 $10,620,000
SC-6 $50,444,000 $947,000 $51,390,000
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RECORD OF DECISION SUMMARY
silresim site
Page S9
SC-l1 $15,294,000 $2,040,000
SC-14 $10,085,000 $854,000
SC-15 . $17,862,000 $854,000
'8. state Acceptance
$17,330,000
$10,940,000
$18,720,000
The Commonwealth of Massachusetts through the Department
Protection (MA DEP) concurs with the selection of (SC-4)
vacuum/vapor extraction, stabilization and a RCRA cap as
alternative for the Silresim site.
of Environmental
in situ
the source control
The DEP provided a number of comments on the Proposed Plan and Feasibility
study to assist EPA in evaluating state acceptance of the selected remedy.
They provided a list of Applicable, Relevant and Appropriate Requirements
(ARARs) for the selected remedy, including chemical, location and action-
specific ARARs. DEP indicated that the Proposed Plan appeared to be
consistent with the definition contained in the Massachusetts contingency
Plan for a temporary solution. They also indicated their support for the
waiver of the bottom landfill liner specification of the Toxic Substance
and Control Act (TSCA), by recognizing that the selected remedy will be
protective of human health and the environment to exposures to PCBs.
Among DEP'S comments on the Proposed Plan, they recommended that wells
rather than trenches be further evaluated for use associated with the
vacuum extraction system, due to a reduction in air emissions from
excavating soil with volatile organic compounds. They recommended the use
of. a dome or sealed tent to reduce VOC emissions from the soil to be
temporarily stockpiled during the implementation of the remedy. Also, DEP
indicated that emissions testing would be required by th~m prior to and
during the implementation of the remedy, and that a fOllow-up risk
assessment should be performed once remedial activities have been completed
to ensure the protection of human health and the environment.
9.
community Acceptance
varied comments were received from residents and members of the business
community living near the site, state officials, and the Silresim
Potentially Responsible Parties regarding the content of the Feasibility
study and cleanup of the silresim site. The comments received during the
public comment period on the Proposed Plan and FS are summarized in the
attached document entitled "The Responsiveness Summary" (Appendix E). In
addition, the comments are summarized below. .
Three residents presented comments at the public hearing on July io, 1991.
One resident expressed a concern for the level of air emissions associated
with the preferred treatment systems. One resident favored an alternative
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RECORD OP DBCISION SUKHARY
Silresim Si1:e
Page 60
shorter period of time than the preferred remedy. Another resident
commented that a follow-up health study be performed that specifically
tracked the health status of people who have moved out of the residential
neighborhoods adjacent to the Site. An adjacent property and business
owner indicated in writing their support for the remedy, yet, they
expressed their concern for impacts it will have on the use of their
property.
" The Massachusetts Department of Public Health (DPH) expressed their support
"for the preferred alternative. However, DPH indicated their concern for
the health of residences closest to the Site. Due to the potential for
seepage of-groundwater into the basements of these homes," they suggested
that the affected residents be informed of the potential exposures and that
additional data be gathered to better assess these exposures. DPH also
expressed their concern that the Lowell Car Wash in the vicinity of the
Site, who have used groundwater to wash cars, may become affected in the
future. They recommend cOllecting more data on their well and the
geography in the area. Additionally, they' mirrored one of the residents
concerns regarding potential air emissions during implementation of the
remedy. .
A group of the Potentially Responsible Parties have raised numerous
technical and legal concerns that support waiving drinking water standards
(Maximum Contaminant Levels, MCLs) at the Site, changing the point of
compliance for meeting cleanup levels for groundwater to River Meadow
Brook, and selected less stringent cleanup levels for soils. Although they
believe that the selected cleanup remedy is sound and cost effective, they
do not believe that it is technically feasible, or appropriate, to
remediate the aquifer at the selected point of compliance to drinking water
standards. They believe that containment of the plume is a more
appropriate alternative. Additionally, the PRPs believe that EPA has not
taken into account the background levels of contaminants found in the area
or EPA's current Risk Assessment guidance which would raise the cleanup
levels to be met.
B.
1.
COMPARISON OF MANAGEMENT OF MIGRATION (MM) ALTERNATIVES
Overall Protec~ion of Human Hea~h anq the Environment
Alternatives MM-2, MM-3 and MM-4 would provide equal overall protection of
human health and the environment, either by reducing contaminants to
MCLs/MCLGs or other health based standards, or through a combination of
mass reduction, institutional controls and/or engineering controls. In
either case, potential exposure risks associated with direct contact,
ingestion and inhalation of contaminants in groundwater, surface water and
air would be significantly reduced.
Alternative MM-l would" offer minimal protection of human health and the
environment by limiting future use and development of the affected
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RECORD OF DECISION SUMMARY
silresim site
Page 61
2.
ComDliance with ARARs
Action-sDecific. Each of the activities and treatment technologies
implemented under the management of migration alternatives would be
designed and implemented to meet corresponding action-specific ARARs.
Chemical-sDecific. The design of alternatives MM-2, MM-3, and MM-4
would be as a long-term remediation strategy. Actual times required to
restore groundwater to cleanup levels are not possible to predict with any
degree of reliability. Federal and state drinking water standards may
either be attained or waived on the grounds of technical impracticability.
Since these alternatives will control the migration of groundwater off of
the Silresim property, chemical-specific ARARs and TBCs for groundwater,
surface water, and air would be met at the compliance points.
At the completion of alternative MM-l, no chemical-specific ARARs would be
met, since no removal, treatment. or destruction of contaminants would
occur.
Location-sDecific. The only location-specific ARARs identified are
the Massachusetts Wetlands Protection Act and the Massachusetts Hazardous
Waste Facility site regulations which would regulate activitie5 within a
lOO-foot buffer of the two wetland areas at Silresim: East Pond and River
Meadow Brook. If any activities such as the installation of extraction
wells were to take place within this buffer zone, they would be designed
and implemented to meet this ARAR.
3.
Lona-Term E£fectiveness
Maanitude of Residual Risk. Alternatives MM-2 through MM-4 offer a
reduction in risks associated with residual contamination by using
groundwater extraction to control the migration of contaminated
groundwater. The groundwater extraction/treatment system would be
effective in mitigating risks, by meeting interim cleanup levels associated
with exposures to: groundwater at the edge of the RCRA cap (compliance
point), surface water, and air.
Alternative MM-l would result in the highest potential risks, since no
treatment of groundwater would be implemented and risks would be controlled
only by institutional measures. .
Adeauacy and Reliabilitv of Controls. Alternatives MM-2 through MM-4
employ groundwater extraction as the controlling measure for residual
contamination. If properly designed, operated, and maintained, a
groundwater extraction system would be an adeqUate and reliable means of
controlling further off-site migration. Alternative MM-l offers reliable
but potentially inadequate controls. All alternatives include groundwater
monitoring to assess long-term effectiveness.
4.
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RECORD OF DECISION SUMMARY
silresim Si~e
Page 62
Alternatives MM-2 through MM-4 would reduce the mobility of contaminated
groundwater by use of a groundwater extraction system. These alternatives
also use groundwater treatment to reduce the toxicity of groundwater
through removal of organic contaminants. Each of these alternatives
provide comparable removal efficiencies. Reductions in contaminant volume
. result in each of these alternatives through the various treatment
technologies employed. The extent of these reduction~ depends on the
treatment of residuals and on the extent of the oxidation reactions in
alternative MM-4. Alternative MM-l results in no reductions in toxicity, .
mobility and volume.
5.
Short~Term Effectiveness
Protection of Communi tv. Implementation of alternative MM-l would not
result in additional risks to the community, since no contaminants wOUld be
removed, treated or destroyed. Alternatives MM-2, MM-3 and MM-4 would
result in similar, minimal risks to the community associated with the
excavation of soils, emissions from the treatment units, and off-site
transportation of materials. .
Protection of Workers. Alternative MM-l ~ould result in the' lowest
risks to workers, since minimal actions will be taken and no contaminants
would be removed, treated or destroyed. Alternatives MM-2, MM-3 and MM-4
would result in similar risks to workers performing excavation activities
and operation of treatment equipment. .
Environmental Impacts. Implementation of alternative MM-l would not
be expected to result in environmental impacts, since no contaminants would
be removed, treated or destroyed. Alternatives MM-2, MM-3 and MM-4 would
result in similar, minimal impacts to the environment as a result of
excavation and extraction well installation activities.
Estimated Time to Achieve Obiectives. Alternative MM-l involves
institutional controls which could be implemented in approximately one
year. Alternatives MM-2 through MM-4 involve groundwater extraction and
treatment, which could be designed, constructed, and started up in
approximately two to three years. The extraction system for these
alternatives would be expected to function as a long-term remediation
system to reduce further migration and meet cleanup levels at the
compliance points. EPA cannot reliably predict when cleanup levels can be
achieved at this Site,. however, it is anticipated that it will not be less
than thirty years from implementation.
6.
Implementability
Technical Feasibilitv
Construction and Operation. Alternative MM-l includes little or no
construction. Alternatives MM-2 through MM-4 would use standard
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RECORD OF DECXSXON SUMMARY
Silresim site
. paqe 63
issues. Alternative MM-l includes groundwater monitoring as the only major
.. operating component. Alternatives MM-2 through MM-4 also include
monitoring. Operation and maintenance efforts for these three options are
ant~cipated.to be comparable.
Reliability of Technoloav. Alternative MM-l uses relatively simple
monitoring procedures. Alternative MM-2 appears to have high reliability
based on its successful long-term use at a similar Superfund site (the
Gilson Road site in Nashua, New Hampshire). Alternative MM-4 uses
UV/chemical oxidation, which has been successfully demonstrated in short-
term testing. The steam stripping technoloqy employed for alternative MM-3
. has not been as widely used as other groundwater treatment techniques.
. .
Ease of Undertakinq Additional Remedial Action. Alternative MM-l
presents no impediments to future remedial actions. Alternatives MM-2
through MM-4 would present problems if future actions required removal or
relocation of major portions of the extraction and/or treatment systems.
Monitorinq Considerations. Alternatives MM-l through MM-4 present no
major impediments to future monitoring.
Administrative Feasibility
Alternative MM-l would require cooperation between the City of Lowell, the
DEP, and the EPA for monitoring efforts and data analysis. Alternatives
MM-2 through MM-4 require greater efforts, and also require compliance with
sewer use ordinances for discharge to the Duck Island treatment facility
should that be the discharge option determined during the remedial design
phase.
Availability of Services and Materials
. Alternative MM-l would use widely-available monitoring equipment.
Alternatiyes MM-2 through MM-4 also require services and materials for
groundwater extraction and treatment, most of which are widely available.
Alternative MM-2 -(air stripping) appears to use the most widely-available
equipment, followed by alternative MM-3 (steam stripping) and MM-4
(UV/chemicaloxidation).
7.
Cost
The estimated present worth value of each management of migration
alternative is listed below. It should be noted that these costs are
estimates made during the Feasibility study that are expected to provide
accuracy of +50 percent to -30 percent. .
Capital
Costs
o & M
Present
Worth
MM-l
$64,000
$416,000
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RECORD OF DECZSZOH SUMMARY
silresim site
Page 64
MM-3
$4,405,000
$4,405,000
$7,277,000
$7,914,000
$11,680,000
$12,320,000
. MM-2
MM-4
$4,8'66,000
$6,570,000
$11,440,000
8.
state AcceDtance
The Massachusetts Department of Environmental Protection (MA DEP) concurs
with the selection of an air stripper (MH-2), aqueous phase carbon
adsorption and thermal oxidation as the management of migration alternative
for the Si~resim site.
In DEP's comments to EPA on the Proposed Plan, they recommended that
alternative MM-4 be further evaluated due to the high carbon usage rates
reported for the selected remedy (MM-2) in the Feasibility study. Also,
DEP indicated that emissions testing would be required prior to and during
the implementation of the remedy, and that a follow-up risk assessment
should be performed once remedial activities have been completed to ensure
the protection of human health and the environment.
9.
Communi tv AcceDtance
The comments received during the public comment period on the Proposed Plan
and FS are summarized in the attached document entitled "The Responsivenesr
Summary" (Appendix E)~ Please see the Comparison of Source Control
Alternatives, Community Acceptance, above for an additional summary of the
comments submitted to EPA by the public.
x.
THE SELECTED REMEDY
The remedy selected for the Silresim Site includes Source Control
alternative SC-4 and Management of Migration alternative'MM-2 to address
all contamination at the Site. A detailed description of the cleanup
levels and the selected remedy is presented below.
A.
Cleanup Levels
i.
Interim Groundwater CleanuD Levels
Interim cleanup levels have been established in groundwater for all
contaminants of concern identified in the baseline risk assessment found to
pose an unacceptable risk to either human health or the environment.
Interim cleanup levels have been set based on the appropriate 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 remedial actions will be made as
the remedy is being implemented and at the completion of the remedial
action. At the time that all groundwater ARARs identified in the ROD and
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RECORD OP DECISION SUMMARY
Silresim Si~e
Page 65
protectiveness of the remedy have been achieved, a risk assessment shall be
performed on the residual groundwater contamination. This risk assessment
of the residual groundwater contamination shall follow EPA procedures and
will assess the cumulative carcinogenic and non-carcinogenic risks posed by
exposure to 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
pe performance standards for this ROD.
Because th~ aquifer at and beyond the compliance boundary is classified as
a Class IIB aquifer under the Federal Groundwater Protection strategy and
Class I by the Commonwealth of Massachusetts, a potential 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 MCLGs. In the absence of a'
MCLG, a 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 ground water and practical
quantitation limits. Interim cleanup levels for compounds in groundwater
exhibiting non-carcinogenic effects and for which there is no evidence of
carcinogenicity or which have not been classified as to their carcinogenic
potential, have been set at the MCLG. In the absence of an MCLG, 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).
All groundwater ARARs identified in the ROD and newly promulgated ARARs and
modified ARARs which call into question the protectiveness of the remedy,
must be met at the completion of the remedial action at the point of
compliance. These levels will be obtained at and beyond the edge of the
final RCRA Subtitle C cap which will be installed as part of the Source
Control action (approximately the existing fence line or Silresim property
boundary). The installation of a final cover over the residual
contamination left on the Silresim property limits its potential future
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RECORD OF DECISION SUKKARY
Silresim Site
paqe 66
TABLE 2
SILRESIM SITE
INTERIM GROUND WATER CLEANUP LEVELS
Carcinoqenic
Contaminants of
Concern
Arsenic
Benzene
Bis(2-ethylhexyl)phthalate
Carbon Tetrachloride
Chloroform
1,1-Dichloroethene
1,2-Dichloroethane
1,2-Dichloropropanei
Dioxinh
Hexachlorobenzenei
Methylene Chloride
PAHs (B(a)p)h
PCBSh
Styreneh . .
1, 1,2, 2-Tetrachloroethane
1, 1, 2-Trichloroethanei
Trichloroethene
Non-carcinoqenic
Contaminants
of Concern
2-Butanone
Cadmi um i
Chlorobenzene .
Chromium (trivalent)
Copperi
1,2-Dichlorobenzenei
Trans-1,2-Dichloroethenei
Ethylbenzenei
Lead
Nickel
Phenol
Selenium
Toluene
1, 2, 4-Trichlorobenzene
1, 1, l-Trichloroethane
Xylenesi
Cleanup
Level (-pob)
350
5
100
100
1,300
. 600
100
700
15
100
21/000
50
1,000
9
200
10,000
Cleanup
Level (oob)
50
5
4
5
100
7
5
5
5E-08
1
5
.2
.5
100
5
5
5
Basis
GWSIl
MCLG
MCLG
MCLG
pMCLGe
MCLG
MCLG
MCLG
. policy
pMCLGe
RfDj
MCLG
MCLG
pMCLG
MCLG
MCLG
Basis
MCL
MCL
pMCL8
MCL
MCL
MCL
MCL
MCL
pMCLc
pMCL
pMCL
pMCL
MCL
MCLGd
PQLf
pMCL
MCL
SUK
Level of
Risk
2E-04b
4E-06
2E-06
2E-05
2E-05
lE-04
1E-05
lE-05
. 2E-04
5E-05
lE-06
7E-05
lE-04
9E-05
3E-05
8E-06
2E-06
9E-04
Tarqet .
Endpoint Hazard
of Toxicitv Ouotient
fetotoxicity 0.2
kidney o. 3
liver/kidney 0.2
liver 0.003
stomach 1. 0
liver O. 2
liver 0.2
liver/kidney 0.2
CNS k
liver/kidney 0.2
fetal bdy wt 1.0
hair/nails 0.5
lvr/kdny 0.2
liver 0 . 2
liver 0.06
bdy wt/hyper 0.2
HAZARD INDEX
!mil
liver
Kidney
Body Weiqht
1.2
0.9
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RECORD OF DECISION SUMMARY
silresim site
paqe 67
a- Maximum Contaminant Level
b - The cleanup level for arsenic in groundwater has been set at the MCL of
'50 ppb. The carcinogenic risk posed by arsenic at 50 ppb in groundwater
will~pproximate 2 in 1,000. However, in light of recent studies
indicating that many skin tumors arising from oral exposure to arsenic are
non-lethal and in light of the possibility that the dose-response curve for
the skin cancers may be sublinear (in which case the cancer potency factor
used to generate risk estimates will be overstated), it is Agency policy to
manage these risks downward by as much as a factor of ten. As a result,
the carcinogenic risks for arsenic at this Site have been managed as if
they were 2 in 10,000. (See EPA memorandum, "Recommended Agency Policy on
the carcinogenic Risk Associated with the Ingestion of Inorganic Arsenic"
dated June 21, 1988.) "
c - Proposed Maximum Contaminant Level
d - Maximum contaminant Level Goal
e - Proposed Maximum contaminant Level Goal
f - Practical Quantitation Limit
9 - Massachusetts Groundwater Standard, 314 CMR 6.07
h - Additional groundwater indicator substance, which has the potential to
leach into groundwater.
i-Additional groundwater indicator substance based on Site groundwater
exceeding either an MCL, pMCL, MCLG or a pMCLG.
j - Reference Dose - Concentration corresponding to a reference dose.
k - A hazard quotient is not available for lead as EPA has not issued a
reference dose for this compound. The cleanup level for lead comes from a
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RECORD OP DECISION SUMMARY
Silresim Si~e
Page 68
While these cleanup levels are consis~en~ with ARARs (and suitable TBC
criteria) for groundwater, a cumulative risk that could be posed by these
compounds may exceed EPA'sacceptable risk range for remedial action.
Consequently, these levels are considered to be interim cleanup levels for
groundwater. Thus, when all groundwater ARARs identified 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
protective 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. Record of
Decision and shall be considered performance standards for any remedial
action.
Although the goal of this remedial action is to restore the groundwater to
its beneficial uses which are federal and state drinking water standards
(MCLs), and EPA and the Commonwealth of Massachusetts believe that the
selected remedy will achieve this goal, studies suggest that it may not be
possible to achieve these standards throughout the area of attainment
within a reasonable period of time. Groundwater contamination may be
especially persistent in the immediate vicinity of the contaminant source,
where concentratons are relatively high and DNAPL has been detected. The
practicability of achieving cleanup levels throughout the Site cannot be
determined until the extraction system has been implemented and plume
response monitored over time. .
If the selected remedy cannot meet the cleanup levels (i.e., MCLs)
following a reasonable period of system operation, contingency measures and
goals may. be considered by EPA for replacement. These measures and goals
would be considered if they are protective of human health and the
environment, but are technically practicable under the corresponding
circumstances.
For alternate co~tingency measures and levels to be considered by EPA, the
following condition would need to be satisfied: contaminant levels have
ceased to decline over time, and are remaining constant at some
statistically significant level above health-based goals in portions of the
aquifer outside of the compliance points. If it is determined on the basis
of the preceding criteria and the system performance data that portions of
the aquifer cannot be restored to their beneficial use, any or all of the
following contingency measures will occur as a modification of the existing
system: (a) institutional controls will be maintained to prevent access to
groundwater that remains above health-based levels: (b) ARARs will be
waived for those portions of the aquifer based on the technical
impracticability of achieving further contaminant reduction; and (c)
continued pumping will be required as a long-term gradient control, or
containment measure.
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RECORD OP DECISION SUMMARY
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during a future review, following a reasonable period of operation of the
selected remedy. If it is determined on the basis of the stated criteria,
that MCLs/MCLGs or other health-based ARARs cannot be achieved at the Site,
a waiver of ARARs will be invoked, which will be accompanied by an
Explanation of Significant Difference (ESD) or an amendment to the Record
of Decision.
ii.
soil CleanuD Levels
Cleanup levels for soils were developed to reduce risks associated with two
potential exposure scenarios. The first of these scenarios is the
potential ingestion of contaminated groundwater resulting from the leaching
of contaminants from unsaturated-zone soils into groundwater and the
transport of these contaminants to a receptor. The second is the potential
direct contact exposure to surficial soils in five areas off the Silresim
property and to unsaturated zone soils on the Silresim property (if the cap
were degraded and the fence removed). .
Unsaturated Soils
Soil cleanup levels were developed for unsaturated-zone soils to meet the
response objective of protecting human health from the ingestion of
groundwater contaminated by soils. (The unsaturated zone includes all soil
from one foot below ground surface to the water table, following dewatering
associated with the selected remedy). Cleanup levels for indicator
substances in unsaturated soils were based on the analysis of compounds
leaching from unsaturated-zone soils into the groundwater system and to a
hypothetical water supply well on the Silresim property.
It should be noted that the compliance point for groundwater (at the edge
of. the RCRA Subtitle C .cap) does not alter EPA's determination that cleanup
levels for the unsaturated zone soils be based upon a hypothetical water
supply located on the Silresim property. The flow and dilution of
contaminants from the center of the Silresim property to its edge is
negligible.
The MacKay partitioning model was utilized to calculate cleanup levels for
indicator substances identified for soils in the unsaturated zone. .ARARs
for the groundwater (i.e., MCLs) were used as inputs into the leaching
model. In the absence of an ARAR, the level corresponding to a 10-6 risk
level (for carcinogens) or a hazard quotient of one (non-carcinogenic
effects) was utilized. It should be noted that inorganics selected as
indicator substances in the baseline risk assessment were not evaluated in
the leaching analyses due to low solubility and absorptive properties; the
potential for these compounds to leach from soils at significant
concentrations is limited. consequently, inorganics are viewed as
presenting a risk primarily from the ingestion and direct contact of soils
and are therefore addressed in the following section (surficial soil
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TABLE 3
SILRESIM SITE
UNSATURATED SOIL CLEANUP LEVELS
carcinogenic
contaminants of
Concern
Volatile Orqanic ComDounds
. Benzene
'Carbon Tetrachloride
Chloroform
l,l-Dichloroethene
l,2-Dichloroethane
Methylene Chloride
Styrene
1, 1, 2, 2-Tetrachloroethane
l,l,2-Trichloroethane
Trichloroethene
Others
Bis(2-ethylhexyl)phthalate
l,2-Dichloropropane
Dioxin
Hexachlorobenzene
PAHs (carcinogenic)
PCBs
Non~carcinogenic
Contaminants
of Concern
Soil
Cleanup
Level CDDb)
Basis for
Model XnDut
Level of
Residual GW
Risk
4
5
40
5
1
1
170
6.
3
6
MCL
MCL
MCL
MCL .
MCL
pMCL
MCLG
PQL
.pMCL
. MCL
4E-06
2E-Os
2E-OS
lE-04
lE-Os
lE-06
9E-Os
3E-Os
8E-06
2E-06
300
3
1
34
10,000
2,300
pMCL
MCL
pMCL
pMCL
pMCL
MCL
2E-06
1E-Os
2E-04
SE-OS
7E-Os
lE-04
SUK
7E-04
Basis for
Cleanup Hodel
LevelCDDb) XnDut
Target Residual GW
Endpoint of Hazard
Toxicitv Quotient
Volatile Orqanic ComDounds
chlorobenzene 300 MCLG lvr/kdny 0.2
Trans-l,2-Dichlorothene 67 MCLG liver 0.2
I, I, I-Trichloroethane 300 . PQL liver 0.06
Others
1,2-Dichlorobenzene 8,900 MCLG liver 0.2
1, 2, 4-Trichlorobenzene 720 pMCLG liver 0.2
Ethylbenzene 6,800 MCLG lvr/kdny 0.2
Phenol 5,300 RfD body wt 1.0'
Toluene 2,700. MCLG lvr/kdny 0.2
2-Butanone 60 GWS fetotox 0.2
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RECORD OF DECISION SUHMARY
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SUM HAZARD INDEX
Liver:
Kidney:
Body Weiqht:
NOTE
1.2
0.6
1.2
a - Specific soil quantitation limits are hiqhly matrix dependent.
such, cleanup levels listed above are subject to the limits of
quantitation.
Rfd - Reference Dose
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For those soil. indicator compounds identified above as volatile organic
compounds (VOCs), cleanup levels must be met throughout the contaminated
. unsaturated zone (defined as one foot below ground surface to the water
table following dewatering associated with the remedy) at the Site. For
the remaining indicator compounds, unsaturated cleanup levels must be met
at and beyond the point of compliance (at and beyond the edge of the final
RCRA Subtitle C cap).
The remedial action includes vacuum/vapor extraction of all contaminated
soils exceeding cleanup levels to enhance mass removal of VOCs at the Site.
The cleanup levels for the remaining indicator substances will be met at
the point of compliance through excavation, stabilization and disposal
under a firial RCRA cap. Areas of excavation off of the Silresim property
will be backfilled with clean soil. Therefore, cleanup levels for all. of
. the unsaturated soil indicator compounds will be met. The RCRA cap,
stabilization and long-term maintenance will prevent exposure to
unsaturated soils and minimize the mobility to groundwater of the residual
waste left on Site.
iii. Surficial Soils
Cleanup levels for surficial soils were developed to reduce risks
associated with direct contact and ingestion exposures to contaminated
soils in five areas off the Silresim property and to soils on the Silresim
property, if the cap and fence were removed. No ARARs were available for
the indicator substances in soils, therefore, health-based levels
(concentrations corresponding to a 10-6 excess cancer risk level or a
hazard quotient of 1.0) were derived and other potential cleanup criteria
were compiled. .
Health-based cleanup levels were developed for soil indicator substances
that were found to pose a risk in excess of 10-6 or a hazard quotient of
1.0 when evaluated under a worst-case scenario in the baseline risk
assessment. This included seven VOCs, dioxins (as 2,3,7,8-TCDD
equivalents), PCBs, carcinogenic polycyclic aromatic hydrocarbons (cPAHs),
phenol and six inorganics.
Cleanup levels were derived for direct contact exposure including dermal
absorption and incidental ingestion by an older child/adult who may come
into contact with these areas. These levels were based on exposure
assumptions under a more-likely case scenario as developed in the FS. The
specific methodology used to calculate health-based cleanup levels is
presented in Appendix B of the RI.
Cleanup levels for two indicator substances are based on average background
concencentrations identified in surficial soils at the Silresim site.
Although the risk-based cleanup levels for PAHs and arsenic were calculated
to be more stringent than their average background levels, background
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TABLE 4
SILRESIM SITE
SURFICIAL SOIL CLEANUP LEVELS
carcinogenic
contaminants of
Concern
soil
Cleanup
Level (DD})
Basis
Level of
Risk
Volatile Orqanic
Benzene
l,l-Dichloroethene
l,2-Dichlo~oethane
Methylene Chloride
styrene
l,1,2,2-Tetrachloroethane
Trichloroethene
ComDounds
15,000
720
4,800
58,000
14,000
2,200
40,000
risk
risk
risk
risk
risk
risk
risk
1E-06
1E-06
1E-06
1E;"06
lE-06
1E-06
lE-06
others
Arsenic
Dioxin
PAHs (carcinogenic)
PAHs (total)
PCBs
21,000
1
11,000
29,000
1,000
background
pol icy'
background
background
policy
7E-078
4E-05
6E-05
6E-05b
2E-06
SUK
1E-04b
Non-carcinogenic
contaminant
of Concern
Lead
Cleanup
Level (DD})
500,000
Basis for
Hodel
InDut
policy
Target
Endpoint
of Toxicitv
CNS
Hazard
ouotient
c
a - Recent studies indicate that many skin tumors arising from oral
exposure to arsenic are non-lethal and that the dose-response curve for the
skin cancers may be sublinear (in which case the cancer potency factor used
to generate risk estimates will be overstated). It is Agency policy to
manage these risks downward by as much as a factor of ten. As a result,
the carcino~enic risk for arsenic at this site has been managed as if it
were 7 x 10.. (See EPA memorandum, "Recommended Agency POlicy on the
Carcinogenic Risk Associated with the Ingestion of Inorganic Arsenic" dated
June 21, 1988.)
b - Total PAH risk is based on the cleanup level of 11,000 for carcinogenic
PAHs. Therefore the risk of 6E-05 has only been incorporated once to the
sum total risk estimate.
c - The cleanup level for lead is based on OSWER Directive 9355.4-02,
"Interim Guidance on Establishing Soil Lead Cleanup Levels at Superfund
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detection of these compounds at elevated levels outside of the areas
suspected to be contaminated by surface run-off from the Silresim facility.
Because Silresim cannot be strictly implicated as the only source of these
constituents, it. is acceptable to consider local background concentrations
for PAHs and arsenic (See Section 3.20 in the FS for more detail).
The cleanup level assigned for PCBs is based on guidance established under
the Federal Toxic Substance Control Act (TSCA). TSCA has issued a
remediation goal of 1 ppm for PCBs at Superfund sites where land use is
residential in nature (exposures occur to residents). This level is
considered by EPA to be protective of human health and the environment.
Five of the surficial soil cleanup levels. designated in the Proposed Plan
have been eliminated, including: chromium, copper, mercury, phenol and
selenium. Based on further review and consideration of the data presented
in the RI/FS it was determined that none of the exposure pathways for each
of these compounds exceeded EPA's acceptable risk level. Chromium, copper,
mercury, phenol and selenium are non-carcinogenic compounds. The non-
carcinogenic risk posed by each compound, under each exposure pathway
considered, fell below a hazard quotient of one. Therefore, EPA has
omitted chromium, copper, mercury, phenol. and selenium from the list of
cleanup levels to be met in surficial soils at the Site.
For those indicator compounds identified above as volatile organic
compounds (VOCs), cleanup levels must be met in all surficial soils. For
the remaining compounds, cleanup levels must be met at and beyond the point
of compliance (the edge of the final RCRA cap). For soils on the Silresim
property, surficial soil cleanup levels for VOCs will also apply as a
result of the future exposure scenarios (cap and fence removed). The more
stringent of the two cleanup levels for each VOC will apply.
Again, the remedial action includes vacuum/vapor extraction of all
contaminated soils, which will enable the target cleanup levels to be met
both on and off. the Silresim property for VOCs only. The cleanup levels
for the remaining indicator substances will be met at the point of
compliance through excavation, stabilization and disposal under a final
RCRA cap. The .areas of excavations outside the Silresim property will be
backfilled with clean fill. The construction and maintenance of the RCRA
cap will prevent exposure to contaminated soils on the Silresim property.
Cleanup levels in surficial soils attain EPA's risk management goal for
remedial actions (carcinogenic risk level between 10-4 and 10-6).
iv.
Other Cleanup Levels
Because cleanup levels for soil and groundwater will be met, it is
unnecessary to set cleanup levels for indicator substances associated with
1) surface waters and sediments of East Pond, River Meadow Brook and
Concord River, 2) indoor air of Lowell Iron and Steel company and the
nearest residential building, and 3) ambient air. Each of these exposure
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RECORD OF DECISION SUMMARY
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Page 7S
either the groundwater or soil media for which cleanup levels are
established. EPA has determined that by meeting the cleanup levels for
both the soil and groundwater media, all risks associated with the
migration of contaminated groundwater or VOCs should be reduced. However,
a final risk assessment of residuals will address these concerns at a
future date.
. B.
DescriDtion of Remedial ComDonents
i.
Source Control
The source control portion of the remedy will involve the following major
components (Fiqure 6, Appendix A):
2.
3.
9.
10.
.11.
12.
13.
14.
15.
16.
1.
Post signs at the Site, construct additional perimeter fence and
maintain the existing fence;
Implement public education progr~ms and institutional controls;
Perform pilot test of vacuum/vapor extraction system to optimize
final design; .
Construct the vacuum/vapor extraction system;
Place low-permeability temporary cover over areas of contaminated
soil off the Silresim property:
Extend and repair cap on the silresim property as required;
start-up and operate vacuum/vapor extraction system until
acceptable VOC concentrations in soil are reached;
Perform additional bench-scale and/or pilot scale
stabilization/solidification studies;
strip and stockpile existing clay cap and gravel;
Excavate and stockpile all soils requiring stabilization;
Backfill areas outside of silresim property with clean fill;
Stabilize contaminated soils;
Perform confirmatory TCLP analyses;
Place treated soil under RCRA cap;
Upgrade existing cap to conform to RCRA Subtitle C standards; and
Perform long-term monitoring and five-year reviews.
4.
5.
6.
7.
8.
The first stage of the source control remediation will. include the
construction of additional fencing outside the limits of the existing
perimeter fence to prevent potential direct contact exposures with.
contaminated surficial soil. The site would be posted by placing clearly
labeled signs on the fence. Additionally a public education program to
inform the public about potential hazards at the site (via public meetings,
press releases, direct mailings etc.), and institutional controls,.
including access, deed and land use restrictions, to prevent the potential
use of contaminated areas would be established.
In situ vacuum/vapor extraction (also known as soil venting) will be
utilized to remove VOCs from approximately 137,000 cubic yards of
unsaturated-zone and surficial soils (Figure 7, Appendix A). Vacuum/vapor
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RECORD OF DECISION SUMMARY
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vacuum pumps or blowers
extraction wells. VOCs
further treatment prior
volatilize to a limited
to induce air
from soil and
to discharge.
extent.
flow towards a trench or a network of
water desorb into this air stream for
Semi-volatiles and PCBs may also
Soil gas probes, placed at varying distances from extraction wells or
trenches, are used to obtain vapor samples to assess the performance of the
system. Vacuum extraction systems are typically operated until observed
concentrations fall below target levels. The zone of influence of the
extraction system is monitored with manometers using the same boreholes as
the soil ga~ probes.
Trenches and potentially wells will be used for vacuum/vapor extraction.
The reliability and effectiveness of in situ systems has been well
demonstrated at many sites across the country, including a SITE (Superfund
Innovative Technology Evaluation) demonstration at Groveland,
Massachusetts.
A bench scale treatability study was performed to evaluate the
effectiveness of vacuum/vapor extraction on SiTresimsite soils (test
results are presented in Appendix F of the RI). Results of the test showed
that VOC cleanup levels can be attained for most target compounds after the
exchange of approximately 10,000 pore volumes.
The results of the treatability testing, along with information on soil
characteristics obtained during the RI, were used as input to a two-
dimensional soil. gas flow model to assess the time required to attain
cleanup levels with various well/trench spacings. Preliminary results
indicate that close well spacings will be required to provide acceptable
cleanup times. Trenches will allow somewhat wider spacing (approximately
18 trenches of varying length, with a nominal spacing of 45 feet), and
increased effectiveness in achieving cleanup levels in heterogeneous soils.
Trenches will be installed to the water table, to depths up to 14 feet.
The estimated times to achieve VOC cleanup levels for the soils at the Site
are:
approximately three years for the gravel fill on the Silresim
property which is part of the existing cap (placed in 1984).
approximately five years for the cinder and miscellaneous fill
material throughout the Site.
approximately 30 years for the natural sandy silts throughout the
Site.
The results of the treatability study indicate that vacuum/vapor extraction
will provide relatively short-term reduction of VOC concentrations in the
fill layers, but would need to be undertaken for a longer term to achieve
cleanup levels in the lower-permeability natural soils. A vacuum/vapor
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RECORD OF DECISION SUMKARY
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extraction pilot-scale test will be necessary to further evaluate its
.effectiveness and efficiency at the Site and to more closely estimate costs
(e.g., costs associated with spacing/location of extraction wells/trenches,
manifold and vacuum blower, and off-gas control requirements).
. Vapor extraction trenches and/or wells will be installed in the unsaturated
zone, and manifolded to vacuum pump(s) or blowers wit~ a thermal oxidizer
or fume incinerator (air pollution control). Using the selected
groundwater extraction system (MM-2), the water table will be lowered by an
additional 6 feet to increase the depth of the unsaturated zone (process
known as dewatering). The groundwater extraction and treatment system will
precede the" source control portion of the remedy by 6 to 12 months to
perform dewatering. The dewatering effluent would be treated by the
. groundwater treatment system.
As discussed above, excavation of a series of trenches across the Site will
be necessary to install the vacuum/vapor extraction piping system. It is
estimated that they will be approximately 18 inches wide, 14 feet deep (to
the groundwater table), and at 45 foot intervals (pigure 7, Appendix A).
Trenches would be partially backfilled with crushed stone wrapped in
geotextile, then completely backfilled with excavated soil and/or clay.
Figure 8 in Appendix A shows a typical section of an extraction or air
inlet trench. (Excavation will begin after the groundwater level is
depressed to steady state conditions. The groundwater extraction system
will be designed to achieve this depression in approximately .six to twelve
months).
The final determination of the number, depth, and locations of the trenches
and wells associated with the vacuum/vapor extraction system will be
finalized during the remedial design phase. These design details can be
provided through the initial pilot-testing of a full scale unit. Periodic
review and modification of the design, construction, maintenance, and
operation of the soil vacuum/vapor extraction system will be necessary.. A
frequency for reviewing the progress of the systems for meeting the goals
and design criteria will be established during the design phase.
During excavation, soil erosion will be controlled through the use of silt
fences, hay bales, shallow drainage ditches and/or grading. Shallow
drainage ditches will be constructed where necessary to facilitate drainage
of storm water away from the immediate work area, allowing excavation and
backfilling to be performed in areas free of standing water.
FOllowing the construction of drainage and erosion control structures,
clearing and grubbing would be performed in areas where vegetation.exists.
Any monitoring wells not intended for long-term monitoring will be
decommissioned, and wells intended for long-term monitoring would be
extended and capped at an elevation above finish grade.
stockpile areas would be prepared as necessary within the existing cap area
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would be graded to shed stormwater, and would conform to all applicable.
RCRA and TSCA specifications. Prior to placement of soil in the stockpile
area, a double layer of 6-mil polyethylene plastic sheeting will be placed
over the ground surface. Hayba1es and silt fencing will be placed around
the perimeter of the stockpile area to reduce losses of stockpiled soils.
A separate stockpile area will be maintained for clay cap material
excavated from the existing cap. Following stockpiling, approximately
1,500 to 1,750 cubic yards of soil excavated from trenches would be treated
by vacuum/vapor extraction along with the other in situ soils by placing
them under a cap extension in the northeast corner of the Silresim
property, described below.
During excavations, control mechanisms will be taken to prevent VOCs and
contaminated particulates from escaping to the atmosphere. Available
techniques to control releases of particulate matter during excavation may
include water and chemical (e.g., calcium chloride) application to the
soils, run-off controls, specialized excavation equipment (e.g., caisson
augers) and equipment decontamination. Techniques are available to reduce
the release of VOCs during excavation: however, these techniques are less
proven and generally more complex than particuTate controls. These include
the application of vapor suppressing foams, or the erection of domes or
air-sealed "tents" over work areas. Exhaust air from the domes or vents
would be treated to remove VOCs prior to discharge. The decision of which
control measures are necessary will be made during the remedial design
stage, however, the best demonstrated control technologies will be utilizec
in conformance with the Clean Air Act. .
Following the installation of the vacuum/vapor extraction piping, the
existing clay cap on the site will be extended and upgraded. This will be
done to enhance the effectiveness of vacuum/vapor extraction and to reduce
direct contact exposures. The existing cap was constructed by U.s. EPA
contractors as part of the 1984 Interim Remedial Measure. The cap consists
of approximately 14 inches of low permeability clay placed over 6 to 36
inches of sand and gravel. Any areas of the cap that may be eroded due to
stormwater runoff will be repaired to the standards of the existing cap.
Areas off of the "Silresim property to be treated using vacuum/vapor
extraction will be covered with a low-permeability cover. This interim
cover is intended to provide a barrier to air flow during the period of
operation of the vacuum/vapor extraction system.
The contaminated air stream from the vacuum/vapor extraction system will be
treated using a thermal oxidizer or fume incinerator to control the
emissions of VOCs. The thermal oxidation unit would include a scrubbing
system to remove acid gases. The treated air will meet all federal and
state emissions standards prior to being released to the atmosphere.
Collected condensate from the vacuum/vapor extraction system and aqueous
wastes from the thermal oxidizer (scrubber) will be either treated on Site
or shipped off Site for treatment. Following vacuum/vapor extraction to
remove the VOCs, approximately- 18,000 cubic yards of soil at the Site (on
and off of the Silresim property), contaminated with non-VOCs and inorganic
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compounds, will be excavated and stabilized (Fiqure 9, Appendix A).
Stabilization is a waste treatment process designed to accomplish one or
more of the following purposes: (1) reduce waste solubility, mobility and
toxicity: (2) improve handling characteristics: and (3) limit the potential
for migration by reducing the exposed surface area. It is the conversion
of a waste to a more chemically stable form or to a more solid form by the
'addition of a binding material, such as cement.
Several stabilization processes are commercially available for use with
hazardous wastes. Although many are proprietary, most are cement, lime, or
thermoplastic-based. Cement-based methods involve mixing ,contaminated
solids with a cement, such as Portland cement. The resulting high pH
material neutralizes acids and causes many metals to form less soluble
compounds. Lime-based methods are similar to those using cement, but
produce a less durable product. Thermoplastic methods involve drying, ,
followed by mixing with a heated, petroleum- or plastic-based material
(usually asphalt, although polyolefins have been used). It should be noted
that nearly all stabilization processes involve the addition of materials
to the waste, and thus increase the total waste volume (not mass of
hazardous constituents). Volume increases usually range from 20 to 60
percent.
Implementation generally involves soil excavation: mixing occurs at the
ground surface or in an above ground vessel. Because VOCs will have been
stripped out of the soil via the vacuum/vapor extraction system prior to
excavation, it is expected that only minimal controls during excavation and
processing will be necessary to prevent additional volatilization. It
should be noted that, occupational Safety and Health Administration (OSHA)
general industry and health and safety requirements for the performance of
excavation and transportation activities, including trench excavation
requirements will be met during the remedial design and remedial action.
The soil to be stabilized, and the overlying clay and gravel, will be
excavated and stockpiled separately according to the methods described
above. Stabilization will be implemented using a mobile treatment plant.
Excavated areas outside of the Silresim property will be backfilled with
clean fill. TCLP analyses would be performed on treated soils to confirm
the effectiveness of the treatment prior to final disposal on the Silresim
property.
During the remedial design phase, additional soil samples will be collected
to refine the volume of soil to be treated in the northern portion of the
site. In 1990, the northern portion of the site was regraded by the owners
of the property. Therefore, pre-design work will include analysis of
samples collected north of the Silresim property for all surficial soil and
unsaturated soil indicator substances (see Tables 7& 8 above).
All stabilized soil will be disposed of under a cap conforming to RCRA
subtitle C standards located primarily on the Silresim property. Due to
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RECORD OP DBCISION SUMKARY
si1resim site
Page 8~
cap is likely to exceed the limits of the existing fence on the Silresim
property. It is expected, therefore, that the RCRA cap will extend beyond
the existing fence just northeast, east and southeast of the Silresim
property. Access to some or all of this property may have to be acquired.
site preparation activities for cap construction will include grading and
removal of debris, fences, scrap vehicles, etc.
. The cap design will be consistent with the state and Federal closure
.requirements for a RCRA facility. At a minimum, the cap will consist of a
mUlti-layer system composed of a vegetative topsoil layer and a subsurface
drainage layer overlying a low-permeability bar~ier of clay and synthetic
liner material. The details of the materials of construction and the
thickness of the layers will be established during the remedial design
phase. .
It is estimated that all components of this remedy will be implemented
within seven years after the completion o~ remedial design, although
approximately 30 years would be required to achieve cleanup levels in the
natural soils at the Site. This assumes that cleanup levels for VOCs in
soils to be excavated and stabilized are reached in approximately five
years, that stabilization will be implemented within one-half year
(assuming a production rate of 180 cubic yards per day), and that the cap
would be constructed in approximately one and one-half years.
Because contaminated materials would remain on site in stabilized form,
long-term monitoring and five-year reviews would need to be implemented.
The 1986 CERCLA amendments require that conditions be reviewed every five
years at NPL sites where wastes remain on site. All data obtained in the
monitoring program would be evaluated in the five-year reviews. These
reviews will consider all relevant data and determine if additional
remedial actions are necessary.
ii.
Manaqement of Miqration
The Management of Migration portion of the remedial alternative will
include the following major .components (Piqure 10, Appendix A):
1.
2.
3.
4.
5.
6.
7.
Implement.public education programs;
Implement institutional restrictions on future water use; .
Install groundwater extraction wells, pumping equipment and
associated piping; .
Install treatment equipment, building, and discharge piping;
start-up and operate extraction, treatment, and discharge
systems; .
Dispose of non-aqueous phase contaminants and secondary wastes
generated during the operation of the treatment process; and
Perform long-term monitoring and five-year reviews.
Public education programs and institutional restrictions would primarily be
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RECORD OP DECISION SUKKARY
silresim site
Page 81
remedy. In terms of institutional controls, water use restriction clauses
would be added to property deeds in areas of known groundwater
contamination.
As discussed in the section on cleanup levels, the aquifer at the Site is a
Federal Class IIB water body and Massachusetts Class I water body, which is
a potential source of drinking water. Therefore, MCLs and non-zero MCLGs
established under the Safe Drinking Water Act are ARARs.to be met at the
points of compliance, which EPA has set at the edge of the RCRA cap,
approximately shown on piqure 9 in Appendix A. Since groundwater ARARs are
currently exceeded at the points of compliance and the risk to human health
significantly exceeds EPA's acceptable risk range in this ~rea, active
groundwater treatment is required to meet and sustain groundwater ARARs.
The groundwater extraction system will consist of numerous conventional
extraction wells, located in both the overburden and bedrock aquifers
within the contaminated groundwater plume to maximize groundwater
extraction rates. It is estimated, for cost purposes only, that an
aggressive extraction scheme will include at least 9 shallow (about 25 to
40 feet deep) wells,S moderate depth (50 to 6~ feet) wells, 4 deep
overburden (60 to 70 feet) wells, and 5 shallow bedrock (20 to 30 feet into
bedrock) wells.
The extraction system will be designed to halt further migration of
contaminated groundwater toward identified receptors (basements, River
Meadow Brook, East Pond), capture as much of the contaminant plume as
possible, and ac~ieve drawdowns across the site in support of the source
control remedy. Extraction well locations will be selected, in part,
especially to intercept groundwater contamination migrating toward
vulnerable receptors such as industrial and residential basements, East
Pond and River Meadow Brook.
It is estimated that, on average, each extraction well will contribute
between 0.2 to 2 gallons per minute (qpm) of flow, yielding a total
estimated flow of about 25 qpm. (Potential yields of bedrock wells can
only be roughly estimated at this point). To better refine estimates of
well flows, a pUmp test will be conducted during the remedial design phase.
It is noted that selected deep overburden and shallow bedrock extraction
wells will be located within the zone of suspected DNAPL contamination.
siting extraction wells in this zone will provide dewatering to facilitate
soil vapor extraction, enhance containment of dissolved phase
contamination, and enhance mass removal rates. EPA believes the benefits
of siting extraction wells in this zone outweigh the potential risk of
mobilizing DNAPL to greater depths during well drilling. Special
precautions will be taken during the bedrock well installations to minimize
the potential for introducing additional DNAPL into the bedrock. The
specific number and locations of extraction wells targeting DNAPL
contamination will be finalized during the remedial design phase, following
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RECORD OF DECISION SUMMARY
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conditions.
Following groundwater extraction, the water will be pumped to a phase
separation settlement tank, where gravity separation of contaminated water
. from non-aqueous phase contaminants, such as floating product and DNAPL,
would occur. The tank will be designed to allow gravity separation of
aqueous and non-aqueous phase contaminants at the destgn flow rate.
Floating product will be skimmed from the surface; dense non-aqueous phase
contaminants will be removed fram the bottom of the tank. The remaining
aqueous stream will flow by gravity into the iron/manganese removal system.
Removal of iron and manganese will be required prior to air stripping to
. reduce clogging of the air stripper and reduce iron and manganese .
concentrations to within discharge limits. As indicated in the RI, iron
concentrations up to 268 mg/l (ppm) and manganese concentrations up to 12.3
mg/l have been observed in Silresim groundwater. These concentrations
indicate that iron/manganese removal is required to reduce clogging of
treatment equipment. Metals other than iron and manganese exist at average
concentrations less than likely effluent limits, and therefore may not
require removal. However, some incidental removal of metals other than
iron and manganese will occur during treatment.
A chemical precipitation/filtration unit will be utilized to remove the
metals. Chemical precipitation removes dissolved metals' by precipitating
them as hydroxides or sulfides. Adjustment of pH may be used to maximize
removal of desired metals. Chemical precipitation/filtration equipment
will consist of chemical storage. tanks, a chemical mixing tank, a
flocculation tank, and a clarifier. A chemical precipitant would be added
to the contaminated groundwater in the mixing tank. Dissolved metals,
primarily iron and manganese, will be converted to insoluble forms by
reaction with the precipitant. Flocculation will be used to agglomerate
precipitates and other solids into settleable particles. The resulting
solids will be settled out in the clarifier, possibly after addition of
settling aids such as polYmers. A subsequent filtration step will remove
additional solids not removed by the clarifier. Each tank will require
some form of VOC emissions control such as fume hoods or tank covers with
vents.
Air stripping will be accomplished using either a counter-current air
stripping tower or a tray aerator. This decision will be made during the
design stage. A stripping tower consists of a vertical tower filled with
packing material. contaminated water flows downward through the packing
material while air is forced upward through the tower by a blower. The
large surface area of the packing material improves contact of contaminated
water with the flowing air. Contaminated air exits the top of the tower,
and is directed to subsequent treatment to remove volatilized organics.
Tray aerators operate on the same principle as a packed tower, but differ
substantially in construction'; The unit consists of stacked, perforated
trays across which water flows while air is bubbled through from beneath
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Prior to air stripping, the influent will be heated. Air stripper removal
efficiencies can be increased by heating the influent groundwater prior to
air stripping. Heating will be accomplished by using either steam or
another heating method (to be decided during the design phase). Heating of
influent results in more efficient stripping and thus reduces the organic
loading on the liquid-phase carbon adsorbers.
Volatilized organics from the air stripper will be destroyed by thermal
oxidation. The thermal oxidation unit will require an auxiliary fuel
source to incinerate the volatile emissions, and a scrubbing system to
remove acid-gasses. This thermal oxidation unit will be utilized for the
vapor streams of both the groundwater treatment system and vacuum/vapor
extraction system employed as part of a source control portion of the
remedy. This system satisfies a specification of the Clean Air Act to
utilize the best demonstrated control technology to minimize VOC emissions.
Occupational Safety and Health Administration (OSHA) general industry and
health and safety requirements specifying permisssible Exposure Limits and
other safety and health requirements during implementation will be met.
Following on-site treatment, the treated water will preferably be
discharged to the City of Lowell's sanitary sewer system, which flows to
the Duck Island Wastewater Treatment Facility (this will be determined
during the remedial design phase). If this facility is able to be
utilized, a connecting pipe will be constructed from the groundwater
treatment building to a nearby (existing) sewer line with available
capacity to handle the expected flow. Discharges will conform to the sewer
use ordinances (which include a TTO (Total Toxic organics) standard of 2.13
mg/1, and may include toxicity-based standards). The Duck Island treatment
plant discharges treated water to the Merrimack River under an existing
National Pollutant Discharge Elimination System (NPDES) permit.
If the Duck Island Wastewater Treatment Facility is unable to be utilized,
the. groundwater will be discharged to River Meadow Brook (this will be
determined during the remedial design phase). Discharge to River Meadow
Brook will involve construction of buried piping from the on-site treatment
building to either the Brook, which at its closest point is approximately
400 feet from the site boundary, or to a storm drain that flows to the
Brook. It is likely that the new pipeline would cross both public land
(e.g., Tanner Street) and private land. Easements will be required from
the affected parties. A gravity piping system shall be installed from the
treatment building to the drainage system installed on site by EPA in 1984.
If discharge to River Meadow Brook is selected, a NPDES permit will be
obtained.
Secondary waste management would be required for off-site disposal of non-
aqueous phases from gravity separation (e.g., DNAPL, floating product), and
residues from the metals removal process (e.g., metals hydroxide sludge
from chemical precipitation).
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As stated above under the Cleanup Levels section, EPA is unable to reliably
predict when cleanup levels at the points of compliance can be achieved.
The combination of high concentrations of contaminants in the qroundwater,
expected low groundwater extraction rates due to low permeability of
aquifer materials, and the existence of DNAPL prevent a reliable
estimation. EPA does, however, believe that achievinq cleanup levels at
the points of compliance will take in excess of thirty years given the
, current conditions at the Site and state of technology.
EPA believes that long-term groundwater remediation for the Silresim Site
is reasonable given the serious potential exposure risks posed by the
continued migration of the plume to nearby receptors (residential
basements, East Pond, River Meadow Brook, potential drinking water wells,
etc.). Therefore, the qroundwater extraction and treatment system will be
implemented to meet interim cleanup levels in the shortest time possible.
Periodic review and modification of the design, construction, operation,
maintenance and monitoring of the groundwater extraction and treatment
system will be necessary. If the performances of the systems are not
meeting the design criteria, adjustment or modi~ication may be necessary.
These adjustments or modifications may include relocating or adding
extraction wells or alternating pumping rates. Switching from continuous
pumping to pulsed pumping may improve the efficiency of contaminant
recovery and should be evaluated and necessary modifications undertaken.
Should new information regarding the extraction and treatment technology
become available, it will be evaluated and applied as appropriate.'
As described above under the source control portion of the remedy, when
waste remains on site long-term monitoring is required to record and allow
evaluation of trends in contaminant concentration and extent of contaminant
migration. Monitoring will consist of sampling and analyses of surface
water, groundwater, and downgradient sewers.
As part of the long-term monitoring program, additional groundwater
monitoring wells may be needed to further define the lateral extent and
depth of contamination in the plume. Additional groundwater sampling and
analyses would be required ,for the' indicator substances during remedial
design to update water quality data from the RI and on a regular basis
throughout the remediation. Specific wells and analytical parameters may
be added or deleted depending on sampling results and observed trends.
Additionally, surface waters of East Pond and River Meadow Brook, and
basement air from neighboring residential and industrial buildings may need
to be sampled periodically to evaluate the migration of groundwater to
those receptors.
Again, to the extent required by law, 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
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completion of the remedial action (i.e., before the site is proposed for
deletion from the NPL).
XI.
STATUTORY DETERK~TIONS
The remedial action selected for implementation at thesilresim 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 ~lso satisfies the
statutory p'reference for treatment which permanently and significantly
reduces the mobility, toxicity or volume of hazardous substances as a
principal element. Additionally, the selected remedy utilizes alternate
treatment technologies or resource recovery technologies to the maximum
extent practicable. .
A.
The Selected Remedy 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, red~cing or controlling
exposures to human and environmental receptors through treatment,
engineering controls, and institutional controls; more specifically the
vacuum/vapor extraction, stabilization and capping of contaminated soils,
and the collection and treatment of contaminated groundwater at the edge of
the RCRA Subtitle C cap will reduce the risks posed to human health and the
environment. The stabilized waste deposited on the Silresim property will
remain in place. Potential direct contact and ingestion of contaminated
soil, and inhalation of volatilized organics from the soil will be
. eliminated through treatment and capping. continued migration of
contaminants to surface water, sediments, and basement air will be
eliminated as a result of the groundwater extraction and treatment system,
thus effectively reducing exposure risks.
The remedial actions, as proposed, will be protective of human health and
the environment. Vacuum/vapor extraction will permanently reduce the
toxicity, mobility and volume of VOCs, and some semi-VOcs, which constitute
the primary contaminants at the site. stabilizing and capping the residual
contaminants in soil will significantly reduce further migration (leaching)
of those contaminants into the groundwater. Treatment of groundwater will
also reduce the toxicity, mobility and volume of contaminants in the .
groundwater; treatment will retard the migration of the contaminated plume
and halt further contamination of the aquifer. Extraction and treatment
will continue until contaminant concentrations are deemed to be protective
of human health and .the environment. A long-term monitoring program will
ensure the remedy remains protective of human health and the environment.
Again, the final groundwater cleanup levels will be determined as the
result of a risk assessment performed on residual groundwater contamination
after all interim cleanup levels have been met. Unless the resultant
cumulative risk is within the 10-' to 10-6 incremental risk range and the
cumulative hazard index for similar target endpoints is below the specified
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level of concern, remedial actions shall continue, until protective levels
are attained. Finally, implementation of the selected remedy will not pose
unacceptable short-term risks or cross-media impacts since the technologies
are proven and will be field tested to reduce operational risks, and.
special engineering precautions will be used to minimize potential for air
releases of contaminants.
B.
The Selected Remedy Attains ARARs
This remedy will attain all applicable or relevant and appropriate federal
and state ~equirements that apply to the Site. Substantive portions of
environmental laws from which ARARs for the selected remedial action are
derived, and the specific ARARs include (among others) those listed below.
Appendix D of this ROD contains a table of all ARARs identified for this
Site and whether they are applicable, relevant and appropriate or to be
considered. Within the table is also presented a brief synopsis of the
requirements and the action to be taken to meet them.
i.
Chemical SDecific
Massachusetts Groundwater Quality Standards - Applicable
Standards include Groundwater Classification;
Water Quality Criteria to Sustain the Designated
Uses; and Regulations to Achieve Uses and
Maintain Groundwater Quality - 314 CMR 6.00.
Massachusetts Air POllution Control Regulations - Applicable
310 CMR 7.01, 7.02 (2) (a), 7.06, 7.09, 7.10, and 7.18
Massachusetts Operation and Maintenance and Pretreatment Standards for
Waste Water, Treatment Works, and Indirect Discharges, 314 CKR 12.00 -
Applicable
Massachusetts Surface Water Discharge Permit Requirements ~ Relevant and
Appropriate
Regulates discharges to surface waters and any treatment works
associated with discharges. Applicable if groundwater is discharged
to River Meadow Brook - 314 CMR 3.00.
Federal Safe Drinking Water Act (SDWA) - Relevant and Appropriate
National Primary Drinking Water Regulations (NPDWR)
40 CFR 141.
Maximum Contaminant Levels (MCLs) and Maximum Contaminant
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Massachusetts Drinking Water Regulations - Relevant and Appropriate
Massachusetts Maximum contaminant Levels (MMCLs).
MMCLs for compounds detected at the Silresim site are
Federal MCLs Adopted by DEP- 310 CMR 22.00.
Clean Air Act (CAA) - Relevant and Appropriate
National Ambient Air Quality standards (NAAQS) for
Total Suspended Particulates (during excavations) - 40 CFR
Part 50.
NAAQS for Hazardous Air Pollutants such as NO., S02' CO, Lead, and
Mercury - 40 CFR 1 to 99.
Massachusetts Ambient Air Quality Standards, 310 CKR 6.00 - Relevant and
Appropriate
Massachusetts Prevention and/or Abatement of Air POllution 310 CKR 8.00 -
'Relevant and Appropriate
ii.
Location SDecific
Massachusetts Wetlands Protection Act (WPA) Regulations - Applicable
100 foot buffer zone of wetlands (East Pond, River Meadow Brook) is
regulated under WPA - 310 CMR 10.00. .
Massachusetts Hazardous Waste Paci1ity siting Regulations - Relevant and
Appropriate
Provides substantive requirements for the siting of hazardous waste
facilities - 990 CMR 1.00
iii.
Action SDecific
Clean Water Act (CWA) - Applicable
National Pollution Discharge Elimination System ,(NPDES)
A NPDES permit is required if treated groundwater were discharged off-
site to the surface waters of River Meadow Brook - 40 CFR 107, 171.1
to 171.5. '
Massachusetts Air Pollution Control Regulations - Applicable
310 CMR 7.01, 7.02 (2) (a), 7.06, 7.09, 7.10, and 7.18
Toxic Substances Control Act (TSCA) - Applicable
Regulates the Disposal and Storage of PCBs.
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RECORD OF DECXSXON SUMMARY
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Massachusetts Operation and Haintenance and Pretreatment Standards for.
Waste water, Treatment Works, and Xndirect Discharges, 314 CxR 12.00 -
Applicable .
Massachusetts Surface Water Quality Standards - Applicable
Regulations recommend the use of Federal Ambient
Water Quality criteria (FAWQCs) to establish water quality
for toxic pollutants. Applicable if groundwater is
discharged to River Meadow Brook - 314 CMR 4.04 and 314 CMR
4.06(2).
Massachusetts operation and Maintenance and Pretreatment Standards for
Wastewater Treatment Works and Xndirect Discharge - 314 CMR 12.00
Massachusetts Hazardous Waste Regulations, 310 CxR 30.00
These regulations are consistent with RCRA and provide for the
identification, handling, transport, and record keeping of hazardous
waste. . .
310 CMR 30.500, 30.561, 30.590, 30.610 - 30.633, 30.640, 30.660
are relevant and appropriate requirements
310 CMR 6.80 and 310.690 are applicable.
Clean Air Act (CAA) - Relevant and Appropriate'
National Ambient Air Quality standards (NAAQS) for
Tota~ Suspended Particulates (during excavations) - 40 CFR Part 50.
NAAQS for Hazardous Air Pollutants such as NOx' S02' CO, Lead, and
Mercury - 40 CFR 1 to 99.
utilize Best Demonstrated Control Technologies for emissions.
Massachusetts Ambient Air Quality standards, 310 CKR 6.00 - Relevant and
Appropriate
Massachusetts prevention and/or Abatement of Air POllution 310 CKR a.oo -
Relevant and Appropriate
Resource Conservation and Recovery Act - Relevant and Appropriate
RCRA Subtitle C, 40 CFR 260 - Regulates the Generation, Transport,
Excavation, Storage, Treatment and Disposal of Hazardous Waste.
General RCRA Part 264 requirements that are relevant and
appropriate to this remedial action involving on-site treatment,
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RECORD OP DECISION SUMMARY
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preparedness and prevention (Subpart C); contingency plan and
emergency procedures (Subpart D); groundwater protection (Subpart F);
closure and post-closure requirements (Subpart G); and landfills
(cap).
RCRA 40 CFR 268 - Land Disposal Restrictions.
Massachusetts Sur~ace Water Discharge Permit Requirements - Relevant and
Appropriate
Regulates discharges to surface waters and any treatment works
associated with discharges. Applicable if groundwater is discharged
to River Meadow Brook - 314 CMR 3.00'.
Massachusetts Public Health Regulations, 105 CKR 670 - Relevant and
Appropriate
Massachusetts "Right to KnoW" Regulations, 310 CKR 33.00 and 554 CHR 21.00
- Relevant and Appropriate
A discussion of why these requirements are applicable or relevant and
appropriate may be found in the FS Report at pages 22 to 33.
The following pOlicies, criteria, and guidance (among others) will also be
considered (TBCs) during the implementation of the remedial action:
To Be considered
Pederal Safe Drinking Water Act (SDWA)
Proposed Maximum contaminant Levels (pMCLs) and Proposed Maximum
contaminant Level Goals (pMCLGs) under NPDWR-40 CFR. 141.
American Conference of Governmental Industrial Hygienists (ACGIH)
,Threshold Limit Value (TLV), ~ime Weighted Average (TWA) and Short-
Term Exposure Limit (STELs) for basement air of Lowell Iron and Steel.
Clean Water Act (CWA) - Federal Ambient Water Quality criteria (FAWQCs).
EPA Reference Doses (R~D) - For Noncarcinogens.
EPA Lifetime Health Advisories - Office of Drinking Water.
EPA Risk speci~ic Doses - For Carcinogens.
EPA Directive for Lead - OSWER Directive 9355.4-02.
Agency for Toxic Substances and Disease Registry (ATSDR), dioxins
Massachusetts Allowable ,Ambient Limits (AALs) and Threshold Effects
Exposure Limits (TELs).
Massachusetts Office o~ Research and Standards Drinking Water Guidelines
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i(a) .
Chemical SDecific
Federal and state Drinkinq Water Standards
The groundwater aquifer at and beyond the compliance boundary is classified
as Class IIB under the Federal Groundwater Protection Strateqy and Class I
by the Commonwealth of Massachusetts, which is a source of potable water.
While Maximum contaminant Levels (HCLs) and Maximum Contaminant Level Goals
. (MCLGs) promulgated under the Federal Safe Drinking Water Act are not
applicable to groundwater, they are relevant and appropriate to groundwater
cleanup bec~use the groundwater may be used as a drinking water source. In
addition, the NCP requires that usable groundwater be restored to their
beneficial uses whenever practicable. See 40 CFR 300.430(a) (iii) (F).
Massachusetts groundwater quality standards for Class I groundwater issued
in 314 CMR 6.00 are applicable requirements for the Silresim site. The
state drinking water standards that are relevant and appropriate for
groundwater as a potential drinking water supply are the Massachusetts
Maximum contaminant Levels (MMCLs) issued under 310 CMR 22.00. .MM~Ls for
compounds detected at the Silresim Site are federal MCLs and MCLGs adopted
by DEP.
In addition to the Federal and state regulatory standards and guidelines
for drinking water and groundwater, risk-based criteria are to be
considered. These criteria include concentrations derived from EPA
Reference Doses (RfDs) and risk-specific doses based on carcinogenic
Potency Factors (CPFs) and standard exposure assumptions for the ingestion
of drinking water.
This remedy will attain these ARARs as well as those identified in Appendix
D, and will comply with those regulations which have been identified as
TBCs by meeting the groundwater cleanup levels at the compliance points
through the groundwater treatment system. Removing the VOCs from the soil,
stabilizing the residual contaminants in soil and capping of the site will
further reduce the volume of leachate generated. The soil and groundwater
treatment systems will reduce levels of contamination at the Site to the
interim cleanup levels. identified in this ROD. Treated groundwater will
also meet Federal standards, State criteria for drinking water, and the
discharge requirements to either the POTW or River Meadow Brook which
include Massachusetts Surface Water Discharge Permit Requirements (314 CMR
3.00), and Massachusetts Surface Water Quality Standards (314 CMR 4.04, 314
CMR 4.06(2». If the treated groundwater is discharged to River Meadow
Brook, the applicable requirements of the Massachusetts certification for
Dredging, Dredged Materials, Disposal and Filling in Waters of the.
Commonwealth will be met (314 CMR 9.00).
Federal and State Air Oualitv Standards
Federal Primary and Secondary National Ambient Air Quality Standards
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carbon monoxide, ozone, nitrogen oxides, lead and particulate matter.
Silresim is located in a non-attainment area for ozone and carbon monoxide.
Generation of fugitive dusts and air emissions from soil excavation and
treatment facilities (air stripper and vacuum extraction systems) are
subject to NAAQS. Maximum achievable control technologies will be utilized
to promote and maintain public health and welfare.
Massachusetts air regulations include Ambient Air Quality Standards (310
CMR 6.00), Air Pollution Control Regulations (310 CMR 7.00) and
requirements for the Abatement of Episodic and Incidental Air Pollution
Emergencies (310 CMR 8.00). Certain provisions of' 310 CMR 7.00 which
require th~ best available emissions controls and specify.ambient air
quality standards are applicable and will be met. The remaining state
standards for fugitive emissions from excavation, and emissions from
treatment equipment associated with this remedy are relevant and
appropriate, and the substantive. requirements will be met.
These Federal and State air standards will. guide mitigation measures
designed to control the release of fugitive dust and particulate matter
during excavations at the Site as well as limit VOC emissions from the
vacuum/vapor extraction and air stripper treatment systems at the Site.
For the evaluation of volatiles released from groundwater seepage in the
Lowell Iron & Steel building, occupational criteria, namely Threshold Limit
Values (TLVs), are criteria To-Be-Considered. TLVs refer to airborne
concentrations of substances, and represent conditions under which it is
believed that nearly all workers may be repeatedly exposed day after day
without adverse effect. TLVs are recommendations issued by the American
Conference of Governmental Industrial Hygienists (ACGIH) and are used as
guidelines in the control of potential occupational health hazards.
Given the nature of potential' exposures at Lowell. Iron & Steel and the
definition of the TLVs, the TLV Short Term Limits (TLV-STL) are relevant
criteria for evaluating short-term exposures that may occur when volatiles
are released from basement seepage during sporadic flooding events. The
TLV Time Weighted Average (TLV-TWA) is relevant for assessing long-term
exposures during dry periods when volatiles may be released into the
basement on a chronic basis. Through the treatment of. soil and groundwater
at the Site, relevant TLVs will be met.
ii(a).
Location Snecific
River Meadow Brook and East Pond are wetlands under the Massachusetts
Wetlands Protection Act (WPA) Regulations (310 CMR 10.00). While the
Silresim site lies outside of the 100-foot buffer zone under jurisdiction
of the WPA for both of these wetlands, portions of the groundwater
contaminant plume are within the buffer zone of East Pond. Activities
associated with management of migration (groundwater extraction well
installations, discharge line construction, etc.) within the 100-foot
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,be met.
iii(a)~ Action SDecific
Federal Primary and Secondary National Ambient Air Quality Standards
(NAAQS) under the Clean Air Act (CAA) and Massachusetts air pollution
regulations (310 CMR 6.00-8.00) are also action specific ARARs. The
discussion of these requirements is found above under section i(a),
Chemical Specific ARARs.
These Federal and State air standards will guide mitigation measures
designed to control the release of fugitive dust and particulate matter
, during excavations at the site as well as limit VOC emissions from the
vacuum/vapor extraction and air stripper treatment systems at the Site.
Under the Clean Water Act (CWA), the National Pollution Discharge
Elimination System (NPDES) permit requirements for point-source discharges
are relevant and appropriate if treated groundwater is discharged to River
Meadow Brook. These requirements include compliance with technology-based
standards, water quality criteria, discharge monitoring systems and records
maintenance. Federal water quality standards will be complied with. In
addition, CWA regulations governing CERCLA wastewater discharge to a POTW
are applicable. Discharges to the "Duck Island Treatment Plant and
pretreatment standards for discharges will be met (if POTW discharge is
selected during remedial design).
Discharges to surface waters of Massachusetts and the outlets for such
discharges and any treatment works associated with these discharges are
regulated. These regulations, include the Massachusetts Surface Water
Discharge Permit Requirements (314 CMR 3.00), Massachusetts Surface Water
Quality standards (314 CMR 4.04, 314 CMR 4.06(2» and Massachusetts
certification for Dredging, Dredged Materials, Disposal and Filling in
Waters of the Commonwealth (314 CMR 9.00). As discussed above under
Chemical Speqific ARARs, these regulations are ARARs and will be met
through treatment and proper controls on the remedial components.
RCRA regulations are relevant and appropriate to the source control and
management of migration portions of the remedy. The portions of RCRA
Subtitle C that are relevant and appropriate to on-site treatment, storage
or disposal include preparedness and prevention (Subpart C): contingency
plan and emergency procedures (Subpart D): groundwater protection (Subpart
F): closure and post-closure requirements (Subpart G): waste piles
(Subpart L): and landfills, (Subpart N). Massachusetts Hazardous Waste
Regulations that pertain to above ground storage conainers and tanks used
to treat or store hazardous waste is applicable and will be met (310 CMR
30.680 and 30.690). Additional Massachusetts Hazardous Waste Regulations
that pertain to handling, storage, treatment and disposal of hazardous
waste on-site are relevant and appropriate requirements and'will be met
through proper design and implementation of the remedial components. The
off-site treatment and disposal of wastes generated from the soil and
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groundwater treatment systems at this site must meet all Federal and state
requirements (administrative requirements are not ARARs, however, the
substantive requirements must be met). Because the Massachusetts Hazardous
Waste Program is authorized to administer the RCRA regulations listed
above, the state regulations will be the operative requirements to be met.
The Land Disposal Restrictions (40 CFR 268) of Hazardous and Solid Waste
Amendments of RCRA apply to characteristic RCRA hazardous waste at the
site. Under source control, LDRs are triggered because soil contaminated
with RCRA characteristic waste will be excavated, treated above ground in a
stabilization unit and disposed of on the Silresim Site within one area of
contamination. EPA has determined that fol!owing treatment, LDRs for RCRA
hazardous substances at the Site will be met. However, the final
, determination will be made following treatment of the soil to determine
whether the regulated levels have been met and the remedy is in compliance
with LDRs. The comprehensive analysis of LDRs for each of the alternatives
considered in'the detailed analysis is embodied in a separate report titled
"Final Assessment of LDRs; Silresim site" dated June 6, 1991 which is in
the Adminstrative Record. '
The PCB Disposal Requirements promulgated under TSCA are applicable to the
remedy because the selected remedy involves storage and disposal of soils
contaminated with PCBs in excess of 50 ppm. Under the Disposal
Requirements, soils and sediments contaminated with PCBs may be disposed of
in an incinerator meeting the standards of 40 CFR Section 761.69 or a
landfill meeting the requirements of 40 CFR Section 761.75. Under the
provisions of 40 CFR section 761.75(c) (4), the EPA Regional Administrator
may waive one or more of the specified landfill requirements upon, finding
that the requirement is not necessary to protect against an unreasonable
risk of injury to human health or the environment from PCBs. ' In this case,
placement of soils with PCBs, which have been stabilized, under a RCRA cap
will provide a permanent and protective remedy that satisfies the
requirements of the ~art 761 landfill regulations. Long-term monitoring of
groundwater wells will also be instituted, as required by the ,chemical
waste landfill regulations.
The Regional Administrator is excercising the waiver authority contained
within the TSCA regulations at 40 CFR Section 761.75(c) (4), and is waiving
certain requirements of the chemical waste landfill regulations. The
provisions to be waived require construction of chemical waste landfills in
certain low permeable clay conditions [Section 761.75(b) (1)], the use of a
synthetic membrane liner [Section 761.75(b) (1)], and that the bottom of the
landfill be 50 feet above the histroic high water table [Section
761.75(b) (3)].
The Regional Administrator hereby determines that, for the following
reasons, the requirements of 40 CFR Sections 761.75(b) (1), and (3) are not
necessary to protect against an unreasonable risk of injury to human health
or the environment from PCBs in this case. Among the primary reasons that
-------
RECORD OF DECISION SUMMARY
silresim Site
Page 94
detection and concentrations of PCBs detected in Site soils. PCBs are not
the primary threat at this Site. Although there were a limited number of
samples analyzed with PCBs over 50 ppm, the majority had concentrations
below 1 ppm and at non-detectable levels. In contrast, the landfill
requirements that are waived are designed to protect against the risk from
disposal of PCBs at levels no lower than 50 ppm. The specifications
. regarding liners, soil conditions and depth to groundwater wer~ designed to
protect against the risks that high levels of PCBs will migrate into
groundwater or be released to air or surface water.
Low permeability clay conditions, a synthetic membrane 1i~er for the
underlying substrate, and 50 foot soil barrier to the water table are
unnecessary requirements at this site to prevent migration of PCBs. The
soil will be stabilized and disposed of on Site in excavated areas within
the upper portion of the unsaturated zone. Disposal of stabilized and
capped waste in this zone will minimize the hydraulic connection between
the treated soils and groundwater and subsequent migration of PCBs in
groundwater. Furthermore, given the low mobility of PCBs in stabilized
soils, migration of PCBs to groundwater would be minimal.
This remedy will also comply with the storage requirements of the PCB
Disposal Regulations by the construction of a temporary storage area
meeting the standards of 40 CFR section 761.65.
C.
The Selected Remedial Action is Cost-Effective
In the Agency's judgment, the selected remedy is cost effective, i.e., the
remedy affords overall effectiveness proportional to its costs. In
selecting this remedy, once EPA identified alternatives that are protective
of human health and the environment and that attain, or as appropriate,
waive ARARs, EPA evaluated the overall effectiveness of ~ach alternative by
assessing the relevant three criteria: long term effectiveness and
permanence; reduction in toxicity, mobility, and volume through treatment;
and short term effectiveness, in combination. The relationship of the
overall effectiveness of this remedial alternative was determined to be
proportional to its costs. .
Of the eight alternatives evaluated and considered protective (SC-2 through
SC-15), SC-2, SC-3, SC-14, and the selected remedy (SC-4), have the most
cost-effective components. Whereas SC-2 meets ARARs and is considered
reasonably protective against exposures such as direct contact and .
ingestion of soil, it is the least protective of the eight because none of
the contaminants are eliminated, reduced or stabilized; therefore the costs
are least effective for the level of protection. Although SC-3 is
reasonably protective iri that VOCs, which are the primary threat at the
Site, are eliminated and the remaining constituents are capped, it is only
marginally less expensive than the selected remedy and is not as protective
because it does not include stabilization for the remaining compounds; .
therefore, it is not considered as cost effective as SC-4. SC-14 provides
-------
RECORD OF DECISION SUMMARY
silresim Site
Page 95
eliminate additional extractable and heavier organics, however, they both
include stabilization and a cap and are therefore equally protective of
direct contact, ingestion and leaching related exposures.
Logistical/implementability concerns related to the addition of an added
treatmentsysteni, and concerns related to the effectiveness of solvent
extraction to treat PCBs and dioxins make SC-14 less reliable and therefore
less cost-effective proportionate to the selected remedy.
The short-term inhalation risks associated with alternatives that include
large-scale excavations (SC-6 and SC-lO) prior to VOC treatment, and the
very high costs of thermal treatments in proportion to the added long-term
protection~o human health and the environment are not considered
proportionately cost-effective. Although. the alternatives that include
thermal desorption or incineration (including SC-ll) reduce or eliminate
extractable and heavier organics, the selected remedy provides adequate
protection against all potential exposures to those contaminants by
stabilizing and capping the residual waste at a much reduced cost (a
detailed cost estimate for the selected source control remedy (SC-4) is
provided in Table 8 of Appendix B). .
All three of the alternatives that include groundwater extraction and
treatment attain ARARs and are protective. Steam stripping (MM-3) is
slightly more expensive than the selected remedial alternative (MM-2) and
MM-4. Although the selected remedy is comparable in cost to MM-4, which
includes a UV/chemical oxidation treatment system, air stripping with a
heated influent (MM-2) is more widely available and tested for sites with a.
similar waste stream, and therefore considered more reliable and
proportionately cost-effective.
All three alternatives include the estimated costs of an extraction system
and a pretreatment process to separate non-aqueous phase liquids and remove
metals. The final details of the extraction system will. be known upon
completion of the pump test during predesign activities. Although
extraction costs may therefore change, the cost of extraction would
same for each groundwater alternative (a detailed cost estimate for
selected management of migration remedy (MM-4) is provided in Table
Appendix B).
be the
the
9 of
The least expensive alternative, MM-l, the no-action alternative, does not
meet ARARs since it would not reduce the concentration of contaminants
found in the groundwater to drinking water standards and is not considered
protective of human health and the environment.
D.
The Selected Remedy utilizes Permanent Solutions and Alternative
Treatment or Resource Recovery Technologies to the Maximum Extent
Practicable'
Once the Agency identified those alternatives that attain or, as
appropriate, waive ARARs and that are protective of human health and the.
-------
RECORD OF DECISION SUMMARY
Si1resim Site
Page 96
and alternative treatment technologies or resource recovery technologies to
the maximum extent practicable. This determination was made by deciding
which one of the identified alternatives provides the best balance of
trade-offs among alternatives in terms of: 1) long-term effectiveness and
permanence; 2) reduction of toxicity, mobility or volume through treatment;
3) short-term effectiveness; 4)implementability; and 5) cost. The
balancing test emDhasized long-term effectiveness and permanence and the
reduction of toxicity, mobility and volume through treatment; and
considered the preference for treatment as a principal element, the bias
against off-site land disposal of untreated waste, and community and state
acceptance~ The selected remedy provides the best balance of trade-offs
among the alternatives. . .
Each of the source control alternatives meets its corresponding ARARs.
Because alternatives SC-4 through SC-15 each include stabilization, a RCRA
subtitle C cap, a site fence, and institutional controls to manage residual
contaminants, they all offer good protection against the principle exposure
risks including direct contact and ingestion of soil, inhalation of VOC
emissions, and risks associated with the migration of residual contaminants
into groundwater. .
Whereas SC-15 offers the most permanent protection on-site because treated
soils would be disposed of off-site, it is unreliable as. a result of the
uncertainty of securing a facility to accept dioxin and PCB contaminated
waste, and poses potential serious short-term risks related to the
transport of wastes off Site. SC-6, SC-10 and SC-ll offer the next most
permanent protection in the shortest time period due to the removal of
extractable and heavier organics; however, the short-term risks associated
with large scale. excavations (SC-6 & SC-IO) are considerably higher than
those alternatives that strip the VOCs off prior to major excavation; are
considerably more costly than the others compared to the added level of
permanent protection offered; and pose serious implementation issues
(spatial requirements are greater than the others). SC-14 offers more
permanent protection than the selected remedy because it too treats the
extractable and heavier organics to cleanup levels; however, the inclusion
of an additional treatment process adds an extra measure of difficulty
associated with implementation than compared to the selected alternative.
Although alternatives SC-6 through SC-15 may offer more permanent
protection, they are not any more protective than the selected remedy which
prevents exposures to the remaining contaminants.
The selected remedial alternative and SC-3 employ the most readily
available services and materials, including in. situ vacuum/vapor
extraction, stabilization (SC-4 only) and a cap. Vacuum/vapor extraction
is reliable for removal of VOCs which are the principle threat at the Site,
and stabilization combined with a cap is the most reliable means of
migration control for residual materials (particularly metals). Both
stabilization and capping effectively reduce exposure risks to the
contaminants remaining on-site. SC-1 and SC-2 offer little permanent
-------
RECORD OP DECISION SUMMARY
Silresim Si~e
Page '7
least protective in the long-term because it does not employ a RCRA cap as
SC-2 does. Although alternatives SC-6 through SC-1S offer greater
reductions in toxicity, mobility and volume of extractables and heavier
organics, the selected alternative provides an effective barrier
(containment) against exposures to those constituents and is therefore more
proportionately cost-effective.
MM-1 would not meet ARARs and would not reduce the toxicity, mobility and
volume of contaminants at the Site and is therefore not protective of human
health and the environment. The selected management of migration
alternative (MM-2) was chosen because of the long-term effectiveness and
permanence and ability to reduce toxicity, mobility and volume of
contaminants through capture and treatment. Additionally, it was chosen
because the components are all well proven, reliable, readily available and
easily implementable. Although MM-2, MM-3 and MM-4 would be equally
effective in meeting ARARs for approximately the same cost (MM-3 slightly
more), and each includes institutional controls to be protective of human
health in the short term, MM-3 and MM-4 are generally less proven and
available technologies. Unlike MM-2, the use of steam stripping (MM-3),
would require a licensed boiler operator to be on hand at all times
(operation and maintenance costs could be potentially higher .in the long-
term). -
The Selec~ed Remedy Sa~isfies ~he Preference for Trea~en~ Which
Permanen~ly and Siqnifican~ly Reduces ~he Toxici~y, Mobili~y or
Volume of ~he Hazardous Subs~ance& a& a principal Elemen~
The principal element of the selected source control portion of the remedy
is in situ treatment of VOCs in soils via vacuum/vapor extraction and
subsequent stabilization and capping of residual contaminants. The
principle element of the selected management of migration portion of the
remedy is groundwater extraction and treatment utilizing air stripping.
These elements address the primary threat at the Site, contamination of
soil and groundwater. The selected remedy satisfies the statutory
preference for treatment as a principal element by: permanently reducing
the volume of VOCs and some semi-VOCsi reducing the mobility of the
remaining organics and metals in the soili and aggressively extracting and
treating contaminated groundwater which poses a potential threat through
its migration an~ discharge to nearby basements, River Meadow Brook, East
Pond, and to a future potential drinking water supply.
E.
XII. DOCOMENTATION OP SIGNIPICANT CHARGES
EPA presented a Proposed Plan (preferred alter~ative) for
remediation of the Site on June 6, 1991. The source control portion of the
preferred alternative included in situ vacuum/vapor extraction,
stabilization and a RCRA Subtitle C cap. The management of migration
portion of the preferred alternative included groundwater extractionl
gravity separation of non-aqueous phase liquids, chemical
-------
RECORD OF DECISION SUMMARY
silresim site
Page 98
aqueous phase carbon adsorption and thermal oxidation. No significant
changes from the Proposed Plan have been made to the selected remedies as
detailed in the Record of Decision. Minor changes include the correction
of accounting errors in the estimated cost of the selected remedy. These
corrections reduced the total cost of the selected remedy by $130,000.
It should be noted that some discrepancies in analysis exist among
documents in the Administrative Record, but that this Record of Decision
represents EPA's final position with regard to these discrepancies. This
position was reached after carefully reviewing and considering all
information. presented to EPA. Any discrepancies noted would not affect
EPA's decision on the remedy.
XIII. STATE ROLE
The Commonwealth of Massachusetts, Department of Environmental Protection
has reviewed the various alternatives and has indicated its .support.for the
selected remedy. The state has also reviewed the Remedial Investigation,
Risk Assessment and Feasibility study to determine if the selected remedy
is in compliance with applicable or relevant and appropriate state
environmental laws and regulations. Massachusetts concurs with the
selected remedy for the Silresim site. A copy of the declaration of
-------
FIGURE 1
FIGURE 2
FIGURE 3
FIGURE 4
FIGURE 5
FIGURE 6
FIGURE 7
FIGURE 8
FIGURE 9
FIGURE 10
APPENDIX A
FIGURES
LOCUS PLAN
SILRESIK SITB HAP
CROSS SECTION OF OVERBURDEN
WELL LOCATION HAP
DISTRIBUTION OF TOTAL VOC'S IN GROUNDWATER
CONCEPTUAL BLOCK FLOW DIAGRAM FOR SC-4
CONCEPTUAL SITE PLAN FOR VACUUH/VAPOR EXTRACTION
CONCEPTUAL CROSS SECTION FOR VACUUM/VAPOR
EXTRACTION TRENCH
CONCEPTUAL SITE PLAN FOR SC-4
-------
O'
1000
2000'
I
4000'
FROM USGS LOWELL,MASS. - N.H.
QUA DRANGLE MAP (1970)
SILRESIM
SITE
LOCUS PLAN
FIGURE 1 L\-r'\J
POOR QUA' I
-------
SILRESIM SITE
LQwell, Massachusetts.
N
-
Not to Scale
.
11111111111111 Railroad
-- Fence
1- Maple Street c;ondo Development
2- Gr.ater Lowel~ Supply
3- Alco Metals
8- B&L Used Auto Parts
9. Union Street Metal
10. Jelline of Lowell
". Scann.1 Boiler Works
12. Lowell Iron & Steel
"
-------
20
120
(6~'[ASTI -.51
120
100 100
i"i
80 80
)
60 60
40
40
zo
o
o
-20
-zo
)I ( CPT HOL (S WtAE n:MPORJU'"
UGEria
~ C~Y CAP
C3 Fill
D ~CU$mINE SI\ T I'mImI
AHO SAHO ..--
SllRESIM SITE
lOWfLl. MASSAC~
I."'.f::~':: I
~CUS",INE SILT AND 8AH0
Wlnt II\.'IY . Cl.AY LAYERS
A8U\ TION Till
I!!!I
1E0000K
Cor.~TS (00\5H10 WHERIINFE"MO I
HOR. 100
.
VERT. 20
o
o
FEU.
100
",;-::;&>;1
zo
FIGURE
3
lOOGEWIENT nu
-------
~G
N
-----
."':'04
~ ..
-.-.\ ,,""\.-~
. -~~~
- , " ,
, ,
...-.. \, 4'4".
~ \ ."
'.
'4"..
,.
.
,
,
\
---
"""','
---
+.4'.
"
""
- -.-
LEGEND
+
,5' PIEZOMETER INSTALLED BY GZA
+
05 'PIEZOMETER INSTALLED BY GZA
-+
~INGLE 'If:VEL GROUIONATER MONITORING WELL
INSTAlI.EO BY COM
f)
CONE PENETROMETER BORING BY COM
o
MVLTI . LEVEL GROUNDWATER. MONITORING WEll
:NSTALLED BY G14
,.'
.
SINGLE - LEVEL GROUNDWATER MOHITORIHG WELL
INSTALLED BY GZA
-+
MULTI-10M\. GROUNOWATER MONITORING WELL
INSTALLIO 8'f P£RIIINS JORDAN, INC. (19811
...
SINGLE'LEII!:L GROUNDwAT[n M()NTORINO WEll
INSTAlL£D BY PERII/NS JOAOAN,INC.1198)
.
~INOLE 'LE.VEL GROUNOWAT[R IoIONITORING WELL
INSTALLED BY OTHERS.
$EWER MANHOlES IAPPROIC'IoIATE LOCATION IlASED
ON IIIFORIoIATION 08TAINEO FROlol CITY f7 lDWELLI
-'&- ~ESTROYEO WELL
.
SOlIHST SAMPliNG LOCATION
I
o'
zod
I
400'
100'
SllRESIM SITE
LOWELL, IoIASSACHUSETTS
SITE PLAN
i991
-------
N
~
--
--
-'-
~
~I
"
!IOT::S:
FIGURE IS A MODIFICATION OF FIG 6.19(GZA 19891.
. FOR AOOITIONAl INFORMATION ,SEE FIGURE "-I.
SYlAOOlS MAY NOT BE THE SAME AS SHCM'N IN FI~ H.
; . ANALYSIS OF SAr.FLES ccu.ECT£O BY GZA (1980,I986,I988),NUS(I'
AND COM (19911.
~ CONTOURS OF EQUAL 'CONCENTRATION ARE IDEALIZED
INTEff'RETATIONS '" DATA FfI)I,I WIDELY SAIICED EXPLORATIONS
AND ARE SL8JECT TO CHANGE WITH TIME.
LEGEN~:
@
01HOI
INOI
'6801
0'40,0001
~11O'501
NO
HA
-100-
.
TOTAL VQ.ATllE ORGANIC WoI~S(I.OC'S) IN ~NOI*\'
(Pi'll) CO" DATA 1991.
TOTAL '.O..ATllE (fIGANIC COMrouNOS (VOC~) IN ~[)I
(PP~
(VAWn liSTED IN ORDfR OF INCREASING DEPTH IN
MULTILEVEl WELLS)
AI'PAOXlMAT£ TOTAL \OC lEVEL BASED ON GC SCREENING
RESJL TS.
APmOXIMATE RANGE r:F TO~ll.OC lEVEL(ppb) BASED
CW GC SCREENING RESJl T5
INDCATES NOT DETECTED
INDICATES NOT ANALYZED
c:.cwTOUAS '" Eaw. CO'ICEHTRATION '" TaTAL VOLATLI
OIIGANIC CONPQ..tolDS (ppb) HIGHEST VOC (XNCENTRATION
AT fACH LOCATION USED FOR CON1tJlJt ~S.
RAI/GE r:F VOC lEVELS BASED ON MUmu: SA~ES
I
0'
,
I
40d
100'
200
SILRESIM SITE
LOWELl, IMSSACHUSETTS
SITE PLAN
SHOWING
DISTRIBUTION OF TOTAL VOC'S
IN GROUNDWATER
FIGURE 5
-------
CI)
5 p
~ i
~ CI)
en @
~
tr1 ()
~~o
t:H:-4 Z
t-40n
~:E~
~:ac
J,.~~F:
:!1 ~ ~ t;7j
(;} z>5
~ ~::~
tr1
ON - SITE
STABILIZATION I SOLIDIFICATION
OF SOIL
----------------------,
------------- ,
. REAGE~ .
: ADDmON :
. .
I .
. r I
I I
~ I I
-IN - SITU I I
V ACUUM I "EXCAVATE I ,
I -t.DISPOS
VAPOR SOIL STOCKPILE . FEED MIXING r-. CURING . ON S
EXfRACTION CONTAMINATED .... SOIL ~ PREPARATION ..
-. I
OF VOC wrrn ON SITE . .
CO~AMINATED NON - VOCs (STAGING) I I '
I I
SOIL . , j
I ---------______1
'- - - .. - - -------------
DEBRIS
AL
ITE
< <
<
-------
!()"'&:£" " / I', i
/-,.....,...: ,',',,'. , ~ .
/::-.... ",.",',....':,'/? '.,',,' \
(:'::'/?:',~:,:,>-,~, ',....:, /, "/:.:":}~~) ,
" d$:':';::::::::~(" r- " ,(.\, ,""''-'/
" .:"':"'LY'r ,',. ':(;'......-',~~.j' \
,~.,_._.~. ~. ...
. ,(~\£gI2&]#'I%MI%B*fk1!2iJ)i~
/ "" / \",%"-"",, "'UV,
'~ ' ~~'~: 'i:.:~ :':'::'::::::::::::::':;?7>:/;/:z.;~::?::::'" '
'~ /- I a~.,:,;~(.:::.:,:.:,,:::.:.:,,:::,..:,
. , .~ -- " t~~~\f%Lt'
'. (J ~ ~::'~,lF,t:'
: ' ~~ '
It'
~
II)
. C::::J
D
C4N4D4
-c
o
00
iO :;t 1
Q()
Z c:
~~
-i
.<
N
-
LEGEND
-,---
---'1--
-x-
---------
.- - - - - - -,
1- - - - - ... _I
,': "-:::: I
I.' ".,," I
ITImTJITl
EXIS T ING FENCE I TO REMAIN I
EXISTING FEN'E I TO 8E REMovED I
CONSTRU'T NEW fENCE
INSTAcL VACUUM/VGPO~ ExTRGCTlO'j SYSTEM PIPING
E1CC*,ATE SOILS WH[RE N()N-VOC CONf.u,,,.,,T< h'~~~ CL[ANl1' GOAlS SfA8Lil£/
~O"Y'>4) CO"SOI.lOAI[ O",SII[ enow pnorosEo RCRA CAP BACMOI.l OH,SIT( ARE
wITH CLEAN 'I\.L
COflSTR'JCT LOW PERMEABI'_TY COVER I REfER TO FIG 8-lc)
'ONSTRU'T NEtt R'RA CAP(REFEII !O FIG 8"0)
UPGRAOE OuSTiNG CAP TO RGRA STAN(lAHU~ IHEFER TO fIG 8 -10)
SILRESIM
SITE
SITE PLAN -ALTERNATIVE SC-4
VACUUM/VAPOR EXTRACTION
1991
7
LOWELL.
MASS,
-------
,',- ...." '." ,.....,;".....0' ,,,"".. /
,~:O~, "~-"O:'-:''''''>-!''''P',~,~,"y, I'~ '.
.,-0-:.0:- J.o"".o:oo.~:~c'o'~...9o.:o,
'~:( '. :C' . 0... "'<:> D:0.o.o.
'...' ~;...:.- '.0:, 'Q:C)P~ :i:):.:o:ch,
FILL 8ELDW ..... '- "'(P~:O"<;:) O.;'-.Q:~~~
lOW F'ERMt:ABILITY ~():,~':", ~();~':.:o. ~;?~%~.,o ~
COvER,THICKNESS VARIES \ ~.~. .:!O':<:)Q.:...:., ,.,-'" .'9~( -------PERF P'IC '5:H eOINLETQR
, : * ~ Ex,RACTlOrJ PIPE (QIA "ARIE'51
T~P_OF PIPE BELOW DEPTH ~ J
OF SUBSEOUENT C~TAMtNATED +. "
SOH... EXCAVATION
I
LOW ~(RMEl.Blllr, :O"!:R
OR RCRA CAP
\~:I::,
~E
LBACI
-------
N
-
j
LEGENC
-.-
Ex,S TlNG fENCE I ro REMAIN I
-1'-
Ex'STlNG FEN'E I ro BE REMOvEOI
-.-
CONSTRU,r rlEW FErlCE
r--- - --I
'- - ....- ~.'
oC:'v.sr( SOIlS ",HcR( liON. vCX: CONU",u",.",,'C r-."I"r,.
!".CA.""" All) (ON501.o0A'( 0"'511( 11«0'" pnoroS[o.';;nClEANlP GOAlS SfAlrllZE/
\'"111f Cl('J"r~, 1\ CAP 6AClCr'-L O"'SJt{.I,
.'
I I
I:.~~'" '.. :., :1
1.
-------
I
s CJ)
~.~
. ~
~.~
~
~.,,8
t:'~Z
~~~
~>t:'~
5"'~~~
~ ~~~.
rn >E:g
~ ~ ~
o tI1
VENT TO
ATMOSPHERE""
.
.
OFF. m'E .
RECLAMA110N AIR
OR
INClNERA110N ~ POLLUTION --
CON1ROL
u VOLATILES
VOLATILES VOLATn..ES
.
A.OATING '
SOLVENT
PHASE
.
.. UQUID - .
- OR f\ vrrY W A-n:R PRETRBA'IMENT FOR WATER AIR PHASE EFFL
L...-- GRANUlAR
-.. SEPARATION .. METALS REMOV AI. ! .. STRIPPING ..
AcnvA'IED
SINKING CARBON
SOLIDS SOLVEm'
PHASE
i, .
oN-SITEI OFF. SITE METAL SLUDGE OR HEAmG REGENERA 110N DISCHA
OFF. SITB RECLAMATION MEOlA TO FURrnER OP OR TO PO
INCINERATION OR 1REATMENT AND lOR INFLUENT OFF. SITE OR S
INCINERA 'nON DISPOSAL OFF SITE DISPOSAL WA
..
UENT
RGE
lW
URF ACE
TER
PUMPED
GROtJND.
WATER
-------
TABLE 1
TABLE 2
TABLE 3
TABLE 4
TABLE 5
TABLE 6
TABLE 7
TABLE 8
TABLE 9
APPENDIX B
TABLES
CONTAMINANTS OF CONCERN
INTERIM GROUNDWATER CLEANUP "LEVELS
UNSATURATED SOIL CLEANUP LEVELS
SURFICIAL SOIL CLEANUP LEVELS
SUMMARY OF HAZARD INDICES AND CANCER
RISK ESTIMATES
SUMMARY OF THE INITIAL SCREENING OF
SOURCE CONTROL ALTERNATIVES
SUMMARY OF THE INITIAL SCREENING OF
MANAGEMENT OP MIGRATION ALTERNATIVES
DETAILED COST ESTIMATE OF SC-4
DETAILED COST ESTIMATE OF MM-2
-------
TABLE 1
SILRESIM SITE
CONTAMINANTS OF CONCERN
contaminants Groundwater/ Vent Indoor
of Concern Surface Water Soils Emissions Air
Acetone X
Arsenic X X
Benzene X X .X X
Bis(2-ethylhexyl)phthalate X X
2-Butanone X
Carbon Tetrachloride X X. X
Chlorobenzene X X
Chloroform 'X X X X
Chromium X X
Copper X
l,l-Dichloroethane X X
1,2-Dichloroethane X X X
l,l-Dichloroethene X X X X
1,2-Dichloroethene X
Dioxins X
Ethylbenzene X
Lead X
Methylene Chloride X X X X
Mercury X
.Nickel X
PARs X
PCBs X
Phenol X
Selenium X
» Styrene X
Tetrachloroethene X X
1, 1, 2,2-Tetrachloroethane X X
Toluene X X X
1,2,4-Trichlorobenzene X X
1, 1, l-Trichloroethane X X X X
Trichloroethene X X X X
Trichlorofloromethane X
-------
TABLE 2
SILRESIM SITE
INTERIM GROUND WATER CLEANUP LEVELS
carcinogenic
contaminants of
Concern
. Arsenic
Benzene
Bis(2-ethylhexyl)phthalate
Carbon Tetrachloride
Chloroform
l,l-Dichloroethene
l,2-Dichloroethane
1,2-Dichloropropanei
. Dioxinh
Hexachlorobenzenei
Methylene Chloride
PAHs (B(a)p)h
PCBsh
styreneh
1,1,2,2-Tetrachloroethane
1,1,2-Trichloroethanei
Trichloroethene
Non-carcinogenic
contaminants
of Concern
2-Butanone
Cadmiumi
Chlorobenzene
Chromium (trivalent)
Cop peri. .
1,2-Dichlorobenzenei
Trans-1,2-Dichloroethenei
Ethylbenzene i
Lead
Nickel
Phenol
Selenium
Toluene
1,2,4-~richlorobenzene
1,1~1-Trichloroethane
Xylenesi
Cleanup
Level (DDb)
350
5
100
100
1,300
600
100
100
15
100
21,000
50
1,000
9
200
10,000
Cleanup
Level CDpb)
50
5
4
5
100
7
5
5
5E-08
l'
5
.2
.5
100
. 5
5
5
Basis
GWS9
MCLG
MCLG
MCLG
pMCLGe
MCLG
MCLG
MCLG
policy
pMCLGe
RfDj
MCLG
MCLG
pMCLG
MCLG
MCLG
Basis
MCL
MCL
pMCL8 .
MCL
MCL
MCL
MCL
MCL
pMCLc
pMCL
pMCL
pMCL
MCL'
. MCLGd
PQLf
pMCL
MCL
SUK
Level of
Risk
2E-04b
4E-06
2E-06
2E-05
2E-05
1E-04
IE-05
1E~05 .
2E-04
5E-05
1E-06
7E-05
1E-04.
9E-05
3E-05
8E-06
2E-06
9E-04
Tarqet
Endpoint Hazard
of Toxicitv ouotient
fetotoxicity 0.2
kidney O. 3
liver/kidney 0.2
liver 0.003
stomach 1 . 0
liver 0.2
liver 0.2
liver/kidney 0.2
CNS k
liver/kidney 0.2
fetal bdy wt 1.0
hair/nails 0.5
1 vr/kdny 0.2
1 i ver 0 . 2
liver 0.06
bdy wt/hyper 0.2
HAZARD INDEX
SUM
liver
Kidney
Body Weiqht
1.2
0.9
-------
TABLE 2
a- Maximum Contaminant Level
b - The cleanup level for arsenic in groundwater has been set at the MCL of
50 ppb. The carcinogenic risk posed by arsenic at 50 ppb in groundwater
.will approximate 2 in 1,000. However, in light of recent studies
indicating that many skin tumors arising from oral exposure to arsenic are
non-lethal and in light of the possibility that the dose-response curve for
the skin cancers may be sublinear (in which case the cancer potency factor
used to generate risk estimates will be overstated), it is Agency policy to
manage these risks downward by as much as a factor of ten. As a result,
the carcinogenic risks for arsenic at this site have been managed as if
they were 2 in 10,000. (See EPA memorandum, "Recommended Agency Policy on
the carcinogenic Risk Associated with the Ingestion of Inorganic Arsenic"
dated June 21, 1988.) .
c - Proposed Maximum Contaminant Level
d - Maximum Contaminant Level Goal
e - Proposed Maximum Contaminant Level Goal
f - Practical Quantitation Limit
g - Massachusetts Groundwater Standard, 314 CMR 6.07
h - Additional groundwater indicator substance, which has the potential to
leach into groundwater.
i.- Additional groundwater indicator substance based on. Site groundwater
exceeding either an MCL, pMCL, MCLG or a pMCLG.
j - Reference Dose - Concentration corresponding to a reference dose.
k - A hazard quotient is not available for lead as EPA has not issued a
reference dose fo~ this compound. The cleanup level for lead comes from a
June 1990 memorandum from Henry Longest and Bruce Diamond to Patrick Tobin.
-------
TABLE 3
SILRESIM SITE
UNSATURATED SOIL CLEANUP LEVELS
carcinogenic
contaminants of
Concern
soil
Cleanup
Level (ppb)
Basis for
Model Input
Level of
Residual GW
Risk
Volatile Orqanic Compounds
Benzene 4 MCL 4E-06
Carbon Tetrachloride 5 MCL 2E-05
Chloroform 40 MCL 2E-05
l,l-Dichloroethene 5 MCL 1E-04
1,2-Dichloroethane 1 MCL 1E-u5
Methylene Chloride 1 pMCL 1E-06
styrene 170 MCLG 9E-05
1,1,2,2-Tetrachloroethane 6 PQL 3E-05
1,1,2-Trichloroethane 3 pMCL 8E-06
Trichloroethene 6 MCL 2E-06
others
Bis(2-ethylhexyl)phthalate
1,2-Dichloropropane
Dioxin
Hexachlorobenzene
PARs (carcinogenic)
PCBs
pMCL
MCL
pMCL
pMCL
pMCL
MCL
300
3
1
34
10,000
2,300
Non-carcinogenic
contaminants
of Concern
Basis for
Cleanup Model
Level (ppb) Input
Volatile Orqanic Compounds
chlorobenzene
Trans-1,2-Dichlorothene
1,1,1-Trichloroethane
300
67
300
MCLG
MCLG
PQL
others
1,2-Dich1orobenzene
1,2,4-Trichlorobenzene
Ethylbenzene
Phenol
Toluene
2-Butanone
Xylenes
8,900
720
6,800
5,300
2,700
60
22,000
MCLG
pMCLG
MCLG
RfD
MCLG
GWS
MCLG
2E-06
1E-05
2E-04
5E-05
7E-05
1E-04
SUM
7E-04
Target Residual GW
Endpoint of Hazard
Toxicitv ouotient
lvr/kdny
liver
liver
liver
liver
1 vr/kdny
body wt
lvr/kdny
fetotox
bdy-wt/hyper
SUM HAZARD INDEX
NOTE
Liver:
Kidney:
Body Weight:
0.2
0.2
0.06
0.2
0.2
0.2
1.0
0.2
0.2
0.2
1.2
0.6
1.2
'a - specific soil quantitation limits are highly matrix dependent.
such, cleanup levels listed above are sUbject to the limits of
quantitation.
Rfd - Reference Dose
As
-------
TABLE 4
SILRESIM SITE
. SURFICIAL SOIL CLEANUP LEVELS
Carcinogenic
Contaminants of
Concern
soil
Cleanup
Level (DDb)
Volatile Orqanic
B"'!,,7.,.~e
1,1-Dichloroethene
1,2-Dichloroethane
Methylene Chloride
Styrene
1,1,2,2-Tetrachloroethane
Trichloroethene
Compounds
15,000
. 720
4,800
58,000
14,000
2,200
40,000
Others
Arsenic
Dioxin
PAHs (carcinogenic)
PAHs (total)
PCBs
21,000
1
11,000
29,000
1,000
Non-carcinogenic
Contaminant
of Concern
Lead
Cleanup
Level (DDb)
500,000
Basis
Level of
Risk
risk
risk
risk
risk
risk
risk
. risk
1E-06
1E-06
lE-06
1E-06
1E-06
lE-06
lE-06
background
policy
background
background
policy
7E-078
4E-05
6E-05
6E-05b
2E-06
SUM
1E-04b
Basis for
Hodel
rnDut
policy
Target.
Endpoint
of Toxicitv
CNS
Hazard
Ouotient
c
a - Recent studies indicate that many skin tumors arising from oral.
exposure to arsenic are non-lethal and that the dose-response curve for the
skin cancers may be sublinear (in which case the cancer potency factor used
to generate risk estimates will be overstated). It is Agency policy to
manage these risks downward by as much as a factor of ten. As a result,
the carcino~enic risk for arsenic at this Site has been managed as if it
were 7 X 10.. (See EPA memorandum, "Recommended Agency Policy on the
Carcinogenic Risk Associated with the Ingestion of Inorganic Arsenic" dated
June 21, 1988.)
b - Total PAH risk is based on the cleanup level of 11,000 for c~rcinogenic
PAHs. Therefore the risk. of 6E-05 has only been incorporated once to the
sum total risk estimate.
c - The cleanup level for lead As based on OSWER Directive 9355.4-02,
"Interim Guidance on Establishing Soil Lead Cleanup Levels at Superfund
-------
TABLE 5
SILRESIM SITE
SUMMARY. OF HAZARD INDICES AND CANCER RISK ESTIMATES
WORST -CASE MORE-LIKELY CASE
EXPOSURE PATHWAYS .
CUMULATIVE CUMULA TIVE CUMULATIVE CUMULATIVE CUMULATIVE CUMULATIVE
I HAZARD INDEX HAZARD INDEX CANCER RISK HAZARD INDEX HAZARD INDEX CANCER RISK
(acute) (chronic) (aculo) (chronic)
PRESENT CONDITIONS
Oll-slle Surficial Soils \
Formor Arrow Carrier Property
IncldentallngelUon -- I.IE-OI B.IE-OB -- 5.8E-03 I.OE-06
Dermal Abeorpllon -- 1.5E~3 8.0E-OB -- 4021:-04 2.0E-06
1.1 E-O I 1.4E-05 B.2E-03 3.0E-06
B & M Railroad Area
Incldentallnge.Uon -- 9.0E~1 1.5E~4 -- 2.8E~2 G.2E-oe
Dermal Abeorpllon -- 1.5E~~ 2.9E-05 -- 3.0E~4 1.1 E-05
9.0E~1 1.8E~4 2.8E~2 1.7E~S
Southeastern Corner
IncldenlallngesUon -- B.9E+OO 8.0E-04 -- G.4E~2 1.4E-05
Dermal Abaorpllon -- 2.2E+OI 2.4E~3 -- l.eE~1 3.3E~5
2.9E+OI 3.2E~3 2.2E~1 4. 7E~S
Lowell Iron & Steel Properly .
Incidenialingeilion -- 1.5E+OO I.7E-04 -- 2.3E-02 2.6E-06
Dermal Abeorpllon -- 2.7E-OI 5.9E~4 -- 7.2E~2 1.4E-05
1.8E+OO 7.6.E~4 9.5E~2 1.7E-oS
Dermal Abeorpllon -- Employeee 1.9E~2 2.1E~2 8.GE-05 3.8E-03 5.8E~3 3.9E~7
Northeaslern Corner
Incldentallnge.llon -- 1 2E-o I 1.5E-oS -- 2.5E-02 3.5E-06
Dermal Absorption -- 3.3E~3 7.5E-01l -- 7.5E~4 4.9E-OII
1.2E-O I 2.3E-oS 2.6E-02 8.4E-06
Lowell Iron & Sleel Basement Seepage
Inhalation
Groundwaler Seepege 1.4E+02 1.8E+O I 1.0E-ol 1.2E-02 1.8EJ..o3 4.2E-06
Indoor Air 8.5E-02 1.4E-02 1.~E-05 4o2E-02 . 3.5E-G3 9.3E-G7
Dlrecl Contacl - -- 1.1E-G5 -- -- --
1.4E+02 1.8E+OI 1.0E-Gt 5.4E-G2 5. I E-G3 5.1 E-06
On-silo Vonl Emieslone
Inhalation -- 5.9E-03 4.4E-05 -- 5.2E-05 7.IIE-07
-------
Table 5
SILRESIM SITE
SUMMARV OF HAZARD iNDICES AND CANCER RISK ESTIMATES
WORST -CASE MORE-lIKEL V CASE
.
EXPOSURE PATHWAYS CUMULATIVE CUMULATIVE CUMULATIVE CUMULATIVE CUMULATIVE CUMULATIVE
HAZARD INDEX HAZARD INDEX CANCER RISK . HAZARD INDEX HAZARD INDEX CANCER RISK
(acute) (chronlo) (acula) (chronic)
FUTURE CONDITIONS
On-.lle Un88luraled Zone SoIl.
'ncldent."noe..lon 1.1E-01 5.3E-01 4.0E-05 2.0E-02 5.8E-03 3.4E-07
Dermal AbtOfpllon I.OE.OO 1.1E+OO 1.OE-04 11.1 E-03 UE-02 t .8E-08
1.7E.00 UE+OO 2.3E-04 2.5E-02 4.2e-02 2. tE-08
Groundwater .. DrlnklnQ W.ter Supply
'noe"'on - 5.1E+03 !U£+OO - t.5E+Ot 0.8E-03
.
;
N. Main Streel Ruldence BaHmenl Seep !A! ..
Inhalallon 1.8£+00 1.2E+OO 1.1E-02 8.2E-02 1.3E-02 1.5E-05
SeweQe Trealmenl Planl Emlllion.
Inhalallon - 1.5E-05 3.8E-01 - 5.1 E-08 1.2e-07
Surlace Wale"
River Meadow Brook
'n08.lIoo 1.7E-03 UE-04 5.1E-08 2.1 E-04 2.5E-08 5.IE-10
Dermal AbtOfplloo 1.7£+00 3.8E-02 UE-08 2.3E-02 2.8E-04 5.7E-08
1.7e.00 UE-02 8.8e-08 2.3E-02 2.8e-04 5.8E-08
Ea" Pond
InOlllloo 1.1 E+OO 3.OE-02 8.1£-08 1.1£+00 1.3£-02 2.7E-08
Dermal AbtOfptloo 2.4£+02 UE+OO 1.2£-03 1.2E+02 t .5e+oo 3.oE-04
2.4e+02 5.8E+OO t .2E-03 1.2E+02 t .5E.00 3.0E-04
Concord River
InOlllloo 2.8E-04 4.OE-05 t .OE-08 1.4E-05 1.2£-08 2.4E-10
Dermal AbtOfpllon 8.0E-02 1.1£-02 2.3E-08 1.5e-03 1.3E-04 UE-08
8.OE-02 1.1E-02 2.3£-08 1.5E-03 1.3e-04 Ue-08
-------
Page I of 5
TAULE 6
SILRESIM SITE-
SUMMARY OF THE INITIAL SCREENING OF SOURCE CONTROL REMEDIAL ALTERNATIVES
- - 1IIIilll!!ft!\IIIIBlllllit\111I! 1~1.11,,1~llllil:\\
SC- I Minimal/No Action I) Site Access Restriction X
2) Public Education
3) Monitoring/Reporting
4) Repair and Extend Cover
SC-2 On-Site and ore-Site Cover I) ExpansionJUpgrade of Cover X
System 2) Site Access Restriction
3) Public Education
4) Monitoring/Reporting
SC-3 V acuumN apor Extmction I ) In Situ Vapor Extraction X
with Dewatering
2) Soils Consolidation On-Site
3) ExpansionJUpgrade of Cover
4) Site Access Restriction
S) Public Education
6) Monitoring/Reporting
SC-4 VacuumNapor Extraction, I) In Situ Vapor Extraction X
Stabilization/Solidification, with Dewatering "
and Disposal On Site 2) Excavation
3) S tabil ization/Solidification
4) On-S ite Disposal
5) Site Access Restriction
6) Monitoring/Reporting
-------
se-5
se-6
se-7
VacuumNapor Extmction
IUld Orc-Sile Disposal
Thermal Desorption and
Disposal9n Site
Thermal Desorption and
Off-Site Disposal
Page 2 of 5
TAnLE 6 (CONT'D)
..]__rJIIII
I) In Silu Vapor Extraction
with Dewatering
2) Excavation
3) Stabilization/Solidification
(if necessary)
4) Off-Sile Disposal.
5) On-Site ReconsolidationlRCRA
Cover for Dioxin
Contaminated Soils.
6) Site Access Restriction.
7) Monitoring/Reporting*
I) Excavation
2) Thermal Desorption
3) Stabilization/Solidification
(if necessary)
4) On-Site Disposal
5) Site Access Restriction
6) Monitoring/Reporting
x
x
1) Excavation
2) Thermal Desorption
3) Stabilization/Solidification
(if necessary)
4) Off-Site RCRA Landfill.
5) On-Site ReconsolidationlRCRA
Cover for Dioxin
Contaminated Soils.
6) Site Access Restriction.
7) Monitoring/Reponing
-------
Page 3 of 5
TAnLE 6
(CONT'D)
----
SC-8
VacuumNapor Extraction,
Thennal Desorption, and
on-site Disposal
SC-9
VacuumNapor Extraction
and Thennal Desorption On-
Site. and
Off-Site Disposal
SC-lO Incineration and Disposal
On-Site
1) In Situ Vapor Extraction
with Dewatering
2) Excavation
3) Thennal Desorption
4) Stabilization/Solidification
(if necessary)
5) On-Site Disposal
6) Site Access Restriction
7) Monitoring/Reporting
1) In Situ Vapor Extraction
with Dewatering
2) Excavation
3) Thennal Desorption
4) Stabilization/Solidification
(if necessary) ,
5) Off-Site RCRA. Landfill.
6) On-Site ReconsolidationlRCRA
Cover for Dioxin
Contaminated Soils.
7) Site Access Restriction.
8) Monitoring/Reporting.
x
x
1) Excavation
2) On-Site Incineration
3) Stabilization/Solidification
(if necessary)
4) On-Site Disposal
5) Site Access Restriction
6) Monitoring/Reporting
-------
Page 4 of 5
TARLE 6
(CONT'D)
,.
"--°"1__-
SC-l1 Vacuum/Vapor Bxtraction,
Incineration, and Disposal
On Site .
SC-12 Off-She Incineration
SC-t3 Vacuum/Vapor .Extraction
and Off-Site Incineration
1) In Situ Vapor Extraction
with Dewatering
2) Excuvation
3) On-Site Incineration
4) Stabilization/Solidification
(if necessary)
5) On-Site Disposal
6) Site Access Restriction
7) Monitoring/Reporting
I) Excavation
3) Off-Site Incineration.
4) Stabilization/Solidification
(if necessary).
5) Off-She RCRA Landfill.
6) On-Site ReconsolidationlRCRA
Cover for Dioxin
Contaminated Soils.
7) Site Access Restriction.
8) Monitoring/RcporLing
x
x
I) In Situ Vapor Extraction
with Dewatering
2) Excavation
3) On-Site Incineration.
4) Stabilization/Solidification
(if necessary).
5) Off-Site RCRA Landfill.
6) On-Site ReconsolidationlRCRA
Cover for Dioxin
Contaminated Soils.
7) Monitoring/Rcporting.
-------
Page 5 of 5
TABLE 6
(CONT'D)
~---
SC-14 VacuumNapor Extraction, I} In Situ Vapor Extraction X
Solvent Extraction, and with Dewatering
Disposal On Site 2} Excavation
3} Solvent Extraction II
4} Stabilization/Solidification
(if necessary)
5) On-Site Disposal
6} Site Access Restriction
7) Monitoring/Reporlin.g
I) In Situ Vapor Extraction
with Dewatering
. 2) Excavation
3) Solvent Extraction II
4) Stabilization/Solidification
(if necessary)
5) Off Site RCRA Landfill
SC-15 VacuumNapor Extraction
and Solvent Extraction On
Site, and Off-Site Disposal
X
Notes:
1.
"." indicates that these steps woul(" be dependent upon whether or not off-site disposal facilities could be located for dioxin contaminated soils.
2.
-------
. -
Page I of 2
TABLE .7
SILRESIM SITE"
SUMMARY OF THE INITIAL SCREENING OF MANAGEMENT OF MIGRATION REMEDIAL ALTERNATIVES
.~.......__.R::8-
MM-2 Pump and Treat Metals
Pretreaunent, Air Stripping,
and Carbon Adsorption
1) Deed/Land Use Restrictions
2) Public Education
3) Mo!,!itoring/Reporting
1) Groundwater Extraction
2) Scparation of Non-Aqueous
Phases .
3) Mctals Pretreaunent
4) Air Stripping
5) Liquid-Phase Carbon Adsorption
6) Discharge to POTW or
Surface Water
x
MM-I Minimal/NO Action
x
MM.3 Pump and Treat by Metals
Pretreaunent, Steam Stripping,
and Carbon Adsorption
I) Groundwater Extraction
2) Separation on Non-Aqeous .
Phases
3) Mcwls Pretreaunent
4) Stcam Stripping
5) Liquid-Phase Carbon Adsorption
6) Discharge to POTW or
. Surface Water
-------
Note:
I.
"
Page 2 of 2
TARLE 7 (CONT'D)
..p~~#r~___-
MM-4 Pump and Treat by Metals
Pretreatment and UV and
Chemical Oxidation
I) Groundwater Extraction
2) Separation of Non-Aqueous
Phases
3) MelBls Pretreatment
4) UV/Chemical Oxidation
6) Discharge to POTW or
Surface Water
x
MM-5 Pump and Treat Off Site
I) Groundwater Extraction
2) Collection
3) Transportation
4) Off-She Treatment
x
-------
SILRESI M SITE
TABLE 8
CAPITAL AND O&M COST ESTIMATE
ALTERNATIVE SC-4: VACUUMIVAPOR EXTRACTION, STABILIZATION.
AND DISPOSAL ON SITE
Page 1
. . Est .... Unit ...... Capital Annual. PresefitWorth
. Cost Component. . Quant.itY . ..... . Cost < Cost (1) O&M 'O&M/Replacement
)... .<. 30 years, 10%
I. INSTITUTIONAL ACTIONS
1. Deed Restrictions $5,000 -
2. Public Education Programs $40,000 -
3. Off-Site Property Use 1 AC $50,000 $37,000 (3)
4. Acquisition of Property 4 AC $50,000 $200,000
5. Site Security - $87,600(2) $426,000
Subtotal: ' $276,000 $426,000
II. GENERAL & SITE PREPARATION
1. Site Fencing 875 LF $13 $11,000 $3,700 $35,000
2. General Site Preparation LS $105,000
2. Site Preparation for Venting LS $50,000
3. VOC Emissions Control $100,000
4. Extend & Repair Existing Cap LS $87,000 $21,400 (2) $93,000
5. Site Preparation for LS $84,000 (3)
Stabilization/Solidification
6. Strip & Stockpile 7000 CY $17 $119,000 (3)
Existing Cap -,
7. Construct RCRA Cap 180000 SF $10 $1,016,000 (7) S21 ,400 (5) $109,000
8. Restore Off-Site Areas LS $28,000 (7)
9. Reveg.lRepave Off-Site Areas 2 AC $25,000 $28,000 (7)
10. Additional Soil Analyses $50,000
-
, Subtotal: $1.678,000 $237,000
ilii. VACUUMIVAPOR EXTRACTION
I TREATMENT COSTS
1. Pilot Testing LS $139,000
2. Excavation/Stockpiling Soil 17500 CY $21 $368,000
from Trenches & Off-Site Areas
3. Pipe Installation 8640 FT $25 $?1~.Mn
4. Trench Backfill 14400 CY $10 $144,000
5. Temporary Cap 2200 SY $16 $35,000
6. Equipment Purchase LS $775,000
& Installation
7. Construct Treatment LS $50,000
Equipment Housing
8. Startup & Debug $50,000
9. Operation & Maintenance $50,000 $471,000
10. Sampling and Analyses $54,000 $509,000
11. Excess Soil Handling 15000 CY $6 $90,000
-------
:?agc 2
TAi3LE 8
IV. STABILIZATION/SOLIDIFICATION
TREATMENT COSTS
1. Treatability Study. $40,000
2. Excavate/Stockpile 18200 CY $21 $237.000 (3)
Soil
3. Treatment Cost 30000 TN $42 $782,000 (3)
4. Sampling and Analyses 18200 CY $4 $45,000 (3)
5. Monitoring during Treatment lS $60.000 (3)
6. Backfill Treated Soil 18200 CY $10 $113,000 (3)
".. -
Subtotal: $1.277 ,000 $0
V. RESIDUALS HANDLING
1. Off-Site Disposal of $20.000 $189.000
Aqueous Waste (If Required)
Subtotal: $0 $189,000
VI. LONG TERM MONITORING
& REVIEW
1. Monitoring & Inspections (6) $50,000 (4) $77,000
2. Five Year Reviews $50,000 (4) $77,000
.
, Subtotal: $0 $154.000
I
,CONSTRUCTION SUBTOTAL $5,098,000 - $1.986.000
I
I . 10% $510,000
i 1. Health and Safety
'- Bid Contingency 10% $510,000
e.
I 3. Scope Contingency 200~ ..' $1.020,000
I
;CONSTRUCTION TOTAL $7,138.000
t 1. Services During Construction ....... ... .
10% $714.000
TOTAL IMPLEMENTATION COST $7.852,000
1. Engineering and Design 10% $785,000
. TOT Ai. CAr:i7 Ai. C0~ 1"S $8,637,000
. TOTAL PRESENT WORTH OF ALTERNATIVE: $10.620,000
r
NOTES:
1. Capital costs are incurred in year 0 unless otherwise stated.
Capital costs for"alternatives where treatment technologies do not occur in year 0
represent present worth costs using a discount rate of 100/0.
2. Cost is incurred annually for years 1 through 6.
3. Capital cost incurred in year 5.
4. Cost is incurred in years 5, 10, 15, 20, 25 and 30.
5. Cost is incurred annually for years 7 through 30.
6. Soils only. Groundwater monitoring covered under MM alternatives.
7. Cost is incurred in year 6.
-------
Page 1
TABLE 9
SILRESIM SITE
ALTERNATIVE MM-:2: PUMP & TREAT ON-SITE BY
. METALS PRETREATMENT. AIR STRIPPING & CARBON ADSORPTION
Est. Unit Capital Annual Present Wonh
. Cost Component Quantity . Cost Cost (1) O&M O&M/Replacement
30 vears, 10%
.\lSTITUTIONAL ACTIONS
. De&d Restrictions $5,000 -
:. Public Education Programs $40,000 -
Subtotal: $45,000 $0
3ENERAL & SITE PREPARATION
. MobIDemob & Site Prep LS $50,000
.. Housing & Utilities LS $113,000
Subtotal: $163,000 SO
GROUNDWATER EXTRACTION SYSTEM
. . Installation of Welts LS $280,000 $20,000 $189.000
.. Well Vaults & Subsurface Piping LS $166,000
. Equipment Purchase & Installation LS $96,000 $20',000 $189,000
-
Subtotal: $542,000 $378.000
TREAiMENT SYSTEM
. Gravity Separator . t.S $40,000 $2,500 $24,000
.. FelMn Removal System LS $100,000 $20,000 $189,000
. Air Stripper with Influent Heater LS $450,000 $75,000 $707,000
. Fume Incinerator LS $200,000 $35,000 $330.000
. Aqueous A"ctivated Carbon LS $100,000 $300,000 $2,828,000
. Process Piping, Valves, LS $510,000 $20,000 $189,000
Instrumentation, etc.
". Operating Labor $180,000 $1,697,000
:. Startup LS $40,000
'. Laboratory Equipment LS $30,000 $5,000 $47,000
..'
-
Subtotal: $1,470,000 $6,011.000
DISCHARGE SYSTEM
. Sewer Connection 150 LF $160 $24,000 $20,000 $1 e!:ooo
Subtotal: $24,000 $189.000
RESIDUALS HANDLING
. Off-Site Disposal $30,000 $283.000
Subtotal: $0 $283.000
. LONG TERM MONITORING & REVIEW
. . Monitoring & Inspections (3) $36,000 $339.000
:!. Five Year Reviews $50,000 (2) $77.000
t Additional Analyses $36,000
-------
Page 2
TABLE 9
'CONSTRUCTION SUBTOTAL $2.280.000 $7.277.000
1. Health and Safety 1 00/0 $228.000
2. Bid Contingency 10% $228.000
3. Scope Contingency 20% $456.000
CONSTRUCTION TOTAL $3.192.000
1. Services During Construction 15% $479.000
TOTAL IMPLEMENTATION COS." $3,671,000 -
1. Engineering and Design 20% $734,000
TOT AL CAPITAL COSTS $4,405,000
TOTAL PRESENT WORTH OF ALTERNATIVE: $11,680,000
NOTES: 1. Capital costs are incurred In Year 0 unless otherwise stated.
2. Takes place every five years.
3. Groundwater only. Soil monitoring is covered in SC alternatives.
eo
~
-------
Page 1 of 2
TABLE 7
SILRESIM SITE.
SUMMARY OF THE INITIAL SCREENING OF MANAGEMENT OF MIGRATION REMEDIAL ALTERNATIVES
~=.:)II"--'.~
MM-l Minimal/No Action
1) Decd/Land Use Restrictions
2) Public Education
3) MonilOring/Reporting
1) Groundwater Extraction
2) Separation of Non-Aqueous
Phases
3) Metals Pretreatment
4) Air Stripping
5) Liquid-Phase Carbon Adsorption
6) Discharge (0 POlW or
Surface Water
x
MM-2 Pump and Treat Metals
Pretreatment, Air Stripping,
. and Carbon Adsorption
x
MM-3 Pump and Treat by Metals
Pretreatment, Steam Stripping,
and Carbon Adsorption
1) Groundwater Extraction
2) Separation on Non-Aqeous
Phases .
3) Metals Pretreatment
4) Steam Stripping
5) Liquid-Phase Carbon Adsorption
6) Discharge to POlW or
Surface Water
-------
Page 2 of 2
TABLE 7 (CONT'O)
~.-_--
MM-4 Pump and Treat by Metals
Pretreatment and UV and
Chemical Oxidation
I) Groundwater EXlraction
2) Separalion of Non-Aqueous
Phases
3) Met~ds Pretreatment
4) UV/Chemical Oxidation
6) Discharge toPOTW or
Surface Water
x
MM-5 Pump and Treat Off Site
I) Groundwater Extraction
2) Collection
3) Transportation
4) Off-Site Treatment
x
Note:
I.
-------
SILRESIM SITE
TABLE 8
CAPITAL AND O&M COST ESTIMATE
ALTERNATIVE SC-4: V ACUUMN APOR EXTRACTION, STABILIZATION.
AND DISPOSAL ON SITE
Page 1
. . . ".' ,, ' '.'.. :.ESt........ ;:~~~:,>. i Capital. Annual . Present.Worth
. ..' ,",' ',,'," ," .,',' ...
,.. > Cost 'CompOnent': .'.... ',.Quantity Cost (1) O&M," ,O&M/Replacement
..' . ..'. 30 years, 10%
I. INSTITUTIONAL ACTIONS
1. Deed Restrictions $5,000 -
2. Public Education Programs $40,000 -
3. Off-Site Property Use 1 AC $50,000 $37,000 (3)
, 4. Acquisition of Property 4 AC $50,000 $200,000
5. Site Security $87,600(2) $426.000
.
Subtotal: $276,000 $426,000
II. GENERAL & SITE PREPARATION
1. Site Fencing 875 LF $13 $11 ,000 $3,700 $35,000
2. General Site Preparation LS $105,000
2. Site Preparation forVenting LS $50,000
3. VOC Emissions Control $100,000
4. Extend & Repair Existing Cap LS $87,000 $21,400 (2) $93,000
5. Site Preparation for LS $84,000 (3)
Stabilization/Solidification
6. Strip & Stockpile 7000 CY $17 $119,000 (3)
Existing Cap ..
7. Construct RCRA Cap 180000 SF $10 $1,016.000 (7) $21,400 (5) $109,00.
8. Restore Off-Site Areas LS $28,000 (7)
9. Reveg.lRepave Off-Site Areas 2 AC $25,000 $28,000 (7)
10. Additional Soil Analyses $5C1,OOO
-.......-.
Subtotal: $1,678,000 $237,000
III. VACUUMNAPOR EXTRACTION
TREATMENT COSTS
1. Pilot Testing LS $139,000
2. Excavation/Stockpiling Soil 17500 CY $21 $368,000
from Trenches & Off-Site Areas
3. Pipe Installation 8640 FT $25 $?1~.nnn -
4. Trench Backfill 14400 CY $10 $144,000
5. Temporary Cap 2200 SY $16 $35,000
6. Equipment Purchase LS $775,000
& Installation
7. Construct Treatment LS $50,000
Equipment Housing
, 8. Startup & Debug $50,000
9. Operation & Maintenance $50,000 $471,000
10. Sampling and Analyses $54,000 $509,000
11. Excess Soil Handling 15000 CY $6 $90,000
-------
Page 2
TABLE 8
IV. ST ABILIZA TION/SOUDIFICA TION
TREATMENT COSTS
1. Treatability Study $40.000
2. Excavate/Stockpile 18200 CY $21 $237.000 (3)
Soil
3. Treatment Cost 30000 TN $42 $782,000 (3)
4. Sampling and Analyses 18200 CY $4 $45.000 (3)
5. Monitoring during Treatment LS $60.000 (3)
6. Backfill Treated Soil 18200 CY $10 $113.000 (3)
-"
-
Subtotal: $1.277.000 $0
V. RESIDUALS HANDLING
1. Off-Site Disposal of $20,000 $189,000
Aqueous Waste (If Required)
- Subtotal: $0 $189,000
VI. LONG TERM MONITORING
! & REVIEW
: 1. Monitoring & Inspections (6) $50,000 (4) $77 ,000
2. Five Year Reviews 550,000 (4) $77,000
.
Subtotal: $0 $154,000
CONSTRUCTION SUBTOTAL $5.098.000 $1.986,000
1. Health and Safety 10% $510.000
2. Bid Contingency 10% $510,000
..
3. Scope Contingency 20% .. - $1,020.000
'.
CONSTRUCTION TOTAL $7,138,000
h- --. -
-..-.
1. Services During Construction 10% $714,000
TOTAL IMPLEMENTATION COST $7,852.000
1. Engineering and Design 10% $785,000
TOTAL. CArj'i AL. Cu~ rs $8,637,000
TOTAL PRESENT WORTH OF ALTERNATIVE: $10,620,000
~
NOTES:
1. Capital costs are incurred in year 0 unless otherwise stated.
Capital costs for alternatives where treatment technologies do not occur in year 0
represent present worth costs using a discount rate of 10%.
2. Cost is incurred annually for years 1 through 6.
3. Capital cost incurred in year 5.
4. Cost is incurred in years 5,10,15,20,25 and 30.
5. Cost is incurred annually for years 7 through 30.
6. Soils only. Groundwater monitoring covered under MM alternatives.
-------
Page 1
TABLE 9
SILRESIM SITE
ALTERNATIVE MM-2: PUMP & TREAT ON-SITE BY
METALS PRETREATMENT. AIR STRIPPING & CARBON ADSORPTION
Est. Unit Capital Annual Present Worth
Cost Component Quantity. .Cost Cost (1) . O&M O&M/Replacement
30 Years. 10%
:. INSTITUTIONAL ACTIONS
1. Deed Restrictions $5.000 -
2~ Ptiblic Education Programs $40,000 -
Subtotal: $45,000 $0
a. GENERAL & SITE PREPARATION
1. MoblDemob & Site Prep LS $50,000
2. Housing & Utilities LS $113,000
Subtotal: $163.000 $0
:11. GROUNDWATER EXTRACTION SYSTEM
1. Installation of Wells. LS $280.000 $20.000 $189.000
2. Well Vaults & Subsurface Piping LS $166.000
3. Equipment Purchase & Installation LS $96,000 $20.000 $189.000
Subtotal: $542,000 $378.000'
IV. TREAiMENT SYSTEM
1. Gravity Separator . t.S $40,000 $~,500 $24,000
2. FeiMn Removal System LS $100.000 $20,000 $189.000
3. Air Stripper with Influent Heater LS $450,000 $75,000 $707,000
4. Fume Incinerator LS $200,000 $35,000 $330.000
5. Aqueous Activated Carbon . LS $100.000 $300,000 $2,828,000
6. Process Piping, Valves, LS $510,000 $20,000 $189.000
Instrumentation, etc.
7. Operating Labor $180,000 $1.697.000
8. Startup LS $40,000
9. Laboratory Equipment LS $30.000 $5,000 $47,000
. _0'
Subtotal: $1,470,000 $6.011,000
V. DISCHARGE SYSTEM
1. Sewer Connection 150 LF $160 $24,000 $20,000 $18'-000
Subtotal: $24.000 $189.000
VI. RESIDUALS HANDLING
1. Off-Site Disposal $30,000 $283.000
Subtotal: $0 $283,000
VII. lONG TERM MONITORING & REVIEW
1. Monitoring & Inspections (3) - $36.000 $339.000
2. Five Year Reviews $50.000 (2) $77.000
3. Additional Analyses $36.000
I Subtotal: $36,000 $416,000
-------
page 2
TABLE 9
CONSTRUCTION SUBTOTAL $2.280.000 $7,277,000
1. Health and Safety 100/0 $228,000
2. Bid Contingency 10% $228,000
3. Scope Contingency 20% $456.000
CONSTRUCTION TOTAL $3,192.000
1. Services During Construction 15% $479.000
TOTAL IMPLEMENTATION COS'.' $3,671,000 -
1. Engineering and Design 20% $734,000
TOT AL CAPITAL COSTS $4,405,000
TOTAL PRESENT WORTH OF ALTERNATIVE: $11,680.000
NOTES: 1. Capital costs are incuned In Year ° unless otherwise stated.
2. Takes place every five years.
3. Groundwater only. Soil monitoring is covered in SC alternatives.
.,
-------
APPENDIX C
-------
Chemical-Specific ARARs. Criteria. Advisories. and Guidance
.. . . .....
. .........
n' .. .........
u.. ...... ...
.......'"''''''''
. .... ...-, .........
...... ..."-' .... ..
... ... .....-...
.....'" ...,........... ....
::Mtfdi~::i'
'...
0"'--
.. ..
.,,"
Groundwater
Federal Safe Drinking Water Act.
(SDW A) National Primary Drinking
Water Regulations (NPDWR) - 40
CFR 141
Relevant and Appropriate
Federal-RCRA-MCLs - 40 CFR Part
264.94
Relevant and Appropriate
Massachusetts Groundwater Quality
Standards - 314 CMR 6.00
Applicable
725054-24
"
nO-"'"''''
...
.. ..."..;.~~~~::~~:~~~tt~~~~:::::;::::::
...
Maximum Contaminant Levels (MCLs)
are enforceable standards that are
applicable to drinking water supplies.
M CLs are relevant and appropriate for
groundwater that may be a potential
source of drinking water.
M CLs have been adopted as part of
RCRA groundwater protection
standards. These standards are equal to
MCLS established under NPDWR,
SDWA.
These standards consist of groundwater
classifications, which designate and
assign uses for which groundwater
shall be maintained and protected;
water quality criteria necessary to
sustain tlie designated uses; and
regulations to achieve the designated
uses or maintain the existing
groundwater quality.
.1
. ".:.~~u,?~jt~1:~~:~n:o.At~ri::.;:
Groundwater at and beyond the point
of compliance will attain MCLs at
the completi,)Q of the remedy (or
will be waived on the grounds of
technical impracticability). These
levels will be attained by the capture
and treatment of contaminated
groundwater in the plume.
Groundwater at and beyond the point
of compliance will attain MCLs at
the completion of the remedy (or
will be waived on the grounds of
technical impracticability). These
levels will be attained by the capture
and treatment of contaminated
groundwater in the plume.
Massachusetts groundwater quality
standards for Class I groundwater
will be met at the compliance point
(or be waived on the grounds of
technical impracticability). These
standards will be met by the capture
and treatment of contaminated
groundwater in the plume.
-------
.................,........ .
.. ......,...,....,......-"..,
::::::.:M~it.iri:::
....,
,. "
Groundwater
(cont'd)
725054-24
Chemical-Specific ARARs. Criteria. Advisories. and Guidance
(cont'd)
....
. ',",
'.','.',,'
............. ,
.......... .
..."",, .". """"'''''''''''''''''''' .','."."
.....i.:~~~::~r..~~~~i~~~~~t!
Massachusetts Drinkin, Water
Regulations - 310 CMR 22.00
Relevant and Appropriate
Massachusetts Drinking Water
Regulations include Massachusetts
Maximum Contsminant Levels
(MMCLa). If MMCLs are more
stringent they will supersede fecteml
MCLs.
Fedeml SDW A, NPDWR - 40 CPR
141
To. Be Considered
Proposed MCLs may become potential
ARARs, when promulgated, and are
considered in the absence of MCLa
EPA Reference poses (RID) for
Noncarcinogens
To Be Considered
Reference doses and standard exposure
assumptions for body weight and daily
drinking water ingestion mte are used
to derive cleanup goals protective of
noncarcinogenic effects.
Nonregulatory concentmtion limits for
contaminants in drinking water that are
considered protective of adverse non-
carcinogenic bealth effects over a
lifetime.
EPA Lifetime Health Advisories .
(HAs), Office of Drinking Water
To Be Considered
2"
,. ...
::...~~ti6~t~:u~~e:n:o.~~~~::..
MMCLs for compounds detected at
Silresim are fedeml MCLs adopted
by MA DEP and will be met at the
compliance points (or waived).
These levels will be met by the
capture and treatment of
contaminated groundwater in the
plume.
Proposed MCLs will be attained at
the point of compliance (or be
waived on the grounds of technical
impracticability) at the completion of
the remedy. These standards will be
met by the capture and treatment of
contaminated groundwater in the
plume.
EP A Reference Doses will be met at
and beyond the compliance point (or
be waived based on technical
impracticability).
Lifetime HAs will be met at and
beyond the compliance point (or be
waived based on technical
impmcticability).
-------
.. .... .
.. .. ..... ..
..... ....." ...
.... ............ ....
.................. ..
. .. ....... ... ... .......... .
..................... ..........
........"""""'''''''''' ...
:".:.::::::::$j!~.::.:.:.
..... ... .
Groundwater
(cont'd)
Chemical-Specific ARARs. Criteria. Advisories. and Guidance
(cont'd)
3
. ..
!i:j!li::!!j!i!:jijl:li:l_m_i:,t:!II~~!~~~!i!jiil;ji:ii:I!!:::::I. .::ii.i:~iJ,~;i:~~~ili~nM:::~tW~:;.::...
SDW A M811.imum Contaminant Level'
Goals (MCLGs) and proposed MCLGs
To Be Considered
Massachusetts Office of Research and
Standards Drinking Water Guidelines
(ORSGLs)
To Be Considered
Surface Water Massachusetts Surface Water Discharge Relevant and Appropriate
Permit Requirements - 314 CMR 3.00
725054-24
Massachusetts Operation and Mai nten-
ance and Pretreatment Standards: 'or
Wastewater Treatment Works and
Indirect Discharge - 314 CMR 12.00
Federal Clean Water Act (CW A) -
Federal Ambient Water Quality
Criteria (FA WQC)
Applicable
To Be Considered
M CLGs are set with a margin of safety
at levels that would result in no known
or anticipated adverse heslth effects
over a lifetime.
Guidance for chemicals other than
those with MMCLs in drinking water.
Standards regulate discharges of pollu-
tants to surface waters, outlets for such
discharges and any treatment works
associated with these discharges.
Regulations to ensure pr.oper operation
and maintenance of wastewater treat-
ment facilities and sewer systems
within the Commonwealth.
FAWQC are non-regulatory concentra-
tions for the protection of aquatic life,
and of human health from water inges-
tion and fish consumption.
Non-zero MCLGs and proposed
MCLGs will be met at and beyond
the compliance point (or be waived
based on technical impracticability).
When other federal and state
standards are not available, ORSGL
standards will be met at and beyond
the compliance point (or be waived
based on technical impracticability).
Groundwater will be extracted and
treated in conformance with Massa-
chusetts surface water discharge
permit requirements.
Remedial activities will comply with
all provisions of this regulation.
Groundwater will be extracted and
treated to prevent exceedance of
these criteria.
-------
:":...:.:'. ... '.;.:.:.;':'.';.:.<.:~'::
:!i!!!!!!:ii.a!~~'i...
Air
72S0S4-24
Chemical-Specific ARARs. Criteria. Advisories. and Guidanc~
(cont'd)
4
;ttII..4~.1.,'fj*~~!1rili~~1ili,
Regulations specify requirements to Adequate controls will be utilized to
prevent visj~le emissions, not to exceed meet these requirements.
the criteria set forth in the regulations.
Massachusetts Ambient Air Quality
Standards - 310 CMR 6.00
Relevant and Appropriate
Regulations specify primary and secon-
dary ambient air quality standards to
protect public health and welfare for
certain pollutants.
Massachusetts Air Pollution Conb 01
Regulations - 310 CMR 7.01 and
7.02(2)(a)
Applicable
Regulations pertain to the prevention of
emissions in excess of Massachusetts
or national ambient air quality stand-
ards or in excess of emission limita-
tions in those regulations.
310' CMR 7.06
Applicable
310 CMR 7.09.
Applicable
Regulations specify requirements to
prevent dust and odors - genersted
during remedial actions - which
contribute to air pollution.
Regulations specify requirements on
construction equipment to supp~
sound. Massachusetts DEP policy re-
quires that the site perimeter noise
levels not exceed 10 decibels above
ambient noise levels.
310 CMR 7.10
Applicable
.'
Mitigative measures will be taken to
control fugitive dust released during
excavation and construction activi-
ties. A thermal oxidizer will be used
to control air emissions from the
groundwater and soil treatment
systems.
A thermal oxidizer will be used as
the best available control technology
to control air emissions from the
groundwater and soil treatment sys-
tems. Mitigative measures will be
taken to control emissions from
excavation activities.
Adequate controls will be utilized to .
meet these requirements.
Mitigative measures will be used to
reduce noise levels to below the
regulated level.
-------
...... . .
.... .. .''''
.. .......... ........
. . .... ....... .
""'''' ............. .......
... .. ... ... ........... .
,."",."".,.,,,,,,,.,,,,,,
........................... .
;:::::::M~fW#.;:::
... ..
.. .......,.
Air (cont'd)
12S0S4-24
Chemical-Specific ARARs. Criteria. Advisories. and Guidance
(coot'd)
Massachusetts Air Pollution Control
Regulations (cont'd) - 310 CMR 7.18
Massachusetts Prevention and/or
Abatement of Air Pollution Episode
and Air Pollution Incident Emergencies
310 CMR 8.00
Clean Air Act (CAA)
NAAQS for Total Suspended
Particulates - 40 CFR 50
NAAQS for Hazardous Air
Pollutants - 40 CFR I to 99
Applicable
Relevant and Appropriate
Relevant and Appropriate
Relevant and Appropriate
s
.... .. .,.. .. . .. .. . .. ..
.' '.'...'.'.' '.'...'.'.', ... .'.'. '. .'...,'....',"...'. , ......' ..".',.. ". '.'
.:ji::!i!:ij!::.!;:.:i!i..~~m~.~~i:I~~r~~~m~::::: ....... .. ...:::!:~f~~;iiij~~t~T~t~:1.~t~.~}...
Regulations specify requirements on
emissions over 100 tons per year.
Regulations specify requirements to
prevent ambient air contaminant con-
centrations of any location from reach-
ing levels which would constitute lie-
nificant harm or imminent and substan-
tial endangerment to public health.
Regulation specifies maximum primary
and secondary 24-hour concentrations.
Fugitive dust emissions from site exca-
vation must be below a 24-hour aver-
age of 150 Ilg/m' for particles having a
mean diameter of 10 microns or less. .
Regulations specify amounts of
emissions for pollutants such as NO.,
SO:z, CO, lead, mercury, and
particulates for stationary sources.
A thermal oxidizer will be used as
the best available control technology
to control air emissions from the
groundwater and soil treatment sys-
tems. Mitigative measures will be
taken to control emissions from
excavation activities.
Mitigative measures will be taken to
control fugitive dust released during
excavation and construction activi-
ties. A thermal oxidizer will be used
to control air emissions from the
groundwater and soil treatment
systems.
Fugitive dust emissions will be
controlled during excavation and
construction activities to maintain
concentration below these levels.
Proper design considerations will be
implemented to control emissions
from groundwater and soil
treatments as appropriate.
-------
.........'.....'...'....'.' .. ...'
...'....'..........'.'.'... .'..........'.'.'......
[[[
::I:;:II:II:jllll::::::
Air (cont'd)
Soil
72S0S4-24
Chemical-Specific ARARs. Criteria. Advisories. and Guidance
(cont'd)
American Conference of Governmental
Industrial Hygienists (ACGIH)
Threshold Linlit Value (TLVs), Time
Weighted Average (TWAs), and Short-
Term Exposure Limit (STELa)
To Be Considered
Massachusetts Allowable Ambient
Limits (MLs) and Threshold Effects
Exposure Limits (TELs)
To Be Considered
EPA Directive for PCBs (OSWER
Directive 9355.4-01)
To Be Considered
EPA Directive for Lead (OSWER
Directive 9355.4-02)
To Be Considered
6
~j..IIB..i!.llii'lill..lii
TLVs are issued as criteria for con-
trolling air quality for occupational
settings. STELs are fifteen minute
time-weighted concentrations. TWAs
are based on an 8-hour per day, 40-
hour work week. .
Chemical-specific ambient air limits
based on health dats.
Guidance on remedial action for Super-
fund Sites with PCB contsmination
recommends a soil action level of 1 .
mglkg for residential land use and 10
to 2S mglkg for industrial land use.
Interim guidaDce on estsblishing soil
lead cleanup levels of Superfund Sites
recommends a concentration of total.
lead of 500 to 1,000 mglkg.
TL V -TWAs and TL V -STELa will be
met in the basement of Lowell Iron
and Steel's operational facility
through the capture and treatment of
contaminated groundwater in the
northern plume.
TELs and AALs will be met at the
Duck Island sewerage treatment
plant and neighboring residential
area (if selected as the groundwater
discharge location) through the cap-
ture and treatment of groundwater
prior to discharge. These standards
will also be met on-site through soil
and groundwater treatment.
All soil with PCBs above the recom-
mended levels will be excavated,
stabilized, and capped on-site to
prevent exposure.
All soil with lead above the recom-
-------
..... .. n. ...... u.
n ....... n' .....
0...... ..........'
... ...... .. ..... .....
....,..................
:,:,::,::,:1..f,:~mn,:,:::::
... .. ..... ....
...""-''''''-''-'
....."",,",".". .
........,..........
. . . . . .. ..........
.... .. ..
Soil (cont'd)
725054-24
Chemical-Specific ARARs. Criteria. Advisories. and Guidance
(cont'd)
EPA Reference Doses (RID) for
Noncarcinogens
To Be Considered
Agency for Toxic Substances and
Disease Registry (ATSDR)
Recommendation for Dioxins
To Be Considered
..... """', .':'~~~
::::::::::,::!!!i:~~m~~f-:!:~~{~~~~::,
Reference doses and standard exposure
assumptions for body weight and daily
soil contact and ingestion rates are used
to derive concentration of compound
protective of noncarcinogenic effects.
A level for residential soils contami-
nated with dioxins (as 2,3,7,8-TCDD
equivalents) of 0.001 mglkg is
recommended.
7
,..
. .. ." . '.' .
. ..... .
. . .... . ....
,~ct~~n to beTaken t(){\tta.in"
;,', ,', "', "",.;Reqwremenf.{.l,,"""':
EP A Reference Doses for some
Silresim indicator compounds
(VOCs, some semi-VOCs) will be
met through vacuum extraction
treatment of the soil. All soil with
levels of the remaining target com-
pounds exceeding the RIDs will be
excavated, stabilized, and capped on-
site within the point of compliance.
All soil with levels of dioxin
exceeding 1 ppb outside of the point
of compliance will be excavated,
stabilized, and capped on-site to
prevent exposure.
-------
..... .
. . ..... '.. . .
........ "'...
, ',':, "R", eq,::,':::'~,::,.',i,rft,',"',n,,'::en,.,'.,', t, ,., ,:,:,,}}}\},:\
"."'.'..'.'.'.'....'.'.'.'.'.'.','.',"
, ,
..,.....
.'"''''
Massachusetts Wetland Protection Act
(WPA) Regulations - 310 CMR 10.00
Massachusetts Hazardous Waste Facilit)'
Siting Regulations - 990 CMR 1.00
72S0S4-24
Location-Specific ARARs. Criteria. Advisories. and Guidance
Applicable
Relevant and Appropriate
1
." "
/')stJihri.art:,o~,R~ui~:.;!..,!:,.:.j!"",:,::!j:"i',.'!t.tti~n: :~.: ~:Taken. to:. Attai~,lttq~i,~..~t.:
These regulations include standards on dredg-
ing, filling, altering, or polluting inland wet-
lands. Work within 100 feet of a wetland is
regulated under these requirements.
Requirements for the expeditious and safe
siting of hazardous waste facilities in the
Commonwealth, which include controls on the
construction, operation, and maintenance of
'new facilities for storage treatment or disposal
of hazardous waste.
All work, including installation of groundwater
monitoring wells, to be performed within the
l00-foot buffet ZOne will be done in accordance
with these regulations.
Any remedial activities to occur within the 100-
foot buffer zone of East Pond will meet these
requirements.
-------
Action-Specific Potential ARARs and Criteria to be Considered (TBCs)
Federal
Clean Air Act (CAA)
NAAQS for Total Suspended
Particulates - 40 CFR 50
Relevant and Appropriate
NAAQS for Hazardous Air
Pollutants - 40 CFR I to 99
...
.. .n
. .
. ...
..
. ... . ....... -, ". .. ..... 0.. .
.. '..........",... . ....
. ... ........... . ".. .......... . ....
p. ..... P' ........... ....... n.. .. .
......~~~!ry:~f..!i~4~iffnt~ht..
..
.. .
..
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n. .""
. ...
.. .
. -."
. ..
...
Regulation specifies maximum primary and secondary 24-
hour concentrations. Fugitive dust emissions from site
excavation must be below a 24-hour average of 150
Ilg/m' for particles having a mean diameter of 10 microns
or less.
Relevant and Appropriate Regulations specify amounts of emissions for pollutants
such as NO., S02' CO, lead, mercury, and particulates
for stationary sources.
Clean Water Act (CW A)
National Pollution Discharge
Elimination System (NPDES)-
40 CFR 122 and 125
Applicable
General Pretreatment Regulations
for Existing and New Sources of
Pollution - 40 CFR 403
A 'plicable
n.s0S4-24
Regulations for discharges into public surface waters.
Regulations for discharges of pollutants to POTW and
specification of pretreatment standards for these
discharges.
....~ct.i~~.:~~:U~:~:O...Attai~..
Fugitive dust emissions will be controlled
during excavation and construction activi-
ties to maintain concentration below these
levels.
Proper design considerations will be
implemented to control emissions from
groundwater and soil treatments as
appropriate.
If River Meadow Brook is selected as the
discharge location for treated ground-
water, the requirements of the NPDES
program will be met, including the efflu-
ent standards, monitoring and testing,
and standard and special conditions for
discharge. Discharges to the Duck Island
treatment plant will also meet the sub-
stantive and administrative provisions of
NPDES, if selected.
Requirements for discharges to Duck
Island Treatment Plant and pretreatment
standards for discharges will be met if
the POTW is selected for discharge of
treated groundwater.
-------
Hie Potential ARARs and Criteria to be Considered
(cont'd)
BCs
Fish and Wildlife Coordination Act
- 16 USC 661
Applicable
Requires the notification of the appropriate State agency
exercising jurisdiction over Wildlife Resources and U.S.
Fish and Wildlife Service when undertaking any Federal
action that modifies any body of water or affects fish and
wildlife. .
Resource Conservation and Recovery
Act (RCRA)
Subtitle C, 40 CFR 260
Relevant ;lJ1d Appropriate RCRA regulates the generation, transport, storage, treat-
ment and disposal of hazardous waste.
40 CFR 264 .
Subpart C - Preparedness and
Prevention (40 CFR 264.30-264.37)
Relevant and Appropriate Requirements to minimize the possibility of fires, explo-
sions, and unplanned releases of waste during design,
construction, and operation of TSD facilities.
Subpart D - Contingency Plan
and Emergency Procedures
(40 CFR 264.50-264.56)
Relevant and Appropriate Requirements for emergency procedures such as explo-
sions and fires, including. contingency plan identifying
procedures to be followed.
725054-24
2
..cq;:t~~~~!~I~!~i~i{t;
If treated groundwater is discharged to
River Meadow Brook, it will be done so
as to minimize adverse impacts on fish
and wildlife, and Federal and State agen-
cies listed in this statute wiU be notified
. and consulted during remedial design if
any adverse impacts are anticipated. .
All excavation, storage, treatment, and
disposal activities will be designed and
implemented in accordance with the
RCRA regulations.
Safety and communication equipment will
be installed at the site; local authorities will
be familiarimd with site operations and
COIlstmction activities will be conducted to
prevent any type of spillage or contami-
nated nmoff from leaving the site.
Plans will be developed and implemented
during site work, including implementa-
tion of site remedies and long-term
monitoring activities. Copies of the plans
will be kept on site.
-------
Action-Soecific Potential ARARs and Criteria to be Considered (TOCs)
(coot'd)
I
el
. .
.. .
.' .'........' '...!'...i..ii,....:...':..;..'.:....'.';:...... '~~i~H6f:~~~J!!~~!!.
:;:::::::':'?:'~::'::
.. . -- -. .... h. .. ..
. n. ,- . ... ....-
n.. .. .... ... ... .
...... ... .... .. ... "........
H .'." R.#.Q~i~.,~~~.
... .
: Status..
.... .
...'
.....
40 CFR 264 (cont'd)
Subpart F - Groundwater Protection Relevant and Appropriate Requirements for groundwater monitoring program for
(40 CFR 264.90-264.101) the site.
Subpart G - Closure and Post-
Closure (40 CFR 264.110-264.120)
Relevant and Appropriate Requirement for closure and post-closure of hazardous
waste facilities.
Subpart L - Waste Piles
(40 CFR 264.250-264.259)
Relevant and Appropriate Regulations for the storage and treatment of hazardous
waste in piles, including protection from precipitation,
surface runoff, and wind erosion.
Subpart N - Landfills
(40 CFR 264.300-264.311)
Design and construction requirements for placement of a
cap over waste.
Relevant and Appropriate
40 CFR 268
Land Disposal Restrictions
Relevant and Appropriate Regulations specify requirements for disposal of hazar-
dous waste. .
725054-24
3
..
. ..
.. .... .. ... .. .
. .'.. . .. ..
. . . .. . . .. . .
.,Actioti (0 beTakeri t~Atb.ii~
HH Itequiremerit .' ......'. .
..
A groundwater monitoring program will
be designed, installed, and implemented
to evaluate and measure groundwater
contamination at and beyond the point of
compliance, will meet the substantive
standards of this regulation.
Treated soils will be monitored to ensure
that they can be disposed of on site with-
out further treatment. A post-elosure
monitoring program will be implemented.
Drainage and erosion control structures
will be placed prior to excavation. Ex-
cavated soils will be stored in compliance
with all substantive provisions of this
regulation.
The cap will be designed and constructed
to conform to RCRA standards to pri-
marily eliminate direct contact and reduce
infiltration of rainwater. The cap and sur-
rounding area will be graded to control
run-on and run-off.
LDRs for RCRA hazardous substances at
the site will be met through soil treat-
ment. To ensure that LDRs have been
met, the soil will be tested following
treatment.
-------
Action-Specific Potential ARARs and Criteria to be Considered (TBCs)
(cont'd)
4
Toxic Substances Control Act
(TSCA) - 40 CFR 761 .
State
Massachusetts Ambient Air Quality
Standards - 310 CMR 6.00
Massachusetts Air Pollution Control
Regulations - 310 CMR 7.01 and
7.02(2)(a)
725054-24
Applicable
Establishes treatment requirements,' including incineration
and disposal for PCB-contaminated materials, including
soils.
Relevant and Appropriate Regulations specify primary and secondary ambient air
quality standards to protect public health and welfare for
certain pollutants.
Applicable
Regulations pertain to the prevention of emissions in
excess of MassachuSetts or national ambient air quality
standards or in excess of emission limitations in those
regulations.
..... ......~~ti6It..t.~~J::t:f..1~~i.~..::
TSCA disposal requirements for PCBs
will be met by waiving certain require-
ments of the chemical waste landfill regu-
lations. Provisions to be waived are sec-
tions 761. 7S(b)(1), construction of a
landfill in low permeable clay conditions;
761.7S(b)(2), use of a synthetic mem-
brane liner; and 761.7S(b)(3), the bottom
of the landfill being SO feet above the
historic high water table. EP A has deter-
mined that the excavation, stabilization,
and capping of PCB-<:ontaminated soil
will provide a permanent and protective
remedy that satisfies the part 761 landfill
requirements.
Mitigative measures will be taken 10 con-
trol fugitive dust released during excava-
tion and construction activities. A
thermal oxidizer will be used to control
air emissions from the groundwater and
soil treatment systems.
A thermal oxidizer will be used as the
best availabl ~ control technology to con-
trol air emissions from the groundwater
and soil treatment systems. Mitigative
measures will be taken to control emis-
sions from excavation activities.
-------
Action.-Specific Potential ARARs and Criteria to be Considered (TBCs)
(cont'd)
Massachusetts Air Pollution Control
Regulations (cont'd)
310 CMR 7.06
Applicable
310 CMR 7.09
Applicable
310 CMR 7.10
Applicable
310 CMR 7.18
Applicable
Massachusetts Prevention and/or
Abatement of Air Pollution Episode
and Air Pollution Incident
Emergencies - 310 CMR 8.00
Relevant and Appropriate
Policy, Controls 01 VoltJIile Organic
Compound (VOC) Emissions from Air
Strippers which are used to treat
Contaminated Groundwater
To Be Considered
725054-24
. . .
. .
.H.:~~:~~::~!~!.~~!t~~t::
. ...
... .
"00-
......
," ~ :::::
......, ...
,... ....
Regulations specify requirements to prevent visible
emissions, not to exceed the criteria set forth in the
regulations.
Regulations specify requirements to prevent dust and
odors - generated during remedial actions - which
contribute to air pollution.
Regulations specify requirements on construction
equipment to suppress sound.
Regl;llations specify requirements on emissions over 100
tons per year.
Regulations specify requirements to prevent ambient air
contaminant concentrations of any location from reaching
levels which would constitute significant harm or immi-
nent and substantial endangerment to public health.
Requirements which specify the use of a vapor phase
granular activated carbon on air emissions.
5
.. .
..~~~?~. t~~:u~~:n~~ i\.tbii~
Adequate controls will be utilized to meet
these requirements.
Adequate controls will be utilized to meet
these requirements.
Mitigative measures will be used to
reduce noise levels to below the regulated
level.
A thermal oxidizer will be used as the
best available control technology to con-
trol air emissions from the groundwater
and soil treatment systems. Mitigative
measures will be taken to control emis-
sions from excavation activities.
Mitigative measures will be taken to con-
trol fugitive dust released during excava-
tion and construction activities. A
thermal oxidizer will be used to control.
air emissions from the groundwater and
soil treatment systems.
Adequate controls will be utilized. to meet
these requirements.
-------
Action-Specific Potential ARARs and Criteria to be Considered (fOCs)
(cont'd)
Massachusetts Hazardous Waste
Regulations - 310 CMR 30.00
310 CMR 30.500 and 30.561
310 CMR 30.580
310 CMR 30.590
310 CMR 30.620 to 30.633
310 CMR 30.640
310 CMR 30.660
310 CMR 30.680 and 30.690
Regulations for handling, storage treatment, disposal, and
record keeping at hazardous waste facilities.
Relevant and Appropriate Requirements specifically pertaining to the construction
and long-tenn operation of a treatment system.
Relevant and Appropriate Requirements specifically pertaining to on-site treatment
or long-term storage of hazardous waste.
Relevant and Appropriate Requirements specifically pertaining to monitoring, main-
tenance, and security of wastes left on-site following
treatment.
Relevant and Appropriate Requirements specifically pertaining to the cap for RCRA
closure.
Relevant and Appropriate Requirements for the construction and operation and
closure of waste piles.
Relevant and Appropriate Requirements for the protection of groundwater appropri-
ate to hazardous waste treatment units.
Applicable
Requirements that pertain to above ground storage con-
tainers and tanks used to treat or store hazardous waste.
Massachusetts RIGHT TO KNOW - Relevant and Appropriate Requirements for the transmission of health and safety
105 CMR 670.00 information to the public and workers concerning toxic
and hazardous substances.
Massachusetts RIGHT TO KNOW - Relevant and Appropriate Requirements for the disclosure of information regarding
554 CMR 21.00 toxic and hazardous substances to DEP .and workers. .
Massachusetts Hazardous Waste
Activity Notification - 310 CMR
33.(0)
725054-24
Relev~t and Appropriate
Regulations establish rules and requirements for the
distribution of information related to toxic and hazardous
substances to the public.
6
. ............!i~~~4.~;~~~d:n~~~~tt#~;..:..::.::..
Substantive requirements of 811 relevant
and appropriate Massachusetts require-
ments will be met through proper design
and implementation.
All tanks and containers used on-site will
meet the applicable requirements.
Appropriate notification requirements will
be met.
Appropriate notification requirements will
be met.
Appropriate notification requirements will
be followed.
-------
,~ ~,'
,.. . .
. .. .
.' Requi~ent.:: =::
Massachusetts Surface Water Discharge
Penrut Requirements - 314 CMR
3.00
Massachusetts Su'rface Water Quality
Standards - 314 CMR 4.04
314 CMR 4.06(2)
Massachusetts Certification for
Dredging, Dredged Material Disposal
and Filling in Waters - 314 CMR
9.00
Massachusetts Operation and Mainten-
ance and Pretreatment Standards for
Wastewater Treatment Works and
Indirect Discharge - 314 CMR 12.00
Federal Clean Water Act (CW A) -
Federal Ambient Water Quality
Criteria (FAWQC)
725054-24
Action-Specific Potential ARARs and Criteria to be Considered (TBCs)
(cont'd)
.:' ,....,.....,.,...,:.,.,::..q~'~i~.q.
Relevant and Appropriate
Applicable
Applicable
Applicable
Applicable
To Be Considered
. '.:(':.:.
... . . . .. .... .
- . ".
tSwnmary of Req.uirmient
::=."",. :'..' "." :":':" . :.."" .'"
, 7. ,;:..>
,,;.. }:.,
, .,';';}.; t.
',. .'
....
Standards regulate discharges of pollutants to surface w lters,
outlets for such discharges and any treatment works
associated with these discharges.
Requirements for the antidegradation of surface waters.
These provide for control of eutrophication and establish
discharge criteria.
Requirements for the antidegradation of unlisted surface
water bodies.
7
..... "... .. ".. ... ....
... .'.".'.. .. . ".. .."'", ...-",",". ,'.",".".'..'
...AC(j~~ti~u~~~:?:..,~~tair,.:.,
Groundwater will be extracted and treated
in conformance with Massachusetts surface
water discharge permit requirements.
..." .
If River Meadow Brook is selected as the
discharge location, the water will be treated
to meet these standards.
If River Meadow Brook is selected as the
discharge location, the water will be treated
to meet the applicable standards.
Requirements for the unifonn and coordinated administration If River Meadow Brook is selected as the
of dredging and dredged material disposal and filling discharge point for treated groundwater,
projects in the waters of the Commonwealth. certification will be acquired.
Regulations to ensure proper operation and maintenance of
wastewater treatment facilities and sewer systems within the
Commonwealth.
Remedial activities will comply with all
provisions of this regulation.
FA WQC are non-regulatory concentrations for the protection Groundwater will be extracted and treated
of aquatic life, and of human health from water ingestion to prevent exceedance of these criteria.
and fish consumption.
-------
APPENDIX D
-------
~
Daniel S. Greenbaum
Commissioner
James C. Colman
Assistant Commissioner
[7k 6£ c;/
~~t{/g~~
q;~if0~~
{iJtUeOU/ if 'WfMtet Jib7 ~
~1PVl£o.J~ ~ ~02tOO'
Julie Belaga
Regional Administrator
u.s. Environmental Protection
JFK Federal Building
Boston, MA 02203
september 19, 1991
Agency
RE: State Concurrence
with Record of
Decision for the
Silresim Federal
Superfund Site
ID #3-0352
Dear Ms. Belaga:
The Department of Environmental Protection (the Department)
has reviewed the preferred remedial alternative recommended by
the u.S. EPA for source control and management of migration
measures at the Si1resim Federal Superfund site in Lowell,
Massachusetts. The Department concurs with the choice of
remediation selected.
This remedial action addresses the contaminated soils and
groundwater and comprises the following components:
1.)
2. )
Source Control Alternative
-vacuum/vapor extraction of contaminated soils,
-stabilization of the residual contaminated soils and
-disposal on-site under a RCRA cap.
Management of Migration Alternative
-air stripping of the contaminated groundwater
Because contaminated material will remain on the Site, the
use of institutional controls will be necessary. The chosen
remedial action will only achieve a temporary solution as defined
by the Massachusetts Contingency Plan (MCP). A long-term
monitoring program will ensure that the remedy remains protective
of human health and the environment.
-------
Julie Belaga
Page Two
September 19, 1991
The EPA will perform a risk assessment on the residual
groundwater contamination remaining after project completion to
determine whether the remedial action has been effective.
Remedial actions will continue until protective levels are
attained.
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 the Silresim Superfund Site. .
The Department has reviewed the ARARs identified for the
Commonwealth and it appears the proposed remedy meets all ARARs.
The Department will continue to evaluate the ARARs as remedial
design progresses and during implementation and operation of the
remedy.
The Department looks forward to working with the
designing and implementing the preferred alternative.
have any questions or require additional information,
contact Evelyn Tapani at 556-1125. .
EPA in
If you
please
v ruly yours,
an>el ~
Commissioner
Massachusetts Department of
Environmental Protection
cc:
James C. Colman, Assistant Commissioner
Madeline Snow, Division Director
Helen Waldorf, Section Chief
Evelyn Tapani, Project Manager
Richard Chalpin, Regional Engineer
-------
APPENDIX E
-------
RESPONSJ:VENESS SUKKARY
SJ:LRESJ:H SUPERFUND SJ:TE
LOWELL, MASSACHUSETTS
September 19, 1991
U.S. Environmental Protection Agency
-------
SILRESIM SUPERFUND SITE
RESPONSIVENESS SUHJIARY
LOWELL, MASSACHUSETTS
TABLE OP CONTENTS.
Paae
PRE PACE
............ ..... ...... .... ..................... ... .... 1
I.
OVERVIEW OP REMEDIAL ALTERNATIVES CONSIDERED
IN THE FEASIBILITY STUDY, INCLUDING THE
PREFERRED ALTERNATIVE .................................. 2
II.
SITE HISTORY AND BACKGROUND ON COMMUNITY
INVOLVEMENT AND CONCERNS ...............................
3
III.
SUMMARY OF COMMENTS RECEIVED DURING THE PUBLIC
COMMENT PERIOD AND EPA RESPONSES. . . . . . . . . . . . . . . . . . . . . .. 5
Part I.
Citizen Comments .............................
6
Part II.
State Officials .............................. 10
A.
B.
C.
D.
Human Heal th and Communi ty Concerns ~............... 10
Feasibili ty Study.............................o.... 13
EPA's Preferred Alternative ....................... 14
Applicable or Relevant and Appropriate.
Requirements (ARARs) ...................~....~..... 19
General Comments................................... 22
E.
Part. III.
potentially Responsible Parties ............. 23
ATTACHMENT A -
COMMUNITY RELATIONS ACTIVITIES CONDUCTED AT
THE SILRESIM SITE
ATTACHMENT B -
-------
RESPONSIVENESS st7KllARy
SILRESIK SUPERFUND SITE
LOWELL, MASSACHUSETTS
Preface
The U.S. Environmental Protection Agency (EPA) held a 60-day
public comment period from June 20, 1991 to August 19, 1991 (due
to a hurricane on August 19, the comment period was extended one
day to August 20) to provide an opportunity for the public to
comment on the Remedial Investigation (RI), Feasibility Study
(FS), the Proposed Plan and other documents developed for the
Silresim Superfund Site in Lowell, Massachusetts (the Site). The
FS examined and evaluated various options, called remedial
alternatives, to address contamination at the Site. EPA made a
preliminary recommendation of its Preferred Alternative for Site
remediation in the Proposed Plan issued on June 19, '1991 before
the start of the comment period. All documents on which the
preferred remedy selection was based have been placed in the
Administrative Record for public review. The Administrative
Record is a collection of all the documents considered by EPA to
select the remedy for the Site. It is available at the EPA
Records Center at 90 Canal Street in Boston, Massachusetts and at
the Pollard Memorial Library on Merrimack stre~t in Lowell,
Massachusetts prior to the public comment period.
The purpose of this Responsiveness Summary is to document EPA
responses to 'the questions and comments raised during the public
comment period. EPA has considered all of the comments in this
document before selecting a final remedial alternative to address
contamination at the Site.
The Responsiveness Summary is organized into the following
sections:
I.
11.
III.
Overview of Remedial Alternatives Considered in the
Feasibility Study and Proposed Plan, including the'
Preferred Alternative - This section briefly outlines the
remedial alternatives evaluated in the FS and the Proposed
Plan, including EPA's Pre~erred Alternative.
site History and Backqround on community Involvement and
Concerns - This section provides a brief Site history and a
general overview of community interests and concerns
,regarding the Site.
Summary of Comments Received During the Public Comment
Period and EPA Responses - This section summarizes and
provides EPA's responses to the oral and written comments
received from the public during the public comment period.
In Part I of this Section, the comments received from
citizens are presented. Part II summarizes comments
-------
received by state officials. Part III summarizes comments
from the Potentially Responsible Parties (PRPs). 0
In addition, two attachments are included in this Responsiveness
Summary. Attachment A provides a chronology of community
relations activities at the Site. Attachment B contains a copy
of the transcript from the informal public hearing held on July
10, 1991 in Lowell, Massachusetts. The comments submitted during
the public comment period are available in the Administrative
Record for the silresim site.
I.
OVERVIEW OF REMEDIAL ALTERNATIVES CONSIDtRED IN THE
FEASIBILITY STUDY AND PROPOSED PLAN
using.the information gathered during the Remedial Investigation
(RI), EPA identified several objectives for the cleanup of the
silresim Superfund site. The primary cleanup objective is to
reduce the risks to human health and the environment posed by
exposure to the source contamination on-site and to groundwater
contamination that has already or may in the future migrate off-
site. Cleanup levels for groundwater and soil are set oat levels
that EPA considers to be protective of human health and the
environment.
After identifying the cleanup objectives, EPA developed and
evaluated potential cleanup alternatives, called remedial
alternatives. The FS describes the remedial alternatives
considered to address the contaminants of concern and the
pathways in which they pose a threat. The FS also describes the
criteria EPA used to narrow the range of alternatives to 9
potential source control (SC) remedial alternatives and 4
potential management of migration (MM) remedial alternatives.
The 9 source control remedial alternatives considered are:
SC-1:
Minimal/No Action
SC-2:
RCRA Cap
SC-3:
Vacuum/Vapor Extraction, RCRA Cap
Vacuum/vapor Extraction, Stabilization and Disposal
On-site
SC-4:
SC-6:
Thermal Desorption, stabilization, RCRA Cap
SC-10: Incineration, Stabilization, RCRA Cap
SC-ll: Vacuum/vapor Extraction, Incineration, Stabilization
and RCRA Cap
SC-14: vacuum/Vapor Extraction, Solvent Extraction,
-------
stabilization, and RCRA Cap
SC-1S: Vacuum/Vapor Extraction, Solvent Extraction,
Stabilization, Off-Site Disposal, RCRA Cap
The 4 management of migration remedial alternatives are:
MM-1: Minimal/No Action
MM-2: Pump and Treat On-Site by Metals Pretreatment, Air
stripping, and Carbon Adsorption
MM-3: Pump and Treat On-site by Metals Pretreatment, Steam
Stripping, and Carbon Adsorption
MM-4: Pump and Treat On-Site by Metals Pretreatment and
UV/Chemical Oxidation
The preferred alternative selected by EPA to address site
contamination includes a combination of technologies to address
contaminated soil and groundwater at the site. The preferred
Source Control alternative (SC-4) includes in-situ vacuum/vapor
extraction of contaminated soil, excavation and stabilization of
soil with residual contamination, and disposal of stabilized
materials on-site under an impermeable Resource Conservation and
Recovery Act (RCRA) Cap. The preferred groundwater treatment
alternative (MM-2) includes extraction and treatment of
contaminated groundwater utilizing air stripping as the primary
treatment component. During remedial design, EPA will determine
whether the treated contaminated groundwater will be discharged
to the Duck Island Sewage Treatment Facility (POTW) or to River
Meadow Brook. In addition, the cleanup plan will rely on
institutional controls to prevent any use of groundwater until
contaminant concentrations have decreased to safe levels. A
long-term monitoring program will also be implemented during pre-
design and will continue until EPA determines that the remedy is
protective. .
After a car~ful review of the comments made during the public
comment period, EPA documented the selected remedy in the Record
of Decision. The selected remedy shows no significant changes
from the preferred alternative. All of the remedial alternatives
considered for implementation at this site can be found in the
Record of Decision Summary, the Proposed Plan and the Feasibility
study.
II.
SITE HISTORY AND BACKGROmm ON COMHUHITY INVOLVEMENT AND
CONCERNS
The Silresim site is a five-acre abandoned chemical waste
recycling facility, located at 86S Tanner Street in Lowell,
Massachusetts. The site-and its surrounding areas have been used
-------
for industrial activities since the early 1900's, including an
oil and fuel storage depot from 1916 to 1971. From 1971 through
1977, the Silresim Chemical corporation operated a chemical waste
reclamation facility on the site.
The Silresim Chemical Corporation filed for bankruptcy in late
1977, after receiving numerous notices of permit violations from
the Massachusetts Division of Water Pollution Control during the
mid-1970's. In 1978, the Silresim Chemical Corporation abandoned
the Site, leaving approximately one million gallons of hazardous
materials on-site in drums and bulk tanks. .
From 1978 to 1982, the Massachusetts Department of Environmental
Quality Engineering (DEQE, now the Massachusetts Department of
Envir~nmental Protection) secured the site and took steps to
minimize immediate threats to public health. and the environment,
which included the construction of a site fence, provisions for
24-hour security, removal of liquid wastes in on-site drums and
above-ground tanks, and actions to prevent the further migration
of contamination. .
In 1982, EPA placed the Site on the National Priorities List,
making it eligible for Federal action under th~ Superfund ~w~
Between the Spring of 1983 and December 1984, EPA removed all
structures remaining on the site, extended the fence, and placed
a temporary clay cap over the Site. On July 12, 1985, EPA issued
an Administrative Order by Consent to the Silresim site Trust, a
group of parties deemed potentially responsible for contamination
at the site, who agreed to undertake a Remedial
Investigation/Feasibility Study to determine the nature and
extent of contamination and evaluate potential cleanup
alternatives which would address contamination at the Silresim
Site. .
. Throughout the site's history, community concern and involvement
have been sporadic. During the early 1980's community concern
and involvement was high when groundwater, soil and air quality
data became available. Several citizens groups were established
to address site issues. These groups and other members of the
. Lowell community participated actively in early developments at
the Site~ However, in recent years indicators of local interest
have decreased significantly.. .
EPA and the Massachusetts Department of Environmental Protection
(DEP) have kept the community and other interested parties
informed of site activities and involved in the decision-making
process through informational meetings, fact sheets, press
releases, public meetings, and a publicly accessible Site file in
the Pollard Memorial Library in Lowell. In 1983 and 1984, EPA
and DEP operated an information hot-line and participated in
regular meetings of a group called the Silresim Task Force, which
was designed to improve communications between federal, state,
-------
and local officials, and the citizens.
During september 1985, EPA released a community relations plan
which outlined a program to address community concerns and keep
citizens informed of and involved in remedial activities. In
response to a petition from a local environmental organization
(the Ayer City HQmeowners Chapter of the Greater Lowell
Environmental Campaign), DEP designated the Silresim Site as a
Public Involvement Plan (PIP) site in 1988. DEP developed the
plan jointly with EPA so that federal and state community
relations efforts would not be duplicated. The resulting joint
Community Relations Plan/Public Involvement Plan was finalized in
June 1991.
EPA has held numerous informational meetings since the Site's
listing on the NPL. For example, on April 26, 1990, EPA held an
informational meeting to discuss the results of the Remedial
Investigation. On June 19, 1991, EPA held a meeting to describe
the cleanup alternatives presented in the Feasibility Study, and
to present EPA's Proposed Plan. During both of these meetings
EPA answered questions from. the public. Those in attendance at
these meetings included local area residents, state and local
officials, representatives from EPA, and representatives from
companies interested in the site activities and cleanup .
decisions. Summaries of these informational meetings can be
found in the Administrative Record at the Pollard Memorial
Library in Lowell.
The 30 day public comment period on the alternatives presented in
the Feasibility study, the Proposed Plan and on any other
documents previously released to the public that began on June
20, 1991 and was extended an additional thirty days to August 19,
1991 (due to a hurricane on August 19, the comment period was
extended one day to August 20). On July 10, 1991, EPA held an
informal public hearing to accept any oral comments. The
transcript from this meeting is included as Attachment B to this
Responsiveness Summary. The comments made at this hearing and
EPA's response to the comments are included in Section III of
this Responsiveness Summary. .
EPA has prepared site fact sheets and distributed them to
recipients on the site mailing list and at public meetings.
These fact sheets included a Superfund Program fact sheet in
April, 1990 and a Proposed Plan fact sheet in June, 1991. EPA
has issued other press releases regarding site developments and.
public meetings throughout the site's history.
III.
SUMMARY OF COMMENTS RECEIVED DURING THE PUBLIC COMMENT
PERIOD AND EPA RESPONSES
This Responsiveness Summary addresses comments received by EPA
during the public comment period. Three citizens of Lowell
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addressed EPA's Preferred Alternative during the public hearing
on July 10, 1991. Four sets of written comments were received by
EPA during the public comment period including: local businesses,
the Massachusetts Department of Public Health, the Massachusetts
Department of Environmental Protection and the Silresim PRP
group.
Part I - citizens
Comment 1: One commenter requested that the public comment
period be extended for an additional 30 days. The commenter
stated that 30 days is not a sufficient period considering the
extensive nature of the Proposed Plan and given the potential
health impacts that the remedy may have to a community of 800
families. The commenter stated that more details should have
been provided in the Proposed Plan, specifically concerning the
type and concentrations of air emissions from the preferred
trea tment systems. .
EPA Response: The public comment period was extended an
additional 30 days on July 16 pursuant to the formal verbal and
written request made by Norine Brodeur, dated July 10, 1991. The
comment period ended August 19, 1991 (due to a hurricane, an .
aditional day was granted, .extending the comment period to August
20, 1991). . .
The proposed Plan is intended to provide a brief summary of all
of the alternatives studied in the Detailed Analysis phase of the
Feasibility study and of EPA's preferred cleanup alternative.
The Proposed Plan is a conceptual plan and is intended to solicit
public concerns and comments prior to EPA's final remedial
selection. Following EPA's.consideration of public comments on
the preferred alternative and the others analyzed, EPA records
its decision in greater detail in the Record of Decision. If EPA
were to get into a great deal of specificity on all of the
alternatives under consideration in the proposed Plan, the
superfund process would be unnecessarily prolonged.
Although certain unknowns exist during the public comment period,
such as what the exact air emissions would be from excavations
and treatment, EPA does identify whether the alternatives would
be protective of human health and whether state and federal
requirements (such as those of the Clean Air Act) would be
achieved by the remedy based on the information provided in the
Feasibility study. The Remedial Design phase is the phase during
which technical drawings and specifications are developed for the
subsequent Remedial Action. During the design phase, field
studies are performed that include actual on-site treatment
systems to test their effectiveness and to determine what the
contaminant concentrations are in system emissions.
Unfortunately, EPA cannot determine exactly what the effluent
levels will be from a treatment system until the system is
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designed and implemented. Prior to this phase, estimates are
made to determine whether available controls will meet the
appropriate health based standards/limits.
In addition to the remedy meeting state and federal standards for
treatment emissions, a health and safety plan will be developed
to protect workers on-site and people in the surrounding area
during implementation of the remedy. Air monitoring will be also
required to ensure that allowable levels of contaminants are not
exceeded.
Comment 2: One commenter stated that incineration should have
been considered and selected as the most permanent remedy at the
Site. The commenter is concerned that a cap will not prevent the
rainwater from infiltrating into the soil around the. cap and that
leaching of contaminants from the soi1 into the groundwater and
migrating off-site will still occur. The commenter stated that
the cost of incineration is justified in permanently mitigating
the problem.
EPA Response: Incineration was considered for the Silresim Site
in two of the nine final Source Control alternatives (SC-10 and
SC-11). SC-10 called primarily for excavation and incineration
of all soil exceeding cleanup levels for indicator substances
(except for inorganics) at the Site. SC-11 called for in-situ
vacuum/vapor extraction of volatile organic compounds (VOCs), and
subsequent incineration of soil contaminated with semi-vocs and
heavier organics such as PCBs and dioxins. EPA acknowledges this
resident's concern regarding the importance of permanently
eliminating all the waste at the Site; however, EPA has
determined that neither of these alternatives would yield results
that are proportionate to the selected remedy in terms of their
overall protectiveness, implementability, effectiveness and cost.
Section 12l(b) (1), of CERCLA presents several factors that EPA is
required to consider at a minimum 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 is performed on the
alternatives using the nine evaluation criteria in order to
select a site remedy. A summary of the comparison of each
alternative's strength and weakness with respect to the nine
evaluation criteria is found in section IX of the attached Record
of Decision.
Although SC-10 and SC-11 would have provided more permanent
protection by reducing the concentrations of most contaminants at
the Site (with the exception of metals), the selected remedy will
provide the same level of protection for less money by reducing
the principal threats at the Site (volatile organic compounds)
and by preventing exposure to the remaining contaminants left on
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site through stabilization and capping. Alternative's SC-10 and
SC-ll also would require a final cap, as residual contaminants
would remain on Site. Even though incineration would reduce the
concentrations of heavier organics such as PCBs and dioxins,
these constituents are found less frequently, in lower relative
concentrations. They are less soluble and therefore less likely
to leach into the groundwater. The selected remedy also calls
for stabilization to bind the residual contaminants and a cap to
increase the long-term effectiveness of stabilization and prevent
exposures.
Unlike with the selected remedy or SC-ll, excavation of 137,000
cubic yards of VOC contaminated soil down to the water table
would be necessary prior to incineration to implement SC-10.
Altho~gh there are controls for minimizing air emissions due to
VOCs, the potential short-term risks (8 years to incinerate) to
site workers and the community are considerably higher than those
associated with the selected alternative. Additionally,
incineration would result in higher air emissions, even with
controls, than the selected alternative.
EPA has also determined that the technical feasibility of
excavating a very large volume of soil (SC-10) poses major
construction problems, including large-scale application of VOC
emissions control and the location of treatment equipment and
facilities. Treatment equipment would have to be located either
on the Silresim property and moved at least once during the
course of the project, or located off the property outside the
areas to be excayated.
In conclusion, in situ vacuum/vapor extraction, stabilization and
a cap will be protective of human health and the environment and
reduce the toxicity, mobility and volume of contaminants at the
site at a considerably lower cost than either SC-10 or SC-ll.
Although SC-10 would complete the job in one-third less time than
the selected source control alternative, the short-term risks are
considered higher and the construction problems greater in
comparison.
.[It should be noted to the commenter that incineration applies
only to unsaturated (dry) soil. Incineration will not reduce the
level of contamination that currently exists in the groundwater.
It is technically infeasible to incinerate the contaminated
groundwater plume.] .
Comment 3: One commenter stated that a follow-up health study
should be performed on those residents with physical ailments
that have moved out of the silresim area. .
EPA Response: EPA does not prepare health assessments in
association with Superfund Sites. The Centers for Disease
Control (Agency for Toxic Substances and Disease Registry) in
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cooperation with the Massachusetts Department of Public Health
are responsible for evaluating potential health risks associated
with Superfund Sites. Please refer to Suzanne Simon with the
Agency for Toxic Substances and Disease Registry, at (617) 223-
5526 for information regarding Silresim health studies.
Comment 4: The Lowell Iron & Steel Company and Scannell Boiler
Works at 50 Tanner St. (adjacent to the Silresim property)
expressed. support for EPA's objectives for cleaning up the Site,
but. expressed concern for the impact current Site conditions have
on their health and the impact that the preferred alternative may
have on their businesses. Company representatives stated that
implementation of .the proposed remedial alternative will require
long-term and unrestricted access to, and use of, their
properties which may cause their businesses to close. They have
requested that EPA actively persuade the PRPs to re~olve the
problem by working with Lowell Iron and Steel representatives
immediately. .
EPA ResDonse: Since the release of contaminants at the former
Silresim Chemical Company during the 1970's, the contaminants
have migrated beyond the original limits of this property. The
contaminants have primarily migrated via 1) surface runoff to the
soil of the abutting properties, 2) leaching into and with the
groundwater, and 3) into the air.
EPA and the Centers for Disease Control, Agency for Toxic
Substance and Disease Registry, use current Site conditions to
determine what potential exposure risks are posed by the Site and
whether there is an imminent and substantial endangerment to
human health (and what actions are necessary). If Site
conditions change, additional exposure pathways may be created.
As previously stated in written correspondence to the principals
of Lowell Iron and Steel Company and Scannell Boiler Works, a
portion of their property, which is north of the Silresim
property, is contaminated and includes as part of t~e Silresim
Superfund Site. Therefore, EPA is concerned that use of that
property in a manner that differs from the assumptions made in
the Remedial Investigation, prior to implementation of the remedy
described in the Record of Decision, may present an additional
exposure risk. Additionally, .EPA's need for unrestricted access
for the purpose of sampling and other pre-design activities prior
to the implementation of the remedy is essential.
EPA realizes that ownership of property included in a Superfund
site, or part of one, is burdensome and has the potential to
restrict use of that property. However, EPA's first .
responsibility is to the overall protection of human health and
the environment. In order to mitigate the risks that the
Silresim Site poses. to the public and environment, remedial
action is required. Unfortunately, the action requires long-term
unrestricted access to the abutting property to meet the cleanup
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levels set forth in the Record of Decision.
Although it is premature to identify whether a settlement will be
reached with the Potentially Responsible Parties (PRPs) at the
Site, EPA is hopeful that negotiations for performance of the
remedial action will be fruitful. EPA wants a fair resolution
for all parties affected by the Site, including the abutting
property owners. EPA is currently considering this matter, and
has urged the PRPs to do the same and open the lines of
communication with all involved to ensure a speedy and equitable
resolution.
Part II - state Officials
Written comments were received from the Massachusetts Department
of Public Health (DPH) and the Departaent of Environmental
Protection (DEP). Where the same or similar comments have been
given by both Departments they have been grouped together for the
purpose of providing a complete response. The comments are
organized in the following categories: A) Human Health and
community Concerns; B) Feasibility Study C) Preferred
Alternative; D) Applicable or Relevant and Appropriate
Requirements (ARARs); E) General Comments.
A.
Human Health/community Concerns
Comment 1: In letters submitted during the public comment
period, the Massachusetts Department of Environmental Protection
(DEP) and Department of Public Health (DPH) expressed concern
about public health, if contaminants should seep into and
volatilize .within the basement of the closest residence to the
Site on North Main Street. DPH representatives indicated that,
in such a case, exposure to residents (especially children) could
occur through ingestion, absorption, and/or inhalation. They
recommended that EPA notify the potentially affected residents of
exposure possibilities. DPH also recommended that EPA gather
more information regarding depth of the basement, type of
basement floor, foundation type, and the extent of past seepage
of groundwater into the basement..
EPA Response: EPA shares the Department of Public Health and the
Department of Environmental Protection's concern regarding
potential basement seepage of contaminated groundwater into the
nearest residence to the site. Sampling and analysis data from
the Remedial Investigation had previously indicated that the
contaminated groundwater plume did not extend to the house
closest to the Si~e/s southern perimeter.. However, the plume is
slowly migrating and, until the remedy is implemented, poses
potential exposure risks related to potential seepage of
contaminants into the basements of residential dwellings closest
to the site.
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In order to document the nature and extent of the groundwater
plume in this area, EPA recently (August, 1991) collected
additional groundwater and surface water/sediment samples south
and southeast of the Site. Groundwater samples were collected
from existing wells and piezometers located on Main Street,
Canada street and Map~e street. Additionally, surface water and
sediment samples were collected from East Pond.
The results of this sampling and analysis will be used to
evaluate changes in the current identification of exposure risks
posed by the Site. These samples are currently being analyzed.
Once this data is available, the Agency for Toxic Substances and
Disease Registry (ATSDR) will review the data to determine if
there are any potential health risks and/or make a recommendation
of adqitional actions necessary to be protective of human health.
This data will also be made available to residents who may be
potentially affected, and will become part of the Silresim
Administrative Record, located at the Lowell Public Library and
at EPA's offices in Boston. The closest resident on North Main
Street, as well as other residents located in the vicinity of
Silresim, are on EPA's mailing list which means that they should
have been receiving EPA mailings related to the Silresim Site,
which include the Remedial Investigation Fact Sheet, meeting
notices, notices of sampling efforts, notice of the availability
of the Silresim Administrative Record, the updated EPA/DEP
Community Relations Plan, and the Proposed Plan.
A decision regarding the need for more information regarding the
construction of basements and occurrences of seepage into the
nearest basements will be made following EPA's review of the
validated data from the recent sampling event.
Comment 2: .The Massachusetts Department of Public Health stated
their concern for the use of a well at a car wash located
approximately 2,000 feet from the Site. The car wash all~gedly
utilizes groundwater for its operations. The Department is
concerned that if the contaminated plume were to reach the car
wash, there would be a potential future exposure pathway by
inhalation and absorption of VOC~. Although the FS indicates
that well yields are expected to be very low in the Silresim
area, the Department is not convinced that the well yields are
too low to prevent future use for industrial or residential
purposes and suggests that EPA gather more information regarding
the physical nature of the well and surrounding area at the car
wash.
EPA ResDonse: It is true that the estimated water yield from a
hypothetical drinking water well is very low due to the physical
nature of the aquifer at and near the Silresim Site. However,
this factor alone would not prevent the installation of a well in
the site area for the purpose of yielding drinking water.
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The well at the car wash 2,000 feet away from the Silresim Site
is reportedly no longer being utilized for the purpose of
cleaning vehicles. The future potential exposures of inhalation,
dermal contact and ingestion of contaminated groundwater at the
car wash were not evaluated because the exposures were not
believed to be reasonable. The Silresim plume is moving at an
exceptionally slow rate. In the past 15 years the plume has only
migrated 400 feet away from the site. The forthcoming remedial
action is expected to curtail plume migration, and therefore be
protective of the nearest receptors to the Site, as well as those
further away such as the Lowell Car Wash.
It should be noted, however, that ingestion of contaminated water
at a future hypothetical water supply well on the site was
evaluated in the baseline risk assessment in the Remedial
Invest~gation as a worst-case scenario. Superfund risk
assessments are used primarily to determine the necessity of
remedial actions at sites and to develop target cleanup levels.
Sampling and analysis data from the Remedial Investigation is
reviewed by the Centers for Disease Control (Agency for Toxic
Substances and Disease Registry) to determine if there .is any
imminent and substantial endangerment to human health and what
interim measures are necessary to be protective. If no remedial
action were to be taken at Silresim, and the plume were to
migrate to the Lowell Car Wash (or to any other utilized
groundwater well), certainly institutional controls such as well
restrictions would be maintained to ensure protection against
exposure to site contaminants.
For the reasons described above, EPA does not believe that it is
necessary to collect additional information regarding the well at
Lowell Car Wash.
Comment 3: The Massachusetts Department of Public Health
recommended that EPA pay particular attention to air emissions,
controls and monitoring while implementing remedial action at the
Site. The Department recommended EPA give careful scrutiny to
. air emissions, controls and monitoring, and potential problems
associated with any off-site transportation of hazardous waste.
The Department stressed these recommendations to ensure that
nearby residents were confident about the health and safety
procedures to be exercised during the remedial activities..
EPA Response 3: The remedial action at Silresim includes a
number of activities and processes that call for controls of air
emissions that could otherwise pose a threat to human health and
the environment. As stated in the attached Record of Decision,
air emissions controls and monitori~g will be undertaken in
compliance with all applicable or relevant and appropriate
federal and state requirements. Although the nature of the
specific emissions is not yet known, and will not be known until
the source control and management of migration systems have been
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designed and implemented, it is projected that controls can and
will reduce the contaminant concentrations to meet federal and
state specifications for the protection of human health and the
environment. A monitoring program will be designed and
implemented to ensure that all emissions standards are met and
that Site workers and the community are protected.
During the remedial design stage of the project, a health and
safety plan is implemented prior to conducting any work at the
site. All potential exposures are accounted for with planned
protective response measures. In addition to controls for air
emissions, design specifications are included for the proper
handling of all wastes to be shipped off-site for further
treatment. Furthermore, shipment of waste off Site for further
treatment will be undertaken in compliance with all federal and
state requirements. .
Again, the specifics of air emissions controls and monitoring are
addressed fully in the remedial design phase, as opposed to the
Record of Decision. All design documents and data generated as a
result of design activities are releasable to the public. During
remedial design, EPA will be more than happy to respond to public
concern regarding the remedy by discussing the specifics of any
design deliverable or data.
Comment 4: The Massachusetts Department of Environmental
Protection recommended that a risk assessment on the remaining
residual contamination be completed following completion of
remedial activities, to ensure remedial actions are protective of
human health and the environment.
EPA Resconse: EPA agrees with DEP that a risk assessment should
be performed on the remaining residual contamination following
the eompletion of remedial activities: to ensure the protection
of human health and the environment. This provision is found in
Chapter X of the ROD, in the section on Cleanup Levels.
B.
Feasibility study
Comment S: The DEP indicated that off-site disposal of
dioxin-contaminated soil was mentioned several times in the
Feasibility study. To the Department's knowledge, however, no
licensed faci~ity exists which accepts dioxin-contaminated soil.
The Department further indicated that the Record of Decision
should address this issue.
EPA Resconse: The only alternative in the Feasibility Study
which includes disposal of dioxin contaminated waste at an off-
site hazardous waste facility is Source Control Alternative 1S
(SC-1S). The difficulty of finding a licensed facility to accept
contaminated waste is noted in both the FS and ROD. The FS
states in the detailed analysis of SC-1S, that "There are
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currently no facilities in the United states that will accept
dioxin-contaminated materials, and only one company [Rollins
Environmental Services (TX), Inc.] that has submitted a permit
application to EPA for consideration." The selected remedy does
not include off-site disposal of dioxin-contaminated waste.
Comment 6: The DEP pointed out that the use of water sprays and
dust suppressant chemicals, mentioned in the Feasibility Study,
are meant to control particulate emissions, not VOC emissions.
EPA Response: DEP's comment is correct. Mechanisms to control
releases of particulate matter during excavation may include
water and chemical (e.g., calcium chloride) application to the
soils, run-off controls, specialized excavation equipment (e.g.,
caisson augers) and equipment decontamination. Mechanisms to
control the release of VOCs during excavation include the
application of vapor suppressing foams, or the erection of domes
or air-sealed "tents" over work areas. Exhaust air from the
domes or vents would be treated to remove VOCs prior to
discharge.
Comment 7: Based on DEP's review of the Feasibility study, they
noted that their Department continues to conduct. scheduled
operation and maintenance at the site (maintaining the cap fence
and sign postings). Additionally, they noted that the cap has
been seeded and does support vegetation.
EPA Response: EPA has noted in the ROD that the DEP continues to
conduct scheduled operation and maintenance at the Site,
including maintenance of the clay cap, fence and sign postings,
and that the cap does support vegetation and has been seeded with
clover.
c.
Preferred Alternative
Comment 8: The Massachusetts Department of Environmental
Protection suggested that EPA further evaluate Alternative MM-4,
which includes chemical oxidation. The Department stated that
Alternative MM-4 requires less secondary waste management and
appears to be more effective in removing ketones and methyl
chloride than the preferred alternative (MM-2).
EPA Response: EPA further considered Management of Migration
Alternative 4 which includes chemical oxidation as its primary
treatment component. EPA remains confident that Management of
Migration Alternative 2, which includes air stripping with a
heated influent, is the most appropriate alternative for
addressing groundwater contamination at the site.
Unlike with MM-4, a required component of the selected
groundwater treatment system (MM-2) is aqueous-phase carbon
adsorption to remove contaminants not removed by the air .
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stripper. The treatability study conducted during the
Feasibility study for aqueous-phase carbon adsorption assumed
ambient temperature air stripping. The selected remedy includes
heating the influent prior to air stripping which will
significantly increase the removal of ketones and other less
volatile compounds in the effluent for subsequent carbon
treatment. Therefore, carbon usage will be greatly reduced from
the 930 pounds per day maximum usage rate (less than half)
calculated pursuant to the treatability study. This carbon will
either be regenerated in place or be shipped off-site for
regeneration and re-use at the site.
Although EPA considers the level of secondary waste management
for each alternative in their evaluation of a~ternatives, there
are other criteria considered in the evaluation. The National
contingency Plan articulates nine evaluation criteria to be used
in assessing each of the remedial alternatives considered by EPA
for selection. Of the alternatives that attain ARARs, are
protective of human health and the environment, and utilize
permanent solutions and treatment technologies to the maximum
extent practicable, EPA must determine which one provides the
best balance of trade-offs in terms of the nine evaluation
criteria.
EPA has determined that Alternative MM-2 will provide the best
balance of trade-offs among the alternatives evaluated. EPA
believes that each of the components of the selected remedy are
well proven, reliable, readily available and easily implementable
at the Silresim Site. Although MM-2, MM-3 and MM-4 would be
equally effective in meeting ARARs, and are comparable in cost
(given the costs are rough estimates), and include institutional
controls to be protective of human health in the short term,
MM-3 and MM-4 are generally less proven and available
technologies.
Chemical oxidation, the primary component of MM-4, is an
innovative technology which has been proven successful for the
destruction of low levels of volatile organic compounds with
little air emissions. However, the application of the chemical
oxidation process at Si~resim may require high dosages of
chemicals (ozone or hydrogen peroxide at a potential ratio of
oxidant to contaminants from 5:1 to 10:1), flow recirculation
and/or long residence time in order to treat the high
concentration and types of compounds found at the Site. This
would significantly increase the cost of the treatment.
Decreasing the amount of ozone or hydrogen peroxide could result
in incomplete oxidation, which would create organic byproducts in
the effluent which may not meet discharge standards (total.
organic carbon). Additional treatment of the water may be
required.
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Air stripping is a physical process, whereby the parent
contaminants are transferred from the aqueous phase to the vapor
phase for further treatment. The UV/Oxidation process although
reduces the parent contaminants, may result in undefined
oxidation byproducts. These intermediate compounds have a
tendency to be more water soluble and less adsorbable by carbon,
wherease the remaining compounds in the effluent from air
stripping can be removed more readily by the aqueous carbon.
Chemical oxidation cannot easily treat compounds such as ketones
and aliphatic and saturated compounds, which do not readily
oxidize. As stated above, residence times would,be longer and/or
the groundwater would have to be recirculated through the system
which would increase energy consumption. This will also result
in an increase in the temperature of the effluent stream. Based
on the. high concentrations of contaminants found in the
groundwater at the silresim Site and assuming a water t~mperature
increase of approximately 5 degrees fahrenheit per minute
retention time in the reactor, an increase of 60-100 degrees,
fahrenheit in the effluent stream could be expected. This stream
would th~refore require further treatment prior to discharge.
Additionally, the pretreatment system for inorganic contaminants,
biological growth and naturally occurring chemicals may have to
be more extensive and effective (than for air stripping) to .
prevent scaling or deposits that precipitate on the ultra-violet
(UV) lamps. The estimated life span of the UV lamps is
approximately 3 months, but the lamps may require maintenance as
often as every few weeks. Scaling of the UV lamps appears to be
a serious obstacle to implementation of the UV/Oxidation
technology. The precipitate which forms on the lamps prevents
the transmittance of UV light to the contaminated water resulting
in variable system performance.
A summary of the comparison of each alternative's strengths and
weaknesses is found in section IX of the ROD, and EPA'srationale
for selecting MM-2 is expressed in Section XI of the ROD.
Comment 9: The Massachusetts Department of Environmental
Protection stated that its Division of Air Quality Control
requires emissions testing prior to and during the initial
excavation of the vacuum/vapor extraction system trenches so
the presence and concentration of odorous and toxic elements
be detected~
that
can
EPA ReSDonse: Emissions testing will be conducted during
excavation of the'trenches for the vacuum/vapor extraction system
to ensure protection of human health and the environment.
Comment 10: The DEP suggested that extraction wells rather than
trenches be utilized for the vacuum/vapor extraction system to
reduce the potential emissions of VOCs.
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EPA ReSDonse: In reference to the selected vacuum/vapor
extraction system for remediation of. soil contamination at the
Site, EPA agrees with DEP that the use of extraction wells (to
extract contaminants from the soil for aboveground treatment) is
preferable to trenches. However, it is expected that trenches,
in addition to extraction wells, will be necessary to meet soil
cleanup levels within a reasonable period of time. Because the
majority of soil at Silresim to be remediated consist of silts
and fine sands, trenches and extraction wells provide the most
practical and cost effective means of meeting soil cleanup levels
at the site. The final determination of the n~er, depth, and
location of the trenches and wells associated with the
vacuum/vapor extraction system will be finalized during the
remedial design phase.
Comment 11: The estimated volume of soil to be excavated and
stockpiled on-site from the vacuum/vapor extraction trenches is
approximately 1,750 cubic yards. Because of the anticipated high
levels of VOC emissions, the DEP recommended using a dome or air.
sealed tent to protect the immediate area from emissions
originating at the site. .
EPA ReSDonse: contaminated soil excavated from the trenches will
be deposited and covered with a ~lay cap on the Si1resim property
(in the northeast corner) and treated via the vacuum/vapor
extraction system. To control the release of volatile organic
compounds during excavation and stockpiling, techniques such as
the application of vapor suppressing foams, or the erection of
.domes or air-sealed "tents" over work areas will be. utilized. If
domes are used, exhaust air from the domes or vents will be
treated to remove VOCs prior to discharge.
EPA recognizes DEP's view that, based on the anticipated VOC
levels, a dome or air sealed tent is the preferable control
mechanism. However, this is a design level issue, not an issue
to be handled in the ROD. The decision of which control measures
are necessary will be made during the remedial design stage.
Comment 12: The DEP asked that the ROD provide clarification of
the handling and disposal of stabilized soil. They specifically
were looking for clarification on whether the stabilized soil
will be stored on-site, tested for leaching and then permanently
disposed of under a cap. .
EPA Response: EPA has clarified that the stabilized soil will be
disposed of on-site, following a leaching test to determine the
effectiveness of the stabilization treatment to prevent leaching
of the contaminants. . Following stabilization of the contaminated
soil, it will be disposed of in the existing capped area and
permanently covered with a RCRA cap.
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Comment 13: The vacuum/vapor extraction system is expected to
remediate soil in the upper half of the unsaturated zone, prior
to excavation, stabilization and disposal of those soils on-site
under a final cap. Given that the vacuum/vapor extraction system
is expected to operate for a total of 30 years, DEP requested
that EPA clarify where excavated soils will be stored during this
period and how maintenance of the extraction system will be
accomplishe~, given the placement of stabilized soil and a RCRA
cap over the site.
EPA ReSDonse: Once the soil in approximately the upper half of
the unsaturated zo~e meets the target cleanup levels for.
volatile organic compounds (approximately 5 years), soil which
exceeds. the target cleanup levels for the remaining indicator
substances will be stabilized and then placed on the Silresim
site for final disposal. The installation of a RCRA.cap over
the stabilized soil will occur following the completion of
stabilization. The vacuum extraction system will continue to
operate after the stabilization and cap are complete.
The operation of the vacuum/vapor extraction system under
stabilized soil is feasible and.no major difficulties. are
anticipated. It is possible that some removal of the system for
repair or replacement will be required. However, it is a
relatively simple matter to keep the stabilized soil off the top
of the trenches. Therefore, no limitations were indicated in
the ROD. Specifications of the maintenance of the vacuum/vapor
extraction system will be accounted for in the remedial design
phase of this project.
Comment 14: The DEP expressed concern about the introduction of
dense non-aqueous phase liquid (DNAPL) to bedrock and asked EPA
to require contractors to provide details in the project design
about measuring the possibility of this type of introduction.
EPA ReSDonse: Selected deep overburden and shallow bedrock
extraction wells will be located within the zone of suspected
DNAPL contamination. siting extraction wells in this zone will
provide dewatering to facilitate soil vapor extraction, enhance
containment of dissolved phase contamination, and enhance mass
'removal rates. EPA believes the benefits of siting extraction
wells in this zone outweigh the potential risk of mobilizing'
DNAPL to greater depths during well drilling. Special
precautions will be taken during the rock well installations to
minimize the potential for introducing additional DNAPL to the
bedrock. The specific number and locations of extraction wells
targeting DNAPL contamination will be finalized during the
remedial design phase. This has been noted in the ROD..
Comment 15: The DEP indicated that National Pollution Discharge
Elimination System (NPDES) permits are written based on water
quality based limits, which can be more stringent than Maximum
18
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Contaminant Levels (MCLs, the selected cleanup levels for
groundwater treatment). The DEP urged EPA to consult the Quality
criteria for Water (1986, as amended).
EPA ResDonse: The state water quality limits associated with
NPDES permits are currently more stringent than MCLs primarily
for metals. The selected remedy includes metals
precipitation/filtration. If River Meadow Brook is selected as
the discharge location, the groundwater treatment system is
expected to reduce the concentrations of metals below water
quality based NPDES limits. However, pilot testing of the
groundwater treatment system will be necessary to insure .that the
NPDES limits will be met.
D. .
ARARs
Comment 16: During the public comment period the Massachusetts
Department of Environmental Protection submitted a list of state
ARARS to supplement those identified in the Feasibility study.
In a follow-up letter to EPA, DEP further refined their list of
ARARs. The Department indicated that the lists were not
comprehensive, but that it would be useful to EPA in evaluating
the "state Acceptance" criterion required in the National
Contingency Plan (NCP). The ARARs include Chapter
21E/Massachusetts Contingency Plan (MCP). Chapter 21E of the
Massachusetts General Law establishes the MCP as an independent
enforcement authority, which is not subject to the waiver
provisions of CERCLA (Superfund Act) Section 121(d) (4). This
provides for potentially more stringent standards than those set
forth in the National Contingency Plan, and is considered by DEP
to be applicable to the Silresim site.
EPA ReSDonse: EPA considered DEP's identification of State
ARARs potentially suitable to the Silresim Site, and have
included each of the ARARs identified in their refined list in
the ROD (listed in Appendix C of this ROD), with tQe exception
of Chapter 21E/Massachusetts Contingency Plan (MCP).
Chapter 21E and the MCP are state analogues to CERCLA and the
National Contingency Plan, respectively. CERCLA specifically
. authorizes the President to carry out response actions and
requires the promulgation of a National Contingency Plan for.
selection of response actions, to which the President must
adhere. (42 U.S.C Sections 9604(a), 9605, 9607(a) (4) (A).)
Congress established a federal program that sets nationwide
priorities for site cleanups and consistent national rules for
selection of cleanup actions. The states may promulgate legally
enforceable environmental standards (i.e., ARARs) which federal
cleanups must meet. The states may enact and exercise their own
statutory authorities to conduct cleanups using their own
preferred risk assessment methodologies and contingency plans.
The states may not, however, impose those contingency plans on
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the President and EPA.
requirements of CERCLA.
Neither Chapter 21E nor the MCP is a legally enforceable
environmental standard that would qualify as an ARAR. Chapter
21E authorizes DEP to undertake response actions in much. the
same way that CERCLA authorizes the President to do so. The
only articulated standard for cleanup actions is "a level of
control... such that no... substance of concern will present a
significant or otherwise unacceptable risk of damage to health,
safety, public welfare, or the environment." M.G.L. c. 21E
Section 3A. This states a general goal, but it falls short of
the specificity required to be a "promulgated standard,
requirement, criteria, or limitation." 42 U.S.C. Section
9621(d) (2) (A) (ii). "General goals that merely express
legislative intent about desired outcomes or conditions but are
non-binding are not ARARs," nor could they be absent some
objective standard to define whether they are met. 55 Federal
Register 8746.
To do so would be contrary to the
The "no... significant or otherwise unacceptable risk" language
of Chapter 21E, analogous to the "protective of human health and
the environment" language of CERCLA, is a guiding principle to
be given site-specific content by reference to other binding
statutory or regulatory requirements, rather than itself being
an ARAR. Indeed, this cleanup goal is so general that even if
"no... significant or otherwise unacceptable risk" could be
considered a 'standard, Chapter 2lE would still not be an ARAR
because there is no way to determine whether it is "more
stringent than" the comparable federal standard of Itprotective"
remedies. .42 U.S.C. section 9621(d) (2) (A) (ii).
The Massachusetts contingency Plan (MCP), DEP's regulation that
guides implementation of the Chapter 21E authority, also fails
to meet CERCLA's definition of ARARs. The MCP, like its federal
analogue, contains no specific "standard, requirement, criteria,
or limitation," but instead prescribes a process for remedial
decision making. DEP must follow the MCP's procedure for
assessing risk, but the MCP leaves selection of the Ultimate
cleanup level and remedial strategy to DEP's discretion. See,
~, 310'C.M.R. section 40.543(3)(g)3.a (use of excess lifetime
cancer risk. as "guideline" for remedial decisions). Thus the
MCP itself does not provide objective, enforceable standards
that could serve as ARARs and mandate specified cleanup levels.
To consider the MCP an ARAR would produce an anomalous results.
Were that the case, EPA would have to disregard its own properly
promulgated procedures in favor of the Commonwealth's, and defer
to the Commonwealth's discretionary judgment of what risks were
"acceptable" at a particular site. Such a result would
contravene Congressional intent, as evidenced by the precise
elaboration of state ARARs and the President's authority to
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promulgate the National Contingency Plan, 42 U.S.C. Sections
9621(d) (2) (A), 9605, and would frustrate CERCLA's paramount goal
of expeditious and efficacious site cleanups. See NCP preamble,
55 Federal Register at 8689 ("Requiring the Superfund program to
comply with both the administrative requirements of CERCLA and
the administrative or other non-substantive requirements of
other laws would be unnecessary, duplicative and would delay
Superfund activities.") Therefore, the MCP, 310 CMR 40.00, is
not considered an ARAR at this Site.
Comment 17: The DEP stated that they support EPA's proposal to
waive the bottom liner specifications of the Federal Toxic
Substance and Control Act (TSCA) disposal requirements for
polychlorinated biphenyls (PCBs), recognizing that the remedial
actions proposed would be protective of human health and the
env ironment from exposures to PCBs.' . .
EPA ResDonse: In addition to the liner specification of the TSCA
PCB disposal requirements, EPA has determined that two additional
provisions are not necessary to be protective of human health and
the environment from exposures to PCBs. The PCB Disposal
Requirements promulgated under TSCA are applicable to the remedy
because the selected remedy involves storage and disposal of
soils contaminated with PCBs in excess of ~O ppm. Under ~he
Disposal Requirements, soils and sediments contaminated with PCBs
may be disposed of in an incinerator meeting the standards of 40
CFR Section 761.69 or a landfill meeting the requirements of 40
CFR Section 761.75. Under the provisions of 40 CFR Section
761.75(c) (4), the EPA Regional Administrator may waive one or
more of the specified landfill requirements upon finding that the
requirement is not necessary to protect against an unreasonable
risk of injury to health or the environment from PCBs.
In the case of the Silresim Site, placement of soils with PCBs,
which have been stabilized, under a RCRA cap, will provide a
permanent and protective remedy that satisfies the requirements
of the Part 761 landfill regulations. Long-term monitoring of
groundwater wells will also be instituted, as required by the
chemical waste landfill regulations.
The Regional Administrator is exercisinq the waiver authority
contained within the TSCA regulations at 40 CFR Section
761.75(c) (4) and is waiving certain requirements of the chemical
waste landfill regulations. The provisions to be waived require
construction of chemical waste landfills in certain low permeable
clay conditions [Section 761.75(b) (1)], the use of a synthetic
membrane liner [Section 761.75(b)(1)], and that the bottom of the
landfill be 50 feet above the historic high water table [Section
761. 75 (b) (3)].
The Regional Administrator hereby determines that, for the
following reasons, the requirements of 40 CFR Sections
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761.75(b) (1), and (3) are not necessary to protect against an
unreasonable risk of injury to health or the environment from
PCBs in this case. Among the primary reasons that the waived
specifications are not necessary is the low frequency of
detection and concentrations of PCBs detected in Site soils.
PCBs are not the primary threat at this Site. Although there
were a limited number of samples analyzed with PCBs over 50 ppm,
the majority had concentrations below 1 ppm and at non-detectable
levels. In contrast, the landfill requirements that are waived
are designed to protect against the risk from disposal of PCBs at
levels no lower than 50 ppm. The specifications regarding
liners, soil conditions and depth to groundwater were designed to
protect against the risks that high levels of PCBs will migrate
into groundwater or be released to air or surface water.
Low permeability clay conditions, a synthetic membrane liner for
the underlying substrate, and 50 foot soil barrier to the water
table are unnecessary requirements at this Site to prevent
migration of PCBs. The soil will be stabilized and disposed of
on site in excavated areas within the upper portion of 'the
unsaturated zone. Disposal of stabilized and capped waste in
this zone will minimize the hydraulic connection between the
treated soils and groundwater and subsequent migration of PCBs in
groundwater. Furthermore, given the low mobility of PCBs in
stabilized soils, migration of PCBs to groundwater would be
minimal.
E.
General Comments
Comment 18: The DEP suggested that EPA redefine the Site. The
Department indicated that under the Massachusetts Contingency
Plan (MCP), the term "on-site" is interpreted to include the
areal extent of the contamination and all related areas in close
proximity to the contamination necessary for the implementation
of the remedy.
EPA Response: EPA agrees with the DEP's definition of the
Silresim site. In conformance with the definition. of "On-site"
in the National Contingency Plan (NCP), the Silresim Site (the
"Site") is defined by the areal extent of contamination and all
suitable areas in very close proximity to the contamination
necessary for implementation of the response action. This is
stated in Section I, page 1, of the Record of Decision.
Comment 19: The DEP indicated that the definition of
"halogenated" in the glossary of th~ Proposed Plan is erroneous.
EPA Response: The correct definition of a "halogenated
hydrocarbon" is "one of a group of halogen derivatives of organic
hydrogen and carbon-containing compounds; the group includes
monohalogen compounds and polyhalogen compounds that contain the
same or different halogen atoms." "Halogenation" is a chemical
22
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process or reaction in
a substance, generally
these definitions came
Chemical Terms.
which a halogen element is introduced into
by the use of the element itself. Both of
from the McGraw-Hill Dictionarv of .
Part III -
Potentially Responsible parties (PRPs)
One set of written comments were received from a group of
Silresim PRPs, known as the Silresim Site Generators Committee
(the "Committee").
In brief, the main comments of the Committee were: (1) EPA
identification of federal and state drinking water standards
(MCLs) are inappropriate cleanup levels for the site; (2) EPA
failed to consider EPA's March 25, 1991 Risk Assessment guidance
which ~ould have resulted in less stringent cleanup goals for
soil; (3) EPA's selected compliance point for meeting MCLs (edge
of RCRA cap) is unnecessary and should have alternately been
identified as River Meadow Brook; (4) meeting MCLs at the Site
is technically infeasible within a reasonable time period; (5)
use of average background levels as soil cleanup levels for some
indicator compounds is inappropriate; (6) cleanup levels should
be based on River Meadow Brook as the groundwater receptor
location, and not the edge of the RCRA cap; (7) the selected
remedy should be flexible.
Comment 1: It is inappropriate to base groundwater and soil
cleanup goals on Maximum Contaminant Levels (MCLs), which are
drinking water standards established under state and federal
drinking water laws. The Committee stated that these goals are
flawed because the site is located in an industrial area, the
groundwater is not currently used as a drinking water source,
there are no private wells being utilized in the area, the
suspected well yields are low, and the existence of DNAPL will
prevent the attainment of these goals. The Committee cited the
ROD for the Sullivans Ledge site where DNAPL was recognized as a
limiting factor to attaining MCLs. Additionally, the Committee
stated that Massachusetts regulations limit use of the site for a
water well because of the proximity of other sources of
contamination.
EPA Response: EPA disagrees that the selection of Maximwn
contaminant Levels (MCLs), which are drinking water standards
established under state and federal drinking water laws, is
inappropriate for the silresia site. The aquifer at the Site is
classified as a Class IIB aquifer under the Federal Groundwater
Protection strategy and Class I by the Commonwealth of
Massachusetts. These classificatio~s mean that the groundwater
is potentially a source of drinking water and other beneficial
uses. At sites where groundwater is or may be used for drinking
water, MCLs set under the Safe Drinking Water Act or more
stringent promulgated state standards are generally applicable or
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relevant and appropriate standards (ARARs).
It is within EPA's authority to determine ARARs at the site and
to determine cleanup levels necessary to attain those ARARs.
with respect to achieving drinking water standards in the
aquifer, the NCP, in 40 CFR Part 300, provides that it is the
policy of EPA's Superfund program to use EPA's Groundwater
Protection strategy as quidance in determining the appropriate
remediation for contaminated groundwater at CERCLA site. The
aquifer at silresim is a valuable resource both under EPA's
-Guidelines for Groundwater Classification and under the state
classification for groundwater. Although the groundwater
presently is not being utilized as a drinking water source and is
not suitable for direct human consumption without treatment due
to chemical contaminants or land use impacts, the goal of the
state and federal governments is to restore potential sources of
drinking water to drinking water quality and for other beneficial
uses.
EPA recognizes that the area in the immediate vicinity of the
Silresim site is industrial (industries which could be adversely
affecting the groundwater) and that the availability of a public
water supply generally averts the aquifer from use as a drinking
water supply. However, the edge of the Silresim contaminated
plume is currently at the closest residential neighborhood and
is continuing to migrate further away from the original Site.
Despite the suspected low water yield in the site area due to the
local geology, private water wells (abandoned due to the current
affordable public water supply) were once utilized in this
neighborhood. It is not infeasible or inconceivable that private
wells could, once again, be installed within the Silresim plume
in the future for the purpose of drinking water or other uses.
The PRPs have stated that "...Massachusetts requlations preclude
use of the site for a water well because of the proximity of
other sources of contamination." This statement is correct only
insofar as a permit for a public water supply is concerned. A
public water supply well would not be permitted, however, there
are no restrictions on private use of the aquifer (especially for
'industrial or non-potable use). Only the local Board of Health
would have jurisdiction on private supply for individual homes~
EPA has determined that the risk of drinking groundwater from the
Silresim contaminated plume, either now or in the future, poses
an unacceptable risk and supports remediation of the aquifer to
drinking water standards.
EPA recognizes the potential difficulties associated with meeting
drinking water standards at the site due to the existence of high
concentrations of contaminants and dense non-aqueous phase liquid
in the overburden and fractured bedrock, and the suspected low
groundwater extraction rates due to low permeability of aquifer
materials. However, the uncertainties associated with the degree
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of effectiveness that the selected soil and groundwate~-treatment
systems will afford prevent EPA from concluding that ARARs or an
alternate set of stringent and protective standards is infeasible
at this Site. -..
--:.:- '0.. -
--_'l"
;;;:-~,.1.,:~1:,:,,: .
,,~".'.~' .J.;.~.,:,.. . ".
The PRPs have requested that less stringent cleanup levels be
selected based on exposure pathways more realistic than drinking
water. Although the goal of this remedial action is to restore
the groundwater to its beneficial uses which are federal and
state drinking water standards (MCLs), and EPA and the
Commonwealth of Massachusetts currently believe that the selected
remedy could potentially achieve this goal, EPA recognizes the
PRPs concerns and the current studies that suggest that it may
not be possible to achieve these standards throughout the area of
attainment within a reasonable period of time' for the reasons
stated above. The practicality of achieving cleanup,levels
throughout the site cannot be determined until the extraction
system has been implemented and plume response monitored over
time. .
EPA has stated in the ROD that if the selected remedy cannot ~eet
the cleanup levels (i.e. MCLs) following a reasonable period of
system operation, contingency measures and goals may be , '
considered for replacement. These measures and goals would be
considered if they are protective of human health and the
environment, but are technically practicable under the
corresponding circumstances.
For alternate contingency measures and goals to be considered by
EPA, the following condition would need to be satisfied:
contaminant levels have ceased to decline over time, and are
remaining constant at some statistically significant levels above
health-based goals in portions of the aquifer outside of the
compliance points. If it is determined on the basis of the
. preceding criteria and the system performance data that portions
of the aquifer cannot be restored to their beneficial use, any or
all of the following contingency measures will occur as a
modification of the existing system: (a) institutional controls
will be maintained to prevent access to groundwater that
maintains above health-based levels; (b) ARARs will be waived for
those portions of the aquifer based on the technical
impracticability of achieving further contaminant reduction; (c)
continued pumping will be required as a long-term gradient
control or containment measure.
The decision to invoke any or all of these measures may be made
by EPA during a future periodic review, following a reasonable
period of operation of the selected remedy. The remedial'
decision referenced in the Committee's comments for the Sullivans
Ledge site in New Bedford, Massachusetts, and the decision for
the silresim site were based upon individual site circumstances
and factors. While the_circumstances at the Sullivans Ledge Site
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may be similar to those at the Silresim Site, there are
differences that warrant individual consideration (i.e, whether
MCLs are ARARs). EPA's remedy selection process does not require
an evaluation of how other CERCLA sites have met the statutory
requirements and compare to the site at issue.
Comment 2: EPA failed to consider the Agency's March 25, 1991
Risk Assessment guidance. The Committee stated that under this
revised guidance document, cleanup levels for volatile organic
compounds (VOCs) and phenol would be less stringent than those
reported in the Proposed Plan. The Committee further suggested
that this guidance and the preamble to the National Contingency
Plan (NCP) both support the conclusion that the Site should be
classified as commercial/industrial. This classification would
result in less stringent cleanup levels proposed by EPA.
Additionally, they recommended using action levels identified for
soil under EPA's RCRA corrective action program.
EPA Response: With respect to the March 25, 1991 EPA guidance,
officially entitled, Risk Assessment Guidance for Superfund.
Volume I: Human Health Evaluation Manual Supplemental Guidance
"Standard Default Exposure Factors" Interim Final, and its
relevance to the derivation of cleanup levels for soils, there
are some key points to consider. First, as the guidance
indicates, "the exposure factors presented in this document are
generally considered most appropriate and should be used in
baseline risk assessments unless alternate or site-specific
values can be clearly justified by supporting data". Guidance on
calculating risk-based cleanup levels is still in the
developmental phase. The relevance of the March 25, 1991
guidance to the derivation of risk based cleanup levels, if any,
has not officially been made.
Secondly, even if the above mentioned guidance is eventually
endorsed by EPA in the derivation of cleanup levels (it is an
interim guidance), Region I policy is to adopt the new exposure
parameters outlined in the March 25 guidance only if it is deemed
appropriate. within Region I, these exposure assumptions were to
be considered for all baseline risk assessments initiated after
March of 1991. The baseline risk assessment for Silresim was
completed in March of 1990. EPA determined that it was neither
appropriate nor necessary to generate another revision of the'
baseline risk assessment to accommodate this guidance.
similarly, the development of cleanup levels in the Feasibility
Study occurred primarily during 1990, again, before the issuance
of this guidance. In order to avoid any further delays to this
project, EPA has committed to the use of exposure assumptions
used in the baseline risk assessment and in drafts of the
Feasibility Study. . The Risk Assessment and cleanup levels
developed for this site have been reviewed by EPA and are
believed to be appropriate. '
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Regarding the claim that surficial soil cleanup levels derived
using the March 25, 1991 guidance would be less stringent for
VOCs and phenols than those ultimately selected, EPA is unable to
substantiate this claim. In fact, EPA believes that use of the
March 25, ,1991 guidance would have led to more stringent soil'
cleanup levels for every compound. For example, the key
assumptions used in the Feasibility study and March 25, 1991
guidance are as follows:
Feasibili~v studY 03/25/91 Guidance
Frequency of Exposure - 60 days per year 350 days per year
Duration of Exposure - 70 years 30 years
Net - 4.200 days 10.500 days
Because of the greater exposure under the new guidance, any
cleanup level derived using these factors in soils would be ~ '
conservative than those selected at this site. .
with regard to the committee's belief that the site should be
classified as commercial/industrial for exposure assessments
utilized for establishing cleanup levels at the Site, consistent
with the March 25, 1991 guidance 'and preamble to the NCP, EPA has
assumed that land use for the Silresim property is
commercial/industrial. However, EPA has also assumed that the
land immediately adjacent to the site is "residential" because
there are known exposure pathways to neighboring residents.
The March 25, 1991 guidance. states that "residential exposure
scenarios and assumptions should be used whenever there are or
may be occupied residences on or adiacent to the site. Because
the exposure parameters corresponding to a residential exposure
scenario generally result in a higher potential exposure than a
commercial/industrial scenario, the residential exposure
parameters were used to develop cleanup levels.
The Feasibility Study (Appendix B, Table B-3) includes the
assumptions that were used in deriving risks and cleanup levels
for direct contact and ingestion of soil at the site. The age
attributed to the receptor population is 5-70 years, to reflect a
realistic trespassing scenario by a neighboring resident (the 1-5
year old population which is known to have the greatest soil
ingestion rate was excluded). Where a "resident" is identified
in the FS as the exposed population (Table B-3 and elsewhere in
the FS) this resident is considered by EPA to be a "neighboring"
resident to the Silresim site. EPA believes that surficial soil
cleanup levels, based on direct contact and ingestion of soils,
have been derived consistent with land use considerations put
forth in the NCP and the March 25, 1991 guidance and reflective
of actual exposure pathways.
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Lastly, with respect to the use of RCRA corrective action levels
for soils, per the July 27,1990 Federal Register, these values
1) represent only proposed levels and are not promulgated
standards, 2) are not based on site-specific assumptions and do
not reflect the risks posed by contaminants at Silresim, and 3)
were not initially intended to be consistent with CERCLA (Subpart
S is currently being developed to be consistent with CERCLA).
Comment 3: Designation of the edge of the RCRA cap (roughly
approximated by the Silresim property boundary) as the point of
compliance for meeting groundwater cleanup levels is unnecessary
because of the unlikelihood that groundwater at the Site will be
utilized as a drinking water supply (as contended in comment #
1). The Committee believes that River Meadow Brook is the most
appropriate and reasonable compliance point for meeting
groundwater cleanup levels, and as an input parameter to the
leaching model used for developing unsaturated soil cleanup
levels (attached to their comments was a list of recommended
cleanup values for both media). The Committee believes that
exposures related to basement seepage of contaminated groundwater
can be mitigated by utilizing source control measures.
EPA ResDonse: As discussed by EPA under R~sponse 1, Part III,
above, the aquifer at the Site is classified as a Class IIa
aquifer under the Federal Groundwater Protection Strategy and
Class I by the Commonwealth of Massachusetts and is therefore a
potential source of drinking water and other beneficial uses. At
sites where groundwater is or may be used for drinking water,
MCLs set under the Safe Drinking Water Act or more stringent
promulgated State standards are generally applicable or relevant
and appropriate standards (ARARs). Although the groundwater
presently is not being utilized as a drinking water source, the
goal of the state and federal governments is to restore potential
sources of drinking water to drinking water quality.
The PRPs have requested that less stringent cleanup levels be
selected based on exposure pathways more realistic than drinking
water. The Risk Assessment detailed in the Remedial
Investigation clearly supports the need for stringent cleanup
levels and" an aggressive remedy to be protective of all exposures
posed by the contaminated groundwater. EPA has determined that
River Meadow Brook is not an appropriate point of compliance for
meeting groundwater cleanup levels and as an input parameter to
the leaching model used for developing unsaturated soil cleanup
levels, because it is not protective of human health and the
environment and does not meet Applicable or Relevant and
Appropriate Requirements (ARARs) identified for this Site.
The current and future potential exposures which exceed EPA's
acceptable risk range of 10-4 and 10-6 include ingestion of
contaminated groundwater if used as a drinking water source, "
inhalation of vapors inside residential and industrial basements
-------
due to groundwater seepage, and direct contact and dermal
absorption of surface waters of East Pond. The point of
compliance identified in the Feasibility study as River Meadow
Brook represents a broad perimeter that extends beyond the
current and future potential exposures of concern. These
exposures are inside this point of compliance, suggested for use
by the Committee. The cleanup levels proposed by the Committee,
based on this compliance point, are not considered protective of
the exposure risks identified above. The source control portion
of the remedy alone would not "handle" these exposures as
contended by the Committee.
EPA has determined that cleanup levels will be met and based upon
the edge of the RCRA cap to insure adequate protection of human
healtb and the environment and to meet ARARs. The final RCRA cap
will limit this area from its potential future uses -(i.e.,
drinking water supply). The cleanup levels recommended by the
Committee will not be utilized.
Comment 4: The technical feasibility of achieving designated
groundwater cleanup goals within a reasonable period of time is
uncertain due to the presence of- DNAPL, high concentrations of
dissolved contaminants, and the low permeability of soils at the
Site. The Committee believes that many of the cleanup goals will
not be reached within 100 years. Referencing the NCP and
decisions made at the Nyanza Superfund Site in AShland,
Massachusetts and the Sullivan's Ledge Superfund site in New
Bedford, Massachusetts, the Committee believes either MCLs should
be waived and the remedy should essentially operate as a
containment system or the remedy should be considered interim.
The Committee believes that a containment system will be
protective of human health and the environment and reduce costs.
EPA Response: As stated above under Comment 1, Part III, EPA
recognizes the potential difficulties associated with meeting
drinking water standards at the Site due to high dissolved
contaminant concentrations and DNAPL in the aquifer and
low groundwater extraction rates resulting from low permeable
aquifer materials. However, the uncertainties associated with
-the degree of effectiveness which the selected remedy will afford
prevent EPA from concluding that it is infeasible to meet --
groundwater ARARs within a period of time considered reasonable
for this Site.
The Committee does not believe that all of the cleanup levels can
be reached within a 100 year time frame. This is an
unsubstantiated estimate. There is currently no reliable
estimate for the period of time necessary to meet the established
cleanup objectives.. EPA believes that the infeasibility of
achieving cleanup levels throughout the Site cannot and should
not be determined until the remedy has been implemented and plume
response monitored over time. The Risk Assessment, detailed in
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the Remedial Investigation clearly supports the need for
stringent cleanup levels and an aggressive remedy in order to be
protective of all exposures posed by the contaminated
groundwater. EPA believes that selection of a remedy for the
purpose of plume containment would not facilitate the design and
implementation of an aggressive groundwater treatment
alternative, and may not be adequately protective of human health
and the environment.
Although the goal of this remedial action is to restore the
groundwater'to its beneficial uses, which are federal and state
drinking water standards (MCLs), EPA does recognize the
Committee's concerns and the current studies that suggest that it
may not be possible to achieve these standards throughout the
area of attainment within a reasonable period of time for the
reasons stated above. Subsequently, EPA has stated in the ROD
that if the selected remedy cannot meet the selected 'cleanup
levels following a reasonable period of system operation, ,
contingency measures and goals may be considered for replacement.
These measures and goals would be considered if they are still
protective of human health and the environment, but are
technically practicable under the corresponding circumstances.
As stated previously in EPA's response to ~omment 1, Part III,
the remedial decision made at each Superfund Site is based on an
individual set of circumstances and factors. The decisions made
at the sites referenced in the Committee's comments, specifically
the Nyanza site in Ashland, Massachusetts, and the Sullivan's
Ledge Site in New Bedford, Massachusetts, are immaterial to the
decision made at the silresim site. While the circumstances at
the Nyanza site and Sullivans Ledge Site may be similar to those
at the Silresim Site, there are differences that warrant
individual consideration. EPA's remedy selection process does
not require an evaluation of how other CERCLA sites have met the
statutory requirements and compare to the site at issue.
Unlike the Nyanza site and the Sullivan's Ledge Site, EPA does
not believe that the criteria necessary to waive groundwater
ARARs have been satisfied at the Silresim site. Therefore, at
periodic intervals during implementation of the selecte~ remedy,
EPA will review the treatment system for its effectiveness and
feasibility in meeting the cleanup objectives. Following ~
reasonable period of system operation, EPA may deter imine that
alternative cleanup levels are warranted for this Site.
Comment 5: The Committee believes that it is innapropriate to
set cleanup levels for such compounds as arsenic, mercury and
polycyclic aromatic hydrocarbons (PAHs) at the average background
concentrations detected in the Site area. The Committee does not
believe that these constituents are ,related to Silresim
operations and that establishment of such cleanup levels is
contrary to the provisions of the Superfund law. Therefore, at a
-------
minimum, the upperbound background values should be selected to
avoid remediation of soil not contaminated by Silresim.
EPA ResDonse: EPA does not believe that the available data
regarding arsenic, mercury and polycyclic aromatic hydrocarbons
(PAHs) detected at the site (both on and off the Silresim
property) substantiate the Committee's claim that these compounds
are unrelated to previous hazardous waste activities at Silresim.
The Silresim Chemical Corporation accepted a wide range of mixed
hazardous waste. The hazardous constituents found on the.
Silresim property and in adjacent runoff areas are considered by
EPA to be Silresim-related contaminants. .
Soil samples were collected in the Silresim area, specifically to
characterize local background values for various metals and PAHs
suspected of being elevated due to the urban environment. Levels
of these metals and PAHs in various locations around the Site
were found to be elevated. However, EPA does not believe that
this information precludes the detection of these compounds on
the Silresim site from being related to Silresim hazardous waste
activities. However, EPA believes that because Silresim cannot
be strictly implicated as the only source of these constituents,
it is acceptable to consider local background concentrations in
the determination of cleanup levels for Site remediation.
Two sets of background values for various indicator compounds are
presented in the Feasibility study, including actual sampling
data from the site and a range of values reported iri literature
for soils in the eastern united States. EPA believes that, where
the use of background values is warranted for consideration in
determining, soil cleanup levels, Site-specific local values are
preferable to literature-based regional values. EPA selected
the average concentrations of background soil data for the Site
as the cleanup levels for arsenic, mercury, selenium, phenol and
PAHs in surficial soils.
Of the five indicator substances listed above, EPA has determined
that soil cleanup levels for mercury, phenol and selenium are
unnecessary. EPA has also determined that the soil cleanup,
levels for, chromium and copper are unnecessary. Based on further
review and consideration of the data presented in the RIfFS, it
was determined that the exposure pathways for each of these
compounds did not exceed EPA's acceptable risk level. Chromium,
copper, mercury, phenol and selenium are non-carcinogenic
compounds. The non-carcinogenic risks posed by each of these
compounds, under each exposure pathway considered, fell below a
hazard quotient of one. Therefore, EPA has omitted chromium,
copper, mercury, phenol and selenium from'the list of cleanup
levels to be met in surficial soils at the site.
Unlike the compounds listed above, the risk associated with
direct co~tact and ingestion of PAHs and arsenic in soil do
-------
exceed EPA's acceptable risk range, essentially because they are
carcinogens (cPAHs). The health-based risk levels derived in the
FS for cPAHs and arsenic are 0.31 mg/kg and 2.9 mg/kg (parts per
million), respectively. The average background values for cPAHs
and arsenic are 11 mg/kg and 21 mg/kg, respectively. EPA
believes that the average local background values selected for
arsenic and cPAHs will be adequately protective of human health
and the environment and is therefore an acceptable alternative
cleanup level. EPA does not agree that the upper bound
background values detected outside the Site for PAHs and arsenic
are appropriate or protective standards.
Comment 6: The Committee referred EPA to an earlier draft of a
discrete segment of the Feasibility Study, known as the
Development of Alternatives or FS-2. This report contains a list
of groundwater and soil cleanup levels that were based on River
Meadow Brook as the point of compliance. These levels are less
stringent than those selected by EPA, which are based on the edge
of the RCRA as the compliance point. The Committee believes that
River Meadow Brook is the appropriate point of compliance for
meeting groundwater cleanup levels and for use in determining
unsaturated soil cleanup levels. Attached to the Committee's'
comments is a list of refined cleanup levels for. soil and'
groundwater based on River Meadow Brook as the compliance point.
The Committee has requested that EPA adopt these alternate
cleanup levels.
EPA ReSDonse: Please refer to EPA's response to Comments 1 and
3, Part III, above. For the reasons provided above in the
previous responses, EPA has determined that River Meadow Brook is
not the appropriate point of compliance for meeting groundwater
cleanup levels and as an input parameter to the leaching model
used for developing unsaturated soil cleanup levels. EPA has
.determined that groundwater cleanup goals will be met at the edge
of the RCRA cap to ensure adequate protection of human health and
the environment and to meet applicable and relevant and
appropriate requirements for this Site. Therefore, the cleanup
levels recommended by the Committee will not be utilized.
Comment 7: The Committee requested that EPA provide for
flexibility in its cleanup plan so .that innovative and
cooperative water and energy saving measures could be adopted
during the remedial phase. The Committee specifically noted the
utilization of a cogeneration plant being developed adjacent to
the Site for use in the selected groundwater extraction and
treatment system.
EPA ReSDonse: The Record of Decision is fairly specific in terms
of the selected treatment components to be utilized and the
potential discharge locations for treated groundwater. The
Feasibility Study 'evaluated three potential locations for the
discharge of treated groundwater. EPA has determined based on
32
-------
the evaluation provided in the FS that the discharge location
will be either to the Duck Island Sewage Treatment facility
(POTW) or to River Meadow Brook. This decision will be made
during the remedial design phase of the project. The groundwater.
treatment system calls for air stripping of a heated influent.
The most appropriate .means of heating the influent will also be
decided upon during the remedial design phase.
33
-------
ATTACBHBRT A
CHRONOLOGY OP COKKUHITY RELATIONS ACTIVITIBS AT TBB SILRBSIK SITE
-- 1982-83
-- 1983-1984
-- 3/30/83
-- 5/26/83
-- 6/7/83
-- 6/28/83
-- 8/8/83
-- 11/17/83
-- 1/18/84
-- 3/15/85
-- 6/6/85
-- 9/85
-- 10/16/85
-- 5/6/86
-- 7/9/86
the Silresim site was placed on the National
Priorities List (NPL)
EPA and DEP operate an information hotline and
participate in regular meetings of the Silresim
Task Force
EPA announces that industrial facilities are
emmitting unacceptable levels of VOCs in the
vicinity of the Silresim site
EPA announces construction of a fence around the
Site
EPA announces a cost-share agreement with the
Commonwealth of Massachuesetts to perform
interim remedies and conduct studies at the Site
EPA holds an informational public meeting to
present operating plans for removal of buildings
and construction of a cap at the Site
I
EPA announces start of work on removing buildings
EPA announces start of work on temporary clay cap
EPA holds public meeting to provide an update on
schedule for cap construction
EPA announces public comment period on Remedial
Investigation work plans
EPA announces agreement with the Silresim Trust to
perform the Remedial Investigation and Feasibility
Study (RI/FS) at the Site
EPA announces availability of the Site Community
Relations Plan .
EPA holds public meeting on plans for site studies
EPA holds public meeting on progess and plans of
Site studies
EPA holds public meeting on progess and plans of
site studies
-------
-- 10/14/86
-- 12/12/86
-- 12/21/87
-- 5/88
-- 10/88
-- 11/88
-- 5/3/89
-- 6/22/89
-- 9/27/89
-- 3/27/90
-- 4/90
-- 4/26/90
-- 11/7/90
-- 6/91
-- 6/91
-- 6/19/91
-- 6/20/91
--'7/10/91
EPA announces additional field studies (Phase II)
EPA announces presence of trace levels of dioxin
in soils just outside Site fence
EPA confirms presence of low levels of dioxin at
Site
EPA announces that Ayer City Homeowners
Association has issued a Letter of Intent to apply
for a Technical Assistance Grant (TAG) at the site
EPA issues a fact sheet provi~ing updates on site
activities
DEP receives a petition requesting that DEP
designate Silresim a "Public Priority Site"
DEP designa~es Silresim as a Public Involvement
Plan (PIP) Site
EPA announces that the TAG grant is still
available
EPA announces availability of the Administrative
Record
EPA announces 2 administrative agreements with
over 200 parties for $3.4 million
EPA issues a fact sheet on the Superfund program
EPA holds public meeting on results of the
Remedial Investigation studies.at the site
EPA announces additional soil and ground water
sampling at the Site
DEP and EPA issue a joint Public Involvement
Plan/Community Relations Plan for the Site
EPA issues a fact sheet on the Site Proposed Plan
EPA holds public meeting to explain cleanup
alternatives, including EPA's preferred
alternative
Public comment period on the Proposed Plan and
other documents begins
EPA holds informal public hearing to accept oral
-------
ATrArnMENT B
TRANSCRIPT
- United States
Environmental' Protection Agency
Public Hearing
. Silresim Superfund Site
Proposed Remedial Action Plan
Smith Baker Center
Lowell, Massachusetts
July 10, 1991
-------
UNITED STATES OF AMERICA
ENVIRONMENTAL PROTECTION AGENCY
------------------------
IN THE MATTER OF:
PROPOSED PLAN
SILRESIM SUPERFUND SITE:
LOWELL, MASSACHUSETTS
------------------------
BEFORE:
Margaret Leshen,
Leslie McVickar,
Project Manager
Section Chief
Remedial
Smith Baker Center
400 Merrimack Street
Lowell, Massachusetts
wednesday, July 10, 1991
7:15 p.m.
M.A.
TOROSIAN & ASSOCIATES,
-------
2
1
PRO C E E DIN G
2
MS.
LESHEN:
Good evening and
3
welcome.
This
is the
Silresim
4
Superfund Site public
hearing and I'm
5
Margaret Leshen,
the Section Chief of
6
the Superfund Section at the EPA.
I'm
7
here to chair
this
session
and I want
8
to welcome everyone.
9
Before we get
started,
I'm
10
going to explain exactly how this
11
evening i.s going
to be. run.
It
is an
12
informal public hearing and as such we
13
do have
these microphones around the
14
room so
that our
court transcriber can
15
record what is
happening
this
eve.~-~~g .
16
If you
intend to make
a comment
17
during the
evening,
when we open the
18
actual
and formal hearing,
I'm going to
19
ask you to get a card or' sheet
from
20
Sharon,
our community
relations person,
21
so that we
can actually call your
name
22
out and
record
your name
for
the
23
record.
24
Before we begin the
informal
M.A.
TOROSIAN & ASSOCIATES,
-------
3
1
hearing part,
Leslie
MCVickar,
the
2
project Manager,
is going to make an
3
informal
presentation about the
4
proposed plan and then we will take
5
formal
comments and then we will
close
6
the meeting.
If there
is time,
we" will
7
answer
questions.
8
Tonight's .meeting
is to
take
9
comments on
the Proposed Plan and the
10
Feasibility study.
We want to ensure
11
that you're
commenting- on all the
12
alternatives that
were
presented in the
13
Feasibility Study and the Proposed
14
Plan.
15
A s.._y-o u
know,
we opened the
16
public
comment
period on June 20th and
17
it runs
through July 19th.
After this
18
evening,
you will have time
to submit
19
.,
your written
comments to our office in.
20
Boston as long as
they
come
in to
21
Leslie McVickar
before July 19th.
22
All
the
comments
that we.
23
receive' this evening,
as
well as the
24
comments
that we
receive
in writing
M.A.
TOROSIAN & ASSOCIATES,
-------
4
1
before July 19th,
will be
responded to
2
in writing in a document
called the
3
Responsiveness Summary that will be
4
attached to a Record of Decision at the
5
Site and
a Record of Decision will make
6
a decision on the
remedial action
that
7
will
take place at the
site.
8
As
I
said,
we have Leslie
9
MCVickar,
the EPA Project Manager,
with
10
us this evening.
We have Evelyn" Tapani
11
who is
the state
Proj~ct Manager with
12
us and Doug Fine,
the
state community
13
relations contact,
as well as Ann Fox
14
from the Mass Department of Health.
.. - .15
Does anyone
have
any questio"Il"S"
16
on how we are going to
run this
17
meeting?
If not,
I'm going to ask
18
Leslie to make a
short presentation
19
about the Proposed Plan.
20
MS.
MCVICKAR:
The United
21
States Environmental Protection Agency
22
has proposed a cle~nup plan,
referred
23
to as the
preferre"d alternative,
to
24
address
contamination at
the Silresim
M.A.
TOROSIAN & ASSOCIATES,
-------
5
1
Superfund Site
in Lowell,
2
Massachusetts.
The preferred
3
alternative
is EPA's preliminary
4
selection of a
remedy and may be
5
altered based upon comments
or new
6
information received during
the current
7
public comment period which would
8
significantly affect
EPA's
evaluation
9
of the
alternatives.
10
EPA's preferred cleanup plan
11
includes a
combination- of technol~gies
12
to address
contaminated soil and
13
groundwater at Silresim.
The first
14
phase of the proposed remedy is to
15
address
soil ~ontamination which would
16
involve
in-situ vacuum/vapor extraction
17
of 137,000'cubic yards of soil on and
18
off the Silresim property to reduce the
19
..
concentrations of volatile organic
20
compounds
to protective
levels.
21
MS.
LESHEN:
We have a little
22
competition.
23
MS.
McVICKAR:
Then,
soils
24
exceeding the cleanup
goals
for the
M.A.
TOROSIAN & ASSOCIATES,
-------
6
1
remaining
contaminants of concern would
2
be excavated and treated utilizing a
3
treatment known as
stabilization,
which
4
would bind the contaminants
in
the soil
5
together,
thereby reducing the
6
potential for these
contaminants
to
7
leach into the
groundwat"er.
Final
8
disposition of the
stabilize"d
9
con tam i n ate" d
soil would be primarily on
10
the Silresim prope~ty under a permanent
11
multi-layer cap meeting federal
12
speCifications.
13
The preferred alternative to
14
address
the contaminated groundwater
- 15
would
include a
system to extract and~
16
treat
groundwater from
the contaminated
17
plume to meet target cleanup goals at
18
the Si1resim property boundary.
19
Groundwai~r would be extracted
from
20
numerous .extraction wells and
initially
21
be pumped to a phase
separation
22
settlement tank
to separate
the dense
23
non-aqueous phase
liquid from the
24
water.
Groundwater would
then be
M.A.
TOROSIAN & ASSOCIATES,
-------
7
1
treated for
removal
of metals utilizing
2
chemical precipitation/filtration.
3
Following chemical precipitation,
the
4
groundwater would be heated and treated
5
using an air stripper to
remove the
6
organic compounds from the water.
The
7
contaminated air
stream would be
8
treated using
thermal oxidation,
and
9
the
remaining
contaminated groundwater
10
would subsequently pass through units
11
of granulated activated
carbon,
known
12
as
carbon adsorption,
before being
13
discharged to the Duck Island sewage
14
treatment facility.
If this facility
15
could not
b e .u sed,
the treated
16
groundwater will be discharged to
17
nearby River Meadow Brook.
18
If public comment and
19
additional
information cause the
EPA to
20
alter their evaluation of
the preferred
21
alternative or of the other
22
alternatives
considered in the
23
Feasibility Study~
EPA could modify the
24
preferr~d plan or
select another
M.A.
TOROSIAN & ASSOCIATES,
-------
o
1
alternative.
2
There were eight other
Source
3
control
alternatives and
three other
4
Management of Migration
alternatives
5
considerd for
selection
in the
6
Feasibility Study.
I will "b r i e fly
7
outline each of
these,
beginning with
8
Source
Control,
before concluding.
9
Sou r c eo Con t r 0 1
Plan number
1
is
10
the no
action alternative under which
11
no remedial
action
of the
contaminated
12
soils would
occur.
Under
this
13
alternative
the only activities would
14
include additional perimeter
fencing of
15
the site,
posting warning
signs,
an
16
extension of
the existing
cap into
17
newly fenced areas and institutional
18
controls.
19
Source Control alternative
20
number
2 calls
for a cover system over
21
contaminated soil
exceeding target
22
cleanup levels both on and off
the
23
Silresim property.
The existing cap
24
would be upgraded and extended to
M.A.
TOROSIAN & ASSOCIATES,
-------
1
comply with federal
requirements.
2
Alternative number 3
calls for
3
in-situ vacuum/vapor extraction to
4
remove primarily volatile organic
5
compounds,
followed by excavation of
6
soils contaminated with non-volatile
7
organics
and final
disposition on the
8
Silresim property under a cap.
9
Alternative number 6
calls for
10
on-sit.e
treatment of the contaminated
11
soil utilizing thermal desorption.
12
Soils with residual
contamination
13
exceeding target cleanup goals would be
14
stabilized,
to bind the contaminants
15
with the
soil,
and ~isposed of on the
16
Silresim property under a final cap.
17
Source Control alternative
18
number 10
includes on-site incineration
19
of all
soil
contaminated above
targe~
20
c 1 ea n u p g 0 a 1 s ,
followed by
21
stabilization and final
disposition of
22
the stabilized material
under a cap on
23
the Silresim property.
24
Alternative number 11
includes
M.A.
TOROSIAN & ASSOCIATES,
-------
10
1
in-situ vacuum/vapor extraction of all
2
soils with concentrations exceeding
3
target cleanup goals
for volatile
4
organic compounds,
followed by
5
incineration
of residual
soil
still
6
contaminated with non-volatile
7
organics.
Folowing incineration,
the
8
remaining
contaminated soil would be
9
stabilized and disposed of on the
10
Silresim pr~perty under a
final cap.
11
12
Source Control alternative
number 14
includes
in-situ vacuum/vapor
13
extraction,
followed by solvent
14
eX.traction to
remove
residual
organic
15
compounds.
Following solvent
16
extraction,
soil which still exceeds
17
target cleanup
goals would be
18
stabilized and disposed of
under a
1,9
final cap on 'the Silresim property.
20
Final
Source Control
21
alternative,
number 15,
is nearly
22
identical
to number 14.
The sole.
23
difference
is
that
the
remaining
24
contaminated
soil,
following solvent
M.A.
TOROSIAN & ASSOCIATES,
-------
1
extraction,
would be
stabilized and.
2
disposed of at
a licensed facility
3
off-site.
The
Silresim property would
4
still,
however,
be
capped.
5
Management
of Migration
6
alternative number
1 does n9t include
7
treatment of the
contaminated
8
groundwater.
This alternative would
9
include only
institutional controls to
10
restrict
the use of groundwater at the
11
site and a
long-term groundwater
12
monitoring
program.
13
Management of migration
14
alternative number
3
is
similar
to the
15
preferred groundwater alternative,
with
16
the substitution of steam stripping for
17
air
stripping.
The groundwater would
18
be extracted and initially pumped to a
19
settling tank
to
remove dense
20
non-aqueous
phase
liquids.
The
21
groundwater would then be
treated to
22
remove metals using chemical
23
precipitation,
and then pumped to a
24
steam stripper
to
separate the volatile
M.A.
TOROSIAN & ASSOCIATES,
-------
12
1
organic
compounds
from
the water.
The
2
residual
contaminated air would be
3
treated using carbon adsorption or a
4
thermal
oxidizer.
The
residual
5
contaminated water would be further
6
treated using carbon adsorption.
The
7
treated water would then be discharged
8
to the Duck
Island
treatment
facility
.9
or
to River
Meadow Brook.
10
The final Management of
11
Migration alternative,. number 4,
.i s
12
also a pump and treat alternative.
13
Following the pre-treatment units
to
14
separate dense non-aqueous phase
liquid
15
and metals
from the groundwater,
it
16
would be
treated using ultraviolet
17
chemical
oxidation
to remove the
18
organic compounds.
Either carbon
19
..
adsorption or
thermal oxidation would
20
be used to
control
emissions of
21
volatile organic compounds.
The
2.2
treated water would then be
dischargd
23
to the Duck
Island
treatment
facility
24
or to River Meadow Brook.
M.A.
TOROSIAN & ASSOCIATES,
-------
13
1
MS.
LESHEN:
Thank you,
Leslie.
2
I would like
to call
the
first
3
person
that would like to
make a
4
comment.
Norine Brodeur.
5
MS.
BRODEUR:
I would like to
6
make a
formal
request
that you extend
7
the comment period for
30 days.
I
8
think that
the extens
is extremely
9
important.
I
know that the
study has
10
been ongoing for 10 years.
I don't
11
feel as though" 30 days is
too much to
12
ask.
I would expect that the
13
responsible parties would say it
is
14
another delay that would be our fault
15
and we have been accused of
that and
16
worse.
After 10
years,
however,
I
17
don't
think that
30 days
is too much to
18
ask.
This particular plan is very
19
extensive,
very intricate and
as a
20
comm~nity people we have
to weigh and
21
look at this plan and say what
is best
22
for our
community.
what
is at
risk
is
23
the health of 800
families.
If we make
24
the wrong decision because we only have
M.A.
TOROSIAN & ASSOCIATES,
-------
14
1
30 days,
that would be unfortunate to
2
say the least.
3
I feel as
though everybody has
4
worked
very,
very hard and you feel
5
comfortable with
this.
I don't.
I
6
think that it is a big
risk.
I don't
7
think
the community knows enough to
8
evaluate it.
We have tried to contact
9
people to see if anyone would look at
10
this information
for us
for" free
11
because we have no funds
and they will
12
not.
It is an extensive
job.
It takes
13
an awful
lot of time to
review the
14
amount of material
that has come out
15
about .the
site and what
kind of
16
alternatives you are looking at.
We
17
hope that
in
the next 30 days that
we
18
might get lucky and find
someone.
19
Maybe
we won't.
But I don't think that
20
it is
too much to ask to give us the
21
opportunity.
We still see a lot of
22
sickness in the ~eighborhood.
We hear
23
about new things and the old things.
24
We are very,
very concerned that if we
M.A.
TOROSIAN & ASSOCIATES,
-------
15
1
go forward without knowing all
the
2
d eta i I s °0 f
the Proposed Plan,
what kind
3
of emissions,
for
instance,
what will
4
be the
result,
we don't
know.
We are
5
not sure,
you know,
and that's why it
6
is so
important.
7
So again,
my main
concern is
8
time.
It has
taken 10 years
to get to
9
this point and another
30 days won't
10
make
any difference unless we get the
11
help we need and then ~t may make all
12
the difference
to us.
Thank you.
13
MS.
LESHEN:
Thank you.
Would
14
anyone
like to make a comment?
I have
15
received at
this point no further
16
formal
requests for additional
comment
17
but I und~rstand there were some people
18
considering making
a comment in the °
19
audience.
20
We are
going
to need to have
21
your
name.
22
MR.
WILLETT:
Ray Willett.
2 °3
MS.
LESHEN:
Ray Willett.
24
MR.
WILLETT:
You have
all
M.A.
TOROSIAN & ASSOCIATES,
-------
16
1
kinds of alternatives here but you do
2
not have
one that
is the ultimate
that
3
says,
seal,
it
is
all done.
4
Now,
a cap is being put on
5
these places to keep the
rainwater,
6
they
say,
from going down there.
It is
7
like an umbrella but all
around these,
8
these sites,
the
rain ~s
going into the
9
soil
and it gets
into
there.
10
NoW,
there is a system.
I
11
believe
it was about four years ago
12
they had a
meeting,
a meeting on Smith
13
Street
and there was one vendor
that
14
had an
incinerator to move onsite.
15
That could burn the
soil
right
in,
dirt
16
and all,
and pile it up and when it
17
went through,
it went
right back and
18
now you have sterile
soil.
Now,
you
19
don't have to bother with that any
20
more.
Everyone of
your alternatives
21
eventually is going to lead into
22
problems again.
23
N,ow,
you say that is going to
24
be ,awful
expensive.
But,
what does
it
M.A.
TOROSIAN & ASSOCIATES,
-------
17
1
cost already to take and clean that
site and that's not the end? Now, you
want to do more. Now, somebody says
2
3
4
for about
two years.
Now,
that
is
5
nothing.
That's no good.
We want
6
forever.
The problems are
there.
I
7
know that
at one
time it was
referenced
8
that,
well,
that would be our
job at
9
that time.
There are
jobs
for
10
eve rybody..
There
are many,
many sites
11
around
this
country that would be
12
moving
around and doing youi job but I
13
think
that you should complete the
job
14
where
you are
so that there will be no
15
more
problems.
16
MS.
LESHEN:
Thank you.
17
MS.
WELCOME:
Most of the
18
questions
that I have already have been
19
"
answered at
a previous meeting.
20
MS.
LESHEN:
Would anyone
else
21
that
is present now
that would like to
22
make a
comment into the
record?
23
(Pause)
24
MS.
LESHEN:
As I'm closing the
M.A.
TOROSIAN & ASSOCIATES,
-------
~o
1
hearing,
I would like to go
into
2
exactly what is going to
go on from-
3
here.
The people are
encouraged to
4
submit written comments to our office
5
at this point in
time by July 19th.
6
Leslie and I are not empowered to
7
extend the
comment period
here
and now
8
on the
spot.
If there is
an extension,
9
it will be published in the riewspaper
10
and people will be notified.
But I
11
would urge you to work
on your comments
12
for that day.
13
As I
stated
earlier,
all the
14
comments
received
tonight,
as 'well as
15
the ones
received in
writing during the
16
comment period, will be
responded to in
17
the Responsiveness Summary which w~
18
attach to the Record of Decision.
All
19
of the
information and
the Feasibility
20
Study and the Proposed plan which is
21
all information that you should be
22
referring to when you are commenting
23
are available at the Lowell Library as
24
well as our office in Boston.
M.A.
TOROSIAN & ASSOCIATES,
-------
19
1
Any time people
can call Leslie
2
with questions but we urge you to
3
submit your comments
in writing.
I
4
would like
to ask
for one more time
if
5
there
is anyone that would like to make
6
a
comment into the
record?
7
MS.
WELCOME:
My name
is Ann
8
Welcome.
9
MS.
LESHEN:
I
think
she needs
10
you to talk
to the mike.
She is
11
recording as well.'
12
MS.
WELCOME:
I would like to
13
I would like
to know to what extent
14
a
follow-up is
being done health-wise
15
for people who have moved out of the
16
Silresim area and still
have physical
17
problems.
I
think
that
follow-up is of
18
the utmost
importance.
19
MS.
LESHEN:
Hearing no
20
objections,
I'm going to close the
21
hearing and that means no further
22
comments will be
responded
to from this
23
evening in, the
responsiveness
summary.
24
No Qne
is
changing their mind?
M.A.
TOROSIAN & ASSOCIATES,
-------
.... v
1
MS.
BRODEUR:
Anything
written,
2
you will respond to?
3
MS.
LESHEN:
Right.
4
(Pause)
5
MS.
LESHEN:
Okay.
Then we
6
will
close
the record.
Thank you very
7
much.
8
(Whereupon,
the hearing
9
concluded at 7:30 p.m.)
10
11
12
13
14
15
16
17
18
. 19
"
20
21
22
23
24
M.A.
TOROSIAN & ASSOCIATES,
-------
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
21
1
COMMONWEALTH OF MASSACHUSETTS.
2
MIDDLESEX,
S S .
3
4
Marybeth Coldwell,
I ,
Registered
5
Professional Reporter,
do hereby certify
6
that the aforegoing pages,
1 through 21,
in
7
the matter of the Silresim Superfund Site
8
. have been accurately recorded and
9
transcribed to the
best of my knowledge,
skill and ability.
~' -!/v--'1
../
, 1/
/
111
----
----------
Marybet. : Coldwell,
lj'
RPR
M.A.
TOROSIAN & ASSOCIATES,
-------
APPENDIX P
-------
o.
Silresim Chemical Corp.
NPL Site
Administrative Record
Index
Compiled: September 13, 1989 .
Updated: April 25, 1990
Updated: June 19, 1991
ROD Signed: September 19,1991
Prepared for
Region I
Waste Management Division
U.S. Environmental Protection Agency
With Assistance from
AMERICAN MANAGEMENT SYSTEMS, INC.
-------
Introduction
This document is the Index to the Administrative Record for the SiJresim Chemical Corp.
National Priorities List (NPL) site. Section I of the Index cites site-specific documents, and Section
n cites guidance documents used by EPA staff in selecting a response action at the site. Additional
guidance documents that EP A staff may have consulted in selecting a response action are available
through EPA's Region I office.
The Administrative Record is available for public review at EPA's Region I Office in Boston,
Massachusetts, and at the Pollard Memorial Library, 401 Merrimack Street, Lowell, Massachusetts
01850. Questions concerning the Administrative Record should be addressed to the EPA Region I
Remedial Project Manager.
The Administrative Record is required by the Comprehensive Environmental Response,
Compensation, and Liability Act (CERCLA), as amended by the Superfund Amendments and
-------
Section I
-------
1.0
ADMINISTRATIVE RECORD INDEX
for the
Silresim Chemical Corp. NPL Site
Pre-Remedial
1.3
1.2
Preliminary Assessment
1.
2.
"Potential Hazardous Waste Site - Identification and Preliminary Assessment"
Form, EPA Region I (July 3, 1980).
"Potential Hazardous Waste Site - Tentative Disposition" Form, EPA Region I
(July 3, 1980).
Site Inspection
1.
2.
"Potential Hazardous Waste Site - Site Inspection Repon" Form, EPA Region I
(July 3, 1980).
"Potential Hazardous Waste Site - Site Inspection Repon" Form, EPA Region I
(May 18, 1982).
1.18 FIT Technical Direction Documents (1DDs) and Associated Records
1.
2.
"Final Repon: Analysis of Hazardous Waste Mismanagement Incident in
Lowell, Massachusetts," Fred C. Han Associates, Inc. (June 12, 1978).
Memorandum from Paul F. Clay, NUS Corporation to Menill S. Hohman, EPA
Region I (March 29, 1983) with attached "Internal Draft Repon - Silresim Air
Monitoring," NUS Corporation. Concerning purpose and transmittal of attached
repon.
Memorandum from Mark E. Brickell, NUS Corporation to John F. Hackler and
Barbara H. Ikalainen, EPA Region I (May 10, 1983) with attached "Analysis of
Silresim Samples," NUS Corporation (March 30, 1983 through May 16, 1983).
Concerning perimeter soil sampling, sampling of wells, and remedial measures.
Memorandum from Mark E. Brickell, NUS Corporation to EPA Personnel
. (June 22, 1983). Concerning results of analysis of purge able and extractable
priority pollutants taken at the Arrow Camer and Menends Investtnent Realty
Propeny.
Lener from Mark E. Brickell, NUS Corporation to John Scannell, Scannell
Boiler Works (June 24, 1983) with attached sampling location maps.
Concerning results of soil contamination screenings on Scannell Boiler Works
propeny. "
Letter from Mark E. Brickell,"NUS Corporation to Phillip Nyman (Attorney for
Wright Leasing and Realty) (June 24, 1983) with attached sampling location
maps. Concerning results of soil contamination screenings in the Wright
Leasing and Realty parking lot.
"Sampling Methodology," EPA Region I with attached sampling locations maps.
Concerning soil sampling surveys performed during March and April 1983, and
on June 13, 1983 through June 16, 1983. "
3.
4.
5.
6.
-------
Page 2
2.1
Removal Response
2.0
CotTespondence
1. Letter from John P. Lehman, EPA Headquaners to Chris Johnson, Silresim
Chemical Corporation (October 31,1974). Concerning attached memorandum
and draft resume of vital statistics regarding waste treatment and disposal
operations at the Si1resim Chemical Corporation.
2. Letter from Thomas C. McMahon, Commonwealth of Massachusetts Division of
Water Pollution Control to Daniel K. Moon, EPA Region I
(December 27, 1977). Concerning a list of prioritized tasks for site analysis.
3. Letter from Paul G. Keough, EPA Region I to William X. Wall, Member of the
Commonwealth of Massachusetts State Senate (February 2, 1978). Concerning
information on site activities. .
4. Memorandum from Thomas C. McMahon, Commonwealth of Massachusetts
Division of Water Pollution Control to David Standley, Commonwealth of
Massachusetts Deparnnent of Environmental Quality Engineering
(March 8, 1978). Concerning the status of the Si1resim Chemical Corporation as
of March 8, 1978.
5. Letter from Thomas C. McMahon, Commonwealth of Massachusetts Division of
Water Pollution Control to William Adams, EPA Region I (April 10, 1978).
Concerning a request for assistance with water sample analysis.
6. Letter from William Adams, EPA Region I to Thomas C. McMahon,
Commonwealth of Massachusetts Division of Water Pollution Control
(April 27, 1978). Concerning assistance in identifying organic chemicals. .
7. Letter from Thomas C. McMahon, Commonwealth of Massachusetts Division of
Water Pollution Control to Charles D. Lincoln, EPARegion I
(August 8, 1978). Concerning a request for initiation of immediate defensive
actions.
8. Letter from Charles D. Lincoln, EPA Region I to Thomas C. McMahon,
Commonwealth of Massachusetts Division of Water Pollution Control
(August 18, 1978). Concerning the immediate initiation of defense actions.
9.. Memorandum from Hans Bonne, Commonwealth of Massachusetts Division of
Water Pollution Control to Members of the Task Force on Si1resim
(November 20, 1978). Concerning initiation of cleanup operations.
10. Telephone Notes between Richard C. Boynton, EPA Region I and Glen
Gihnore, Commonwealth of Massachusetts Division of Water Pollution Control
(January 4, 1979). Concerning update of site cleanup.
11. Trip Repon on a Visit to Silresim Chemical Corp., Janet DiBiasio,
EPA Region I and Peter Schneider, NERCOM (February 15, 1979).
Concerning observation of cleanup operations as of February 1, 1979.
12. Meeting Notes, Public Meeting for the Silresim Chemical Corp. Site, EPA
Region I, Commonwealth of Massachusetts Depanment of Environmental
Quality Engineering (June 23,1981). Concerning public demands for sampling
at the site.
2.2
Removal Response Reports
2.3
"Hazardous Waste Cleanup: Silresim Site in Lowell, Massachusetts," The
MITRE Corporation for the Co~onwealth of Massachusetts Division of Water
Pollution Control (June 1979).
Sampling and Analysis Data
1.
The Sampling and Analysis Datafor the Removal Response may be reviewed, by
-------
Page 3
2.4
Pollution Repons (POLREPs)
1.
2.
3.
4.
5.
6.
7.
POLREP 2, EPA Region I (June 30, 1983).
POLREP 3, EPA Region I (July 13, 1983).
POLREP 4, EPA Region I (August 4,1983).
POLREP 4, EPA Region I (September 2, 1983).
POLREP 1, EPA Region I (June 25, 1986).
POLREP 2 and Final, EPA Region I (August 25,1986).
POLREP 1, EPA Region I (December 15.1986).
2.9
Action Memoranda
1.
3.0
Memorandum from William N. Hedeman Jr., EPA Headquaners to Lee M.
Thomas, EPA Headquarters (June 10, 1983). Concerning implementation of
initial remedial measures including removal of structures, installation of fencing
and signs, and site cap.
Memorandum from Katherine E. Daly, EPA Region I to Michael R. Deland,
EP A Region I (April 28, 1986). Concerning completion of removal activities
and reparation of a chain link fence. . .
Remedial Investigation (RI)
2.
3.1
Correspondence
1. Letter from J. Elliott Thomas Jr., EPA Region I to John D. Tewhey, Jordan
Gorrill Associates (January 24, 1983). Concerning results and QA package
from soil taken at Silresim. .
2. Memorandum from EPA Region I Health Effects Study Group to Merrill S.
Hohman, EPA Region I (April 1, 1983). Concerning conclusions reached from
the March 14, 1983 through March 23.1983 air monitoring stUdy.
3. Letter from Barbara H. Ikalainen, EPA Region I to Phillip Nyman (Attorney for
Wright Leasing and Realty) (June 21. 1983). Concerning transmittal of the
Remedial Action Master Plan.
4. Letter from Barbara H. Ikalainen, EPA Region I to John Scannell, Scannell
Boiler Works (June 21,1983). Concerning transmittal of the Remedial Action
Master Plan for the Silresim Site. ..
5. Letter from Peter J. Aucella, City of Lowell Division of Planning and
Development to David M. Webster. EPA Region I (April 2, 1985). Concerning
request that issues sUITounding potential development at Silresim Site be
addressed in the Remedial Investigation/Feasibility Study Work Plan.
6. Letter from David M. Webster. EPA Region I to Norine Danley, Ayer City
Homeowners and Renters Association and Massachusetts Fair Share .
(June 3, 1985). Concerning reopening of comment period and other questions
surrounding the Remedial Investigation/Feasibility. Study Work Plan.
7. Letter from John R. Moebes, EPA Region I to Peter J. Aucella, City of Lowell
Division of Planning and Development (June 5, 1985). Concerning response to
letter of April 2, 1985 regarding upcoming Remedial Investigation/Feasibility
StUdy issues.
8. GCA Corporation Attendance List, Remedial Investigation/Feasibility Study
Kickoff Meeting for the Silresim Chemical Corp. Site (July 11. 1985).
9. Meeting Notes. Remedial Investigation/Feasibility Study Kickoff Meeting for the
Silresim Chemical Corp. Site. GCA Corporation and EP A Region I
(July 19, 1985). Concerning the RIIFS process and overview.
10. Meeting Notes, Remedial Investigation/feasibility Study Monthly Oversight
Meeting for the Silresim Chemical Corp. Site. GCA Corporation and EPA
-------
Page 4
3.1
Correspondence (cont'd.)
11. Meeting Notes, Remedial Investigation/Feasibility Study Monthly Oversight
Meeting for the Si1resim Chemical Corp. Site, GCA Corporation and EPA
Region I (September 17, 1985). Concerning various plans in the RIIFS.
12. Meeting Notes, Remedial Investigation/Feasibility Study Monthly Oversight and
Planning Meeting for the Silresim Chemical Corp. Site, GCA Corporation and
EPA Region I (October 23, 1985). Concerning Project Operations Plans.
13. Meeting Notes, Remedial Investigation/Feasibility Study Monthly Oversight and
Planning Meeting for,the Silresim Chemical Corp. Site, GCA Corporation and
EPA Region I (November 5, 1985). Concerning RIlFS progress.
14. Meeting Notes, Remedial Investigation/Feasibility Study Monthly Oversight and
Planning Meeting for the Silresim Chemical Corp. Site, GCA Corporation and
EP A Region I (December 11, 1985). Concerning the RIlFS work plan. ,
15. Lenerfrom Heather M. Ford, EPA Region I to James K. Rogers, Silresim Site
Trust (December 16, 1985). Concerning the December RIlFS Oversight and
Planning meeting. ,
16. Meeting Notes, Remedial Investigation/Feasibility Study Monthly Oversight and
Planning Meeting for the Silresim Chemical Corp. Site, GCA Corporation and
EPA Region I (January 13, 1986). Concerning RI/FS progress.
17. Meeting Notes, Remedial Investigation/Feasibility Study Monthly Oversight and
Planning Meeting for the Silresim Chemical Corp. Site, GCA Corporation and
EP A Region I (February 4, 1986). Concerning site sampling and progress.
,18. Meeting Notes, Remedial Investigation/Feasibility Study Monthly Oversight and
Planning Meeting for the Silresim Chemical Corp. Site, GCA Corporation and
EPA Region I (March 7,1986). Concerning progress and deliverable dates.
19. Letter from Philip L. Scannell, Dennis Scannell, and John P. Scannell, Scannell
Development Group to E. Michael Thomas, EPA Region I (March 13, 1986)
with attached print of proposed buildings. Concerning construction plans,
excavation, and moving fill.
20. Letter from James K. Rogers, Si1resim Site Trust to David M. Webster, EPA
Region I (April 18, 1986). Concerning deliverable delays.
21. Meeting Notes, Remedial Investigation/Feasibility Study Monthly Oversight and
Planning Meeting for the Silresim Chemical Corp. Site, GCA Corporation and
EPA Region I (April 24, 1986). Concerning site progress.
22. Meeting Notes, Remedial Investigation/Feasibility Study Monthly Oversight and
Planning Meeting for the Silresim Chemical Corp. Site, GCA Corporation and
EP A Region I (May 14, 1986). Concerning QNQC of sampling procedures and
progress.
23. Letter from Richard J. Chalpin, Commonwealth of Massachusetts Department of
Environmental Quality Engineering to Norine Brodeur, Ayer City Homeowners
and Renters Association (May 30, 1986). Concerning answers to questions
about the state's role in the Silresim Remedial Investigation/Feasibility Study.
24. Meeting Notes, Remedial Investigation/Feasibility Study Monthly Oversight and
Planning Meeting for the Silresim Chemical Corp. Site, GCA Corporation and
EPA Region I (June 20, 1986). Concerning site progress.
25. Draft Meeting Notes, Remedial Investigation/Feasibility Study Monthly,
Oversight and Planning Meeting and Public Meeting for the Silresim Chemical
Corp. Site, GCA Corporation and EPA Region I (July 14, 1986). Concerning
citizens issues, and site progress and plans.
26. Meeting Notes, Remedial Investigation/Feasibility Study Monthly Oversight and
Planning Meeting for the Silresim Chemical Corp. Site, GCA Corporation and
EP A Region I (August 11, 1986). Concerning sampling and site progress.
27. Meeting Notes, Remedial Investigation/Feasibility Study Monthly Oversight and
Plan'ning Meeting for the Silresim Chemical Corp. Site, GCA Corporation and
-------
Page 5
3.1
Correspondence (cont'd.)
28. Letter from loel Balmat, EPA Region I to lames K. Rogers, Silresim Site Trust
(October 20, 1986). Concerning conditional approval of proposed vent
sampling plan.
29. Letter from loel Balmat, EPA Region I to Charles A. Lindberg, Goldberg-Zoino
& Associates, Inc. (October 20, 1986). Concerning monthly groundwater
monitoring.
30. Meeting Notes, Final Monthly Oversight and Planning Meeting for the Silresim
Chemical Corp. Site, Alliance Technologies Corporation and EPA Region I
(November 24, 1986). Concerning overview of field activities and deliverables.
31. Final Draft Meeting Notes, Monthly Oversight and Planning Meeting for the
Silresim Chemical Corp. Site, Alliance Technologies CorporatiQn and EP A
Region I (December 15, 1986). Concerning overview and oversight offield
activities.
32. Final Version Meeting Notes, Monthly Oversight and Planning Meeting for the
Silresim Chemical Corp. Site, Alliance Technologies Corporation and EP A
Region I (March 4, 1987). Concerning dioxin in soils, overview of field
activities, and deliverables.
33. Transcript, EPA Region I and Goldberg-Zoino & Associates, Inc. Remedial
Investigation Review Meeting, Camp Dresser & McKee Inc. (May 27, 1987).
34. Letter from Margaret I. Leshen, EPA Region I to lames K. Rogers, Silresim
Site Trust (May 17, 1988). Concerning scheduling of events necessary for
continuation of the Silreshn Superfund Project
35. Letter from Leslie McVickar, EPA Region I to Philip L. Scannell Ir., Lowell
Iron and Steel Corp. (Iune 16, 1988). Concerning soil sampling data and health
risk material. '
36. Meeting Notes, Remedial Investigation/Feasibility Study Technical Oversight
and Planning Meeting, EPA Region I (November 18, 1988). Concerning field
studies, air sampling, and the RIIFS.
37. Letter from Leslie McVickar, EPA Region I to Kenneth Carr, U.S. Department
of the Interior Fish and Wildlife Division (December 27, 1988). Concerning
transmittal of the March 1987 "Draft - Remedial Investigation Repon,"
Goldberg-Zoino & Associates, Inc. for Silresim Site Trust.
38. Letter from Leslie McVickar, EPA Region I to Philip L. Scannell Jr., Lowell
Iron and Steel Company (March 16, 1989). Concerning soils analytical data,
summary tables and well screening results. .
39. Letter from lames K. Rogers, Silresim Site Trust to Leslie McVickar, EPA
Region I (March 23, 1989). Concerning revised schedule for the Remedial
Investigation. .
40. Letter from Leslie McVickar, EPA Region I to Kenneth Carr, U.S. Department
of the Interior Fish and Wildlife Division (April 18, 1989). Concerning
transmittal of the April 1989 "Revised Draft Repon - Remedial Investigation -
Volumes I through VnI," Goldberg-Zoino & Associates, Inc. for Silresim Site
Trust.
41. Memorandum from Deirdre Menoyo, Goodwin, Procter & Hoar (Attorney for
Silresim Site Trust) to E. Michael Thomas, EPA Region I, Leslie McVickar,
EP A Region I, Charles A. Lindberg, Goldberg-Zoino & Associates, Inc. and
Silresim Trustees (July 12, 1989). Concerning the Dense Non-Aqueous Phase
Liquid (DNAPL) anicle by Allan Feenstra and John A. Cherty.
42. Letter'from James K. Rogers, Silresim Site Trust to Leslie McVickar, EPA
Region I (January 16, 1990). Concerning the Silresim DNAPL Investigation.
43. Letter from Merrill S. Hohman, EPA Region I to lames K. Rogers, Silresim
Site Trust (February 27, 1990). Concerning site RIIFS issues.
44. Memorandum from William Holden, CDM Federal Programs Corporation to
File (March 27, 1990). Concerning field oversight activities at the site.
45. "Presentation to the U.S. Environmental Protection Agency Region I," Guy C.
-------
3.2
Page 6
3.1
CoITespondence (cont'd.)
46. Letter from Leslie McVickar, EPA Region I to James K. Rogers, Silresim Site
Trust (August 22, 1990). Concerning the DNAPL Investigation.
47. Letter from James K. Rogers, Silresim Site Trust to Leslie McVickar, EPA
Region I (August 29, 1990). Concerning the DNAPL Investigation. .
48. Letter from RuthAnn Shennan, EP A Region I to Susan M. Cooke, Goodwin,
Procter & Hoar (Attorney for Silresim Site Trust) (September 7, 1990).
Concerning notification that EP A has approved the March 1990 Final Draft
Remedial Investigation for the sire.
49. Letter from Susan M. Cooke, Goodwin, Procter & Hoar (Attorney for Silresim
Site Trust) to RuthAnn Sherman, EPA Region I (October 23, 1990).
Concerning the anached "Comments on DNAPL Investigatory Program at the
Silresim Superfund Site," John A. CheITY a,nd Guy C. Patrick
(October 22, 1990).
50. Lener from Leslie McVickar and RuthAnn Shennan, EPA Region I to Susan M.
. Cooke, Goodwin, Procter & Hoar (Attorney for Silresim Site Trust)
(November 8, 1990). Concerning the DNAPL Investigation.
51. Memorandum from J. Pickens, Camp Dresser & McKee Inc. to Addressees
(November 28, 1990). Concerning the Cone Penetration Testing (CPT)
program activities at the site.
52. Memorandum from J. Pickens, Camp Dresser & McKee Inc. to Addressees
(December 7, 1990). Concerning the CPT program activities at the site.
53. Letter from James P. Cassidy Jr. (Attorney for Ralph Tucci) to EPA Region I
and Commonwealth of Massachusetts Department of Environmental Protection
(January 21, 1991). Concerning request for sampling data.
54. Letter from James P. Cassidy Jr. (Attorney for Ralph Tucci) to Merrill S.
Hohman, EPA Region I (May 7, 1991). Concerning request for future sampling
data.
55. Letter from Leslie McVickar, EPA Region I to James P..Cassidy Jr. (Attorney
for Ralph Tucci) (May 22, 1991). Concerning Mr. Cassidy's request for
sampling data.
56. Letter from Leslie McVickar, EPA Region I to James P. Bond, Tanner Street
Businessmen's Group (July 26, 1991). Concerning transmittal of the March
1990 "Final Draft Repon - Remedial Investigation - Volumes I-ill,"
Goldberg-Zoino & Associates, Inc. for Silresim Site Trust. .
Sampling and Analysis Data
1.
Letter from Richard L. Fortin, Perkins Jordan, Inc. to J. Elliot Thomas Jr., EPA
Region I (January 10, 1983). Concerning the transmittal of attached Boring
Logs, New England Boring Contractors, Inc. (December 8, 1982 through
December 13, 1982), Field Inspection Boring Logs, E.C. Jordan Co.
(December 8, 1982 through December 14, 1982), and Boring and Monitoring
Well Locations Map of the Silresim Chemical Corp. Site.
Air Sampling Locations Maps and COITesponding Data (March 14, 1983 through
March 23, 1983).
'Draft - Silresim Air Monitoring - Si1resim Chemical Corporation," NUS
Corporation (August 10, 1984).
Memorandwn from Mark E. Brickell, NUS Corporation to David M. Webster,
EPA Region I (August 1, 1985) with attachments. Concerning Silresim CLP
Analytical Data from soil samples taken on June 29, 1983 outside of existing
fence line.
Memorandum from Mark E. Brickell, NUS Corporation to David M. Webster,
EPA Region I (August 1, 1985). Concerning Silresim CLP Analytical Data
from soil samples taken on April 27, 1983 outside of existing fence line.
Memorandum from Mark E. Brickell, NUS Corporation to David M. Webster,
EP A Region I (August 1, 1985). Concerning Silresim groundwater monitoring.
2.
3.
4.
5.
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Page 7
3.2
Sampling and Analysis Data (cont'd.)
7. Letter from Matthew West for Lawrence Feldman, Goldberg-Zaino &
Associates, Inc. to.the Silresim Site Trustees (March 10, 1986). Concerning
attached laboratory repon from initial round of groundwater samples at the
Silresim site.
8. Letter from Lawrence Feldman, Goldberg-Zaino & Associates, Inc. to the
Silresim Site Trust (April 1, 1986). Concerning gas chromatograph screening
results. .
9. Letter from Claire G. Quadri for Charles A. Lindberg and Lawrence Feldman,
Goldberg-Zaino & Associates, Inc. to the Silresim Site Trustees (May I, 1986).
Concerning transmittal of attached "Volatile Organic Analysis Data Time History
of Concentrations of Chemical Compounds," Goldberg-Zaino & Associates,
Inc. (December 2, 1981 through December 4, 1985).
10. Letter from Lawrence Feldman, Goldberg-Zaino & Associates, Inc. to the
Silresim Site Trust (May 22, 1986). Concerning PCB contamination of surficial
soils. .
11. Letter from John E. Ayres, Goldberg-Zaino & Associates, Inc. to the Silresim
Site Trustees (May 30, 1986). Concerning the transmittal of attached outline of
a proposed air vent sorbent tube sampling program for the Si1resim site.
12. Letter from Lawrence Feldman, Goldberg-Zaino & Associates, Inc. to the
Silresim Site Trust (May 30, 1986). . Concerning transmittal of chemical
analyses completed by Roy F. Weston, Inc. during Pans II and III of the
Silresim Remedial Investigation.
13. Letter from Charles A. Lindberg, Goldberg-Zaino & Associates, Inc. to Nancy
Bettinger, Commonwealth of Massachusetts Department of Environmental
Quality Engineering (May 30, 1986). Concerning transmittal of attached
subsurface profile sketches and water level data sheets.
14.. Memorandum from Charles Moulton, GCA Corporation to Thomas Spittler,
EPA Region I (July 7,1986). Concerning Organic Data Validation Case No.
5870, IT Analytical Services. .
15. Memorandum from Michael Jasinski, GCA Corporation to Nancy Piligian and
David M. Webster, EPA Region I and Rosemary Ellersick, GCA Corporation
(July 8, 1986). Concerning transmittal of attached memos reporting on Organic
Validation Cases No. 5304 - Compuchem Labs, No. 5304 - Chemtech
Consulting, No. 5629 - Hittman Ebasco, Inc., No. 5629 - Aquatec, Inc.
(July 7, 1986).
16. Memorandum from Charles A. Lindberg and William R. Beloff for John E.
Ayres, Goldberg-Zaino & Associates, Inc. to the Silresim Site Trust
(July 9, 1986). Concerning the contents and transmittal of attached results of
surficial soil PCB analyses completed by Roy F. Weston, Inc. and Cambridge
Analytical Associates, Inc.'
17. Memorandum from Nancy Bettinger, Conunonwealth of Massachusetts
. Department of Environmental Quality Engineering to Richard J. Chalpin,
Commonwealth of Massachusetts Department of Environmental Quality
Engineering (August 19, 1986) with attached "Analysis of Water Samples from
MSF - Lowell- Silresim," ERT for Wehran Engineering (August 15, 1986).
Concerning chemical analysis results for samples collected from sewers in the
vicinity of the Silresim site. .
. 18. Letter from James Okun, Goldberg-Zaino & Associates, Inc. to Joel Balmat,
EPA Region I (November 3, 1986). Concerning transmittal of chromatography
for the Silresim Air Vent Study.
19. Letter from Marie M. Studer, Cambridge Analytical Associates to Linda
Boynton, EPA Headquaners (November 4, 1986). Concerning transminaI of
attached sample data package for Case No. 6483 (Inorganics Analysis) for the
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Page 8
3.2
Sampling and Analysis Data (cont'd.)
20. Letter from Charles A. Lindberg, Goldberg-Zoino & Associates, Inc. to the
Silresim Site Trost (November 6, 1986). Concerning ttansminal of attached
draft preliminary results of groundwater screening and revision of proposed
Phase n groundwater sampling plan. .
21. Memorandum from Peter R. Kahn, EPA Region I to Joel Balmat, EPA Region I
(November 19,1986). Concerning air vent sampling field performance audit at
Silresim site.
22. Meeting Notes, November 14,1986 Silresim Remedial Investigation/Phase Two
Groundwater Sampling Meeting, EPA Region I (November 19, 1986) with
attached draft groundwater sampling data. Concerning additional sampling of
specific monitoring wells. .
23. Letter from Joel Balmat, EPA Region I to Richard Boyle, Transit Construction
Company (November 26, 1986). Concerning transmittal of attached analytical
results of sampling activities on the Transit Construction Company property.
24. Letter from Emily C. Carfioli, Roy F. Weston, Inc. to Claire G. Quadri,
Goldberg-Zoino & Associates, Inc. (December 4, 1986). .Concerning
transmittal of attached sampling and analysis data summaries.
25. Letter from Emily C. Carfioli, Roy F. Weston, Inc. to Claire G. Quadri,
Goldberg-Zoino & Associates, Inc. (December 6, 1986). Concerning
transmittal of attached volatile organic analysis data and summary sheet for
dioxin samples.
26. Memorandum from Elio Goffi, EPA Region I to Nancy Barmakian, EPA
Region I (January 8, 1987). Concerning data validation for Silresim Case No.
2606A.
27. Letter froni Claire G. Quadri, Goldberg-Zoino & Associates, Inc. to the Silresim
Site Trust (January 15, 1987). Concerning transmittal of attached preliminary
dioxin results.
28. "Silresim Phase n Split Samples" Data, GCA Corporation and Alliance
Technologies Corporation (February 12, 1987). .
29. "WorklQA Plan Shon Form - Silresim Chemical Corp. Site," EPA Region I
(June 3, 1987).
30. Lener from Charles A. Lindberg, Goldberg-Zoino & Associates, Inc. to Joel
Balmat, EP A Region I (July 1, 1987). Concerning transmittal of attached
"Silresim Water Levels," (April 10, 1987).
31. Memorandum from James Ward, EPA Region I to Gary Lipson, EPA
Region I (August 12, 1987). Concerning Silresim soil sampling.
32. Memorandum from Gary Lipson, EPA Region I to Joel Balmat, EPA
Region I (August 24, 1987). Concerning sampling at Silresim Site.
33. Memorandum from Elio Goffi, EPA Region I to Nancy Papoulias, EPA
Region I (November II, 1987). Concerning anached Silresim Site Case
No. 3012-A. .
. 34. Letter Repon from John Walker for Karen L. Stone, Camp Dresser & McKee
Inc. to Nancy Barmakian, EPA Region I (December 10, 1987). Concerning
Case No. 8129 - Four Low Level Soil Samples AH828-AH831 - Scannell
Propeny.
35. Memorandum from S.R. Gates, Camp Dresser & McKee Inc. to Margaret J.
Leshen, EPA Region I (February 16, 1988). Concerning ttansmittal of attached
Silresim - Scannell property soil sampling. .
36. Memorandum from Margaret J. Leshen, EP A Region I to File
(February 18, 1988). Concerning soil sample locations at Scannell property.
37. Memorandum from Karen L. Stone, Camp Dresser & McKee Inc. to Nancy
Barmakian, EJ>A Region I (February 19, 1988). Concerning case 8129, organic
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Page 9
3.2
Sampling and Analysis Data (cont'd.)
38. Lener Repon from Karen L. Stone. Camp Dresser & McKee Inc. to Margaret J.
Leshen. EPA Region I (February 22.1988) with attached Lener Repon from
Karen L. Stone. Camp Dresser & McKee Inc. to Nancy Bannakian, EPA
Region I (February 19. 1988). Concerning explanation of Data Qualifiers for
Validated Organic and Inorganic Data - Case 8129. as an addendum to letter'
repon of December 10. 1987.
39. Memorandum from Peter R. Kahn, EPA Region I to Leslie McVickar, EPA
Region I (October 3. 1988). Concerning the transmittal of attached revised
. "Indoor Air Toxics Study Work Plan - Lowell Iron and Steel, Co.." EPA
Region I (September 1988).
40. Letter from Charles A. Lindberg. Goldberg-Zoino & Associates, Inc. to Leslie
McVickar. EPA Region I (October 20,1988).. Concerning surficial soil
sampling.
41. Memorandum from Peter R. Kahn. EPA Region I to Leslie McVickar, EPA
Region I (November 4. 1988). Concerning transmittal of attached fmal "Indoor
Air Toxics Sampling Results - Lowell Iron and Steel Company." EPA Region I
(October 1988).
42. . "Cenificate of Laboratory Analysis," Camp Dresser & McKee Inc.
(November 9,1988). Concerning Silresim samples collected October 12.1988.
43. Memorandum from Peter R. Kahn. EPA Region I to Leslie McVickar. EPA
Region I (November 30. 1988). Concerning the transmittal of attached "Indoor
Air Toxics Study Work Plan - Administration Building - Lowell Iron and Steel
Company." EPA Region I (November 1988).
44. "Case Repon." TMS Analytical Services Inc. (December 5, 1988). Concerning
case 4246A with attached: .
A. Letter from Mary Ann Becker, Lucy B. Guzman. and Joseph D. Mastone.
Roy F. Weston. Inc. to Dennis P. Gagne, EPA Region I
(January 26. 1989). Concerning the review and evaluation of attached
dioxin/furan package submitted by TMS Analytical Services Inc.
B. Memorandum from Leslie McVickar. EPA Region I to Debra Szaro, EPA
Region I (February 21, 1989). Concerning request for review of dioxin
samples.
C. Letter from Dan Delinger. TMS Analytical Services, Inc. to Elio Goffi.
EPA Region I (March 23, 1989). Concerning explanation of discrepancy
of data.
D. Memorandum from Elio Goffi. EPA Region I to Leslie McVickar, EPA
Region I (April 4. 1989). Concerning independent audit of data package
from Roy F. Weston, Inc.
45. Memorandum from Peter R. Kahn. EPA Region I to Leslie McVickar. EPA
Region I (January 31, 1989). Concerning the transmittal of "Indoor Air Toxics
Sampling Results - Administration Building - Lowell Iron and Steel Company."
EPA Region I (January 1989). .
46. Letter from Stacy Sabol, Goldberg-Zoino & Associates. Inc. to Leslie
McVickar. EPA Region I (February 16, 1989). Concerning draft groundwater
analytical summary tables for samples taken in the fall of 1988.
47. Letter from Charles A. Lindberg. Goldberg, Zoino & Associates, Inc. to James
K. Rogers. Silresim Site Trust (March 8. 1989). Concerning attached Final
Status Repon on Fa1l1988 Soil Samples.
48. Letter from Charles A. Lindberg, Goldberg. Zoino & Associates, Inc. to James
K. Rogers. Silresim Site Trust (March 10. 1989). Concerning attached tables
on field activities.
49. Memorandum from William R. Swanson. Camp Dresser & McKee Inc. to Leslie
McVickar. EPA Region I (April3.~1989). Concerning summary table for split
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Page 10
3.2
Sampling and Analysis Data (cont'd.)
The records cited in entry numbers 50 through 71 may be reviewed, by appointment
only, at EPA Region I, Boston, Massachusetts.
50. Letter from John D. Tewhey, Perkins Jordan, Inc. to J. Elliott Thomas Jr., EPA
Region I (February 11, 1983). Concerning the attached analyses of 15 soil
samples from the Lowell area. .
51. "Inorganics Traffic Repon" Forms and "Organics Traffic Repon" Forms
. Package, EP A Region I (December 4, 1985).
52. "Inorganics Traffic Repon" Forms and "Organics Traffic Repon" Forms
Package, EPA Region I (Februart26, 1986 through November 13, 1986).
53. Letter from Caner P. Nulton, Roy F. Weston, Inc. to Charles A. Lindberg,
Goldberg-Zaino & Associates, Inc. (February 28, 1986). Concerning data
reports of January 27, 1986 (metals, VOAs and BNAs) and January 28, 1986
(TCDD).
54. Letter from Matthew West for Lawrence Feldman, Goldberg-Zaino &
Associates, Inc. to the Silresim Site Trustees (March 10, 1986). . Concerning
transmittal of attached laboratory repon from initial round of groundwater
samples at the Silresim site.
55. Memorandum from Michael Jasinski, GCA Corporation to David M. Webster,
EPA Region I (July 7, 1986). Concerning transmittal of copies of all GCA
Corporation sample results and accompanying split sample results.
56. "Organic Analysis Data Sheet" Forms, Aquatec, Inc. (October 11, 1986 through
November 26, 1986). Concerning organics analysis results from Phase II
swficial soil sampling at Silresim site. - .
57. "Inorganics Traffic Repon" Forms and "Organics Traffic Repon" Fonns
Package, EPA Region I (October 24, 1986 through October 28, 1986).
58. . "Inorganics Traffic Repon" Fonns and "Organics Traffic Repon" Fonns
Package, EPA Region I (November 20, 1986 through November 21, 1986).
59. "Initial Calibration Summary," (November 25, 1986). Concerning dioxin.
60. Lener from Elio Goffi, EPA Region I to Nancy Bannakian, EPA
Region I (January 8, 1987). Concerning attached data validation for Silresim
Case No. 2626A. .
61. "Inorganics Traffic Repon" Forms and "Organics Traffic Repon" Forms
. Package, EPA Region I ( January 15, 1987).
62. Lener from Charles A. Lindberg, Goldberg-Zaino & Associates, Inc. to the
Silresim Site Trust (February 2, 1987). Concerning transmittal of draft
analytical results (samples taken from November through December 1987) from
soil and groundwater sampling rounds conducted at the Silresim site.
63. Letter from Charles A. Lindberg, Goldberg-Zaino & Associates, Inc. to Joel
Balmat, EPA Region I (February 10, 1987). Concerning transmittal of attached
revised data summary and full QNQC package for dioxin analyses of samples
. 5S-16 and SS-17. .
64. Lener from Benjamin Rice, Alliance Technologies Corporation to Joel Balmat,
EPA Region I (March 4, 1987). Concerning content and transmittal of attached
data validation of Phase Two test pit samples - Case No. 6572.
65. Letter from Charles A. Lindberg, Goldberg-Zaino & Associates, Inc. to Joel
Balmat, EPA Region I (March 6, 1987). ~oncerning the transmittal of attached
QNQC packages for samples SS-16, 17, and 18, and samples SS-6, 7, 8, 10,
11, and 14.
66. "Technical Repon for USEPA - Volumes 1,2, and 3," Environmental Testing
and Certification Corp. (June 1987). Concerning 3 volumes ofraw dioxin data.
67. Letter from Roben F. Smith for Harry J. Klann, Environmental Testing and
Certification Corp. to Nancy Barmakian, EPA Region I (August II, 1987).
Concerning addendum to "Technical Repon for USEPA - Volumes 1,2, and 3,"
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Page 11
3.2
Sampling and Analysis Data (cont'd.)
68. Letter from Lewis Pillis, Centec Analytical Services, Inc. to Wayne Wirtanen,
EPA Region I (October 9, 1987). Concerning transmittal of attached inorganic
analyses data package for Case No. 8129.
69. "Regional Review of Organic Contract Laboratory Data Package," NUS
Corporation (December 10, 1987). Concerning Case No. 8129 - Scannell
Propeny.
70. Letter from Charles A. Lindberg, Goldberg-Zaino & Associates, Inc. to James
K. Rogers, Silresim Site Trust (January 4, 1989). Concerning attached soil and
groundwater data.
71. "Data Validation for the Organic Fraction of Case 10725," V ersar, Inc.
(February 14, 1989). Concerning Fall 1988 split sampling results from Camp
Dresser & McKee Inc.
3.4
Interim Deliverables
1. "Preliminary Draft - Remedial Action Master Plan," Camp Dresser & McKee
Inc. (January 10, 1983).
"Remedial Action Master Plan," Camp Dresser & McKee Inc. (April 1983).
Draft "Remedial Action Operating Plan," EPA Region I (June 1983).
Draft "Project Operations Plan" - Deliverable 1, Updated with Revisions
1 and 2, Goldberg-Zoino & Associates, Inc. for Silresim Site Trustees
(August 22, 1985).
5. Draft "Project Operations Plan - Volume I," Goldberg-Zaino & Associates, Inc.
for Silresim Site Trustees (October 1985). .
,6. Draft "Project Operations Plan - Volume n" - Revision 1, Updated with
Revisions 1 and 2, Goldberg-Zaino & Associates, Inc. for Silresim Site
Trustees (October 1985).
7. Draft - "Phase One Sampling Plan" - Deliverable 2, Goldberg-Zaino &
Associates, Inc. for Silresim Site Trustees (December 1985). .
8. Final - "Project Operations Plans - Volume I" - Deliverable 1, Revision 2,
Goldberg-Zoino & Associates, Inc. for Silresim Site Trustees (January 1986).
9. Final - "Project Operations Plans - Volume n" - Deliverable 1, Revision 2,
Goldberg-Zaino & Associates, Inc. for Silresim Site Trustees (January 1986).
10. "Use of Barcad Instruments for Groundwater Monitoring," Goldberg-Zaino &
Associates, Inc. for Silresim Site Trustees (January 1986).
11. "Phase One Sampling Plan" - Deliverable 2, Revision 1, Goldberg-Zoino &
Associates, Inc. for Silresim Site Trustees (February 1986).
12. Letter from John E. Ayres, Goldberg-Zaino & Associates, Inc. to Silresim Site
Trustees (May 30, 1986). Concerning transmittal of the outline of a proposed
air vent sorbent tube sampling program for the Silresim site (Deliverable - 4).
13. "Preliminary Results - Phase I Sampling" - Deliverable 3, Goldberg-Zaino &
Associates, Inc. for Silresim Site Trustees (May 1986).
14. "Phase Two Sampling Plan" - Deliverable 4, Goldberg-Zaino & Associates, Inc.
for Silresim Site Trustees (June 1986).
15. "Phase Two Sampling Plan" - Revised Deliverable 4, Goldberg-Zaino &
Associates, Inc. for Silresim Site Trustees (August 1986).
16. Letter from Charles A. Lindberg for Lawrence Feldman, Goldberg-Zaino &
Associates, Inc. to Silresim Site Trust (October 1, 1986). Concerning proposed
"Phase n Groundwater Sampling and Analysis Plan" for the Silresim site
(expands on section 3.50 of Deliverable 4).
17. Letter Repon from Charles A. Lindberg for Lawrence Feldman, Goldberg-Zoino
& Associates, Inc. to Silresim Site Trustees (October 10, 1986). Concerning
protocol for vent air sampling. .
18. "Phase Two Sampling Plan" - Revised Deliverable 4, Goldberg-Zaino &
Associates, Inc. for Silresim Site Trustees (November 1986).
2.
3.
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Page 12
3.4
Interim Deliverables (cont'd.)
19. "Preliminary Results - Phase Two Sampling" - Deliverable 5, Goldberg-Zoino &
Associates, Inc. for Silresim Site Trustees (December 1986).
20. "Site-Specific Health and Safety Plan - Remedial Investigation Addendum -
Silresim Site," Goldberg-Zoino & Associates, Inc. for Si1resim Site Trustees'
(October 1988).
21. Letter from Charles A. Lindberg, Goldberg-Zoino & Associates, Inc. to James
K. Rogers, Silresim Site Trust (December 29, 1988). Concerning transmittal of
attached addenda to Remedial Investigation Work Plans.
22. Letter from Charles A. Lindberg, Goldberg-Zoino & Associates, Inc. to James
K. Rogers, Silresim Site Trust (May 25, 1990). Concerning the attached map
and "Seismic Refraction Survey," Weston Geophysical Corporation for
Goldberg-Zoino & Associates, Inc. (April 1990).
23. Letter from William R. Swanson, CDM Federal Programs Corporation to Leslie
Mc Vickar, EP A Region I (September 6, 1990). Concerning the attached "Health
and Safety Plan," CDM Federal Programs Corporation (September 5, 1990).
Comments
24. Comments Dated January 19, 1983 from Thomas F. McLoughlin,
Commonwealth of Massachusetts Department of Environmental Quality
Engineering on the January 10, 1983 "Preliminary Draft - Remedial Action
Master Plan," Camp Dresser & McKee Inc.
25. Comments Dated January 25, 1983 from Norine Danley, Lowell Fair Share on
the January 10, 1983 "Preliminary Draft - Remedial Action Master Plan," Camp
Dresser & McKee Inc.
26. CommentS Dated March 4, 1983 from Thomas F. Mcloughlin, Commonwealth
of Massachusetts Department of Environmental Quality Engineering on the
January 10. 1983 "Preliminary Draft - Remedial Action Master Plan," Camp
Dresser & McKee Inc.
27. Comments Dated April 22, 1983 from Thomas F. McLoughlin, Commonwealth
of Massachusetts Department of Environmental Quality Engineering on the
Apri11983 "Remedial Action Master Plan," Camp Dresser & McKee Inc.
28. Comments Dated July 12, 1983 from Bruce Maillet, Commonwealth of
Massachusetts Department of Environmental Quality Engineering on the
June 1983 Draft "Remedial Action Operating Plan," EPA Region I.
29. Comments Dated July 12, 1983 from Wesley E. Straub, U.S. Department of
Health and Human Services on the June 1983 Draft "Remedial Action Operating
. Plan," EP A Region I.
30. Comments Dated September 3, 1985 from Philip Gschwend, Massachusetts
Institute of Technology Department of Civil Engineering on the August 22, 1985
Draft "Project Operations Plan" - Deliverable 1, Goldberg-Zoino & Associates,
Inc. for Silresim Site Trustees.
31. Comments Dated September 4, 1985 from Phyllis Robey, Lowell Fair Share on
the August 22, 1985 Draft "Project Operations Plan" - Deliverable 1,
Goldberg-Zoino & Associates, Inc. for Silresim Site Trustees with attached
"Proposal for a Technical Assistance Grant"
32. Comments Dated September 24,.1985 from David M. Webster, EPA Region I
on the August 22, 1985 Draft "Project Operations Plan" - Deliverable 1,
Goldberg-Zoino & Associates, Inc. for Silresim Site Trustees.
33. Letter from David M. Webster, EPA Region I to James K. Rogers, Silresim Site
Trust (October 8, 1985). Concerning transmittal of attached CommentS Dated
October 1, 1985 from Charles Porfen, EPA Region I on the August 22, 1985
Draft "Project Operations Plan" - Deliverable 1, Goldberg-Zoino & Associates,
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Page 13
3.4
Interim Deliverables (cont'd.)
Comments
34. Letter from Heather M. Ford, EPA Region I to James K. Rogers, Silresim Site
Trust (November 18, 1985) with attached Comments from EPA Region I on the
August 22, 1985 Draft "Project Operations Plan" - Deliverable 1, .
Goldberg-Zoino & Associates, Inc. for Silresim Site Trustees. Concerning
conditional approval of the "Project Operations Plan" - Deliverable 1,
Revision 1, Goldberg-Zoino & Associates, Inc. for Silresim Site Trustees
(October 1985).
35. Comments Dated January 10, 1986 from David M. Webster, EPA Region I on
the December 1985 Draft - "Phase One Sampling Plan" - Deliverable 2,
Goldberg-Zoino & Associates, Inc. for Silresim Site Trustees.
36. Comments Dated January 15, 1986 from James Thomas, Roben-Clemens, and
Michael Jasinski, GCA Corporation on the December 1985 Draft - "Phase One
Sampling Plan" - Deliverable 2, Goldberg-Zoino & Associates, Inc. for Silresim
Site Trustees with anached "A Laboratory Evaluation of Ground Water
Sampling Mechanisms," M.J. Barcelona, J.A. Helfrich, E~E. Garske, and J.P.
Gibb. .-
37. Comments Dated January 21, 1986 from Julio C. Olimpio, U.S. Department of
the Interior Geological Survey Water Resources Division on the December 1985
Draft - "Phase One Sampling Plan" - Deliverable 2, Goldberg-Zoino &
Associates, Inc. for Silresim Site Trustees. .
38. Comments Dated January 28, 1986 from Heather M. Ford, EPA Region Ion the
December 1985 Draft - "Phase One Sampling Plan" - Deliverable 2,
Goldberg-Zoino & Associates, Inc. for Silresim Site Trustees.
39. Comments Dated February 6, 1986 from Heather M. Ford, EPA Region I on the
December 1985 Draft - "Phase One Sampling Plan" - Deliverable 2,
Goldberg-Zoino & Associates, Inc. for Silresim Site Trustees. .
40. Comments and Approval Dated February 24, 1986 from Heather M. Ford, EPA
Region I on the December 1985 Draft - "Phase One Sampling Plan" - Deliverable
2, Goldberg-Zoino & Associates, Inc. for Silresim Site Trustees.
41. Comments Dated February 28,1986 from Philip Gschwend, Massachusetts
Institute of Technology Department of Civil Engineering on the December 1985
Draft - "Phase One Sampling Plan" - Deliverable 2, Goldberg-Zoino &
Associates, Inc. for Silresim Site Trustees. - .
42. Comments and Approval Dated May 13, 1986 from David M. Webster, EPA
Region I on the May 1986 "Preliminary Results - Phase I Sampling" -
Deliverable 3, Goldberg-Zoino & Associates, Inc. for Silresim Site Trustees.
43. Comments Dated June 23, 1986 from Richard J. Chalpin, Commonwealth of
Massachusetts Department of Environmental Quality Engineering on the .
May 1986 "Preliminary Results - Phase I Sampling" - Deliverable 3,
. Goldberg-Zaino & Associates, Inc. for Silresim Site Trustees.
44. Comments Dated July 10, 1986 from Philip Gschwend, Massachusetts Institute
of Technology Department of Civil Engineering on the June 1986 "Phase Two
Sampling Plan" - Deliverable 4, Goldberg-Zoino & Associates, Inc. for
Si1resim Site Trustees. -
45. Comments Dated July 21, 1986 from Richard J. Chalpin, Commonwealth of
Massachusetts Department of Environmental Quality Engineering on the June
1986 "Phase Two Sampling Plan" - Deliverable 4, Goldberg-Zoino &
Associates, Inc. for Silresim Site Trustees.
46. Draft Comments Dated August 4, 1986 on the June 1986 "Ph~ Two Sampling
Plan" - Deliverable 4, Goldberg-Zoino & Associates, Inc. for Silresim Site.
Trustees.
47. Comments Dated August 13, 1986 from David M. Webster, EPA Region Ion
the June 1986 "Phase Two Sampling Plan" - Deliverable 4, Goldberg-Zoino &
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3.4
Page 14
Interim Deliverables (cont'd.)
Comments
48. Comments and Conditional Approval Dated September 18,1986 from David M.
Webster, EPA Region I on the August 1986 "Phase Two Sampling Plan"-
Revised Deliverable 4, Goldberg-Zoino & Associates, Inc. for Si1resim Site
Trustees.
49. Comments Dated October 16, 1986 from Peter R. Kahn, EPA Region I on the
October 10, 1986 Letter Report Concerning Protocol for Vent Air Sampling,
Goldberg-Zoino & Associates, Inc. .
50. Comments and EP A Conditional Approval Dated October 20, 1986 from Joel
Balmat, EPA Region I on the October 10, 1986 Letter Report Concerning
Protocol for Vent Air Sampling, Goldberg-Zoino & Associates, Inc.
51. Comments Dated November 21, 1986 from David M. Webster, EPA Region I
on the "Phase Two Sampling Plan" - Revised Deliverable - 4, Goldberg-Zoino
& Associates, Inc. for Silresim Site Trustees. .
52. Comments and Approval Dated February 2, 1987 from Heather M. Ford, EP A
Region I on the December 1986 "Preliminary Results - Phase Two Sampling"-
Deliverable 5, Goldberg-Zoino & Associates, Inc. for Silresim Site Trustees.
Responses to Comments.
3.6
53. Response Dated March 9, 1983 from Merrill S. Hohman, EPA Region Ion the
January 25, 1983 Comments from Norine Danley, Lowell Fair Share.
54. Response Dated November 27, 1985 from James K. Rogers, Silresim Site Trust
and John E. Ayres, Goldberg-Zoino & Associates, Inc. to the
November 18, 1985 Letter from Heather M. Ford, EP A Region I.
55. Response Dated December 20, 1985 from Heather M. Ford, EPA Region I to
the November 27, 1985 Response from James K. Rogers, Silresim Site Trust
and John E. Ayres, Goldberg-Zoino & Associates, Inc.
56. Response Dated January 22, 1986 from John E. Ayres, Goldberg-Zoino &
Associates, Inc. to the January 10, 1986 Comments from David M. Webster,
EP A Region 1.
57. Response Dated May 30, 1986 from Lawrence Feldman, Goldberg-Zoino &
Associates, Inc. to the May 13, 1986 Comments and Approval from David M.
Webster, EPA Region 1.
Remedial Investigation (RI) Reports
1.
2.
"Draft - Remedial Investigation Report - Volume I" - Deliverable 6,
Goldberg-Zoino & Associates, Inc. for Silresim Site Trust (March 1987).
''Draft - Remedial Investigation Report - Volume II" -.Deliverable 6,
Goldberg-Zoino & Associates, Inc. for Silresim Site Trust (March 1987).
'Draft - Remedial Investigation Report - Volume m" - Deliverable 6,
Goldberg-Zoino & Associates, Inc. for Silresim Site Trust (March 1987).
"Draft - Remedial Investigation Report - Volume IV" - Deliverable 6,
Goldberg-Zoino & Associates, Inc. for Silresim Site Trust (March 1987).
"Draft - Remedial Investigation Report - Revised Chapters 5, 6, and 7,"
Goldberg-Zoino & Associates, Inc. for Silresim Site Trust
(September 30, 1988).
"Revised Draft Report - Remedial Investigation - Volume I," Goldberg-Zoino &
Associates, Inc. for Silresim Site Trust (April 1989). .
"Revised Draft Report - Remedial Investigation - Volume II - Tables,"
Goldberg-Zoino & Associates, Inc. for Silresim Site Trust (April 1989).
"Revised Draft Report - Remedial Investigation - Volume m," Goldberg-Zoino
& Associates, Inc. for Silresim Site Trust (April 1989).
3.
4.
5.
6.
7.
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Page 15
3.6
Remedial Inve$tigation (RI) Repons (cont'd.)
9. "Revised Draft Report - Remedial Investigation - Volume IV - Appendices A-F."
Goldberg-Zoino & Associates, Inc. for Silresim Site Trust (April 1989).
10. "Revised Draft Report - Remedial Investigation - Volume V - Appendices G-J,"
Goldberg-Zoino & Associates, Inc. for Silresim Site Trust (April 1989).
11. "Revised Draft Report - Remedial Investigation - Volume VI - Appendices
K-M," Goldberg-Zoino & Associates, Inc. for Silresim Site Trust (Apri11989).
12. "Revised Draft Report - Remedial Investigation - Volume vn - Appendices
. N-O," Goldberg-Zoino & Associates, Inc. for Silresim Site Trust (April 1989).
13. "Revised Draft Report - Remedial Investigation - Volume VIII - Appendices
P-R," Goldberg-Zoino & Associates, Inc. for Silresim Site Trust (April 1989).
14. "Revised Draft Report - Remedial Investigation - Volume I," Goldberg-Zoino &
Associates. Inc. for Silresim Site Trust (September 1989). .
15. "Revised Draft Report - Remedial Investigation - Volume II," Goldberg-Zoino &
Associates, Inc. for Silresim Site Trust (September 1989).
16. "Revised Draft Report - Remedial Investigation - Volume ill," Goldberg-Zoino
& Associates. Inc. for Silresim Site Trust (September 1989).
17. "Final Draft Report - Remedial Investigation - Volume I," Goldberg-Zoino &
Associates, Inc. for Silresim Site Trust (March 1990).
18. "Final Draft Report - Remedial Investigation - Volume II," Goldberg-Zoino &
Associates, Inc. for Silresim Site Trust (March 1990).
19. "Final Draft Report - Remedial Investigation - Volume ill," Goldberg-Zoino &
Associates, Inc. for Silresim Site Trust (March 1990). .
20. "Final Draft Report - Remedial Investigation - Volume IV," Goldberg-Zoino &
Associates. Inc. for Silresim Site Trust (March 1990).
21. "Final Draft Report - Remedial Investigation - Volume V," Goldberg-Zoino &
Associates. Inc. for Silresim Site Trust (March 1990).
22. "Final Draft Report - Remedial Investigation - Volume VI," Goldberg-Zoino &
Associates, Inc. for Silresim Site Trust (March 1990). .
23. "Final Draft Report - Remedial Investigation - Volume vn," Goldberg-Zoino &
Associates, Inc. for Silresim Site Trust (March 1990).
24. "Final Draft Report - Remedial Investigation - Volume VIII," Goldberg-Zoino &
Associates, Inc. for Silresim Site Trust (March 1990).
25. "Final Draft Remedial Investigation Addendum - Volume I," CDM Federal
Programs Corporation (] une 1991).
26. ''Final Draft Remedial Investigation Addendum - Volume II," CDM Federal
Programs Corporation (June 1991).
Comments
27. Comments Dated April 16. 1987 from Lawrence Feldman for Charles A.
Lindberg, Goldberg-ZOino & Associates, Inc. on the March 1987 "Draft-
Remedial Investigation Repon" - Deliverable 6, Goldberg-Zoino & Associates,
Inc. for Silresim Site Trust.
28. Comments Dated April 28. 1987 from Dodie Brownlee, Commonwealth of
Massachusetts Department of Environmental Quality Engineering on the
March 1987 "Draft - Remedial Investigation Report" - Deliverable 6.
Goldberg-Zoino & Associates, Inc. for Silresim Site Trust. .
29. Comments Dated April 29, 1987 from Philip Gschwend, Massachusetts Institute
of Technology Department of Civil Engineering on the March 1987 "Draft-
Remedial Investigation Report" - Deliverable 6, Goldberg-Zoino & Associates,
Inc. for Silresim Site Trust.
30. Comments Dated May 18, 1987 from Richard J. Chalpin, Commonwealth of
Massachusetts Department of Environmental Quality Engineering on the
March 1987 "Draft - Remedial Investigation Report" - Deliverable 6.
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Page 16
3.6
Remedial Investigation (RI) Reports (cont'd.)
Comments
31. Final Draft Comments Dated August 21, 1987 from Joel Balmat, EPA Region I
on the March 1987 "Draft - Remedial Investigation Report" - Deliverable 6,
Goldberg-Zoino & Associates, Inc. for Silresim Site Trust.
32. Comments Dated September 30, 1987 from Margaret J. Leshen, EPA Region I
on the March 1987 "Draft - Remedial Investigation Repon" - Deliverable 6,
Goldberg-Zoino & Associates, Inc. for Silresim Site Trust.
33. Comments Dated December 7, 1988 from Leslie McVickar, EPA Region I on the
September 30,1988 "Draft - Remedial Investigation Report - Revised Chapters
. 5,6, and 7," Goldberg-Zoino & Associates, Inc. for Silresim Site Trust
34. Comments from Phillip L. Scannell Jr., Scannell Boiler Works on the
March 1987 "Draft - Remedial Investigation Report" - Deliverable 6,
Goldberg-Zoino & Associates, Inc. for Silresim Site Trust.
35. Comments from Ayer City Homeowners Association on the March 1987 "Draft-
Remedial Investigation Repon" - Deliverable 6, Goldberg-Zoino & Associates,
Inc. for Silresim Site Trust. .
36. Corrections Dated May 22, 1989 from Charles A. Lindberg, Goldberg-Zoino &
Associates, Inc. on the April 1989 "Revised Draft Repon - Remedial
Investigation," Goldberg-Zoino & Associates, Inc. for Silresim Site Trust.
37. Comments Dated June 16, 1989 from Leslie McVickar, EPA Region I on the
April 1989 "Revised Draft Repon - Remedial Investigation," Goldberg-Zoino &
Associates, Inc. for Silresim Site Trust. .
38. Comments Dated June 30, 1989 from Leslie McVickar, EPA Region I on the
ApriI1989 "Revised Draft Repon - Remedial Investigation," Goldberg-Zoino &
Associates, Inc. for Silresim Site Trust with the attached:
A. Comments Dated May 15, 1989 from Kenneth Finkelstein, U.S.
Department of Commerce National Oceanic and Atmospheric
Administration on the April 1989 "Revised Draft Report - Remedial
Investigation," Goldberg-Zoino & Associates, Inc. for Silresim Site Trust
with attached .Comments Dated August 13, 1987 from Kenneth Finkelstein
for Lawrence E. Keister, U.S. Deparnnent of Commerce National Oceanic
and Atmospheric Administration on the March 1987 'Draft - Remedial
Investigation Repon," Goldberg-Zoino & Associates, Inc. for Silresim
Site Trust.
B. Comments Dated May 25, 1989 from Roben Adler, EP A Region I on the
April 1989 "Revised Draft Repon - Remedial Investigation," Go1dberg-
Zoino & Associates, Inc. for Silresim Site Trust.
C. Memorandum from Boyd Allen, Commonwealth of Massachusetts
Department of Environmental Quality Engineering to Helen Waldorf,
Commonwealth of Massachusetts Department of Environmental Quality
Engineering (June 20, 1988). Concerning Superfund sites and Class III
designation.
D. Memorandum from Roben Adler, EPA Region I to Jane Downing, EPA
. Region I (February 17, 1989). Concerning ground water classification
and ARAR compliance at the Sullivan's'Ledge SupeIfund Site.
E. "Massachusetts Drinking Water Standards and Guidelines,"
Commonwealth of Massachusetts Department of Environmental Quality
Engineering (March 1989).
39. Comments Dated December 13, 1989 from Leslie McVickar, EPA Region I on
the September 1989 "Revised Draft Report - Remedial Investigation,"
Goldberg-Zoino & Associates, Inc. for Silresim Site Trust with the attached
Comments Dated October 10, 1989 from Kenneth Carr, U.S. Department of the
Interior Fish and Wildlife Division on the September 1989 "Revised Draft
Report - Remedial Investigation," Goldberg-Zoino & Associates, Inc. for
-------
t'age 1 "7
3.6
Remedial Investigation (RI) Repons (cont'd.)
Responses to Comments
3.7
40. Response Dated June 16, 1987 from Joel Balmat, EPA Region I to Comments
from Phillip L. Scannell, Jr., Scannell Boiler Works.
41. Response Dated November 4, 1987 from Charles A. Lindberg and John E.
Ayres, Goldberg-Zaino & Associates, Inc. to the September 30,1987
Comments from Margaret J. Leshen, EPA Region I.
42. Response Dated March 2,1990 from Charles A. Lindberg, Goldberg-Zaino &
Associates, Inc. to the December 13, 1989 Comments from Leslie McVickar,
EP A Region I.
Work Plans and Progress Repons
1.
2.
"Work Plan - Remedial Investigation/Feasibility Study of Alternatives," NUS
Corporation (September 1983).
"Work Plan for an RIlFS of the Silresim Site," Goldberg-Zaino & Associates,
Inc. and Roy F. Weston, Inc. (April 1984). .
"Remedial Investigation/Feasibility Study - RI/FS - Work Plan," Camp Dresser
& McKee Inc. (February 11, 1985).
"Remedial Investigation/Feasibility Study - RI/FS - Work Plan - Appendix B,"
Camp Dresser & McKee Inc. (February II, 1985).
Trip Repon on a Visit to Silresim Site, Peter Hall, GCA Corporation
(March 3, 1986). Concerning technical oversight of Goldberg-Zaino &
Associates, Inc.'s sampling activities.
Cross-Reference: Memorandum from Peter R. K,ahn, EPA Region I to Leslie
McVickar, EPA Region I (October 3, 1988). Concerning the tran~mittal of
attached revised "Indoor Air Toxics Study Work Plan - Lowell Iron and Steel,
Co.," EPA Region I (September 1988) [Filed and cited as entry number 39 in
. 3.2 Sampling and Analysis Data]. .'
Cross-Reference: Memorandum from Peter R. Kahn, EPA Region I to Leslie
McVickar, EPA Region I (November 30, 1988). Concerning the transmittal of
attached "Indoor Air Toxics Study Work Plan - Administration Building -
Lowell Iron and Steel Company," EPA Region I (November 1988) [Filed and
cited as entry number 43 in 3.2 Sampling and Analysis Data].
"Trip Repon, Soil Sample Collection at the Silresim Superfund Site,
December 26-28, 1990," CDM Federal Programs Corporation (March 5, 1991).
Letter from William Holden, CDM Federal Programs Corporation to Leslie
McVickar, EPA Region I (April 16, 1991). Concerning the attached "Trip
Repon, Groundwater Sample Collection at the Silresim Superfund Site,
February 4-8, 1991."
3
4.
5.
6.
7.
8.
9.
. Comments
10. Comments Dated May 10, 1985 from James C. Colman, Commonwealth of
Massachusetts Department of Environmental Quality Engineering on the
February II, 1985 "Remedial Investigation/Feasibility Study - Work Plan,"
Camp Dresser & McKee Inc.
11. Letter from Charles A. Lindberg, Goldberg-Zaino & Associates, Inc. to James
K. Rogers, Silresim Site Trust (October 7, 1988) with attached Comments from
Leslie McVickar, EPA Region I on the August 1988 "Silresim Remedial
Investigation Additional Sampling Work Plan," and attached "Silresim Remedial
Investigation - Revised Addendum Work Plan," Goldberg-Zaino & Associates,
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Page 18
3.9
Health Assessments
1. Memorandum from Christine 1. Spadafor, EPA Region I to Leslie Carothers,
EPA Region I (July 27, 1982). Concerning health surveys and health
investigations for hazardous waste sites in Region I.
2. Memorandum from Georgi A. Jones, U.S. Department of Health and Human
Services Public Health Service Centers for Disease Control to John Figler, EPA
Region I (October 27,1982). Concerning a review of Silresim Superfund site.
3. Memorandum from Chester L. Tate Jr. and Thomas K. Welty, Department of
Health and Human Services Public Health Service Centers for Disease Control
to Assistant Director for Program, U.S. Department of Health and Human
Services Public Health Service Centers for Disease Control (June 30, 1983).
Concerning attachments regarding issue of temporary relocation of residents
during structural demolition and clay capping.
4. "Silresim Area Health Study - Report of Findings - Executive Summary," Center
for Survey Research, University of Massachusetts-Boston and Boston
University School of Public Health for Commonwealth of Massachusetts
Department of Environmental Quality Engineering (November 22,1983).
5. Comments from Ayer City Homeowners and Renters Association on the
November 22, 1983 "Silresim Area Health Study - Report of Findings -
Executive Summary," Center for Survey Research, University of
Massachusetts-Boston and Boston University School of Public Health for
Commonwealth of Massachusetts Department of Environmental Quality
Engineering.
6. Memorandum from Marilyn R. DiSirio, U.S. Department of Health and Human
Services Public Health Service Agency for Toxic Substances and Disease
Registry to Joel Balmat, EPA Region I (January 12, 1986). Concerning
reconunendation to fence or temporarily cover contaminated area to protect the
public health.
7. M~morandum from David Fornez Jr. for Jeffrey A. Lybarger, U.S. Department
of Health and Human Services Public Health Service Agency for Toxic
Substances and Disease Registry to Marilyn R. DiSirio, U.S. Department of
Health and Human Services Public Health Service Agency for Toxic Substances
and Disease Registry (August 8, 1986). Concerning recommendation for
additional soil sampling to defme perimeter of contamination and extend
restricted area.
8. Memorandum from Louise A. House, U.S. Department of Health and Human
Services Public Health Service Agency for Toxic Substances and Disease
Registry to Ira Leighton, EPA Region I (December 10, 1987). Concerning issue
of immediate removal action.
9. Memorandum from Louise A. House, U.S. Department of Health & Human
Services Public Health Service Agency for'Toxic Substances and Disease '
Registry to Leslie ¥cVickar, EPA Region I (March 5, 1989). Concerning health
consultation on indoor air samples at the Silresim site and Lowell Iron and Steel
Company.
10. Letter from John B. Miles Jr., U.S. Department of Labor Occupational Safety
and Health Administration to Leslie Mc Vickar, EP A Region I (March 8, 1989).
Concerning review of indoor air samples. . .
11. Letter from Leslie Mc Vickar, EP A Region I to Philip L. Scannell Jr., Lowell
Iron and Steel Company (March 16, 1989). Concerning transmittal of attached
A TSDR and OSHA Health Assessment for Indoqr Air Samples taken
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Page 19
4.0
Feasibility Study (FS)
4.1 CoITespondence
4.2
Letter from RuthAnn Shennan, EPA Region I to Susan M. Cooke, Goodwin,
Procter & Hoar (Attorney for Silresim Site Trust) (October 3, 1990).
Concerning the site MCP Risk Assessment Addendum.
Letter from Leslie McVickar, EPA Region I to Evelyn Tapani, Commonwealth
of Massachusetts Department of Environmental Protection (February 12, 1991).
Concerning the state's need to respond to EPA comments on the December 1990
"Draft Deliverable FS-3 Detailed Analysis of Alternatives," Goldberg-Zoino &
Associates for Silresim Site Trust
Letter from Evelyn Tapani, Commonwealth of Massachusetts Department of
Environmental Protection to James K. Rogers,' Silresim Site Trust
(April 17, 1991). Concerning Notice of Response Action requiring compliance
to implement a remedial action at the site. .
Letter from Leslie McVickar, EPA Region I to Evelyn Tapani, Commonwealth
of Massachusetts Department of Environmental Protection (May 2, 1991).
Concerning transmittal of the May 1991 "Draft Feasibility Study Report," GZA
GeoEnvironmental, Inc. for Silresim Site Trust and request for comments.
Letter from Leslie McVickar, EPA Region I to Evelyn Tapani, Massachusetts
Department of Environmental Protection (May 16, 1991). Concerning
transmittal of the "First Draft Silresim Proposed Plan" and request for
comments.
Letter from Evelyn Tapani, Commonwealth of Massachusetts Department of
Environmental Protection to Charles A. lindberg, Goldberg-Zoino &
Associates, Inc. (May 31, 1991). Concerning completion of the MCP risk
assessment addendum.
Letter from Charles A. lindberg, Goldberg-Zoino & Associates, Inc. to Evelyn
Tapani, Commonwealth of Massachusetts Department of Environmental
Protection (June 7, 1991). Concerning completion of the MCP risk assessment
addendum.
Letter from RuthAnn Shennan, EPA Region I to Susan M. Cooke, Goodwin,
Procter & Hoar (Attorney for Silresim Site Trust) (June 27, 1991). Concerning
approval of the June 1991 "Final Draft Feasibility Study Repon - Volumes'
I-IV," GZA GeoEnvironmental, Inc. for Silresim Site Trust.
Sampling and Analysis Data
1.
2.
3.
4.
5.
6.
7.
8.
1.
Letter from James K. Rogers, Silresim Site Trust to Leslie McVickar, EPA
Region I (September 11, 1989). Concerning request by the National Oceanic
and Atmospheric Administration (NOAA) for additional water and surface
samples with attached:
A. "Proposed Additional Sampling River Meadow Brook," Goldberg-Zoino
& Associates, Inc. for Silresim Site Trust
B. "Proposed Surface Water/Sediment Sampling Location Plan,"
Goldberg-Zaino & Associates, Inc. for Silresim Site Trust (August 1989).
Letter from Charles A. lindberg, Goldberg-Zaino & Associates, Inc. to James
K. Rogers, Silresim Site Trust (February 5, 1990). Concerning transmittal of
the attached sampling results from River Meadow Brook.
Letter from Charles A. lindberg, Goldberg-Zaino & Associates to James K.
Rogers, Silresim Site Trust (November 8, 1990). Concerning the status of the
soil treatability studies.
Letter from Mei Ching Tse and Anita C. Rigassio, Camp Dresser & McKee, Inc.
to Dennis P. Gagne, EPA Region I (July 16, 1991). Concerning results of
water samples.
2.
3.
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Page 20
4.2
Sampling and Analysis Data (cont'd.)
5.
Letter from Mei Ching Tse and Anita C. Rigassio, Camp Dresser & McKee, Inc.
to Dennis P. Gagne, EPA Region I (July 17, 1991). Concerning results of
water and soil samples.
CommentS
6.
4.3
CommentS Dated February 15, 1990 from Kenneth Finkelstein, U.S.
Department of Commerce National Oceanic and Atmospheric Administration on
the results of the"Proposed Additional Sampling River Meadow Brook,"
Goldberg-Zoino & Associates, Inc. for Silresim Site Trust.
Scopes of Work
1.
"Work Plan for Silresim DNAPL Investigation -- Feasibility Addendum,
Volume I -- Technical Scope of Work ," CDM Federal Programs Corporation
~~1~~ . . .
"Attachment I - Technical Memorandum - Scope of Work - Additional Sampling
for Feasibility Study Addendum," CDM Federal Programs Corporation
(June 1991).
2.
4.4
Interim Deliverables
Repons
1. "Development of Remedial Alternatives - Deliverable FS-1," Goldberg-Zoino &
Associates, Inc. for Silresim Site Trust (December 1988).
2. . "Alternatives Array Document," Goldberg-Zoino & As~ociates, Inc. for Silresim
Site Trust (August 1989). . .
3. "Deliverable FS-2 - Remedial Alternatives Screening," Goldberg-Zoino &
Associates, Inc. for Silresim Site Trust (November 1989).
4. "Revised Deliverable FS-2 Remedial Alternatives Screening," Goldberg-Zoino
& Associates for Silresim Site Trust (July 1990).
5. "Draft Deliverable FS-3 Detailed Analysis of Alternatives - Volume I,"
Goldberg-Zoino & Associates for Silresim Site Trust (December 1990).
6. "Draft Deliverable FS-3 Detailed Analysis of Alternatives - Volume n,"
Goldberg-Zoino & Associates for Silresim Site Trust (December 1990).
7. "Draft Deliverable FS-3 Detailed Analysis of Alternatives - Volume m,"
Goldberg-Zoino & Associates for Silresim Site Trust (December 1990).
8. "Draft - MassachusettS Contingency Plan Risk Assessment Addendum," GZA
GeoEnvironmental, Inc. for. Commonwealth of Massachusetts on behalf of
Silresim Site Trust (June 1991).
CommentS
9. Comments Dated January 18, 1989 from Leslie McVickar, EPA Region Ion the
December 1988 "Development of Remedial Alternatives - Deliverable FS-l,"
Goldberg-Zoino & Associates, Inc. for Silresim Site Trust.
10. Comments Dated February 1, 1990 from Leslie Me Vickar, EP A Region I on the
. November 1989 "Deliverable FS-2 - Remedial Alternatives Screening,"
Goldberg-Zoino & Associates, Inc. for Silresim Site Trust.
11. Letter from Leslie McVickar, EPA Region I to James K. Rogers, Silresim Site
Trust (May 22, 1990). Concerning the submittal of Revised Deliverable FS-2.
12. CommentS Dated July 13, 1990 from Charles A. Lindberg, Goldberg-Zoino &
Associates on the July 1990 "Revised Deliverable FS-2 Remedial Alternatives
-------
4.5
Page 21
4.4
Interim Deliverables (cont'd.)
13. Letter from Charles A. Lindberg, Goldberg-Zoino & Associates to James K.
Rogers, Silresim Site Trust (August 1, 1990). Concerning errors in the Revised
Deliverable FS-2 Remedial Alternatives Screening.
Comments
14. Comments Dated September 11, 1990 from Leslie McVickar, EPA Region I on
the July 1990 "Revised Deliverable FS-2 Remedial Alternatives Screening,"
Goldberg-Zoino & Associates for Silresim Site Trust
15. Comments Dated February II, 1991 from Leslie McVickar, EPA Region Ion
the "Draft Deliverable FS-3 Detailed Analysis of Alternatives," Goldberg-Zoino
& Associates for Silresim Site Trust .
16. Comments Dated April 3, 1991 from Leslie McVickar, EPA Region I on the
December 1990 "Draft Deliverable FS-3 Detailed Analysis of Alternatives,"
Goldberg-Zoino & Associates for Silresim. Site Trust
Responses to Comments
17. Lenerfrom James K. Rogers, Silresim Site Trust to Leslie McVickar, EPA
Region I (February'27, 1991). Concerning late response to EPA's Draft
Comments on the December 1990 :'Draft Deliverable FS- 3 Detailed Analysis of
Alternatives," Goldberg-Zoino & Associates for Silresim Site Trust,
18. Response Dated March 5, 1991 from Charles A. Lindberg, Goldberg-Zoino &
Associates on the February 11, 1991 Comments from Leslie McVickar, EPA
Region I.
19. Response Dated May I, 1991 from Charles A. Lindberg, Goldberg-Zoino &
Associates on the February 11, 1991 and April 3, 1991 Comments from Leslie
Mc Vickar, EP A Region I.
Applicable or Relevant and Appropriate Requirements (ARARs)
1.
Cross-Reference: Lener from M. Gretchen Muench, EPA Region I to Donald
Nagle Commonwealth of Massachusetts Department of Environmental
Protection (April 12, 1991). Concerning the attached:
A. Letter from William Walsh-Rogalski, EPA Region I to Peter R. Bronson,
Commonwealth of Massachusetts Department of Environmental Protection
(January 3, 1991). Concerning transmittal of portions of the brief filed
concerning the F.T. Rose Disposal Pit site.
B. Letter from William Walsh-Rogalski, EPA Region I to Peter R. Bronson,
Commonwealth of Massachusetts Department of Environmental Protection
(January 9, 1991). Concerning the attached portions of the F.r. Rose
Disposal Pit site brief [Filed and cited as entry number 5 in 9.1
Correspondence].
Cross-Reference: Letter from Peter R. Bronson, Commonwealth of
Massachusens Department of Environmental Protection to William
Walsh-Rogalski, EPA Region I (April 22, 1991). Concerning identifying the
Massachusetts Contingency Plan (MCP) in the ARAR process [Filed and cited
as entry number 6 in 9.1 Correspondence].
"Final Assessment of LDR's," CDM Federal Programs Corporation
(June 6, 1991).
Cross-Reference: "Draft - Massachusens Contingency Plan Risk Assessment
Addendum," GZA GeoEnvironmental, Inc. for Commonwealth of .
Massachusens on behalf of Silresim Site Trust (June 1991) [Filed and cited as
entry number 8 in 4.4 Interim Deliverables].
2.
3.
-------
4.7
Page 22
4.6
Feasibility Study (FS) Repons
Repons
1.
2.
"Draft Feasibility Study Repon - Volume I," GZAGeoEnvironmental, Inc. for
Silresim Site Trust (May 1991). .
"Draft Feasibility Study Repon - Volume n," GZA GeoEnvironmental, Inc. for
Silresirn Site Trust (May 1991).
"Draft Feasibility Study Repon - Volume In," GZA GeoEnvironmental, Inc. for
Silresirn Site Trust (May 1991).
"Draft Feasibility Study Repon - Volume IV," GZA GeoEnvironmental, Inc. for
Silresim Site Trust (May 1991).
"Final Draft Feasibility Study Repon - Volume I," GZA GeoEnvironmental, Inc.
for Silresim Site Trust (June 1991).
"Final Draft Feasibility Study Repon - Volume n," GZA GeoEnvironmental,
Inc. for Silresim Site Trust (June 1991). .
"Final Draft Feasibility Study Repon - Volume In," GZA .GeoEnvironmental,
Inc. for Silresim Site Trust (June 1991).
"Final Draft Feasibility Study Repon - Volume IV," GZA GeoEnvironmental,
Inc. for Silresim Site Trust (June 1991).
3.
4.
5.
6.
7.
8.
Comments
9.
Comments Dated June 3,1991 from Leslie McVickar, EPA Region I on the May
1991 "Draft Feasibility Study Repon (FS-IV)," GZA GeoEnvironmental, Inc.
for Silresim Site TrusL
Comments on the Feasibility Study received by EP A Region I dwing the formal public
comment period are filed and cited in 53 Responsive Summaries.
Work Plans and Progress Repons
Draft - "Work Plan - Silresirn Feasibility Study," Goldberg-Zoino & Associates,
Inc. for Silresim Site Trust (August 1988).
"Revised Work Plan - Silresim Feasibility Study," Goldberg-Zoino &
Associates, Inc. for Silresim Site Trust (October 1988).
"Final Work Plan - Silresim Feasibility Study," Goldberg-Zoino & Associates,
Inc. for Silresim Site Trust (January 1989).
Lener from James K. Rogers, Silresim Site Trust to Leslie McVickar, EPA
Region I (August 30, 1989). Concerning the attached "Treatability Studies
Work Plan," Goldberg-Zoino & Associates, Inc. for Silresim Site Trust
(August 31, 1989).
Lener from Charles A. Lindberg, Goldberg-Zoino & Associates, Inc. to James
K. Rogers, Silresim Site Trust (November 29, 1989) with the attached
"Proposed Exploration Location Plan," Goldberg-Zoino & Associates, Inc. for
Silresim Site Trust (August 1989). Concerning a revised work plan for
geophysical studies at the site.
Comments
1.
2.
3.
4.
5.
6.
Comments Dated November 18..1988 from Leslie McVickar, EPA Region I on
the October 1988 "Revised Work Plan - Silresim Feasibility Study,"
Goldberg-Zoino & Associates, Inc. for Silresim Site Trust.
Comments Dated October 17, 1989 from Leslie Mc Vickar, EP A Region Ion the
August 31, 1989 "Treatability Studies Work Plan," Goldberg-Zoino &
Associates, Inc. for Silresim Site Trust.
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Page 23
4.7
Work Plans and Progress Reports (cont'd.)
Comments
8.
Comments Dated November 8, 1989 from Leslie McVickar, EPA Region I on
the August 31, 1989 "Treatability Studies Work Plan," Goldberg-Zoino &
Associates, Inc. for Si1resim Site Trust.
4.9
Proposed Plans for Selected Remedial Action
1.
"EPA Proposes Cleanup Plan for Silresim Superfund Site," EPA Region I
(June 1991). .
Comments
Comments on the Proposed Plan received by EP A Region I during the formtll public
comment period areflled and cited in 5.3 Responsiveness Summaries.
Record of Decision (ROD)
5.0
5.3
5.4
Responsiveness Summaries
Cross-Reference: Responsiveness Summary, EPA Region I .
(September 19,1991) [Filed and included as Appendix E in entty number 1 in
5.4 Record of Decision (ROD)].
Cross-Reference: Transcript, Public Meeting Summary, EPA Region I
(June 10, 1991) [Filed and included as Exhibit A in entty number 1 in 5.4
Record of Decision (ROD)].
The following citations indicate written comments received by EP A Region I during
the formtll public comment period.
1.
2.
3.
Comments Dated June 28, 1991 from Anne T. Fox, Commonwealth of
Massachusetts Department of Public Health on the June 1991 "EPA Proposes
Cleanup Plan for Silresim Superfund Site," EPA Region I.
Letter from Norine Brodeur to EPA Region I (July 10, 1991). Concerning a
request for an extension of time on the public comment period. .
Comments Dated August 6,1991 from John P. Scannell Jr., Scannell Boiler
Works Co., Inc. and Philip L. Scannell In, Lowell Iron & Steel Co., Inc. on the
June 1991 "EPA Proposes Cleanup Plan for Silresim Superfund Site," EPA
Region I.
Comments Dated August 19,1991 from Evelyn Tapani and Helen Waldorf,
Commonwealth of Massachusetts Department of Environmental Protection on
the June 1991 "EPA Proposes Cleanup Plan for Si1resim Superfund Site," EPA
Region I. .
Comments Dated August 20, 1991 from Susan M. Cooke, Goodwin, Procter &
Hoar (Attorney for Silresim Site Trust) on the June 1991 "EPA Proposes
Cleanup Plan for Silresim Superfund Site," EPA Region I.
Cross-Reference: Letter from Helen Waldorf, Commonwealth of Massachusetts
Department of Environmental Protection to Leslie McVickar, EPA Region I
(September 13,1991). Concerning clarification of state ARARs [Filed and cited
as entty number number 7 in 9.1 Correspondence].
4.
5.
6.
7.
8.
Record of Decision (ROD)
1.
-------
9.0
9.1
State Coordination
Page 24
Correspondence
1.
Letter from Kenneth A. Hagg, Commonwealth of Massach\1Setts Department of
Environmental Quality Engineering to Thomas Spittler, EPA Region I
(August 2, 1982). Concerning a request for assistance from EPA in analyzing
air samples.
Letter from Michael R. Deland, EP A Region I to Gerald E. St Hilaire,
Commonwealth of Massachusetts Executive Office of Communities and
Development (April 1985). Concerning notification of proposed Superfund
project
Letter from Gerald E. St Hilaire, Commonwealth of Massachusetts Executive
Office of Communities and Development to David M. Webster, EPA Region I
(May 30, 1985). Concerning review of EP A proposal for a remedial
investigation and feasibility study at Si1resim Chemical Corp.
Letter from Marcia J. Berger, Commonwealth 9f Massachusetts Department of
Environmental Quality Engineering to James K. Rogers, Silresim Site Trust
(May 30, 1986). Concerning update on conditions at the Silresim site and
explain recommended interim capital improvements.
Letter from M. Gretchen Muench, EPA Region I to Donald Nagle
Commonwealth of Massachusetts Department of Environmental Protection
(April 12, 1991). Cpncerning the attached:
A. Letter from William W alsh- Rogalski, EP A Region I to Peter R. Bronson,
Commonwealth of Massachusetts Department of Environmental Protection
(January 3, 1991). Concerning transmittal of portions of the brief filed
concerning the ET. Rose Disposal Pit site.
B. Letter from William Walsh-Rogalski, EPA Region I to Peter R. Bronson,
Commonwealth of Massachusetts Department of Environmental Protection
(January 9, 1991). Concerning the attached ponions of the F.T. Rose
Disposal Pit site brief.
Letter from Peter R. Bronson, Commonwealth of Massachusetts Department of
Environmental Protection to William Walsh-Rogalski, EPA Region I
(April 22, 1991). Concerning identifying the Massachusetts Contingency Plan
(MCP) in the ARAR process.
Letter from Helen Waldorf, Commonwealth of Massachusetts Department of
Environmental Protection to Leslie McVickar, EPA Region I
(September 13, 1991). Concerning clarification of state ARARs.
2.
3.
4.
5.
6.
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10.0 Enforcement
Page 25
10.1
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Page 26
11.5 Site Level - General Correspondence (cont'd.)
9. Lener from Heather M. Ford, EPA Region I to James K. Rogers, Si1resim Site
Trustees (June 24, 1986). Concerning change in EPA project coordinator from
Heather M. Ford to David M. Webster.
10. Letter from Menill S. Hohman, EPA Region I to attached Mailing List
Concerning notification of potential liability.
13.0 Community Relations
13.1 Correspondence
1. "Ayers City Fair Share/Silresim Cleanup Committee - Demand Sheet," Lowell
Fair Share (July 22, 1981).
2. "Fair Share's Neighborhood Health & Safety Issue Request List,"
Massachusetts Fair Share (June 17, 1982).
3. Memorandum from EPA Region I to File (August 2,1982). Concerning City of
Lowell Superfund Contact.. ..
4. Telephone Notes Between Barbara H. Ikalainen, EPA Region I and Norine
Danley Brodeur, Lowell Fair Share (August 25, 1982). Concerning upcoming
Silresim Task Force Meeting.
5. Letter from Michael S. Dukakis, Governor of the Commonwealth of
MassachusettS to Norine Danley, Lowell Fair Share (September 10, 1982).
Concerning future plans for Si1resim. .
6. Telephone Notes Between E. Michael Thomas, EP A Region I and Margo
Vickers, Public Interest Economics (September 16, 1982). Concerning contract
between EPA and Public Interest Economics.
7. Lener from Daniel W. Dubner, Medical Associates to Whom It May Concern
(March 16, 1983). Concerning Danley family relocation away from Silresim
waste site, with attached: .
A. Letter from Michael A. Gilchrist, Medical Associates to Mr. and Mrs. Robert
Brand (October 26, 1982). Concerning Brand family relocation from
present address. .
B. Letter from Alan T. Kent, Dr.'s Kent and Weisfeldt, Inc. to Whom It May
Concern (March 17, 1983). Concerning relocation of Janet Brand from
Silresim Superfund site.
C. Memorandum from Georgi A. Jones, U.S. Department of Health and .
Human Services Public Health Service Centers for Disease Control to John
Figler, EPA Region I (October 27, 1982). Concerning review of Si1resim
Superfund site.
D. "News Release," Massachusetts Department of Environmental Quality
Engineering (September 14, 1982). Concerning selection of Boston
University School of Public Health to conduct health study of residentS
living near Silresim Superfund site. .
E. Memorandum from Christine J. Spadafor, EPA Region I to Leslie
Carothers, EPA Region I (July 27, 1982). Concerning health surveys and
health investigations for hazardous waste sites in Region I.
F. Telephone Notes Between Christine J. Spadafor, EPA Region I and Mary
Ann Fraelich, EPA Headquarters (July 14, 1982). Concerning Silresim
health evaluation by CDC.
8. Meeting Agenda, Silresim Task Force (April 6, 1983). Concerning schedule of
events at task force meeting.
9. Lener from Lester A. Sutton, EPA Region I to Norine Danley (May 6, 1983).
Concerning progress at the Silresim site. .
10. Meeting Notes, John F. Hackler, Barbara H. Ikalainen and David Pickman,
EPA Region I and Si1resim Task Force. (May II, 1983). Concerning
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Page 27
13.1 Correspondence (cont'd.)
11. Telephone Notes Between Barbara H. Ikalainen, EPA Region I and Norine
Danley (May 16, 1983). Concerning request for proposals.
12. Letter from John F. Hackler, EPA Region I to John F. Q'Dowd, Boston &
Maine (May 17, 1983). Concerning soil sample screening analysis on B & M
propeny. . .
13. Letter from Barbara H. Ikalainen, EPA Region I to Mr. and Mrs. Allan Danley
(May 18, 1983) with attached "Press Release - Fair Share: Health and Safety
Should Come First In Silresim RAMP." Concerning response to requests
outlined in May 11, 1983 Lowell Fair Share press release.
14. "Contingency Relocation Plan" (July 6, 1983).
15. Memorandum from Mark E. Brickell, NUS Corporation to Barbara H.
Ikalainen, EPA Region I (July 7,1983). Concerning transmittal of attached:
A. Lener from Mark E. Brickell, NUS Corporation to Norine Danley,
Massachusetts Fair Share (June 28, 1983). Concerning m team field
work.
B. Letter from Mark E. Brickell,. NUS Corporation to William L. Strigler,
(June 28, 1983). Concerning FIT team field work.
C. Letter from Mark E. Brickell, NUS Corporation to Norine Danley,
Massachusetts Fair Share (June 28, 1983). Concerning sampling on
Scannell Boiler Works property.
D. Letter from Mark E. Brickell, NUS Corporation to Lawrence B. Boyd,
Boston & Maine Corporation (June 28, 1983). Concerning surface soil
sampling on properties adjacent to the.Silresim Chemical site.
E. Letter from Mark E. Brickell, NUS Corporation to John F. Q'Dowd, Boston
& Maine Corporation (June 28,1983). Concerning surface soil sampling on
properties adjacent to the Silresim Chemical site.
. F. Letter from Mark E. Brickell, NUS Corporation to. Norine Danley,
Massachusetts Fair Share (June 28, 1983). Concerning surface soil
sampling on properties adjacent to the Silresim Chemical site.
G. Letter from Mark E. Brickell, NUS Corporation to Norine Danley,
Massachusetts Fair Share (June 28,1983). Concerning soil contamination
investigation of the Wright Leasing and Realty parking 10L
H. Memorandum from Paul F. Clay, NUS Corporation to Norine Danley,
Lowell Fair Share (June 29,1983). Concerning the final report on the air
monitoring study.
16. Letter from Barbara H. Ikalainen, EPA Region I to Allan Danley, Lowell Fair
Share (July 21, 1983). Concerning response to points made in Fair Share
handout from July 12, 1983 public meeting.
17. Letter from David Pickman, EP A Region I to Steve Starrod (August 8, 1983).
. Concerning response to call made on the Silresim information hotline.
18. Letter from William H. Foege, U.S. Department of Health and Human Services
Centers for Disease Control to Norine Danley, Lowell Fair Share
(August 26, 1983). Concerning review of proposed remedial plan for the
Silresim site.
19. "Silresim Superfund Site - Recommended Remedial Measures," National Toxics
Campaign for the Ayer city residents (October 1983).
20. Telephone Notes Between John Figler, EPA Region I and Georgi A. Jones,
U.S. Department of Health and Human S"ervices Public Health Service Centers
for Disease Control (January 17, 1984). Concerning Silresim health study.
21. Letter from Adam Parker, Lowell Fair Share (January 27,1984). Concerning
transmittal of Steve Lester's analysis of hydrogeological study.
22. "Hotline Updat~" EPA Region I (January 27,1984). Concerning update "for the
weeks of January 23 and 30, 1984.
23. "Hotline Update," EPA Region I (February 13, 1984). Concerning update for
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Page 28
13.1 CoITespondence (cont'd.)
24. Letter from Merrill S. Hohman, EPA Region I to Phyllis Robey
(February 16, 1984). Concerning response to issues raised at the
February 5, 1984 National Campaign Against Toxic Hazards conference.
25. Meeting Notes, Citizens Meeting with AA for External Affairs
(September 1984). Concerning action to be taken at Silresim.
26. Letter from Debra Prybyla, EP A Region I to Mr. and Mrs. Allan Danley
(December 17, 1984). Concerning public participation throughout the RIlFS
phase.
.27. Letter from Debra Prybyla, EPA Region I to Norine Danley (January 16, 1985).
Concerning response to information request
28. Letter from Richard T. Leighton, EPA Region I to Bany Pollack, Technology
Investment Trust (February 14, 1985). Concerning summary of telephone
conversations relating to propeny at 108 Tanner Street.
29. Letter from James P. Bond, Tanner Street Businessmen's Group to EPA
Region I (March 20, 1985). Concerning test boring requirements.
30. Memorandum to File, EPA Region I (March 25, 1985). Concerning requests
made by Norine Danley. .
31. "Silresim Superfund Site - Summary of Plans for Studies of the Site," EPA
Region I (March 1985).
32. "Silresim Superfund Site - Summary of Plans for Studies of the Site," EPA
Region I (April 1985). .
33. Memorandum from David.M. Webster, EPA Region I to Brooke Cook, EPA
Region I (May 17, 1985). Concerning April 29, 1985 Silresim public meeting.
34. Letter from John R. Moebes, EPA Region I to Peter J. Aucella, City of Lowell
(May 22, 1985). Concerning potential future site uses of the Silresim site.
35. Letter f~om David M. Webster, EPA Region I to Norine Danley, Ayer City
Homeowners and Renters Association and Massachusetts Fair Share
(June 3, 1985). Concerning response to requests made regarding the work plan
for the RI/FS.
36. Letter from Patricia L. Meaney for Merrill S. Hohman, EPA Region I to Norine
Danley, Fair Share (June 28, 1985). Concerning response to request for
information.
37. Letter from Phyllis Robey, Lowell Fair Share to David M. Webster, EPA
Region I (September 18, 1985). Concerning transmittal of proposal to PRPs.
38. Letter from David M. Webster, EPA Region I to George Kokoliadis
(October 2, 1985). Concerning transmittal of fact sheet. .
39. Letter from Merrill S. Hohman, EPA Region I to Norine Danley, Ayer City
Homeowners & Renters Association and Lowell Fair Share (October 15, 1985).
. Concerning denial of requested funds.
40. Letter from David M. Webster, EPA Region I to Norine Brodeur,
(February 21,1986). Concerning measures taken to include citizen participation
in the RIIFS process.
41. Letter from Norine Brodeur, Ayer City Homeowners & Renters Association to
David M. Webster, EPA Region I (March 3, 1986). Concerning the Community
Relations, Health and Safety, and Sampling Plans for the Silresim site.
42. Meeting Notes, EPA Region I and Commonwealth of Massachusetts,
Department of Environmental Quality Engineering (March 17, 1986).
Concerning public relations and the Site Safety Plan. .
43. Telephone Notes Between David M. Webster, EPA Region I and David
Pickman, EPA Region I (April 23, 1986). Concerning list of citizen concerns.
44. Letter from David Pickman, EPA Region I to Norine Brodeur, Ayer City
Homeowners & Renters Association (April 24, 1986). Concerning response to
earlier questions.
45. Memorandum to David M. Webster, EPA Region I (April 1986). Concerning
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. Page 29
13.1 Correspondence (cont'd.)
46. Letter from Phyllis Robey to Michael R. Deland, EPA Region I (June 4,1986).
Concerning videotaping of public meetings.
47. Letter from J. Winston Poner, EP A Headquaners to William McDonald
(June 23, 1986). Concerning suppon of Region fs policy regarding
videotaping of Superfund project management meetings.
48. Letter from.Merrill S. Hohman, EPA Region I to Norine Brodeur, Ayer City
Homeowners & Renters Association (June 26, 1986). Concerning response to
request letters.
49. Letter from David M. Webster, EPA Region I to Phyllis Robey (July 2, 1986).
Concerning decision not to videotape May 22,1986 meeting.
50. Letter from Joel Balmat, EPA Region I to Norine Danley Brodeur, Ayer City
Homeowners & Renters Association (February 4, 1987) with attached Letter
from Norine Danley Brodeur, Ayer City Homeowners & Renters Association to
Joel Balmat, EPA Region I (January 21, 1987). Concerning response to request
to expand oversight contract of Alliance Technologies Corporation.
51. Meeting Agenda, Ayer City Homeowners Association (March 2, 1987).
Concerning New England Regional Educational Conference on Hazardous
. Waste.
52. Letter from Philip L. Scannell Jr., Scannell Boiler Works to Merrill S. Hohman,
EPA Region I (July 8,1987). Concerning the remedial investigation repon
conducted by Goldberg-Zoino & Associates, Inc. .
53. Letter from James A. Thompson Jr., Pepe & Hazard (Attorney for Scannell
Boiler Works) to E. Michael Thomas, EPA Region I (November 16, 1987).
Concerning request for all sampling and monitoring results from EP A regarding
Scannell Boiler Works property. .
54. Letter from Nancy Papoulias, EPA Region I to Philip L. Scannell Jr., Scannell
Boiler Works. Concerning results of soil samples collected on Scannell
propeny .
55. Letter from Merrill S. Hohman, EPA Region I to Philip L. Scannell Jr., Scannell.
Boiler Works. Concerning response to letter dated July 8, 1987 regarding
sampling activities on Scannell propeny. .
56. "Silresim Demands," Ayer City Homeowners & Renters Association.
57. Letter from Norine Danley Brodeur, Ayer City Homeowners Association to Joel
Balmat, EPA Region I. Concerning off-site PCB levels, attached map of desired
monitoring wells, and questions.
58. Letter from David M. Ozonoff and Mary Ellen Colten, Center for Survey
Research to Residents ofl,.owell. Concerning scientific sample for health study.
59. Letter from David M. Ozonoff and Mary Ellen Colten, Center for Survey
. Research to Residents of Lowell. Concerning participation in health study.
60. "Silresim Update for Ayer City Residents," Lowell Fair Share.
61. ''The Most Inunediate and Imponant Technical Solutions for the Initial Remedial
. (Ceanup and Protection) Measures at Silresim," Richard C. Bird Jr. for Ayer
City Residents.
62. List of Demands, Lowell Fair Share. Concerning list of five demands to
improve EPA's temporary cleanup plan for Silresim.
63. "Why Are We Upset About The EPA's Latest Plans For Silresim?" Ayer City
Homeowners Association and Lowell Fair Share. Concerning list of reasons
why action on Silresim should begin immediately.
64. Letter from Michael R. Deland, EPA Region I to Phyllis Robey, Massachusetts
Fair Share. Concerning response to previous issues.
65. "Notice to Residents," Barbara H. Ikalainen, EPA Region I. Concerning
transmittal of attached "Summary of Safety Precautions In Operating Plan for
Remedial Action at Si1resim Site.
66. Letter from Norine Danley, Lowell Fair Share to E. Michael Thomas, EPA
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Page 30
13.1 Correspondence (cont'd.)
67. Set of Silresim Hotline Messages including:
A. Revised Tape Message, David Pickman, EPA Region I (May 16, 1983).
B. "Repon on EPA Operations at Silresim Chemical Waste Site"
(August 31, 1983).
C. "Repon on Infonnation Line (Also to News Media)" (September 9, 1983).
D. Tape Message, Michael R. Deland, EPA Region I (September 13,1983).
E. Tape Message, David Pickman, EPA Region I (September 27, 1983).
F. Tape Message, Richard T. Leighton, EPA Region I (November 15, 1983).
G. Tape Message, Richard T. Leighton, EPA Region I (November 28,1983).
H. Tape Message, Richard T. Leighton, EPA Region I (January 10, 1984).
I. Tape Message, Richard T. Leighton, EPA Region I (Apri113, 1984).
68. Letter from Norine Danley Brodeur, Ayer City Homeowners Association to
Merrill S. Hohman, EPA Region I. Concerning response to requests for the
residents of Ayer City.
- 13.2 Community Relations Plans
"Community Relations Plan - Silresim Chemical Corporation."
(September 1985).
"Draft Public Involvement Plan/Community Relations Plan," Commonwealth of
Massachusetts Department of Environmental Protection (Apri11991).
"Final Public Involvement Plan/Community Relations Plan," Commonwealth of
Massachusetts Department of Environmental Protection (June 1991).
Comments
1.
2.
3.
4. . Comments Dated March 1986 from Ayer City Homeowners on the
September 1985 "Community Relations Plan - Silresim Chemical Corporation."
. 13.3 News ClippingslPress Releases
News Clippings
1. "Major Field Study Scheduled at Silresim Chemical Plant," The Sun - Lowell,
MA (February 16, 1978). .
2. "Claims Toluene Still Being Dumped in City Sewer System," The Sun - Lowell,
MA (March 14, 1978). .
3. "The Headache of Hazardous Waste," The Boston Sunday Globe - Boston, MA
(June 18, 1978). .
. 4~ "EPA Tests at Silresim Site Asked by Tsongas," The Sun - Lowell, MA
(August 18, 1978).
5; "Suspect, 17, Charged in Lowell Fire, Blast," The Boston Evening
Globe - Boston, MA (August 21, 1978).
6. "Fire in Lowell Razes Chemica1 Storehouse," The Boston Globe - Boston, MA
(August 21, 1978).
7. "The Lesson From Lowell," The Boston Globe - Boston, MA
(August 25, 1978). . .
.8. "Poison Chemicals: Where Do We Dump Them?," The Boston Herald - Boston,
MA (September 6, 1978).
9. "EPA Regulations Would Govern Chemical Disposal," The Sun - Lowell, MA
(December 14, 1978).
10. "Chemicals' Effects Difficult to Measure," The Sun - Lowell, MA
(July 14, 1982).
11. "Does Fair Share Play Fair?," The Sun - Lowell, MA (July 15, 1982).
12. "Silresim Founder Says He's a Victim too," The Sun - Lowell, MA
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Page 31
13.3 News Clippings/Press Releases (cont'd.)
News Clippings
.
13. "Silr~sim Health Study Consultant to be Picked," The Sun - Lowell, MA
(September 12, 1982).
14. "Silresim," The Sun - Lowell, MA (October 16, 1982).
15. "Study No Surprise to Plant's Neighbors," The Boston Globe - Boston, MA
(January 21, 1983). .
16. "Repon Spurs Fears About Air Near Silresim," The Sun - Lowell, MA
(March 6, 1983).
17. "This is Not Massachusetts, This is Toxichusens," The Item - Wakefield, MA
(March 8, 1983).
18. "State Officials Ask EP A to Conduct Air Tests," The Daily Times and
Chronicle - Wobum, MA (March 8,1983).
19. "Senate OKs Hazwaste Fund...," The Transcript - North Adams, MA
(March 8, 1983).
20. "$25-Million Cleanup Gets Senate Nod," The News - Milford, MA
(March 8, 1983).
21. "EPA to Recheck Lowell Toxic Site," The News - Newburypon. MA
(March 9,1983).
22. "Dump's Neighbor:s Blast EPA," (March 10, 1983). .
. 23. . "Relocation Aid Urged for Mass. Residents," The Patriot Ledger - Quincy, MA
(March 11, 1983).
24. "Repon Finds Water Safe Near Silresim,'! The Sun - Lowell, MA.
(March 13, 1983). .
25. "Air Tests Get Underway," The Sun - Lowell, MA (March 14, 1983).
26. "Tests Explore Health Threat," The Gazette - Haverhill, MA (March 15, 1983).
27. "Tests Begin at Lowell Waste Site," The Boston Globe - Boston, MA
(March 15, 1983)
28. "Dumping," The Harvard Independent - Harvard University, Cambridge, MA
(March 17, 1983).
29. "Air Test Finds Pollutants - But They're not From Silresim." The Sun - Lowell.
MA (March 18.1983).
30. "Pollutants From Lowell Finn at 'Nuisance' Levels." The Sun - Lowell, MA
(March 21, 1983).
31. "Ayers City Leaders Need More Convincing," The Sun - Lowell. MA
(March 22. 1983).
32. 'Dukakis Signs Superfund Bill at Toxic Waste Dump." The Standard Times -
New Bedford. MA (March 25.1983).
33. "Dukakis Approves 'Superfund' of$25m for Hazardous Waste," The Boston
Globe - Boston, MA (March 25. 1983).
34. "State Gets Toxic Waste Law." The Chronicle and Times - Reading, MA
(March 25, 1983).' .
35. "Majilite Moves to Reduce Odors Near Silresim Site." The Sun - Lowell. MA
(March 26. 1983). .
36. "Silresim Editorial False, Misleading," The Sun - Lowell, MA
(March 31,1983).
37. "Silresim Tests Find 'Normal Urban Air'," The Sun - Lowell, MA
. (March 31. 1983).
38. "State Orders Toxic Cleanup." The Boston Herald - Boston, MA
(April 5. 1983).'
39. "2 Lowell Firms Told to Cut Use of Chemical," The Patriot Ledger - Quincy.
MA (April 5, 1983). .
40. "An End to the Silresim Story ...?," The Sun - Lowell, MA (April 7, 1983).
41. "EPA May Cap Silresim," The Sun - Lowell. MA (April 7, 1983).
42. "Focus of Health Study Now Shifts to Account for New Air Problems,"
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. Page 32
13.3 News Clippings/Press Releases (cont'd.)
News Clippings
43. "EPA Approves Fence to Surround Silresim," The Sun - Lowell, MA
(May 27, 1983). .
44. "Some Relocations to be Considered," The Sun - Lowell, MA (June 22, 1983).
45. "Silresim Cleanup Delayed Two Weeks," The Sun - Lowell, MA
(July 29, 1983).
46. "State Settles Suit Against Silresim, Bank," The Sun - Lowell, MA
(August 25, 1983).
47. "Tank Finding Taken in Snide," The Sun - Lowell, MA (September 9, 1983).
48. 'Dump Cleanup to Begin, .. The Greenfield Recorder - Greenfield, MA
(September 14, 1983).
49. "Workers Clean Out Silresim Waste Tank," The Sun - Lowell, MA
(September 15, 1983).
50. "Firms Must Pay for Waste Cleanup," The Boston Globe - Boston, MA
(September 22, 1983). .
51. "Work Delayed on Installation of Clay Cap on Silresim Site," The Sun - Lowell,
MA (December 12,1983).
52. "Higher Rate of llls Near Toxic Site," The Boston Globe - Boston, MA
(January 20, 1984) with attached letter from David Pickman, EPA Region I to
Chris Chinlund, The Boston Globe (January 20, 1984). .
53. "Feds Plan to Make Clean Silresim Sweep," The Sun - Lowell, MA
(January 26, 1984). .
54. "The Silresim Settlement," The Boston Business Journal- Boston, MA
(April 9-16, 1984). .
55. "Toxic Waste Victims Evoke Tears, Suppon," The Sun - Lowell, MA
(April 12, 1984).
56. "Finn Begins to Lay Cap Over Silresim Waste Site," The Sun - Lowell, MA
(April 30, 1984).
57. "Toxic Waste Dumps Suspected of Affecting Health of Neighbors," The
Washington Post - Washington D.C. (May 27, 1984).
58. "Fair Share Head Joins Group Pushing for Silresim Cleanup," The Sun-
Lowell, MA (July 3, 1984).
59. "Water, Toxic Waste Key '85 Issues: EPA," The Sun - Lowell, MA
(December 28, 1984).
60. "EPA Seeks Comment About Silresim," The Sun - Lowell, MA
(March 18, 1985).
61. "How to Track Down Toxins," Newsweek Magazine (May 6,1985).
6~. "Firms Agree to Fund Silresim Site Study," The Sun - Lowell, MA
(June 6, 1985).
63. "Lowell Clean-up," Fitchburg Leominster Sentinel & Enterprise - Fitchburg,
MA (June 7, 1985).
64. "Group Seeks EPA Funds to Treat Lead Paint Homes," The Sun - Lowell,
MA (June 12, 1985). .
65. "Soil Contamination in Ayers City Threatening Neighborhood: Residents,"
The Sun - Lowell, MA (July 21, 1986).
66. "EPA Seeking Buried Waste at Silresim," The Sun - Lowell, MA
(November 13, 1986). .
67. "EPA Still Testing Toxic Waste Site," The Gloucester Daily Times - Gloucester,
MA (November 14,1986).
68. "Dioxin Found Near Old Waste Site; EPA to Cover Contaminated Soil,"
The Boston Globe - Boston, MA (December 13, 1986).
69. "Dioxin Found Near Silresim Site," The Sun - Lowell, MA
(December 13, 1986).
70. "Waste Site to be Covered," The Lawrence Eagle Tribune - Lawrence, MA
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. Page 33
13.3 News Clippings/Press Releases (cont'd.)
News Clippings
71. 'Dioxin-Contaminated Soil at Silresim to be Covered," The Sun - Lowell, MA
(December 16, 1986).
72. "Wrong Sand Delivery Delays Covering Dioxin," The Sun - Lowell, MA .
(December 17.1986).
73. "EPA Returns to Lay Cover Over Contaminated Soil," The Sun - Lowell. MA
(December 18, 1986).
74. "Test Results Due on Dioxin at Silresim," The Sunday Sun - Lowell. MA
(December 21. 1986). .
75. ''EPA Takes New Round of Silresim Soil Tests," (June S, 1987).
76. 'The United States Environmental Protection Agency Announces The
Availability Of The Administrative Record For The Silresim Superfund Site In
Lowell, Massachusetts." The Sun - Lowell, Massachusetts
(September 27, 1989).
77. "Residents Want a Tnnetable for Silresim Cleanup," The Sun - Lowell, MA
(April 26. 1990). . . . .
78. ''EPA Extends Time for Public Input on Silresim Cleanup," The Sun-
Lowell, MA (July 16, 1991).
79. "EPA Butt of Lowell Wrath." The Boston Herald - Boston. MA.
80. "Congressmen Start Waste Inquiry Amid Poisons. Stench and Decay,"
The New York Times - New York.
81. "EPA Downplays Toxic 'Hot Spot'."
82. "Neighborhood Group Charges Chemicals Filtering into Rivers." The Sun -
Lowell,MA. . .
83. "Atkins Calls for Expanded Role in Waste Site Cleanup Program," The Sun -
Lowell. MA.
84. "Arrow Parking Area Contaminated," The Sun - Lowell. MA.
8S. "Silresim Team Divided on How to Close the Site." The Sun - Lowell. MA.
86. "Visit by EPA Chief Unlikely."
Press Releases
87. "News Release," Commonwealth of Massachusetts Department of
Environmental Quality Engineering (April 23. 1982). Concerning a
newly-fonned task force meeting on April 27. 1982.
88. "Environmental News Release," EPA Region I (July 23, 1982). Concerning.
announcement of eligibility for action under Superfund.
89. "Statement - Selection of New Superfund Sites." Anne M. Gorsuch. EPA
Headquarters (July 23, 1982). .
90. "News Release," Commonwealth of Massachusetts Department of .
Environmental Quality Engineering (September 14,1982). Concerning selection
of Boston University School of Public Health to conduct a comprehensive health
study.
91. "News Release," Commonwealth of Massachusetts Department of
Environmental Quality Engineering (October 13, 1982). Concerning the results
of the Silresim air monitoring study.
92. "Draft Press Release" EPA Region I (April 1, 1983). Concerning announcement
of fIndings of the Health Effect Study Group reviewing air quality data from
Silresim Site.
93. "News Release," Commonwealth of Massachusetts Department of
Environmental Quality Engineering (April 4. 1983). Concerning Administrative
Orders issued against two Lowell fmns.
94. "Environmental News Release," EPA Region I (May 26,1983). Concerning
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Page 34
13.3 News ClippingslPress Releases (cont'd.)
Press Releases
95. "New England Newswatch," WBZ - TV (September 9, 1983). Concerning the
discovery of a two tons of sludge in a 20,000 gallon tank at the Silresim site.
96. "News Release - Lowell Health Study Released Today," Commonwealth of
Massachusetts Department of Public Health and Commonwealth of
Massachusetts Department of Environmental Quality Engineering
(January 19, 1984).
97. "Environmental News Release," EPA Region I (January 25, 1984). Concerning
announcement of a January 18, 1984 public meeting of the Silresim Task Force.
98. "Lowell Hazardous Waste Finn Faces License Revocation," Commonwealth of
Massachusetts Department of Environmental Quality Engineering
(May 3, 1984).
99. "Report on EPA Operations at Silresim Superfund Site," EPA Region I
(May 1984). Concerning installation of a temporary clay. cap.
100. "EPA Seeks Public Comment on Plans for Study at Silresim Superfund Site,"
EPA Region I (March 15, 1985).
101. "EPA Environmental News - Public Meeting to Explain Plans for Studies at
Silresim Superfund Site," EPA Region I (April 19, 1985).
102. "EPA Environmental News - EPA Signs Agreement on Silresim Superfund
. Site," EPA Region I (June 6, 198~).
103. "New England Newswatch," WCVB - TV (July 21,1986). Concerning a hot
spot at the Silresim site. .
104. "New England Newswatch," WCVB - TV (December 12,1986). Concerning
discovery of new area of dioxin contamination outside Silresim site's fence.
105. "EPA Environmental News - EPA to Conduct Additional Soil Sampling for
Dioxin," EPA Region I (June 2, 1987).
106. "Environmental News - EPA Recovers $3.4 Million at Silresim Superfund Site,"
EP A Region I (March 27, 1990).
107. "Environmental News - EPA Announces Public Meeting to Discuss Results of
Study on Silresim Superfund Site," EPA Region I (April 13, 1990).
108. "Environmental News - EPA to Collect Additional Data at Silresim Superfund
Site," EPA Region I (November 7, 1990).
109. "Notice of Document Availability," Commonwealth of Massachusetts
Department of Environmental Protection (April 10, 1991). Concerning "Draft
Public Involvement Plan/Community Relations Plan."
110. Public Meeting Notice, Massachusetts Department of Environmental Protection.
Concerning public meeting to be held April 24, 1991.
111. "Environmental News - EPA Announces $22.5 Million Proposed Cleanup Plan
for the Silresim Superfund Site," EPA Region I (June 6, 1991).
112. "Environmental News - EPA Extends Public Comm~nt Period on Proposed
Cleanup Plan for Silresim Superfund Site," EPA Region I (July 16, 1991).
113. "Environmental News Release," EPA Region I. Concerning industrial .
emissions of volatile organic chemicals at unacceptable levels in the vicinity of
the Silresim site. .
114. "For Immediate Release," EP A Region I. Concerning possibility of installing a
temporary cap on the Silresim site. .
13.4 Public Meetings
1.
Cross-Reference: Meeting Notes, Public Meeting for the Silresim Chemical
Corp. Site, EP A Region I and Commonwealth of Massachusetts Department of
Environmental Quality Engineering (June 23, 1981). Concerning public
demands regarding sampling studies at the site [Filed and cited as entry number
12 in 2.1 Correspondence].
"Air Study Inadequacy," Lowell Fair Share (November 10, 1982).
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Page 35
13.4 Public Meetings (cont'd.)
3. EPA Region I Attendance List, Operating Plan Public Meeting for the Silresim
Chemical Corp. Site (June 13, 1983).
4. "Summary of Si1resim Task Force Meeting - Lowell, Massachusetts," EPA
Region I, January 25, 1984.
5. Ayer City Homeowners and Renters Association Meeting Agenda
(April 29, 1985) with attached:
A. "Silresim Demands," Ayer City Homeowners and Renters Association
(April 29, 1985).
B. "Demands for the Kyan Street Site," Ayer City Homeowners and Renters
Association (April 29, 1985).
C. "Summary of Plans for Studies of the Site," EPA Region I (April 1985).
6. Memorandum from David M. Webster, EPA Region I to Brooke Cook, EPA
Region I (April 29, 1985). Concerning EPA responses to demands made by the
Ayer City Homeowners and Renters Association at April 29, 1985 public
meeting. .
7. Meeting Notes, Public Meeting for the Silresim Chemical Corp. Site, EPA
Region I (October 16, 1985).
8. Memorandum from EPA Region I to File (May 6, 1986). Concerning outline
for the May 6, 1986 public meeting. .
9. National Campaign Against Toxic Hazards, Massachusetts Fair Share, and Ayer
City Homeowners and Renters Association Meeting Agenda (June 30, 1987)
with attached:
A. "Superfund Alternatives for Managing Hazardous Waste," EPA
Headquarters (Fall 1986). .
B. Letter from Joseph H. Kenny, Terra Vac Inc. to Thomas Spittler, EPA
Region I (December 28, 1985) with attached "Vacuum: Defense System for
Ground Water VOC Contamination."
10. EPA Region I Meeting Summary, Public Meeting for the Si1resim Site
(April 25, 1990).
11. EPA Region I Meeting Summary, Public Meeting for the Si1resim Site
(June 19, 1991).
13.5 Fact Sheets
1.
2.
"Silresim Fact Sheet," Commonwealth of Massachusetts Department of
Environmental Quality Engineering (December 4, 1978 through June 7, 1979).
'Do we have an immediate crisis at the Si1resim site?!!," Massachusetts Fair
Share (March 9, 1983). Concerning results of air monitoring work
commissioned by the Commonwealth of Massachusetts.
"Silresim Update - HaZardous Waste Cleanup Report - Ayer Qty Fair Share,"
Lowell Fair Share (May 9, 1983). Concerning a Silresim Task Force Meeting
scheduled for May 11, 1983.
"Repon on EPA Operations at Silresim Chemical Waste Site," EPA Region I
(August 12, 1983). Concerning initiation of dismantling work at site.
''Repon on EPA Operations at Silresim Chemical Waste Site," EPA Region I
(August 22, 1983). Concerning continuation of dismantling work and site
monitoring. .
"Repon on EPA Operations at Silresim Chemical Waste Site," EPA Region I
(August 31, 1983). Concerning dismantling work and equipment preparatory to
the laying of a temporary cap. .
"Repon on EPA Operations at Silresim Chemical Waste Site," EPA Region I
(September 8,1983). Concerning anticipated completion of dismantling.
Memorandum from David M. Webster, EPA Region I to Heather M. Ford,
Richard T. Leighton, Debra Prybyla, E. Michael Thomas, and Pam Hill, EPA
Region I (February 14, 1985). Concerning attached Fact Sheet for informal and
formal public meetings.
3.
4.
5.
6.
7.
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Page 36
13.5 Fact Sheets (com'd.)
9. "Silresim Superfund Site - Summary of Plans for Studies of the Site," EPA
Region I (March 1985).
10. "Fact Sheet - Summary of Enforcement Activities" with attached "Chronology,"
Commonwealth of Massachusetts Department of Environmental Quality .
Engineering.
13.7 Technical Assistance Grants
1. Letter from Norine Danley, Ayer City Homeowners and Renters Association
(July 1985). Concerning request for assistance.
2. Memorandum from David M. Webster, EPA Region I to Heather M. Ford, EPA
Region I (July 22, 1985). Concerning request for $100,000 from citizens'
groups in Lowell.
3. Memorandum from Heather M. Ford, EPA Region I to Menill S. Hohman, EPA
Region I (August 15, 1985). Concerning proper channels for Technical
Assistance Grant requests. .
4. Letter from James K. Rogers, Silresim Site Tru~t to Phyllis Robey, Lowell Fair
Share (October 14, 1985). Concerning request of a Technical Assistance Grant
from the Silresim Site Trustees. .
5. Letter from Merrill S. Hohman, EPA Region I to Norine Danley, Ayer City
Homeowners Association and Lowell Fair Share (October 15, 1985).
Concerning Superfund statutes for grants to private citizens or groups.
6. Telegram from Norine Danley Brodeur, Ayer City Homeowners and Renters
Association to Michael R. Deland, EPA Region I (December 9, 1986). .
Concerning request for Technical Assistance Grant of $50,000 and a waiver of
the 20% matching of funds.
7. Letter from J. Winston Poner, EPA Headquaners to Norine Danley Brodeur,
Ayer City Homeowners and Renters Association (January 27,1987).
Concerning explanation of the initiation of the Technical Assistance program
pursuant to SARA.
8. Letter from Chris Jendras, EPA Region I to Interested Citizen (March 31, 1988).
Concerning approval of regulations for Technical Assistance Grants.
9; Letter from Norine Brodeur, Greater Lowell Environmental Campaign to Mary
H. Grealish, EPA Region I (April 13, 1988). Concerning request for Technical
Assistance Grant and waiver on matching funds. .
10. Letter from MJ. Gonsalves, Nonhern Tanner Street Business Association to
Mary H. Grealish, EPA Region I (May 6,1988). Concerning request for
technical assistance.
11. Letter from Mary H. Grealish, EPA Region I to Norine Brodeur, Ayer City .
Homeowners Association (May 12, 1988). Concerning Federal regulations for
obtaining a grant.
12. Letter from Mary H. Grealish, EPA Region I to M.J. Gonsalves, Northern
Tanner Street Business Association (May 20, 1988). Concerning forming a
coalition with other potential applicants.
13. Letter from Mary H. Grealish, EPA Region I to James P. Bond, Tanner Street
Businessmen's Group (June 9,1988). Concerning reply to attached letter from
James P. Bond.
14. Letter from Mary H. Grealish, EPA Region I to James P. Bond, Tanner Street
Businessmen's Group (June 23,1988). Concerning enclosure of copy of "The
Citizens' Guidance Manual for the Technical Assistance Grant Program."
15. Letter from Mary H. Grealish, EP A Region I to Norine Brodeur, Ayer City
Homeowners Association (June 23, 1988). Concerning reply to attached letter,
enclosure of a grant application package, and a copy of "The Citizens' Guidance
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Page 37
13.7 Technical Assistance Grants (cont'd.)
16. Letter from Mary H. Grealish, EPA Region I to M.J. Gonsalves, Northern
Tanner Street Busir;,;.;ss Association (June 23,1988). Concerning enclosure of
copy of "The Citizens' Guidance Manual for the Technical Assistance Grant
Program. "
17. Letter from James P. Bond, Tanner Street Businessmen's Group to Mary H.
Grealish, EPARegion I (June 26,1988). Concerning withdrawal of Letter of
fure~ ,
18. Letter from Norine Brodeur Routhier, Greater Lowell Environmental Campaign
to Mary H. Grealish, EPA Region I (July 19, 1988). Concerning request for
extension of time for application.
19. Letter from Mary R Grealish, EPA Region I to Noone Brodeur Routhier, Ayer
City Homeowners Association (July 26, 1988). Concerning response to request
for extension of time for application.
20. Letter from Mary R Grealish, EPA Region I to Norine Brodeur Routhier, Ayer
City Homeowners Association (August 11, 1988). Concerning availability of
application to the public.' , ,
21. Lener from Mary R Grealish, EPA Region I to Norine Brodeur Routhier, Ayer
City Homeowners Association (December 6, 1988). Concerning preliminary
review of application.
22. Lener from Mary R Grealish, EP A Region I to Norine Brodeur Routhier, Ayer
City Homeowners Association (March 27,1989). Concerning response to
issues raised in December 6, 1988 lener.
14.0 Congressional Relations
14.1 COITespondence .
1.
Letter from Alex Kidaloski for Paul E. Tsongas, Member of the U.S. House of
Representatives to Dennis Huebner, EPA Region I (September 28, 1977).
Concerning attached lener from Gerry Tremblay, Silresim Chemical Corp. to
Alex Kidaloski, Aide to Congressman Paul E. Tsongas.
Lener from Daniel K. Moon, EP A Region I to Alex Kidaloski for Paul E.
Tsongas, Member of the U.S. House of Representatives (November 1, 1977).
Concerning the Si1resim Chemical Corporation's request for information on
potential liquid waste generators. .
Cross-Reference:' Lener from Paul G. Keough, EPA Region I to William X.
Wall, Member of the Commonwealth of Massachusetts State Senate
(February 2,1978). Concerning information on activities at the Silresim
Chemical Corporation site ,[Filed and cited as entty number 3 in 2.1,
CoITespondence ].
Letter from Congressman Paul E. Tsongas, Member of the U.S. House of
Representatives to Douglas N. Costle, EPA Headquarters (August 15, 1978).
Concerning expediting the clean-up of Silresim Chemical Corporation facility.
Letter from Thomas C. Jorling, EP A Region I to Edward M. Kennedy, Member
of the U.S. Senate (August 2,1979). Concerning attached letter from Michael
E. McLaughlin, County of MiddleseJt Office of the County Commissioners to
James E. Carter, President of the United. States.
Letter from Edward M. Kennedy and Paul E. Tsongas, Members of the U.S.
Senate, and James M. Shannon, Member of the U.S. House of Representatives
to John Hernandez, EPA Region I (March 10, 1983). Concerning air
monitoring studies at Si1resim Superfund site. ,
Letter from Paul E. Tsongas, Member of the U.S. Senate to Lester A. Sutton,
EPA Region I (April 6, 1983). Concerning air monitoring studies at Si1resim
site.
2.
3.
4.
5.
.6.
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Page 38
14.1 Correspondence (cont'd.)
8. Letter from Lester A. Sutton, EP A Region I to Paul E. Tsongas, Member of the
U.S. Senate (May 16, 1983). Concerning response to letter regarding air
monitoring studies at the Silresim Chemical Corporation Site.
9. Letter from Paul G. Keough, EPA Region I to Paul E. Tsongas, Member of the
U.S. Senate (June 7,1983). Concerning EPA efforts in protecting the public
health in Lowell, Massachusetts.
10. Letter from Paul E. Tsongas, Member of the U.S. Senate to Dr. Vernon N.
Houle, U.S. Department of Health and Human Services Agency for Toxic
Substances and Disease Registry (July 15, 1983). Concerning the visit to
Silresim Site in Lowell, Massachusetts by Houle's staff.
11. Memorandum from Betsy Home, EPA Region I to David M. Webster, EPA
Region I (August 12, 1985) with attached attendance list and meeting notes.
Concerning briefmg on Superfund sites in Congressman Atkins' District.
12. Telephone Notes Between David M. Webster, EPA Region I and Kathi
Anderson for Edward M. Kennedy, Member of the U.S. Senate
(April 22, 1986). Concerning Silresim site activities and Upcoming public
meeting. .
13. Telephone Notes Between David M. Webster, EPA Region I and Stan .
Rosenberg for Chester Atkins, Member of the U.S. House of Representatives
(May 1, 1986). Concerning public meeting scheduled on May 6, 1986. .
14. Memorandum to David M. Webster, EPA Region 1. Concerning preliminary
meeting of city officials and members of the public. .
16.0 Natural Resource Trustee
16.1 Conrespondence
Letter from Kenneth Finkelstein, U.S. Department of Commerce National
Oceanic and Atmospheric Administration to EPA Region I (March 8,1988).
Concerning procedure for requesting a Covenant Not to Sue (release from
liability) for natural resources.
Cross-Reference: Letter from Leslie McVickar, EPA Region I to Kenneth Carr,
U.S. Department of the Interior Fish and Wildlife Division
(December 27,1988). Concerning transmittal of the March 1987 "Draft-
Remedial Investigation Report," Goldberg-Zoino & Associates, Inc. for Silresim
Site Trust [Filed and cited as entry number 37 in 3.1 Correspondence].
Cross-Reference: Letter from Leslie McVickar, EPA Region I to Kenneth Carr,
U.S. Department of the Interior Fish and Wildlife Division (April 18, 1989);
Concerning transmittal of the April 1989 "Revised Draft Repon - Remedial
Investigation - Volumes I through vm," Goldberg-Zoino & Associates, Inc. for
Silresim Site Trust [Filed and cited as entry number 40 in 3.1 Correspondence].
Telephone Notes Between Leslie McVickar, EPA Region I and James
Mikolaities, U.S. Department of the Interior Fish and Wildlife Division
(May 12, 1989). Concerning review of the April 1989 "Revised Draft Repon -
Remedial Investigation - Volume I," Goldberg-Zoino & Associates, Inc. for
Silresim Site Trust .
Letter from Kenneth Finkelstein, U.S. Department of Commerce National
Oceanic and Atmospheric Administration to EPA Region I (May 24, 1989).
Concerning procedures for notifying the NOAA trustee and request for a
Covenant Not to Sue (release from liability) for natural resources.
16.5 Technical Issue Pap~s
1.
2.
3.
,4.
5.
1.
Letter from Bruce Blanchard, U.S. Department of the Interior to Gene Lucero,
EP A Headquarters (February 24, 1984). Concerning a preliminary natural
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Page 39
17.0 Site Management Records
17.1 CJone~ndence
1.
Letter from Susan M. Cooke, Goodwin, Procter & Hoar (Attorney for Silresim
Site Trust) to RuthAnn Sherman, EPA Region I (June 6, 1990). Concerning'
information on monitoring wells.
Letter from Susan M. Cooke, Goodwin, Procter & Hoar (Attorney for Silresim
Site Trust) to RuthAnn Sherman, EPA Region I (June 19, 1990). Concerning
summary of outstanding issues.
17.2 Access Records
2.
1. Letter from James A. Thompson Jr., Pepe & Hazard (Attorney for the Scannell
families) to Leslie McVickar, EPA Region I (March 14, 1990). CJoncerning
Scannell property adjacent to the site.
2. Letter from Timothy M. Conway, EPA Region I to James A. Thompson Jr.,
Pepe & Hazard (Attorney for the Scannell families) (March 29,1990).
. CJoncerning Scannell property adjacent to the site.
3. Letter from James A. Thompson Jr., Pepe & Hazard (Attorney for the Scannell
families) to Timothy M. Conway, EPA Region I (April 13, 1990). CJoncerning
Scannell property adjacent to the site.
4. Letter from RuthAnn Sherman, EPA Region I to James A. Thompson Jr., Pepe
& Hazard (Attorney for the Scannell families) (June 25,1990). Concerning
Scannell property adjacent to the site.
5. Letter from James A. Thompson Jr., Pepe & Hazard (Attorney for the Scannell
families) to RuthAnn Sherman, EPA Region I (August 10, 1990). Concerning
consent for access to property.
6. "Consent for Access to Property," EP A Region I (September 7, 1990).
CJoncerning the Lowell Iron & Steel CJompany.
7. Letter from Merrill S. Hohman, EP A Region I to William L. Stigler, Lowell
Used Auto Parts (September 17, 1990). CJoncerning request for access to
property.
8. Letter from Merrill S. Hohman, EPA Region I to Donald Doubleday, Lowell
Department of Public Works (September 17, 1990). Concerning request for
access to property.
9. Letter from Merrill S. Hohman, EPA Region I to Daniel T. Sullivan
(September 17,1990). Concerning request for access to property.
10. Letter from Merrill S. Hohman, EP A Region I to Arthur Hammer, Mill City
Investments, Inc. (September 17, 1990). Concerning request for access to
property. .
11. Letter from Merrill S. Hohman, EPA Region I to David Anderson, Boston and
. Maine Corporation (September 17, 1990). Concerning request for access to
property.
12. Letter from Merrill S. Hohman, EPA Region I to Roben P. Betty and Joan M.
Betty (October 24, 1990). Concerning request for access to propeny.
13. Letter from Merrill S. Hohman, EPA Region I to Ralph Tucci, Lowell Used
Auto Parts, Inc. (October 24, 1990). Concerning request for access to propeny.
14. Letter from Leslie McVickar, EPA Region I to Philip L. Scannell ill
(November 8, 1990). CJoncerning request for access to property.
15. Letter from Leslie McVickar, EPA Region I to Roben P. Betty and Joan M.
Betty (November 14, 1990). Concerning request for access to propeny.
16. Letter from Merrill S. Hohman, EPA Region I to Ralph Tucci, Lowell Used
Auto Parts, Inc. (November 14, 1990). Concerning request for access to
property .
17. Letter from Merrill S. Hohman, EP A Region I to Anthony O'Neill, Mill City
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Page 40
17.2 Access Records (cont'd.)
18. Letter from Leslie McVickar. EPA Region I to Philip L. Scannell m. Lowell
Iron and Steel Company (May 2. 1991). Concerning transmittal of the
combined Commonwealth of Massachusetts Department of Environmental
Protection Public Involvement Plan and the Community Relations Plan.
19. Letter from Merrill S. Hohman. EPA Region I to Ralph Tucci. Lowell Used
Auto Parts. Inc. (May 2. 1991). Concerning request for access to property.
20. Letter from Merrill S. Hohman. EPA Region I to Philip L. Scannell. Ill. Dennis
Scannell and John P. Scannell. Lowell Iron and Steel Company (June 5. 1991).
Concerning request for access to property.
21. Letter from Merrill S. Hohman. EPA Region I to Anthony Dinapoli. L'Energia
Incorporated (June 6. 1991). Concerning request for access to property.
22. Letter from Leslie McVickar. EPA Region I to John Scannell. Lowell Iron and
Steel Company and Anthony DiNapoli. L'Energia Corporation (June 14. 1991).
Concerning protective abandonment of monitoring wells at the site.
23. Letter from Leslie McVickar. EPA Region I to Ralph Tucci. Lowell Used Auto
Parts. Inc. (August 5. 1991). Concerning schedule for gr<>undwater sampling
on Mr. Tucci's property.
24. Letter from Leslie McVickar. EPA Region I to Anthony O'Neill. Mill City
Investments (August 5. 1991). Concerning schedule for groundwater sampling
on Mr. O'Neill's property.
17.4. Site Photographs/Maps
Index of 20 Rolls of Photographs of the Silresim Initial Remedial Measure
(IRM). NUS Corporation (December 16,1983 to December 11, 1-984).
The .records cited in entry numbers 2 through 7 may be revif!Ved, by appointment
only, at EPA Region /, Boston, Massachusetts. .
1.
2.
3.
4.
As-Built Plans for Silresim Site Clay Cap, NUS Corporation (July 12, 1985).
Map of Property In Lowell. Massachusetts at Wye Leading to Lowell Secondary
Track. Boston and Maine Corporation (September 23. 1985).
20 Rolls of Photographs of the Silresim Initial Remedial Measure (lRM). NUS
Corporation (December 16. 1983 to December II, 1984).
"Site Analysis - Silresim Site - Volume I," U.S. EPA (August 1989).
"Site Analysis - Sjlresim Site - Volume 2." U.S. EPA (August 1989).
Aerial Photographs and Slides of the Silresim Site.
5.
6.
7.
. 17.5 Site Descriptions/Chronologies
'1.
"Status Report - Silresim Chemical Corporation Hazardous Waste Problem."
Commonwealth of Massachusetts Department of Environmental Quality
Engineering (August 21, 1978). .
"Format for Inventory of Disposal Sites Where Hazardous Waste Threatens
Public Health." Commonwealth of Massachusetts Department of Environmental
Quality Engineering (October 1978).
"Massachusetts Water Quality Task Force," Commonwealth of Massachusetts
Department of Environmental Quality Engineering (September 1979).
Concerning the discovery of Silresim Waste Site.
"Site Cleanups Continue," Commonwealth of Massachusetts Department of
Environmental Quality Engineering (October II, 1981). Concerning removal
cleanup progress. .
"Silresim Chemical Corporation," EPA Region I (September 1982). Concerning
the history of Silresim Chemical Corporation.
Memorandum from EPA Region I to File (April 15, 1983 through
September 15. 1983). Concerning Silresim activity and cost timeline.
2.
3.
4.
5.
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Page 41
17.5 Site Descriptions/Chronologies (cont'd.)
7. Memorandum from EPA Region I to File (May II, 1983). COncerning timeline
of cleanup activity at Si1resim site presented at the May II, 1983 Task Force
meeting.
8. "Summary of Recent Events," EPA Region I (September 30, 1987 through
January 9, 1988).
9. "The Si1resim Superfund Site Historical Summary," EPA Region I.
(September 7, 1988). Concerning the historical events related to the Si1resim
Superfund Site's creation and cleanup.
10. "Site Cleanup: Si1resim Chemical (MA)," Richard T. Leighton, EPA Region I.
Concerning Si1resim as a case study.
11. "Summary of Si1resim." Concerning the events and problems related to the site.
17.7 Reference Documents
1. "Volatilization of Organic Compounds from Shallow Phreatic Aquifers,"
June Anne Swallow, Massachusetts Instinite of Technology (August 1983).
2. "Detennination of2,3,7,8-TCDD in Soil and Sediment," EPA Region vn
(September 1983).
3. "Draft - Repon on TCDD Sampling Methods," Daniel J. Harris, EPA Region
VII (December I, 1983). .
. 4. "Assessment of Health Risk from Exposure to Contaminated Soil," John K.
Hawley, New York State Depanment of Health Bureau of Toxic Substance
Assessment (May to, 1985). .
5. "Special Analytical Services," EPA Region IV (October 9, 1986).
6. "Interim Procedures for Estimating Risks Associated with Exposures to
Mixtures of Chlorinated Dibenzo-p-Dioxins and -Dibenzofurans (CDDs and
CDFs)," EPA Headquarters (October 1986).
7. "What Has Gone Wrong?" R. Allan Freeze and John A. Cherry, Ground Water
(July/August 1989). .
8. "Groundwater Contamination: Pump-and- Treat Remediation," Douglas M.
Mackay and John A. Cherry, Environmental Science Technoloey.
Vol. 23 No.6 (1989). .
9. Memorandum from Richard Willey, EPA Region I to Carl DeLoi, EPA Region I
(February 15, 1991). Concerning topics discussed during meeting with John A.
Cherry and EPA Headquarters personnel on February 5, 1991 with attached
meeting attendance list.
10. "Measurement of Hydraulic Conductivity Distributions - A Manual of Practice,"
Fred J. Molz, Oktay Guven, and Joel G. Melville, Auburn University.
11. "The Cone Penetration Test for Environmental Investigations," Tony A. Kiefer,
Technic~ Ltd. .
12. "Risk Assessment for Pentachlorophenol and Dioxin/Furan in Chehalis,
Washington," Panicia C. StOrIn and David Tetta. .
13. 'Detennination of Airborne Volatile Nitrogen Compounds Using Four
Independent Techniques," NUS Corporation.
14. "Assessing Health Risks from Contaminated Soils," Barbara D. Beck, EPA
Region L
17.8 State and Local Technical Records
1.
2.
"Silresim Cleanup" (December 4, 1978 through June 7, 1979).
Memorandum from John J. O'Brien, EPA Region I to William A. Simmons,
Commonwealth of Massachusetts Department of Environmental Quality
Engineering (July 28,1981). Concerning contract for Phases ill of Silresim
cleanup operation.
''Hydrogeologic Investigation," Perkins Jordan, Inc. (February 26, 1982).
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. Page 42
17.8 State and Local Technical Records (cont'd.)
"Remedial Action Study," Perkins Jordan, Inc. (April 27, 1982).
"Remedial Action Study Addendum," Perkins Jordan, Inc. (July 26, 1982).
Comments Dated July 26, 1982 from Stephen U. Lester, Citizen's
Clearinghouse for Hazardous Wastes, Inc. on the February 26, 1982
"Hydrogeological Investigation," and the April 27, 1982 "Remedial Action
Study," Perkins Jordan, Inc.
7. "Preliminary Evaluation of the Silresim Air Monitoring Study," Commonwealth
of Massachusetts Department of Environmental Quality Engineering
(October 13, 1982). .
8. Draft "Field Investigation of Silresim Chemical Waste Site and Surrounding
Neighborhood," TRC Environmental Consultants, Inc. (November 23, 1982).
9. "Addendum - Hydrogeologjc Investigation," Perkins Jordan, Inc.
(March 8, 1983).
10. "Tanner Street Industrial Park, Lowell, Massachusetts," The Geotechnical
Group, Inc. (July 1985). .
18.0 Initial Remedial Measme
4.
5.
6.
18.1 Correspondence
1.
Memorandum from E. Dennis Escher, NUS Corporation to Patrick C. Falvey,
NUS Corporation (March 1, 1983). Concerning Silresim Chemical Corporation
IRM assignment.
Trip Report on a Visit to Silresim Chemical Corporation Site, EP A Region I,
Camp, Dresser & McKee Inc., and NUS Corporation (March 7, 1983).
Concerning development of work plan, demolition, and capping construction
specifications for an IRM.
Memorandum from Health Effects Study Group, EP A Region I to Merrill S.
Hohman, EPA Region I through John R. Moebes, EPA Region I
(April 1, 1983). Concerning the conclusions of the Lowell Air Monitoring
Study conducted March 14, 1983 through March 23,1983.
Letter from Thomas F. McLoughlin, Commonwealth of Massachusetts
Department of Environmental Quality Engineering to Merrill S. Hohman, EP A
Region I (April 15, 1983). Concerning the agreement between EPA Region I
and DEQE regarding future actions at the Silresim site.
Meeting Agenda, EPA Region I (June 13, 1983). Concerning Silresim
Operating Plan meeting.
Letter from Thomas F. McLoughlin for Anthony D. Cortese, Commonwealth of
Massachusetts Department of Environmental Quality Engineering to Paul G. .
Keough, EPA Region I (June 22, 1983). Concerning a credit audit for
cost-sharing under CERCLA.
Telephone Notes Between Larry Giarrizzo, Commonwealth of MaSsachusetts
Department of Environmental Quality Engineering and James Plunkett, NUS
Corporation (June 28, 1983). Concerning state regulations and restrictions
existing in the development of a sedimentation basin in conjunction with
remedial actions.
Memorandum from John F. Hackler, EPA Region I to Silresim Working
Committee (June 30, 1983). Coricerning Draft Operating Plan for the Silresim
Site.
Memorandum from James Plunkett, NUS Corporation to Patrick C. Falvey,
NUS Corporation (June 30, 1983). Concerning utilities potentially affected by
the Silresim Remedial Action. .
2.
3.
4.
5.
6.
7.
8.
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Page 43
18.1 CoITespondence (cont'd.)
10. Memorandum from John Figler, U.S. Department of Health and Human
Services Centers for Disease Control to John R. Moebes, EPA Region I
(July 7,1983). Concerning Centers for Disease Control position on Silresim
with attached: .
A. Draft "Notice to Residents," Barbara H Ikalainen, EPA Region I
(July 1983). Concerning attached summary operating plan.
B. "Summary of Safety Precautions in Operating Plan for Remedial Action at
Silresim Site, Lowell, MA," EPA Region I (July 1983).
11. Memorandum from George D. Gardner, NUS Corporation to Flle
(July 11, 1983). Concerning a meeting with Barbara H. Ikalainen regarding
work plan for the IRM. .
12. Memorandum from John F. Hackler, EPA Region I to Edward Taylor, EPA
Region I (July 13, 1983). Concerning a Request for Analytical Services in
Support of the Initial Remedial Measures to be perfonned at the Silresim
Hazardous Waste Site. .
13. "Notice to Residents," Barbara H. Ikalainen, EPA Region I to Residents
(July 14, 1983). Concerning attached "Summary of Safety Precautions in
Operating Plan for Remedial Action at Silresim Site, Lowell, MA." .
14. Memorandum from P. Goldstein, NUS Corporation to E. Dennis Escher and
R.A. Bums, NUS Corporation (July 25, 1983). Concerning verbal
authorization received for IRM constt'Uction at Silresim.
15. Memorandum from Patrick C. Falvey, NUS Corporation to File.
(August 1, 1983). Concerning a meeting.with Barbara H. Ikalainen, E. Michael
Thomas, and David Pitman, EP A Region I.
16. Memorandum from Barbara H. Ikalainen, EPA Region I to William Kaschak,
EPA Headquarters (August 19, 1983). Concerning approval of NUS
Corporation work plan for the IRM.
17. Letter from Gary F. Smith, NUS Corporation to Mr. Grant, D.T. Grant
Company, Inc. (September 7, 1983) Concerning discrepancies and problem
areas following an inspection of site work.
18. Memorandum from Patrick C. Falvey, NUS Corporation to Mark E. Brickell,
NUS Corporation (September 7, 1983). Concerning meeting with Silresim
subcontractors.
19. Memorandum from Patrick C. Falvey, NUS Corporation to E. Dennis Escher
and Gary F. Smith, NUS Corporation (September 8, 1983). Concerning
hazardous waste fluids collected at Silresim Site.
20. "Conference Report Number 1," C.J. Mabardy Inc. and NUS Corporation
(November 9, 1983). Concerning site progress and personnel safety.
21. "Conference Report Number 2," EPA Region I and NUS Corporation
(November 10, 1983). Concerning site progress. .
22. Meeting Agenda, EPA Region I (November 10, 1983). Concerning subcontract
award, hotline, and IRM progress. .
23. Letter from Patrick C. Falvey, NUS Corporation to Robert Hamel, Colonial Gas
Energy Systems (December 7, 1983). Concerning interference of a 6" gas line
with new sewer line.
24. Memorandum from George D. Gardner, NUS Corporation to E. Dennis Escher,
D. Threlfall, and D.R. Brenneman, NUS Corporation (January 18, 1984).
Concerning a series of meetings at EP A Region I.
25. Memorandum from Patrick C. Falvey, NUS Corporation to P. Goldstein,
E. Dennis Escher, D. Threlfall, George D. Gardner, and W. Bell, NUS
Corporation (January 19, 1984). Concerning dismantling and capping of site,
and shutdown of project.
26. Letter from Patrick C. Falvey, NUS Corporation to Richard T. Leighton, EPA
Region I (March 2, 1984). Concerning attached letter regarding cessation of
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Page 44
18.1 COITespondence (cont'd.)
27. Letter from Patrick C. Falvey, NUS Corporation to Raymond E. Hamwey, C.J.
Mabardy Inc. (March 29,1984). Concerning the fonnal notification to reactivate
construction activities at Si1resim Site.
28. Memorandum from William D. Trimbath, NUS Corporation to File
(May 7, 1984). Concerning status of construction at the site.
29. Letter from William D. Trimbath, NUS Corporation to Richard T. Leighton,
EPA Region I (May 14, 1984). Concerning transmittal of minutes of
May 7, 1984 meeting.
30. Letter from Mark E. Brickell, NUS Corporation to Gino Palmacci,
Massachusetts Bay Transit Authority (July 6,1984). Concerning a request for
permission to use MBT A owned land in Readville, Massachusetts.
31. Memorandum from John George, NUS Corporation to George D. Gardner and
Patrick C. Falvey, NUS Corporation (August 21, 1984). Concerning measures
to prevent erosion of site cap. ,
32. Letter from William D. Trimbath, NUS Corporation to Raymond Hamway, C.J.
Mabardy Inc. (September 25,1984). Concerning calculations of clay compacted
in place at the Si1resim job site.
33. Memorandum from Debra Prybyla, EPA Region I to Richard T. Leighton, EPA
Region I (January 3,1985). Concerning property damages to B & L Used Auto
Parts. ,
,34. Letter from Patrick C. Falvey and Donald Senovich, NUS Corporation to
Richard T. Leighton, EPA Region I (March 21,1985), Concerning the sale of
equipment and tankage stored on James <;J. Grant Company's property 'with
attached "Equipment Inventory List."
35. Letter from Patrick C. Falvey and George Latulippe, NUS Corporation to
Richard T. Leighton, EPA Region I (May 10, 1985). Concerning approval to
proceed with the sale of equipment and tankage.
36. Telephone Notes Between EPA Region I and Marcia 1. Berger, Commonwealth
of Massachusetts Department of Environmental Quality Engineering
(January 29, 1986). Concerning depressions in the cap at Silresim Site.
37. Telephone Notes Between David M. Webster, EPA Region I and Patrick C.
Falvey, NUS Corporation (February 3, 1986). Concerning delegating
cOITeCtion of fence problems to Camp Dresser & McKee or EP A Region I FIT
~ce. .
38. Letter from Patrick C. Falvey, NUS Corporation to David M. Webster, EPA
Region I (February 4, 1986). Concerning transmittal of sample drawing and
specifications for fencing. ,
39. Memorandum from David M. Webster, EPA Region I to File (April 30, 1986).
Concerning a trip report to Silresim Site to inspect fence problem.
40. Memorandum from David ,M. Webster, EPA Region I to File (May 28, 1986).
Concerning emergency action regarding PCB contaminated soil near Silresim
site. ' ,
41. "Engineering, Procurement & Construction Schedule," NUS Corporation.
18.2 Sampling and Analysis Data
1.
2.
"Interim Draft Report Overview," NUS Corporation (March 29, 1983).
Letter from Paul F. Clay and Anthony 1. DeMarco, NUS Corporation to
Thomas Powers" Commonwealth of Massachusetts Department of
Environmental Quality Engineering (May 16, 1983). Concerning attached
Ambient Air Sampling Data.
Soil'and Monitoring Well Samples, NUS Corporation (May 16, 1983 through
July 11, 1984).
Letter from Paul F. Clay, NUS Corporation to Thomas Powers, Commonwealth
of Massachusetts Department of Environmental Quality Engineering
(June 2, 1983). Concerning attached ambient air sampling data.
3.
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18.2 Sampling and Analysis Data (cont'd.)
Page 45
5.
6.
7.
"Ponable Chromatography Analysis," NUS COIporation (June 17, 1983).
"Air Monitoring Data Silresim HWS," NUS COIPOration (June 24, 1983
through July 7, 1983).
Memorandum from John F. Hackler, EPA Region I to Edward Taylor, EPA
Region I with attached sampling maps and plans (July 13, 1983). Concerning a
request for analytical services in suppon of the IRM.
Memorandum from John M. Panaro, NUS Corporation to Richard T. Leighton,
EP A Region I (September 29, 1983). Concerning the final repon of the Silresim
Air Monitoring Project.
18.4 Initial Remedial Measure (IRM) Reports
8.
1.
2.
3.
"Specification for Chain-Link Fence," NUS Corporation (May 26, 1983).
Ooss-Reference: Draft "Remedial Action Operating Plan," EPA Region I
(June 1983) [Filed and cited as entry number 3 in 3.4 Interim Deliverables].
"Silresim Magnetometer Survey," NUS Corporation (February 10, 1984).
18.5 Work Plans and Progress Repons
1. Letter from Thomas R. Sheckells, EPA Headquarters to Noel Urban, U. S. .
Army Corps of Engineers (April 29, 1983). Concerning attached "Technical
Assistance Amendment Form lAG Number 3A425." .
2. Progress Repon, NUS Corporation (June. 17, 1983).
3. Trip Repon on a Visit to the Silresini Site Pertaining to Air Analysis, John M.
Panaro, NUS Corporation (June 22, 1983).
4. Letter from Barbara H. Ikalainen, EPA Region I to George D. Gardner, NUS
Corporation (July 13, 1983). Concerning review of Work Plan dated
June 1983.
5. M~morandum from Barbara H. Ikalainen, EPA Region I to William Kaschak,
EPA Headquarters (August 19, 1983). Concerning approval of NUS
Corporation Work Plan.
6. "Work Plan -Initial Remedial Measures," NUS Corporation (September 1983).
7. Progress Repon, NUS Corporation (October 1983).
8. Work Plan, NUS Corporation (November 15, 1983).
9. Progress Repon, NUS Corporation (November 18, 1983).
10. Progress Repon, NUS Corporation (November 1983). .
11. Trip Repon on a Visit to the Silresim Site, George D. Gardner, NUS
Corporation (December 15, 1983).
. 12. Progress Repon, NUS Corporation (December 1983).
13. Progress Repon, NUS. Corporation (January 11, 1984).
14. Trip Repon on a Visit to the Silresim Site, George D. Gardner, NUS
Corporation (January 19, 1984).
15. Trip Repon on a Visit to Silresim Site, Charles D. Wilder, NUS Corporation
(April 26, 1984) with attached letters of recommendation from Inland Pollution
. Control, Inc.
16. Trip Report on a Visit to Silresim Site, William D. Trimbath, NUS Corporation
(May 17, 1984). .'
17. Trip Repon on a Visit to Silresim Site, William D. Trimbath,NUS Corporation
(May 21, 1984). .
18. Progress Repon, NUS Corporation (May 22,1984).
19. Trip Repon on a Visit to the Silresim Site, William D. Trimbath, NUS
Corporation (May 25, 1984).
20. Trip Repon on a Visit to the Silresim Site, William D. Trimbath, NUS
Corporation (May 29, 1984).
21. Trip Repon on a Visit to the Silresim Site, William D. Trimbath, NUS
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Page 46
18.5 Work Plans and Progress Repons (cont'd.)
22. Progress Repon, NUS Corporation (June 8, 1984).
23. Progress Repon, NUS Corporation (June 14, 19,84).
, 24. Trip Repon on a Visit to the Silresim Site, William D. Trimbath, NUS
Corporation (June 19, 1984).
25. Trip Repon on a Visit to the Silresim Site, William D. Trimbath, NUS
Corporation (July 11, 1984).
26. Progress Repon, NUS Corporation (July 16, 1984).
27. Progress Repon, NUS Corporation (July 26, 1984).
28. Progress Repon, NUS Corporation (August 10, 1984).
29. Progress Repon, NUS Corporation (September 5, 1984).
30. Trip Repon on a Visit to the Silresim Site, William'D. Trimbath, NUS
Corporation (September 9, 1984).
31. Progress Repon, NUS Corporation (September 10, 1984).
32. Trip Repon on a Visit to the Silresim Site, William D. Trimbath, NUS
Corporation (September 19, 1984).
33. Trip Repon on a Visit to the Silresim Site, William D. Triinbath, NUS
Corporation (September 25, 1984). .
34. Trip Repon on a Visit to the Silresim Site, William D. Trimbath, NUS
Corporation (September 25, 1984).
35. Progress Repon, NUS Corporation (October 9, 1984).
36. Progress Repon, NUS Corporation (October 25, 1984).
37. Progress Repon, NUS Corporation (November 5, 1984). ,
38. Trip Repon on a Visit to the Silresim Sit~ William D. Trimbath, NUS
Corporation (November 26~ 1984).
39. Trip Repon on a Visit to the Silresim Site, William D. Trimbath, NUS
Corporation (December 4, 1984).
40. Trip Report on a Visit to the Silresim Site, William D. Trimbath, NUS
Corporation (January 2, 1985). '
41. Trip Repon on a Visit to the Silresim Site, William D. Trimbath, NUS
Corporation (January 4, 1985).
42. Lener from Donald ,Senovich, NUS Corporation to Richard T. Leighton, EPA
Region I (July 22,1985). Concerning Work Assignment AmendmeIit Request.
43. Lener from Dennis P. Gagne, EPA Region I to Donald Senovich, NUS
Corporation (August 12, 1985). Concerning response to Work Assignment
Amendment Request
18.7 Operations and Maintenance Records
1.
Telephone Notes Between Thomas Riley, NUS Corporation and Marcia J. '
Berger, Commonwealth of MassachusettS Depanment of Environmental Quality,
Engineering (June 20, 1985). Concerning catch basin on site cap.
Memorandum from Yee Cho, Commonwealth of Massachusetts Department of
Environmental Quality Engineering to David M. Webster, EPA Region I
(August 19, 1985). Concerning transfer of funding for operations and
maintenance activities.
Memorandum from Marcia J. Berger, Commonwealth of Massachusens
Department of Environmental Quality Engineering to Nancy Bettinger,
Commonwealth of MassachusettS Department of Environmental Quality
Engineering (August 23, 1985). Concerning project manager status for
operation and maintenance activities.
Memorandum from Marcia J. Berger, Commonwealth of Massachusens
Department of Environmental Quality Engineering to Jeff Gould,
Commonwealth of MassachusettS Department of Environmerital Quality
Engineering (November 14, 1985). Concerning proposed operation and
maintenance work at Silresim Site.
2.
3.
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Page 47
18.8 Action Memoranda
1.
Memorandum from William N. Hedeman Jr., EPA Headquaners to Lee M.
Thomas, EPA Region I (June 10, 1983). Concerning a request for authorization
to proceed with implementation of Initial Remedial Measures and completion of a
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Section II
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. Page 48
GUIDANCE DOCUMENTS
EPA guidance documents may be reviewed at EPA Region I, Boston, Massachusetts.
General EP A Guidance Documents
1. U.S. Environmental Protection Agency. Office of Research and Development. Municipal
Environmental Research Laboratory. Carbon Ads01:ption Isothenns for Toxic Or~anics
(EPA-600/8-80-023), April 1980.
2. U.S. Environmental Protection Agency. Office of Water and Waste Management Evaluatin~
Cover Systems for Solid and Hazardous Waste, 1980. .
3. U.S. Environmental Protection Agency. Office of Research and Development Municipal
Environmental Research Laboratory. Handbook for EvaJuating Remedial Action Technology
Plans (EPA-600/2-83-076), August 1983. .
4. U.S. Environmental Protection Agency. Office of Ground-Water Protection. Ground-Water
Protection Strategy, August 1984.
5. U.S. Environmental Protection Agency. Office of Solid Waste and Emergency Response,
Office of Emergency and Remedial Response, and Office of Research and Development.
Review orIn-Place Treatment Techniques for Contaminated Surface Soils - Volume 1:
Technical Evaluation (EPA-540/2-84-003a), September.1984.
6. "Guidelines Establishing Test Procedures for the Analysis of Pollutants Under the Clean Water
Act; Final Rule and Interim Final Rule and Proposed Rule" (40 CFR Part 136), Federal
Reiister, October 26, 1984.
7. U.S. Environmental Protection Agency. Office of Emergency and Remedial Response.
Hazardous Response Suppon Division. Standard Qperatin~ Safety Guides. November 1984.
8. U.S. Environmental Protection Agency. Office of Research and Development Environmental
Research Laboratory. EPA Guide for Minimizing the Adverse Environmental Effects of
. Cleanup of Uncontrolled Hazardous Waste Sites, (EPA-600/8-85/008), June 1985.
9. U.S. Environmental Protection Agency. Office of Solid Waste and Emergency Response.
Guidance on Feasibility Studies under CERCLA (Comprehensive Environmental Res.ponse.
Compensation. and Liability Act) (EP N540/G-85/003, OSWER Directive 9355.0-05C),
June 1985-.
10. Memorandum from Gene Lucero to the U.S. Environmental Protection Agency, .
August 28, 1985 (discussing community relations at Superfund Enforcement sites).
11. U.S. Environmental Protection Agency. Office of. Waste Programs Enforcement
The Endangerment Assessment Handbook, August 1985.
12. U.S. Environmental Protection Agency. Office of Waste Programs Enforcement. Toxicology
Handbook, August 1985.2. Covers for Uncontrolled Hazardous Waste Sites,
September 1985.
13. U.S. Department of Health and Human Services. National Institute for Occupational Safety
and Health, and Occupational Safety and Health Administration. Occupational Safety and
Hea1th Guidance Manual for Hazardous Waste Site Activities, October 1985.
14. U.S. Environmental Protection Agency. Office of Emergency and Remedial Response.
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Page 49
15. U.S. Environmental Protection Agency. Hazardous Waste Engineering Research Laboratory.
Handbook: Remedial Action at Waste Di~osal Sites (Revised) (EPA/625/6-85J006),
October 1985. '.
16. "National Oil and Hazardous Substances Pollution Contingency Plan," Code of FederaI
Re~lations (Title 40, Pan 300), 1985.
17. U.S. Environmental Protection Agency. Office of Emergency and Remedial Response.
Community Relations in Superfund: A Handbook (Interim Version) (EPA/HW-6, OSWER
Directive 9230.0-3A), March 1986.
18. U.S. Environmental Protection Agency. Office of Health and Environmental Assessment
Develo.pment of Advisory Levels for Polychlorinated Biphenyls (PCBs) Cleanup
(OHEA-E-187), May 1986.
19. U.S. Environmental Protection Agency. Hazardous Waste Engineering Research Laboratory.
Handbook for Stabilization/Solidification of Hazardous Waste (EPA/54012-861OO1),
June 1986.
20. U.S. Environmental Protection Agency. Office of Research and Development Hazardous
Waste Engineering Research Laboratory. Treatment Technoloe;y Briefs: Alternatives to
Hazardous Waste Landfills (EPA/600/8-86/017), July 1986.
21. U.S. Environmental Protection Agency. Office of Emergency and Remedial Response. DJ:afi
Guidance on Remedial Actions for Contaminated Groundwater at Sl1perfund Sites (OSWER
Directive 9283.1-2), September 20, 1986. -
22. U.S. Environmental Protection Agency. Office of Solid Waste and ~mergency Response and
Office of Emergency and Remedial Response. Mobile Treatment Technolo~es for Superfund
Wastes (EPA 54012-86/003 (f), September 1986.
23. U.S. Environmental Protection Agency. Comprehensive Environmental Re~onse.
Compensation. and Liability Act of 1980, as amended October 17,1986.
24. "Interim Procedures for Estimating Risks Associated with Exposures to Mixtures of
Chlorinated Dibenzo - p - Dioxins and Dibenzofurans (CDDs and CDFs)," EPA Region I,
October 1986. .
25. U.S. Environmental Protection Agency. Office of Emergency and Remedial Response.
Draft Guidance on Remedial Actions for Contaminated GroundWater at Superfund Sites
(OSWER Directive 9283.1-2), October 1986.
26. U.S. Environmental Protection Agency. Office of Emergency and Remedial Response.
Sl1perfund Public Health Evaluation Manual (OSWER Directive 9285.4-01), November 1986.
27. U.S. Environmental Protection Agency. Office of Solid Waste and Emergency Response.
Interim Guidance on Sl1perfund Selection of Remedy (OSWER Directive 9355.0-19),
December 24, 1986.
28. U.s. EnVironmental Protection Agency. Office of Research and Development Hazardous
Waste Engineering Research Laboratory. TechnoloiY Briefs: Data Requirements for Selectini
Remedial Action Technoloey (EPA/600/2-87/OO1), January 1987.
29. U.S. Environmental Protectfon Agency. Office of Solid Waste and Emergency Response.
Data Quality Objectives for Remedial Re~onse Activities: Develo.pment Process
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Page 50
30. "PCB Spill Oeanup Policy" (40 CFR Pan 761). Volume 52. Number 63. April 2. 1987.
31. Letter from Lee M. Thomas to James J. Florio. Chairman. Subcommittee on Consumer
Protection and Competitiveness. Committee on Energy and Commerce. U.S. House of
Representatives, May 21, 1987 (discussing EPA's implementation of the Superfund
Amendments and Reauthorization Act of 1986).
32. Memorandum from J. Winston Porter to Addressees ("Regional Administrators, Regions I-X;
Regional Counsel, Regions I-X; Director. Waste Management Division, Regions I, IV. V,
Vn,and VIn; Director, Emergency and Remedial Response Division, Region ll; Director,
Hazardous Waste Management Division, Regions ill and VI; Director, Toxics and Waste
Management Division, Region IX; Director, Hazardous Waste Division. Region X;
Environmental Services Division Directors, Region I, VI, and Vil"), July 9, 1987 (discussing
interim guidance on compliance with applicable or relevant and appropriate requirements).
33. U.S. Environmental Protection Agency. Office of Solid waSte and Emergency Response.
Alternate Concentration Limits Guidance (OSWER Directive 9481.00-6C,
EPN530-SW-87-017) July 1987.
34. U.S. Environmental Protection Agency. Office of Health and Environmental Assessment
A Compendium of TechnolQeies ~ in the Treatment of Hazardous Waste
(EPN625/8-87/014), September 1987. .
35. U.S. Environmental Protection Agency. Office of Emergency and Remedial Response.
A Cornpendium of Superfund FieJd Operations Methods (EPN5401P-87/001, OSWER
Directive 9355.0-14), December 1987.
36. Record of Decision, Keefe Environmental Services NPL Site, Epping, New Hampshire, EPA
Region I. Boston. Massachusetts. March 21, 1988.
37. U.S. Environmental Protection Agency. Office of Solid Waste and Emergency Response and
Office of Emergency and Remedial Response. Draft Guidance on CERCLA Compliance with
Other Laws Manual (OSWER Directive 9234.1-01), May 6,1988.
38. U.S. Environmental Protection Agency. Office of Emergency and Remedial Response.
Superfund Automated Records of Decision System (RODs) User Manual
(EPN540/G-87/005), August 1988.
39. U.S. Environmental Protection Agency. Office of Emergency and Remedial Response.
CERCLA (Com,prehensive Environmental Res.ponse. Compensation. and Liability Act)
Com,pliance with Other Laws Manual (EPN540/G-891OO6, OSWER Directive 9234.1-01),
August 1988. . ..
40. . Public Health Risk Evaluation Database c'PHRED) User's Manual (two diskettes containing the
dBase ill+ system are included), September 16,1988.
41. U.S. Environmental Protection A~ncy. Office of Emergency and Remedial Response.
Technolo~ Screenin~ Guide for Treatment of CERCLA (Comprehensive Environmental
Re!;ponse. Compensation. and Liability Act) Soils and Slud~es (BPA 54012-88/004), .
September 1988.
42. U.S. Environmental Protection Agency. Office of Emergency and Remedial Response.
Guidance for Conductin~ Remedial Investigations and Feasibility Studies Under CERCLA
(Com,prehensive Environmental Res.ponse. Compensation. and Liability Act) (Interim Finan
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Page 51
43. Memorandum from Michael Callahan, U.S. Environmental Protection Agency Office of Health
and Environmental Assessment to Henry L. Longest, U.S. Environmental Protection Agency
Office of Emergency and Remedial Response, December 6, 1988 (discussing update of PCB
clean-up levels).
44. U.S. Environmental Protection Agency. Office of Emergency and Remedial Response.
Guidance on Remedial Actions for Contaminated Ground Water at Superfund Sites
(EPN540/G-88/003, OSWER Directive 9283.1-2), December 1988.
45. U.S. Environmental Protection Agency. Risk Reduction Engineering Laboratory. Technolo~
Evaluation Repon SITE Program Demonstration Test. HAZCON Solidification. Dou~lassville.
Pennsylvania. Volume I. (EPN540/5-89-001a), February 1989.
46. Memorandum from Bill Hanson, U.S. Environmental Protection Agency Site Policy and
Guidance Branch to Regional Superfund Branch Chiefs, Regions I-X, April 7, 1989
(discussing PCB Contamination at Superfund Sites).
47. Memorandum from Jonathan Z. Cannon to Regional Administrators, Regions I-X (OSWER
Directive 9347.1-0), April 17, 1989 (discussing policy for Superfund compliance with the
RCRA land disposal restrictions). .
48. U.S. Environmental Protection Agency. Risk Reduction Engineering Laboratory. Technolo~
Evaluation Re.pon: SITE Program Demonstration Test TeITa Vac In Situ Vacuum Extraction
System Groveland. Massachusetts. Volume I (EPN540(5-89/003a), April 1989.
49. U.S. Environmental Protection Agency. Office of Solid Waste and Emergency Response.
ARARs O's & A's (OERR 9234.2-01FS), May 1989.
50. U.S. Environmental Protection Agency. Office of Solid Waste and Emergency Response.
Land Di~osal Restrictions: Summary of ReQuirements. June 1989.
51. U.S. Environmental Protection Agency, Region 1. SuwlementaI Risk Assessment Guidance
for the Superfund Pro~m, (EPA 901/5-89-(01), June 1989.
52.. Memorandum from Louis F. Gitto, U.S. Environmental Protection Agency Air, Pesticides,
and Toxic Management Division, Region I to Merrill S. Hohman, Waste Management
Division, Region I (OSWER Directive 9355.0-28), July 12,1989 (discussing air stripper
control guidance).
53. U.S. Environmental Protection Agency. Office of Solid Waste and Emergency Response.
Risk Assessment Guidance for Superfund. Human Health Evaluation Manual Pan A,
July 1989.
54. U.S. Environmental Protection Agency. Office of Solid Waste and Emergency Response.
Superfund LDR Guide #1. Overview of RCRA Land Di~sal Restrictions t1...DRs) (OSWER
Directive 9347.3-01FS), July 1989. .
55. U.S. Environmental Protection Agency. Office of Solid Waste and Emergency Response.
Superfund LDR Guide #2. Complyin~ With the California List Restrictions Under Land
Disposal Restrictions (LDRs) (OSWER Directive 9347.3-02FS), July 1989.
56. U.S. Environmental Protection Agency. Office of Solid Waste and Emergency Response.
Superfund LDR Guide #3. Treatment Standards and Minimum Technolo~ ReQuirements
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. Page 52
57. U.S. Environmental Protection Agency. Office of Solid Waste and Emergency Response.
Superfund LDR Guide #4. Comptyini With the Hammer Restrictions Under Land Di~posal
Restrictions (LDRs) (OSWER Directive: 9347.3-04FS). July 1989.
58. U.S. Environmental Protection Agency. Office of Solid Waste and Emergency Response.
Superfund LDR Guide #5. Determinini When Land Disposal Restrictions tLDRs) Are
Applicable to CERCLA Response Actions. (OSWER Directive: 9347.3-05FS). July 1989.
59. U.S. Environmental Protection Agency. Office of Solid Waste and Emergency Response.
SupeIfund LDR Guide #6A. Obtainini a Soil and Debris Treatabi1i(y Variance for Remedial
Actions. (OSWER Directive: 9347.3-06FS). July 1989.
60. U.S. Environmental Protection Agency. Office of Emergency and Remedial Response.
Interim Final Guidance on Preparini SupeIfund Decision Documents (OSWER Directive
9355.3-02). July 1989.
61. "R-CRA Regulations," Code of Federal Reilliations (Title 40. Pan 264)~ July 1989.
62. U.S. Environmental Protection Agency. Office of Solid Waste and Emergency Response.
CERCLA (Comprehensive Environmental Res.ponse. Compensation. and Whility Act) .
Compliance with Other Laws Manual - Pan IT: Clean Air Act and Other Environmental Statutes
and State Reqpirements (EPN540/G-89/009. OSWER Directive 9234.1-02). August 1989.
63. Memorandum from Henry L. Longest. U.S. Environmental Protection Agency Office of
Emergency and Remedial Response to Regional Waste Management Division Directors
(OSWER Directive 9355.4-02) September 7. 1989 (discussing soil lead clean-up levels).
64. Record of Decision, So. Municipal Water Supply Well NPL Site, Petersborough. New
Hampshire. EPA Region I, Boston. Massachusetts. September 2'. 1989.
65. Record of Decision. Kellogg-Deering Well Field NPL Site. Norwalk. Connecticut, EPA
Region I. Boston, Massachusetts. September 29. 1989.
66. U.S. Environmental Protection Agency. Office of Solid Waste and Emergency Response.
CERCLA Compliance with Other Laws Manual - RCRA ARARs: Focus and Closure
Requirements (OSWER Directive 9234.2-04). October 1989.
67. U~S. Environmental Protection Agency. Office of Solid Waste and Emergency Response.
Ground Water Issue - Performance Evaluation of Pump-and- Treat Remedi.miQm
(EPN540/4-89/005). October 1989. .
69. U.S. Environmental Protection Agency. Office of Solid Waste and Emergency Response.
The Feasibility Study: Development and Screenin!: of Remedial Action A~tematives
(OSWER Directive 9355.3-0IFS3). November 1989.
70. U.S. Environmental Protection Agency. Office of Solid Waste and Emergency Response.
CERCLA Compliance with State Reqpirements. (OSWER Directive 9234.2-05FS).
December 1989.
-
71. U.S. Environmental Protection Agency. Office of Solid Waste and Emergency Response.
Superfund LDR Guide #7. Determinini When Land Dis.posal Restrictions (LDRs) are Relevant
and Appropriate to CERCLA Response Actions. (OSWER Directive 9347.3-08FS).
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Page 53
72. U.S. Environmental Protection Agency. Risk Reduction Engineering Laboratory. Technolo~
Evaluation Re.pon: SITE Pro~m Demonstration of the rntrox International Ultraviolet
Radiation/Oxidation Technolo~ (EPN540/5-891012), January 1990.
73. U.S. Environmental Protection Agency. Risk Reduction Engineering Laboratory. Handbook
on In Situ Treatment of Hazardous Waste-Contaminated Soils (EPA/54012-901OO2),
January 1990.
74. U.S. Environmental Protection Agency. Office of Solid Waste and Emergency Response.
CERCLA Compliance with Other Laws Manual - CERCLA Compliance with the CW A and
SDWA (OSWER Directive 9234.2-06/FS), February 1990.
75. "National Oil and Hazardous Substances Pollution Contingency Plan," Federal Re~ster
(Vol. 55, No. 46), March 8, 1990, p. 8666.
76. 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.
77. "A Field Evaluation of the UV/Oxidation Technology to Treat Contaminated Groundwater,"
HMC, March/April 1990.
78. U.S. Environmental Protection Agency. Office of Solid Waste and Emergency Response.
CERCLA Compliance with Other Laws Manual - Summary of Part n - CAA. TSCA. and
Other Statutes (OSWER Directive 9234.2-07/FS), April 1990.
79. Memorandum from Henry L. Longest and Bruce Diamond, U.S. Environmental Protection
Agency Office of Solid Waste and Emergency Response to Regional Waste Management
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80. "Protection of Environment," Code of Federal Re~lations (Title 40, Pans 190-299), Revised
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81. U.S. Environmental Protection Agency. Office of Emergency and Remedial Response.
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82. U.S. Environmental Protection Agency. Office of Solid Waste and Emergency Response.
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83. U.S. Environmental Protection Agency. Risk Reduction Engineering Laboratory. Guide for
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84. Memorandum from Timothy Fields Jr., U.S. Environmental Protection Agency Office of .
Emergency and Remedial Response to Regional Waste. Management Division Directors
(OSWER Directive 9285.6-03) March 25. 1991 (discussing standard default ex~osure factors).
85. Memorandum from Timothy Fields Jr., U.S. Environmental Protection Agency Office of
Emergency and Remedial Resp(;>nse to Regional Waste Management Division Directors
March 27, 1991 (discussing guidance on key terms used in Superfund).
86. U.S. Environmental Protection Agency. Office of Solid Waste and Emergency Response..
Guide to Developin~ SUl'erfund No Action. Interim Action. and Continiency Remedy RODs
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Page 54
87. U.S. Environmental Protection Agency. Office of Solid Waste and Emergency Response.
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88. U.S. Environmental Protection Agency. Office of Solid Waste and Emergency Response.
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89. U.S. Environmental Protection Agency. Office of Solid Waste and Emergency Response.
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90. U.S. Environmental Protection Agency. Hazardous Waste Engineering Research Laboratory.
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91. U.S. Environmental Protection Agency. Impact of the RCRA Land Di~sal Restrictions of
Superfund Response Actions in Superfund.
. .
92. U.S. Environmental Protection Agency. Hazardous Waste Engineering Research Laboratory.
Ap.plication ofLow-Tem.perature Thermal Technoloey to CERCLA (Comprehensive
Environmental Re~nse. Compensation. and Liabi1i~ Act) Soils.
93. U.S. Environmental Protection Agency. Office of Emergency and Remedial Response.
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